# Flood Representation Nppf 2024 12

> ARCHIVED - December 2024 NPPF edition (superseded 17 August 2026). Use only when the user explicitly asks to work under the pre-August-2026 framework and has confirmed they want the archived skills; outputs must state they cite a superseded framework. Evaluate the flood-risk and drainage evidence submitted with a UK planning application (Flood Risk Assessment, Drainage Strategy / SuDS report, and the Sequential/Exception Test justification), identify the national policy and guidance it engages, and draft a concise, well-founded objection — or advise that no sustainable objection exists. England-focused. Not legal advice; no warranty; output requires human review.

- Skill: `seagulltwo/flood-representation-nppf-2024-12` (Agent Skill, multi-file: 8 files)
- Install (CLI): `npx skillmds@latest add seagulltwo/flood-representation-nppf-2024-12`
- Raw SKILL.md: https://api.skillmd.com/api/skills/seagulltwo/flood-representation-nppf-2024-12/raw
- Safety review: pending
- Works with: Claude Code, Claude.ai, OpenAI Codex
- Category: Docs & Writing
- License: MIT
- Author: SeagullTwo (https://skillmd.com/u/seagulltwo)
- Updated: 2026-09-17
- Page: https://skillmd.com/skills/seagulltwo/flood-representation-nppf-2024-12

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# Flood-risk representation on a planning application

Help a member of the public produce a rigorous, credible representation on the **flood-risk
and drainage** merits of a planning application. The skill does three things:

1. **Evaluate** the applicant's flood-risk and drainage evidence against current national
   policy and guidance, and identify the material deficiencies.
2. **Map** each deficiency to the specific policy, test and guidance it engages.
3. **Draft** the representation in clear, precise, concise language — or advise that the
   evidence is sound and no sustainable objection exists.

## When to use

The user has a planning application and wants to object, or find out whether they can, on
flood-risk or drainage grounds — the Sequential/Exception Tests, an inadequate or missing Flood
Risk Assessment, increased flood risk elsewhere, surface-water/foul drainage, or sustainable
drainage (SuDS). Trigger phrases: "object on flood grounds", "is this Flood Risk Assessment
adequate", "this will flood my property / make flooding worse", "they haven't done a sequential
test", "the drainage isn't sustainable."

Not this skill: ecology, transport, heritage, general amenity — separate matters.

## What you need first

- The **application reference and council**, or the **documents themselves** — uploaded,
  pasted, or already-downloaded files work directly; the companion **planning-document-search**
  skill is only needed when you don't have them (it retrieves them from the reference + council).
- The **flood/drainage documents** — the Flood Risk Assessment, the Drainage Strategy / SuDS
  report, and any Sequential/Exception Test statement. Also the **Environment Agency and Lead
  Local Flood Authority consultation responses** (often decisive — read them first).
- The **flood context** — which **Flood Zone** the site is in (Environment Agency "Flood map for
  planning"), its size, and any other flood sources (surface water, groundwater, sewers) or
  critical drainage area; whether the site is greenfield.
- The **local plan's** flood-risk and drainage policies, and any Strategic Flood Risk Assessment.

## The integrity principle and two anchors (read before drafting)

**Only object where the evidence is genuinely inadequate or the risk genuinely unacceptable.**
If the site is in Flood Zone 1 with no other source, an FRA may not even be required; if the FRA
is adequate, the tests are satisfied, and the EA and LLFA are content, there is **no sustainable
objection** — say so. Treat "don't object" as a valid output.

Two anchors:
- **The statutory consultees are your allies.** The **Environment Agency** (river/sea risk) and
  the **Lead Local Flood Authority** (surface-water drainage on major development) are statutory
  consultees. Read their responses first; align with any objection/holding position and press
  for it to be resolved *before* determination.
- **The two hard requirements.** Whatever the benefits: the development must be **safe for its
  lifetime** and must **not increase flood risk elsewhere** (ideally reduce it). Test both.

**Classify every point's ask — (A) refuse, (B) don't determine yet, or (C) condition it.**
An evidential deficiency is not itself a reason for refusal. For each confirmed point, be
explicit about which outcome it supports: **(A)** the evidence *demonstrates* an unacceptable
impact (a failed Sequential/Exception Test; demonstrated risk elsewhere) → a refusal reason;
**(B)** the evidence is *insufficient* for the Council to reach the necessary conclusion (no
FRA where one is required; no climate-change allowances; an unresolved EA/LLFA holding
objection) → the application should **not be determined** until the information is provided;
**(C)** the issue can be adequately controlled → ask for the *specific* condition or
obligation (a detailed drainage scheme, runoff limits, a SuDS maintenance plan). Most
deficiency findings are (B), not (A) — claiming (A) on (B) evidence is the classic
credibility mistake. And test every point against (C): if a condition would lawfully and
satisfactorily resolve it, ask for that rather than refusal — over-asking weakens the whole
representation.

## Workflow

### Step 1 — Intake and read
Identify the **flood zone(s)** and sources of risk, the site size, whether it is greenfield, and
the application type. Read the **EA and LLFA responses first**. Get the FRA, Drainage Strategy
and any Sequential/Exception Test statement.

### Step 2 — Evaluate against the deficiency catalogue (function 1)
Work through [`references/deficiency-catalogue.md`](references/deficiency-catalogue.md). Confirm
each candidate deficiency is **present** and **material**, and capture the specific evidence —
the document, author, date, and the paragraph/figure/plan. Quote the FRA's own words, or the
consultee response. Grade findings and lead with the decision-critical.

Key tests: Is the **Sequential Test** passed (reasonably available lower-risk sites)? Is the
**Exception Test** (both limbs) met where required? Is a **site-specific FRA** provided where
required, assessing **all sources** with current data and **climate-change allowances**? Are
**safe access/egress and floor levels** shown, and **residual risk** assessed? Does the scheme
**increase flood risk elsewhere** (floodplain storage, runoff)? Does the **drainage** follow the
hierarchy, restrict runoff, and secure maintenance? Are the **EA/LLFA** satisfied?

### Step 3 — Map to policy and guidance (function 2)
Attach the precise instrument from
[`references/national-guidance.md`](references/national-guidance.md) — the NPPF flood paragraphs
and the Sequential/Exception Tests, the PPG (flood zones, when an FRA is required, vulnerability
classes), the EA/LLFA roles and standing advice, the climate-change allowances, and the SuDS
standards — plus the **local plan** flood policies and the Strategic Flood Risk Assessment. Cite
specifically.

### Step 4 — Draft (function 3)
Draft to [`references/house-style.md`](references/house-style.md) and
[`references/objection-template.md`](references/objection-template.md): header → RE line (note
the flood zone) → opening → bulleted framework list → numbered conclusion-headed points (lead
with the Sequential Test; quoted evidence; the ask) → numbered **Summary of requests** →
objection sentence → sign-off. Keep it concise; use bullets for lists and `(a)/(b)` for
multi-limb points (e.g. the Exception Test).

### Step 5 — Check before sending
- Every point is evidenced from the documents/consultees or cited policy; nothing asserted.
- Figures and flood-zone references are accurate.
- It aligns with, and builds on, the EA/LLFA positions.
- Consultant-/campaign-specific framing excluded unless the user asked and it is defensible.
- Requests are concrete and correctly timed.
- Every point is classified **(A) demonstrated harm / (B) insufficient evidence / (C)
  conditionable** — and no point asks for refusal where a condition would lawfully and
  satisfactorily do.
- **Hand back to a human, with the two warnings:** the draft must be read and checked, and
  submitting it puts a **public document in the user's name** on the council's portal.

## Reference files

- [`references/deficiency-catalogue.md`](references/deficiency-catalogue.md) — the evaluation
  checklist.
- [`references/national-guidance.md`](references/national-guidance.md) — the policy/guidance
  catalogue with citations.
- [`references/house-style.md`](references/house-style.md) — how a strong representation reads.
- [`references/objection-template.md`](references/objection-template.md) — skeleton + annotated
  worked example.

## Scope and limitations

- **Not legal advice, and no warranty.** Not a substitute for a solicitor or a flood-risk
  engineer; guarantees no outcome; provided "as is".
- **Human review is necessary before submitting.** A person must check every figure and citation
  against the actual documents.
- **A UK planning representation is a public document in the submitter's name** — normally
  published on the council's portal; include only personal details the user is content to make
  public.
- **England-focused.** The NPPF/PPG and EA/LLFA framework are England; devolved policy differs —
  flag when outside England.
- **Evidence-bound.** Don't invent flood levels, flows or modelling; where information is
  missing, that *absence* is itself the point ("no FRA / no sequential test"), argued as such.
- **The honest answer is sometimes "don't object."**