The Planning Practice Guidance (PPG) on flood risk, updated on 17th September 2025, represents a significant shift in how flood risk is managed through the planning system. The changes create new opportunities for development but also impose higher expectations on applicants and planning authorities.
Implications for Developers and Landowners
A key change is that, in cases of surface water flooding, a robust site-specific Flood Risk Assessment (FRA) can remove the requirement for the Sequential Test. Development can therefore now proceed without having to demonstrate the availability of more sequentially preferable sites, provided the FRA clearly shows that:
- Occupiers will be safe for the full lifetime of the development.
- Flood risk to surrounding areas will not increase.
This offers Northern Trust Land the opportunity to unlock existing sites and potential new opportunities previously considered unsuitable. However, the bar for FRA’s has been raised considerably – they must be thorough, technically robust, incorporate climate change projections, and demonstrate resilience both on-site and in wider catchment terms.
Challenges & Higher Standards
The change offers a route to approval for sites in areas of surface water flooding, but shifts emphasis onto the quality of FRA evidence:
- More advanced modelling and expert input may raise upfront costs.
- Poorly prepared FRAs risk delays or refusal, as authorities will rely on them more heavily.
- The benefit currently applies only to surface water flooding; river and tidal risks still require the Sequential Test.
This places greater emphasis on professional competence and early technical investment, one of the key strengths of working with Northern Trust Land.
Strategic & Policy Context
The PPG also refines how decision-makers assess “reasonably available” sites within Sequential Testing. New provisions emphasise proportionality, allow consideration of sites outside an applicant’s control, and permit aggregation of smaller sites. The use of updated Environment Agency data, including the 2025 Flood Map for Planning, which now models defended and undefended extents, strengthens the evidence base for both local decision-making and strategic planning.
Wider Planning System Impact
The revised guidance reflects government priorities for integrating resilience into sustainable growth. It reinforces:
- The expectation for Sustainable Drainage Systems (SuDS) in all developments.
- Closer alignment between planning policy, investment in flood defences, and climate adaptation strategies.
- A stronger link between development viability and long-term resilience.
Conclusion
The latest PPG update provides greater flexibility by enabling detailed FRAs to substitute for the Sequential Test in certain cases, but they significantly raise expectations of technical evidence. This requires greater investment in early and rigorous assessments, making Northern Trust Land your ideal promotion partner.
