National Flood Risk Assessment 2 Update (NaFRA2)

NAFRA2 (National Flood Risk Assessment 2) is an updated flood risk assessment model developed by the Environment Agency in England, building on the previous update to the National Flood Risk Assessment from 2018 and the original assessment 2014 (TBC). The data will inform government agencies, local authorities, and communities in planning and enhancing flood resilience measures.

Key Takeaways

• An increased number of areas are now considered at risk, meaning some locations that were once outside flood zones may now require further consideration including Flood Risk Assessments (FRAs).
• 6.3 million properties in England are in areas at risk of flooding by rivers, the sea or surface water.
• With current climate change predictions, 1 in 4 properties in England will be in areas at risk of flooding by mid-century.
• There are 48% fewer properties in areas at medium risk, many of which we now consider to be in high-risk areas.
• 4.6 million properties in areas at risk of flooding from surface water – this is a 43% increase from the previous assessment.

According to the 2023 Land Use Statistics*, approximately 10.4% of England’s land area falls within Flood Zone 3 (excluding flood defences). NaFRA update and the EA Flood Map for Planning set for release on 25/03/2025, this figure is likely to rise. As a result, the amount of land available for development that is not affected by flood risk could decrease, adding further pressure to the government’s ambitious housing target.

The South East, in particular, has some of the highest concentrations of existing properties at medium to high risk of flooding from rivers, the sea, and surface water, according to NaFRA data. It has also been identified as one of the largest contributors to the government’s target of 300,000 new homes per year, with 45,429 planned.

Read more in this article by The Guardian, with comments from our Director – Daniel Cook. 

With so much change in the mapping and data, there is a greater need to understand the national and local policies that exist to regulate appropriate development in flood-affected areas.  Those policies can be acted upon effectively whilst promoting appropriate mitigation techniques to support development.

You only have to look at the last twenty years.

National Policy is structured to mitigate risk and promote appropriate development. 

With focus on the NPPF, Paragraph 170 identifies that development should be directed away from high flood risk areas. It further discusses that where development is necessary in such areas, the development should be made safe for its lifetime without increasing flood risk elsewhere. The subsequent paragraphs direct developers, local authorities and professional consultants on how to evolve a site for development whilst working with flood risk not just now but in the future tied to the lifetime of the development, paragraph 172.  Developments promoted in areas of flood risk must comply with Paragraph 178 & 179. The exception test with both elements needing to be passed. To understand whether the development needs to pass the exception test reference to the Planning Practice Guidance – Flood Risk and Coastal Change, Table 2: Flood risk vulnerability and flood zone ‘incompatibility’. To understand whether your development is appropriate, reference to this table is required as well as Annex 3 of the NPPF and checking the flood zones against EA flood map for planning or appropriate SFRA. 

Above all else, Footnote 63 of the NPPF promotes that a site-specific Flood Risk Assessment should be conducted even for those cases where the development is NOT subjected to the Exception Test as per the requirements below. 

‘A site-specific flood risk assessment should be provided for all development in Flood Zones 2 and 3. In Flood Zone 1, an assessment should accompany all proposals involving: sites of 1 hectare or more; land which has been identified by the Environment Agency as having critical drainage problems; land identified in a strategic flood risk assessment as being at increased flood risk in future; or land that may be subject to other sources of flooding, where its development would introduce a more vulnerable use’

It is recognised that there is a need for housing, there will be a greater risk in the future from flooding as a result of the outputs from NAFRA and the incoming Flood Map for Planning. 

Concerns are raised around the appropriate drainage of developments. Schedule 3 of the Flood and Water Management Act has not been fully adopted. However, the latest NPPF has made updates to not only flood risk but also how we should mitigate and manage surface water runoff generated from new development. Paragraphs 181, item c, & 182 promote better sustainable drainage practices for all developments unless there is clear evidence that this would be inappropriate to do so. 

Flood risk is complex, policy is intricate and disparate. Working with experts to advise, inform and mitigate flood risk is important for planning, operation of the development and insurance.