MHCLG PPG Updates on Surface Water Flooding

The Ministry of Housing, Communities and Local Government (MHCLG) has updated the Planning Practice Guidance (PPG) on flood risk, most notably regarding surface water flood risk.

In August 2022, PPG was updated to state that sequential tests should account for all sources of flood risk and climate change. Whereas previously the sequential test had only been triggered in relation to flooding by rivers and sea, this change resulted in surface water flooding also potentially triggering the need to undertake a sequential test even if any risk it could be adequately mitigated through the development process. 

To help boost housing delivery the guidance has now been subject to further updates on 17th September 2025. The updates clarify that the aim of the of the sequential test is to ensure low risk areas are the preferred locations for new development and “this means avoiding, so far as possible, development in current and future medium and high flood risk areas considering all sources of flooding including areas at risk of surface water flooding.”

Paragraph 175 of the National Planning Policy Framework states that “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).”

PPG (Paragraph: 027 Reference ID: 7-027-20220825 Revision date: 17 09 2025) now confirms that a sequential test does not need to be applied “where a site-specific flood risk assessment demonstrates clearly that the proposed layout, design, and mitigation measures would ensure that occupiers and users would remain safe from current and future surface water flood risk for the lifetime of the development (therefore addressing the risks identified e.g. by Environment Agency flood risk mapping), without increasing flood risk elsewhere.” 

In the consideration of a planning application, PPG states that “the absence of a 5-year housing land supply is not a relevant consideration in applying the sequential test for individual applications. However, housing considerations, including housing land supply, may be relevant in the planning balance, alongside the outcome of the sequential test.”

PPG (Paragraph: 027 Reference ID: 7-027-20220825 Revision date: 17 09 2025) now provides further guidance and limits for the search area for a sequential assessment application for non-major housing development. It states, “it would not usually be appropriate for the area of search to extend beyond the specific area of a town or city in which the proposal is located, or beyond an individual village and its immediate neighbouring settlements.” 

PPG (Paragraph: 028 Reference ID: 7-028-20220825 Revision date: 17 09 2025) sets out the considerations for a sequentially assessed site to be ‘reasonably available’ (an appropriate preferred location) as being:

• Suitable for the type of development proposed;

• Able to meet the same development needs; and

• Having a reasonable prospect of being developed at the same time as the proposal.