Planning reform and water infrastructure: what does new consultation guidance mean for project delivery?
Water infrastructure is entering its biggest investment cycle in decades - with the Regulators’ Alliance for Progressing Infrastructure Development (RAPID) targeting an unprecedented 30 new large-scale infrastructure projects through the Major Water Infrastructure Programme.
Given a substantial proportion of capital investment under this programme will go to Nationally Significant Infrastructure Projects (NSIPs), the reforms now being introduced through the Planning and Infrastructure Bill (2025) will materially impact how major water projects are planned, consulted on and examined – having significant implications for project delivery and consumer trust.
What the new guidance changes
Most notably on Friday 3rd July 2026, the Ministry of Housing, Communities and Local Government published new guidance officially removing statutory requirements for applicants to consult on NSIPs. Instead, ‘proportionate’ alternatives tailored to the location, nature, complexity, stakeholder type, and stage of each project are being encouraged– all at the applicant’s discretion. This will create efficiency savings. But it will also transfer much greater responsibility onto applicants to demonstrate that affected communities and authorities have been engaged in a meaningful way.
Sector-specific challenges
The water sector also faces other unique challenges. The timing of these projects mean water companies will face greater scrutiny toward whether their approaches to consultation and engagement reflect their Price Review 2024 commitments.
Unlike energy and transport infrastructure, where applicants can draw on dozens of recent DCO applications, water companies are also largely writing the playbook as they go. As of July 2026, only two water NSIPs have received planning consent, six are in the pre-application process and one has been accepted for examination - leaving an obvious gap in precedent for how consultation and engagement should be undertaken. Still, some lessons can be gleaned from what’s been done so far and broader best practice.
Local authority engagement – transparency and need case is key
Although local authorities are well-equipped to navigate the Development Consent Order (DCO) process through the recent boom in large-scale renewable energy applications, the biggest challenge has already proven to be a comparatively limited understanding on how they should engage on different water infrastructure classes. Gaps in knowledge compounded by pressure from communities means opposition can quickly fill the vacuum.
Recent pushback on a proposed reservoir highlights this, with the local authority citing that the water company had ‘failed to make a plausible case […] for the [project]’, and that a bunded reservoir would impact the environment over a natural storage option. Elsewhere, authorities have raised concerns about wastewater recycling options being introduced too late in the programme and inconsistencies in how alternative siting options are presented during consultation.
Whether or not these criticisms are ultimately borne out through the DCO process, they illustrate how quickly uncertainty can become part of the wider debate around a project when information is not front-loaded– and that local authorities are no less immune to answering fundamental questions on the need case of a project than any other group. Water companies must therefore be prepared to make this immediately clear and in strong, transparent terms, with robust explanation as to why certain information might not be available at each stage.
Community opposition and defining ‘adequacy of consultation’
With the UK government committed to approving 150 NSIPs this Parliament, the scale and pace of wider infrastructure development is attracting better mobilised and more planning literate communities than ever before. Their objections have also held significant weight.
Figure 1: a map showing Major Water Infrastructure Programme projects with confirmed addresses (in blue) against other Nationally Significant Infrastructure Projects (red).
For example, a written representation has been submitted to the House of Lords Environment and Climate Change Select Committee, specifically claiming that consultation had failed to meet public standards. Examining authorities themselves have also raised inadequacy of consultation as a concern on other consented water NSIPs. With definitions of adequacy itself now being redefined at the applicant’s discretion, water companies must engage early with communities and authorities to shape the scope and format of consultation to minimises risk of this issue emerging at examination.
What successful applicants are likely to do different
The removal of consultation requirements should not be mistaken for a relaxation of scrutiny. If anything, examining authorities, local authorities and communities are likely to focus more clearly on whether applicants have exercised their new discretion responsibly.
There is no one-size-fits-all approach, but following these principles could prove essential as more projects navigate the new consultation regime:
- Lead with the need case - all engagement should emphasise the need case for the project, primarily that demand reduction, water recycling and fixing leakages doesn’t eliminate the need for new infrastructure. Water companies must also make clear from the outset where alternative project locations or routes have been considered and may be inadequate.
- Sustained communication is key - given the complexity of large-scale water projects and gaps in public understanding from little infrastructure being delivered in recent decades, water companies must maintain a regular drumbeat of engagement to reassure customers and demonstrate where feedback is tangibly affecting project design. Previous recommendation reports from examining authorities have highlighted where design changes have not been properly highlighted in between rounds of consultation, making this a risk to acceptance from the Planning Inspectorate (PINS).
- Less prescriptive approaches create space for more meaningful and collaborative engagement - time and resource intensive statutory consultation requirements have now gone, giving applicants more license for more two-way workshop-style, iterative engagement over more informational drop-in exhibition events. Water companies should make the most of these opportunities to build processes that work for them and the communities hosting their infrastructure.
- Less is not more – where applicants leave questions unanswered, others will answer instead. Where information is missing, it will be important explain the rationale and when it will become available.
- Secure stakeholders’ buy-in on consultation approaches - local authorities and communities are valuable resources for determining the scope of engagement and consultation, and early advice from PINS on strategy will be critical.
- Don’t disregard other guidance – Ofwat’s Public Value Principles and the Gunning Principles offer good foundations, and any engagement and consultation programme should have regard to a water company’s existing customer engagement processes.
Alex Rowntree (alex.rowntree@alpacacommunications.com) is a Senior Significant Projects Manager at Alpaca Communications, a specialist communications and engagement firm specialising in resilient infrastructure.
More from the water sector
Find out how the UK water sector is informing, innovating, and influencing change