Sequential Test for Medway Planning Applications

Where flood risk applies in Medway

The council's Strategic Flood Risk Assessment (updated May 2025) finds the predominant risk is tidal:

• The tidal River MedwayThe Medway is tidal from Allington Lock, south of Medway, through Rochester, Strood and Upnor, where it forms the Medway Estuary. Its levels are governed by extreme sea levels in the estuary, so riverside land in the towns is at risk from tidal surges.
• The Hoo Peninsula and Isle of GrainThe north of Medway is marshland drained by man-made ditches into the Thames. Tide locking at their outlets can raise water levels in the ditches, and Environment Agency modelling shows the Isle of Grain and parts of the Cliffe Marshes and Hoo Peninsula could flood when waves overtop the defences.
• Defences below standardThe whole coastline has defences except Allhallows-on-Sea, but their standard varies from 1 in 20 to 1 in 1,000 years. The 2011 Medway Flood Defence Strategy found most defences in the urban areas below the required standard, and climate change will reduce that protection further.
• Surface water and groundwaterSmall valleys in the town centres channel surface water to low points, and the Chalk Downs hold a large aquifer, so groundwater can emerge at the base of dry valleys and on low-lying land beside the river.

What Medway Council will look for

Medway 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 Medway 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. Medway includes the towns of Strood, Rochester, Chatham, Gillingham and Rainham and the villages of the Hoo Peninsula, so a narrower area matching the settlement served is often more defensible than the whole authority for smaller schemes.
• Assess the council's own sources of sitesthe Medway Local Plan 2041 allocations (submitted for examination December 2025), each with its delivery period, the Medway Land Availability Assessment (June 2025) and the Brownfield Land Register 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.

Medway-specific pitfalls

• Reliance on defencesMuch of riverside Medway is defended, but the Sequential Test uses flood zones as if the defences were not there. The defences matter for the site-specific flood risk assessment, not for choosing between sites.
• A Local Plan at examinationOur reports use the allocations of the Medway Local Plan 2041, submitted in December 2025 and now at examination. The Inspectors may change or delete allocations, so check any allocation your conclusion depends on.
• Delivery datesEach allocation's delivery period comes from the submitted plan. The council has since proposed a stepped housing trajectory, published only as totals, so some sites may now be expected later.
• Sites outside the allocationsMedway's Land Availability Assessment phased only the sites it found suitable, available and achievable, which are the allocations. Other sites are included only where they are on the brownfield register.

Fixed-fee Sequential Tests for Medway

We have built our Medway Sequential Test on published Environment Agency and Medway Council data. Plot your site on our Medway 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 Medway.

Source: Medway Strategic Flood Risk Assessment (Herrington Consulting, updated May 2025).

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