Reliable Sequential and Exception Test
Detailed Reports to get your Development Underway
Sequential and Exception Tests for your Planning Application
We work with planning consultants to create comprehensive sequential test reports in compliance with the UK planning system, national and local planning policy and the planning appeal system.
We use our substantial understanding of the local planning requirement to create reliable reports.
Our Sequential and Exception Reports
We combine our planning expertise with flood data to provide you with an accurate assessment of the sequential test. We are happy to talk you through all of the available options – so get in touch!
How Do We Work?
We consult the local planning policies to determine the scope of the assessment.
We liaise with the architects and project team to determine project considerations.
We review the sites contained within the development plan.
We assess the availability of sites appropriate for the proposed development in areas with a lower probability of flooding.
We enable you to make informed changes to your design, ensuring that it meets the local and national planning policies. We also work hard to meet your deadline.
Our Sequential and Exception Test Methodology
To help your development to get through the planning stages, we apply our tried and tested sequential test methodology. Our work reflects our desire to create a more inclusive and sustainable society.
Understand the local authority requirements and the site within the planning policies.
Identify the alternative sites to be tested. Review the council’s policy documents and planning approvals to determine the baseline parameters for comparable sites.
Flood Zone identification and evaluation of flooding from other sources. Determine the reasonably available sites.
Complete report by assessing the sites and taking into account other factors such as employment land requirement, transport and services.
Our background in planning and flood risk analysis ensures a robust sequential test that strengthens your planning application.
Frequently Asked Questions
What is the sequential test?
The sequential, risk-based approach outlined in paragraph 100 of the NPPF and the Planning Practice Guidance on Flood Risk and Coastal Change (PPG) is designed to ensure that areas with little or no risk of flooding from rivers (Flood Zone 1) and other sources of flooding are developed in preference to areas at higher risk.
The intent of the sequential test is to determine the areas at higher risk of flooding (Flood Zones 2 & 3) and focus on developing areas outside of these zones.
In cases where development is necessary it must be safe and not increase flood risk elsewhere. The proposed development should aim to reduce the causes and impact of flooding.
Within Flood Zone 1, a Sequential Test should be taken to ensure that, wherever possible, the development is situated away from areas at risk from all other sources of flooding. For example: ground water flood and run-off flooding.
How can you determine if your development is at risk from flooding?
- Check our flood maps and determine the flood risk probability. There are four flood zones. Zone 1, Zone 2, Zone 3a and Zone 3b.
- Flood defences normally have no bearing upon the designation of the Flood Zones as the consequences for your development need to be assessed against a ‘worst case’ scenario. Once you know the Flood Zone your development is in, you:
- Check the strategic flood risk assessment
- Once you know if it is at risk of flooding then you check your site against the Strategic Flood Risk Assessment. This way you can establish if the council has already applied a sequential test to your development.
- However, the council may request a sequential test even if your development is located within an approved area for development.
When is the Sequential Test required?
The Sequential Test is required for:
Developments where a sequential tests has not been completed as part of the Strategic Flood Risk Assessment or the local plan.
All development proposals within flood risk zones 2, 3a and 3b and if the development is considered to be inappropriate for the flood zone of the site. See tables above. In such circumstances permission would normally be refused.
When is a Sequential Test not required?
A Sequential Test is not required in the following circumstances:
(Please note that this list is not exhaustive)
- If the proposal is for the change of use of land/buildings only. This applies for any change of use unless it involves a change of use to a caravan, camping or chalet site, or to a mobile home or park home site. If significant operational activities (for example major excavations) are proposed then a Sequential Test is required.
- If the proposal is a minor non-residential extension only (i.e. less than 250 square metres).
- If the development does not increase the size of the building and only includes alterations to external appearance.
- If it is a householder development that does not create a separate unit of residential accommodation.
- If the local council, as part of the Local Plan process, or a neighbourhood planning group, have already sequentially tested the site. Despite this, a sequential test is required if the proposed development is not in accordance with the allocations and planning policies. An example of this is a situation in which a housing development is proposed for a site which has been allocated for a less vulnerable industrial use.
- If a building is being replaced. If an applicant is seeking to redevelop by demolishing an existing property and constructing a new one, the Sequential Test will not be necessary if the following criteria are satisfied:
- If a flood risk assessment submitted with the application demonstrates that the development would not increase the risk of flooding both on the site and elsewhere.
- If the vulnerability of the development is not increased. Examples of increased vulnerability include: a) the demolition of an existing dwelling and the erection of two new residential units; b) the provision of new basement accommodation; and c) the significant increase in the number of employees or visitors.
How do I pass the Sequential Exception Test?
The Sequential Test is an essential evidence approach method utilised to assess and compare various sites in relation to their flood risk and use.
The following information is required to pass the Sequential Test:
- Definition of the search area.
The area of search for alternative sites is defined by the local council. However it is possible to challenge these search areas as long as:
It can be demonstrated (with evidence) that there is a specific need within a specific area. For example: a development that includes a mix of uses may need to apply the Sequential Test using different areas of search for the different uses. For the test to be passed, each use within the proposal must also pass.
It is possible that the site is located within specific designated areas by the council, where the area of search is likely to be limited to the town within which the site is located.
2. Submit the evidence.
- The name and location of the site proposed for development and an explanation of why that specific site was chosen.
- A statement defining the area of search.
- A map identifying all other alternative sites considered within lower areas of flood risk and their planning status.
- A statement that clarifies why other sites within lower areas of flood risk are unavailable.
How can I identify alternative sites?
We identify alternative sites that are reasonably available by looking at the following information:
- Sites allocated in a Local Plan or Neighbourhood Plan.
- Sites that are suitable and already have planning permission for the intended use.
- Documents that have been produced by the council to advise the emerging Local Plan. For example, the Land Availability Assessments.
- In cases where a site cannot be identified from council-produced documents, then alternative sites within the same area should be taken into consideration.
- For instance, we contact local estate agents for small housing sites, including single properties, which are below the site capacity threshold used in the Land Availability Assessment.
- We also have continuous communication with the local council to discuss the availability of alternative sites to be considered in the Sequential Test.
What is meant by “reasonably available?”
In their Core Strategy Policies, the councils define what they mean by ‘reasonably available.’ The reasonably available policy limits the Sequential Tests to sites that the applicant owns or could acquire, and excludes alternative sites that have a planning permission which is likely to be implemented.
The Environment Agency, however, has issued a national guidance that categorises sites with existing permission as ‘reasonably available.’ This approach has also been supported on appeal.
In conclusion, a site is considered to be “reasonably available” if all of the following criteria are met:
- The site must fall within the agreed upon area of search.
- The site can accommodate the requirements of the proposed development. Applicants may need to consider the possibility of splitting their development over multiple sites. This will be particularly relevant to housing sites.
The site is either:
- The subject of a valid planning permission for development of a similar character and scale; or
- identified as having development potential within the required timescale, either in the LAA or
- In a Local Plan policy or supporting evidence; or in the case of small sites, for sale and not subject to known planning constraints.
How do you mitigate flood risk?
Flood zone mitigation interventions are dependent on the depth of floodwater.
For shallow depths (water up to 300mm/1 foot) the best solution is to locate the development above flood levels. This can be achieved by the construction of floodgates and walls, or by raising the final floor level of the property 300mm above the flood level.
For deeper depths of water, you will need to take into account building materials, foundations, floors, walls, fittings, services, doors and windows that minimise water entry whilst maintaining structural integrity.
To tackle water entry, you will need to take into consideration which kind of materials and construction techniques facilitate drying and cleaning.
Mitigation strategy should be in accordance with the “CLG 2007 improving the Flood Performance of New Buildings Publication” for new buildings and the “Preparing for floods, Interim Guidance for Improving the Flood Resistance of Domestic and Small Business Properties” for existing buildings.
What is a Compensatory Flood Storage?
The flood storage compensation refers to the volume taken by the project from the flood zone. The compensatory flood storage should be in compliance with the following requirements:
- It should be given back on a level for level basis and water should flow freely out of the allocated compensatory storage volume. .
- Wherever possible, it should be located next to the flood zone.
- The volume of the compensatory flood storage provided must be equal to the volume of floodwater displaced by the development.
What information must I submit as part of the compensatory flood storage?
As part of the compensatory flood storage it is necessary to provide:
- A site plan which indicates both proposed and existing developments.
- A Flood Zone map showing the extent and depth of the flood area for the existing and proposed development.
- Calculations illustrating both the proposed area of the displaced flood water and the corresponding compensatory storage area.
- Cross-sections demonstrating both the proposed and current ground levels in relation to the finished floor levels.
- A digital terrain model that shows the flood in relation to the development.