Consultation response - The proposed NPPF reforms and what they mean for flood risk

Louis Ramirez
Jun 2
4 min read

Updated: Jun 3

March 2026 -

This briefing is written for flood action groups, other civil society actors, politicians and policy makers.

It explains the Government's proposed reforms to the National Planning Policy Framework (NPPF) in England and what they mean for flood risk — particularly surface water flooding — and sets out the position of Flooded People UK and the flood action groups it represents.

What the NPPF is and why this reform matters

The National Planning Policy Framework (NPPF) sets the rules local authorities in England follow when deciding where and what to build. The Government has consulted on reforms to it, and Flooded People UK — together with 27 flood action groups and sixteen individual flood survivors — submitted a response.

Two long-standing safeguards sit at the centre of the concern. The sequential test steers development towards land at the lowest flood risk first; the exception test sets a higher bar a development must clear if it cannot avoid flood-risk land. Flooded People UK argues these are vital instruments for avoiding inappropriate development and should be kept — even where the only risk is from surface water.

The context is a rising share of new homes in harm's way: Aviva estimates that between 2022 and 2024 roughly one in nine new homes were built in areas of medium or high flood risk, up on the average across the 2010s.

What the reforms change

The presumption in favour of sustainable development (Q36)

Even as amended, Flooded People UK warns the revised presumption risks enabling development that will itself be flooded or intensify flooding elsewhere, weakening the effective consideration of flood risk — especially surface water — in planning decisions.

Development within settlements (Q37)

The shift towards greater permissiveness worries the group at a time of rising surface water flooding. The “automatic right to connect” new developments to drainage has placed pressure on England's drainage systems since at least the 2008 Pitt Review — yet Schedule 3 of the Flood and Water Management Act 2010, which would let authorities act on drainage capacity, has never been brought into force.

Planning for climate change — CC1 and CC3 (Q42, Q44)

Flooded People UK welcomes CC1's greater emphasis on avoiding increased vulnerability to climate change, including flood risk, and on addressing specific risks in site allocations. But it sees a contradiction: other parts of the package weaken planning for flood risk even as CC1 strengthens the climate framing. On CC3, the group supports locating development where flood risk is minimised, while warning that the combined effect of policies F4 to F8 is to dilute flood-risk scrutiny.

The flood risk policies F4–F8

The central objection is that newly introduced exceptions to the sequential and exception tests for surface water flooding open a route for proposals to avoid adequate consideration of flood risk.

The core concern: surface water exemptions

The sequential test (F5)

Flooded People UK objects to clause 2.b.ii, which would create an exemption from the sequential test based on a developer's own submissions about current and future surface water flood risk.

The exception test (F6)

A parallel concern applies to F6 clause 2.a, which would similarly allow the exception test to be bypassed on the strength of proposer submissions about surface water safety.

Why self-assessment is the problem

With planning authorities stretched, the group fears that site-specific flood risk assessments wrongly claiming safety from surface water will not be properly scrutinised. It points to a 2023 TCPA survey of local authority planning staff in which one in four felt they lacked the skills and expertise to account for flood risk, and over a third felt their authority lacked the capacity and resources to do so. In practice, the group argues, the changes create a system of developer self-monitoring for surface water flooding.

Flooded People UK's view: If homes are then flooded from surface water, occupants face not only the upheaval of flooding but possible exclusion from affordable insurance, because new-build properties are not covered by Flood Re.

Drainage and watercourses

Sustainable drainage systems (F8)

The group welcomes stronger promotion of sustainable drainage systems (SuDS) and the requirement that they meet the National Standards. But it notes that SuDS remain dependent on a development's drainage implications being considered, rather than being mandatory. Given that Schedule 3 of the 2010 Act was never enacted and that development keeps pressing on existing drainage, it argues SuDS should be made mandatory for all developments, as the 2010 Act intended.

De-culverting and re-naturalising rivers (Q175)

Flooded People UK welcomes the new policy to avoid enclosing watercourses and to encourage de-culverting and the re-naturalisation of river channels.

The human stakes

Behind the policy detail are people who have lived through flooding. The submission carries their testimony.

“Even the best PFR in the world can't completely stop water entering your property. We should just build houses on safer land. Water damage is the worst kind of damage you can get in your home. It destroys everything, causes mould growth and is incredibly disruptive.”

— Kathryn Moss, Sandiacre, flooded 2023

“The current government is pushing for new homes to be built, and it seems that councils are prioritising this over people's wellbeing and flooding issues.”

— Jenny South, Plymouth, flooded 2025

Where Flooded People UK stands

In short, the coalition supports the reforms that strengthen climate and drainage thinking — CC1's framing, the promotion of SuDS to National Standards, and the de-culverting policy — but opposes the new surface water exemptions to the sequential and exception tests, which it believes will put more people in harm's way. It calls for the tests to be maintained for surface water, for SuDS to be made mandatory, and for Schedule 3 of the 2010 Act to be enacted.

The response was submitted by Flooded People UK alongside 27 flood action groups across England and sixteen individual flood survivors.

Key sources

Flooded People UK and flood action groups — response to the NPPF reform consultation (2025).
Aviva — estimate of new homes built in medium or high flood risk areas, 2022–24.
The Pitt Review (2008) — learning lessons from the 2007 floods.
Flood and Water Management Act 2010 — Schedule 3 on sustainable drainage.
TCPA (2023) — survey of local authority planning staff on flood risk.
Flood Re — eligibility, including the exclusion of new-build properties.