All aboard – A year of change for lead local flood authorities (LLFAs)

26 March 2026

Glen Westmore of the Association of SuDS Authorities on how climate, policy and governance change is impacting local authorities’ response to flooding

For lead local flood authorities (LLFAs), significant guidance and policy change seems to come along like buses: very little, then all at once!

Against the backdrop of current or upcoming local government reorganisation towards more consistent unitary authorities, all this additional change can be emotionally exhausting and taxing to find time for. But our view at the Association of SuDS Authorities (ASA) is that these buses are taking us towards an improved and more integrated surface water management destination in 2026.

New national standards for SuDS

We are now nine months on from the publication of new national standards for sustainable drainage systems, a document which successfully collated the best practice that most LLFAs were already using in their role as statutory consultee providing advice for surface water in planning. The new standards also added two fundamental changes: firstly, the requirement to intercept at least the first 5mm of rainfall falling on the development site area. Secondly, developers also need to use the collection of rainwater for non-potable use – rainwater harvesting (RWH) – as the first consideration in managing surface water. Both of these are welcome as they support increased resilience against water stress and, if done correctly, reduce consumer water bills. There is work to do when it comes to including RWH across all types of development, but the technology is there and the whole sector is evolving quickly into this space.

The standards also doubled down on the requirements for SuDS to be truly multifunctional: supporting biodiversity (with obvious linkages to biodiversity net gain (BNG) obligations); delivering amenity; and mitigating any water quality impacts. The fundamental message – of considering water early in the design process in a holistic way – was music to many ears, but this really does require collaboration both for the design team and those assessing planning applications.

Given the wording in the December 2024 update of the National Planning Policy Framework (NPPF), the standards are also likely to impact non-major developments (those of fewer than 10 houses, or smaller than 1ha or 1,000sqm). This is a positive step change for these development types, which make up a significant proportion of planning applications and have a huge cumulative impact on surface water runoff. Many LLFAs are launching guidance on how to incorporate SuDS proportionally in this space but it may be a learning curve for many smaller developers, especially regarding water reuse.

All things flood

Then in July we had an update from the Department for Environment, Food and Rural Affairs (Defra) on the statutory guidance that LLFAs must follow when conducting Section 19 flood investigations under the Flood and Water Management Act 2010. The guidance clarifies the scope of the investigation required by LLFAs when significant flooding occurs; plus reporting duties; communication with other risk management authorities (RMAs); and expectations on data collection and publication. Again, this consolidated the approaches many authorities were using anyway.

The autumn and winter then brought a whole fleet of government consultations covering flood funding reforms, design guides, a new FCERM strategy and a revised NPPF.

In October, the flood funding reforms confirmed the rules for the FCERM programme for 2026 onwards, with all prioritised projects under £3 million eligible for full government funding and larger projects getting £3 million upfront plus 90% of remaining costs. There’s a clear focus on supporting deprived communities, and LLFA schemes are expected to benefit, both in terms of confirmed delivery and because there is now less need to find partnership funding. The associated FCERM funding policy guidance, published this month, fills in the details and highlights the eligibility of standalone natural flood management projects. These provide wider benefits to people, nature and the environment, support biodiversity, improve water quality and enhance resilience to climate change. Again, we see the bus route moving towards more integrated catchment management and wider consideration of water.

National Planning Policy Framework

And so, spring has arrived, and we await the outcome of the NPPF consultation with much anticipation. The full integration of national SuDS standards into the framework, as well as the integration of water management across climate change, building sustainability and biodiversity considerations, is to be welcomed. SuDS will hopefully support good site design and water management across the full range of development sizes. Alongside this, I hope we will see the retention of the new policy text protecting open ditches, streams and rivers, and encouraging removal of piped watercourses where possible; this will support the role of LLFAs in regulating changes made to non-main watercourses. We are also lobbying for a change to the Sequential Test for surface water: to ensure a consistent principle of locating development away from all areas of medium and high flood risk, whilst recognising the positive impact SuDS can have on managing low levels of this type of risk.

As I’m sure we will see at Flood & Coast 2026, many lead local flood authorities, internal drainage boards and water companies are leading the way, providing clarity locally with guidance to support the implementation of the emerging approaches. In the long term, the recent changes will undoubtedly move us towards a better place: improved SuDS on developments; reduced flood risk through NFM, catchment approaches and water level management; more integrated water management; and greater climate resilience. The destination of travel is looking good.

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The ASA are working with CIWEM, among others, to provide clarity on the new approaches and to support Defra and the Ministry of Housing, Communities and Local Government (MHCLG) in their advice. For more information about joining ASA as either a local authority member or as an associate member please visit: suds-authority.org.uk.

For more on how lead local flood authorities will be responding to these changes, book your ticket to Flood & Coast 2026, where experts will be coming together on day one for a panel discussion entitled “FCERM in transition: Responding to climate, policy, and governance change”.

Glen Westmore is the Flood Risk Planning and Consenting Team leader in the Flood and Climate Resilience Team at Surrey County Council and co-chair of the Association of SuDS Authorities