Planning Practice Guidance (PPG) Update: Changes to the Sequential Test

The Planning Practice Guidance (PPG) on Flood Risk and Coastal Change was updated on the 17^th September 2025. Changes were made to Paragraphs 23, 27 and 28, and a brand-new paragraph 27a was added.

In this post, we assess the changes to the PPG wording and outline the implications the new guidance has on application of the Sequential Test moving forward.

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Impact on Development:

Sequential Test and Surface Water Flood Risk:

The updated PPG states that the Sequential Test no longer needs to be applied where it can be demonstrated that a development would remain safe from current and future surface water flood risk for the lifetime of the development without increasing flood risk elsewhere.

Therefore, providing that a site-specific Flood Risk Assessment can demonstrate that occupiers will remain safe from surface water flood risk, and there are no alternative sources of flood risk at the site, the Sequential Test no longer needs to be applied.

Proportionate Search:

Greater emphasis has been given to the Sequential Test being proportionate to the scale and nature of a development. The guidance outlines the need for pragmatism when defining the search radius and highlights the fact that it may not always be appropriate to extend the search beyond a specific village or town.

Holistic Approach: 

Additional factors including housing land supply should be considered alongside the outcome of the Sequential Test. This means that in instances where the Sequential Test is not passed a development should no longer be automatically refused.

‘Reasonably Available’ Site:

The definition of what a ‘reasonably available’ site is has been revised so that it no longer includes the requirement for applicants to consider part of a larger site within their search. The new definition also states that ‘reasonably available’ sites should meet the same development needs as the original site.

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What are the Technical Changes?

Paragraph 23: What is the aim of the sequential approach?

Change:

The following sentence has been removed

'Even where a Flood Risk Assessment shows the development can be made safe throughout its lifetime without increasing risk elsewhere, the Sequential Test still needs to be satisfied'.

Paragraph 27: How should the sequential test be applied to planning applications?

Change:

Major changes have been made to Paragraph 27. It has been reworded to now state that

'In applying paragraph 175 a proportionate approach should be taken'.

And that the sequential test does not need to be applied 'where a site-specific flood risk assessment demonstrates clearly that the proposed layout, design, and mitigation measures would ensure that occupiers and users would remain safe from current and future surface water flood risk for the lifetime of the development… without increasing flood risk elsewhere'.

The following sentence has also been taken from the former Paragraph 28 ‘The absence of a 5-year housing land supply is not a relevant consideration in applying the Sequential Test for individual applications’. However, in the revised guidance it is followed by ‘housing considerations, including housing land supply, may be relevant in the planning balance, alongside the outcome of the Sequential Test'.

Paragraph 27a: How should the area of search for the sequential test be identified?

Change:                                                                                                          

Whilst Paragraph 27a is a new addition to the PPG, it includes components from the former Paragraph 27 such as the Sequential Test being defined by local circumstances.

It also includes the following slightly reworded sentence

'Where there are large areas in Flood Zones 2 and 3 (e.g. coastal towns and settlements on major rivers) and development is needed in those areas to sustain the existing community, sites outside them are unlikely to provide reasonable alternatives'.

The final  section of Paragraph 27a  introduces the concept that in certain circumstances large scale developments could be split across a number of alternative sites at lower risk of flooding. However, this would only be acceptable where those alternative sites would be capable of accommodating the development in a way which would still serve its intended market(s) as effectively.

Paragraph 28: What is a ‘reasonably available’ site?

Change:

The following has been removed from Paragraph 28 “or part of a larger site”  and “they are able to meet the same development needs” has been added.

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How We Can Help

If you would like to find out more about how the recent update may impact your development, get in touch with one of our chartered consultants who would be happy to discuss your site in more detail.

Get in touch with us here or call us on 01174 414993.