Freshwater Habitats Trust response to the Independent Water Commission interim report
3rd June 2025
Today, the Independent Water Commission has published its interim report.
Led by Sir Jon Cunliffe, the Independent Water Commission has been tasked with examining the regulatory framework for the water sector. The ‘Cunliffe review’ is expected to inform new legislation, which will reform regulation of the water industry and the water environment.
Since the Commission was established in October last year, we’ve been engaging directly to advocate for greater recognition of small waters within the Water Framework Directive – the overarching law guiding monitoring and management of our freshwaters. Making this change would transform the way we protect freshwaters in Britain, safeguarding a much larger proportion of our freshwater environment – and ensuring that small waters, which are the backbone of freshwater biodiversity in most landscapes, are properly looked after.
Encouragingly, the Commission’s Call for Evidence document included recognition that ‘the exclusion of many small water bodies from the WFD means that a large proportion of water bodies in England and Wales are not regularly monitored’, and that ‘achieving broader environmental objectives, like the biodiversity targets in the Environment Act 2021, may be challenging without action on smaller water bodies’.
Disappointingly, these ideas are not explicitly recognised within the Commission’s interim report. The interim report isn’t intended to be exhaustive, however, and we hope that the Commission will continue to engage with us and other environmental groups to ensure that small waters are better represented within future water law.
As the Commission itself recognised in its Call for Evidence, small waters ‘make up over 70% of waterbodies in England and Wales’. In most landscapes, small waters support more plant and animal species than larger rivers and lakes. If we continue to ignore these habitats, we can’t hope to restore freshwater biodiversity.