Flood, Drainage and SuDS

Choosing a climate change allowance and a lifetime

7 min readBy PlanScope Editorial Team

Peak river flow and peak rainfall allowances do different jobs and are not interchangeable. How to choose the band, justify the lifetime and present both so a reviewer can check them.

There is no single national climate change allowance any more, so the flood risk climate change allowance choice for your site depends on which river basin district and management catchment it sits in, which band the Environment Agency's guidance points you to for that flood zone and use, and what lifetime you have set for the development. Get any one of those three wrong and the whole hydraulic assessment is wrong, usually in the direction that costs you a consultation objection.

Allowances are published by catchment, not nationally

The Environment Agency publishes peak river flow allowances by river basin district and management catchment. Each catchment has its own set of percentage uplifts, so two schemes 30 miles apart can carry materially different allowances, and a figure lifted from a neighbouring scheme is unlikely to be right.

The first step is therefore an administrative one. Identify the river basin district and the management catchment for the watercourse that presents the risk, state both in the assessment, and take the allowances from the current published tables rather than from a consultant's spreadsheet.

Sea level rise allowances are separate again, published by region as cumulative rates, and tidal sites need those rather than the river flow figures. A site affected by both, such as a tidally influenced reach, needs both and a view on which drives the design.

Peak river flow and peak rainfall do different jobs

This confusion is widespread and expensive. Peak river flow allowances apply to fluvial flood risk and feed into the hydraulic model that produces flood levels and extents. Peak rainfall intensity allowances apply to surface water drainage design and feed into the attenuation and conveyance calculations.

They are published separately, they have different band structures and different time periods, and they are not interchangeable. A Flood Risk Assessment uses the river flow allowance to establish levels. A Drainage Strategy uses the rainfall allowance to size storage.

Where a reviewer finds a river flow percentage applied to a rainfall calculation, the drainage design goes back to the start. Keep the two allowances in separate, labelled tables so nobody can confuse them later, and name the rainfall dataset you used alongside, a point covered in which rainfall dataset to cite in a drainage calculation.

Which band applies to your scheme

Peak river flow allowances come in bands, usually described as central, higher central and upper end, with the Environment Agency's guidance setting out which band or bands to use according to the flood zone and the flood risk vulnerability classification of the development.

The logic is proportionate. A more vulnerable use in a higher risk zone is tested against a higher band than a less vulnerable use in a lower risk zone, because the consequences of underestimating are greater. Essential infrastructure and highly vulnerable development attract the most demanding treatment.

Read the selection table in the current guidance rather than relying on a summary, including this one, because the matrix has been revised and the vulnerability classifications sit in Planning Practice Guidance rather than in the allowances document. Where the development is mixed, classify by the most vulnerable element rather than by the predominant one.

Where the exception test is engaged, the allowance choice also feeds the safety argument, so the two have to be consistent, as the exception test for flood risk sets out.

Setting the development lifetime

Planning Practice Guidance treats the lifetime of residential development as 100 years unless there is specific justification for a shorter period. Non-residential development is normally assessed over a shorter lifetime related to the design life of the building and the use.

The lifetime decides which future time period you take allowances from, so it is not an administrative detail. A residential scheme assessed over 100 years from a consent granted this year runs well past the mid-century horizon, which means the later epoch applies.

Two mistakes recur. The first is assessing housing over 60 years because that is the figure in an old report, which understates the allowance. The second is a temporary or time-limited use assessed over 100 years, which overstates it and can make a perfectly acceptable scheme look unacceptable. If you are arguing for a lifetime shorter than 100 years on residential development, say so explicitly and give the justification. An unexplained 75 years will be queried.

Input Where it comes from
River basin district and management catchment Environment Agency catchment mapping for the relevant watercourse
Peak river flow allowance band Environment Agency allowances guidance, read against flood zone and vulnerability
Flood risk vulnerability classification Planning Practice Guidance on flood risk and coastal change
Development lifetime Planning Practice Guidance, 100 years for residential unless justified
Peak rainfall intensity allowance Environment Agency allowances guidance, drainage design only
Sea level rise allowance Environment Agency allowances guidance, by region, for tidal sites

Sensitivity testing between bands

Testing more than one band is normal practice on anything beyond a small site, and it is often what persuades a reviewer. Run the design band, then run the band above it, and report what changes.

What you are looking for is whether the scheme fails gracefully. A layout where the upper end band raises levels by 150 mm against a 300 mm freeboard is resilient. A layout where the upper end band puts water through the front door is not, and that is worth knowing at design stage rather than at appeal.

Sensitivity testing also gives you something to offer. Where the higher band causes a problem that could be managed by a finished floor level 200 mm higher, raising the floor costs less than arguing about which band applies.

Stating the allowance so a reviewer can check it

Set out the inputs as a short list near the front of the assessment, not buried in an appendix. The Environment Agency's consultation responses frequently turn on whether the allowance can be identified at all.

A reviewer needs the catchment, the band, the time period, the percentage applied, the lifetime assumed, the date of the guidance table used, and the model the allowance was applied in. Seven lines. Where those seven lines are present and correct, the technical discussion starts in the right place, and where they are absent the response tends to be a holding objection asking for them.

State the date you took the figures from the guidance, too. Allowances are updated, and an assessment that names its source date can be read fairly if the tables move before determination.

Why an allowance copied from an older report fails

Allowances have changed more than once. Earlier guidance used broad national percentages applied by region, which were replaced by catchment-based figures, and the bands and time periods have been restructured along the way. A percentage that was defensible in 2017 may bear no relation to the current figure for the same catchment.

So the practice of starting from a previous flood risk assessment for a nearby site carries real risk, and it is common in SME development where the same consultant works across a district. Ask when the allowances in the draft were taken, and from which table.

And if a draft assessment states a single percentage with no catchment and no band, treat that as a flag rather than as a number. Automated drafting can structure an assessment and set out the method, and it cannot choose the allowance for your catchment or build the hydraulic model, which is why flood risk assessment beyond a simple screening exercise is work for a suitably qualified specialist.

This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it.

PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval. For specialist technical reports, qualified professional input may be required. Enter your postcode on PlanScope to see whether your site needs a flood risk assessment or a drainage strategy.

Frequently asked questions

Are climate change allowances still national percentages?

No. The Environment Agency publishes peak river flow allowances by river basin district and management catchment, so two sites 30 miles apart can carry different figures. Identify the catchment for the watercourse presenting the risk, state it in the assessment, and take the percentages from the current published tables.

What is the difference between peak river flow and peak rainfall allowances?

Peak river flow allowances apply to fluvial flood risk and feed the hydraulic model that produces flood levels. Peak rainfall intensity allowances apply to surface water drainage design and feed the attenuation calculations. They have different bands and time periods and are not interchangeable, so keep them in separate labelled tables.

What lifetime should a residential scheme be assessed over?

Planning Practice Guidance treats the lifetime of residential development as 100 years unless there is specific justification for a shorter period. The lifetime decides which future time period the allowance comes from, so an unexplained 60 or 75 years on a housing scheme will be queried and usually understates the allowance.

Do I need to test more than one allowance band?

Sensitivity testing is normal on anything beyond a small site. Run the design band, then the band above it, and report what changes. The point is to show whether the scheme fails gracefully, and where the higher band causes a problem a slightly higher floor level usually costs less than arguing about bands.

Why can't I reuse the allowance from a nearby scheme?

Allowances have been restructured more than once, moving from broad national percentages to catchment based figures with revised bands and time periods. A percentage defensible in 2017 may bear no relation to the current figure for the same catchment, so always ask when and from which table a draft figure was taken.

Sources and further reading

flood riskclimate change allowancesdrainageenvironment agencydevelopment lifetimemajor development

This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.

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