Appendix 1: Changes to the Environmental Destination for Water Resources planning guidance
Updated 8 May 2026
1. Summary of the post-consultation changes
We have carefully considered the views shared by the 41 respondents to the consultation. In response we have made a number of changes to the Environmental Destination for Water Resources planning Gguidance which are summarised in this document.
The key changes we have made to the guidance following the public consultation are:
- better description of governance
- clearer explanation on developing the alternative pathways
- requirements for Sites of Special Scientific Interest (SSSIs)
- how costs and benefits can be considered in plans
- account for improved data and evidence, and managing uncertainty
- relationship to the Water Industry National Environment Programme (WINEP)
- improved consideration of catchment and nature-based solutions
- clarity on engagement with Non-Public Water Supply sectors
We have also changed the title to ‘Environmental Destination for Water Resources – planning guidance to support water company and regional water resources planning’.
A version of the guideline with highlighted changes made since the publicly consulted version is available on request from water-company-plan@environment-agency.gov.uk.
2. Key consultation response topics
2.1 How requirements for SSSIs are considered
Consultation response summary
One respondent asked for clearer explanation of how additional obligations for designated riverine sites should be assessed and stronger reference to the provisions of the Wildlife and Countryside Act including obligations towards SSSIs.
Our response
We have included additional text to provide further clarity on flow targets for riverine European Sites and SSSIs, and how these should be used in planning (section 5.4). We have also made explicit reference to interim targets set out in the Environmental Improvement Plan (EIP) 2025 (with specific reference to SSSIs) in developing the planning pathways (sections 7.5.1 and 7.6.2) and how this should be presented in plans (section 7.7.1). New text in section 5.1 strengthens reference to the Wildlife and Countryside Act 1981.
2.2 Governance
Consultation response summary
Many respondents asked for a better understanding of governance, how decisions are made and how this work interfaces with River Basin Management Plans (RBMP), Water Industry National Environment Programme (WINEP), Price Review 2029 (PR29), permitting and wider planning.
Our response
We have added new sections to provide further information on governance and relationship to other plans:
- section 6.2 explains how environmental destination links to the 4 main water planning frameworks (water resources management plan (WRMP), RBMP, WINEP and Drainage and Wastewater Management Plans)
- section 6.3 explains how environmental destination planning links across sectors
- section 6.4 provides an overview of the approach and decision making
We have also made clear what information regulators need, how they will use this and how regulatory feedback should be used to finalise plans (sections 7.8 and 7.9). This also notes that government will decide if they wish to provide direction to WRMPs.
Further information on interactions with PR29 will be provided with forthcoming PR29 methodology. Ofwat will engage with companies, regulators and stakeholders as this is developed.
2.3 Cost benefit
Consultation response summary
We had many responses requesting more clarity in how WRMPs and regional plans should assess and present the costs and benefits of resolving the impacts of environmentally unsustainable abstraction.
Our response
We have clarified that assessments of Disproportionate Cost for Water Framework Directive Regulations can only be carried out in RBMP (environmental destination guidance section 6.2 and 7.6). We have also added information as to how assessments of costs and benefits can be included in WRMPs and regional planning and how this information may feed into future RBMP (environmental destination guidance section 7.7). This includes undertaking sensitivity analysis to test slightly different levels of environmental ambition to determine if most benefits could be achieved at materially lower cost.
2.4 Alternative planning pathways
Consultation response summary
We received comments requesting a clearer explanation of how alternative pathways can ensure the best choices are made, reflecting future uncertainty, deliverability and wider system needs. Comments also questioned the clarity of the term “technically deliverable”, and whether there is a requirement to model a large number of scenarios.
Our response
We have clarified the difference between scenarios and pathways (environmental destination guidance section 6.1). We have added wording to explain that the Fastest Technically Feasible (FTF) Pathway is a reference planning pathway to inform choices (environmental destination guidance section 7.4). We have clarified that alternative pathways should set out choices around when requirements are delivered and which solutions are selected, and sensitivity analysis should be carried out to explore slightly different levels of environmental ambition (environmental destination guidance section 7.7.2). In section 7.7.1 we have added a clear steer to identify which pathways should be assessed in addition to the FTF Pathway so that plan developers can decide how many they wish to assess.
2.5 Environmental destination scenarios, data and evidence
Consultation response summary
We had many responses asking for:
- a clearer explanation of how investigation outcomes update environmental destination scenarios and inform flow recovery required in relation to decision points in the planning cycle
- clarity on how alternative flow targets are proposed and adopted
- stronger monitoring and learning loops
- greater transparency over underlying datasets and assumptions
Our response
We have added new text explaining how outcomes from improved evidence can inform planning approaches and how evidence to inform alternative flow targets may be considered in RBMP objective setting (section 5.4). We have also explained the difference between evidence for planning and evidence for implementation or licence change decisions (sections 6.5 and 7.2.4). Section 6.4 now also includes information on sensitivity analysis.
We have introduced the Sustainable Abstraction Feedback Spreadsheet (SAFS) as a consistent format for proposing improvements to scenarios (section 7.1). We have explained the use of the Sustainable Abstraction Calculator and Optimiser tool to test abstraction reduction scenarios (section 7.3.2).
2.6 Relationship with WINEP
Consultation response summary
A number of respondents raised concerns on how environmental destination planning outputs connect into WRMP option choices and price review processes.
Our response
We have strengthened wording on investigations and implementation evidence, including the role of WINEP in reducing uncertainty over time (section 7.2.4) and explained how environmental destination planning steps align with environmental destination WINEP studies in Asset Management Period 8 (AMP8) (section 6.5).
Further information on interactions with PR29 will be provided with forthcoming PR29 methodology. Ofwat will engage with companies, regulators and stakeholders as this is developed.
2.7 Use of catchment solutions
Consultation response summary
Some respondents had concerns that nature-based solutions are not seen as meaningful components to deliver required outcomes and wanted the guidance to more clearly allow catchment measures to reduce or mitigate licence reductions where justified by evidence. We also received some comments that secondary effects (such as flood risk, groundwater emergence, water quality changes) should be assessed alongside benefits.
Our response
We have expanded step 3 to include a wider range of solutions, including catchment measures, nature-based solutions, river restoration, augmentation and no-regret interim actions and added new text encouraging pairing of abstraction reductions with nature-based solutions (section 7.3.2).
We have also introduced a new section on secondary impacts (7.6.4).
2.8 Engagement with non-public water supply (non-PWS) sectors
Consultation response summary
We received some requests for guidance on how non-PWS is involved and concerns that non‑PWS may lack capacity, funding or tools to engage meaningfully. Some respondents also asked how permit reviews align with environmental destination.
Our response
We have added a new section (6.3) on cross-sector planning, including how non-water-industry sectors and permit reviews fit into environmental destination planning and future water need assessment. We have not provided further detail for non-PWS sectors as this guidance is primarily intended for regional groups and water companies as referred to in section 2.