Freshwater Habitats Trust response to the Independent Water Commission’s Final Report
25th July 2025
We’ve spent the past few days digesting the wide-ranging (and very long) Independent Water Commission Final Report by Sir Jon Cunliffe and his team, which was published on Monday 21st July.
Overall, the report makes a clear-sighted diagnosis of key issues with the water sector’s regulatory framework, and provides some sensible – if somewhat guarded – recommendations for reform of environmental regulation.
In our engagement with the Commission, we’ve focused on pushing for better incorporation of small waters – including ponds, headwater streams and small wetlands – into the statutory water environment monitoring and management regime, which primarily derives from the Water Framework Directive Regulations. Our evidence submission to the Independent Water Commission made a strong case for including small freshwater habitats because of their critical importance for biodiversity.
Amongst the review’s 88 recommendations, we were therefore encouraged to see acknowledgement of the need to ‘revisit the fundamentals of the Water Framework Directive Regulations’. The report acknowledges that we need to do this to ‘reflect advances in scientific understanding’ since the introduction of the Water Framework Directive more than 20 years ago.
These scientific advances include a now-incontrovertible body of evidence that small waters are vitally important for freshwater biodiversity – and for the achievement of statutory biodiversity targets.
Whilst the review stops short of specific recommendations on small waters, it recognises that a ‘monitoring regime which covers the whole water environment… is necessary’, and that ‘Government should consider opportunities to support progress towards biodiversity targets. This may include a review into whether relevant small water bodies, which are currently not included, should be in scope for a future framework.’
Elsewhere in the report, the Commission flags the ecological importance of small waters ‘for priority species and spawning grounds’. However, it cites potential challenges with resourcing for expanded monitoring of small waters, and notes the need to consider the ‘costs and benefits of their inclusion’. The report points out that integrating novel technologies such as eDNA, and enabling integration of other monitoring data sources, could help to overcome these resource constraints.
It’s now Government’s turn to take these recommendations, build on them, and begin the long-overdue restoration of our water environment. Small waters – like ponds, small streams, and small wetlands – will be vital in this task. As Government brings forward their much-vaunted Water Bill, we’ll continue to raise our voice for these special habitats, and for freshwater more generally. Watch this space!