Change description : 2025-08-27 16:58:00: Updated due to planned changes to Flood Map for Planning, recent policy changes to NPPF, publication of a FRA template, and new national standards for SuDS [Guidance and regulation]
Check if your development needs to satisfy the sequential and exception tests
Before you start a FRA, check if your development needs to satisfy the sequential test.
The sequential test steers development to areas with the lowest flood risk. It compares your proposed site with other available sites to show which one has the lowest flood risk. The LPA may refuse planning permission if other, lower risk sites are identified.
When the sequential test is needed
A sequential test is required for major and non-major development (refer to check the development class) if any proposed building, access and escape route, land-raising or other vulnerable element will be:
in Flood Zone 3b and your development is not incompatible
within Flood‘Flood ZoneZones 1plus andclimate thechange’, floodshowing mapforplanningshowsit is at increased risk of flooding from rivers or sea duringin itsfuture lifetime – see the flood map for planning
within Flood Zone 1 and the flood map for planning shows it is at risk of flooding from surface water
in Flood Zone 1 and the LPA’s SFRA shows it will be at increased risk of flooding during its lifetime
subject to sources of flooding other than rivers or sea
A development is not exempt from the sequential test just because a FRA shows it can be made safe throughout its lifetime without increasing risk elsewhere. See What is the aim of the sequential approach?
When development is exempt from the sequential test
Development is exempt from the sequential test if it is a:
householder development like residential extensions, conservatories or loft conversions
small non-domestic extensions with a footprint of less than 250 square metres
change of use - except changes of use to a caravan, camping or chalet site, or to a mobile home or park home site
Development is also exempt from the sequential test if it is a development on a site allocated in the development plan through the sequential test and:
the proposal is consistent with site’s allocated use
there have been no significant changes to the known level of flood risk to the site, now or in the future, which would have affected the outcome of the test
You may not need a sequential test if development can be laid out so that only elements such as public open space, biodiversity and amenity areas are in areas at risk of any source of current or future flooding.
How to apply the sequential test
You should speak to the LPA early to discuss the sequential test and to determine an appropriate area of search for the test. The LPA should consider whether the test is passed, with reference to the information it holds on land availability.
You should also include information with your application to identify any other ‘reasonably available’ sites not already identified by the LPA within the area of search. This should include sites such as those currently available on the open market. The LPA may also require you to check on the status of alternative sites to determine if they can be considered ‘reasonably available’. Refer to guidance on Applying the sequential test to individual planning applications. Speak to the LPA to find out what further information may be needed on the sequential test.
directly affect a watercourse that is not a main river
involve activity in the floodplain of a main river which could divert or obstruct floodwaters, damage any river control works or affect drainage, and potential impacts are not controlled by a planning permission
are covered by regional flood defence and land drainage byelaws, where these are applicable
Check if your development activity and location are covered by regional flood defence and land drainage byelaws by referring to this statutory guidance.
Flood risk permits or consents are often needed as well as planning permission. Getting planning permission does not guarantee you’ll also get a flood risk permit or consent.
If there is a watercourse (including culverted watercourses) on or next to your development site, you should also read owning a watercourse and your watercourse: rights and roles. These will help you understand your responsibilities and the rules you need to follow.
What to include in the flood risk assessment
You can increase the chances of including the right information in your FRA by using the Environment Agency’s FRA template and guidance.
Your FRA should be:
appropriate to the scale, nature and location of the development
proportionate to the degree of flood risk
Your FRA should appraise the suitability of the flood risk datasets it has used. This should take account of:
how you have laid out your development to avoid areas of flood risk, make space for water and retain access for any watercourses or flood defences
site drainage arrangements, including the location of any SuDS, where relevant
any new or existing structures that could affect water flow for example bridges, embankments, culverts
Survey of site and development levels
You need to provide a survey and cross-section showing existing and proposed:
site levels
average site level
ground level of the access road(s) next to your building(s)
finished floor levels of the lowest room(s) in your building(s)
Check with your LPA to find out if you also need to show your site in relation to its surroundings.
You should also show estimated flood levels for your site in the design flood, and any watercourses on or next to the site. Show all levels in metres above Ordnance Datum (the height above average sea level). You may be able to find Ordnance Datum information from the Ordnance Survey. If not, you will need to pay for a land survey by a qualified surveyor.
Information on past floods
You should also include details of past floods where this information is available. To find out about past floods:
contact your lead local flood authority (LLFA) - your local council will help you find out who this is
contact your LPA about any relevant flood investigation reports (also known as section 19 reports)
Details on the frequency, extent and severity of any past flooding should be included where available, including how it affected your development site. Where changes to flood risk management structures and features have happened since past flooding, explain how these may affect flood risk to your site.
FRAs for large scale or vulnerable development in high-risk areas are likely to need to include a high level of detailed information. In some cases, this will need to include detailed hydraulic modelling. This is to make sure the flood risk to and from the development is understood in a proportionate way. The Environment Agency and LLFAs often have hydraulic modelling which can help you assess flood risk.
Refer to What is residual flood risk? Ask the Environment Agency for the information they hold on flood defence breach. If breach models are not available, you will need to assess the potential effect and reach of flood water if a defence is breached. Refer to Flood Risk Assessment Guidance for New Development, particularly section 12 of phase 2 full technical report, for guidance on how to do this.
Your FRA should:
consider the safety of people in buildings, in the areas around buildings and in adjacent areas
demonstrate how the development will stay safe throughout its lifetime, without increasing flood risk elsewhere - this should include people who are less mobile or who have a physical impairment
consider the structural safety of buildings
the impact of a flood on the essential services provided to and by a development
You need to lay out your site to steer the most vulnerable aspects of the development to the lowest risk parts of the site.
Put low vulnerability uses in areas of highest risk, for example:
amenity open space
nature conservation areas
biodiversity areas
If buildings cannot wholly avoid areas at risk of flooding, follow the guidance on floor levels.
Floor levels
Finished floor levels should be a minimum of whichever is higher of 600mm above the:
average ground level of the site
adjacent road level to the building(s)
estimated river or sea flood level for the site
Where there is a high level of certainty about your estimated flood level, you may be able to reduce this to 300mm. If there is a particularly high level of uncertainty it may need to be increased.
Your FRA should specify the estimated flood level for your site. The estimated flood level is the depth of flooding anticipated on your development site in a:
In areas affected by both river and tidal flooding, your FRA should consider a scenario when river and sea flood events combine to create worse flooding.
You may be able to request the estimated flood level and information about residual risks through the Environment Agency’s flood map for planning. You may also be able to get it from your LPA’s strategic flood risk assessment. If not, you will need a flood risk specialist to calculate this for you.
Your plans need to show how you are going to ensure the development is not flooded by surface water or groundwater. You could do this by:
diverting water away from buildings but safely managing it within the site
raising floor levels above the estimated flood levels of surface and groundwater flooding
You should also use construction materials that have low permeability up to at least the same height as finished floor levels.
If you cannot raise floor levels in this way, consider if the development can be made safe and appropriately flood resistant and resilient.
This can be done by:
raising floor levels as much as possible
moving vulnerable uses to upper floors
including extra flood resistance and resilience measures
When considering the height of floor levels, you should:
consider any additional requirements from the SFRA
account for any information on past floods
Flood water can put pressure on buildings causing structural issues. If your design aims to keep out a depth of more than 600mm of water, you should get advice from a structural engineer. They will need to check the design is safe.
Extra flood resistance and resilience measures
Follow the guidance in this section:
for development in areas at risk of flooding where you cannot raise the finished floor levels to the required height
if your building design should prioritise excluding flood water where possible
if design should also speed recovery in case water gets in
Make sure your flood resilience plans for the development follow the guidance in the CIRIA Property Flood Resilience Code of Practice. Note that the code of practice uses the term ‘recovery measures’. In this guide we use ‘resilience measures’.
It may not be possible to safely exclude the full estimated flood level. If this is the case, you will need to exclude it to the structural limit then allow additional water to flow through the property. Note that the Environment Agency is unlikely to consider internal flooding of new vulnerable development to be acceptable.
The design should be appropriately flood resistant and resilient by:
using flood resistant materials that have low permeability to at least 600mm above the estimated flood level
making sure any doors, windows or other openings are flood resistant to at least 600mm above the estimated flood level
using flood resilient materials (for example lime plaster) to at least 600mm above the estimated flood level
raising all sensitive electrical equipment, wiring and sockets to at least 600mm above the estimated flood level
making it easy for water to drain away after flooding such as installing a sump and a pump
making sure there is access to all spaces to enable drying and cleaning
making sure that soil pipes are protected from back-flow such as by using non-return valves
dealing with and preventing water from the surrounding ground entering below ground structures such as basements - British Standard 8102:2022
You also need to comply with relevant Building Regulations in Part P. They set minimum and maximum heights for certain electrical infrastructure.
Temporary or demountable flood barriers are not appropriate for new buildings. Only consider them for existing buildings when:
there is clear evidence that it would be inappropriate to raise floor levels and include passive resistance measures
an appropriate flood warning or other appropriate trigger is available
arrangements are in place to ensure such features will be maintained, serviced and replaced in line with manufacturer recommendations
If your proposals involve the development of buildings constructed before 1919, refer to Flooding and Historic Buildings guidance produced by Historic England.
Access and escape
You need to provide details of your emergency access and escape plans if any part of your development is below the estimated flood level. This includes access and escape routes. Follow the Flood Risk Emergency Plans for New Development guidance.
Make sure your plans show:
a safe route of access and escape, set above the estimated flood level and connects the site to an area away from flood risk
that any single storey buildings or ground floors without access to upper floors can access a safe refuge above the estimated flood level
that any basement rooms have clear internal access (for example a staircase) to an upper floor above the estimated flood level
how the development could be evacuated before an extreme flood (0.1% annual probability of flooding with an allowance for climate change)
You need to show that residual risks can also be safely managed, ensuring people will not be exposed to hazardous flooding. This may mean additional mitigation measures are needed such as:
further floor raising to minimise internal flood depths
precluding sleeping accommodation on ground floors
providing an internally-accessible safe refuge
You also need to comply with relevant Building Regulations in Part B. They require you to provide suitable access for the fire service.
To ensure an acceptable standard of operation for the lifetime of the development, SuDS for major development will need to have:
appropriate minimum operational standards
maintenance arrangements
Even where the national planning policy framework (NPPF) does not require the use of SuDS, we recommend they be considered on all development types. This would include changes of use, wherever appropriate.
You should include all the information set out in:
Refer to the non-statutory technical standards for guidance on the design, maintenance and operation of SuDS. Further guidance on how to design SuDS to maximise their benefits is in the CIRIA Suds Manual.
You can follow Water UK’s Design and Construction Guidance to design and construct SuDS. This will ensure they qualify for adoption by the relevant water and sewerage company.
You need planning permission to surface more than 5 square metres of a front garden with a non-porous material.
Sites within the functional flood plain
If your site falls within the functional floodplain you need to state this.
Functional floodplain is defined in Table 1 of Planning Practice Guidance and shown in your LPA’s SFRA. If suitable information is not available for your site, you should make your own assessment of whether it is in a functional floodplain. To inform your assessment of functional floodplain you can refer to the following information on flood map for planning:
present day 3.3% annual probability extent of river and sea flooding with defences
water storage areas
Your FRA should appraise the suitability of these datasets for identifying functional floodplain in each location.
Only two vulnerability classifications are not considered incompatible with the functional floodplain. These are:
water compatible
essential infrastructure that has met the exception test
Such development will also need to be designed and constructed to:
stay operational and safe for users during a flood
avoid impeding water flows or increasing flood risk elsewhere
make sure there is no net loss of floodplain storage
Getting planning advice on your proposals
The Environment Agency can give a free preliminary opinion to applicants. This advice is in addition to the statutory consultation process. They can tell you which climate change allowances to use and how to use them in your assessments.
Provided additional guidance to ensure FRAs appraise the suitability of flood risk datasets before use
25 March 2025
Amended to signpost new flood and coastal erosion risk data and provide advice on its use and to reflect revised policy on sustainable drainage systems in the December update to the National Planning Policy Framework.
22 July 2024
Added link to 'your watercourse: rights and roles' under 'check if you need any other permissions or consents' section.