Fife Council Flood & Drainage Updates 2025: Key Developer Changes

Overview

Earlier this year (June 2025), Fife Council published an updated version v3.0 of its Design Guidance on Flooding and Surface Water Drainage Requirements, replacing the previous 2022 edition (v2.1). This update aligns the document with National Planning Framework 4 (NPF4), SEPA guidance, and current best practices in flood risk management, including hydraulic modelling requirements and SuDS design. For developers, the changes introduce more detailed requirements, a tiered approach to applications, and enhanced focus on climate resilience.

1. Alignment with National Planning Framework 4 (NPF4)

The new guidance follows NPF4 Policy 22 (Flood Risk) and Policy 10 (Coastal Development), establishing “avoidance first” as a core principle: “development at flood or erosion risk should be avoided wherever possible.”

2. Introduction of a Tiered System (Major vs Local Applications)

Applications are now categorised into Tier 1 (Local) and Tier 2 (Major) developments.

Local Applications require independent SuDS/FRA checks by a separate company from the designer/assessor, covering:

• Small-scale housing (fewer than 50 units or <2 hectares site area)
• Small business/industrial schemes (<10,000 m2 floorspace or <2 hectares)
• Most change-of-use applications
• Small extensions or alterations

Major Applications allow independent checks within the same company as the designer/assessor, including:

• Housing: 50+ dwellings, or site over 2 hectares
• Business/industrial/storage/distribution: Over 10,000 m2 floorspace or site >2 hectares
• Electricity generation: Capacity >=20 MW
• Waste management: >=25,000 tonnes per year, or >=50 tonnes per day (sludge)
• Transport/infrastructure: Road, railway, tram, waterway, aqueduct or pipeline >8 km long
• Fish farming: Surface area of water >2 hectares
• Mineral extraction: Site area >=2 hectares
• Other development: Gross floorspace >=5,000 m2 or site area >2 hectares

What this means: Expect extra professional sign-off requirements, particularly for smaller schemes that previously may have slipped through with less scrutiny.

3. Updated Climate Change & Sea Level Rise Allowances

• Rainfall uplift: Still 39%, but applicants must always check SEPA’s latest figures
• Sea level rise: Now explicitly included: 0.85m by 2080, plus 0.15m per decade beyond 2100 for long-life developments
• Freeboard: More stringent guidance for coastal sites, factoring in wave action and erosion. Previously, finished floor levels could be situated 600mm above the peak still water extreme design coastal flood level. Since the 2025 update, an additional allowance to account for wave action must be included, meaning acceptable finished floor levels will generally be higher than previously acceptable
• Compensatory storage: If land raising removes floodplain storage, like-for-like replacement is mandatory. Per NPF4, compensatory storage applies only to four exceptions:
  • Essential infrastructure where the location is required for operational reasons
  • Water compatible uses
  • Redevelopment of an existing building or site for an equal or less vulnerable use
  • Redevelopment of previously used sites in built up areas where the LDP has identified a need to bring these into positive use and where proposals demonstrate that longterm safety and resilience can be secured in accordance with relevant SEPA advice

What this means: Modelling expectations are higher, and proposals near coasts will be expected to include finished floor levels higher than before.

4. Flood Risk Assessment (FRA) — More Detail Required

• FRA now required at both PPP and Full Application stage
• Must demonstrate safe access/egress during flood events
• Hydraulic models must include sensitivity testing. Fife Council provides four explicit examples:
  • Boundary conditions (e.g., 20% increase in design flow)
  • Surface roughness (increasing or decreasing the roughness coefficient used in the model)
  • Location and type of upstream and downstream boundary conditions to ensure no impact on results within the area of interest
  • Blockage of critical structures such as culverts and other hydraulic structures prone to blockage during flood events. The percentage blockage scenario(s) should be justified based on site specific factors

What this means: Fife Council now requires more technical modelling if a site is within or close to areas at risk of flooding.

5. Drainage Impact Assessment (DIA) — Replaces Surface Water Management Plans

“Surface Water Management Plans” have been replaced with Drainage Impact Assessments (DIA), maintaining the same principle of demonstrating sustainable drainage with expanded requirements:

• No SuDS or storage allowed in the 200-year + climate change floodplain. This is a key amendment; early consideration of both flood risk and SuDS design should occur during initial project stages
• The list of sensitive receiving watercourses has expanded to include:
  • Auchtermuchty — Calsay Burn / Auchtermuchty Burn
  • Ballingry — Lochty Burn (and unnamed culverted watercourses within the town)
  • Cairneyhill — Torry Burn
  • Cupar — Lady Burn, River Eden
  • Dunfermline — Lyne Burn, Mowbray Burn, Bellyeoman Burn
  • East Wemyss — Kingslaw Burn
  • Falkland — Maspie Burn (and unnamed culverted watercourses within the town)
  • Freuchie Mill — Pittilock Burn
  • Inverkeithing — Inverkeithing Burn, Keithing Burn, Brankholm Burn, Whinny Burn
  • Kirkcaldy — Den Burn, Tiel Burn
  • Kinglassie — Lochty Burn
  • Leven — Scoonie Burn, River Leven
  • Rosyth — Brankholm Burn, Whinny Burn
  • St Andrews — Kinness Burn, Lumbo Burn, Cairnsmill Burn, Swilken Burn

If planning a controlled surface water discharge to any named watercourse, discharge rates up to and including the critical 1 in 200 year plus climate change event must be lower than the standard Fife-wide criteria (the lesser of 1 in 2 year greenfield runoff rate / 3.3 l/s/ha, compared to 1 in 5 year greenfield runoff rate / 4.0 l/s/ha).

What this means: If planning surface water discharge to sensitive watercourses, account for additional on-site attenuation compared to other watercourses throughout Fife region.

6. Coastal Erosion

For the first time, coastal erosion is explicitly addressed. The Council’s stance emphasizes that “Avoidance is the first principle for development in erosion risk areas.” Coastal schemes will face an additional layer of risk assessment beyond flood risk alone. The Dynamic Coast webmap provides a starting point for identifying if a site may be at risk of coastal erosion.

How Aegaea Can Help

The latest changes require additional flood risk and drainage input during early project stages. Aegaea has extensive experience throughout the Fife Council region, with flood risk consultants, drainage experts, and hydraulic modellers well-versed in local and national Scottish policy.