September 2025
Thames Rivers Trust – Briefing: The Cunliffe Review, Water Company Performance
Thames Rivers Trust Position Statement: The Cunliffe Review and the Future of Water Governance in England
Thames Rivers Trust: Working Together for Clean and Healthy Rivers
Introduction
The Independent Water Commission (IWC), led by Sir Jon Cunliffe, conducts the most comprehensive review of the UK water sector in over thirty years. Its final report provides a clear, evidence-based overview of the system's failings, including fragmented regulation, short-term planning, and the lack of a unified framework for delivery. Thames Rivers Trust (TRT) welcomes the report's recommendations and supports the call for a systems-based, catchment-led approach that restores coherence, accountability, and long-term investment in river management.
We especially support the Commission's acknowledgement of two principles that have been long promoted by the Catchment Based Approach (CaBA) network and its partners.
- The central role of Catchment Partnerships in delivering integrated, place-based action.
- The creation of Regional Water System Planning Authorities to bridge the gap between national policy and local delivery.
These two elements, when implemented effectively and with adequate investment, can transform how England manages its rivers, providing clean, resilient waterways for people and nature.
A Strong Mandate for Catchment Partnerships
The Cunliffe Review recognises what the Thames Rivers Trust and its partners have long proven: catchment partnerships are England's most effective, locally trusted, and cost-efficient way to deliver water and nature recovery. Across the Thames Basin, 26 partnerships, supported and led by TRT, unite statutory agencies, local authorities, landowners, businesses, and communities to provide collaborative solutions to complex water issues.
Our submission to the Commission (April 2025) included clear evidence from Catchment Hosts across the basin. Partnerships are exceeding expectations given their resources, delivering measurable improvements in water quality, biodiversity, and community engagement with minimal funding. However, they face challenges due to inconsistent support and short-term funding cycles, with many coordinators working part-time and depending on goodwill.
TRT therefore supports the Commission's call for increased funding for Catchment Partnerships and the appointment of a full-time coordinator in each catchment. Stable, multi-year funding is vital to realise the full potential of this network. Modest investment in capacity-building, training, and project development can generate disproportionately high returns, attracting significant additional funding, engaging thousands of volunteers, and ensuring that local priorities are aligned with national outcomes.
The Missing Middle: Regional Governance
The Cunliffe Review highlights a 'missing middle' in current governance, a gap between national strategy and local implementation. TRT strongly backs the idea of creating Regional Water System Planning Authorities to coordinate across sectors, align investment, and ensure local voices influence national decisions.
This regional tier is essential. Many challenges confronting the Thames Basin, such as sewage pollution, diffuse agricultural runoff, drought resilience, and flood risk, operate on a scale that exceeds individual catchments. A regional governance model offers the coordination, oversight, and strategic accountability necessary to integrate multiple delivery streams, including WINEP, LNRS, ELMs, flood risk management, and biodiversity net gain, without undermining local leadership.
Through our proposed Thames Regional Investment Catchment initiative, TRT aims to demonstrate how this model could work in practice. The proposal would connect the 26 partnerships of the Thames Basin to shared goals, pooled expertise, and collaborative funding streams. This two-tier approach, with local delivery via catchments and coordinated oversight through regional investment catchments, provides a practical framework that aligns with the reforms proposed by Cunliffe.
A regional tier can also achieve cost savings by sharing specialist functions such as GIS, monitoring, and data management across multiple catchments. It can ensure that regional and national targets are based on local evidence while providing the coherence and accountability necessary for government and regulators.
Integration, Collaboration, and Delivery
TRT's experience across the Thames Basin underlines a key conclusion of the Cunliffe Review: the water sector is overwhelmed with too many plans, too few outcomes, and insufficient integration. The answer is not more paperwork but improved coordination and implementation.
Catchment Partnerships already exemplify this approach. They bring together partners around shared priorities, blend local knowledge with technical expertise, and actively involve communities in river stewardship. With support from a regional framework, they can align with the new regulatory and planning structure proposed in the Cunliffe Review, ensuring that measures under the Water Industry National Environment Programme (WINEP), nature recovery strategies, and flood management plans are implemented coherently and effectively.
This integrated model also addresses the Commission's call for enhanced monitoring and data transparency. The CaSTCo initiative, led nationally by The Rivers Trust and supported by TRT partners, has demonstrated how citizen science and digital monitoring can complement regulatory data, enhance decision-making, and rebuild public trust. Expanding this model throughout the Thames Basin would establish a strong, shared evidence base essential for both local initiatives and regional planning.
Aligning with The Rivers Trust and the Catchment-Based Approach
TRT fully supports the position outlined by The Rivers Trust in its response to the Cunliffe Review. We endorse establishing a single, unified water regulator to improve oversight, make enforcement clearer, and refocus on environmental outcomes. We also back the creation of Regional Water Authorities as operational bodies with transparent accountability and local input, including Catchment Partnership representatives on their boards.
TRT supports establishing a national monitoring framework that integrates regulatory, scientific, and citizen-sourced data to support transparent, evidence-based decisions. We also welcome the expansion of nature-based solutions as essential infrastructure for flood resilience, water quality enhancement, and climate adaptation.
However, TRT emphasises that these reforms should not marginalise existing community-led structures. The Catchment-Based Approach must continue to be the foundation of delivery, not an addition to new institutions. Regional governance should empower rather than replace local partnerships, ensuring that decisions stay connected to catchment knowledge and community priorities.
Next Steps and Implementation
The Cunliffe Review's recommendations offer a once-in-a-generation chance to rebuild trust, restore rivers, and modernise water governance. However, success will depend on how the government executes these changes.
TRT calls for:
- Immediate enhancement of Catchment Partnerships, with secure multi-year funding and investment in skills, training, and project development.
- Early pilots of regional planning authorities used the Thames Basin as a testbed for basin-scale governance linking multiple catchments under a shared investment and monitoring framework.
- Integrating CaBA partnerships into the statutory planning framework, with formal recognition as their delivery bodies within environmental, agricultural, and water company investment programmes.
- Consistent public and political backing for transparency, collaboration, and environmental recovery, guaranteeing reforms extend beyond political cycles.
Conclusion
The Thames Basin is one of the UK's most complex and dynamic river systems, home to 15 million people and a network of dedicated partnerships working every day to restore its health. The Cunliffe Review rightly states that the future of water management relies on reconnecting national ambition with local action.
Thames Rivers Trust is ready to help realise that vision. By enhancing the Catchment-Based Approach and integrating it into a clear regional governance structure, government can create a system that is locally driven, nationally accountable, and environmentally transformative.
