How the NPPF and September 2025 PPG update apply to flood risk on your site, and where advisory work fits in before reports are commissioned.
The National Planning Policy Framework (NPPF) sets out how flood risk should be considered in planning. Planning Practice Guidance (PPG) provides the detailed interpretation, and the September 2025 update made significant changes to how the Sequential Test applies to flooding, including surface water.
Understanding the policy is one thing. Understanding what it means for a specific site, with its particular flood zones, surface water flow paths, access routes, proposed use and development constraints, is another. That gap between policy and site is where planning applications succeed or fail on flood risk grounds, and it is where we focus. We investigate how sites behave, and that insight feeds directly into the advice we give on what reports are needed, in what scope, and in what sequence.
This page focuses on the NPPF and PPG as they apply to flood risk on individual sites. We also offer flood risk advisory for the Sequential Test and Exception Test and on the wider Flood Risk Assessment process. Where a site needs scoping advice before reports are commissioned, our Planning and Development Constraints service is often the right place to start.
The NPPF requires a sequential, risk-based approach to development. The aim is to steer new development towards areas of lowest flood risk. Where flood risk is present, the policy operates in layers: a Flood Risk Assessment to demonstrate lifetime safety, the Sequential Test to ask whether a lower-risk site is reasonably available, and where necessary the Exception Test to justify development on a higher-risk site.
The September 2025 PPG update changed how the Sequential Test applies in two important ways. First, it now applies to all sources of flood risk, not just rivers and the sea. Surface water, groundwater, reservoirs and drainage systems are now considered on an equal footing. Second, a narrowly drawn exemption was introduced. Where a site is solely at risk from surface water flooding, and a site-specific FRA can demonstrate the development will be safe for its lifetime without increasing flood risk elsewhere, the Sequential Test does not need to be applied. The exemption is tightly drawn and is conditional on the FRA evidence supporting it, not the existence of a drainage strategy. Where any part of the site is also in Flood Zone 2 or 3, or at risk from groundwater or other sources, the exemption does not apply.
Vulnerability classification also matters. The NPPF classifies development by vulnerability, from Essential Infrastructure down to Water-Compatible uses. A change of use can trigger Sequential and Exception Test requirements that did not apply to the existing use, which is a frequent source of difficulty on conversion and intensification projects.
NPPF and PPG interpretation is most valuable at the front end of a project, before the scope of reports is fixed. Common situations where site-specific advice changes what is actually needed include:
In each of these situations, the value of advisory work is determining whether the FRA is the right next step, what scope it needs, and whether the planning argument can be supported by the available evidence.
The Sequential Test is planning-led. The flood risk input supports it; it does not drive it.
The Sequential Test does not apply in every circumstance, and one of the most common problems we see is assumptions being made either that it is always required, or that it can always be avoided.
National policy and Planning Practice Guidance contain a number of exemptions and qualifications, including certain minor development, changes of use, sites already allocated through a Local Plan process, and specific situations where flood risk considerations have already been addressed at plan-making stage. The position can also differ depending on whether the issue relates to river and sea flooding, surface water flooding, or other sources of risk.
The September 2025 surface water exemption is only one part of a much wider policy framework. Whether the Sequential Test applies depends on the interaction between the proposed use, vulnerability classification, flood source, planning history, allocation status and what the FRA evidence can actually demonstrate.
In practice, the planning question is often not simply “is the Sequential Test required?”, but whether the available planning and technical evidence is capable of supporting the development proposal in its specific context.
For more detailed guidance on the Sequential Test itself, including when it applies, common exemptions, vulnerability classifications and how the planning process typically operates in practice, see our dedicated Sequential Test page.
We look at how a site behaves before we advise on what reports it needs. For NPPF interpretation that means obtaining and reviewing EA model data, mapping surface water extents in GIS, reviewing proposed layouts against flood zone boundaries, and advising on vulnerability classifications, Sequential Test exposure and the availability of the September 2025 surface water exemption.
For architects working to RIBA stages, our dedicated FRA service for architects sets out how flood risk input can be sequenced through the design process. For developers managing multiple sites, our FRA for developers page sets out how we work alongside acquisition and planning teams.
Years combined civil & environmental engineering experience
Years delivering drainage, design and risk advisory
Projects including individual assets valued at £1 billion+
Drainage design and flood risk commissions delivered
We look at the site location, the headline flood risk context and the proposed development to give an indication of likely requirements and whether advisory work is appropriate.
Where detailed review is needed we agree a clear scope and fees.
We obtain the EA model data, surface water mapping, SFRA references and any other relevant evidence, and review against current NPPF and PPG.
We map flood risk against the proposed layout in GIS, consider vulnerability classification, Sequential Test exposure, exemption availability and Exception Test requirements where relevant.
We provide written advice setting out the position, the issues, and the recommended way forward. This may be a short note for a specific question or a fuller scoping document for a complex site.
Where the next step is an FRA, drainage strategy or other deliverable, we can advise and support.
Here are some of our latest testimonials from satisfied clients. If you’d like to discuss your requirements further, please don’t hesitate to get in touch.
We are a charity owning a large parcel of land where gathering water is then affecting neighbouring properties. Received expert flood risk and drainage advice from FPS Environmental Ltd. All dealings with them were timely and professional. Site visit arranged where we were able to fully discuss causes and solutions. Great peace of mind obtained from engaging their expertise.
Michael Rowell
Landowner
The report I received was for a Flood Survey which was very thorough and clearly a lot of work had gone into it. The team were always available and conscious of deadlines. I would definitely recommend them if you are looking to get a flood survey completed.
Mike Gray
We spent thousands of pounds on poor quality investigations before reaching out to FPS Environmental. Most surveyors over promised and underdelivered creating tremendous stress for me and my family. FPSE has been absolutely amazing from the very beginning. They treated us with respect and restored our faith in this industry. We are incredibly grateful to them and highly recommend the company to anybody who wants to get a top product and piece of mind.
George Albota
I have used FPS, Simon and his team on several occasions over the last few years to advise on the flood risk and mitigating factors on both houses and prospective businesses. They have deep expertise and contacts across the spectrum of flood management. In particular, I have found their assessment reports invaluable. Whilst they are understandably busy, they are good to deal with and I would have no hesitation recommending them to anyone who is looking for advice in the sector.
Richard Warburton
Business Owner
FPS was really helpful in providing consulting advice in connection with a residential property acquisition. Sebastian from FPS undertook the survey and followed up with a full report and a consultation call to run through everything. The basic desktop data suggested a high flood risk, but this property-specific survey allowed us to take a well-informed position following Sebastian’s advice. Great work – and he and the FPS team were really helpful throughout the process. I’d certainly recommend them.
Richard Brandon
Very impressed with FPS Environmental Ltd and the guidance we have received to date. We had an hour long online consultation with the principal surveyor, and it was extremely helpful and productive. Thank you FPS. Will use the company again and highly recommend.
Helen Sutherland
FPS were able to work to our schedule and fit in an appointment at short notice. There was great communication from the office staff keeping us informed of any changes or requirements before the site visit.
The site survey was very thorough and Simon very knowledgeable, and quite happy to answer all questions. The provided report was extensive with usable information and recommendations. I will use FPS in the future and happily recommend them to all of my clients.
Drew Kirkland-Crawford
Deadwood Services Ltd
Send us your project brief and we will come back with a scope and indicative fee. Where additional input is required, this is provided on a formal instruction basis.
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