Committee publication · Correspondence · 11 March 2026 · HC 550
Letter from Town and Country Planning Association relating to planning for flood risk and the current consultation on the draft National Planning Policy Framework, 25 February
From: Environmental Audit Committee
Inquiry: Flood resilience in England
Summary
The Town and Country Planning Association writes to the Environmental Audit Committee expressing concern that the draft National Planning Policy Framework (NPPF) inadequately addresses flood risk despite government reassurances. The letter argues that proposed policies use weak language ('should' vs 'require'), weaken sequential testing for surface water flooding, and fail to implement Schedule 3 of the Flood and Water Management Act 2010, leaving communities exposed and creating uninsurable properties.
Key findings
- Policy F8 uses 'should incorporate' rather than 'require' sustainable drainage systems (SuDS), creating uncertainty where NPPF policy can be disregarded
- The sequential test for flood risk has been weakened through legal cases and policy changes, particularly allowing developers to disapply it for surface water flooding—the fastest-growing flood risk source
- Proposed reductions in Lead Local Flood Authority oversight on medium-sized sites, combined with failure to enact Schedule 3 of the Flood and Water Management Act 2010, undermine flood resilience
- Increasing proportion of new homes are being allocated in flood risk areas despite government claims of maintaining 'strong safeguards'
- Current planning system risks creating large volumes of uninsurable property with significant economic consequences
Tone
CriticalTopics
Key actors
Town and Country Planning Association, Toby Perkins MP, Environmental Audit Committee, Helen Morgan MP, Emma Reynolds MP, Department for Levelling Up, Housing and Communities, Lead Local Flood Authorities
Notable line
“This is not the same as ' requiring ' development to deploy SuDS, and because the NPPF is policy which can be disregarded it leaves significant uncertainty in the system.”
Key Quotes
“The planning system is a vital tool for responding to the rapidly increasing threats of flood risk driven by the climate crisis.”
“This is not the same as ' requiring ' development to deploy SuDS, and because the NPPF is policy which can be disregarded it leaves significant uncertainty in the system.”
“Surface water flooding is having a devastating impact on communities and is the fastest growing source of flood risk in England.”
“… the current system is not fit for purpose in securing public safety and economic resilience.”
“… the proposals present real risks to the wider economy through the creation of a significant amount of uninsurable property.”
Source · parliament.uk record ↗