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Programme consultation responses to the Independent Water Commission (aka the Cunliffe Review) and Land Use Framework

Ribble Rivers Trust - Tawd Valley Wetland

In April 2025 the MNbS Programme submitted consultation responses to both the Independent Water Commission (aka the Cunliffe Review) and Land Use Framework. Our responses to both are very similar (not quite identical!)

Because of the inherent overlap between Nature-based Solutions and the way that we plan and use our landscapes. Our responses focus on the multiple benefits of Nature-based Solutions and how they have a key role in helping to address the increasing stresses on the water environment from climate change, population growth, societal pressures such as affordability, ageing infrastructure and the biodiversity crisis.

We have put forward five key recommendations into these important consultations:

1. Set clear, long term strategic direction. We want NbS embed into a legally binding, cross sectoral national strategy (including water, land use, agriculture, energy and others) with integrated, measurable and aligned targets, which should be referenced in every major plan and strategy across different sectors. There should also be better coordinated cross-border regulation.

2. Improve regulatory frameworks to enable outcome-based, flexible delivery We want to shift prescriptive outputs to outcomes and build in TOTEX incentives that account for the entire lifecycle of NbS assets, including long-term operation and maintenance.

3. Integrate regional spatial planning and governance We want to establish (or strengthen) well-funded regional governance, with clearly mandated roles and responsibilities, to align multi-sectoral plans across catchments.
and hold accountable multi-stakeholder catchment partnerships represent a unified vision and voice at local scale.

4. Secure sustainable, long-term funding We want a model that guarantees predictable, long term multi-sectoral funding of NbS schemes, accounting for lifecycle investment.

5. Adopt and deploy a Common Value Framework We want a mandated use of a consistent valuation framework based on multiple capitals, such as our Common Value Framework, which quantifies and transparently reports on the environmental, social and economic benefits of NbS.

If (maybe I should be more optimistic and say when?!) these recommendations are adopted, they will helpf resolve the fragmented planning, misaligned incentives and short-termism that currently hamper the mainstream adoption of NbS.

Our submissions can be downloaded below (as a single document).

Consultation Response