Fife Council Flood & Drainage Updates 2025 | Key Developer Changes
Overview
Earlier this year (June 2025), Fife Council published an updated version v3.0 of its Design Guidance on Flooding and Surface Water Drainage Requirements.
This replaces the previous 2022 edition (v2.1) and brings the document in line with National Planning Framework 4 (NPF4), SEPA guidance, and the constantly evolving best practice in flood risk management, including both hydraulic modelling requirements and SuDS design.
For developers, the changes mean more detailed requirements, a tiered approach to applications, and a further focus on the requirements for climate resilience.
Here’s what’s new and why it matters.
1. Alignment with National Planning Framework 4 (NPF4)
The new guidance, underpinned by NPF4 Policy 22 (Flood Risk) and Policy 10 (Coastal Development), follows a clear principle of “avoidance first”: that development at flood or erosion risk should be avoided wherever possible.
2. Introduction of a Tiered System (Major vs Local Applications)
Applications are now categorised into Tier 1 (Local) and Tier 2 (Major) developments.
- Local Applications: Independent SuDS/FRA checks must be carried out by a different company separate to the designer/assessor. This includes:
- Small-scale housing (fewer than 50 units or <2 hectares site area).
- Small business/industrial schemes (<10,000 m² floorspace or <2 hectares).
- Most change-of-use applications.
- Small extensions or alterations.
- Major Applications: Independent checks may be done within the same company as the designer/ assessor. This includes:
- Housing: 50+ dwellings, or a site over 2 hectares.
- Business/industrial/storage/distribution: Over 10,000 m² floorspace or site >2 hectares.
- Electricity generation: Capacity ≥20 MW.
- Waste management: ≥25,000 tonnes per year, or ≥50 tonnes per day (sludge).
- Transport/infrastructure: Road, railway, tram, waterway, aqueduct or pipeline >8 km long.
- Fish farming: Surface area of water >2 hectares.
- Mineral extraction: Site area ≥2 hectares.
- Other development: Gross floorspace ≥5,000 m² or site area >2 hectares.
What this means : expect extra professional sign-off requirements, particularly for smaller schemes that previously may have slipped through with less scrutiny.
3. Updated Climate Change & Sea Level Rise Allowances
- Rainfall uplift: Still 39%, but applicants must always check SEPA’s latest figures.
- Sea level rise: Now explicitly included: 0.85m by 2080, plus 0.15m per decade beyond 2100 for long-life developments.
- Freeboard: More stringent guidance for coastal sites, factoring in wave action and erosion. Previously, finished floor levels could be situated 600mm above the peak still water extreme design coastal flood level. Since the 2025 update however, an additional allowance to account for wave action must be included, meaning that for coastal sites, acceptable finished floor levels will generally be higher than previously acceptable.
- Compensatory storage: If land raising removes floodplain storage, like-for-like replacement is mandatory. Please note however that in accordance with NPF4, compensatory storage may only be applicable for the 4 exceptions listed in Policy 22a:
- essential infrastructure where the location is required for operational reasons
- water compatible uses
- redevelopment of an existing building or site for an equal or less vulnerable use;
- redevelopment of previously used sites in built up areas where the LDP has identified a need to bring these into positive use and where proposals demonstrate that longterm safety and resilience can be secured in accordance with relevant SEPA advice.
What this means: modelling expectations are higher, and proposals near coasts will be expected to include finished floor levels higher than before.
4. Flood Risk Assessment (FRA) – More Detail Required
- FRA now required at both PPP and Full Application stage.
- Must demonstrate safe access/egress during flood events.
- Hydraulic models must include sensitivity testing. Fife Council provide 4 explicit examples of this, which include:
- Boundary conditions e.g. a 20% increase in design flow
- Surface roughness e.g. increasing or decreasing the roughness coefficient used in the model.
- Location and type of upstream and downstream boundary conditions to ensure there is no impact on results within the area of interest
- Blockage of critical structures such as culverts and other hydraulic structures which may be prone to blockage during flood events. The percentage blockage scenario/s should be justified based on site specific factors.
What this means: as mentioned above, Fife Council are now requiring more technical modelling to be undertaken if a site’s are shown to be within or close to areas at risk of flooding
5. Drainage Impact Assessment (DIA) – Replaces Surface Water Management Plans
“Surface Water Management Plans” have been replaced with Drainage Impact Assessments (DIA).
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- Same principle — demonstrate sustainable drainage — but with expanded requirements.
- No SuDS or storage allowed in the 200-year + climate change floodplain. This is a key amendment, and early consideration with regards to both flood risk and SuDS design should be undertaken during the initial stages of the project.
- The list of sensitive receiving watercourses has expanded, and now contains the following:
- Auchtermuchty – Calsay Burn / Auchtermuchty Burn
- Ballingry – Lochty Burn (and unnamed culverted watercourses within the town)
- Cairneyhill – Torry Burn
- Cupar – Lady Burn, River Eden
- Dunfermline – Lyne Burn, Mowbray Burn, Bellyeoman Burn
- East Wemyss – Kingslaw Burn
- Falkland – Maspie Burn (and unnamed culverted watercourses within the town)
- Freuchie Mill – Pittilock Burn
- Inverkeithing – Inverkeithing Burn, Keithing Burn, Brankholm Burn, Whinny Burn
- Kirkcaldy – Den Burn, Tiel Burn
- Kinglassie – Lochty Burn
- Leven – Scoonie Burn, River Leven
- Rosyth – Brankholm Burn, Whinny Burn
- St Andrews – Kinness Burn, Lumbo Burn, Cairnsmill Burn, Swilken Burn
- Remember, that if you plan on a controlled surface water discharge to any of the named watercourses above – discharge rates up to and including the critical 1 in 200 year plus climate change event will need to be lower than the standard Fife wide criteria (the lesser of 1 in 2 year greenfield runoff rate / 3.3 l/s/ha, compared to 1 in 5 year greenfield runoff rate / 4.0 l/s/ha.
What this means
If you plan on a surface water discharge to any of the sensitive watercourses listed above, please account for additional on-site attenuation in comparison to other watercourses throughout the Fife region.
6. Coastal Erosion
For the first time, coastal erosion is explicitly addressed. The Council’s stance is clear:
“Avoidance is the first principle for development in erosion risk areas.”
What this means: coastal schemes will face an additional layer of risk assessment beyond flood risk alone. Information provided on the Dynamic Coast webmap provides a good starting point, indicating if your site may be at risk of coastal erosion.
How Aegaea can help
The latest changes outlined in the latest version of Fife Council’s Design Guidance on Flooding and Surface Water Drainage Requirements do require additional flood risk and drainage input during the early stages of your project. Aegaea have extensive experience working across the Fife Council region, and our team of flood risk consultants, drainage experts, and hydraulic modellers are well versed in both local and national policy across Scotland.
Get in touch with our dedicated Scotland-based team to find out more.
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