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National Planning Policy Framework 2019 (NPPF)

Changes that Affect Flood Risk

On the 24th July 2018, a revised version of the NPPF was been released in order to consider the changes in national policies relating to Housing and Economic Needs. Following a technical consultation, the updated (and final) version of the NPPF has since been released (on the 19th February 2019). The main changes to the revised NPF are in relation to housing needs across the country, however, there have also been some minor amendments with regard to Flood Risk Management which are summarised below.


Overview and Key Changes

Climate Change

The revised NPPF now includes a stronger emphasis on future development which was absent in the older version. This becomes apparent in Paragraph 155 of the new NPPF which states that “Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk (whether existing or future).” This shows that the government recognises the importance of taking into consideration the impacts of climate change when managing flood risk.

The Sequential Test and Exception Test

There are no major changes regarding the requirements of the Sequential and Exception Test. The revised NPPF rather provides a clearer, more comprehensible terminology of the requirements, aiming to make it easier for the reader to understand its principles. An example is that further clarification has been provided with regard to the need for an Exception Test. Previously, the NPPF simply stated that if it is not possible, following the Sequential Test, to locate development in areas shown to be at lower risk of flooding, the Exception Test can be applied if appropriate. However, the revised NPPF explains in more detail that the requirement for the Exception Test to be applied depends on the “potential vulnerability of the site and of the development proposed, in line with the Flood Risk Vulnerability Classification set out in national planning guidance.” Although the requirements remain the same as the previous NPPF and no changes have been made to the national planning guidance, the application of the Exception Test is more clearly defined. The wording of the two elements of the Exception Test has also been updated, however, the principles and requirements remain unchanged.


For the Exception Test to be passed, the FRA must demonstrate that:

  • the development would provide wider sustainability benefits to the community that outweigh the flood risk; and
  • the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall.

One of the most significant changes has been made in relation to ‘allocated sites’. Although, as in the previous version of the NPPF, the Sequential Test does not need to be applied for sites allocated as part of the development plan, the NPPF now sets out that allocated sites may still be subject to the Exception Test if “relevant aspects of the proposals had not been considered when the test was applied at the plan-making stage, or if more recent information about existing or potential flood risk should be taken into account”.

Is a Flood Risk Assessment still required?

In short, Yes, NPPF still requires a site-specific flood risk assessment to be submitted for all proposals for new development (including minor development and change of use) in Flood Zones 2 and 3. Proposals of 1 hectare or greater in Flood Zone 1, or in an area within Flood Zone 1 which has critical drainage problems also require a site-specific FRA.

Some of the key changes have been made to the requirements for a site-specific Flood Risk Assessment. A Flood Risk Assessment is still required for all development located in Flood Zones 2 and 3, however, for development located in Flood Zones 1, the requirements have been expanded to also include:

“land identified in a strategic flood risk assessment as being at increased flood risk in future”.

“or land that may be subject to other sources of flooding, where its development would introduce a more vulnerable use.”

This highlights the importance of considering flood risk to development in the future. In addition, further clarification has been provided on what minor development entails. The description is now in line with the Environment Agency’s definition and includes householder development and, small non-residential extensions (with a footprint of less than 250m2). A change of use is also classified as minor development, however, a Sequential and Exception Test is still required in line with the classifications set out in the national planning guidance for changes of use to a caravan, camping or chalet site, or to a mobile home or park home site.

Sustainable Drainage (SuDS)

Sustainable drainage has only played a minor role within the previous NPPF which mentioned that “it gives priority to the use of sustainable drainage systems.” However, following changes in both national and local planning policies, which set out requirements to incorporate SuDS into new development, the NPPF has been updated to reflect these changes in policy. It is now necessary to explicitly demonstrate that SuDS is incorporated “unless there is clear evidence that this would be inappropriate”.

In addition, reference has been made to major development, the description of which can be found in The Town and Country Planning Order, and the following requirements are now set out in the NPPF: Major developments should incorporate sustainable drainage systems unless there is clear evidence that this would be inappropriate. The systems used should:

a) take account of advice from the lead local flood authority;

b) have appropriate proposed minimum operational standards;

c) have maintenance arrangements in place to ensure an acceptable standard of operation for the lifetime of the development; and

d) where possible, provide multifunctional benefits.


In summary, the requirements remain largely unchanged. There is a greater emphasis on the impacts of climate change which means that when deciding on appropriate development, it will be necessary to take account of the impacts of climate change when managing future flood risk. Furthermore, the revised NPPF sets a whole new focus on sustainable drainage which has previously been absent. For development, it is now necessary to demonstrated that SuDS is incorporated where possible and SuDS for major development is now required to be designed in accordance with the requirements set out in the NPPF.

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