Consultation outcome

Water resources planning guideline: consultation response summary

Updated 8 May 2026

1. Introduction

Water resources management plans (WRMPs) set out how water companies intend to achieve a secure supply of water for their customers and a protected and enhanced environment. These plans must be prepared every 5 years and reviewed annually.

The water resources planning guideline, published jointly by the Environment Agency, Natural Resources Wales and Ofwat, sets out the expectations that government and regulators have for how water companies in England and Wales should prepare their statutory WRMPs. The guideline is updated every 5 years, ahead of the next cycle of WRMPs. The next set of plans are due to be completed in 2029. We ran a public consultation on the latest water resources planning guideline from October to December 2025. The consultation sought views on the content of the updated guideline. Alongside this, we also provided the supporting document ‘Environmental Destination for Water Resources planning guidance’ (for water companies in England) for comment.

This response to our consultation sets out some of the key areas that respondents highlighted and our high-level response.

2. How we ran the consultation

The consultation opened on 13 October 2025 and closed on 5 December 2025 (midnight).

The consultation ran for a total of 8 weeks.

Stakeholders and the public were invited to provide comments through:

• online response via Citizen Space – the Environment Agency’s digital consultation website
• email submissions using a response form available through the consultation website
• requesting printed copies via the National Customer Contact Centre

Participants were asked to:

• comment on concerns with the draft guideline
• suggested improvements
• comment on whether the guideline adequately supports resilient and environmentally protective water resource planning
• provide any other relevant feedback

 Following the close of the consultation:

• responses were analysed and used to refine the water resources planning guideline
• any responses affecting Wales were shared with Natural Resources Wales and Ofwat for consideration and changes made by them where needed
• this formal consultation response document was published on GOV.UK within 17 weeks of the closing date

The final version of the water resources planning guideline was published on 2 April 2026.

We received 41 responses in total, of which:

• 19 were from water companies
• 2 from government organisations
• 3 from water users
• 4 from regional groups
• 13 from community groups and members of the public

The consultation responses highlighted environmental destination as the most significant area of interest, with 56 submissions focused on this topic. Population growth and demand forecasting also emerged as key concerns, receiving 39 and 37 responses respectively. A further 25 to 30 respondents provided feedback on each of the areas of environment, New Appointment and Variations (NAVs), options, and climate change. This indicated a broad range of environmental and operational considerations across the consultation.

3. Changes to the water resources planning guideline

3.1 Summary of pre-consultation changes

The guidance for the last round of planning made some significant changes to water resources planning. This included the introduction of the environmental destination to facilitate long-term planning for environmental improvements, increasing resilience to severe droughts, mandating stochastic assessments and using adaptive planning to manage uncertainty. 

Our ambition for this guideline was to allow some of these changes to take effect without significantly altering planning expectations.

However, we did make the following important improvements to our guidance:

• accommodating growth – refining text on population and non-household growth following close liaison with government and giving explicit consideration of new water intensive industries, including data centres 

• guidance for strategic schemes – providing updated guidance for robust cost estimation for strategic resource options and major projects and understanding the plans sensitivity to change. Identifying ‘in-delivery’ strategic schemes that have reached development and maturity milestones, after having previously been selected at WRMP24. In-delivery schemes would not be subject options appraisal at WRMP29

• climate change – aligning more closely with the Committee for Climate Change’s recommendation of planning for 2°C rise in temperature by 2050 and testing for 4°C by 2100

• environmental destination – development of the guidance based on learning from the previous round and ongoing dialogue. Sections of the guidance were shared for informal comment with stakeholders

• environment – further information on how to account for Habitats Regulation Assessments for existing abstractions and how to consider potential Regulation 19 exemptions within the WRMPs (for water companies in England)

• resource position statement – addition of a formal submission of basic supply-demand data and expanded unconstrained options lists (including opportunities at existing assets) in May 2027. This will allow regulators early sight and comment on the development of WRMP29 as part of the pre-consultation phase  

• uncertainty – allowing the choice of a simpler headroom method for managing uncertainty

3.2 Summary of post-consultation changes

We have carefully considered the views shared by the 41 respondents to our consultation, in conjunction with Natural Resources Wales and Ofwat where appropriate. In response, we have made a number of changes to the water resources planning guideline and the supporting Environmental Destination for Water Resources planning guidance (relevant to water companies in England) which are summarised in this document.

The key changes we have made to the guideline following the public consultation are as follows.

Environmental destination

We have clarified governance and decision-making arrangements for the environmental destination. We have added extra guidance for developing alternative planning pathways and scenarios and further explained how evidence from investigations can inform this. We have clarified how the environmental destination links with other planning frameworks including river basin management planning and the water industry national environment programme.

Baseline and demand management programmes

We have put clearer emphasis on water companies using realistic baseline and demand management programmes. Demand targets are national (for England as a whole) and water companies should demonstrate their contribution. We still expect water companies to be ambitious and innovative in their demand management as this is critical to future water supplies.

Nature-based solutions 

To encourage the inclusion of nature-based solutions, the guidance now allows these to be included as preferred options in resource zones in deficit where the primary benefit is to supply (even if their contribution to the supply-demand balance is uncertain).

Further refinements around growth 

We have refined how water companies should consider local and strategic plans. We have also removed specific reference to 9% reduction of non-household by 2037 to 2038. This is a national target that contributes to the overall distribution input per person target and some companies may have significant non-household growth in their area.

We have also made the following changes:

• refinements to how NAVs should be considered by incumbent water companies
• refinements to the in-delivery schemes section
• inclusion of the consumer involvement rule
• explanation of robust cost estimation
• more emphasis on planning for peak demand
• allowing baseline leakage to include changes due to climate change and growth where there is evidence to support this
• refinement of the Habitats Regulation Assessment section

A version of the guideline with highlighted changes made since the publicly consulted version is available on request by contacting water-company-plan@environment-agency.gov.uk.

4. Key consultation response topics

Our consultation asked respondents to highlight the areas of most concern to them. In this section, we have taken some of the areas with the most significant comments and described where we have and have not changed the guidance as a result.

4.1 Independent Water Commission

The Independent Water Commission (IWC), led by Sir John Cunliffe, reviewed the water sector regulatory system in England and Wales. It delivered its recommendations in July 2025. The government delivered its subsequent water white paper setting out its initial response in January 2026. Several respondents made reference to this reform and the implications for the guidance.

The Department for Environment, Food and Rural Affairs (Defra) has confirmed that WRMP29 will take place as planned whilst the reform transition plan is worked through. Therefore, the changes made in this update to the guidance are to support WRMP29 and not intended to fully reflect longer term changes to water resource planning frameworks that will result from IWC recommendations. Regulators continue to work with UK and Welsh governments to deliver reform, and will continue to engage with companies and stakeholders on this process. Further details will be released with the water reform transition plan, this will also include details for companies which are wholly or mainly in Wales.

4.2 Nature-based solutions

Consultation response summary

Responses to the consultation emphasised the importance of nature‑based solutions and that they should be encouraged in the water resources planning guideline. They highlighted that nature-based solutions should be assessed on an equal basis with traditional infrastructure, given their environmental value and contribution to climate resilience. Concerns were raised that the current guidance was a barrier to including nature-based solutions in WRMPs.

Our response

Regulators strongly support the inclusion of nature-based solutions. We have made an important change to the guideline to allow nature-based solutions, where the primary benefit is to the supply-demand balance, to be included as preferred options in WRMPs, even if their impact is uncertain.

Previously, it had been difficult to justify these schemes because any scheme was required to contribute to a component of the supply-demand balance. However, we recognise that there can be considerable uncertainty regarding the benefits around these schemes. The guidance now allows these schemes to be included if the primary benefit is to water resources and they are in a zone where there is a baseline deficit.

4.3 Environmental destination

This section relates to guidance for water companies in England only. There will be guidance issued separately for water companies in Wales.

Consultation response summary

Responses to the consultation called for the guidance to give a clearer picture of governance and decision-making arrangements for the environmental destination. In addition, respondents asked questions on where cost and benefit decisions are made on the pursual of environmental objectives.

Respondents were keen for the guidance to give more detail on how improved data and evidence can be incorporated into the planning approach to reduce uncertainty. Clarity was requested around how planning for sustainability changes to abstraction relates to decision-making for implementing abstraction changes.

There were also requests for the guidance to have a stronger reference to the duties on water companies under the Wildlife and Countryside Act (1981).

Our response

We have clarified governance arrangements for the environmental destination in the guidance by providing:

• an overview of the approach to decision-making
• additional detail on how decisions should be taken in the water resources planning process
• additional detail on where government and regulators fit into decision-making

It is now clear in the guidance that the cost benefit assessment of environmental objectives is part of the river basin management planning process, not the water resources management planning process. There is also greater emphasis on setting out the links between the different processes. We have added extra guidance for developing alternative planning pathways and scenarios, and how these should be used to support the proposed plan as best value for the environment and society. 

We have included additional guidance on how investigations to improve certainty of environmental water requirements, often conducted as part of the water industry national environment programme, should be considered when developing the environmental destination in planning. The guidance also now outlines the relationship between planning for sustainability changes and subsequent regulatory decisions to implement sustainability changes.

The guidance now has strengthened reference to water company duties under the Wildlife and Countryside Act (1981) and new reference to Environment Improvement Plan targets (including for Sites of Special Scientific Interest – SSSIs) in developing the planning pathways.

Further detail on changes to the Environmental Destination for Water Resources planning guidance is included in Appendix 1.

4.4 Growth

Consultation response summary

Respondents made a number of detailed comments concerning population growth and using local authority plan data. Some water companies challenged the feasibility of using local authority plan figures 6 months before the submission of the draft plans.

A number of respondents commented that national non-household demand reduction targets were challenging to deliver in areas of economic growth. Some respondents queried how new towns should be considered in the company planning.

Our response

We made several clarifications in section 6 because of the responses received. We have:

• strengthened the importance of engaging with local and strategic planning authorities as they develop their spatial development strategies – it is important that water companies have active and ongoing engagement with local planning authorities throughout the planning process
• changed the requirement “to use latest local and strategic plan data available up to 12 months before the publication of the plan and a shorter period if possible” from 6 months
• clarified that companies should review and update population and property forecast between draft and final plan with the latest data available up to 6 months before submitting the plan – water companies should continue to monitor changes to planning data and use it to inform reviews before and after publication of the plan
• updated the guidance to reference emerging and adopted spatial strategies

We have also removed specific reference to 9% reduction of non-household by 2037 to 2038 as this is an England-wide national target. Some companies may have significant non-household growth in their area. Water companies should explain if their plan does not show an overall reduction in non-household water consumption.

Any significant new development such as new towns or growth corridors should be included as part of housing plan numbers. We have contributed to a UK Water Industry Research (UKWIR) project looking at demand forecasting methodology. The outputs of this research are due this Spring and will be factored into updates to the guidance.

4.5 Demand management targets

Consultation response summary

A number of respondents expressed concern that the demand management targets for England were too ambitious and leading to less resilient plans. Some respondents commented on the importance of government-led interventions in achieving demand management targets and asking for guidance on how these should be quantified.

Our response

Our previous guideline set out that companies should consider national demand management targets in their planning but could justify variation from these at a company level. A number of companies stated in their consultation responses that they believed they had unrealistic demand programmes in their plans due to meeting government expectations. We have put clearer emphasis on the need for a realistic baseline and deliverable demand management programmes, and that demand targets are national with water companies demonstrating their contribution. We still expect water companies to be ambitious and innovative in their demand management as this is critical to ensuring security of supply.

More details will be released on water labelling in 2026. Other interventions should be tested as adaptive pathways and based on information available, for example, once the building regulations consultation response is available.

4.6 New Appointment and Variations (NAVs)

Consultation response summary

NAV appointments are made under the Water Industry Act 1991 (Sections 7 and 8) and enable Ofwat to replace the existing water supply or sewerage undertaker (or both) for another for a specific area. NAVs undertake much of the same duties and responsibilities as the previous statutory company, including the requirement to produce WRMPs.

The consulted guideline contained some further guidance around the consideration of NAVs by the incumbent water companies. These included:

• providing information on the assumptions made around growth of NAV sites
• ensuring no double-counting of the inbuilt headroom in bulk supply agreements in incumbent headroom
• suggesting a staggered bulk supply profile as the site is developed

We had a number of responses concerning NAVs. Some of these responses were in support of the changes we have made. Others questioned whether using contractual volumes were the most realistic assumptions and asked for more guidance to be given to NAVs to guide their planning assumptions. Some respondents challenged the need for providing further information on assumptions and the guidance to review bulk supply contracts at relevant points. Further respondents asked for clarification as to how demand management targets applied to NAVs.

Our response

We made some further changes as a result of the consultation responses. These include:

• guidance on how NAVs should consider their planned level of leakage in section 9.3.1
• how incumbent metering forecasts should consider the forecast of new properties from existing NAVs
• changing the ‘should’ review bulk transfers to ‘best practice’

We are also updating our supplementary guidance for NAVs.

4.7 Options and costs

Consultation response summary

There were a number of responses on cost estimation for priority schemes, including concern it created a tiered estimation process that would introduce decision making bias. We also received a number of responses on optioneering and third party options.

Our response

We made some clarifications to the cost estimation section (section 8.3.7) and reviewing costs (section 8.3.8). These include:

• clarifying the ask for robust (rather than different) cost estimation for strategic schemes, and to consider cost elements specific to their risk and uncertainty
• understanding the sensitivity of best value decision making to cost changes
• clarifying when companies should consider revisiting best value decision making outcomes

We have also asked that companies engage with third parties on any barriers that they perceive on proposed options.

4.8 In-delivery schemes

Consultation response summary

In general, the new concept of in-delivery schemes was welcomed, but some respondents were concerned that the criteria would exclude some schemes that did not yet meet scheme development maturity milestones. Some comments also highlighted the ambiguity as to whether all 3 conditions needed to be met.

Our response

Regulators have reviewed the criteria and have made some minor clarifications as a result of the responses, including making it clear that all 3 conditions need to be met for a scheme to be considered ‘in-delivery’. We have not changed the conditions themselves. This reflects the need to carefully balance the planning certainty gained with ‘in-delivery’ status, with the scheme scope stability reached through key development milestones.

4.9 Supplementary guidance

Consultation response summary

A number of respondents asked about the timescales of the supplementary guidance and whether they could be made available online.

Our response

We are developing the supplementary guidance over the Spring, in conjunction with Natural Resources Wales and Ofwat. The resource zone integrity, outage and climate change supplementary guidance has been finalised. The remainder of the guidance is under development. If you wish to be part of an informal consultation on these guidance notes, please email water-company-plan@environment-agency.gov.uk.

The current expected list of guidance is as follows:

Supplementary guidance	Is there an update expected from WRMP24 version?
Adaptive planning	Yes – in development
Outage	Yes – finalised
Resource zone integrity	Yes – finalised
1 in 500	No update
Environment and Society in Decision-making (England only)	Yes – in development
Preventing deterioration (England only)	Yes – in development
Leakage	Yes – in development
Climate change	Yes – finalised
Stochastics	Yes – in development
NAVs	Yes – in development
Demand options	New

While we are exploring how to make the supplementary guidance more accessible, the latest versions are available by emailing water-company-plan@environment-agency.gov.uk.

5. Next steps

The guideline was published on 2 April 2026. Water companies will publish their resource position statements in May 2027 and submit their draft WRMPs to Defra and the Welsh Government (as appropriate) in February 2028. A public consultation on these plans will follow shortly after this.

We will also pick up some of the more detailed comments in our supplementary guidance notes, for example around adaptive planning and best value metrics. These will be revised and published over the next 6 months.

The new water supply planning framework indicated by the water white paper will give us the opportunity to reconsider WRMPs and where further improvements in resilience and planning can be made, for water companies in England. The Welsh Government Green Paper on water will determine the framework for companies covering parts or all of Wales.

6. List of respondents

Of the 41 respondents, 3 asked to remain anonymous and have therefore been removed from this list.

Water operators (19)

Affinity Water

Anglian Water

Canal and River Trust

Dwr Cymry Welsh Water

Hafren Dyfrdwy

Independent Water Networks Limited (IWNL)

Northumbrian Water

Portsmouth Water

Pennon

Severn Trent Water

Southern Water

South East Water

South Staffs Water

Thames Water

Yorkshire Water

United Utilities

Waterlevel Limited

Wessex Water

Government bodies (2)

Essex county council

Natural England

Water users (3)

Extreme Drought Resilience Service Limited (EDRSL)

J Myatt & Co – Fruit growers

Norfolk Environment Food and Farming

Regional groups (4)

Water Resources East (WRE)

Water Resources North (WReN)

Water Resources Southeast (WRSE)

Water Resources West (WRW)

Community groups and members of the public (13)

3 individual respondents

Blueprint for Water

Joint Environment Programme (JEP)

Pupils 2 Parliament

Rebalance Earth Venture Limited

Royal Horticultural Society (RHS)

Water UK

Waterwise

Wildfish