The EIP: 10 Days of the 10 Goals - Goal 3: Clean and Plentiful Water

Goal 3 of the Environmental Improvement Plan 2025 (“EIP 2025”) relates to water. The Government’s ambition is simple to articulate but daunting to deliver: “We will protect and improve our waters, delivering clean and plentiful water for people and the environment.”

Water pollution has become a particularly hot topic in the UK in recent years, as repeated sewage spillages and contamination incidents have highlighted systemic weaknesses in infrastructure and regulation. Recent data from the Environment Agency show a 60% rise rise in serious pollution events caused by English water companies last year, undermining ecological health and public confidence. The issue has sparked public protest, political debate and calls for regulatory bodies including Ofwat and the Environment Agency to take firm action to hold water firms to account.

There has also been a rise in public recognition and support for the rights of the rivers: to flow, thrive and be free from pollution. In March 2025 Lewes Council recognised for the first time in the UK the legal rights of a river through introducing a Rights of River Charter for the River Ouse, which came about as the result of campaign work supported by the Environmental Law Foundation. In taking this step, Lewes Council follows in the footsteps of movements in New Zealand, Canada and Colombia (among others), and is already setting a precedent across the UK.

The Goal presents a dense series of intentions and commitments, to achieve a vision of water systems restored to ecological health and a secure public water supply that can withstand climate shocks.

But as for previous Goals, sentiment quickly gives way to metrics. And so, with wellington boots firmly on, we wade in.

Commitments

Goal 3 is structured around five strands of commitment, spanning pollution control, long-term supply security, chemicals regulation and public accountability.

1. We will ensure English waters are clean, resilient and plentiful

The headline promise for Goal 3 is broad, wrapping together ecological recovery, infrastructure reform and sector regulation.

On the structural side, the EIP commits to “root and branch reform” of the water sector, including a new single regulator with regional elements, tougher penalties on polluters – including through the new Water (Special Measures) Act, and an explicit political pledge to halve sewage pollution from water companies by 2030.

Alongside this, the government recommits to restoring 75% of water bodies to good ecological status (GES) and “securing continuous improvement” in the water environment, while using the Independent Water Commission’s recommendations to rationalise the tangle of plans and regulators that currently govern the sector.

2. Enabling nature to flourish in healthy water catchments

Here the EIP leans hard into a “catchment-based” approach. The government promises to use catchment partnerships as the organising framework for action across public, private and third sectors (Commitment 23), backed by a regional element through a new regulator and targeted funding, including up to £1 million for cross-border research in the Wye.

Urban water management is pulled into this same logic. By 2029, all new developments with drainage impacts are expected to use standardised SuDS with sustainable maintenance built in (Commitment 24), supported by new national policy, reforms to planning rules and work to end the era of “unadopted” drainage on housing estates. This will be a space to watch.

On pollution, the numbers get more concrete:

• 55% reduction in phosphorus loadings from treated wastewater by 2030 against a 2020 baseline (Commitment 25), delivered through upgrades at 440 wastewater treatment works.
• 12% reduction in nitrogen, phosphorus and sediment pollution from agriculture by 2030, rising to 18% in sensitive catchments with protected sites in unfavourable condition (Commitment 26). This is to be delivered via doubled EA farm inspection funding to 2029, revised Farming Rules for Water guidance, slurry grants, buffer strips and woodland creation, a new nutrient management tool (due winter 2025), and a dedicated programme to monitor and drive agricultural water quality improvements.
• Eight mine water treatment schemes, 20 “diffuse interventions” and 55 catchment studies by 2030 (Commitment 27), plus a specific chalk-stream restoration package (Commitment 28) involving Water Restoration Fund / Water Environment Improvement Fund spending, 11 flagship chalk stream projects and over £2 billion of water company investment targeted at those habitats.

Commitment 29 then wraps this strand, supporting delivery of £24 billion of water company expenditure to improve the environment, including more than £10 billion for around 2,500 storm overflows, and the recycling of fines via the Water Restoration Fund and Water Environment Improvement Fund back into catchment-scale projects.

3. Ensuring a sustainable supply of water to homes, public buildings and businesses

This heading deals squarely with water quantity. The EIP notes a projected 5 billion litre per day national shortfall by 2050 if current trends continue, and positions demand reduction and leakage alongside new infrastructure and abstraction reform as the response.

The core quantitative commitments are:

• Cutting public water supply use per head by 9% by March 2027 and 14% by March 2032 from a 2019–20 baseline (Commitment 30), with household and non-household targets underneath this.
• Reducing household consumption to 122 litres per person per day by 2038 (Commitment 31) and non-household use by 9% by 2038 (Commitment 32). Measures include a mandatory water efficiency label on water-using products from 2026, potential minimum standards and design guidance, and a review of planning policy and building standards to encourage water reuse, dual-pipe systems and more water-efficient housing and commercial buildings.
• Reducing leakage by 20% by March 2027 and 30% by March 2032 from a 2017–18 baseline (Commitment 33), with Ofwat using performance commitments and incentives to hold companies to their targets, and government looking at how smart metering, usage data and tariff structures can reinforce demand reduction.

Water abstraction is brought into the same “sustainable supply” framework. Commitment 35 is to modernise the abstraction licensing system, including moving it into the Environmental Permitting Regulations and responding to recommendations in the June 2025 Independent Water Commission review, while Commitment 36 aims to double the number of Water Abstractor Groups from 7 to 14 by 2030. See here for reporting on a recently-launched challenge against a water abstraction licence to Sellafield nuclear power plant, raising concerns about the impact on the environmentally sensitive rivers Calder and Ehen.

4. Delivering clean rivers, lakes and seas for people to enjoy

The EIP promises modernised Bathing Water Regulations, tightening designation criteria and allowing sites to be managed more flexibly (including outside the traditional bathing season). It also flags a UK-wide ban on wet wipes containing plastic, expected to take effect in spring 2027, to cut microplastic and blockages in sewers and waterway, and focuses on storm overflow spillages (featuring a new Storm Overflows Discharge Reduction Plan (“SODRP”)).

Securing the ability to enjoy clean water has also been an important trend in litigation. For example, Jo Bateman is bringing a ‘right to swim’ challenge against South West Water for loss of amenity after she was unable to swim at Exmouth Beach after a spill linked to a burst water main led untreated sewage to be discharged into the sea.

5. Monitoring and reporting

Finally, Goal 3 has its own monitoring and reporting approach, sitting within the broader Environmental Indicator Framework but with some water-specific twists.

Legal and Policy Significance

On paper, at least, Goal 3 comes with a relatively dense metrics backbone. The real question – as with Goals 1 and 2 – is how far those indicators will be allowed to drive regulatory and investment decisions when they show under-performance, and how transparent that conversation will be in the annual EIP progress reports. Several themes stand out:

Increased regulatory pressure on water companies: An avowedly tougher stance on enforcing a “polluter pays” approach is a notable feature of this Goal. Concerns about the activity of water companies have also been a particular feature of the recent litigation landscape, especially in the wake of the landmark decision in Manchester Ship Canal Company v United Utilities Ltd [2024] UKSC 22, where the Supreme Court ruled unanimously that the Manchester Ship Canal had a right to bring a private law claim against United Utilities in respect of unauthorised discharges of untreated foul water into their canal. The EIP sets a tone of firmness, echoing recent Ofwat and Environment Agency messaging. With strengthened monitoring, heightened public visibility of spills, and ongoing discussions about criminal liability for executives, the regulatory risk profile for the sector is appears to be on the rise.

Nutrient neutrality and planning remain unresolved tensions: The government signals continued ambition to reduce nutrient pollution in sensitive catchments. However, the interaction with the planning system – and particularly the future of nutrient neutrality requirements – remains politically delicate. Goal 3 hints at reforms but gives few operational details. (See C.G. Fry & Son Ltd v SSLUHC [2025] UKSC 35 on nutrient neutrality in the planning context).

Local authority capacity: As with Goal 2, Goal 3 relies heavily on local authorities to deliver planning controls, nature-based solutions, flood resilience and catchment-scale collaboration. Capacity constraints pose a real threat to delivery.

Agricultural pollution: Diffuse pollution from farming remains one of the hardest issues to solve. The EIP’s commitments rely on voluntary uptake of schemes, enforcement of the Farming Rules for Water and the success of the Environmental Land Management schemes. All are moving parts. It will be interesting to see how the impact of this ‘top down’ approach interacts with “polluter pays” challenges – such as the recently-issued Wye pollution claim (challenging industrial chicken production firms and Welsh Water for extensive run-off pollution in the Wye, Lugg and Usk rivers – to force a reduction in agricultural pollution through carrots as well as sticks.

Climate adaptation is no longer optional: England is already experiencing periods of both drought and extreme rainfall (focused on in Goal 8). Achieving “plentiful” water means diversifying supply sources, aligning abstraction reform with ecological limits, and delivering major new infrastructure. All of this requires predictable long-term investment and cross-party political support.

Overall thoughts

If the government succeeds in delivering on even a substantial part of Goal 3, the benefits for ecosystems, human health, and public trust will be profound. But (as with other Goals) those outcomes will depend less on the plan itself and more on whether implementation, funding and enforcement match the scale of the challenge. The structural challenges – including ageing infrastructure, extreme weather, regulatory complexity, financial pressures on the water sector, and capacity issues for local delivery – mean this Goal sits in a difficult space between aspiration and reality.

Natasha Jackson is a barrister at Landmark Chambers.