I am writing on behalf of the National Infrastructure Commission for Wales (NICW) to provide information for the Call for Evidence issued by the Independent Water Commission. The Call for Evidence sets out the areas where the Independent Water Commission is seeking views in relation to the water sector in England and Wales.  

 In October 2024, NICW published its Building Resilience to Flooding in Wales report (attached) which was the result of over 2 years of work and research by the Commission to make recommendations to the Welsh Government on how Wales can improve its resilience to flooding by 2050.

Following a scoping study, carried out in 2022/23, NICW identified four areas of research to carry out detailed investigations on the flood management system and response in Wales. These four areas of work were:

• Creating a vision for a flood resilient Wales – to explore the potential to set a longer-term vision for flood management
• Strategic and Spatial Responses – examining the current flood risk management planning frameworks
• Resources – including financial and people
• Land Use Planning – examining the planning system and consenting of development in flood risk areas

 These individual pieces of research have been published on our website.

We took these reports and used additional information from our meetings with stakeholders and visits around Wales talking to different organisations, to produce our final report with 17 recommendations. We would like the Independent Water Commission to consider all of our recommendations in its work. We would draw particular attention to the following:

Recommendation 1

Establish a new Water Commissioner with sufficient powers to:

• Provide national coordination and leadership and to develop strategic frameworks and policies for long term resilient land use planning and infrastructure.

• Establish and support a unified approach and framework for catchment planning and partnership delivery in Wales, with implementation being supported by NRW catchment coordinators.

• Support cross sector collaboration between agriculture, flooding, and environmental teams within the Welsh Government and also with external stakeholders (including the farming community, landowners, construction, industry, and local authorities).

• Ensure there is a strategic level connection to facilitate communication and coordination among various stakeholders, integrating efforts across different levels of government and organisations, such as Natural Resources Wales (NRW) and Dŵr Cymru Welsh Water (DCWW).

• Provide clarity, and simplify structures, roles, responsibilities for managing flood risk and the water environment by reviewing governing bodies and groups currently coordinating responses and supporting community action.

• Coordinate the commissioning of flood works and climate resilient infrastructure across Wales.

• Promote cooperation among local authority groups based on catchments, facilitating opportunities for collaborative funding and resource allocation.

Our research and engagement with stakeholders pointed to the need for change in the governance and policy structures and frameworks that exist across the Welsh public sector in order to address flood protection issues in a clear and transparent way and to support long-term resilience planning and delivery. The current situation lacks integration and communication between relevant departments, and so is preventing a cohesive, whole-system response to managing the water environment and mitigating flood risks.

Additionally, the current framework of governing bodies and groups involved in these issues appears overly complex, with a delineation of roles and responsibilities that could be more holistic. This lack of clarity is hampering effective action and accountability. Stakeholders across different levels of government, organisations, and external groups (e.g. farming community, construction industry) also seem to be working in isolation, without a strategic coordinating mechanism to integrate their efforts.

The establishment of a Water Commissioner is essential to provide centralised leadership and coordination for long-term resilience planning in Wales. The Commissioner would need to have sufficient powers to deliver the recommended outcomes. This recommendation stems from the need identified in our research for a dedicated authority to drive strategic frameworks and policies related to flood risk management and infrastructure development. Empowering a Water Commissioner, supported by a national water resilience forum to encourage community involvement, will ensure a unified approach to catchment planning, foster cross-sector collaboration, and streamline governance structures.

Sufficient powers should ensure that this role comes with the weight to make decisions and will help ensure that action is taken as swiftly as possible in the interests of the climate and nature emergencies. This central figure will enhance communication and coordination among stakeholders, facilitate cross-government collaboration, and clarify roles and responsibilities, thereby promoting effective decision-making and efficient implementation of flood resilience measures.

Recommendation 2

Create a long-term 30 year national flood and coastal erosion resilience strategy, based on a 30-year vision for flood resilience and a catchment approach, to set out Wales’ priorities to support and protect communities

and infrastructure in the long-term. Developing this strategic approach will include reviewing and streamlining existing plans, strategies and forums across Wales to provide greater clarity whilst also prioritising response for most at risk areas.

The call for a 30–year national flood resilience strategy based on a catchment approach arises from the recognition of the need for a comprehensive and forward-looking plan to address flood and coastal erosion challenges in Wales. This recommendation aligns with stakeholders emphasising the need for longer term planning than currently exists and the identification and prioritisation of high-risk areas for long term action.

Our research concludes that the current 10 year strategy is not long enough to take the necessary longer term decisions on flood risk management. The layering of existing plans is potentially complex and provides a challenge in their alignment. Developing a strategic and long-term resilience strategy will allow Wales to identify priorities, streamline existing plans, and provide clarity on resource allocation. By adopting a catchment-based approach, the strategy can effectively protect communities and infrastructure while enhancing coordination and response mechanisms for sustainable flood management.

Recommendation 5

Pilot and set up regional/local catchment partnerships (to incorporate existing river and coastal forums) to support a systematic and integrated catchment and coastal management approach. The partnerships:

• Will bring together broad disciplines, through catchment teams, supported by inclusive public representation including large landowners, businesses and (housing) developers, to coordinate integrated catchment responses across the water environment.

• Will help establish positive collaboration with landowners and the farming community.

• Will support small-scale pilots to test and refine methods whilst also piloting a catchment approach akin to the Knepp Estate for the Brecon mega catchment. Use the pilots to exemplify the benefits of a different model for individuals, business, organisations, to build large scale long term resilience.

• Would use Citizens Juries, including a Youth Jury, to convene local groups to influence decisions about climate change adaptation for their community.

A move towards integrated regional/local catchment partnership working will be accompanied by a cultural shift in which the public expect a leading role in local decision making and informing resilience and recovery efforts. These partnerships would be similar to those established in 2013 by the UK Government in the Catchment Based Approach (CaBA) policy framework.

The UK framework provides a range of ideas and suggestions to encourage collaborative working across the catchment, rather than being a prescriptive method for setting up local initiatives, which we believe should be followed in Wales. Funding would be allocated to each catchment to support the establishment of the partnership, and our proposed Water Commissioner would be able to step in should there not be a ‘local offer to work at the catchment scale’ to ensure all partnerships were implemented.

Recommendation 17

Establish open and transparent access to data by 2028 that are in line with open data governance standards allowing organisations and communities access to open-source data so they understand flood risk better, including:

• Enable technological changes and early-warning systems to be used to alert communities and businesses in areas of potential risk.

• Create accessible data through storytelling, digital platforms and portals, designed to facilitate education, open dialogue and collaboration.

• Create and maintain a register of vulnerable residents locally, linking with other service providers.

• Set up open data repositories for all public data, unless there are overriding reasons why this is not in the public interest.

• Undertake a review to identify river health, biodiversity, and water quality information can be hosted in a central space and communicated/shared with communities and organisations across Wales (e.g. data is accessed through apps or on public interfaces like billboards and information boards).

• Provide an opportunity to monitor TAN15 at a local level.

We have selected some of the most relevant recommendations from our report here, but would make the point that all of our recommendations are pertinent, given the close proximity of the water and flooding policy areas and the need to think and operate collaboratively in this sector.

We would welcome the opportunity to meet with the Commission to outline our thoughts in more detail and to discuss areas of common interest.

 We look forward to hearing from you.