The update follows months of feedback and consultation through a dedicated Short Life Working Group involving planning authorities, SEPA, professional bodies, and developers. It aims to address challenges and provide clarity on roles, procedures, and recent changes to guidance.

The letter outlines the responsibilities of SEPA, planning authorities, and the Scottish Government when managing flood risk in development proposals. Under the Flood Risk Management (Scotland) Act 2009, both SEPA and local authorities have a statutory duty to reduce overall flood risk, with developers responsible for supplying accurate, timely flood data.

Planning authorities were reminded that consultation with SEPA is mandatory where developments may materially increase flood risk, though SEPA’s updated standing advice can exempt certain cases. SEPA encourages authorities to use their own data when considering developments near small watercourses and welcomes case-by-case discussions on complex applications.

The letter notes that since the adoption of NPF4, SEPA has raised no objections in 30% of cases in which it was consulted. In a further 66% of cases, objections were withdrawn after developers submitted additional information. Only 4% of cases resulted in a sustained objection.

Planning authorities were also reminded of their obligation to notify Scottish Ministers when they intend to approve applications despite SEPA objections, or without imposing its recommended conditions. While the Scottish Government continues to exercise its call-in powers sparingly, the letter reveals that since NPF4’s adoption, 32 applications have been notified on flood risk grounds. Of these, 24 were cleared back to local authorities, while eight were called in. Four were approved, two refused, and two remain under consideration.

The ministers emphasise that decisions to call in applications are influenced by the clarity with which flood risks are understood and mitigated. The Scottish Government encourages planning authorities to demonstrate robust understanding of flood risk in decision-making.

Acknowledging a need for greater awareness, the letter includes an explainer on flood probability and cumulative risk over time. For example, a site with a 0.5% annual chance of flooding has a near 40% chance of flooding over a 100-year period.

To support better understanding, the Scottish Government highlighted resources now available through SEPA and the Improvement Service Planning Skills Programme, including new flood maps and planning sessions. A new National Planning Skills Commitment Plan 2025, backed by nearly 60 organisations, is also underway.