Changes to the Sequential Test - NPPF
The revised NPPF Paragraph 175 alongside new National Flood Risk Standing Advice changes the landscape for Sequential Test work, potentially unlocking more sites.
So, we have a new National Planning Policy Framework (NPPF), what is the importance of the changes with focus to flood risk? Quite significant.
Aegaea have been supporting many clients on Sequential Test work; and with the recent changes in the NPPF including the revised Paragraph 175 alongside the National Flood Risk Standing Advice to Local Authorities on the sequential test, it has changed the landscape and approach.
“The sequential test should be used in areas known to be at risk now or in the future from any form of flooding, except in situations where a site-specific flood risk assessment demonstrates that no built development within the site boundary, including access or escape routes, land raising or other potentially vulnerable elements, would be located on an area that would be at risk of flooding from any source, now and in the future (having regard to potential changes in flood risk).”
“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 located in areas at risk of any source of current or future flooding.”
Requirements for Sequential Tests
Looking back at the evolution of the NPPF over the past 12 years, the NPPF of 2012 required a Sequential Test if located in Flood Zone 2 and 3, then this evolved to all sources with the later iterations of the NPPF and Planning Practice Guidance.
Aegaea has supported projects throughout this period, demonstrating in some cases that risks from all sources of flooding could be mitigated or removed through the production of a Flood Risk Assessment and good design. However, even with these measures, some applications, adhering to the older guidance, were still subject to the Sequential Test and, in certain cases, failed on this basis alone.
The recent changes with the sequential test are encouraged and welcomed. We have recently had approvals where pragmatism, hydraulic modelling and good design has removed the need for the Sequential Test and led to approvals.