Planning Practice Guidance Update: A More Balanced Approach to the Sequential Test

18 September 2025

Planning Practice Guidance Update: A More Balanced Approach to the Sequential Test

The Planning Practice Guidance (PPG) has been updated with immediate effect, introducing important changes to the way Paragraph 175 of the National Planning Policy Framework (NPPF) is applied when assessing flood risk through the Sequential Test.

Previous Position
Previously, the Sequential Test process was definitive and strict, leaving little flexibility. Any site located within an area of medium or high flood risk was required to undergo the test, regardless of whether mitigation measures could make the site safe. This often led to delays for otherwise deliverable sites and, in some cases, prevented development due to minor or isolated flood risk areas.

Updated Guidance
The revised PPG now provides a more proportionate approach. Where a site-specific Flood Risk Assessment (FRA) clearly demonstrates that the layout, design, and mitigation measures will keep occupiers safe throughout the lifetime of the development, and without increasing risk elsewhere, the Sequential Test does not need to be applied.

This change is expected to remove unnecessary barriers for sites where the risk is minor and manageable, helping ensure development is not delayed by what could be considered isolated or low-level flood risk.

Key Changes at a Glance

• Proportionate Application of the Sequential Test – Clarity on Paragraph 175 of the NPPF  has been provided, which now allows a more balanced approach. Sites should no longer be held up by minor or isolated flood risk issues if an FRA demonstrates that safe development is possible.
• 5-Year Housing Supply Clarified – The lack of a five-year housing supply is no longer relevant when deciding if the Sequential Test should be applied, although it may still play a part in the overall planning balance.
• Focus on Realistic Alternatives – The guidance emphasises focusing on genuine, deliverable alternatives. Small-scale developments will not need to consider sites far beyond their immediate area, while larger schemes may need to assess whether several smaller sites could meet the same housing or development need at a lower risk of flooding.
• Clearer Definition of ‘Reasonably Available’ – Land is now considered “reasonably available” if it can accommodate the same level of development, is deliverable, and is feasible to bring forward within the same timeframe as the proposal.

Implications for Development
These updates are expected to reduce the number of sites that must go through the Sequential Test process and unlock more land for development, particularly where risk can be managed effectively. For many schemes, this should result in faster progress through the planning system and fewer delays caused by technicalities.

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