Building resilience into the NPPF

20 April 2026

Can planning reform deliver growth while protecting communities, asks Charlotte Nunns ahead of her workshop at Flood & Coast 2026

Flood risk is often labelled as an environmental constraint to development. In reality, it is an inherently economic issue. With millions of homes, businesses and critical infrastructure exposed to flooding and coastal change, the choices we make today about where and how we build will determine the resilience, viability and prosperity of communities across England for decades to come.

This is why the government’s December 2025 consultation on the National Planning Policy Framework (NPPF) – and in particular the proposed new chapter, ‘Managing Flood Risk and Coastal Change’ – has attracted such keen attention from practitioners, policymakers and developers alike.

Decades of under delivery have created a long‑running housing crisis. On entering office, the government identified the planning system as a known barrier and moved to reform the NPPF as a first step toward boosting housing supply and economic growth. The changes were led by central government, supported by new legislation, expert advice from the New Towns Taskforce, and engagement with the planning and development sector to create a more delivery‑focused system.

The proposed reforms aim to consolidate guidance, strengthen clarity and better reflect modern risk. My view is that the draft NPPF does lay a stronger foundation for flood risk and climate‑resilient growth. However, the consultation also highlights deeper structural issues that policy wording alone cannot resolve. We must align policy with the evidence, tools and capacity needed to implement it to deliver both sustainable development and meaningful protection from flood risk.

Clearer structure, clearer expectations

One of the most notable improvements in the draft NPPF is clarity. The new chapter on flood risk brings previously scattered and sometimes ambiguous policy into a much more structured, readable and useable format – and this matters. For years, inconsistent interpretations of flood risk policy have created uncertainty for both planning authorities and applicants.

Policy F1 strengthens the requirement for up‑to‑date strategic flood risk assessments (SFRAs), which are produced by local planning authorities to map flood risk and inform where development should take place. Importantly, Policy F1 explicitly requires plans to consider future flood risk as well as current conditions, but it could go further by introducing a five-year SFRA update cycle, which would ensure that current and future flood risk from all sources is considered at all stages of the planning process. Policy F2 reinforces the sequential, risk‑based approach which prioritises development in areas of lowest flood risk, only considering higher-risk sites where no suitable alternatives exist – it remains a cornerstone of national planning policy.

This clearer, more coherent organisation does not change the fundamentals, but it does make them easier to apply and, in a system under significant capacity pressure, clarity is one of the most effective enablers of growth. When requirements are transparent and unambiguous, planning becomes more predictable, decision making becomes more consistent and time frames become more manageable for all parties.

Sequential test improvements – and the challenges that remain

Policy F5 introduces long‑requested refinements to the sequential test. It clarifies when the test applies, how to treat areas at risk of surface water flooding only, and how the “area of search” – the geographical extent used to identify lower-risk alternative sites – should be defined. This supports a more proportionate approach and should reduce unnecessary delays. But the sequential test remains one of the greatest friction points in the planning system and is the area where the gap between policy and practice is most visible.

The inclusion of surface water flooding within the sequential test is understandable, given the growing climate‑related pressures on drainage systems. However, the national surface water maps remain too coarse to support consistent local decision making. They frequently flag risks that are highly localised or manageable with good design, creating unnecessary barriers for otherwise suitable sites. While the updated NPPF recognises the value in site-specific flood risk assessment when applying the sequential test, these do not always capture how surface water actually flows through a site.

In practice, drainage systems are typically designed to manage additional runoff from new development, rather than existing surface water moving across the land. An updated national surface water flood map for planning – one that reflects flow paths rather than just localised surface water pooling or historic flood records – would significantly improve accuracy and reduce unnecessary refusals.

The current test treats defended and undefended floodplains identically. This does not reflect real‑world risk and restricts development in areas where defences are robust, well‑maintained and effective. I consider that a new defended category, for example, Flood Zone 3C, would enable appropriate development behind flood defences, providing that long‑term maintenance is secured through funding mechanisms such as a community infrastructure levy (CIL) or Section 106.

Smaller, unplanned development sites – commonly known as windfall sites – face disproportionate barriers because they are assessed in isolation, without access to the larger-scale mitigation that can help manage flood risk. This creates particular challenges in regeneration‑focused urban areas, where brownfield redevelopment is often both desirable and sustainable.

Current requirements for safe access and escape can prevent development even where most of a site lies in a low-risk area of flooding (Flood Zone 1), if routes in and out are prone to flooding. A more detailed, risk‑based approach – one that looks at how deep and fast floodwater could be, and who might be affected – would better reflect the real level of risk. This aligns with established flood hazard guidance (FD2320) and is less likely to block sustainable development unnecessarily.

Environmental protection and climate alignment

Alongside growth, the NPPF proposals make meaningful progress on environmental resilience. In particular, policy F3 strengthens coastal policy, expanding its scope to tidal rivers and estuaries, requiring alignment with shoreline management plans and formally adopting a 100‑year planning horizon into development planning. Policies F4-F7 bring much‑needed clarity to site‑specific flood risk assessments. They streamline the criteria for the exception test which allows development in higher-risk areas in certain circumstances clarifies when it needs to be applied, and sets clearer standards for when development can be considered safe.

And policy F8 introduces stronger requirements for sustainable drainage systems (SuDS), mandating alignment with national standards and encouraging naturalisation, including the opening up of culverted waterways.

These reforms align with calls made by the sector for a more climate responsive and nature positive planning system. However, the effectiveness of these policies depends heavily on the evidence used to support them. Outdated strategic flood risk assessments (SFRAs), inconsistent surface‑water mapping and variable local planning authority and regulatory capacity remain significant obstacles. Strengthening policy will only deliver the intended outcomes if matched by parallel investment in data, tools and skills.

The NPPF consultation stops short of setting out an enhanced framework that could deliver additional benefits for flood risk planning while also unlocking sustainable development and regeneration. For example, the sequential test does not currently prioritise brownfield land, meaning lower-risk greenfield sites are often favoured instead. Further improvements could be realised through a flood risk credit system that would enable developers to contribute to strategic, catchment‑wide mitigation. This would ensure mitigation requirements are more proportionate to the scale and constraints of individual sites and help unlock development, especially on smaller sites where on‑site mitigation is constrained or difficult to deliver.

Technical barriers the NPPF cannot solve alone

Discussions across the industry, reinforced by recent professional roundtables, consistently identify several systemic issues the NPPF alone cannot address. These include significant variation in SFRA age, quality and methodology and the fact that there is no mandated frequency for SFRA updates. Surface water data limitations, especially around flow paths, plus insufficient tools for small and medium sites with constrained mitigation options are another challenge.

Resource constraints in local planning authorities and lead local flood authorities, and limited integration between planners, developers and regulators are also an issue. Both undermine implementation.

These are not policy failings, they are system failings and they require national coordination, investment and cross-sector collaboration to resolve.

A strong foundation but there is more to do

The proposed NPPF consultation represents a meaningful step forward. It offers clearer policy, stronger environmental protections and a more coherent approach to managing flood and coastal risk. However, clarity alone cannot deliver resilient outcomes.

The true challenge – and opportunity – lies in aligning policy with practice. To build communities that are safe, resilient and economically sustainable, we must pair strong national policy with high‑quality data, consistent guidance and properly resourced authorities.

Flood risk and housing delivery are not opposing priorities. With pragmatic reforms and proportionate, evidence‑based approaches, they can and must be aligned.

Resilience is not the opposite of growth. It is the foundation on which growth depends.

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Charlotte Nunns will be presenting on 11 June at Flood & Coast 2026. Learn more and book your conference ticket today.

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Charlotte Nunns is chair of the CIWEM East Anglian Branch and a senior associate flood risk manager at Mott MacDonald