Changes to the NPPF: SuDS Paragraph 182
The December 2024 NPPF update broadens SuDS requirements beyond major developments, requiring all applications that could affect drainage to incorporate sustainable drainage systems.
On December 12th 2024, the government updated the National Planning Policy Framework (NPPF), introducing significant amendments affecting flood risk management, including changes to the Sequential Test and Surface Water Drainage requirements.
Chapter 14 Overview
The previous NPPF iteration focused on major applications, reflecting a 2015 transition when the Environment Agency returned responsibility to Local Planning Authorities with emphasis on Surface Water Drainage and Sustainable Drainage Systems (SuDS).
Key Changes: December 2023 vs. December 2024
Previous Version (Paragraph 175): The policy stated that “Major developments should incorporate sustainable drainage systems unless there is clear evidence that this would be inappropriate.”
New Version (Paragraph 182): The updated policy broadens scope, stating that “Applications which could affect drainage on or around the site should incorporate sustainable drainage systems to control flow rates and reduce volumes of runoff, and which are proportionate to the nature and scale of the proposal.” The new version emphasizes multifunctional benefits including water quality improvements, biodiversity enhancement, and amenity benefits.
Policy Context and Local Implementation
In practice, developers increasingly face SuDS requirements across minor and major applications, driven by recent local plan policies.
Croydon — Policy DM25 exemplifies this approach, requiring SuDS in all development with specifications for managing surface runoff close to source, achieving better than greenfield runoff rates, and considering future maintenance.
Arun District Council — Policy W DM3 extends requirements to both major and minor developments, mandating source control features. The policy requires winter groundwater monitoring and percolation testing per BRE365, with designs preventing flooding during 1-in-30-year storm events and containing excess flows from 1-in-100-year events plus 30% climate change allowance within site boundaries.
Conclusion
The 2024 NPPF changes reinforce SuDS as critical planning components, aligning with recent local plan policies. The updated framework emphasizes achieving four key pillars: amenity, attenuation, biodiversity, and water quality.