I want to…

respond to the water commission

Make your voice heard with our no-nonsense, question-by-question guidance for responding to the Water Commission’s Call For Evidence.

The Water Commission

Call for Evidence

is now closed

Water Commission Timeline

🗓 Call for Evidence Deadline: The Call for Evidence closes on 23rd April. Responses must be submitted before this deadline to be counted.

📱 When Will We See Results? After submissions are reviewed, the Commission will make a series of recommendations to the UK and Welsh governments in June 2025.

💬 What Happens Next? Based on public feedback, the Commission will shape recommendations for the Government, with a new Water Bill expected to be announced this summer.

What is the Water Commission

Call for Evidence?

Chronic underinvestment, weak regulation, and reckless profiteering have left our rivers infested with ‘poo-llution.’ The Independent Water Commission, launched in response to public pressure after the March for Clean Water, is undertaking a much needed review of this failing water sector. It is now seeking public views in a Call for Evidence – a crucial chance to demand long-overdue reform.

We’re calling for a complete overhaul of Ofwat and the Environment Agency, restoring their funding and enforcement powers. Whether through nationalisation, not-for-profit, or one of the many alternative models our European neighbours are using, one thing is clear – private ownership must end.

See our video explainer narrated by the fantastic Deborah Meaden below:

Water: A Story of Hope

Launch the video

The Commission will deliver recommendations to the Government, shaping future legislation, the management of the water sector, and the fate of our rivers for decades to come.

In the ‘Call for Evidence‘ – effectively a public consultation, the commission wants to find out what you think about the water system. This is a chance to influence the future of our failing water system, and demand a system that ends pollution for profit.

Check out our guidance below for how to make your voice heard.

River action’s position on water sector reform

The current water system is broken. The privatisation of the water industry has failed: it has led to chronic underinvestment, rising bills, and widespread pollution. We believe that wholly private ownership structures should end.

Instead, we need public-interest models that put people and nature first. That means:

Ending exclusive private ownership.
Creating public or not-for-profit alternatives.
Bringing in democratic oversight at local, regional and national levels.

Imagine if you – the bill payer – had a seat at the table. If local councils, environmental voices, and community representatives were on company boards, steering decisions and holding executives to account. Imagine if the Government took responsibility for water company planning, financing and operations through local, regional and national municipal oversight to make sure water quality, human health, abundant nature and fair pricing were top priorities. That’s what real accountability looks like.

This crisis has been enabled by regulatory failure. We are calling for a full overhaul of Ofwat (the financial regulator) and the Environment Agency (the environmental regulator), restoring funding and enforcement powers so the law is upheld and companies act in the public and environmental interest.

Ultimately, private ownership structures must end. There are different models that could deliver this:

Water companies are brought into public ownership and run by the government in the public interest.

Local authorities run water services directly, keeping profits local and decisions close to communities.

Publicly owned regional bodies manage water at catchment scale, coordinating investment, planning and pollution control.

Companies reinvest all profits into the system, with no shareholders/bondholders, learning from the flaws of the DƔr Cymru/Welsh Water model. 

Known as community interest companies in the UK, this model means companies are legally required to deliver social and environmental good, with conditional and capped profits and assets protected.

Approaching The
Call for Evidence

This Call for Evidence consists of 73 questions, covering topics such as regulation, environmental protections, and ownership. You do not need to answer every question – the majority of questions are optional, so to help we’ve separated the questions into sections below so you can answer those most relevant to you.

We’ve provided guidance for each and every question, to help explain the question and highlight relevant information to inform your response. Whilst our guidance aligns with our own advocacy efforts – focusing on stronger regulation, corporate accountability, and ending pollution for profit – we strongly encourage you to put your own views forward.

Copied-and-pasted answers will likely be removed, so it’s crucial to speak in your own voice. Personal views, stories, and ambitions for change are what we want to capture, using our guidance to ensure your response is informed and impactful. Whether you’re a a citizen scientist, a swimmer, or simply someone who is fighting for their local river, your voice will make a real difference.

Find the questions for you

There are 70 questions, many of which are complex and technical. You are not expected to answer everything—focus on the sections that matter most to you. You can save your progress and come back to it later if you need to—there’s no pressure to complete it all in one go.

To help, we’ve highlighted the essential questions to answer, and questions which particular groups might be interested in.

Alternatively, you can see our full guidance for every question below. Simply answer the questions you want, and make your voice heard. Open the response form by clicking the green button below:

If you have less time

For those with limited time, these are the higher priority questions we’d suggest you focus on.

If you have more time

Just higher and medium priority questions we believe most campaigners will have an opinion on.

For Citizen Scientists

Just questions we believe citizen scientists will have a view on and high priority questions.

For Recreational Water Users

Just questions we think will be of interest to sports clubs, groups, or individuals who use the river, as well as high priority questions.

Water Industry Reform

Just questions for those interested in the water sector, its management and reform, as well as high priority questions.

Environmental Management

Questions related to environmental management, nature-based solutions, and catchment-based approaches, as well as high priority questions.

If you don’t identify with the above groups, or want to keep our entire guidance available while you go through the Call for Evidence, please find the full questions guidance below.

Full Guidance: All Questions

Q1-9

Your details

Compulsory for everyone.

The first 9 questions are for your personal and contact details.

Q10-11

Water System Outcomes Top Priorities

High Priority.

For everyone.

This is a key question that will help shape the future of water in the UK.

Explanation (outline the question)
You’ll see a list of options. For each question (10a–10c), you’ll be asked to select one priority. Together, these show what you think the system should focus on most.

Two of the options might look similar – here’s how they differ:

  • “Water bodies being safe for swimming and other recreational uses (e.g. kayaking, paddleboarding)”
    Focuses on pollution controls. This is about stopping sewage and farm runoff so people can safely enter the water.
  • “Recreational access to ‘blue’ (water body) spaces”
    Focuses on rights and access. This is about ensuring the public can get to rivers, lakes and coasts in the first place – it’s about opening up blue spaces to everyone.

Guidance

  • Pick the issues you care most about – this could include public ownership, clean rivers, access, nature recovery, or affordability.
  • You don’t need technical knowledge – just think about what you want the future of water to look like.

Don’t overthink it. There are no right or wrong answers here – this question is about your values.

There is no Question 11 in the Call for Evidence – it skips from Question 10c to Question 12. You haven’t missed anything!

Q12-16

Management of Water

Medium Priority.

Most relevant to anyone interested in:

agricultural pollution

a more democratic water system

local or regional decision-making

Explanation
These questions ask who should be responsible for managing water, how decisions should be made, and whether the current system is working.

Right now, water management in England is fragmented. Many different organisations – from government departments and regulators to water companies and local authorities – all play a role, but often don’t coordinate well. This leads to slow action, weak enforcement, and a lack of accountability when things go wrong.

Example from elsewhere:
In Austria, Sweden, and Denmark, sewage systems are not only publicly owned but also locally managed, granting communities significant decision-making powers. Austria’s “Water Sanctuary” concept exemplifies the cultural and legal integration of environmental stewardship at a local level, while Sweden and Denmark similarly empower municipalities to manage wastewater effectively.

Similar needs in the UK:
In the UK, we are currently taking legal action against Shropshire Council for approving a new intensive poultry unit in the River Severn catchment. The case aims to prevent the kind of widespread ecological damage seen in the neighbouring River Wye, caused by cumulative pollution from agriculture. If successful, this legal challenge could set a national precedent, forcing local authorities to properly consider the combined environmental impact of developments before granting approval. Like Switzerland, the UK needs stronger protections, more joined-up governance, and a greater focus on long-term ecological health.

Explanation

This question is asking: Who should decide what really matters in how our water system is run? Should it be:

  • The UK Government?
  • Local authorities or mayors?
  • Independent regulators (e.g. Ofwat or the Environment Agency)?
  • Water companies?
  • Communities that use and care for local rivers?
  • Everyone who pays a water bill?

It’s about who sets the overall direction—whether that’s reducing pollution, tackling leaks, improving water quality, or keeping bills affordable.

Guidance

We believe communities and the public must have a much stronger voice in setting priorities. People who live near rivers often understand local challenges best—from pollution to drought and flooding. Decision-making must reflect the knowledge and values of those most affected.

We must move away from a system where water companies set and monitor their own targets, and toward a more democratic model where the public interest—not shareholder value—is what counts.

We support a blended approach that combines national strategy with strong local and regional leadership. This could include local authorities, catchment partnerships, and mayors sitting on company boards alongside environmental and public health voices.

International models show this is possible:

In Paris, remunicipalisation cut bills, saved €35 million in the first year, and brought citizens into decision-making.

In Austria, water systems are publicly managed with transparency and local access to water quality data.

In Sweden and Denmark, wastewater systems are municipally owned with high public engagement.

In Scotland, Scottish Water is publicly owned, reinvests all profits, and is accountable to government and parliament.

Imagine if you—the bill payer—alongside local councils and river defenders—had a real say in setting the future direction of our water system. That’s what meaningful accountability looks like.

Explanation

This question is asking whether the way we organise responsibility for water needs to change. Right now, too many different bodies are involved, often with overlapping or unclear roles. This leads to:

  • Delays in tackling pollution and leaks
  • Confusion over who’s responsible
  • Weak enforcement and accountability
  • Ineffective use of public money

As climate change brings more droughts, floods and pollution incidents, we need a water system that can act quickly and decisively—not one bogged down in bureaucracy and blame-shifting.

Guidance

We recommend answering “Yes – changes are needed.”

The current system is fragmented and slow, with too many players and not enough clarity. What’s needed is:

  • Clearer lines of responsibility
  • Joined-up decision-making across catchments
  • Empowered public bodies with teeth
  • Stronger regional leadership and democratic oversight

One promising solution is to create Regional Water Authorities—public bodies that have real powers to plan, coordinate and enforce water policy across whole catchments. These would reflect local needs, bring together different agencies, and include local representation in decision-making.

As the joint submission notes, many European countries already do this well:

  • In France, Paris now runs its water system through a public body with citizen and environmental representation.
  • In Austria, local authorities manage water directly, supported by strong public transparency.
  • In Scotland, publicly owned Scottish Water delivers consistently high service and reinvests in long-term infrastructure.

We believe roles and responsibilities should be reshaped to centre public, local and regional voices, rather than leaving decisions to distant regulators or private companies.

Imagine a future where water decisions are made by people who know the rivers, rely on them, and care about their future—not just their financial return.

Explanation
This question is asking: Should water management be more joined-up?
At the moment, different sectors – like water companies, regulators, farmers, local authorities and developers – often operate in isolation. This leads to:

  • Pollution sources being missed because regulators don’t coordinate.
  • Flood, drought, sewage and water supply being handled separately.
  • Councils and communities being excluded from major water decisions that affect them.
  • Management is fragmented and follows human boundaries, rather than river catchments.
  • This siloed approach also makes it harder to invest in nature-based solutions – like wetlands, buffer strips or natural flood defences – that deliver multiple benefits.

Guidance
We strongly recommend selecting options that support more coordination, local involvement, and joined-up planning. The system will only work if it brings together nature, water, and land use with real accountability and democratic input.

We suggest prioritising these options:

  • A regional or catchment-scale systems planning authority – to allow local planning based on how rivers and landscapes actually work.
  • Aligning water management with democratic structures – so decision-making reflects local voices.
  • Aligning water management planning with other plans – like flood risk and nature recovery, to protect communities and the environment.
  • Pooling together existing funding streams at a spatial level – so investment isn’t wasted in separate silos.
  • Changes to how regulators regulate sectors involved in the water system – to make sure enforcement is coordinated and effective.

Options to avoid:

  • No changes are needed – the current fragmented system is part of the problem.
  • Don’t know – if in doubt, go with the options above that support integration, local knowledge and proper oversight.

Explanation
This question is asking: What are the barriers to better water spending?
The biggest issue isn’t a lack of money – it’s how it’s being spent. Despite rising bills, water companies continue to pay out billions in dividends and executive pay while neglecting vital investment in infrastructure, pollution control, and leak repairs. 

Guidance
You can choose up to three options. We’ve grouped them below to help clarify which best supports community-led, sustainable change – and which could be used to deflect responsibility.

We suggest prioritising these options:

  • Unclear targets and objectives – Water companies often lack binding commitments to reinvest in infrastructure and protect the environment.
  • Limitations of alignment of existing funding pots – Funding is split across sectors without coordination, meaning money is wasted or poorly used.
  • The scale at which actions are developed – Spending plans are often too top-down or generic, ignoring local context and needs.
  • Barriers to partnership schemes – Partnerships across communities, councils, and others can work well – but need better support and funding to succeed.

Options to avoid:

  • Limitations of evidence on costs and benefits – This could be used to delay action or weaken environmental rules.
  • Planning timelines – A valid issue, but in this context it could be used to excuse inaction.

The monitoring and classification system – Monitoring is essential, but this option might be used to shift blame rather than address root problems.

Explanation
This question is asking: Should water governance follow natural boundaries or political ones?
Currently, water management is tied to political regions – meaning different councils, regulators and industries may all have separate policies for the same river. But rivers don’t stop at county lines.

As seen in the case of Shropshire and the River Wye, pollution in one area can cause devastating ecological damage downstream. We need a system that works with nature – not against it – by managing whole river catchments as one connected system.

Guidance
We strongly recommend choosing an approach based on hydrological boundaries, such as river catchments or basin districts. This ensures decisions are made for the whole river system, from source to sea, supporting healthier ecosystems and more joined-up action.

Recommended option:

  • Hydrological boundaries (e.g., water catchments, river basin districts) – This allows for truly catchment-based governance, better environmental outcomes, and collaborative partnerships.

Options to avoid:

  • Local government boundaries – Political lines often divide rivers and break up responsibility, making coordination harder.
  • Don’t know – If in doubt, hydrological boundaries are the clearest path forward.
  • [For Wales only] Welsh government boundaries – We understand that in Wales, you may want to emphasise Welsh governance. However, rivers like the Wye cross national borders and are affected by pollution on both sides. 

Q17-18

Management of the Water Environment

Medium Priority.

Most relevant to anyone who cares about the long-term health of rivers, lakes, and groundwater – especially campaigners, swimmers, anglers, environmental groups, and local communities.

These questions are about the legal standards that protect our rivers – and whether they should be updated, replaced, or strengthened after 2027.

Currently, the Water Framework Directive (WFD) requires governments to aim for ‘Good Ecological Status’ for all rivers, lakes and groundwater. It’s one of the few tools we have for holding polluters to account – but most rivers are still failing due to sewage and agricultural pollution.

After 2027, the rules could be weakened or strengthened. Weakened standards mean fewer obligations for polluters. Strengthened standards could lead to better monitoring, tougher enforcement, and clear targets for river recovery.

The WFD also supports other protections like the Bathing Water and Urban Waste Water Treatment Regulations, so any change could have wide implications.

It currently allows economic arguments to justify delaying or avoiding clean-up – a loophole that has let polluters off the hook and must be reformed.

With no published plan for what happens after 2027, this consultation is a crucial chance to demand stronger protections.

Explanation
This question is asking what changes (if any) should be made to the legal framework that protects rivers, lakes, and groundwater after 2027. The WFD currently sets the standard of achieving Good Ecological Status for all water bodies by 2027. It has been one of the strongest legal tools for holding polluters to account.

However, with only two years left, most rivers are not meeting this target. This raises the question: should the WFD be improved – or scrapped and replaced?

The way this question is answered could influence whether the government chooses to strengthen legal protections and enforcement – or weaken them to suit polluters.

Guidance

We suggest supporting the following options:

  • The targets and objectives – Keeps strong legal protections in place and offers a chance to strengthen commitments after 2027.
  • Governance and accountability – Strengthens enforcement and ensures polluters are held responsible.
  • The monitoring system – Reduces reliance on self-reporting and improves transparency.
  • River Basin Management Plans – Supports better catchment-scale planning for restoration and pollution control.
  • Public participation and engagement – Ensures communities have a say in protecting local waters.
  • The classification system – Select this only if you support expanding it to include pollutants like PFAS and microplastics.

Explanation
This question is asking what changes (if any) should be made to the legal framework that protects rivers, lakes, and groundwater after 2027. The WFD currently sets the standard of achieving Good Ecological Status for all water bodies by 2027. It has been one of the strongest legal tools for holding polluters to account.

However, with only two years left, most rivers are not meeting this target. This raises the question: should the WFD be improved – or scrapped and replaced?

The way this question is answered could influence whether the government chooses to strengthen legal protections and enforcement – or weaken them to suit polluters.

Guidance

We suggest supporting the following options:

  • The targets and objectives – Keeps strong legal protections in place and offers a chance to strengthen commitments after 2027.
  • Governance and accountability – Strengthens enforcement and ensures polluters are held responsible.
  • The monitoring system – Reduces reliance on self-reporting and improves transparency.
  • River Basin Management Plans – Supports better catchment-scale planning for restoration and pollution control.
  • Public participation and engagement – Ensures communities have a say in protecting local waters.
  •  The classification system – Select this only if you support expanding it to include pollutants like PFAS and microplastics.
  • The way economic evidence is considered – This should be reformed to stop polluters using cost arguments to avoid responsibility. Clean water should never be optional.

We suggest avoiding:

  • No changes are needed – This ignores the failure to meet existing targets and the need for stronger action.
  • Economic evidence – This could be used to justify weaker protections based on cost to polluters, rather than public or environmental benefit.
  • The way economic evidence is considered – This should be reformed to stop polluters using cost arguments to avoid responsibility. Clean water should never be optional.

We suggest avoiding:

  • No changes are needed – This ignores the failure to meet existing targets and the need for stronger action.
  • Economic evidence – This could be used to justify weaker protections based on cost to polluters, rather than public or environmental benefit.

Explanation
This is a space for you to explain in your own words how the Water Framework Directive could be improved. It builds on Question 17.

While the WFD has been a powerful tool for protecting rivers, implementation in the UK has been weak – with limited enforcement, over-reliance on self-monitoring, and a failure to meet legal targets. This is your chance to call for stronger protections, not weaker ones.

Guidance

We suggest including points like:

  • The 2027 deadline must not be used to lower ambition. We need stronger, clearer targets – not weaker ones.
  • Strengthen the polluter pays principle, so industries – not bill payers – cover the cost of pollution.
  • Enforcement is too weak. Regulators need more power and funding to take meaningful action.
  • Improve public participation and transparency, giving communities a real role in protecting their rivers.
  • Expand the system to include emerging pollutants like PFAS and microplastics.
  • Build in catchment-based planning and integrate WFD goals with land use and farming policies.
  • Require independent monitoring and clear, accessible data to rebuild trust.
  • Introduce stronger legal duties on regulators, water companies, and public bodies to meet ecological targets.
  • Right now, the WFD allows governments to use economic evidence to justify exemptions from meeting water quality targets – for example, by claiming clean-up is too expensive. This has allowed poor water quality to persist. We believe this loophole should be tightly limited or reformed – not expanded.

Q19

Measuring and Assessing the Water Environment

Medium Priority.

Most relevant to citizen scientists, wild swimmers, local monitoring groups, environmental campaigners.

Explanation
This question is about how we measure the health of rivers and other water bodies – and whether changes are needed to improve the current monitoring system.

Right now, much of the pollution data is self-reported by water companies, leading to underreporting and poor accountability. Some of the most harmful pollutants – including microplastics, PFAS (forever chemicals), and pharmaceuticals – aren’t routinely monitored.

The current system often focuses too narrowly on ecological status, missing public health risks like bacteria in popular swimming areas. It also overlooks valuable contributions from citizen science, even though communities are collecting accurate, useful data across the country.

Guidance

We suggest supporting the following options:

  • Reporting on wider outcomes than ecological status – so health risks to swimmers and river users are properly considered.
  • Use of citizen science – so community data is recognised and acted on.
  • Data sharing platforms for government and third-party evidence/data – to improve transparency, track pollution in real time, and link evidence together.
  • Expanding out from the water body level to report on a whole catchment – to better understand how pollution moves through entire river systems.
  • Full or partial integration with wider environmental monitoring – so water data is considered alongside climate, land use, and nature data to understand the bigger picture.

We suggest avoiding:

  •  “No changes are needed” – the current system is clearly not delivering.
  •  “Using statistical modelling to reduce monitoring” – this risks weakening data collection and letting pollution slip through the cracks.

Q20-23

Strategic Direction for the Water Industry

Lower Priority.

Most relevant to those interested in Water Systems, Authority and Management

Explanation
These questions explore how the government sets direction and priorities for the water industry, and whether the current approach is working. Strategic direction includes things like:

  • Government targets (e.g. Environment Act, Plan for Water)
  • Policy statements (e.g. Strategic Policy Statement in England, Price Review Forum in Wales)
  • National environment plans and guidance

Right now, there are concerns that strategic direction from the government is too vague, poorly enforced, or lacking in ambition. Long-term planning is often fragmented, with unclear roles for local authorities, weak data, and inconsistent targets. Plans don’t always line up – and communities are often left out of the process.

This section is your chance to say:

  • What role you think government should play
  • Whether the current system needs reform
  • What’s stopping long-term, joined-up water planning
  • And what would help water companies deliver their duties better

Explanation

This question is about who sets the long-term direction for the water industry. Should it be the government, regulators, or water companies themselves?

Currently, the government provides some guidance – like the Strategic Policy Statement in England or the Price Review Forum in Wales. But these frameworks are often vague, short-term, and unclear about trade-offs – for example, between affordability, environmental protection, and infrastructure investment.

To face major challenges like climate change, river pollution, drought, and population growth, we need clear, long-term strategic direction – led by government in the public interest, not company profits.

We are asking the commission to consider the creation of Regional Water Authorities. These would be public bodies responsible for planning and oversight at a regional, catchment-wide level – not just enforcing rules, but setting priorities based on local needs. They would bring together local authorities, community representatives, scientists, and environmental voices to make joined-up decisions about investment, nature recovery, pollution control, and resilience.

Imagine if each region had a water authority that worked hand-in-hand with communities, knew the local rivers and risks, and could direct investment where it’s needed most. Instead of faceless boards run for shareholders, decisions could be guided by those who care most – river users, local leaders, and environmental experts.

Other countries show this is possible:

  • In the Netherlands, local authorities retain a ‘golden share’ in water companies to protect public interest.
  • In Austria and Denmark, sewage systems are publicly owned and managed at a local level, reflecting community needs.
  • Regional public governance is the norm across much of Europe – ensuring democratic oversight and long-term vision.

Guidance

We recommend calling for a much stronger and more strategic role for government, to set a clear direction for the water industry that serves people and nature. This should include:

  • Long-term, joined-up planning that avoids short-term fixes and ensures future water security
  • Legally binding environmental targets that can’t be overridden by company profits or political convenience
  • Enforceable obligations on pollution reduction, leak repair, and storm overflow controls
  • Mandatory investment in nature-based, climate-resilient and community-supported solutions
  • Democratic regional governance, where local communities, councils, and environmental experts have real power in decision-making

We support the creation of Regional Water Authorities – public bodies with statutory powers to set strategy at the regional (often catchment) level. These authorities should bring together local authorities, communities, and experts to shape water policy from the ground up – making decisions that reflect local conditions and priorities.

By empowering Regional Water Authorities, government can ensure that water is managed with democracy, accountability, and deep local knowledge at its heart.

Explanation

This question is asking how the government should improve the way it sets direction for the water industry.

At the moment, the UK Government provides Ofwat – the economic regulator for water in England and Wales – with a Strategic Policy Statement (SPS) roughly every five years. This statement sets out government priorities for the sector, like tackling sewage pollution, fixing leaks, or preparing for climate change. Ofwat then interprets those priorities and passes them on to water companies through the rules it sets.

But there are major problems:

  • The SPS is not legally binding, so regulators and companies can ignore it
  • A five-year cycle is too short-term for long-term issues like pollution, infrastructure renewal, and climate resilience
  • Priorities shift with each new government, creating uncertainty and undermining accountability
  • Ofwat’s focus on keeping bills low has too often come at the expense of environmental protection and long-term investment

Guidance

We recommend calling for a much stronger and more strategic role for government, to set a clear direction for the water industry that serves both people and the environment. This should include:

  • Long-term, joined-up planning to prepare for climate change, water shortages, and population growth – not just patching up failures
  • Legally binding environmental and public health targets that can’t be sidelined for short-term financial or political gain
  • Enforceable obligations on pollution, leak repair, and storm overflow controls – with penalties that bite
  • Mandatory investment in resilient, nature-based and community-supported solutions, to reduce pressure on ageing infrastructure and restore ecosystems
  • Democratic regional governance, where local communities, councils, catchment groups and environmental experts have a meaningful say

We support the creation of Regional Water Authorities – publicly accountable bodies with real powers to set strategy at the regional (often catchment) level. These authorities would reflect local needs, bring together a range of expertise, and direct investment where it delivers the most long-term value.

Crucially, investment must not fall solely on bill payers.

In PR24, water bills have already increased – meaning customers are being asked to pay twice: once in the past, when money that should have gone into infrastructure was diverted to shareholders, and again now to fix the resulting failures.

Investors– not just customers – must carry the cost of rebuilding the system.

Other countries offer valuable models:

  • In France, remunicipalisation in Paris led to lower bills and reinvestment in infrastructure, while embedding citizen and environmental oversight.
  • In Austria and Sweden, local public control ensures investment is aligned with long-term sustainability and democratic accountability.
  • In Scotland, publicly owned Scottish Water reinvests all profits and accesses cheaper public financing to fund infrastructure at lower cost.

The UK must learn from these systems – putting long-term public benefit ahead of short-term profit.

Explanation
This question asks why the water industry, regulators, and government are struggling to plan effectively for the long term – and what’s standing in the way of joined-up, year NW Stratfuture-focused water management.

The consultation points to existing planning processes like the Price Review, Water Resources Management Plans, and National Environment Programmes. But many of these suffer from short-termism, poor coordination, and unclear responsibilities.

We believe that profit-driven decision-making, weak government direction, and fragmented planning frameworks are the key barriers.

Guidance

We suggest selecting the following options:

  • Limited clear guidance from UK and Welsh Governments on priorities – underscores the need for a legally binding, long-term National Water Strategy.
  • Limited timebound, specific, and measurable targets – ensures water companies are working towards real goals on pollution, investment and supply resilience.
  • Regulators are not adequately supporting effective planning – calls for Ofwat and the Environment Agency to take long-term planning seriously and enforce it.
  • Plans don’t interact well together – pushes for more integrated planning across regulators, government, and local authorities.

We suggest using ‘Other’ to add:

Water companies prioritise shareholder returns over long-term investment. For example, no new reservoirs have been built since 1992. Profits should never come before public interest.

We suggest avoiding:

  •  “There are no barriers to long-term planning” – this undermines the urgent need for reform.
  • “Regulatory requirements don’t support certainty” – this could be used to argue for deregulation or weaker environmental rules.

Explanation
This question asks how water companies could improve their use of existing planning tools to deliver long-term outcomes – like reducing pollution, upgrading infrastructure, and protecting rivers.

The main planning frameworks include:

  • Price Review business planning – how companies decide where to spend money
  • Drainage and Wastewater Management Plans – how they prevent floods and sewage spills
  • Water Resources Management Plans – how they make sure there’s enough water supply
  • National Environment Programmes – how they meet environmental targets

The problem? These plans are often shaped more by profit than by public interest. Investment decisions are driven by what benefits shareholders in the short term – not by what’s needed to fix leaking pipes, reduce sewage spills, or improve infrastructure.

There’s also a lack of legal accountability. Water companies face few consequences if they miss planning targets or delay action. And with planning focused on five-year cycles, there’s little space for long-term thinking.

Guidance
We recommend calling for much stronger rules and oversight to ensure water company planning actually delivers for people and rivers. For example:

  • Make investment commitments legally binding, so companies can’t wriggle out of delivering upgrades and pollution reduction
  • Introduce tougher penalties for missing environmental and infrastructure targets – with fines used to fund restoration and enforcement
  • Ensure planning is done in partnership with local authorities, regulators, catchment partnerships and communities – not just behind closed doors
  • Shift the focus away from short-term shareholder gain, and towards long-term environmental and social benefit

Things to avoid

  • Saying “no changes are needed” – the current system is clearly failing to deliver on pollution, climate resilience or basic infrastructure
  • Arguing for more flexibility – this risks giving companies more leeway to delay action and protect profits over public good

Q24-27

The Regulators

High Priority.

We’re asking everyone to fill in this key section.

Explanation
The water industry has two essential responsibilities:

  • Ensuring clean, safe drinking water
  • Collecting and treating wastewater to protect public health and the environment

To make sure this happens, we have a regulatory system – but it’s not working.

There are three main regulators:

  • The Environment Agency (EA) in England and Natural Resources Wales (NRW) in Wales – responsible for environmental protection, including river health and pollution oversight
  • The Drinking Water Inspectorate (DWI) – ensures the water from your tap is safe to drink
  • Ofwat (Water Services Regulation Authority) – the economic regulator, meant to balance company profits with customer protection and investment in infrastructure

The current regulatory system has evolved in a piecemeal way, often reacting to crises – like the ongoing sewage scandal – rather than providing clear, joined-up oversight.

What’s gone wrong?
Over the last decade, political decisions have drastically weakened regulators’ capacity to do their jobs. The Environment Agency’s core funding for environmental protection has fallen sharply—from £152 million in 2010–11 to £70 million in 2018–19. When inflation is accounted for, this represents a real-terms cut of nearly a third by 2024–25.

The result? Fewer site visits. Fewer staff. Fewer prosecutions. And more pollution.

At the same time, the EA and NRW often fail to stop sewage pollution before it happens. Ofwat is supposed to make sure companies invest in infrastructure, but has instead allowed billions in profit-taking while rivers decline.

Customer protection is also weak. Ofwat doesn’t factor in how much of your water bill actually goes toward environmental protection.

Enforcement is failing. Fines are rare, and when they do happen, companies treat them as a cost of doing business and continue polluting.

The Water Commission wants to know:

  • Do regulators need stronger powers or more funding?
  • Are their roles clear and effective, or are they stepping on each other’s toes?
  • Should we create a new regulator or reform the existing ones?

What are we asking for:

  • The government must properly fund the Environment Agency, so it has enough staff and resources to investigate pollution and hold polluters to account
  • The EA must tighten permits and properly enforce the laws already in place—sewage dumping is supposed to be rare, not routine

Explanation:
This question asks how well the system of regulation is working – including how effectively the Environment Agency, Ofwat, and the Drinking Water Inspectorate are holding water companies to account.

Right now, the system is failing. Regulators should be working in the public interest – protecting people, rivers, and the environment. But instead, they’ve been too slow, too underpowered, and too lenient with polluting companies.

Over the last decade, political decisions have dramatically weakened the regulatory system. Core funding for the Environment Agency’s environmental protection work has dropped from £152 million in 2010–11 to £70 million in 2018–19. In real terms, that’s a cut of nearly one-third by 2024–25. This has left the agency with too few staff to carry out inspections, enforce permits, or prosecute polluters.

Even when companies dump sewage or miss investment targets, there are few consequences. Fines are rare—and often so small that they’re written off as a cost of doing business. Meanwhile, Ofwat has failed to prevent the extraction of billions in dividends, despite crumbling infrastructure and public outcry.

Guidance:
We recommend answering that the regulatory framework is either:

  • Performing poorly, or
  • Performing very poorly

This reflects the current lack of accountability, enforcement, and meaningful action to protect rivers, ecosystems, and communities.

Explanation
This question is asking whether the different regulators – Ofwat, the Environment Agency, and the Drinking Water Inspectorate – actually work well together, or whether their lack of coordination is making things worse.

Guidance
We believe regulators currently do not coordinate effectively, and this is a major reason why the system is failing. Key problems include:

  • No single body takes full responsibility. The EA, Ofwat and DWI all have different roles – and no one joins them up.
  • Pollution enforcement is slow and disjointed. For example, the EA may want pollution stopped, but can’t require companies to invest – that’s Ofwat’s decision.
  • Regulators pass the buck. When things go wrong, responsibility is pushed between agencies, water companies, and the government – and no one is held to account.
  • There’s no unified strategy. Each regulator focuses on its own silo – but water systems are connected. Without coordination, we can’t tackle the full picture of pollution, drought, or infrastructure breakdown.

In the sewage crisis, the Environment Agency can monitor pollution but can’t make companies invest in sewage treatment upgrades. Ofwat controls funding, but doesn’t prioritise the environment. So no one acts, and pollution continues.

We recommend answering:

  • Very little or
  • Not at all

Explanation
This question is asking what needs to change to fix our broken regulation system. It’s about how regulators like the Environment Agency (EA), Ofwat, and the Drinking Water Inspectorate (DWI) are set up, and whether they need stronger powers, clearer duties, or a completely new approach.

Right now, regulation is too weak, too fragmented, and too easy to ignore. Water companies treat fines as a cost of doing business. They delay investment, repeat illegal activity, and exploit gaps between regulators – all while continuing to pay out millions to shareholders.

Guidance
We recommend calling for a tougher, more coordinated and accountable regulatory system – one that puts people and rivers first. For example:

  • Fines must be high enough to change behaviour. While caps have recently been lifted, it’s still profitable for companies to pollute. This must change. Fines must be meaningful – and actually enforced.
  • Fine revenue must be ringfenced for environmental protection. The Water Restoration Fund was created to reinvest fines into nature, but reports show the Treasury is seeking to siphon off this money for other uses (Guardian, Jan 2025). This must be stopped – the money should go directly to river restoration and better enforcement.
  • Regulators must be given stronger powers to enforce investment. They should be able to require water companies to reinvest profits into fixing leaks, stopping sewage spills, and upgrading infrastructure – with clear consequences if they don’t.
  • The current system must be better joined up. The EA, Ofwat and DWI are responsible for different but connected parts of the system – yet they often work in silos. Better coordination is urgently needed to close loopholes and deliver consistent enforcement.
  • A new legal duty should be introduced – requiring all regulators and water companies to act in the public and environmental interest, similar to duties given to Public Benefit and Community Interest Companies.
  • An open review of the current regulatory model is needed. We need to ask whether the current split between regulators is working – or whether a stronger, single environmental regulator with real teeth is needed.
  • The government must improve access to the courts. The Environment Agency often waits three years or more to prosecute polluters due to court backlogs. This is unacceptable. Legal bottlenecks must be removed to allow swift enforcement and real accountability.

Things to avoid

  • Supporting the current system as it stands – it’s clearly not working
  • Suggesting “more flexibility” for water companies – this often results in delays and weaker obligations
  • Proposals that rely on voluntary commitments instead of legal requirements

Explanation
This question asks whether the Environment Agency (EA), Ofwat, and the Drinking Water Inspectorate (DWI) have enough funding, staff, and expertise to properly regulate the water industry.

Right now, the answer is: not really. Years of budget cuts, understaffing, and weak powers mean that regulators often can’t act quickly or effectively – even when pollution is reported.

Key issues include:

  • Not enough funding – The EA’s budget has been cut significantly over the past decade, which has reduced inspections, slowed enforcement, and limited the ability to respond to pollution.
  • Too few staff – There aren’t enough officers to carry out routine checks on water companies. As a result, pollution can go unnoticed or unpunished for months, even years.
  • Weak enforcement powers – Even when regulators know rules are being broken, they often can’t issue immediate or meaningful penalties.
  • Over-reliance on self-reporting – Water companies are often left to monitor and report on their own pollution. This creates a major conflict of interest and leads to underreporting.

Guidance
You can use this space to reflect your own experience – whether it’s being ignored by the EA, frustrated with Ofwat, or concerned about the lack of inspections in your local area.

We recommend including points like:

  • More funding for regulators – They need resources to do their jobs properly.
  • More technical staff and training – Specialists are needed to analyse complex data and challenge water companies effectively.
  • Stronger enforcement powers – Regulators should be able to issue fines and orders without long delays or legal hurdles.
  • Less reliance on self-reporting – Independent monitoring is essential for public trust and accurate data.
  • Open data sharing between agencies – Government bodies and regulators must share data openly to enable joined-up monitoring, quicker enforcement, and better public transparency.
  • Better collaboration with citizen science – If you’re involved in citizen testing, you might want to highlight its value in spotting pollution. But this should supplement, not replace, the work of regulators. The public shouldn’t be expected to pick up the pieces when regulators are underfunded.
  • Ofwat’s statutory duties should be updated – Environmental protection must be given equal weight to keeping prices low or protecting company profits.

Q28-34

Economic Regulation

Lower Priority.

Most relevant to those interested in:

  • Water company financing and Ofwat
  • How we finance and plan our water system
  • Water company accountability / pollution enforcement
  • Those frustrated by water bills

Explanation
This part of the consultation looks at how the financial side of the water industry is regulated. Since you can’t choose your water provider, water and wastewater companies operate as regional monopolies. That’s why we have economic regulation – to stop companies from abusing their position, overcharging customers, or under-delivering on service and infrastructure.

Ofwat, the economic regulator, is supposed to prevent this. It oversees the system through a process called the Price Review, which happens every five years. This is how Ofwat decides:

  • How much companies can spend on infrastructure (known as base and enhancement costs)
  • What level of return investors can expect – this is called the Weighted Average Cost of Capital (WACC)
  • How companies are rewarded or penalised for performance, using Outcome Delivery Incentives (ODIs) and Performance Commitment Deliverables (PCDs)

But the system is failing.
Our rivers are full of sewage, a third of our water is lost to leaks, and not a single new reservoir has been built in 30 years – all while billions have gone to shareholders. Water companies prioritise short-term profit over long-term investment, and customers are left paying the price.

Here’s where the problems lie:

  • Cost allowances (base/enhancement costs): If Ofwat sets these too low, companies claim they can’t afford vital upgrades. If too high, they overcharge customers and under-deliver. Either way, the public loses.
  • WACC (Weighted Average Cost of Capital): This sets the profit companies are allowed to make on investments. When it’s too generous, it enables large shareholder payouts – even when performance is poor. This is especially concerning given the rise of investors focused on short-term profit extraction. For example, during Macquarie’s ownership of Thames Water, dividends exceeded profits in five out of ten years, while debt quadrupled.
  • Performance incentives (ODIs and PCDs): These are meant to hold companies to account – but in practice, rewards are given even when rivers stay polluted. Penalties are small, and often absorbed as a cost of doing business.

We believe:

  • Reinvestment in infrastructure should be a legal requirement, not optional
  • Shareholder payouts must not come at the expense of basic service and environmental standards

Performance incentives must be reformed so that companies are only rewarded for real, measurable improvements – and face real consequences when they fail

Explanation

We think currently the economic regulatory framework is delivering negative outcomes. They currently have no power to block dividends and bonuses, they don’t have enough resources to properly regulate the huge water companies, and they need to have stronger rules forcing water companies to invest in infrastructure.

Guidance

We recommend responding that the economic regulatory framework is delivering “very little” or “not at all” in terms of positive outcomes.

Explanation
This question asks how Ofwat’s Price Review process (e.g. PR24, PR29) should balance two things:

  • Keeping water bills affordable for households
  • Ensuring long-term investment in the infrastructure we need – like fixing leaks, building reservoirs, and upgrading sewage treatment works

The Price Review sets water company budgets every five years – including how much they can charge, how much they must invest, and how much profit they can make.

But short-term cost control has created long-term failure.
For decades, the system has prioritised low bills and short-term returns over long-term resilience. Water companies have underinvested in critical infrastructure – and now we’re all paying the price through higher bills, more pollution, and supply failures.

Guidance
We believe the system must change so that investment and affordability are no longer treated as opposing goals. It’s not that customers aren’t paying enough – it’s that water companies aren’t reinvesting enough of what they already take.

We recommend calling for:

  • Stop treating investment and affordability as a trade-off. Companies have paid out billions to shareholders while claiming they can’t afford upgrades. That’s a failure of regulation – not of customer funding.
  • Tie executive pay and dividends to investment performance. If companies fail to deliver promised upgrades or reduce pollution, they shouldn’t be rewarding themselves.
  • Support models that prioritise reinvestment. Not-for-profit and public benefit models – like Welsh Water – show that when profits are reinvested instead of extracted, bills stay fair and infrastructure improves.
  • Shift the focus of the Price Review to public benefit. It should centre environmental health and long-term resilience – not just financial returns or short-term savings.

We suggest opposing:

  • Raising bills while companies continue to prioritise shareholder profits
  • Delaying investment beyond the current Price Review cycle
  • Letting companies miss investment targets with no serious consequences

Explanation
The Price Review (PR24, PR29, etc.) is supposed to balance three things:

  • Keeping water bills fair
  • Ensuring investment in infrastructure
  • Regulating company profits

But in practice, it has failed to deliver positive outcomes for people or the environment. Water companies continue to pay out dividends and bonuses while underinvesting in infrastructure – and pollution levels are rising.

Who benefits from this system?
Water companies argue that dividends are necessary to attract investment – but most of those payouts go to overseas shareholders, not back into local infrastructure. Meanwhile:

  • Tourist towns lose income as polluted seas drive visitors away
  • Swimmers, anglers, and surfers lose access to safe blue spaces
  • Local businesses, like paddleboard and kayak rentals, suffer when rivers are unsafe to use

The current system puts corporate profit ahead of environmental and public outcomes. It’s not working – and it needs reform.

Guidance

We suggest recommending the following changes:

  • Make infrastructure reinvestment a legal requirement. Companies should not be allowed to pay out dividends unless essential upgrades have been delivered.
  • Redefine what “growth” means in the water sector. Growth shouldn’t just mean bigger profits – it should mean clean water, resilient infrastructure, and thriving local economies.

Link bonuses and dividends to environmental delivery. No company should be rewarded while missing pollution or investment targets.

Explanation
Base expenditure covers the day-to-day running and maintenance of the water system – like fixing leaks, operating sewage treatment works, and replacing ageing infrastructure.

This question is about how Ofwat decides how much companies are allowed to spend on this core maintenance through the Price Review.

The current problem:
For decades, base expenditure has been set too low. Water companies have cut corners, underinvested in routine upkeep, and prioritised short-term profits over long-term resilience. As a result:

  • A third of our water is lost to leaks
  • Sewage infrastructure is outdated and underfunded
  • Emergency repairs are now more expensive than proper maintenance would have been

Customers are now paying the price for decades of underinvestment.

Guidance

We recommend supporting the following reforms:

  • Base expenditure should be based on what’s actually needed, not just what’s affordable in the short term. If we want reliable water services, maintenance budgets must reflect real infrastructure needs.
  • Water companies should be required to use maintenance budgets for maintenance. Even when allowed higher spending, companies can still prioritise dividends. This must change.
  • Independent assessments should verify what companies claim they need. Right now, companies submit their own data, which may under- or over-estimate costs. Independent review would ensure a more accurate, long-term view.

Explanation
This question is about how Ofwat sets enhancement expenditure – the money water companies are allowed to spend on major upgrades. This includes things like:

  • Building new reservoirs
  • Upgrading sewage treatment works
  • Installing flood defences or climate adaptation infrastructure

Right now, investment in these upgrades is far too low.

  • No new reservoirs have been built in over 30 years – even as demand rises and climate risks increase.
  • Sewage treatment plants are outdated, contributing to frequent raw sewage spills.
  • Water companies often delay or under-deliver even when Ofwat approves spending.
  • Companies must face clear consequences for failing to deliver approved upgrades – otherwise, there’s no incentive to follow through.
  • Ofwat’s spending caps mean only the bare minimum is done – often too late.

Guidance

We recommend calling for the following changes:

  • Set enhancement budgets based on real infrastructure needs, not short-term cost control. If we want a resilient water system, investment must reflect the scale of the challenge.
  • Penalise companies that fail to deliver approved upgrades. Allowing delays or incomplete projects without consequences undermines public trust and environmental goals.
  • Ensure investment serves the public and the environment, not just company profits. Infrastructure spending must prioritise clean water, climate resilience, and river health – not shareholder returns.

Explanation
The Weighted Average Cost of Capital (WACC) is the rate of return water companies are allowed to earn on their investments. It’s meant to attract investment – by offering a decent return to shareholders and lenders – but it also sets the baseline for how much profit companies can make.

The problem?
WACC has been set too high for too long – allowing excessive shareholder payouts without delivering the environmental or infrastructure improvements those profits are meant to fund. The result is:

  • Higher bills for customers
  • Delayed or cancelled infrastructure upgrades
  • Persistent pollution, leaks and underperformance

Guidance
We suggest calling for changes that bring WACC back in line with public benefit, and stop it being a backdoor for excessive private profit.

You could recommend:

  • Reducing WACC to curb excessive profits – while still supporting essential upgrades. WACC should serve the public, not just investors.
  • Tying higher returns to delivery – companies should only receive strong returns if they prove they’re investing in key outcomes, like stopping sewage spills or fixing leaks.
  • Greater transparency – the public deserves to know how WACC-linked funding is being used, and whether it’s delivering for rivers and communities.

You could also point to alternative models that offer a better balance between investment and public good:

  • Community Interest Companies (CICs) are subject to a dividend cap of 35% of profits, helping to ensure that profits are largely reinvested rather than extracted.

This is in sharp contrast to current water companies in England – in 2023–24, Severn Trent paid out 215% of profits in dividends, and Yorkshire Water paid out 125%. That’s not sustainable – and it’s certainly not in the public interest.

Question 34: What, if any, changes could be made to the Price Review process on assessing and setting performance incentives to effectively secure infrastructure delivery?

Explanation
This question is about performance incentives – the system of rewards and penalties that is meant to drive improvements by water companies.

There are two main tools:

  • Outcome Delivery Incentives (ODIs): Bonuses or penalties based on company performance
  • Price Control Deliverables (PCDs): Agreed investment projects companies must deliver in exchange for funding

The issue?
Right now, the incentive system is failing.

  • Some ODIs allow companies to earn bonuses for small or superficial improvements, while missing major pollution or infrastructure targets
  • Fines are too small to act as a deterrent – companies can simply absorb them as a cost of doing business
  • PCDs often lack enforcement, so companies can delay or downgrade infrastructure delivery while still making profits

Real-world example: In 2023–24, Severn Trent Water received £55 million in ODI rewards – despite failing to meet key drinking water quality standards (CRI) [CEO Today]. Meanwhile, Thames Water diverted funds pledged for environmental improvements to cover executive bonuses and shareholder payouts, even as sewage pollution continued [The Guardian]. These examples show how companies can be rewarded for superficial improvements while missing major environmental targets.

Guidance

We recommend supporting the following changes:

  • ODIs should only reward meaningful improvements. Bonuses must be tied to real outcomes – such as reductions in sewage spills, improved river health, or delivery of large-scale upgrades.
  • Stronger penalties for failure to deliver. Companies that don’t meet infrastructure targets should face significant financial consequences or be required to reinvest the equivalent value.
  • Strengthen PCD enforcement. Make sure that agreed investment projects are delivered on time, to a high standard, and without unjustified delays or cuts.

Q35-36

Customer Bills

Lower Priority.

For anyone interested in sewage pollution, bill boycotts, and customer fairness.

Water bills should be fair and affordable – especially for those on low incomes. Ofwat is meant to make sure bills are reasonable, while also giving water companies enough to invest in infrastructure.

But here’s the problem:

  • Bills are rising while trust is collapsing. People are paying more, yet sewage pollution continues and promised upgrades aren’t delivered.
  • Customers don’t know where their money goes. Water companies often fail to show how much of your bill is spent on fixing pipes vs. paying out dividends.
  • Some people pay more than others. Bills vary by region, and many households still don’t have water meters – so some are charged based on outdated estimates, not actual use.

Watch: What the Sewage Campaigning Network had to say about price hikes

Explanation
This question asks whether the current system – where Ofwat regulates what companies can charge – is working to keep bills fair and affordable for the public.

Right now, it’s not.
Water bills are rising, but customers aren’t seeing improvements.

  • Infrastructure is crumbling.
  • Pollution remains high.
  • Water companies have prioritised shareholder payouts over reinvestment in the system.

Customers are being asked to pay more – not for better service, but to make up for decades of underinvestment.

Guidance
We recommend answering:

  • “Very little” or
  • “Not at all”

Explanation
This question is about how the billing system could be improved to make sure water charges are fair, transparent, and support conservation. Right now:

  • Many customers don’t know how their bills are calculated or where the money goes
  • Some households pay disproportionately high bills, while water companies continue to make large profits
  • There are few pricing mechanisms that encourage lower consumption or support those who use less

Fair billing must also go hand in hand with clear rules on reinvestment. If customers are asked to pay more, water companies must be required to deliver real improvements – not just increase shareholder returns.

Guidance

We recommend supporting the following options:

  • Improve transparency for customers. People should know how much of their bill goes toward infrastructure, pollution control, dividends, and company profits.
  • Increase the use of smart water meters. These help track usage, identify leaks, and allow for fairer, more personalised billing.
  • Explore innovative water tariffs – such as rising block tariffs. A Rising Block Tariff means the more water you use, the more each unit costs e.g.  charging lower rates for essential use (drinking, cooking) and higher rates for excessive use (like watering large lawns or filling pools). This encourages water conservation while protecting access to essential water for all households.
    This isn’t something we usually campaign on, but we recognise it as a potentially fairer system for water bill payers – especially if paired with strong protections for essential household needs.

Q37-40

Customer Protections

Lower Priority.

Most relevant to anyone concerned with customer service, affordability, or support for vulnerable households.

Explanation
This section is about how well the regulatory system protects water customers – especially those who are vulnerable or struggling with rising bills. It focuses on:

  • Customer service: Are water companies resolving complaints quickly and fairly?
  • Support for vulnerable customers: Are those on low incomes or with additional needs getting the help they need?
  • Enforcement: Are water companies held to account when service falls short?

As bills rise and trust in water companies remains low, these questions are important for ensuring people feel they’re treated fairly.

Our stance
At River Action, we focus on clean rivers and environmental accountability. We’re not a customer rights organisation, so we’re not offering detailed advice here.

But we strongly believe:

  • Water companies should treat all customers fairly and transparently
  • Service failures should come with consequences
  • Rising bills must come with real accountability – not higher dividends

Things to consider when answering this section:

  • Do you feel customers are adequately protected from poor service?
    → If not, consider answering “very little” or “not at all” to Q37.
  • Do you support a single social tariff to help low-income households?
    → This would replace the current patchwork of regional schemes with a national system.
  • Should enforcement be stronger when companies mishandle complaints or fail to deliver fair service?

You’re encouraged to answer based on your personal views or experiences. Whether you’re a bill payer, a campaigner, or a concerned citizen, your response can help shape a system that works better for people as well as rivers.

Q41-43

Financial Resilience

Medium Priority.

Most relevant to anyone interested in water company debt and management models.

Explanation
Financial resilience is about how stable water companies are financially — whether they can manage debt, maintain investment in infrastructure, and handle economic pressures like inflation and fines without collapsing.

The problem?
Many water companies have taken on huge levels of debt while still paying out massive dividends to shareholders. This has left them financially vulnerable, meaning:

  • Some companies don’t have enough money set aside for critical infrastructure investment, leading to sewage spills, leaks, and underfunded treatment plants
  • When a company gets into financial distress, it risks cutting corners on environmental protections to stay afloat
  • If a company goes bankrupt, the government (and ultimately customers) may have to bail them out — raising concerns about who takes responsibility when private companies fail

Despite this, water companies are highly profitable. They have guaranteed income from customer bills and face no competition, making them one of the easiest businesses to run — so why are they struggling with financial resilience?

Explanation
Many water companies have taken on huge levels of debt while continuing to pay out large dividends, leaving them financially unstable. Now, customers are facing rising bills, while companies claim they can’t afford to invest in infrastructure upgrades.

Regulation has failed to ensure long-term financial health. Instead, it has allowed companies to prioritise shareholder profits over responsible investment in water systems.

Change is urgently needed — not by raising bills, but by reforming the rules so companies are required to reinvest in infrastructure, not load up on debt and pay out dividends.

Guidance
We recommend answering:
“To a great extent”

Explanation
This question is about what changes could strengthen the economic regulation of the water sector. It focuses on how regulators can better manage company debt, prevent financial collapse, and ensure water companies are run in the public interest—not just for shareholder gain.

Guidance

We suggest supporting:

  • Changes to the Price Review process to support financial resilience
    Helps ensure investment in infrastructure and pollution control is prioritised over short-term profits.
  • Changes to the oversight of water company debt (e.g. capping company debt levels)
    Some companies have taken on unsustainable debt while still paying out dividends. Oversight is needed to ensure debt is tied to actual investment in the system—not financial speculation.
  • Changes to financial oversight of companies (e.g. moving to a more supervisory model)
    A supervisory model would allow regulators to monitor company finances more closely and intervene earlier, before problems spiral.
  • Changes to the Special Administration Regime (SAR) (e.g. providing guidance on the thresholds for SAR)
    See below for more detail.

We suggest avoiding:

  • Changes to the way in-distress companies are managed (e.g. giving regulators more discretion in enforcement)
    This could mean struggling companies are let off with weaker penalties, even if they’ve caused environmental damage or failed to invest. Financial difficulty shouldn’t be a free pass for breaking the rules.
  • No changes are needed
    The current system has led to high debt, poor environmental outcomes, and growing public concern. Reform is essential.

If none of the listed options reflect your view, you can also select “Other” and suggest:

  • Linking executive bonuses to environmental and service performance
  • Requiring public reporting of company debt and dividend policies
  • Introducing not-for-profit or publicly owned models that prioritise environmental protection

A note on SAR
The Special Administration Regime (SAR) is the emergency plan used when a water company is close to financial collapse. It allows the government to step in and temporarily take over operations to keep water and sewage services running.

Right now, there are no clear rules for when SAR should be triggered. For example, Thames Water is carrying ÂŁ19 billion in debt, but has not yet entered SAR. If regulators act too late, it could lead to serious service disruption or a costly taxpayer bailout.

River Action believes that SAR thresholds should be made clear, early action should be prioritised, and companies should not be allowed to drift into crisis without intervention. A stronger, more transparent SAR framework is essential for protecting the public and environment from corporate failure.

SAR can also create a path to long-term reform. Under temporary public ownership, the government could acquire water company equity at low or no cost, write off unsustainable debt, and reissue it on far better terms. Our legal advisers have confirmed that the Government has the power to do this. For example, while Thames Water’s new debt carries a 9.75% interest rate, government-backed bonds are typically around 4–5%—roughly half the cost. This would create the conditions for real investment in infrastructure and service delivery, replacing the current model of financial engineering and profit extraction with one focused on long-term public benefit.

Explanation
This question asks whether the way water companies have handled debt, dividend payments, and infrastructure investment has affected their ability to deliver reliable services and protect the environment. In short: has the financial model of the industry contributed to poor performance?

The Commission is asking:

  • Have water companies taken on too much debt?
  • Have they prioritised dividends over investment?
  • Has this contributed to pollution, leaks, or failing infrastructure?

Guidance
If you have experience or local insight into how your water company has operated, you’re encouraged to include your own evidence. However, here are some key national points you may wish to raise in your response:

High Debt, High Dividends, Low Investment
Water companies have borrowed heavily since privatisation, but instead of reinvesting in essential upgrades—such as fixing leaks, modernising treatment plants, or preventing pollution—they have prioritised payouts to shareholders. This has left companies financially fragile and contributed to the decline in water quality and infrastructure.

  • 20% of water supply in England and Wales is lost to leaks due to underinvestment (Ofwat)
  • Thames Water alone leaks 570 million litres of water per day (Thames Water)
  • Since privatisation, ÂŁ85.2 billion has been extracted by shareholders — while infrastructure has crumbled. (River Action and SAS joint submission)
  • Total industry net debt stands at ÂŁ74 billion as of 2025, despite being debt-free when privatised (Financial Times)

Thames Water as a Case Study
Thames Water is a clear example of the risks caused by financial mismanagement in the sector. If Thames Water is allowed to continue operating within its failed financial structure, it stands little chance of being able to ever raise sufficient capital to address its dire environmental performance.

  • It took on ÂŁ14 billion in debt while continuing to pay dividends
  • It is now on the brink of collapse, requiring a ÂŁ3 billion loan provided by Thames Water’s creditors
  • Despite its financial state, it has underinvested in tackling leaks, pollution, and service failures
  • Its CEO has been paid up to ÂŁ2.3 million a year—even while performance targets were missed

Evidence from Ofwat and Financial Reports
Regulators have raised serious concerns about the prioritisation of financial engineering over public service. Ofwat and industry reviews show:

  • In some years, companies like Severn Trent and Yorkshire Water paid dividends far exceeding their profits — with Severn Trent paying out 215% of profits and Yorkshire Water 125% in 2023–24 alone.
  • Some companies have paid more in dividends than they’ve reinvested in infrastructure
  • Borrowing has increased, but water quality and pollution control have not improved
  • Shareholder returns and executive pay have remained high, even where service and environmental performance are poor

Why it matters
When a system is focused around profit maximisation, decisions are based on stock price, not clean water, healthy rivers, or public health. Without stronger financial accountability, the public will continue to face the consequences of corporate mismanagement—through rising bills, worsening pollution, and an unstable water system.

Q44-47

Investment

High Priority.

Relevant to anyone interested in how investment is raised and used in the water sector, especially in relation to company profits, infrastructure upgrades, and financial accountability.

Explanation

This section explores how water companies attract and use investment—and whether the current system ensures that investment benefits the public and protects the environment.

How investment is financed

Customers are often given the impression that investors pay for water company infrastructure maintenance and improvements. In reality, customer bills cover these costs. Investors typically provide upfront capital—through debt or equity—to cashflow investment, but it’s customers who ultimately repay this through their bills, including covering the cost of debt interest and shareholder dividends. This means that investors often take out more than they put in, while customers continue to foot the bill. Although borrowing to invest is common in infrastructure sectors, many water companies have failed to reinvest sufficiently in fixing leaks, modernising treatment plants, or preventing pollution—despite generating large revenues.

Are financial returns fair?
Since privatisation, water companies have paid out over ÂŁ85.2 billion in dividends, while accumulating ÂŁ74 billion in debt. This raises serious concerns that profits have been prioritised over long-term public service and infrastructure maintenance.

Public and political scrutiny
Some argue that public criticism and tighter regulation are making the sector less attractive to investors. But this public frustration is rooted in real failures: sewage dumping, leaks, rising bills, and decades of underinvestment.

This section asks whether the investment framework should change—so that water companies are required to reinvest in essential infrastructure, rather than extracting value for shareholders.

Explanation
This question asks whether current financial regulations are helping or hurting investment in the water industry. The Commission wants to know if companies are able to attract and use investment effectively under the current framework.

Key points to consider

  • The problem isn’t that regulation is too strict—it’s that it hasn’t been strong enough to make sure investment is used properly.
  • Weak oversight has allowed companies to accumulate debt and pay large dividends while failing to fix leaks, reduce sewage spills, or upgrade outdated infrastructure.
  • Claims that regulation discourages investment ignore the fact that water companies already generate stable income through customer bills and face no competition.
  • What’s missing is a requirement to reinvest—not more flexibility.

Guidance
We do not recommend selecting “Significantly hinders investment” or “Somewhat hinders investment.” This could be used to argue for weaker regulation.

We recommend the following option:

“Neither supports nor hinders investment” – this signals that regulation is not stopping investment, but it isn’t doing enough to ensure that investment serves the public or the environment.

Explanation
This question asks whether water company investors are making more or less profit than investors in other regulated industries, such as energy.

Key issues to consider

  • Water companies have historically generated large profits while underinvesting in infrastructure and environmental protection.
  • Since privatisation, they have paid out over ÂŁ85 billion in dividends while building up ÂŁ74 billion in debt, despite being debt-free at the start.
  • While some argue that returns have declined in recent years, many believe they were excessively high for too long, allowing companies to extract profits rather than reinvest.

Guidance
If you choose to respond to this question, you may want to make the case that:

  • Returns in the water sector have historically been too high, especially compared to the level of reinvestment in public and environmental outcomes.
  • Profitability was prioritised over pollution control, infrastructure maintenance, and climate resilience.
  • This legacy of underinvestment needs to be corrected—not by boosting returns, but by ensuring that future investment is tied to environmental performance and public benefit.
  • Privatisation has failed. It created a system that rewarded short-term profit extraction while neglecting long-term infrastructure and public service.

By contrast, many European countries operate water systems under public or municipal ownership, using revenue to directly invest in infrastructure, environmental protection, and service delivery. For example:

  • Paris brought water services back under public control in 2010. In the first year alone, the city saved €35 million, froze water bills, and established a public board that includes citizen and environmental group representation.
  • In Austria, privatisation of water services was constitutionally banned in 2019. Wastewater treatment is managed locally, with regional communities enacting their own regulations.
  • In Sweden, water and sewage systems are not allowed to operate for profit. Fees are limited to covering new investments, and any bill increases must be approved at the regional level.
  • Denmark applies the ‘polluter pays’ principle. Wastewater charges are based on pollutants like phosphorus, nitrogen, and organic material, creating strong incentives for innovation and environmental efficiency. Revenue caps replace competitive market pressure, setting a four-year ceiling on company income—resulting in lower prices, greater innovation, and more efficient operations.

These systems often make use of public financing tools, such as issuing state-backed bonds at lower interest rates (typically 4–5%), which enable long-term investment without extracting profit for shareholders.

The UK should learn from these examples—using public-interest financing and democratic oversight to build the infrastructure and climate resilience our water system urgently needs.

A strong regulatory framework is essential to ensure that water company returns are proportionate, accountable, and directly tied to long-term improvements—not short-term shareholder gain.

Explanation:

This question asks what changes might encourage the right kind of investment—focused on infrastructure, clean rivers, and long-term resilience—rather than profit extraction.

Guidance
The goal should not be to simply attract more investment—it should be to attract the right kind of investment: investment that delivers for the environment, communities, and long-term resilience, not just shareholder profits.

A wholly privatised investment model has failed. It must be replaced with new finance and governance structures that prioritise public benefit and environmental protection, not shareholder gain.

It’s not just about more money—it’s about the right type of investment, on the right terms, within the right ownership structure.

Key points to consider in your response:

  • Tie investment to outcomes
    Investors should only profit if companies meet strict environmental and infrastructure goals—like reducing sewage spills, fixing leaks, and upgrading systems.
  • End pollution for profit
    No investor should benefit while rivers are being polluted. Investment must be channelled into preventing harm, not enabling it.
  • Ring-fence reinvestment
    A portion of all investment should be legally directed into capital upgrades and environmental protection—ensuring the money stays in the system.
  • Stronger oversight of investor behaviour
    Some investors, especially private equity, have extracted value without improving services. Oversight must guard against short-termism and speculative ownership.
  • Use better ownership models to support better investment
    The best way to attract the right kind of investment is by adopting alternative ownership models that are already working in other countries and sectors:

    • Model 1: Nationalisation – full public ownership, run for public good
    • Model 2: Not-for-profit companies – like DĆ”r Cymru Welsh Water, which reinvest all surplus into the system
    • Model 3: Public Benefit Companies – legally required to deliver social and environmental good
    • Model 4: Municipal ownership – where local authorities run water services for local benefit
    • Model 5: Regional water authorities – publicly owned, managing water at catchment scale
  • These models attract investment from institutions and investors that understand that water quality, customers, and nature must come before excessive returns. And with government oversight and operating for public benefit, the risk to investors is lower, the cost of debt interest comes down, and more money stays in the system to clean up water company infrastructure.
  • Issue government-backed bonds
    Government-backed bonds would be highly attractive to investors because they are low risk and come with much lower interest rates than private borrowing. For example, Thames Water’s recent debt came at 9.75% interest, while state-backed bonds typically sit at 4–5%. This would make public-interest investment significantly more cost-effective and sustainable.

We support options that prevent money being extracted from the system without delivering real value. The current model has led to £74 billion in debt and £83 billion in dividends—with little to show in terms of infrastructure improvement or river health.

Future investment must be designed to build climate resilience, social equity, and environmental recovery—not just financial return.

Explanation
This question is asking whether negative public and political perception—like media coverage of sewage spills or criticism of executive bonuses—makes it harder for water companies to attract investment.

Key issues to consider

  • Public backlash is based on real failures—like pollution, underinvestment, and rising bills—not just perception.
  • The issue isn’t too much scrutiny, but too little accountability.
  • Water companies can rebuild trust and improve investor confidence by demonstrating that they are investing properly, acting transparently, and prioritising the environment.

Guidance
We do not recommend selecting “Negatively affects the attractiveness of the sector”, as this could be used to argue for reduced public oversight or media criticism.

Instead, you may want to choose:

  • “Does not affect the attractiveness of the sector” – to highlight that responsible investors will support well-run companies with strong environmental and financial performance.
  • Or select “Other” and explain that:

Public and political criticism has been a justified response to real failures—including widespread sewage pollution, years of underinvestment, and the extraction of billions in dividends while infrastructure crumbles.

This public scrutiny isn’t the problem—it’s part of the solution. It’s what has driven momentum for change, including the March for Clean Water, where thousands of people across the country came together to demand that the Government:

  • End pollution for profit
  • Enforce the law
  • Reform the regulators

These are not radical asks—they are the bare minimum for protecting our rivers and rebuilding public trust.

Importantly, the Government has already committed to clean up rivers and end pollution as one of its top manifesto priorities. If it wants to keep the public—and voters—on side, it must deliver. People are watching.

Public trust is not a threat—it’s the path to rebuilding investor confidence. Companies that take accountability seriously, reinvest in infrastructure, and demonstrate long-term commitment to environmental protection will not be driven away by public scrutiny—they will be strengthened by it. That’s what attracts responsible, long-term investors.

Q48-51

Competition

Lower Priority.

Most relevant to anyone interested in how the structure of the water industry affects accountability, investment, and long-term outcomes.

Explanation
This section is about whether introducing more competition into certain parts of the water sector would improve outcomes—such as efficiency, service, or innovation. Since water is a natural monopoly, competition is limited to specific areas like business retail services, infrastructure projects, and developer services (e.g. new connections).

The Commission is asking:

  • Are existing competition schemes working?
  • Should more competition be encouraged in certain areas?
  • Would it be better to focus on strong public regulation instead?

Guidance
At River Action, our focus is on clean rivers and environmental protection. While competition affects the overall structure of the water industry, it’s not central to our work on pollution, enforcement, and public accountability—so we are not offering detailed recommendations in this section.

However, if you do choose to respond, here are some key points to consider:

  • Should competition exist in a natural monopoly?
    The water industry is not like energy or telecoms—customers can’t switch suppliers. Rather than introducing more market players, some argue that tighter regulation and public ownership would be more effective.
  • Could the regulator be the driver of performance?
    Instead of trying to create artificial markets, Ofwat and the Environment Agency could focus on enforcing higher standards, increasing penalties, and ensuring investment goes where it’s needed.
  • Have competition schemes delivered results?
    Several initiatives—like the business retail market—have seen low uptake and limited benefit. If they’re not improving service or investment, should they be reformed or replaced?
  • Would nationalisation or not-for-profit models deliver better value?
    Public ownership could remove the profit motive and ensure water services are run in the public interest, with a clear focus on sustainability and river health.

Q52

Water Industry Public Policy Outcomes

Medium Priority.

For anyone interested in environmental regulation, enforcement, water law, or systemic reform.

Explanation:

This section is about the legal and regulatory rules that govern water companies—especially those introduced over the past 30 years to protect drinking water, the environment, and long-term water supply. The Commission wants to know:

  • Are these requirements working?
  • Are they clear, enforceable, and joined up?
  • Or have they become too complex or inconsistent—potentially leading to loopholes or poor enforcement?

Guidance
We suggest supporting a review only if the aim is to strengthen protections and close enforcement gaps – not to make life easier for polluters. The issue isn’t a lack of law – it’s that existing laws aren’t being properly enforced.

You could recommend:

  • Tightening permits and improving enforcement – for example, existing laws already ban untreated sewage discharges outside of rare circumstances, but regulators must ensure permits reflect this and are enforced
  • Improving coordination between regulators – clearer roles across the Environment Agency, Ofwat and DWI could help close loopholes and stop blame-shifting
  • Focusing regulation on outcomes – not just tick-box processes, but real-world improvements in water quality, infrastructure, and climate resilience
  • Resisting deregulation disguised as simplification – some companies argue the rules are too complex, but the bigger problem is weak accountability and a lack of will to enforce what already exists

If you respond yes, be clear that any review must strengthen, not weaken, the system – and ensure companies are held to account.

Q53-55

Protecting the Environment

Higher Priority.

For everyone – this is core to holding water companies accountable.

Explanation
This is one of the most important parts of the consultation. It focuses on whether environmental regulations for water companies are working: are they strong enough, enforced properly, and keeping up with new threats?

The Commission is asking:

  • Are companies being held to environmental standards—or getting away with pollution?
  • Is monitoring effective—or do we need more independent oversight?
  • Is enforcement too slow or weak?
  • Are new threats (like microplastics, climate impacts, or PFAS) being properly addressed?

Key points to consider

  • The current system is failing. If environmental regulation were working, we wouldn’t be seeing record levels of sewage pollution, failing treatment works, and repeated breaches by water companies.
  • Self-monitoring doesn’t work. Many companies report on their own pollution, with little independent verification. Independent, real-time monitoring must be expanded.
  • Enforcement is too slow. Penalties often take years to materialise—and are too small to deter repeat offences. Faster enforcement and tougher penalties are essential.
  • New threats need attention. Microplastics, climate-driven flood risks, PFAS (‘forever chemicals’), and antibiotic-resistant bacteria are not adequately tackled in the current regulatory system.
  • Reform must mean strengthening—not weakening. Any review or consolidation of environmental law should lead to clearer, tougher protections and better accountability—not deregulation.

Explanation:
The overwhelming evidence suggests that current environmental regulations are failing to ensure water company compliance.

Key points to consider:

  • In 2023 alone, 3.6 million hours of sewage were discharged into English rivers.
  • Sewage spills increased by 54% between 2022 and 2023, and in 2024 they remained at this high level—demonstrating that current enforcement is failing to act as a deterrent.
  • Since 2015, the Environment Agency has secured only 63 prosecutions, resulting in just ÂŁ151 million in fines—a tiny fraction of water company profits.

Guidance:
We recommend selecting “Very little” or “Not at all” to reflect the clear failure of the current regulatory system to stop pollution and protect the environment.

 The Commission is asking how the legal framework for environmental protection should change.

Key facts to consider
 Only 14% of rivers in England currently meet good ecological status.
–  Current government targets aim to restore 77% of rivers by 2027, yet the government is now only confident that 21% of those targets will be met.
–  In 2023, 3.6 million hours of sewage spills were recorded – a 54% increase from 2022 – and in 2024, they remained at this high level.
–  Since 2015, the Environment Agency has brought just 63 prosecutions, resulting in ÂŁ151 million in fines – while the sector has paid over ÂŁ83 billion in dividends since privatisation.

Recommended selections
Legislative reforms to address current and emerging threats – to ensure laws keep up with modern pollution challenges, such as microplastics, pharmaceuticals, and chemical contaminants.
A review and rationalisation of the environmental legislative framework – but only if the aim is to simplify and strengthen protections, not to weaken them.
Other – if you have time, this is a great option to offer your own detailed suggestions. It allows you to explain where gaps in regulation exist or what stronger protections you’d like to see.

Guidance if selecting ‘Other’
Here are ideas you may want to include if choosing the ‘Other’ option:

  • Strengthen the legal duty on water companies to prevent pollution, not just minimise it where convenient.
  • Enforce existing environmental laws more effectively – pollution is often illegal but tolerated due to lack of enforcement.
  • Provide the Environment Agency with greater powers and funding to act quickly and independently.
  • Introduce a legal ‘polluter pays’ principle – it should be more expensive to pollute than to comply with environmental protections.
  • Close loopholes that allow companies to operate under outdated or lenient environmental permits.

Explanation
This question asks what changes are needed to improve how water companies are monitored and held accountable. It covers issues like self-monitoring, inspections, and how quickly enforcement happens when environmental rules are broken.

Guidance
We recommend selecting all three of the following options, as well as “Other” to strengthen your response:

  • “Enhanced monitoring, including reform of operator self-monitoring” – to push for independent oversight, not just self-reporting by companies.
  • “Expanded use of inspections and audits” – to ensure regulators actively check compliance rather than relying on company-supplied data.
  • “Swifter enforcement” – so that water companies face immediate and meaningful consequences when they break the law.

Why we also recommend selecting ‘Other’
The listed changes are important, but they don’t go far enough. Choosing “Other” gives you the opportunity to call for stronger deterrents and more systemic change.

What to include under ‘Other’

  • End operator self-monitoring – Water companies should not be allowed to monitor their own pollution. Independent verification and greater public transparency of environmental performance data are essential.
  • Introduce tougher penalties – Fines should be proportionate to company revenue to make pollution financially unsustainable. A clear and escalating enforcement framework is needed, including routine use of criminal prosecutions, not just civil sanctions (non-criminal penalties), which are often treated as a cost of doing business.
  • Hold senior executives accountable – In cases of repeated or serious breaches, company leaders should face criminal penalties to ensure real accountability at the top.
  • Require mandatory reinvestment of profits – Water companies should be legally required to reinvest a portion of their profits into sewage treatment, infrastructure upgrades, and pollution prevention.

Ringfence enforcement revenue – Money raised through fines and penalties should be ringfenced for catchment restoration and boosting regulator capacity, not used to plug Treasury gaps. Although there was an announcement earlier this year suggesting fines would be reinvested in clean-ups, reports indicate the Treasury is still seeking to retain the funds for general use (Guardian, Jan 2025).

Q56

Delivering Clean Drinking Water

Lower Priority.
For anyone from communities concerned about drinking water safety or supply issues.

Explanation:

This section looks at how drinking water is regulated to ensure it stays safe and high quality. The Drinking Water Inspectorate (DWI) is the regulator responsible for making sure water companies meet safety standards. The Commission is asking whether:

  • Drinking water standards need updating to stay world-leading
  • The DWI should have stronger powers, especially over new supply systems
  • There are barriers to innovation in water supply infrastructure

Guidance:
At River Action, our focus is on clean rivers and tackling pollution, so drinking water regulation isn’t a core part of our work. However, we recognise that safe drinking water is essential—especially in light of recent incidents.

In 2024, Brixham saw a major outbreak of cryptosporidium in its water supply, making thousands ill. It showed how urgently we need strong oversight, better infrastructure, and swift enforcement when things go wrong.

If you do want to respond to this section, you might consider:

  • Should drinking water standards reflect new risks like microplastics or PFAS?
  • Does the DWI need more power to act quickly when contamination is found?
  • Are there outdated barriers stopping innovation or upgrades in water infrastructure?

While we’re not giving detailed guidance here, we support strong regulation, public transparency, and rapid enforcement when water quality is at risk.

Q57-58

Securing Resilient Water Supply

Low Priority.
For anyone from communities that are susceptible to lack of supply.

Explanation:
This section focuses on how we secure a long-term, resilient water supply in the face of climate change and population growth. Without action, the UK could face a significant water supply gap by 2050.

Water companies are expected to plan ahead using Water Resources Management Plans and Drought Plans, but current systems may not be doing enough to futureproof our water supply or protect rivers and wildlife during shortages.

The Commission is asking:

  • Is the current water regulatory system strong enough to ensure reliable supply?
  • Should we reduce demand through efficiency policies and water-saving measures?
  • Should we change the way water is abstracted from rivers, especially during dry periods?
  • Would an integrated water management framework help ensure more joined-up thinking between agencies, companies, and communities?

This section also considers whether there should be new duties or standards placed on water companies to improve long-term planning, better balance demand and supply, and avoid further environmental damage.

Explanation:
The current regulatory system is not doing enough to ensure a secure, climate-resilient water supply. Key concerns include:

  • Leakage remains a major issue – Around 20% of water supply in England and Wales is lost to leaks.
  • Thames Water alone leaks 570 million litres a day, showing chronic underinvestment in infrastructure.
  • Climate change is expected to reduce summer river flows by up to 45% by 2050, placing greater strain on water sources.
  • No new reservoirs have been built since 1992, despite population growth and increasing drought risk.

Guidance:
We recommend selecting “Very little” or “Not at all” to reflect the failure of the current system to secure long-term water supply.

Explanation:
This question is asking how the current system could be improved to ensure there’s enough clean, reliable water for the future. With climate change, population growth, and extreme weather on the rise, the UK faces serious risks to its long-term water supply. 

Recommended selections:

  • Integrated water management framework to improve the management of the water system – A more holistic approach is needed to balance supply, demand, and environmental protection across catchments.
  • Changes to regulatory responsibilities or introduction of new requirements or standards to oversee delivery – Regulation must be strengthened to ensure water companies invest in infrastructure and reduce wastage.
  • Abstraction reform – Over-abstraction is damaging ecosystems, especially in sensitive areas like chalk streams. Reform is needed to ensure rivers are protected, even in times of drought.
  • New water demand and efficiency policies – Tighter rules on water efficiency are needed to drive down waste, improve household and business efficiency, and promote conservation.

“Other” – if you have time, we recommend selecting this and including more specific suggestions. These could include:

  • Stronger accountability measures – Companies should be held to clear leakage reduction targets, with penalties for failure.
  • New reservoir construction and long-term planning – Investment in new infrastructure is essential to meet growing demand. The Environment Agency has committed to seven new reservoirs by 2050 – but estimates suggest as many as 30 may be needed to close the supply gap. Without stronger delivery oversight, existing plans fall far short.
  • A national strategy to reduce unsustainable abstraction – River flows must be protected as part of future water security planning.
  • Protect rare streams and limit over-abstraction
    Only 73% of groundwater bodies in England currently meet ‘Good quantitative status’, highlighting the urgent need for reform to protect our water sources. This is especially critical for vulnerable ecosystems like chalk streams and SSSI-designated rivers, which are being pushed to the brink by over-abstraction.

Q59-64

Infrastructure and Supply Chain Resilience and Security

Lower Priority.

For anyone interested in whether water companies are investing in infrastructure resilience and security.

Explanation:

This section looks at whether water companies have the infrastructure and supply chains needed to deliver secure, resilient water services. It covers:

  • Infrastructure resilience – Are water companies maintaining assets (pipes, treatment plants, reservoirs) to withstand climate change and population growth?
  • Infrastructure security – Are systems protected from cyber attacks and physical risks?
  • Supply chain risks – Can water companies secure key materials (like treatment chemicals) during disruption?

Guidance:

At River Action, our focus is on preventing pollution and ensuring water companies invest in environmental protection. While resilient infrastructure supports these goals, this section centres more on operational planning, funding mechanisms, and security policy—areas outside our core mission.

That said, we recognise that well-maintained infrastructure reduces sewage spills and water wastage. If you choose to respond, consider the following:

Key points to consider:

  • Infrastructure is not being maintained properly – 20% of water supply is lost to leaks. Thames Water alone loses 570 million litres per day.
  • Investment has been neglected – No new reservoirs have been built since 1992, despite growing demand.

How to answer these questions:

  • If you believe companies are underinvesting in resilience and long-term planning, you may wish to select “Somewhat hinders” or “Significantly hinders” for Questions 59–61.
  • For Questions 62–64, consider advocating for:
    • Stronger requirements on infrastructure maintenance (to prevent leaks and pollution)
    • Greater transparency around investment decisions (so money goes to resilience, not shareholders)

Better coordination across government and industry to reduce supply chain risk and improve system security

Q65-67

Innovation and Technology

Medium Priority

This section is most relevant to people and organisations interested in innovation, nature-based solutions, recreational water quality, and technological approaches to improving water quality, treatment, and infrastructure.

Explanation:
This section asks whether the water industry is doing enough to innovate—and whether the regulatory system is helping or hindering new technologies and ideas. The Commission is exploring whether:

  • Water companies and regulators are too risk-averse, relying on traditional engineering over newer, less-tested approaches.
  • Existing regulations make it difficult to trial or adopt innovative technologies.
  • The Price Review process should treat research and development differently to encourage long-term investment.
  • New technologies—like real-time pollution tracking or AI monitoring—could improve how water is managed and regulated.

Key points to consider:

  • Innovation must serve the environment. Support for innovation should never come at the cost of weaker pollution laws or less accountability for water companies.
  • Funding structures matter. Right now, companies can be discouraged from investing in R&D because of how costs are treated in the Price Review. That needs to change.
  • Many solutions already exist but aren’t being used. For example, real-time pollution tracking technology is available but underused by water companies.
  • Enforcement could benefit from tech. Tools like remote sensing, AI detection of pollution events, and automated water quality testing could strengthen regulatory enforcement.

Tertiary Treatment and Why We Support It
Tertiary treatment is the final stage of wastewater treatment that removes pathogens like bacteria and viruses before water is released into the environment. One of the most effective methods is Tertiary UV (ultraviolet) treatment, which disinfects water without chemicals.

At River Action, we support Tertiary UV treatment in high-use recreational areas like Henley and near Mogden STW, where many people swim, row, and spend time in the water. Without it, harmful pathogens can put public health at risk. We believe investing in this treatment would make rivers safer and ensure water companies take greater responsibility for their impact.

Explanation:
This question asks whether water companies and regulators are encouraged—or held back—when it comes to adopting new technologies and approaches, including nature-based solutions.

Guidance:
We believe the current system somewhat hinders innovation. While new solutions exist, they aren’t being rolled out at scale. Regulation tends to favour traditional engineering fixes and doesn’t provide enough support or incentives for newer approaches—especially those that deliver environmental benefits.

We recommend selecting: “Somewhat hinders innovation”.

This reflects that innovation is possible, but not well supported—particularly when it comes to solutions that could clean up rivers and improve public health, like nature-based systems and Tertiary UV treatment.

Explanation
This question asks what regulatory changes could help water companies adopt new technologies and approaches to improve water quality, reduce pollution, and increase system resilience.

Guidance
We recommend selecting all of the following:

  • “Changes to the way companies and regulators approach risk” – A more flexible, risk-tolerant approach would allow for real-world testing of innovative solutions, including new pollution controls and nature-based approaches.
  • “More outcome-based regulation” – This allows companies to meet environmental targets using the most effective tools available, rather than sticking to outdated or rigid methods.
  • “Changes to the Price Review process” – Separating out research and development funding would better support longer-term innovation and remove barriers to trialling new approaches.

Why we suggest also selecting “Other”
The options listed don’t cover some of the most promising and urgent innovation opportunities—especially those that benefit both people and nature.

  • Tertiary UV treatment → Invest in Tertiary UV treatment of wastewater in areas where water quality is critical for recreation, such as popular bathing, rowing, or paddleboarding sites located near sewage treatment works.
  • Nature-based solutions → Prioritise funding and delivery of nature-based solutions like constructed wetlands and sustainable drainage systems (SuDS), which improve water quality while also supporting biodiversity and climate resilience.
  • Trialling new technologies in high-risk areas → Introduce regulatory mechanisms that require companies to trial innovative technologies—particularly in failing catchments or areas of poor water quality.
  • Open access to innovation data → Mandate public sharing of results from innovation trials, so that lessons can be shared and scaled across the sector.

Catchment-aligned innovation → Build innovation into catchment planning to promote joined-up thinking and integrated environmental solutions.

New technologies offer major opportunities to reduce pollution, improve oversight, and make the water industry more transparent and accountable—but only if companies are required to invest in them and regulators are empowered to act on the data.

Opportunities to highlight:

  • Real-time pollution tracking – Sensor networks and AI tools can provide live monitoring of sewage overflows and pollutant levels, allowing faster intervention and increasing transparency. This can also support citizen oversight and public trust.
  • Tertiary UV treatment – This advanced form of wastewater treatment significantly reduces bacteria and viruses. It is especially important in areas of high recreational use (e.g. Henley, Mogden STW), where untreated pathogens pose serious health risks.
  • Nature-based solutions – Wetlands, reedbeds, and other green infrastructure can naturally filter pollutants and offer climate and biodiversity benefits. These approaches should be mainstreamed and prioritised, not treated as niche or experimental.
  • Smarter data for prevention – AI analysis of catchment data could help identify pollution risks earlier, informing land-use decisions and preventing harm before it occurs.
  • Stronger public transparency – New technology should be used not just for internal monitoring but for public reporting. Live pollution data would empower communities and increase accountability.
  • Integrating citizen science and community tech – Technology can enable trusted, decentralised monitoring. For example, low-cost sensors, smartphone apps, and open-source data platforms allow communities to gather and share pollution data. Regulators and companies should embrace these innovations, creating formal pathways for citizen science data to inform enforcement and planning.

Q68-73

Ownership

Higher Priority

This section is for everyone and focuses on stopping pollution being profitable

Explanation:
This section focuses on who owns and controls water companies—and whether different ownership models lead to better outcomes for people, rivers, and the environment. Since privatisation in 1989, most water companies in England have been privately owned, many by private equity firms, pension funds, or international investors. DĆ”r Cymru/Welsh Water operates under a not-for-profit model. Across Europe, water services are managed through a variety of systems, but public authorities are generally responsible for approving tariffs, determining service quality and establishing and enforcing environmental and health standards.

The Commission is asking:

  • Have company mergers improved or worsened performance?
  • Does being listed on the stock exchange affect company accountability or priorities?
  • How do complex financial structures (like Whole Business Securitisation) impact behaviour?
  • Do investor types matter—are private equity firms worse for the environment than pension funds?
  • Has the Welsh not-for-profit model delivered better outcomes?

River Action’s position:
We believe the current private ownership model has led to widespread underinvestment, financial mismanagement, and failure to protect the environment.

  • Water companies have racked up ÂŁ74 billion in debt since privatisation, while paying out ÂŁ85 billion in dividends.
  • Pollution has become profitable, with companies focusing on shareholder returns instead of fixing leaks or improving treatment plants.
  • Private equity ownership often prioritises short-term gains, not long-term river health or infrastructure.
  • We believe water should be managed for public good, not private profit.
  • Models to consider instead are public ownership, municipalities ownership, regional water authorities, not-for-profits (learning from the poor performance of the Welsh model), or Community Interest Companies (with the correct mission in place). 

Alternative Ownership Models We Support:

Model 1: Public Ownership  

River Action supports full public ownership of water. While the current government has ruled this out, we recommend the Commission recognise the strong public interest in the idea and consider its strengths and weaknesses by looking at publicly owned models across Europe.  

Direct public management involves the public authority being fully responsible for providing and managing the service, a model that was once dominant across Europe. Countries such as Austria, Bulgaria, Croatia, Cyprus and Finland are examples of this. 

In delegated public management, a public authority appoints a separate entity, still publicly owned in most cases, to carry out management tasks. However this sometimes allows for limited private ownership. Belgium, France, Greece and Ireland are the best known examples. 

In delegated private management, a private company is contracted to manage services for a defined period, typically through lease or concession agreements, while ownership of the infrastructure remains with the public sector. This model is common in countries where municipalities subcontract their responsibilities to private firms.

Publicly owned utilities in countries such as Switzerland, Austria and France benefit from democratic oversight, value for customers, lower borrowing costs, and access to government-backed finance at interest rates significantly below those faced by private companies.

These models are not without challenges – underfunding issues, such as in Northern Ireland. The majority of European public ownership models have found success though with the essential combination of effective municipal oversight and the support of governments to back plans to modernise and invest.

If you support renationalisation, feel free to say so in your response. The models below are ones River Action also recommends the commission considers in addition to full nationalisation, and supports them as alternative reforms that may be more achievable in the short term.

Model 2: Municipalities 

Across Europe and the USA, municipalities are responsible for the democratic planning and delivery of water services, finances, governance and operations in each region, and aligned towards achieving a national strategy for sewage treatment, water quality and supply. Municipilisation saves money: Paris saved €35million and reduced the customer’s tariff by 8% in their first year of remuniciplisation). It improves infrastructure: RĂ©gie des Eaux de Grenoble has increased investments in maintenance and infrastructure renewal threefold as compared to the previous private operator improves infrastructure investment). It prevents pollution:  Paris’ Seine bacteriological pollution was reduced by 75% by the end of the Olympic Games. 

Over 180 cities and communities in 35 countries, including Buenos Aires, Johannesburg, Paris, Accra, Berlin, La Paz, Maputo and Kuala Lumpur, all turned from private to municipal water ownership between 2000 and 2014.

Model 3: Regional Water Authorities 

This would re-establish publicly owned Regional Water Authorities, like those that existed before privatisation. 

Drawing on successful European models in Austria, Sweden, and Denmark, where sewage and water systems are publicly owned and locally managed, this approach would ensure that local communities have meaningful input and oversight. In practice, these regional authorities would lead the strategic planning of water services, with private, or hybridised, operators bidding to deliver services under short-term, performance-based licenses. Accountable to government and the public, they would manage water resources for long-term environmental and public benefit, with joined-up planning and pollution control across catchments, while maintaining the potential to draw on private sector expertise and investment within frameworks that prioritise customers, the public and environment.

Model 4: Not-for-profit 

A not-for-profit organisation is a business that aims to do something other than to make profit for the owners, such as providing a public service or helping people. It needs to make enough money to cover its costs, but any surplus is reinvested into the business or used in other ways to further the objectives of the organisation and its beneficiaries.

Some not-for-profit models could allow a water company to remain in the private sector but to realign a water company’s principles and objectives to be realigned in the interest of people and the planet. 

DƔr Cymru/Welsh Water has this model and whilst it has no shareholders, it has over £5 billion in bondholders. In 2024, Welsh customers were paying 25% of their bills to these bondholders. 

This trading of bonds on foreign exchanges may reduce transparency, and key decision-makers within the organisation may have more concentrated authority than directors of PLCs, with just two operational directors in the organisation who have more decision making power than the boards of a PLC. Therefore, as a not-for-profit private limited company DƔr Cymru/Welsh Water are less transparent than many other models. 

DĆ”r Cymru/Welsh Water was responsible for 105,943 sewage spills in 2023, and Ofwat currently rates the company as “lagging behind” across key metrics. The Drinking Water Inspectorate rated Wales as the worst performer on water quality in 2024. Performance is “poorer than target” on 7 of 12 regulatory indicators, including pollution, drinking water quality, and leakage. In 2023, DĆ”r Cymru/Welsh Water was fined ÂŁ40 million for providing misleading data and failing on governance over a five-year period. 

This points to the need to consider other not-for-profit examples than DƔr Cymru/Welsh Water when considering this model, and that all water companies, however they are owned, still need tough holistic regulation to ensure they are compliant with the law. This can only be achieved with well-funded, empowered and independent regulators which are accountable to the public and parliament. This should be in combination with municipal oversight of the planning, funding and operations of a water company at local and national levels as we see across Europe.

Model 5: Public Benefit Company/Community Interest Company

Community Interest Companies (CICs) are limited companies which operate to provide a benefit to the community they serve. 

They are still private companies, allowing private investment to bring in capital for infrastructure investment. Whilst they would still expect to pay shareholder dividends this can only happen when community interest is met (e.g. environment, climate, public health, and bill pricing), hugely incentivised these targets for the board and executives. Dividends are also capped to a maximum of 35% of profits (in contrast, in 2023-2024 Severn Trent paid out dividends at 215% of profits and Yorkshire water paid out dividends worth 125% of profits according to a SAS report to be published April 2025) meaning better value for customers’ money than publicly-traded companies. 

Assets are locked so if the CIC dissolves or fails, it cannot be sold to for-profit businesses, only charities or CICs with a similar community-interest mission. 

You might want to recommend to the Commission that they require all water companies to convert to a CIC model (or a US Public Benefit Company model). 

Explanation:
This question asks whether merging smaller companies into larger ones has improved or worsened performance in areas like pollution, infrastructure, and accountability.

Guidance:
We recommend answering that consolidation has had a negative impact or has not improved performance. Bigger companies have not led to better outcomes—and have often made things worse.

Key points to include in your response:

  • Too big to manage – Consolidated companies are harder to regulate and oversee, leading to weaker enforcement and accountability.
  • Lack of local focus – As companies grow, they often become more distant from local communities and slower to respond to local environmental issues.
  • More complex finances – Consolidation has often gone hand-in-hand with financial restructuring, making it harder to trace spending or understand company priorities.
  • No real performance improvements – Despite consolidation, we’ve seen record sewage spills, high leakage, and decades of underinvestment.

    You could say that reversing consolidation—for example, through more regional models or public benefit companies—might help improve responsiveness, transparency, and reinvestment into local infrastructure and river health.

Explanation:
This question asks whether publicly listed companies (those on the stock exchange) perform differently to privately held ones. It’s about how ownership models affect company behaviour, investment, and environmental performance.

Guidance:
We suggest responding that stock exchange listing (and similar foreign bond exchange for DƔr Cymru/Welsh Water) has resulted in poor company performance and has instead focused on short-term profit pressures.

Key points to include in your response:

  • Focus on shareholder (and bondholder) returns – Stock (and bond) market listing increases pressure to deliver short-term returns, often at the expense of long-term investment in infrastructure and the environment.
  • Dividends over rivers – Companies listed on the stock exchange (or trading bonds) have paid out billions in dividends, even while failing to stop pollution or leaks.
  • Lack of environmental accountability – Listed companies are accountable primarily to profit motivated shareholders, not the public or the environment.
  • No link to better outcomes – Being publicly listed (or issuing bonds) has not led to improved service, reduced pollution, or stronger investment in resilience.

You may wish to add that ownership models focused on public benefit or reinvestment, such as public-owned, municipality-owned, regional water authorities, Community Interest Companies, or Not For Profit models, have the potential to be more aligned with long-term environmental and public service goals, if they can avoid similar systems to the stock exchange e.g. whilst DƔr Cymru/Welsh Water is a not for profit, its bonds are traded on the bond market lead to it suffering from all the same weaknesses as those listed on the stock exchange  

Explanation:
This question is about whether complicated financial structures—like Whole Business Securitisation (WBS)—are undermining how well water companies function. These setups were designed to attract investors by using your water bills as security. But instead of improving performance, they’ve made things worse.

WBS allows companies to take on huge debts while still funnelling profits to shareholders. It also creates layers of financial complexity that make it much harder for regulators to spot risks or enforce accountability in time.

Example:
Thames Water is a well-known example. It used WBS to borrow over £14 billion but failed to invest adequately in its ageing infrastructure. Now it’s in financial crisis—and the public may end up footing the bill.

Its parent company, Kemble Water Holdings Ltd, sits at the top of a tangled corporate web with at least six known layers of ownership between it and Thames Water Utilities Ltd, the operating company that holds the licence to supply water and manage sewage. This complex structure makes it extremely difficult for regulators—like Ofwat and the Environment Agency—to track financial decisions, regulate effectively, or enforce the law when things go wrong.

Alternative Structures:
These financial structures are not a one-off—they are a feature of a broken system. Privatisation has failed. It has created a water sector that prioritises financial engineering over clean rivers, climate resilience, and public service. We need a fundamental shift in ownership and governance.

There are better alternatives:

  • Model 1: Public Ownership– Bringing water into full public ownership and democratic oversight
  • Model 2: Municipal ownership – Putting water back in local hands
  • Model 3: Regional water authorities – Managing water catchments as public assets
  • Model 4: Not-for-profit models – Learning from the flaws of the DĆ”r Cymru/Welsh Water model. 
  • Model 5: Public benefit companies – Legally required to deliver social and environmental good with capped profits.

Guidance:
These structures have:

  • Obscured accountability and delayed regulatory action
  • Enabled unsustainable debt while still paying dividends
  • Reduced investment in infrastructure and pollution control
  • Put profit ahead of people, public health, and the environment

Suggested response:
You could say that these structures are a symptom of a failed privatised model. They’ve made company performance worse by enabling risky behaviour, hiding responsibility, and blocking public accountability. It’s time for a water system run for people and planet—not for profit.

Explanation:
This question is asking whether it matters who owns our water companies—and the answer is yes, it matters a great deal.

Private equity investors often extract short-term profit, driving up debt while neglecting infrastructure. Even long-term investors like pension funds expect stable returns, often limiting how much or how quickly companies invest in environmental improvements. Offshore and foreign investors are often completely unaccountable to the UK public.

This is not just about bad investors—it’s about a failed system. Privatisation has failed. Since it began, water companies have paid out £85 billion in dividends and racked up £74 billion in debt, while allowing pollution, leaks, and public dissatisfaction to spiral. Companies continue to pay out profits even when their performance is deteriorating.

We need to move beyond this broken model. The future of water should be public, transparent, and accountable. Alternative ownership options include:

  • Model 1: Public Ownership, bringing water into full public ownership and democratic oversight
  • Model 2: Municipal ownership – Putting water back in local hands
  • Model 3: Regional water authorities – Managing water catchments as public assets
  • Model 4: Not-for-profit models – Learning from the flaws of the DĆ”r Cymru/Welsh Water model.
  • Model 5: Public benefit companies – Legally required to deliver social and environmental good with capped profits.

Guidance:
The current ownership and investment model is at the root of many sector-wide failures.

  • Companies prioritise investor returns over public service
  • Infrastructure has been neglected while pollution worsens
  • Complex ownership structures hide accountability and delay action

Suggested response:
You might want to say that investor ownership has driven harmful decisions that are against the interest of customers and our environment, and that we need a clean break from this profit-first model. Public benefit must come before shareholder gain. The water sector needs democratic, and publicly accountable ownership—so investment serves the public, not distant investors.

Note: These questions are targeted at those who live in Wales or are part of an organisation that operates in Wales. 

Explanation:
This question asks whether the not-for-profit model used by DƔr Cymru/Welsh Water has delivered better outcomes than the private, profit-driven models used across England.

Guidance:
If you live in Wales and have experience with DƔr Cymru/Welsh Water, you may wish to answer that this example of the not-for-profit model has not been effective in driving improved outcomes and has had a similarly poor performance to private, profit-driven water companies, due to its high debt servicing to bondholders.

Facts to support your view:

  • Despite its not-for-profit status, DĆ”r Cymru/Welsh Water was responsible for 105,943 sewage spills in 2023, and Ofwat currently rates the company as “lagging behind” across key metrics. Performance is “poorer than target” on 7 of 12 regulatory indicators, including pollution, drinking water quality, and leakage.
  • DĆ”r Cymru/Welsh Water has over ÂŁ5 billion debt in bonds. Welsh customers were paying 25% of their bills to these bondholders. 
  • Approximately 41% of DĆ”r Cymru/Welsh Water revenue goes to servicing debt from bonds (according to studies by the University of Greenwich), this is a higher proportion than in both privatised water companies (35%) and publicly owned Scottish Water (8%).
  • Alternative not-for-profit models could enable investment in critical infrastructure that can bring about lower customer bills over time. For example, residential electric bills from Texas not-for-profit Austin Energy tend to be lower when compared to other utilities in Texas. Austin Energy is able to sell surplus energy generation onto the Texas grid and use the profit to invest in future energy efficiency measures. 
  • DĆ”r Cymru/Welsh Water is owned by Glas Cymru whose self-selecting governance model is members appointed by Glas Cymru’s board to ensure that the Board and senior management act in the best interest of the company. Therefore, as a not-for-profit private limited company they bypass public scrutiny.
  • Austin Energy is led by a ‘Utility Oversight Committee’, formed from elected council members, with a democratic responsibility to the residents of Austin City, Texas, USA.

Note: This question is mainly targeted at Welsh residents, as it relates specifically to DĆ”r Cymru/Welsh Water’s ownership model.

Explanation
This question is asking if there are any downsides to DĆ”r Cymru/Welsh Water’s not-for-profit model – and how it compares to other models, like publicly listed companies, publicly owned companies, or community interest companies.

A not-for-profit organisation is a business that aims to do something other than to make profit for the owners, such as providing a public service or helping people. It needs to make enough money to cover its costs, but any surplus is reinvested into the business or used in other ways to further the objectives of the organisation and its beneficiaries.

Guidance

The not-for-profit model could allow a water company to remain in the private sector, but realign its principles and objectives to the interests of people and the environment.

However DƔr Cymru/Welsh Water is a bad example of the not-for-profit model as it has succumbed to the risks of high debt to bondholders, opaque governance, and poor performance and environmental outcomes.  

If you want to recommend the commission look at wholly or hybrid not-for-profit models, it may be worth suggesting the Commission take a holistic look at ownership, governance, regulator enforcement, and public and parliamentary oversight when doing so. You may also want to suggest the Commission consider alternative not-for-profit examples to DƔr Cymru/Welsh Water, like  Austin Energy or Brixton Energy.

Alternatively, you may want to suggest the commission consider a different model you prefer; we’ve outlined the models we’d recommend in this section’s “Section Explanation”.

Key points to consider:

  • Not-for-profit models could enable investment in critical infrastructure that can bring about lower customer bills over time but are at risk of difficult to manage debt without effective regulation, as evidenced by DĆ”r Cymru/Welsh Water bond debt under Ofwat’s regulation.
  • Not-for-profits are at risk of opaque governance with little oversight from the public or parliament if the right governance model is not in place, as evidenced by DĆ”r Cymru/Welsh Water’s and Glas Cymru’s governance models. 
  • Not-for-profits are at still at risk of delivering poor performance for customers and the environment without well-funded, empowered, and independent regulators which are accountable to the public and parliament, as evidenced by DĆ”r Cymru/Welsh Water’s performance under Natural Resources Wales’ regulation and Ofwat.

 Facts to support your view:

  • Despite its not-for-profit status, DĆ”r Cymru/Welsh Water was responsible for 105,943 sewage spills in 2023, and Ofwat currently rates the company as “lagging behind” across key metrics. Performance is “poorer than target” on 7 of 12 regulatory indicators, including pollution, drinking water quality, and leakage.
  • DĆ”r Cymru/Welsh Water has over ÂŁ5 billion debt in bonds. Welsh customers were paying 25% of their bills to these bondholders. 
  • Approximately 41% of DĆ”r Cymru/Welsh Water revenue goes to servicing debt from bonds (according to studies by the University of Greenwich), this is a higher proportion than in both privatised water companies (35%) and publicly owned Scottish Water (8%).It has avoided the excessive debt and dividend extraction seen across much of the English water sector.
  • Alternative not-for-profit models could enable investment in critical infrastructure that can bring about lower customer bills over time. For example, residential electric bills from Texas not-for-profit Austin Energy tend to be lower when compared to other utilities in Texas. Austin Energy is able to sell surplus energy generation onto the Texas grid and use the profit to invest in future energy efficiency measures. 
  • DĆ”r Cymru/Welsh Water is owned by Glas Cymru whose self-selecting governance model is members appointed by Glas Cymru’s board to ensure that the Board and senior management act in the best interest of the company. Therefore, as a not-for-profit private limited company they bypass public scrutiny.  It is accountable to members acting in the public interest, not to shareholders seeking profit.
  • Austin Energy is led by a ‘Utility Oversight Committee’, formed from elected council members, with a democratic responsibility to the residents of Austin City, Texas, USA.

Thank you for contributing your views to the Water Commission Call for Evidence and reading our Call for Evidence guidance; we hope it was useful.

📱 When Will We See Results? After submissions are reviewed, the Commission will make a series of recommendations to the UK and Welsh governments in June 2025.

💬 What Happens Next? Based on public feedback, the Commission will shape recommendations for government action, with a new Water Bill expected to be announced this summer.