ET Planning’s Expertise in Sequential Testing Proves Critical
The Challenge
ET Planning was instructed to support an outline planning application for 26 new apartments in Swale. While the proposed site lay within Flood Zone 1, the application faced a significant policy hurdle due to identified surface water flood risk—triggering the requirement for a Sequential Test. Successfully addressing this requirement was essential to unlocking the development, addressing the final issue stopping development. The key challenges included: Demonstrating full compliance with national and local flood risk policy. Navigating ambiguity in Sequential Test policy and guidance. Presenting a defensible site selection process through detailed comparative analysis. Engaging directly with planning officers to agree test scope, methodology, and to finalise the assessment of sites alongside the Council proactively.
Our Approach
ET Planning led the strategy and technical work required to secure outline permission, preparing and defending a Sequential Test that withstood scrutiny. Comprehensive Sequential Test: We reviewed alternative sites across the borough based on defined criteria—location, capacity, deliverability, and availability—clearly showing no preferable or sequentially superior sites. Policy-led analysis: Our submission aligned with the requirements of both national policy and Swale’s local plan. Stakeholder engagement: We worked closely with Swale Borough Council officers through multiple meetings and correspondence to justify both the methodology and findings of the Sequential Test. This ensured confidence in the robustness of the submission. Planning judgment: Our technical arguments provided the Council with a sound basis for approving the scheme - delivering policy compliance without delay. Swale Borough Council accepted the Sequential Test and granted outline permission for the scheme. This not only enabled the delivery of 26 new homes but also set a precedent for future developments requiring nuanced flood risk justification. Sequential Test Policy Clarification Recent updates to the NPPF (Paragraph 175) now confirm that a Sequential Test is not required where a site-specific flood risk assessment demonstrates that no built form, access, or land raising is proposed in areas at risk from any source of flooding. More case studies will follow in line with new NPPF updates; however, this example highlights ET Planning's commitment to provide a test that satisfies an LPA, whilst working in cohesion with the LPA to obtain a positive outcome. While this update did not apply to this case, ET Planning has subsequently advised on projects where no test is required, supporting clients through policy-compliant letters and technical submissions following this case study. Need help with a Sequential Test or flood risk policy? Contact ET Planning to speak with our planning team about unlocking constrained sites through robust strategy and policy evidence.
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