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Draft 2018 NPPF


What is the draft 2018 NPPF?

Following the 2012 changes made in the planning system, the government has recognised that the current National Planning Policy Framework requires further changes in order to satisfy the housing need in England.

On 5 March 2018, the Ministry of Housing, Communities and Local Government published a draft revised text of the NPPF for consultation. The draft revised NPPF takes a different approach to take planning policy towards maximising house building efficiency rather than viability and deliverability of housing, which was the focus of the 2012 NPPF. Amendments have been made in the draft NPPF regarding design, services, transportation, climate change, local economy and the green belt.

The draft NPPF seeks views on implementation of policy changes that were previously consulted on through the Housing White Paper, the Planning for the right homes in the right places, consultation proposals and the policy changes announced at Autumn Budget 2017. Within the context of the residential development sector, the new planning system has been designed to address five key policy areas:

  • Affordable housing
  • Plan making including the housing requirement
  • Determining planning applications
  • Green belt and brownfield development
  • Housing delivery

What are the key changes in the draft revised NPPF in the context of planning and flood risk?

Meeting the challenge of climate change, flooding and coastal change

Strategic plans should be informed by a Strategic Flood Risk Assessment (SFRA), setting out policies to manage flood risk from all sources. Strategic plans should consider cumulative impacts in, or affecting, areas susceptible to flooding, and take account of advice from the Environment Agency (EA) and other relevant flood risk management authorities, such as Lead Local Flood Authorities (LLFA) and Internal Drainage Boards (IDB).

This implies that local sewer capacity checks may become a material consideration in the planning process and sewarage undertakers being regulatory consultees on all future planning applications.

Exception Test

Where planning applications come forward on sites allocated in the development plan through the Sequential Test, applicants need not apply the test again. However, local planning authorities should consider whether aspects of the exception test (including a site specific Flood Risk Assessment (FRA)) need to be reapplied to specific applications, depending on the extent and nature of potential flood risk identified and assessed during plan production, and the age of such information.

Many of the local authorities’ SFRAs were completed prior to the release of the updated climate change allowances (February 2016). As such, it is likely that sites designated within Local Authorities’ Local Plans may no longer be considered suitable under the new climate change requirements.

Sustainable Drainage Systems (SuDS)

All developments should incorporate sustainable drainage systems unless there is clear evidence that this would be inappropriate.

Also, further changes are expected to appear in the revised NPPF, as some organisations such as the Association of Drainage Authorities (ADA), have responded with the following comments:

  • The NPPF should contain references to consents from other risk management authorities, and not only LLFAs, which may be required in relation to surface water discharges
  • Adoption of SuDS should become a prerequisite within the planning systems
  • Major developments should have to plan for exceedance flows
  • More is needed to support LLFAs and other risk management authorities in regulation and delivering better surface water management

The Consultation on the draft revised NPPF document ended on 10 May 2018 and the final version is envisaged to be published in summer 2018. There will be a six month transitional period from the publication of the new NPPF, during which the 2012 NPPF will continue to be applied in assessing development plans.

If you wish to discuss Flood Risk within planning or SuDS, please do not hesitate to email or


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