IWA agrees that abstraction planning must look decades ahead, but stresses that reservations should only extend a few years into the future due to the inherent uncertainty of long‑term water resource planning. IWA points out that Water Resources Management Plans (WRMPs) change significantly between five‑year cycles, making them an unreliable basis for long‑term licence reservations. Examples from Thames Water’s 2019 and 2024 WRMPs show major shifts in preferred schemes, timings, and priorities. IWA warns that allowing long‑term reservations could lock water companies and regulators into outdated schemes, block higher‑priority uses, and create a backlog similar to the former National Grid connection regime.
IWA rejects the idea that inclusion in a WRMP or sectoral strategic plan automatically justifies a “need for water,” arguing that such plans identify options rather than proving necessity for specific schemes. IWA also questions the relevance and practicality of requiring strategic plans to account for all sectors’ national critical infrastructure needs, noting that this is a government‑level responsibility and that the terminology used in the consultation is unclear and inconsistent with established definitions of Critical National Infrastructure.
Environmental safeguards in the proposed framework are considered potentially adequate, but IWA raises concerns about timing. Developers cannot reasonably proceed to construction if licences might be withdrawn before operation. IWA proposes that reserved licences should expire before construction begins, forcing full environmental assessment at the appropriate stage. Clarification is also needed on how licence timing interacts with delays or accelerations in project delivery.
IWA supports catchment reviews but argues they should apply to all abstractions, not just strategic schemes. Reviews every six years may be too frequent and misaligned with WRMP cycles. IWA advocates for dynamic, real‑time catchment management, as proposed by the Environment Agency in 2025, supported by comprehensive modelling of flows, storage, rainfall, and operational infrastructure. Such tools, ideally developed by the Agency, would enable more efficient and adaptive allocation of water resources.
The proposed hierarchy for allocating water rights is criticised as confusing, overly dependent on shifting government policies, and potentially counterproductive to collaboration. IWA suggests reducing it to just two tiers – Critical National Infrastructure and all other uses – to avoid perverse incentives and reduce the risk of the Agency being perceived as either a tick‑box regulator or an obstacle to government priorities.
IWA also emphasises the need to protect long‑established waterways infrastructure, ensure adequate transition periods for existing abstractors, and create an independent appeal mechanism for licence withdrawals. IWA argues for better recognition of return flows, phased implementation of new licensing requirements, and improved cross‑border coordination for shared catchments.
Overall, IWA calls for a more flexible, collaborative, and technically sophisticated approach centred on real‑time water management rather than rigid licensing hierarchies and long‑term reservations.
The Environment Agency’s consultation document is available here, and IWA’s full response is available here.
