Flood risk and the Sequential Test in Hull
The council's Strategic Flood Risk Assessment (December 2016) sets out why Hull needs its own approach:
- Nearly all of Hull is Flood Zone 3With little land in Flood Zones 1 and 2, the SFRA says that applying a sequential approach purely on the basis of the Environment Agency flood zones would have little effect.
- Sub-zones for the Sequential TestThe SFRA's Figure 14 splits Flood Zone 3a into four sub-zones, from Low to High, based on design flood depths. It says these zones should be used when applying the Sequential Test to allocations and to unallocated sites, so a site in a lower sub-zone is sequentially preferable to one in a higher sub-zone.
- Defended, but with high consequencesMost of Hull is defended by walls, embankments, storage lagoons and pumping. The SFRA explains that this makes flooding unlikely in much of the city, but the consequences of a breach or overtopping would be high.
- The Humber and the River HullThe SFRA models flooding from the River Hull and the Humber frontage, including breaches of their defences, alongside surface water. The 2007 and 2013 floods were used to check the models.
What Hull City Council will look for
Hull City Council applies the national tests in NPPF Chapter 18 and the Planning Practice Guidance, supported by its Strategic Flood Risk Assessment. A Sequential Test submitted with a Hull application should normally:
- Confirm the flood zone and vulnerabilityUse the current Environment Agency Flood Map for Planning and the NPPF Annex F vulnerability class for the proposed use.
- Justify the area of searchNational policy says the area of search should reflect the catchment for the type of development and the need it serves. For most housing in Hull that is the city as a whole; for a smaller scheme serving a particular part of the city, a narrower area may be more defensible.
- Assess the council's own sources of sitesHull City Council's Strategic Housing Land Availability Assessment (2025), including the Hull Local Plan allocations, and the Brownfield Land Register, compared using the Hull SFRA's Sequential Test flood zones are the obvious places to start, and omitting them is a common reason for challenge.
- Evidence every discounted siteWhere an alternative is ruled out as unsuitable, too small or not available in a similar timeframe, give the reason and the evidence. Ownership alone is not enough.
- Screen for the Exception TestState whether the Exception Test applies under Annex F Table 3, and if it does, provide it, drawing on the site-specific flood risk assessment.
Hull-specific pitfalls
- Comparing sites within Flood Zone 3In Hull, showing that alternatives are also in Flood Zone 3 is not enough. Our reports compare the proposal site and each alternative using the SFRA sub-zones, as the council expects.
- Place of safetyBecause a breach could flood quickly and with little warning, the SFRA requires new development to consider a place of safety. That is for the flood risk assessment rather than the Sequential Test, but it affects which sites are suitable.
- AllocationsHull Local Plan allocations are included through the land availability assessment, which groups them by Local Plan table. Sites allocated in the plan may not need the test repeated at application stage.
- Housing-led evidence for non-housing usesHull's land availability evidence is housing-focused. For employment, retail or community uses, you may need to add alternative sites from other sources.
Fixed-fee Sequential Tests for Hull
We have built our Hull Sequential Test on published Environment Agency and Hull City Council data. Plot your site on our Hull Sequential Test page and we'll deliver a submission-ready report within 24 hours of payment for £300. Exception Tests are £450 within 48 hours.
New to the subject? Start with our general guide: what is a flood risk Sequential Test? We also cover other council areas at the same fixed fee. For wider planning help, see planning consultants in Hull.
Source: Hull Strategic Flood Risk Assessment (Hull City Council, December 2016).
Sequential Test guides for other council areas
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Frequently asked questions
Does Hull City Council require a Sequential Test?
Yes, for most development in Flood Zones 2 and 3, in line with national policy. Some minor development and most changes of use are exempt, and sites allocated in the local plan may not need the test repeated.
What area of search should I use in Hull?
National policy says the area of search should reflect the catchment for the type of development and the need it serves. For most housing in Hull that is the city as a whole; for a smaller scheme serving a particular part of the city, a narrower area may be more defensible. The reason must be explained in the report.
Do flood defences mean I don't need a Sequential Test?
No. Flood zones for the Sequential Test are assessed without defences. Defences are taken into account in the site-specific flood risk assessment and the Exception Test, not the Sequential Test.
How much does a Sequential Test cost in Hull?
Our fixed fee for a Hull flood risk Sequential Test or alternatives assessment is £300, delivered within 24 hours of payment. An Exception Test is £450, delivered within 48 hours.
This guide is general information for applications in England and is not advice on your specific project. Requirements differ in Wales, Scotland and Northern Ireland, and every council publishes its own local validation list, so always check the detail with your local planning authority.