Flood Risk and Sustainable Drainage
The NPPF (2026) also places stronger emphasis on addressing flood and coastal change issues at the plan-making stage, with Local Plans expected to be supported by up-to-date Strategic Flood Risk Assessments that consider both current and future climate-related risks. It also reinforces the need to take account of advice from the Environment Agency and other flood risk management authorities.
For developers and landowners, the practical point is that flood risk constraints should be understood at the allocation stage rather than left until application. Future climate change effects and wider consequences of flooding are likely to feature more prominently when authorities decide which sites should come forward.
Policy F3 significantly strengthens the plan-making approach to coastal change. Coastal Change Management Areas will need to take account of Shoreline Management Plans and the National Coastal Erosion Risk Map, cover relevant estuaries and tidal rivers, and consider risk over a 100 year period.
For coastal development, this means a longer-term view needs to be taken when assessing land. Sites which may not appear constrained today could still be affected by future erosion or coastal change and may therefore require a different development strategy or be unsuitable for certain uses.
F4 brings the requirements for site-specific Flood Risk Assessments into one clearer policy and directly references the Flood Map for Planning. It largely consolidates existing requirements which were previously spread between the 2024 NPPF and its footnotes. The important development point is that Flood Zone 1 should not automatically be treated as meaning there is no flood risk issue. Surface water, groundwater, ordinary watercourses and future flood risk need to be considered where relevant. Therefore, early flood risk appraisal remains important even where there is no mapped fluvial or tidal constraint.
One of the most useful changes from a development perspective is, Policy F5 as it gives much clearer guidance on when a Sequential Test is and is not required. Where surface water flooding is the issue, a Sequential Test may not be required if a site-specific FRA can demonstrate that the layout, design and mitigation will keep the development safe for its lifetime.
This should help sites where mapped surface water flooding affects a relatively limited or manageable part of the land. Rather than automatically creating a wider alternative sites exercise, there is greater opportunity to resolve the risk through masterplanning, levels, drainage design and exceedance routing.
F5 also clarifies that the geographical area used for a Sequential Test should reflect the likely catchment of the development’s occupiers or users. This should help prevent unnecessarily wide search areas being applied moving forward.
Also helpfully, Policy F6 brings the Exception Test into a clearer standalone policy and links it directly with the flood risk vulnerability classifications now included within the draft NPPF (2026) itself. This is a useful change as allocated sites which have already passed the Exception Test during plan making should not normally have to repeat the exercise at application stage unless flood risk has materially increased or a more vulnerable use is subsequently proposed.
Policy F7 sets out a clear management test that a development must remain safe throughout its lifetime and must not increase flood risk elsewhere. Where the criteria cannot be met, the policy is explicit that the development should be refused.
With a greater focus on how schemes actually function during flood events, finished levels, safe access, residual risk, exceedance routes and the location of vulnerable uses will all need to work together to demonstrate that a drainage system can accommodate a design storm.
One of the most important changes for drainage design is that going beyond the well trodden path of expecting SuDS to be provided, crucially, those systems should now be designed in accordance with the National Standards for Sustainable Drainage Systems.
One of the most important changes for drainage design is that going beyond the general expectation for SuDS to be provided, crucially, those systems should now be designed in accordance with the National Standards for Sustainable Drainage Systems. This will push drainage further into the front end of masterplanning. The National Standards place emphasis on managing water close to source, water quality, biodiversity, amenity, climate resilience and long-term maintenance. F8 also introduces stronger policy against enclosing watercourses and supports de-culverting and re-naturalising river channels.
Policy F9, strengthens the controls applied to developments at risk from coastal change. Importantly, sites identified as being at risk on the National Coastal Erosion Risk Map will be subject to the same tests as sites within formally designated Coastal Change Management Areas, even where the local authority has not yet incorporated them into one. The policy also makes it explicitly clear that permanent new residential development, including through change of use, is inappropriate within these areas.
The key consequence is that developers should not rely on the current Local Plan designation when assessing coastal land. National erosion mapping and long-term coastal change will need to be considered at the earliest appraisal stage, particularly where a site’s future depends on continued coastal defence.
Brookbanks View:
Flood risk, drainage and climate resilience are becoming key planning and site selection considerations not just application-stage technical matters. Much of the NPPF (2026) consolidates and clarifies existing requirements, but emphasis on early assessment, integrated masterplanning and compliant SuDS design should now provide greater certainty for well-planned sites. Developers who identify flood constraints early, embed blue-green infrastructure within their proposals and demonstrate a clear strategy for long-term resilience will be best placed to navigate policy, and have successful site promotion and delivery.