# Flood Representation

> 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` (Agent Skill, multi-file: 8 files)
- Install (CLI): `npx skillmds@latest add seagulltwo/flood-representation`
- Raw SKILL.md: https://api.skillmd.com/api/skills/seagulltwo/flood-representation/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

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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"; the map does not separate Zone 3b, the functional floodplain, from Zone 3a — the
  council's Strategic Flood Risk Assessment does), 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.
- **If this is an amendment application — the parent permission and every earlier amendment.**
  A s.96A non-material amendment or a s.73 variation supplies only the change, and the flood
  case turns on what that change does to the approved drainage strategy: the SuDS features and
  their catchment, discharge rates, attenuation volumes, finished floor and site levels, flood
  routing, and the conditions securing them. Get the parent's decision notice and full condition
  set, its approved plans and drainage drawings, its officer report and the EA/LLFA responses on
  it, **and every earlier amendment**. Method: the **application-triage** skill's
  `references/amendment-applications.md`.

## 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.

**On an amendment, read the chain before evaluating anything:** assess the change against the
drainage scheme **as already varied** — and note that a s.73 grants a **new** permission, so
the current flood map, the current SFRA and the current climate-change allowances apply to it,
not the ones the parent was assessed against. A strategy that was adequate in its year may not
be adequate now, and that is a point only the chain read makes available.

### 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 **use compatible with the flood zone at all** (an incompatible use is a
refusal, not a test to pass)? Is the **Sequential Test** passed (reasonably available lower-risk
sites within the area of search)? Is the **Exception Test** (all three criteria) 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 policies
(when an FRA is required, the Sequential/Exception Tests, safety, SuDS) and the flood zones and
vulnerability classes in NPPF Annex F, the PPG flood-risk procedure, 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."**