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respond to the water commission

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

The Water Commission

Call for Evidence

is now closed

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 which questions particular groups might be most interested in. Open the Call for Evidence and then click on the group you most identify with, or go to the full questions guidance below. Answer the questions you want to, and make your voice heard.

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

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

Want to see the guidance for all the questions? Return to the full guidance by clicking below.

Recreational River User Questions Only

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

The Water Commission

Call for Evidence

is now closed

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!

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.

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.

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 £151 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 £151 million in fines – while the sector has paid over £83 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).

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. Dŵr 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 £74 billion in debt since privatisation, while paying out £85 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: Régie 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. 

Dŵr 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 Dŵr Cymru/Welsh Water are less transparent than many other models. 

Dŵr 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, Dŵr Cymru/Welsh Water was fined £40 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 Dŵr 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 Dŵr 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 Dŵr 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 Dŵr 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 Dŵr 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 Dŵr 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 Dŵr 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, Dŵr 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.
  • Dŵr Cymru/Welsh Water has over £5 billion debt in bonds. Welsh customers were paying 25% of their bills to these bondholders. 
  • Approximately 41% of Dŵr 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. 
  • Dŵr 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 Dŵr Cymru/Welsh Water’s ownership model.

Explanation
This question is asking if there are any downsides to Dŵr 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 Dŵr 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 Dŵr 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 Dŵr 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 Dŵr 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 Dŵr Cymru/Welsh Water’s performance under Natural Resources Wales’ regulation and Ofwat.

 Facts to support your view:

  • Despite its not-for-profit status, Dŵr 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.
  • Dŵr Cymru/Welsh Water has over £5 billion debt in bonds. Welsh customers were paying 25% of their bills to these bondholders. 
  • Approximately 41% of Dŵr 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. 
  • Dŵr 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.

Want to see the guidance for all the questions? Return to the full guidance by clicking below.

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.