On 7 April, RTPI Cymru submitted a response to the Green Paper: Shaping the Future of Water Governance in Wales. Read the response below.
Long-term sustainability objectives, including those relating to climate resilience, water quality, and the transition to a more integrated natural resources system, must remain central to the future direction of water governance and policy in Wales. Ensuring Wales is equipped to meet the challenges of climate change and ageing infrastructure requires that the governance, planning, regulatory, and investment framework is properly resourced and strategically aligned.
As with the planning system, the water sector has experienced capacity constraints in recent years, and a well-resourced, systems led approach is essential to deliver the outcomes Wales needs.
The proposals set out in the consultation, particularly the creation of a Welsh economic water regulator, the introduction of a national systems planner, and the modernisation of legislation, have clear potential to strengthen long-term strategic direction. Integrating water resources, drainage, wastewater, environmental quality and catchment management in a coherent national framework aligns closely with sustainable development principles and provides opportunities to embed nature-based solutions and improve resilience.
However, it is crucial that the reform programme does not consider these proposals in isolation. The water system intersects directly with development planning, flood management, land use decisions, and climate adaptation. The current green paper makes limited reference to the wider planning system, despite its essential role in shaping infrastructure delivery and ensuring water resilience is integrated into place-based planning. Without recognising these interdependencies, key spatial issues, including siting of assets, growth pressures, and future resilience risk being overlooked.
Strengthening monitoring, regulatory enforcement, and governance will help build public confidence, as will improved transparency for stakeholders.
Any consideration of changes to permitted development rights should be proportionate and evidence based, however, we note that issues in this area appear limited, and we would therefore question the need to consider changes to permitted development rights. Capacity building for planners, and closer engagement with local authorities and flood risk teams, could provide the collaborative approach that is essential to achieving positive outcomes and impact.
RTPI Cymru welcomes discussion on the future of water governance, brought about by this Green Paper.
Our response to the consultation questions is set out below.
Chapter 1: Our Strategic Direction for Water in Wales
Welsh Government’s strategic direction must recognise that land use planning and the management of the water system are fundamentally interconnected, to ensure effective delivery across both areas. This requires closer coordination than currently evident. The document only briefly mentions the importance of land use planning suggesting, that at present, there is lack of meaningful engagement with the planning system.
In this context, the interface between the water industry and local authorities needs to be recognised as one of critical importance in initiating change. In their roles as local planning authorities, unitary authorities and national park authorities take the majority of decisions on development proposals, and prepare the Local Development Plans (LDPs) that guide those decisions. They also collaborate through Corporate Joint Committees at the regional level in the preparation of Strategic Development Plans (SDPs). In these decision making roles, water and sewerage capacity is often of critical importance. Unitary authorities also share with water and sewerage companies and Natural Resources Wales (NRW) the status of Risk Management Authorities under the Flood and Water Management Act 2010. The distinction between local authority boundaries and the river catchment boundaries which drive water industry planning will need to be carefully managed, particularly in delivering Drainage and Waste Water Management Plans.
The direction for monitoring of water in Wales should follow a structured assessment cycle to evaluate the safety of infrastructure and environmental risk. There should also be a recognition of the wider potential of water infrastructure such as reservoirs in facilitating public recreation and access to the countryside, recognising also its heritage value and its key water supply role in enabling navigation of our canals. Robust enforcement is required to improve the quality of our water courses, however action needs to address causes rather than just symptoms. Tackling these issues requires genuine cross-sector collaboration, with solutions shaped from the bottom up. For example, engaging with community groups like citizens science.
Additionally, we need to analyse and define the role of the Nutrient Management Boards and their transition to catchment partnerships across Wales who will be considering a wider remit of responsibilities, including flood plain management and nature-based solutions for more than just nutrients. We recommended that they are a key body to engage with to help deliver some of the ambitions of the green paper and the new regulator.
Chapter 2: Planning Together for a Resilient Welsh Water System
RTPI Cymru would support the establishment of a National System Planning Function in principle. To ensure impartiality, long-term oversight, and meaningful cross-sector coordination, the function should ideally sit within an independent body or within the Welsh Government. A system planning approach can allow for stronger integration between sectors specifically planning with flood risk, water, and the environment. The policies behind the approach should inform LDPs and SDPs to ensure that they are given maximum attention to with future development plans.
As for time scales, 5-year cycles should focus on immediate needs and risks such as sewage assets located on floodplains, which cause downstream pollution when overflowed. Ten-year cycles should focus on medium term projects such as upgrading ageing, heritage-heavy infrastructure that is no longer fit for purpose, this period is also an opportunity for targeted investment of planned growth aligned with LDPs. 25-year cycles should focus on major long-term plans such as major infrastructure upgrades and long-term growth aligned with SDPs and Future Wales 2040.
Interventions between LPAs, water providers, and regulators should be planned and not reactive with key thought for the future to ensure resilience. Welsh Water has in-house planning expertise and is typically proactive, yet this is not reflected in the consultation paper and there is scope for strengthening this engagement further. Consideration should be given to whether water companies should be statutorily required to maintain dedicated planning teams, ensuring consistent, long-term collaboration with the planning system.
In ensuring effective cross-sector collaboration, it will be important for both the National Water Strategy for Wales and the National Flood and Coastal Erosion Risk Management Strategy to be updated to provide an up-to-date context for the implementation of the Green Paper. There is also potential for the Green Paper’s proposals to play a valuable role in delivering the National Climate Adaptation Strategy for Wales. The interface with the Sustainable Farming Scheme will also be important in recognising the potential for agricultural land to be managed in ways that help to mitigate flood risk while also responding to increasing risks of summer droughts.
A key concern in seeking to ensure the resilience of our water infrastructure in a changing climate is the extent to which infrastructure is itself located in flood risk zones. There will be a need for targeted programmes to manage and mitigate these risks. Critical in this context is the presence of water infrastructure in coastal locations. Close collaboration between water and sewerage companies on the one hand and those risk management authorities involved in delivering Shoreline Management Plans on the other, will be essential.
For water bodies and catchment areas that extend across the England/Wales border, formal cross‑border governance arrangements should be established. These agreements should set out clear, consistent mechanisms for collaboration, ensuring both nations work to maintain aligned water policies, shared management objectives, and coordinated interventions. They should also define which authority (England or Wales) holds responsibility for each water body, including roles in monitoring, regulation, and long‑term planning. This structured approach would provide transparency, reduce administrative ambiguity, and support integrated management of cross‑border water systems.
The proposal to expand permitted development rights (PDRs) for water infrastructure requires careful consideration. Planning is sometimes perceived as a barrier, but it provides an essential mechanism for assessing community impacts, visual and landscape effects, and construction disruption. Given rising public interest in water‑related infrastructure, the planning system offers an established framework for transparency and community engagement. A notification‑based approach, similar to the PNA (Pollution assessment from Natural and Anthropogenic sources) model, could be explored as a proportionate alternative that balances delivery with accountability.
Chapter 3: Modernising our Legislative Framework in Wales
The current legislative framework for water management in Wales clearly requires amendment, particularly to address issues arising from development in and around floodplains, where poorly located or outdated assets often contribute to pollution during flooding and leave homes uninhabitable. Prioritising investment in ageing infrastructure that is no longer fit for purpose and effective regulation of agricultural activity, would help modernise the system and reduce environmental risks.
Embedding public health outcomes and nature‑based solutions within future legislation is also essential, as sustainable drainage and natural flood management approaches offer long‑term, low‑impact ways to improve resilience. Strengthening compliance will require more innovation, including real‑time monitoring of sewer capacity and performance to identify risks early, coupled with escalating penalties for pollution incidents and compulsory improvement plans for high‑risk assets. Together, these reforms would support a more modern, preventative, and environmentally responsible water system for Wales.
However, the proposals introduce multiple new frameworks, responsibilities, and standards, but it is not clear how roles would be divided between Welsh Government and regulators. Establishing a coherent, streamlined governance structure is critical to ensure reforms are deliverable, enforceable, and transparent.
As for impacts to the wider sector Welsh agriculture is already experiencing acute challenges linked to extreme weather, including the drought of summer 2025 and prolonged periods of heavy rainfall. Reduced grass growth and increased indoor housing have intensified pressure on hay, straw, and fodder supplies, forcing many farmers to import feed at significant cost, with some facing insolvency. Understanding the relative climate impacts of increased transportation versus investment in resilient farm systems and improved water infrastructure is essential. A more collaborative approach between agricultural stakeholders and water providers will become increasingly important as climate pressures intensify.
