Read the new national planning policy framework? Let's look at flood risk and drainage implications

With this being a very busy time of the year for many of us, there's not much time for extra reading 📖 Hopefully this post saves you some time! ⏱️ 

The government issued a response to the consultation on proposed NPPF & planning system reforms, which summarises the changes well.

You can view it here.

Question 80 in particular is pertinent to the topics discussed in this post, flood risk and drainage. 

Flood Risk / Sequential Tests:

A new paragraph 175 has been added, explicitly stating that a sequential test is not required if a site-specific flood risk assessment demonstrates that all new development, including access/egress routes and other vulnerable areas, is located outside areas at any level of flood risk.

This is a logical approach where now, only development itself (as opposed to open space for example) which falls within the land at risk of flooding will require a sequential test. The government has also committed to updating the Planning Practice Guidance to provide greater clarity on the interpretation of ‘reasonably available sites’ within the context of the sequential test.

Drainage & SuDS:

The government has removed the restriction limiting the consideration of SuDS to ‘Major Development.’ New paragraph 182 of the NPPF now requires SuDS to be considered for all developments, proportionate to the scale and nature of the scheme. The previous NPPF stated ‘Major Developments’ and was typically interpreted, except where standing advice from LLFAs stated otherwise, as SuDS being required only for major development, or non-major/minor development within areas of high flood risk or critical drainage problems. This change also acknowledges the cumulative surface water impact of multiple smaller developments.

Promoting Healthy and Safe Communities:

In response to the consultation question 71, the government has added the following to paragraph 102.a. (previously 101.a.): ‘The safety of children and other vulnerable users in proximity to open water, railways and other potential hazards should be considered in planning and assessing proposals for development’.

This highlights the importance of considering safety for children and vulnerable users especially, which is particularly important for highway and public realm design, the design of SuDS, nature-based solutions or other landscape features that include open water, and the design of new access to unlock the amenity value of canals, rivers, lakes etc.