Flood Risk Assessment for a Care Home, Children’s Home or Supported Living

A flood risk assessment for a care home, children's home or supported living scheme is needed wherever the site sits in Flood Zone 2 or 3, and increasingly in Flood Zone 1 as well. The classification these uses take is more vulnerable, not highly vulnerable. That means Flood Zone 2 without the Exception Test, Flood Zone 3a with it, and refusal in Flood Zone 3b. All of which is settled in a single row of a table.

The application is decided by the next policy along. Policy F7 of the August 2026 NPPF asks whether a development will be safe throughout its lifetime "taking account of the vulnerability of its users". A block of flats and a forty-bed dementia unit sit in the same vulnerability band and answer that question very differently.

The national flood hazard classification the Environment Agency works from defines its first danger threshold as "danger for some – includes children, the elderly and the infirm". A route that is safe for the general public is, in the classification's own words, already dangerous for the people who live in these buildings.

Which flood risk vulnerability class is a care home or children's home?

Care homes, children's homes and supported living schemes are classified as more vulnerable development under Annex F, Table 2 of the August 2026 NPPF. The table groups them as "residential institutions such as residential care homes, children's homes, social services homes, prisons and hostels". Hospitals sit in the same band. So do ordinary dwelling houses, hotels and student halls.

This trips people up, because the residents are, in every ordinary sense of the word, highly vulnerable. The category is not describing them. It describes what the building is used for, and highly vulnerable is a short, specific list: police, ambulance and fire stations and command centres, emergency dispersal points, basement dwellings, caravans and mobile and park homes for permanent residential use, COMAH installations, and radioactive substances disposal sites. Our guide to flood risk vulnerability classification sets out all five categories and the full A to Z.

Three things can still pull a care scheme up into the highly vulnerable band, and all three turn up in real applications.

• Basement or lower-ground bedrooms. A basement dwelling is highly vulnerable in its own right, so it faces refusal in Flood Zone 3a and 3b and the Exception Test in Zone 2. That is a harder band than the house above it.
• Park homes and mobile units. Caravans, mobile homes and park homes intended for permanent residential use are highly vulnerable. Check any modular or relocatable supported living unit against this before anything else.
• The highest-category rule. Where a scheme combines uses of different vulnerability, Annex F takes the most vulnerable one present, unless the parts are genuinely separable with independent access, escape and flood management.

One cross-border note. Wales runs a different system. Under TAN15, all residential development, hospitals and schools are classified highly vulnerable, and a 2025 Notification Direction requires Welsh Ministers to be told about highly vulnerable development on previously undeveloped Flood Zone 3 land. Using the English classification on a Welsh site is a straightforward error.

Does a care home need a flood risk assessment?

Yes, in almost every case where there is flood risk from any source. Policy F4 of the August 2026 NPPF triggers a site-specific flood risk assessment where a development is at risk of flooding now or in the future, from any source, rather than from rivers and the sea alone. In practice that means Flood Zones 2 and 3 every time, and Flood Zone 1 wherever surface water, groundwater, sewer or reservoir risk is mapped on or around the site. Our summary of the August 2026 NPPF flood risk and drainage changes covers the wider rewrite.

What surprises applicants is the second column. The Environment Agency is not consulted on every one of these schemes, and its published standing advice for local planning authorities sets out where the line falls.

A new sixty-bed care home in Flood Zone 2 therefore attracts no statutory Environment Agency consultation on flood risk grounds alone. That is not a licence to submit less. It means the case officer reads your assessment against standing advice with no specialist to lean on, and a thin report is far more likely to produce a holding objection than a conversation. If you want to see what a compliant report contains before commissioning one, our seven-step guide to producing a flood risk assessment walks through the process, and we prepare flood risk assessments for planning applications across England and Wales.

When the Sequential Test applies to a care scheme, and when it does not

A change of use to a care home or children's home is exempt from the Sequential Test. A new building is not. Policy F5 of the August 2026 NPPF lists "changes of use, other than changes of use to a caravan, camping or chalet site, or to a mobile home or park home site" among the exemptions, and that single line decides how hard a great many of these applications are. Most applicants arrive assuming the opposite.

Given how much of this sector arrives by conversion, from former guest houses, pubs, large detached houses and redundant care homes, the test applicants fear most often does not apply at all. The same logic runs through our notes on a change of use to an HMO, on office-to-residential conversions under Class MA, and on barn conversions under Class Q.

LaingBuisson put forty-four per cent of current UK care home capacity as not purpose-built, describing "a large residue of legacy stock, in the form of converted premises dating from the initial expansion of the independent care home sector in the 1980s".

1. Establish the flood zone. Take it from the Flood Map for Planning and the local Strategic Flood Risk Assessment. The functional floodplain, Zone 3b, is fixed locally and does not appear on the national map.
2. Confirm change of use or new build. A change of use is exempt from the Sequential Test. A new building is not, and neither is a rebuild.
3. Define the area of search. The August 2026 Framework caps it, but the search is not confined to land you already own.
4. Compare reasonably available sites. In Mead Realisations Ltd v Secretary of State [2024] EWHC 279 (Admin) the High Court confirmed that lower-risk sites do not need to be owned by the applicant to count as reasonably available.
5. Read Annex F, Table 3. It tells you whether the Exception Test then follows.

Step four is where care schemes come unstuck. The search is defined by the type of development and the catchment it serves rather than by the operator's land holdings, and a local authority commissioning placements across a whole county gives that search area an uncomfortable amount of room. Our explainer on the Sequential and Exception Tests covers the mechanics, the Yatton appeal and the Faversham appeal show how the area of search is argued in practice, and we prepare Sequential and Exception Test reports where the argument needs evidencing properly.

Passing the Exception Test in Flood Zone 3a

Where the compatibility matrix calls for it, the Exception Test now runs to three limbs under Policy F6: wider sustainability benefits to the community that outweigh the flood risk; safety for the development's anticipated lifetime under Policy F7; and no increase in flood risk elsewhere, with a reduction where possible.

For most development, as our developer's guide to building on floodplains sets out, the first limb is the hard one. For this sector it is the other way round, and that is worth knowing before anyone concedes it. The need is unusually well documented, and the figures are not marginal.

• Children's placements. The National Audit Office found local authorities spent an average of £318,400 per child in a children's home in 2023-24, or £6,100 a week, and the Local Government Association has identified placements costing up to £63,000 a week.
• Homes in the wrong places. The NAO records that although the number of children's homes rose by sixty-three per cent between 2019-20 and 2024-25, the average number of places per home fell from 4.4 in 2014 to 3.6 in 2025, and homes "may not be where they are needed".
• Planning as the binding constraint. The Competition and Markets Authority found that providers and local authorities "told us that the planning process was a more significant constraint than finding a suitable property", adding £20,000 to £30,000 per application and pushing the time from site search to first placement beyond two years.
• Adult beds. Knight Frank's Healthcare Development Opportunities 2025 projects a shortfall of around 200,000 beds by 2050, with bed supply having grown 2.9 per cent between 2011 and 2024 against 20.7 per cent growth in the over-65 population.
• Occupancy. The Care Quality Commission reports care home bed occupancy rising from 78 per cent in 2021-22 to 84 per cent in 2024-25, and 87 per cent in London, which also has fewer beds per head of the over-65 population than anywhere else in England.

None of that helps with the second limb, and the second limb is where these applications are actually decided.

Policy F7 and the gap the classification does not close

Policy F7 is where a care scheme is won or lost. It says development in a location known to be at risk from any form of flooding should be refused unless a set of conditions is met, and the second of those conditions does something the vulnerability classification never does. It looks past the building at the people inside it.

The classification asks what the building is for. Policy F7 asks who will be in it, whether they can get themselves out, and what happens if they cannot.

Two schemes can share a vulnerability band, a flood zone and a floor level and still reach opposite answers on that question. Which is exactly why a care home is not assessed like the block of flats next door, even though Annex F puts them in the same row.

The supporting guidance is explicit about this. Planning Practice Guidance requires an assessment to consider the safety of people in and around a building "including people who are less mobile or who have a physical impairment", and asks directly whether occupants more vulnerable to the impact of flooding, meaning "residents who will sleep in the building; people with health or mobility issues", will be in the parts of the building and site at lowest risk. The Environment Agency's guidance for applicants goes further. Its flood risk assessment template asks you to describe occupant vulnerability by reference to mobility and physical impairment, and to confirm whether the proposal includes sleeping accommodation and on what storey.

Those are not box-ticking questions. They are the questions the application turns on, and a generic assessment that answers them with a sentence about the flood warning service will not survive contact with a case officer.

Safe access and escape when residents cannot walk out

Safe access and escape means occupants can reach land outside the flooded area without the intervention of the emergency services. The underlying Defra and Environment Agency research is blunt that a dry route is the standard and a wet route is a concession: "a route can only be completely safe in flood risk terms if it is dry at all times."

Where a dry route cannot be achieved, the thresholds are numerical, and they are tighter than most applicants expect. The joint Environment Agency and ADEPT guidance on flood risk emergency plans for new development sets them out.

• Pedestrian routes. No combination of depth and velocity should produce a flood hazard rating of 0.75 or greater.
• Vehicular routes. Should not exceed 30cm, and less where the water is fast flowing, because vehicles become buoyant.
• Emergency service access. Routes with a hazard rating above 2.0 are unusable by the emergency services themselves.
• Who decides. The local planning authority decides whether safe access and egress is provided, in consultation with its emergency planning team and the emergency services. Not the Environment Agency alone.

The 0.75 figure is the one that matters here. In the national hazard classification it is the boundary of "danger for some – includes children, the elderly and the infirm". The classification was built on the premise that this population becomes endangered first, so the standard route argument, that the water is only ankle-deep and people can walk out, collapses the moment the occupants are named. Our explainer on residual flood risk sets out the hazard rating formula and its four bands in full.

An appeal at Abbey Cloisters in Chertsey in February 2025 shows how far this reaches. The site was in Flood Zone 1, on a dry island surrounded by Zones 2 and 3, and the scheme was ordinary residential rather than a care use. The Inspector dismissed it on egress anyway, finding the route "convoluted and impractical" and noting that it "may be necessary to be used by a range of vulnerable people including elderly, infirm or children" who "will also likely be under a high degree of duress". If a Flood Zone 1 scheme fails on that reasoning, a Zone 3a care home with the same route has no case at all.

Ground-floor sleeping accommodation, freeboard and the place of safety

The answers that pass are structural, not procedural. The Environment Agency's national guidance names them directly: further floor raising to minimise internal flood depths, "precluding sleeping accommodation on ground floors", and providing an internally accessible safe refuge above the estimated flood level.

Finished floor levels should be at least 600mm above the highest of average site ground level, adjacent road level, or the estimated flood level. That can drop to 300mm where there is a high level of certainty about the estimated flood level, and rises where uncertainty is particularly high. The Environment Agency also notes that it "is unlikely to consider internal flooding of new vulnerable development to be acceptable", and that temporary or demountable barriers are not appropriate for new buildings at all. Where levels cannot be raised conventionally, floodable voids and undercrofts are the usual alternative, and the modelled level itself normally comes from Environment Agency flood data. Getting the right climate change allowance into that calculation matters as much as the freeboard itself.

The place of safety is where care schemes part company with everything else, because the standard the guidance sets is one most designs quietly fail.

1. Size it for the whole occupancy. Planning Practice Guidance requires a place of safety "capable of accommodating the likely number of occupants or users of the proposed development". Every resident, plus staff. Not a landing.
2. Make it reachable without help. Refuge facilities must remain accessible, including to the mobility-impaired, for the lifetime of the development. That means an accessible stair and a lift specification that survives the flood, not a stair alone.
3. Assume the utilities fail. Internal places of refuge are unlikely to be appropriate for long-duration flooding once the effect on electricity, gas, telecommunications, water supply and sewerage is accounted for.
4. State the endurance. The guidance asks for the maximum refuge duration "for a range of occupants, including those with health or mobility issues". Most flood risk assessments never give that figure.
5. Show rescue is feasible from it. The refuge must be designed to facilitate rescue if emergency care is needed, or if occupants cannot safely wait for the water to recede.

Several local authorities go beyond the national baseline. Kingston's flood risk assessment guidance prohibits finished floor levels below the one in one hundred year event with climate change and 300mm freeboard for more vulnerable development outright, and the West London Strategic Flood Risk Assessment states plainly that basements "must not include sleeping accommodation". Read the local Strategic Flood Risk Assessment before the design is fixed, not after.

Why an evacuation plan will not carry the application

Because the arithmetic does not work, and the guidance says so in terms. The Environment Agency usually issues a flood warning between thirty minutes and two hours before flooding, and its warnings cover rivers, the sea and groundwater but not surface water. A care home cannot move forty dependent residents, their medication, their care records and their equipment in that window. Behind defences there may be no warning at all.

The policy position follows from that, and it is unusually blunt for planning guidance.

• Emergency plans are not mitigation. Planning Practice Guidance states that "it will not be appropriate to rely solely on emergency plans to mitigate residual risk".
• Rescue is not a design solution. "The emergency services are unlikely to regard developments that increase the scale of any rescue that might be required as being safe."
• Deferring the plan is a warning sign. The Environment Agency and ADEPT guidance says it "will very rarely be appropriate to use a planning condition to defer the provision of an EP, because it may show that the development cannot be made safe".
• Warnings can fail. The same guidance notes that "the successful issuing of a flood warning cannot be guaranteed".

There is a second reason, and applicants raise it least often. Evacuation is itself a harm. Cabinet Office guidance states that an evacuation "should only be carried out if the benefit of leaving an area significantly outweighs the risk of sheltering in place", and that it "can be traumatic, especially for vulnerable people". Its guidance on health facilities describes progressive horizontal evacuation, meaning moving dependent people sideways into a protected compartment rather than out of the building, precisely because full evacuation of a setting with dependent occupants "would only be considered under extreme circumstances".

The English National Study of Flooding and Health, published by Public Health England in 2020, found that evacuation and displacement increased the risk of probable anxiety and post-traumatic stress disorder among people whose homes were flooded, that the rise in mental health problems persisted for three years, and that receiving a warning at least twelve hours in advance was "the only factor associated with reducing the increase in probable psychological morbidity among people who were subsequently displaced from their home".

Twelve hours is six times the upper end of a standard flood warning. So the design response is vertical rather than horizontal: get the residents above the water and keep them there safely, instead of planning to move them out through it.

Two appeals: what actually got permission

Both of the recent care sector appeals below were allowed, and both were allowed for the same reason. The scheme moved sleeping accommodation upwards and improved the building's own capacity to shelter its residents.

Neither decision was won by a better flood model or a more elaborate emergency plan. Both were won by a plan drawing that put the beds upstairs.

Both decisions predate the August 2026 Framework and cite the old Annex 3 numbering, so read them for the reasoning rather than the references. Note the procedural change since, too. From 1 April 2026, most Section 78 appeals in England default to written representations, which generally exclude evidence that was not before the council at determination. The old strategy of fixing a weak flood risk assessment at appeal has largely closed. Our note on planning appeals in 2026 explains what changed.

Registration: why a flood refusal stops the scheme rather than delaying it

For a children's home, planning and registration are locked together. Ofsted's application to register a children's home requires evidence of planning permission alongside the statement of purpose, the location assessment, the fire risk assessment and the evidence of financial viability. No permission, no registration. No registration, no home.

The regulatory duties keep running after opening, and they are not silent on premises.

• Children's homes. The Children's Homes (England) Regulations 2015 require premises to be located so that children are effectively safeguarded and designed and maintained "so as to protect each child from avoidable hazards to the child's health", and regulation 46 requires the registered person to review the suitability of the location at least once a year.
• Supported accommodation. The Supported Accommodation (England) Regulations 2023 impose an annual location assessment and require premises to be accessible, safe and secure, and designed to remove avoidable hazards.
• Adult care. The Care Quality Commission's guidance on regulation 12 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 says providers must be able to respond to major incidents and emergency situations, naming floods among them, and regulation 15 requires premises to be "appropriately located" for their purpose.
• The gap worth noting. There is no flood equivalent to the fire precautions regulation in the children's homes regulations. Fire is expressly regulated. Flood is caught only through the location and premises duties.

This cuts both ways at planning stage, and the second way is useful. A flood emergency plan is a document the operator needs for registration compliance whatever the local planning authority asks for, which makes it easier to produce properly and harder to argue as an unreasonable planning burden.

What your flood risk assessment needs to contain

A flood risk assessment for a care home, children's home or supported living scheme covers everything a residential assessment does, then answers the occupancy questions on top. The Environment Agency's own template and the Planning Practice Guidance checklist set out what those are.

1. Classification and its reasoning. State the Annex F category, and where the use is not squarely named, justify the choice rather than asserting it.
2. Occupant profile. Describe occupant vulnerability by reference to mobility and physical impairment, the pattern and hours of occupation, and staffing levels overnight.
3. Sleeping accommodation by storey. Confirm whether the proposal includes sleeping accommodation and on what floor, and show the more vulnerable occupants in the lowest-risk parts of the site.
4. Levels and freeboard. Finished floor levels against the design flood level, with the right climate change allowance for the development's lifetime.
5. Access and escape. Depth, velocity, hazard rating, speed of onset and duration along the route, so the emergency planning team can advise on it.
6. The place of safety. Capacity, accessibility, endurance, utility independence and rescue feasibility, given as figures.
7. Residual risk. Breach and exceedance, whether a warning gives enough time for the occupancy proposed, and what extra burden the scheme places on emergency planning.
8. The emergency plan itself. Submitted with the application, not deferred by condition.

Get those eight right and the scheme is arguing about design, which is winnable. Leave them to a template and the application is arguing about whether it should exist at all.

If you are looking at a site for a care home, children's home or supported living scheme and the flood map has come back with something on it, the classification is rarely the problem. The occupancy is. Unda's flood risk assessment consultants can classify the use, run the Sequential and Exception Tests where they apply, and prepare a flood risk assessment for your planning application that answers the Policy F7 questions properly the first time. What it costs depends on the site rather than a price list. Call 01293 214444 for a quote within the hour, or email enquiries@unda.co.uk.

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