What the Cunliffe Review Means for Development

On 21 July 2025, the Government’s Independent Water Commission, led by Sir Jon Cunliffe, published a landmark report proposing sweeping reforms to the UK’s water sector. With 88 recommendations spanning regulation, infrastructure planning, water quality, and environmental performance, the Cunliffe Review sets the stage for a transformation in how water is managed and governed across England and Wales.

The Home Builders Federation (HBF) has provided a valuable summary of the report, highlighting a number of recommendations that will be of particular interest and concern to the housebuilding and development sector.

A Sector Under Pressure

The Commission makes it clear: the current water regulatory framework is no longer fit for purpose. It calls for a more coordinated, longer-term, and integrated approach to water systems planning, but also flags the urgent need to restore public trust, attract investment, and ensure a resilient water environment that can support growth.

However, for developers, the short-term outlook may feel more uncertain. The report acknowledges the constraints that current water infrastructure challenges place on housebuilding but does not offer immediate solutions for issues such as nutrient and water neutrality, water supply limitations, or sewerage capacity, challenges that many of our clients face today.

Instead, the Commission proposes several changes that could introduce new hurdles to development delivery, including:

Mandatory consultation with water companies on certain planning applications
A Government review of the current ‘right to connect’
A stronger role for water companies in the planning system
New statutory requirements for Sustainable Drainage Systems (SuDS)
Revisions to permitted development rights for water infrastructure

construction site, crane, construction machinery, construction work house construction, construction site, construction site, construction site, construction site, crane, crane, crane, crane, crane

Planning for Change

The Government is expected to respond formally later this year through a White Paper, followed by consultation and legislation in the form of a Water Reform Bill. While these reforms may offer long-term benefits in terms of resilience and clarity, there is no doubt they will require strategic planning from land promoters, developers and infrastructure providers alike.

How Brookbanks Can Support

At Brookbanks, our Land, Development and Communities group works at the interface of regulation, infrastructure, and delivery. We understand the importance of water-related challenges in unlocking sites and supporting sustainable growth. Our team is already supporting clients to:

Navigate water neutrality and nutrient constraints
Develop integrated utility and drainage strategies
Engage early with statutory consultees, including water companies and the Environment Agency
Deliver robust SuDS and green infrastructure that meet evolving regulatory expectations
Future-proof development through infrastructure phasing and long-term coordination

We believe that early engagement, integrated design, and regulatory alignment are now more important than ever.

Looking Ahead

The Cunliffe Review is a significant moment for water reform in the UK. While it brings uncertainty, it also presents an opportunity to rethink how water infrastructure supports growth and how the development sector can play a constructive role in delivering more resilient, sustainable communities.

We will continue to monitor the Government’s response and engage with our clients to help shape and respond to the evolving water policy landscape.

If you would like to discuss how the proposed reforms may affect your site or pipeline, please get in touch with our Land, Development and Communities team.

Meet our Land, Development and Communities group

Associate Utilities Director

Danny Lloyd-Jones

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Technical Director, Land, Development and Communities Group

Dean Swann

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Project Consultant – Flood Risk and Drainage

Katherine Peers

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Group Director for Land, Development and Communities

Lee Witts

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Director of Utilities

Mat Capper

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