Matt Wyatt, associate at PWA, looks at the latest government updates to flood risk planning policy – and what it means for future development.
For anyone involved in property development, the ‘sequential test’ has often been a source of frustration. For years, this planning requirement has stalled viable projects, with ambiguity around ‘reasonably available’ sites causing costly delays and uncertainty.
We’re pleased to report that a long-awaited update is bringing welcome, pragmatic changes. The government’s September 2025 update to the Planning Practice Guidance (PPG) on flood risk marks a significant shift towards a more evidence-led approach that will help unlock development.
The updated guidance addresses several of the most criticised aspects of the flood risk policy, bringing much-needed clarity.
A key exemption
This is a crucial, though specific, update. The guidance now states that the ‘sequential test’ need not be applied where a site-specific Flood Risk Assessment (FRA) demonstrates the development would be safe from ‘current and future surface water flood risk’.
This is a major step forward for sites where manageable surface water issues -like localised ponding after heavy rain – were previously a significant procedural roadblock. However, it’s vital to note this exemption is specific. For sites where the primary risk is from rivers (fluvial) or the sea (tidal), the full ‘sequential test’ will still be a requirement.
Sensible area of search
The concept of the ‘area of search’ for alternative sites was previously vague. The PPG now provides much-needed clarity.
For non-major housing developments, the area of search should not usually extend beyond the specific town, city area, or village and its immediate neighbours. This prevents applicants from having to assess unrealistic alternatives in distant locations.
Definition agreed for ‘reasonably available’
The guidance now gives a clear definition of what makes an alternative site ‘reasonably available’. A site must be:
- Suitable for the type of development proposed.
- Able to meet the same development needs.
- Have a reasonable prospect of being developed at the same time as the proposal.
Crucially, the guidance confirms that alternative sites do not need to be owned by the applicant to be considered. This provides a clear, consistent framework for assessment.
What this means for your projects
These updates represent a tangible move towards a more balanced and proportionate planning system. For our clients, this means:
- Projects previously stalled by manageable surface water risk may now be deliverable without needing to pass the ‘sequential test’.
- For years, the ‘sequential test’ has been a major barrier to growth in communities with large areas in Flood Zones 2 and 3, such as coastal towns. The updated guidance now takes a much more reasonable approach, acknowledging that where development is needed to sustain these communities, sites located far outside them are unlikely to be realistic alternatives.
- A more streamlined process for eligible sites, these changes will significantly speed up the planning process.
- Clearer definitions reduce ambiguity and the risk of inconsistent decision-making from local authorities.
- This pragmatic approach will help bring forward more sites, including windfall developments, which are crucial for meeting housing targets.
Let’s revisit your plans
Have you had a planning application held up due to an identified surface water flood risk? Have you been hesitant to pursue a site because of a localised drainage issue, even if the wider fluvial or tidal risk was low?
These vital updates could present a new opportunity. The door is now open for projects that were previously locked by procedural red tape related to surface water.
If you require planning advice, PWA can help. Contact Matt or call our planning team on 01772 369 669.
