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1 Brent Local Plan Level 2 Strategic Flood Risk Assessment September 2019 1.0 Introduction 1.1 The Strategic Flood Risk Assessment (SFRA) is a planning tool that enables the Local Planning Authority through the development of the Local Plan to select and develop sustainable site allocations with respect to flood risk. 1.2 Where decision-makers are unable to allocate all proposed development and infrastructure in accordance with the Sequential Test (i.e. steer development to areas of lowest risk of flooding), it is necessary to increase the scope of the Level 1 SFRA to provide information necessary for application of the Exception Test through the process of a Level 2 SFRA. 1.3 The Level 2 SFRA will provide more detail on the nature of flood risk in development allocations located in Flood Zones 2 or 3. This detailed flood risk information will enable the London Borough of Brent to apply the Sequential and Exception Tests within Flood Zones where there is development pressure in areas at medium or high flood risk. 1.4 The Level 2 SFRA should be read in conjunction with the West London SFRA. The consultants Metis were appointed to produce the West London SFRA on behalf of the London Boroughs of Ealing, Brent, Barnet, Hillingdon and Hounslow. This provided a detailed analysis of all sources of flooding across the study area and the impacts of climate change, and provides the context for the Level 2 SFRA. 1.5 The objectives of the Level 2 SFRA are to: provide information needed to apply the Sequential Test within specific development proposals sites at medium or high flood risk in line with the principles of National Planning Practice Guidance (NPPG); allow the flood risk for specific development proposal sites to be assessed, to ensure that development in such areas satisfies the requirements of the Exception Test; consider the detailed nature of the flood hazard, taking into account the presence of flood risk management measures such as flood defences; and inform planning policy for site allocations.
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Page 1: Brent Local Plan Level 2 Strategic Flood Risk Assessment ......1 Brent Local Plan Level 2 Strategic Flood Risk Assessment September 2019 July 2019 1.0 Introduction 1.1 The Strategic

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Brent Local Plan Level 2 Strategic Flood Risk Assessment

September 2019 July 2019

1.0 Introduction

1.1 The Strategic Flood Risk Assessment (SFRA) is a planning tool that enables the Local Planning Authority through the development of the Local Plan to select and develop sustainable site allocations with respect to flood risk.

1.2 Where decision-makers are unable to allocate all proposed development and infrastructure in accordance with the Sequential Test (i.e.

steer development to areas of lowest risk of flooding), it is necessary to increase the scope of the Level 1 SFRA to provide information necessary for application of the Exception Test through the process of a Level 2 SFRA.

1.3 The Level 2 SFRA will provide more detail on the nature of flood risk in development allocations located in Flood Zones 2 or 3. This detailed flood risk information will enable the London Borough of Brent to apply the Sequential and Exception Tests within Flood Zones where there is development pressure in areas at medium or high flood risk.

1.4 The Level 2 SFRA should be read in conjunction with the West London SFRA. The consultants Metis were appointed to produce the

West London SFRA on behalf of the London Boroughs of Ealing, Brent, Barnet, Hillingdon and Hounslow. This provided a detailed analysis of all sources of flooding across the study area and the impacts of climate change, and provides the context for the Level 2 SFRA.

1.5 The objectives of the Level 2 SFRA are to:

provide information needed to apply the Sequential Test within specific development proposals sites at medium or high flood risk in line with the principles of National Planning Practice Guidance (NPPG);

allow the flood risk for specific development proposal sites to be assessed, to ensure that development in such areas satisfies the requirements of the Exception Test;

consider the detailed nature of the flood hazard, taking into account the presence of flood risk management measures such as flood defences; and

inform planning policy for site allocations.

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1.6 The study area comprises the London Borough of Brent in West London. Detailed information on sources of flooding within the borough is available on the interactive SFRA webmap and webpage and therefore not repeated here.

2.0 Sequential Test 2.1 The aim of the Sequential Test is to steer development towards areas of lowest flood risk first, before allocating development within areas

of higher flood risk. Only where there are no reasonable available alternative sites suitable for the development in areas of lower flood risk, should areas of greater flood risk be considered for development.

2.2 All site allocations and proposed intensification corridors (previously developed land which could be developed at a higher density) have been screened against sources of flooding. The full screening is included as Appendix A. The screening assessment used the following key assumptions derived from the National Planning Policy Framework (NPPF), NPPG and the Level 1 SFRA.

Key Assumptions

Sites with 0% of areas in FZ2 and FZ3a/b do not require the Sequential Test (on the basis that other forms of flood risk are generally manageable on a site by site basis)

Less vulnerable sites within FZ2 and 3a/b require the Sequential Test

More vulnerable sites within FZ2 and 3a/b require the Sequential Test

More vulnerable sites in FZ3a require the Sequential and Exception Tests

Highly vulnerable sites in FZ2 require the Sequential and Exception Tests

Highly vulnerable sites are not suitable in FZ3 a/b

Water Compatible use in FZ2 and 3a/b require the Sequential Test

Level 2 SFRA where Sequential & Exception Tests are needed and FZ3 > 20% of site (and will be a significant constraint on development) or if the site is currently less than 20% in FZ3, but will be more than 20% under the selected climate change scenario (100yr +35%)

Flood Zone 3a for surface water is defined using the full 1 in 100 extent from the EA Risk of Flooding from Surface Water Map

Table 1. Screening Assessment Key Assumptions

2.3 The draft London Plan proposes to increase Brent’s annual housing target from 1,525 to 2,915. Given the scale of development required to meet housing need an extensive assessment of potential sites has been undertaken. The findings of the Sequential Test identified that the majority of development proposed for the borough is located in Flood Zone 1 – low probability, and therefore passes the Sequential Test. However, the borough’s housing target cannot be met from sites in Flood Zone 1 alone.

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2.4 The local plan identifies 109 site allocations, excluding those sites with planning permission. 48 sites out of the 109 are affected by flood risk areas to some degree. Of these 11 sites are affected by fluvial flood risk and 66 surface water flood risk. The Sequential Test shows that for 61 of these, the area affected by flood risk is marginal and the vulnerable uses can be accommodated on parts of the site that are at lowest flood risk. However, 12 of the sites require undertaking of an Exception Test and a Level 2 SFRA to inform the test – 7 due to fluvial flood risk and the remainder due to surface water. The full appraisal is included in Appendix A. Table 2 has been reproduced from the PPG and identifies when the Exception Test is required. The vulnerability classifications for different types of development can be identified from Table 3.

Flood Zones Flood Risk Vulnerability Classification

Essential Infrastructure Highly Vulnerable More Vulnerable Less Vulnerable Water Compatible

1

2 Exceptions Test

required

3a Exceptions Test

requited

X Exceptions Test

required

3b Exceptions Test

required

X X X

Table 2. When the Exception Test is Required (Extracted from PPG) Classification Uses

Essential

Infrastructure

Essential transport infrastructure (including mass evacuation routes) which has to cross the area at risk.

Essential utility infrastructure which has to be located in a flood risk area for operational reasons,

including electricity generating power stations and grid and primary substations; and water treatment

works that need to remain operational in times of flood.

Wind turbines.

Highly

Vulnerable

Police and ambulance stations; fire stations and command centres; telecommunications installations

required to be operational during flooding.

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Emergency dispersal points.

Basement dwellings.

Caravans, mobile homes and park homes intended for permanent residential use.

Installations requiring hazardous substances consent. (Where there is a demonstrable need to locate

such installations for bulk storage of materials with port or other similar facilities, or such installations

with energy infrastructure or carbon capture and storage installations, that require coastal or water-side

locations, or need to be located in other high flood risk areas, in these instances the facilities should be

classified as ‘Essential Infrastructure’).

More

Vulnerable

Hospitals

Residential institutions such as residential care homes, children’s homes, social services homes, prisons

and hostels.

Buildings used for dwelling houses, student halls of residence, drinking establishments, nightclubs and

hotels.

Non–residential uses for health services, nurseries and educational establishments.

Landfill* and sites used for waste management facilities for hazardous waste.

Sites used for holiday or short-let caravans and camping, subject to a specific warning and evacuation

plan.

Less

Vulnerable

Police, ambulance and fire stations which are not required to be operational during flooding.

Buildings used for shops; financial, professional and other services; restaurants, cafes and hot food

takeaways; offices; general industry, storage and distribution; non-residential institutions not included in

the ‘more vulnerable’ class; and assembly and leisure.

Land and buildings used for agriculture and forestry.

Waste treatment (except landfill* and hazardous waste facilities).

Minerals working and processing (except for sand and gravel working).

Water treatment works which do not need to remain operational during times of flood.

Sewage treatment works, if adequate measures to control pollution and manage sewage during flooding

events are in place.

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Water-

compatible

Development

Flood control infrastructure.

Water transmission infrastructure and pumping stations.

Sewage transmission infrastructure and pumping stations.

Sand and gravel working.

Docks, marinas and wharves.

Navigation facilities.

Ministry of defence installations.

Ship building, repairing and dismantling, dockside fish processing and refrigeration and compatible

activities requiring a waterside location.

Water-based recreation (excluding sleeping accommodation).

Lifeguard and coastguard stations.

Amenity open space, nature conservation and biodiversity, outdoor sports and recreation and essential

facilities such as changing rooms.

Essential ancillary sleeping or residential accommodation for staff required by uses in this category,

subject to a specific warning and evacuation plan.

Table 3. Vulnerability Classification (Extracted from PPG)

3.0 Exceptions Test 3.1 The purpose of the Exception Test is to ensure that new development is only permitted in medium and high flood risk areas where flood

risk is clearly outweighed by other sustainability factors and where the development will be safe during its lifetime, considering climate change. The Exception Test comprises two criteria, both of which must be satisfied before a development may be considered appropriate within an area of medium or high flood risk.

3.2 Part 1 – wider benefits to the community that outweigh flood risk

3.3 The PPG states ‘Evidence of wider sustainability benefits to the community should be provided, for instance, through the sustainability appraisal. If a potential site allocation fails to score positively against the aims and objectives of the sustainability appraisal, or is not otherwise capable of demonstrating sustainability benefits, the local planning authority should consider whether the use of planning conditions and/or planning obligations could make it do so. Where this is not possible the Exception Test has not been satisfied and the allocation should not be made.’

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3.4 Table 4 and 5 provide a policy review in relation to each site where the Exceptions Test and Level 2 SFRA is required, which considers the potential for wider benefits to the community.

Site Wider Benefits

Bridge Park & Unisys In the London Plan this site is within an Area for Regeneration, being in the top 20% most

deprived areas. The site is wholly brownfield. In its current state the site is of a poor

environmental quality, with dated buildings and the long-term vacant Unisys buildings which on

numerous occasions have been subject to anti-social behaviour such as extensive fly-tipping. It

contrasts with the attractive environment created elsewhere in Stonebridge through modern

development. Redevelopment would improve the environmental quality of the area and create

an attractive gateway to the borough and Stonebridge.

Comprehensive mixed-use development is needed to help facilitate a new leisure centre and to

bring the Unisys buildings back in use. The development will meet an identified need for a new

leisure centre and swimming pool in the south of the borough, as identified in the Council’s

Indoor Sports Facility Strategy. The Council does not own a site of sufficient size to provide

such a facility in the south of the borough which is sequentially preferable and/or which is not

designated open space.

The site benefits from good public transport access with a PTAL rating of both 3 and 4. The

NPPF and London Plan support residential development on underutilised sites in areas of good

public transport accessibility, such as this one.

In conclusion, alternative sites would not bring the regenerative benefits and are insufficient to

provide the capacity to meet London Plan housing targets.

Coombe Road In the London Plan this site is within an Area for Regeneration, being in the top 20% most

deprived areas. The site is used to a relatively low intensity given its position adjacent to a

main movement corridor. The McDonalds in particular is a poor piece of townscape

inconsistent with the small set back from the edge of pavement/ strong building line along the

rest of the road. Other recent developments along Neasden Lane indicates that sites can be

used more intensively to provide mixed use schemes that provide employment opportunities/

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services as well as adding to the dwelling stock. The site has good access to public transport

and local infrastructure including shops and open spaces. The Council needs to ensure

continued provision of employment space, so will seek its retention of employment uses on

site. The location of buildings and their design will have to ensure that there is no unacceptable

risk to building occupants, or property and people elsewhere as a result of any proposed

development. Setting back buildings from the watercourse provides an opportunity for their

enhancement and also potential future public access along pedestrian routes.

In conclusion, alternative sites would not bring the regenerative benefits and are insufficient to

provide the capacity to meet London Plan housing targets.

Watkin Road In the London Plan this site is within the Wembley Opportunity Area. It is also within the

Wembley Growth Area, which is identified to meet a significant proportion of the borough’s

housing and employment need.

The site is located in an area with good public transport accessibility levels and could improve

the public realm as a transition from the new Wembley Park development to the industrial land

located east of Wealdstone Brook. The NPPF and London Plan support residential

development on underutilised sites in areas of good public transport accessibility, such as this

one. Development at this site can bring forward an improved setting for Wealdstone Brook

including the delivery of open space and river restoration work to improve ecological diversity

and climate change adaptation.

In conclusion, alternative sites would not bring the regenerative benefits and are insufficient to

provide the capacity to meet London Plan housing targets.

Argenta House & Wembley Point In its current state the site is of a poor environmental quality, with dated buildings.

Redevelopment would improve the environmental quality of the area, help reduce flood risk

and create an attractive gateway to the borough and Stonebridge.

The Wealdstone Brook is not achieving good status as required by the EU Water Framework

Directive. Development on this site could facilitate naturalisation of the Wealdstone Brook,

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delivering objectives in the Thames River Basin Management Plan and Brent River Corridor

Improvement Plan, and improving water quality.

The site benefits from good public transport access being adjacent Stonebridge Park Station

and having a PTAL rating of 4. The NPPF and London Plan support residential development on

underutilised sites in areas of good public transport accessibility, such as this one.

Although the majority of the site is within flood zone 3b and therefore not suitable for

development other than water compatible uses, land within flood zone 3a could be developed

to deliver benefits to the wider community.

In conclusion, alternative sites would not bring the regenerative benefits and are insufficient to

provide the capacity to meet London Plan housing targets.

Brook Avenue In the London Plan this site is within the Wembley Opportunity Area. It is also within the

Wembley Growth Area, which is identified to meet a significant proportion of the boroughs

housing an employment need.

The site is located in an area with excellent public transport accessibility levels and could

improve the public realm as a gateway to the new Wembley Park development. The NPPF and

London Plan support residential development on underutilised sites in areas of good public

transport accessibility, such as this one. Given the high levels of development around this site,

it would benefit from good access to local shops and services. Redevelopment of this site can

contribute towards an improved setting for the Wealdstone Brook, including the delivery of

open space and river restoration work to improve ecological diversity and climate change

adaptation. It will also remove existing dwellings that are at risk of ground floor fluvial flooding.

In conclusion, alternative sites would not bring the regenerative benefits and are insufficient to

provide the capacity to meet London Plan housing targets.

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College of North West London

Wembley

In the London Plan this site is within the Wembley Opportunity Area. It is also within the

Wembley Growth Area, which is identified to meet a significant proportion of the borough’s

housing and employment need.

The site is located in an area with excellent public transport accessibility levels. The NPPF and

London Plan support residential development on underutilised sites in areas of good public

transport accessibility, such as this one. Given the high levels of development around this site,

it would benefit from good access to local shops and services. The site is likely to be surplus to

the college’s requirements as part of a process of consolidation of better facilities on another

site within Wembley Park. The site’s location on Olympic Way provides an opportunity to

create a high quality development to act as a gateway from Wembley Park Station to the

stadium.

In conclusion, alternative sites would not bring the regenerative benefits and are insufficient to

provide the capacity to meet London Plan housing targets.

Stadium Retail Park & Fountain

Studios

In the London Plan this site is within the Wembley Opportunity Area. It is also within the

Wembley Growth Area, which is identified to meet a significant proportion of the borough’s

housing and employment need.

The NPPF and London Plan support residential development on underutilised sites in areas of

good public transport accessibility, such as this one which has excellent public transport

access and the close proximity to bus, rail and underground transport interchanges. The site

offers substantial development potential as an integral part of the wider Wembley Park

development area. The Wembley Masterplan suggests that there are a number of mixed use

options where creative office and other accommodation can be combined with educational and

commercial accommodation at lower levels with residential development in upper storeys.

In conclusion, alternative sites would not bring the regenerative benefits and are insufficient to

provide the capacity to meet London Plan housing targets.

Table 4. Policy Review – due to fluvial flood zone

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Site Wider Benefits

Turpin’s Yard This site is partly within a location identified in the London Plan as an Area for Regeneration,

being in the top 20% most deprived areas. This is a low density local employment site. The site

benefits from good public transport access having a PTAL rating of 4. The NPPF and London

Plan support residential development on underutilised sites in areas of good public transport

accessibility, such as this one.

In conclusion, alternative sites would not bring the regenerative benefits and are insufficient to

provide the capacity to meet London Plan housing targets.

Park Avenue Garage This is a low density local employment site. The site benefits from good public transport access

having a PTAL rating of 3/4 and being in walking distance to Willesden Green Station. The

NPPF and London Plan support residential development on underutilised sites in areas of good

public transport accessibility, such as this one.

In conclusion, alternative sites would not bring the regenerative benefits and are insufficient to

provide the capacity to meet London Plan housing targets.

Hereford & Exeter Court In the London Plan this site is within an Area for Regeneration, being in the top 20% most

deprived areas. It is a Growth Area and the Council is leading on a 15-year programme which

is about half way through. The Council’s objective is to improve living conditions in South

Kilburn by providing new facilities and high quality homes including 1,200 affordable homes for

social rent for existing South Kilburn secure tenants, supported by homes for market sale. The

funding model of the programme means failure to deliver one phase could prejudice the wider

masterplan for the growth area.

The existing buildings are of poor design and construction creating poor housing conditions

and potential for anti-social behaviour in communal spaces which cannot be remedied cost

efficiently through refurbishment. The opportunity exists to provide better housing along sound

urban design principles creating a human scale environment that integrates with the

surrounding area and is more sympathetic in scale to the conservation area. It will be at a

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density that reflects the PTAL rating and reinforces the street hierarchy and setting of Carlton

Vale in particular, subject to the Council being able to ensure Granville Road is reopened

between this site and the Carlton and Granville Centres which subsequently will result in the

existing Granville Open Space being developed for housing, this site will incorporate its

replacement open space. This will provide a better quality open space with greater opportunity

for sunlight penetration, overlooking/sense of security and due to its prominence more likely to

be used by the surrounding population.

In conclusion, alternative sites would not bring the regenerative benefits and are insufficient to

provide the capacity to meet London Plan housing targets.

Neasden Station Growth Area The London Plan identifies the area surrounding these sites as an Area for Regeneration,

being in the top 20% most deprived areas. The site adjacent to Neasden Lane is currently

mostly low intensity used Strategic Industrial Land and Locally Significant Industrial Sites that

are adjacent to a station with very high public transport accessibility. This accessibility makes

them from a planning perspective a prime site for more intensive use of land. Given Brent’s

status as a ‘provide capacity’ borough for employment space in the London Plan, the SIL and

LSIS also provide a vital role in meeting future employment needs. Site owners/ developers

are showing interest in bringing sites forward. The proposed West London Orbital route

requires appropriate safeguarding of land, but also provides an opportunity to increase the

area’s accessibility and potential for regeneration. In addition, a large potential development

site is the College of North West London’s campus which is to be disposed of to fund a move to

Wembley and improved facilities. Taking these factors together there is an opportunity to

properly plan a wider ‘Growth Area’. This can comprehensively reconsider the area’s role, to

potentially increase its performance as an employment area, but also address other strategic

needs, such as using land more effectively, providing new homes, ensure successful delivery

of a key piece of transport infrastructure and improve the image of Brent on a gateway site. It

also will assist in providing additional population to support Church End and Neasden town

centres.

In conclusion, alternative sites would not bring the regenerative benefits and are insufficient to

provide the capacity to meet London Plan housing targets.

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Queensbury LSIS & Morrisons The NPPF and London Plan support residential development on underutilised sites in areas of good public transport accessibility, such as this one. Furthermore, London Plan policy encourages the comprehensive redevelopment of low-density supermarket sites.

Within the boundary of the site are two areas of locally significant industrial sites, which are not

intensively used and contain buildings which are in poor condition. Given Brent’s status as a

‘provide capacity’ borough in the London Plan, the proposed intensification and co-location at

these sites will contribute towards meeting future employment needs.

In conclusion, alternative sites would not bring the regenerative benefits and are insufficient to

provide the capacity to meet London Plan housing targets.

Table 5. Policy Review – due to surface water flood zone

3.5 The Sustainability Appraisal which underpins Brent’s Local Plan takes the form of an Integrated Impact Assessment incorporating the

requirement of Strategic Environmental Assessment, Health Impact Assessment and Equality Impact Assessment. This has created 24 criteria against which all sites are assessed. Criteria listed in Table 6 below.

Social

Prosperity, Inequalities and Social Inclusion

S1. To promote social inclusion, narrow inequalities and address poverty for all communities within the borough.

Health and Well-being

S2: To improve the health of the population and reduce health inequalities through access to necessary healthcare facilities and an

environment that promotes physical and mental well-being

Housing

S3: To provide everybody with the opportunity to live in a home which is suitable to their identified needs

Quality of surroundings

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S4: To provide a safe, high quality and healthy environment for the borough residents to live, work and enjoy.

Crime and Preventing and Community Safety

S5: To enhance community safety by reducing and preventing crime, anti-social activity and the perception of potential harm to

personal safety

Community Identity

S6: To recognise and provide for Brent’s population diversity while encouraging a shared sense of community and cultural

identity/belonging, as well as engagement in local, high quality community services and facilities

Accessibility

S7: To maintain and enhance the role and vitality and viability of Brent’s town centres and where possible improve accessibility to a

range of services and facilities, such as healthcare and education, especially for the most vulnerable

Environmental

Traffic

EN1: To reduce the effect of traffic on the environment through actively reducing the need to travel and promoting sustainable

modes of movement

Waste Management

EN2: To reduce the production of waste and use of non-renewable materials and maximising re-use and recycling.

Water Quality and Resources

EN3: To improve quality of the water bodies within the borough to ‘good’, protect ground water quality, conserve water resources

and provide for sustainable sources of water supply.

Environmental Health

EN4: Minimise air, noise and light pollution and improve existing areas of poor air quality and contaminated land.

Biodiversity

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EN5: To conserve and enhance the borough’s natural habitats, biodiversity, flora and fauna, water bodies and increase

opportunities for people to access nature in all areas of the borough.

Landscape and Townscape

EN6: Create, enhance and maintain attractive and clean environments including protecting and enhancing the borough’s landscape

and townscape.

Historic Environment and Cultural Assets

EN7: To protect and where appropriate enhance the historic environment and cultural assets.

Climate Change Mitigation

EN8: To mitigate against the impacts of climate change, predominately through reducing greenhouse gas emissions

Climate Change Adaption

EN9: Promote measures which adapt against the impact of climate change

Land and Soil

EN10: To safeguard and conserve soil quality and quantity within the borough

Open Space

EN11: Protect, enhance, and where possible increase the amount of open spaces that are high quality, easily accessible and multi-

functional.

Flood Risk

EN12: To reduce the risk of flooding and resulting detriment to public well-being, the economy and the environment

Economic

Growth and Regeneration

EC1: To actively promote sustainable, resilient and inclusive economic growth and regeneration which tangibly benefits Brent

residents and the environment

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Employment

EC2: To offer everybody the opportunity for rewarding and satisfying employment /self-employment

Investment

EC3: To facilitate both indigenous and inward investment within the borough

Education and Skills

EC4: Maximise the potential for everybody to contribute economically through increasing and improving the provision of and access

to childcare, education and training facilities, volunteering opportunities and informal employment

Efficient Infrastructure

EC5: To encourage efficient infrastructure to support economic growth

Table 6. IIA Criteria 3.6 The Brent Local Plan IIA contains an assessment for all sites in flood zone 2 and 3. In summary, although potential negative impacts in

terms of flood risk were identified, overall the sites demonstrated wider sustainability benefits that meet the objectives set in the IIA of the Local Plan. In particular, the sites scored positively against social objectives as they will help meet need for housing including affordable housing in areas which benefits from good public transport accessibility.

3.7 Part 2 – safe for its lifetime

3.8 PPG states ‘Wider safety issues need to be considered as part of the plan preparation. If infrastructure fails, then people may not be able to stay in their homes. Flood warnings and evacuation issues therefore need to be considered in design and layout of planned developments. In considering an allocation in a Local Plan a level 2 Strategic Flood Risk Assessment should inform consideration of the second part of the Exception Test.’

3.9 The lifetime of the development is considered 100 years for residential, and 60 years for non-residential as defined in the Level 1 SFRA.

3.10 There are a number of ways a new development can be made safe outlined in PPG, including by:

designing buildings to avoid flooding by, for example, raising floor levels;

providing adequate flood risk management infrastructure which will be maintained for the lifetime of the development;

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leaving space in developments for flood risk management infrastructure to be maintained and enhanced, and;

mitigating the potential impacts of flooding through design and flood resilient and resistant construction.

3.11 Specific local circumstances which need to be taken into account, include:

the characteristics of a possible flood event, e.g. the type and source of flooding and frequency, depth, velocity and speed of onset;

the safety of people within a building if it floods and also the safety of people around a building and in adjacent areas, including people who are less mobile or who have a physical impairment. This includes the ability of residents and users to safely access and exit a building during a design flood and to evacuate before an extreme flood;

the structural safety of buildings, and;

the impact of a flood on the essential services provided to a development.

3.12 The Level 1 SFRA provides detailed development management recommendations informed by the local context which will inform local plan policy. In addition, it sets out a checklist regarding what is required to be included in a Site Specific Flood Risk Assessments and Drainage Strategies, informed by the criteria above. The following section of this Level 2 SFRA provides site specific guidance for development within medium to high risk sites to ensure it’s safe for its lifetime.

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4.0 Site Assessments

SFRA Level 2 required due to fluvial flood risk

Site Name: Bridge Park

& Unisys

Site Allocation Ref. BSSA7

Location: Brentfield,

Stonebridge,

NW10 0RG

Site Area (ha): 2.7

Proposed Use: Leisure

centre, office

and

residential

Vulnerability Classification: More vulnerable

Fluvial flooding

Flood zone 2 Flood zone 3a Flood zone 3b

100% 100% 0

Peak flood level in a 1 in 20yr flood event

(AOD)

Peak flood level in a 1 in 100yr flood event

(AOD)

Peak modelled flow in a 1 in 100yr flood

event (cumecs)

26.27m 26.72m 111.62

The site in its entirety is within flood zone 2 and 3a. The River Brent runs approximately 60 metres to the north west of the site and is the source

of fluvial flooding. This section of the River Brent is culverted. The flood depths within the site are up to 600mm at the lowest point in the 1% (1 in

100 year) design event, and whilst relatively slow moving (and therefore unlikely to pose a direct risk to life), it is anticipated that water will sit

within the site for an extended period (exceeding 10 to 12 hours). The predicted peak design flood levels within the site are 25.03m AOD and

26.72m AOD in the 5% (1 in 20 year) and 1% (1 in 100 year) events respectively.

The EA have recorded historic flood events encompassing the north of the site including the Unisys buildings. The site does not benefit from

flood defences. Flood defences for the River Brent are located further upstream at Brent River Park.

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Surface water flooding

Flood zone 3a 15%

Surface water ponding is

predicted on hard standing to

the south east of the site and

to the west of the Unisys

buildings during the 1 in 30-

year pluvial event or greater.

An overland flow path is

observed along the

surrounding road network

connecting to the railway

embankment. The majority of

the ground coverage in the

site is impermeable. This can

compound surface water

flooding as the runoff rate is

greater on impermeable

grounds compared to

permeable areas. In addition,

less water is able to drain

away through infiltration,

which increases the surface

water flood risk in these

areas. The Environment

Agency’s surface water

depth modelling identifies the

potential for depths of 0 -

600mm on the site during the

1% annual chance.

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Climate Change

Main River 35% Climate Change Surface Water 1 in 30yr Surface Water 1 in 100yr (increase)

100% 15% 4%

Surface water flooding is likely to increase in frequency due to climate change.

Geology and Groundwater

Groundwater susceptibility 25%-50%

The site is underlain by Thames Group (also referred to as London Clay) bedrock, a composition of silty clay/mudstone, sandy silts and sandy

clayey silts of marine origin. Thames Group generally has a low hydraulic conductivity which means water does not easily move through it.

However, because of this characteristic and poor drainage, ponding can occur if London Clay is downhill of aquifer outcrops. The Environment

Agency identify the susceptibility of ground water flooding in this location as between 25 and 50%. The site is in a Critical Drainage Area and has

increased potential for elevated groundwater.

Other Sources

Sewer 57% site

Reservoir 0

Canal 0

Sewer flooding can occur due to sewer infrastructure failure or due to an increased flow and volume of water entering a sewer system which

exceeds its hydraulic capacity, causing the system to surcharge. If sewer outfall points are either blocked or submerged due to high water levels,

water can back up in a sewer system and cause flooding. These issues can result in water overflowing from gullies and drainage inspection

holes, causing flooding in the local area. The south of the borough has a combined sewer, leading to increased environmental risks where

flooding occurs. Thames Water Utilities Ltd provide surface water, foul and combined sewer systems in the borough. Thames Water have

recorded incidents of sewer flooding surrounding to the south on land encompassing Technology House and the scrap yard, and to the north on

land surrounding the Unisys Buildings.

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Site Layout and Design

More vulnerable uses should be located on upper floors and ground floor uses made resilient and resistant to flooding. Highly vulnerable uses

and habitable basements will not be permitted on the site.

A positive reduction in the risk of flooding must be demonstrated and flood flow routes improved and not restricted. It must be demonstrated that

the proposed development does not result in an increase in maximum flood levels, within adjoining properties.

Surface Water

A drainage strategy will be required which accords with the Drainage Strategy Submission Checklist included in the Level 1 SFRA. The drainage

strategy for the site must be considered early in the site planning process to ensure adequate inclusion of Sustainable Drainage Systems

(SuDS). SuDS should aim to achieve greenfield run off rates, providing management and attenuation features that ensure that surface water

runoff is managed as close to the source as possible in accordance with the London Plan drainage hierarchy.

Permeable surfaces should be increased, and open space and green infrastructure maximised to ensure space for water to flow during times of

flood. Within flood zone 3a (surface water), flood plain compensation must account for predicted flood depths for the 1 in 30yr and 1 in 100yr

Risk of Flooding from Surface Water mapping or depth predicted for the site.

Finished Floor Levels

Finished floor levels should be set at least 300mm freeboard above the 1 in 100 flood level plus an appropriate allowance for climate change. Internal access to higher floors is required. It important to consider the implications of diverting the water on the flood risk of the wider area. Resilience and Resistant Measures

A number of flood resistance and resilience measures can also be implemented into new developments to mitigate potential flooding. These could include:

installing electrical equipment above flood level

installing flood doors and barriers, to ensure water stays out of a property to a given height

providing adequate flood risk management infrastructure. Space should be left in developments for flood risk management infrastructure to be maintained and enhanced.

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Access/Egress

Safe dry access to and from the site should be provided for the lifetime of the property, factoring in the impacts of climate change. In this case the lifetime of the property is 100 years. Emergency Planning

Details will be required on the flood related risks that will remain once the proposed mitigation measures have been implemented, and how the risks will be managed over the development’s lifetime. Flood warnings and/ or flood alerts need to be considered along with the emergency evacuation procedures in the design and layout of the proposed development. Developments will be required to sign up to the Environment Agency flood warning system. Details will be required on flood warning and emergency evacuation procedures as well as details regarding safe refuge areas above ground floor if dry egress routes for evacuation cannot be guaranteed. This should consider the safety of people within the building and also the safety of people around the building and in adjacent areas, including those who are less mobile. LLFA Consultation

It is recommended that potential developers contact the Environment Agency and Brent Council as the LLFA for further information prior to taking forward site specific plans. Site Specific FRA A Site Specific Flood Risk Assessment will be required which meets the requirements of the Flood Risk Assessment Submission Checklist in the Level 1 SFRA. The Site Specific FRA should be informed by modelling to further assess the flood frequency, depth, velocity and speed of onset.

Summary

Based on the strategic assessment of flood risk and the recommendations for mitigation measures set out above, it is considered that proposed development on this site could be suitably designed to satisfy part 2 of the Exception Test subject to submission of a detailed Site Specific FRA.

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Site Name: Coombe Road Site Allocation Ref. BESA1

Location: Land at Coombe Road Site Area (ha): 1.35

Proposed Use: Housing and

employment

Vulnerability

Classification:

More Vulnerable

Fluvial flooding

Flood zone 2 Flood zone 3a Flood zone 3b

100% 26% 1%

Peak flood level in a 1 in 20yr

flood event (AOD)

Peak flood level in a 1 in 100yr flood

event (AOD)

Peak modelled flow in a 1 in 100yr flood event (cumecs)

31.12m 32.27m 84.73

The site is bounded on its western side by the River Brent and to the east a culverted canal feeder, both of which flows from Welsh Harp

Reservoir. As a result, the site is within flood zone 2, and the edges flood zone 3a. The river which bounds the site is functional floodplain.

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Surface water flooding

Flood zone 3a 0

Climate Change

Main River 35% Climate

Change

Surface Water 1 in 30yr Surface Water 1 in

100yr (increase)

100% 0 0

Geology and Groundwater

Groundwater susceptibility 25%-50%

The site is underlain by Thames Group (also referred to as London Clay) bedrock, a composition of silty clay/mudstone, sandy silts and sandy

clayey silts of marine origin. Thames Group generally has a low hydraulic conductivity which means water does not easily move through it.

However, because of this characteristic and poor drainage, ponding can occur if London Clay is downhill of aquifer outcrops. The Environment

Agency identify the susceptibility of ground water flooding in this location as between 25 and 50%. The site has potential for elevated

groundwater.

Other Sources

Sewer 94% site

Reservoir 100% site

Canal 0

Sewer flooding can occur due to sewer infrastructure failure or due to an increased flow and volume of water entering a sewer system which

exceeds its hydraulic capacity, causing the system to surcharge. If sewer outfall points are either blocked or submerged due to high water levels,

water can back up in a sewer system and cause flooding. These issues can result in water overflowing from gullies and drainage inspection

holes, causing flooding in the local area. The south of the borough has a combined sewer, leading to increased environmental risks where

flooding occurs. Thames Water Utilities Ltd provide surface water, foul and combined sewer systems in the borough. They hold no records of

historic sewer flooding instances within this site as of 2017.

Should the Welsh Harp reservoir be breached or fail, the entirety of the site would be at risk of flooding.

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Site Layout and Design

More vulnerable uses, including residential development should be avoided in the area defined as flood zone 3a; instead less vulnerable and

water compatible uses including landscaped open space should be located here.

A positive reduction in the risk of flooding must be demonstrated and flood flow routes improved and not restricted. It must be demonstrated that

the proposed development does not result in an increase in maximum flood levels, within adjoining properties.

Development should contribute to the restoration of the River Brent and naturalisation of waterways, providing an appropriate landscaped set-

back.

Surface Water

A drainage strategy will be required which accords with the Drainage Strategy Submission Checklist included in the Level 1 SFRA. The drainage

strategy for the site must be considered early in the site planning process to ensure adequate inclusion of Sustainable Drainage Systems

(SuDS). SuDS should aim to achieve greenfield run off rates, providing management and attenuation features that ensure that surface water

runoff is managed as close to the source as possible in accordance with the London Plan drainage hierarchy.

Set-back Distance

An 8m wide undeveloped buffer strip should be retained along main rivers to provide access for maintenance. Finished Floor Levels

If residential development cannot be avoided within the flood extent, finished floor levels should be set at least 300mm freeboard above the 1 in 100 flood level plus an appropriate allowance for climate change. Internal access to higher floors is required. It important to consider the implications of diverting the water on the flood risk of the rest of the site. Resilience and Resistant Measures

A number of flood resistance and resilience measures can also be implemented into new developments to mitigate potential flooding. These could include:

installing electrical equipment above flood level

installing flood doors and barriers, to ensure water stays out of a property to a given height

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providing adequate flood risk management infrastructure. Space should be left in developments for flood risk management infrastructure to be maintained and enhanced.

Access/Egress

Safe dry access to and from the site should be provided for the lifetime of the property, factoring in the impacts of climate change. In this case the lifetime of the property is 100 years. Emergency Planning

Details will be required on the flood related risks that will remain once the proposed mitigation measures have been implemented, and how the risks will be managed over the development’s lifetime. Flood warnings and/ or flood alerts need to be considered along with the emergency evacuation procedures in the design and layout of the proposed development. Particular regard should be given to procedures in the event of reservoir failure. Developments will be required to sign up to the Environment Agency flood warning system. Details will be required on flood warning and emergency evacuation procedures as well as details regarding safe refuge areas above ground floor if dry egress routes for evacuation cannot be guaranteed. This should consider the safety of people within the building and also the safety of people around the building and in adjacent areas, including those who are less mobile. LLFA Consultation

It is recommended that potential developers contact the Environment Agency and Brent Council as the LLFA for further information prior to taking forward site specific plans. Site Specific FRA A Site Specific Flood Risk Assessment will be required which meets the requirements of the Flood Risk Assessment Submission Checklist in the Level 1 SFRA. The Site Specific FRA should be informed by modelling to assess the flood frequency, depth, velocity and speed of onset.

Summary

Based on the strategic assessment of flood risk and the recommendations for mitigation measures set out above, it is considered that proposed development on this site could be suitably designed to satisfy part 2 of the Exception Test subject to submission of a detailed Site Specific FRA.

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Site Name: Watkin Road Site Allocation Ref. BCSA6

Location: Wembley, HA9 0NL Site Area (ha): 1.41

Proposed Use: Residential and employment Vulnerability

Classification:

More vulnerable

Fluvial flooding

Flood zone 2 Flood zone 3a Flood zone 3b

88% 17% 0

Peak flood level in a 1 in 20yr flood event

(AOD)

Peak flood level in a 1 in 100yr flood

event (AOD)

Peak modelled flow in a 1 in 100yr flood event (cumecs)

30.54m 31.37 45.76

The Wealdstone Brook runs along the northern boundary of the site and is a source of flooding. Some low areas adjoining the river are

functional flood plain, although these are outside of the site allocation boundary. 88% of the site is in flood zone 2, whilst areas to the north in

proximity to the brook are in flood zone 3a.

Modelling work to inform the Wembley Area Action Plan indicate in a fluvial flood event floodwater will inundate the site for a short period, not

exceeding 12 hours. The site has no protection from raised formal flood defences.

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Surface water flooding

Flood zone 3a 18%

Surface water ponding

is predicted on Watkin

Road during the 1 in 30-

year pluvial event or

greater. An overland

flow path is observed

along the surrounding

road network. The

Environment Agency’s

surface water depth

modelling identifies the

potential for depths of 0

- 900mm on the site

during the 1% annual

chance. The majority of

the ground coverage in

the site is impermeable.

This can compound

surface water flooding

as the runoff rate is

greater on impermeable

grounds compared to

permeable areas. In

addition, less water is

able to drain away

through infiltration,

which increases the

surface water flood risk

in these areas.

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Climate Change

Main River 35%

Climate Change

Surface Water

1 in 30yr

Surface Water 1 in 100yr

(increase)

70% 18% 10%

Geology and Groundwater

Groundwater susceptibility <25%

The site is underlain by Thames Group (also referred to as London Clay) bedrock, a composition of silty clay/mudstone, sandy silts and sandy

clayey silts of marine origin. Thames Group generally has a low hydraulic conductivity which means water does not easily move through it.

However, because of this characteristic and poor drainage, ponding can occur if London Clay is downhill of aquifer outcrops. The

Environment Agency identify the susceptibility of ground water flooding in this location as between 25 and 50%. The site is in a Critical

Drainage Area. There is increased potential for elevated groundwater to the north of the site.

Other Sources

Sewer 97% site

Reservoir 0

Canal 0

Sewer flooding can occur due to sewer infrastructure failure or due to an increased flow and volume of water entering a sewer system which

exceeds its hydraulic capacity, causing the system to surcharge. If sewer outfall points are either blocked or submerged due to high water

levels, water can back up in a sewer system and cause flooding. These issues can result in water overflowing from gullies and drainage

inspection holes, causing flooding in the local area. The south of the borough has a combined sewer, leading to increased environmental risks

where flooding occurs. Thames Water Utilities Ltd provide surface water, foul and combined sewer systems in the borough.

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Site Layout and Design

The sequential approach should be applied at site level. More vulnerable uses should be restricted to areas of lowest flood risk to the south of

the site outside of flood zone 3a. Highly vulnerable development should be avoided within this site. Encroachment into Functional Floodplain

will not be permitted. Residential basements will not be acceptable in flood zone 3a.

Flow routes should not be obstructed.

Redevelopment must deliver a measurable reduction in flood risk. The development should contribute to flood alleviation schemes and re-

naturalisation to Wealdstone Brook. Planting should be reinforced along the brook.

Surface Water

A drainage strategy will be required which accords with the Drainage Strategy Submission Checklist included in the Level 1 SFRA. The

drainage strategy for the site must be considered early in the site planning process to ensure adequate inclusion of Sustainable Drainage

Systems (SuDS). SuDS should aim to achieve greenfield run off rates, providing management and attenuation features that ensure that

surface water runoff is managed as close to the source as possible in accordance with the London Plan drainage hierarchy.

Permeable surfaces should be increased, and open space maximised to ensure space for water to flow during times of flood. Within flood

zone 3a (surface water), flood plain compensation must account for predicted flood depths for the 1 in 30yr and 1 in 100yr Risk of Flooding

from Surface Water mapping or depth predicted for the site.

Set-back Distance

An 8m wide undeveloped buffer strip should be retained along main the Wealdstone Brook to provide access for maintenance. Finished Floor Levels

For residential development within the flood extent finished floor levels should be set at least 300mm freeboard above the 1 in 100 flood level plus an appropriate allowance for climate change. Internal access to higher floors is required. It important to consider the implications of diverting the water on the flood risk of the rest of the site.

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Resilience and Resistant Measures

A number of flood resistance and resilience measures can also be implemented into new developments to mitigate potential flooding. These could include:

installing electrical equipment above flood level

installing flood doors and barriers, to ensure water stays out of a property to a given height

providing adequate flood risk management infrastructure. Space should be left in developments for flood risk management infrastructure to be maintained and enhanced.

Access/Egress

Safe dry access to and from the site should be provided for the lifetime of the property, factoring in the impacts of climate change. In this case the lifetime of the property is 100 years. Emergency Planning

Details will be required on the flood related risks that will remain once the proposed mitigation measures have been implemented, and how the risks will be managed over the development’s lifetime. Flood warnings and/ or flood alerts need to be considered along with the emergency evacuation procedures in the design and layout of the proposed development. Developments will be required to sign up to the Environment Agency flood warning system. Details will be required on flood warning and emergency evacuation procedures as well as details regarding safe refuge areas above ground floor if dry egress routes for evacuation cannot be guaranteed. This should consider the safety of people within the building and also the safety of people around the building and in adjacent areas, including those who are less mobile. LLFA Consultation

It is recommended that potential developers contact the Environment Agency and Brent Council as the LLFA for further information prior to taking forward site specific plans. Site Specific FRA A Site Specific Flood Risk Assessment will be required which meets the requirements of the Flood Risk Assessment Submission Checklist in the Level 1 SFRA. The Site Specific FRA should be informed by modelling to assess the flood frequency, depth, velocity and speed of onset.

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Summary

Based on the strategic assessment of flood risk and the recommendations for mitigation measures set out above, it is considered that proposed development on this site could be suitably designed to satisfy part 2 of the Exception Test subject to submission of a detailed Site Specific FRA.

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Site Name: Argenta House & Wembley Point Site

Allocation

Ref.

BSSA6

Location: Argenta Way, NW10 0AZ Site Area

(ha):

1.2

Proposed Use: Residential and employment Vulnerability

Classification:

More vulnerable

Fluvial flooding

Flood zone 2 Flood zone 3a Flood zone 3b

100% 99% 72%

Peak flood level in a 1 in

20yr flood event (AOD)

Peak flood level in a 1 in 100yr flood event

(AOD)

Peak modelled flow in a 1 in 100yr flood event (cumecs)

26.27m 26.72m 122.20

Wembley Brook intersects the site. The brook is in a concrete channel which connects to the River Brent via a culvert River Brent and its

tributaries Wembley Brook, Wealdstone Brook, Silkstream

Modelling work approved by the Environment Agency has demonstrated that the site is not within flood zone 3b. However, 89% of the site is

flood zone 3a.

The River Brent has experienced historic flood events.

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Surface water flooding

Flood zone 3a 36%

Surface water ponding is

predicted along the Brook

during the 1 in 30-year

pluvial event or greater.

An overland flow path is

observed along the Brook

connection to the

surrounding road network.

The majority of the ground

coverage in the site and

its surroundings is

impermeable, and lacks

soft landscaping. This can

compound surface water

flooding as the runoff rate

is greater on impermeable

grounds compared to

permeable areas.

The Environment

Agency’s surface water

depth modelling identifies

the potential for depths of

0 - 1200mm on land

surrounding the Brook

during the 1% annual

chance.

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Climate Change

Main River 35% Climate Change Surface Water 1 in 30yr Surface Water 1 in 100yr (increase)

100% 36% 20%

Geology and Groundwater

Groundwater susceptibility 25%-50%

The site is underlain by Thames Group (also referred to as London Clay) bedrock, a composition of silty clay/mudstone, sandy silts and sandy

clayey silts of marine origin. Thames Group generally has a low hydraulic conductivity which means water does not easily move through it.

However, because of this characteristic and poor drainage, ponding can occur if London Clay is downhill of aquifer outcrops. The Environment

Agency identify the susceptibility of ground water flooding in this location as between 25 and 50%. The site is in a Critical Drainage Area with

increased potential for elevated groundwater.

Other Sources

Sewer 87% site

Reservoir 0

Canal 0

Sewer flooding can occur due to sewer infrastructure failure or due to an increased flow and volume of water entering a sewer system which

exceeds its hydraulic capacity, causing the system to surcharge. If sewer outfall points are either blocked or submerged due to high water

levels, water can back up in a sewer system and cause flooding. These issues can result in water overflowing from gullies and drainage

inspection holes, causing flooding in the local area. The south of the borough has a combined sewer, leading to increased environmental risks

where flooding occurs. Thames Water Utilities Ltd provide surface water, foul and combined sewer systems in the borough.

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Site Layout and Design

Development, other than water compatible uses, will not be acceptable within the functional flood plain (flood zone 3b). More vulnerable uses

should be restricted to areas of lowest flood risk and on upper floors. Ground floors should be designed to be resistant and resilient to flood risk.

Basement dwellings will not be acceptable on the site.

Through works to the Wembley Brook proposals should reduce flood risk overall and not increase the risk of flooding on adjoining sites. Flood

flow routes improved and not restricted. Proposals should seek to naturalise the Wembley Brook in accordance with the Thames River Basin

Management Plan and Brent River Corridor Improvement Plan.

Surface Water

A drainage strategy will be required which accords with the Drainage Strategy Submission Checklist included in the Level 1 SFRA. The

drainage strategy for the site must be considered early in the site planning process to ensure adequate inclusion of SuDS. SuDS should aim to

achieve greenfield run off rates, providing management and attenuation features that ensure that surface water runoff is managed as close to

the source as possible in accordance with the London Plan drainage hierarchy. The Wembley Brook is an opportunity for natural SuDS.

Permeable surfaces should be increased, planting and open space maximised to ensure space for water to flow during times of flood. Within

flood zone 3a (surface water), flood plain compensation must account for predicted flood depths for the 1 in 30yr and 1 in 100yr Risk of Flooding

from Surface Water mapping or depth predicted for the site.

Set-back Distance

An undeveloped buffer strip should be retained along main rivers to provide access for maintenance. Generally, this should be 8m wide, however, given the scale of the site the size of the buffer should be informed by detailed discussions with the Environment Agency.

Finished Floor Levels

If residential development cannot be avoided within the flood extent, finished floor levels should be set at least 300mm above the 1 in 100 flood level plus an appropriate allowance for climate change flood level. Internal access to higher floors is required. It important to consider the implications of diverting the water on the flood risk of the rest of the site. Resilience and Resistant Measures

A number of flood resistance and resilience measures can also be implemented into new developments to mitigate potential flooding. These could include:

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installing electrical equipment above flood level

installing flood doors and barriers, to ensure water stays out of a property to a given height

structural columns and stills should be circular design to avoid collection of debris during a flood event

providing adequate flood risk management infrastructure. Space should be left in developments for flood risk management infrastructure to be maintained and enhanced.

Access/Egress

Safe dry access to and from the site should be provided for the lifetime of the property, factoring in the impacts of climate change. In this case the lifetime of the development is 100 years. Emergency Planning

The site is in an EA flood warning area. Details will be required on the flood related risks that will remain once the proposed mitigation measures have been implemented, and how the risks will be managed over the development’s lifetime. Flood warnings and/ or flood alerts need to be considered along with the emergency evacuation procedures in the design and layout of the proposed development. Developments will be required to sign up to the Environment Agency flood warning system. Details will be required on flood warning and emergency evacuation procedures as well as details regarding safe refuge areas above ground floor if dry egress routes for evacuation cannot be guaranteed. This should consider the safety of people within the building and also the safety of people around the building and in adjacent areas, including those who are less mobile. LLFA Consultation

It is recommended that potential developers contact the Environment Agency and Brent Council as the LLFA for further information prior to taking forward site specific plans. Site Specific FRA A Site Specific Flood Risk Assessment will be required which meets the requirements of the Flood Risk Assessment Submission Checklist in the Level 1 SFRA. The Site Specific FRA should be informed by modelling to assess the flood frequency, depth, velocity and speed of onset.

Summary

Based on the strategic assessment of flood risk and the recommendations for mitigation measures set out above, it is considered that proposed development on this site could be suitably designed to satisfy part 2 of the Exception Test subject to submission of a detailed Site Specific FRA.

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Site Name: Brook Avenue Site Allocation Ref. BCSA3

Location: Wembley, HA9 Site Area (ha): 1.5

Proposed Use: Residential Vulnerability

Classification:

More vulnerable

Fluvial flooding

Flood zone 2 Flood zone 3a Flood zone 3b

82% 68% 6%

Peak flood level in a 1 in 20yr

flood event (AOD)

Peak flood level in a 1 in 100yr flood

event (AOD)

Peak modelled flow in a 1 in 100yr flood event (cumecs)

31.95m 32.58m 31.80

The Wealdstone Brook runs in a culvert to the north west of the site and is a source of flooding. The south western corner of the site is in flood

zone 3a due to fluvial flooding, and the majority of the site is in flood zone 2. The low lying areas adjoining the river is functional floodplain.

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Surface water flooding

Flood zone 3a 80%

Surface water ponding is

predicted on the eastern

portion of the site during

the 1 in 30-year pluvial

event or greater. The

Environment Agency’s

surface water depth

modelling identifies the

potential for depths in

excess of 1200mm on

the site during the 1%

annual chance. An

overland flow path is

observed through the

site. Whilst rear gardens

contain soft landscaping

front gardens largely

comprise hard standing.

This can compound

surface water flooding.

Less water is able to

drain away through

infiltration, which

increases the surface

water flood risk in these

areas. Surface water

flooding follows the

location of the fluvial

flood zones.

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Climate Change

Main River 35% Climate

Change

Surface Water 1 in 30yr Surface Water 1 in

100yr (increase)

79% 80% 25%

The extent of flood zone 3a will extend to encompass additional properties as a result of climate change, as will the area of surface water

flooding.

Geology and Groundwater

Groundwater susceptibility <25%

The site is underlain by Thames Group (also referred to as London Clay) bedrock, a composition of silty clay/mudstone, sandy silts and sandy

clayey silts of marine origin. Thames Group generally has a low hydraulic conductivity which means water does not easily move through it.

However, because of this characteristic and poor drainage, ponding can occur if London Clay is downhill of aquifer outcrops. The Environment

Agency identify the susceptibility of ground water flooding in this location as between 25 and 50%. The site is within a Critical Drainage Area.

Other Sources

Sewer 100% site

Reservoir 0

Canal 0

Sewer flooding can occur due to sewer infrastructure failure or due to an increased flow and volume of water entering a sewer system which

exceeds its hydraulic capacity, causing the system to surcharge. If sewer outfall points are either blocked or submerged due to high water

levels, water can back up in a sewer system and cause flooding. These issues can result in water overflowing from gullies and drainage

inspection holes, causing flooding in the local area. The south of the borough has a combined sewer, leading to increased environmental risks

where flooding occurs. Thames Water Utilities Ltd provide surface water, foul and combined sewer systems in the borough. The rear of the site

has been subject to sewer flooding historically.

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Site Layout and Design

More vulnerable uses should be restricted to upper floors and areas of lowest flood risk to the north. Lower vulnerability uses including

landscaped open space or gardens should be located in flood zone 3a. Encroachment into functional floodplain adjacent the site boundary will

not be permitted. Flow routes should not be obstructed.

A positive reduction in the risk of flooding must be demonstrated. It must be demonstrated that the proposed development does not result in an

increase in maximum flood levels, within adjoining properties.

The development should contribute to flood alleviation and re-naturalisation to Wealdstone Brook.

Surface Water

A drainage strategy will be required which accords with the Drainage Strategy Submission Checklist included in the Level 1 SFRA. The

drainage strategy for the site must be considered early in the site planning process to ensure adequate inclusion of Sustainable Drainage

Systems (SuDS). SuDS should aim to achieve greenfield run off rates, providing management and attenuation features that ensure that surface

water runoff is managed as close to the source as possible in accordance with the London Plan drainage hierarchy.

Permeable surfaces should be increased, and open space maximised to ensure space for water to flow during times of flood. Within flood zone

3a (surface water), flood plain compensation must account for predicted flood depths for the 1 in 30yr and 1 in 100yr Risk of Flooding from

Surface Water mapping or depth predicted for the site.

Set-back Distance

An 8m wide undeveloped buffer strip should be retained along main rivers to provide access for maintenance. Finished Floor Levels

If residential development cannot be avoided within the flood extent, finished floor levels should be set at least 300mm freeboard above the 1 in 100 flood level plus an appropriate allowance for climate change. Internal access to higher floors is required. It important to consider the implications of diverting the water on the flood risk of the rest of the site. Resilience and Resistant Measures A number of flood resistance and resilience measures can also be implemented into new developments to mitigate potential flooding. These could include:

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installing electrical equipment above flood level

installing flood doors and barriers, to ensure water stays out of a property to a given height

providing adequate flood risk management infrastructure. Space should be left in developments for flood risk management infrastructure to be maintained and enhanced.

Access/Egress

Safe dry access to and from the site should be provided for the lifetime of the property, factoring in the impacts of climate change. In this case the lifetime of the property is 100 years. Emergency Planning The majority of the site is in an EA flood warning area, with the exception of numbers 24 to 28. Details will be required on the flood related risks that will remain once the proposed mitigation measures have been implemented, and how the risks will be managed over the development’s lifetime. Flood warnings and/ or flood alerts need to be considered along with the emergency evacuation procedures in the design and layout of the proposed development. Developments will be required to sign up to the Environment Agency flood warning system. Details will be required on flood warning and emergency evacuation procedures as well as details regarding safe refuge areas above ground floor if dry egress routes for evacuation cannot be guaranteed. This should consider the safety of people within the building and also the safety of people around the building and in adjacent areas, including those who are less mobile. LLFA Consultation

It is recommended that potential developers contact the Environment Agency and Brent Council as the LLFA for further information prior to taking forward site specific plans. Site Specific FRA A Site Specific Flood Risk Assessment will be required which meets the requirements of the Flood Risk Assessment Submission Checklist in the Level 1 SFRA. The Site Specific FRA should be informed by modelling to assess the flood frequency, depth, velocity and speed of onset.

Summary

Based on the strategic assessment of flood risk and the recommendations for mitigation measures set out above, it is considered that proposed development on this site could be suitably designed to satisfy part 2 of the Exception Test subject to submission of a detailed Site Specific FRA.

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Site Name: College of North West

London Wembley

Site Allocation Ref. BCSA11

Location: Wembley, HA9 Site Area (ha): 0.37

Proposed Use: Mixed-use Vulnerability

Classification:

More vulnerable

Fluvial flooding

Flood zone 2 Flood zone 3a Flood zone 3b

79% 17% 16%

Peak flood level in a 1 in 20yr

flood event (AOD)

Peak flood level in a 1 in 100yr flood event

(AOD)

Peak modelled flow in a 1 in 100yr flood event (cumecs)

31.95m 32.58m 31.80

The Wealdstone Brook runs in a culvert to the north of the site and is a source of flooding. The majority of the site is in flood zone 2. The low lying

areas adjoining the river is functional floodplain.

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Surface water flooding

Flood zone 3a 68%

Surface water ponding is

predicted on the eastern portion

of the site during the 1 in 30-

year pluvial event or greater.

The Environment Agency’s

surface water depth modelling

identifies the potential for

depths in excess of 1200mm on

the site during the 1% annual

chance.

An overland flow path is

observed through the site along

the Wealdstone Brook and

around the college building.

The building is surrounded by

hardstanding which can

compound surface water

flooding as the runoff rate is

greater on impermeable

grounds compared to

permeable areas. In addition,

less water is able to drain away

through infiltration, which

increases the surface water

flood risk in these areas.

Surface water flooding follows

the location of the fluvial flood

zones.

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Climate Change

Main River 35% Climate

Change

Surface Water 1 in 30yr Surface Water 1 in

100yr (increase)

79% 80% 25%

The extent of flood zone 3a will extend to encompass additional properties as a result of climate change, as will the area of surface water flooding.

Geology and Groundwater

Groundwater susceptibility <25%

The site is underlain by Thames Group (also referred to as London Clay) bedrock, a composition of silty clay/mudstone, sandy silts and sandy

clayey silts of marine origin. Thames Group generally has a low hydraulic conductivity which means water does not easily move through it. However,

because of this characteristic and poor drainage, ponding can occur if London Clay is downhill of aquifer outcrops. The Environment Agency identify

the susceptibility of ground water flooding in this location as between 25 and 50%. The site has increased potential for elevated groundwater.

Other Sources

Sewer 21% site

Reservoir 0

Canal 0

Sewer flooding can occur due to sewer infrastructure failure or due to an increased flow and volume of water entering a sewer system which

exceeds its hydraulic capacity, causing the system to surcharge. If sewer outfall points are either blocked or submerged due to high water levels,

water can back up in a sewer system and cause flooding. These issues can result in water overflowing from gullies and drainage inspection holes,

causing flooding in the local area. The south of the borough has a combined sewer, leading to increased environmental risks where flooding occurs.

Thames Water Utilities Ltd provide surface water, foul and combined sewer systems in the borough. There are no records of historic sewer flooding

on the site.

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Site Layout and Design

More vulnerable uses should be restricted to upper floors and areas of lowest flood risk to the west. Lower vulnerability uses including landscaped

open space or gardens should be located in flood zone 3a. Encroachment into functional floodplain adjacent the site boundary will not be permitted.

Flow routes should not be obstructed.

A positive reduction in the risk of flooding must be demonstrated. It must be demonstrated that the proposed development does not result in an

increase in maximum flood levels, within adjoining properties.

The development should contribute to flood alleviation and re-naturalisation to Wealdstone Brook.

Surface Water

A drainage strategy will be required which accords with the Drainage Strategy Submission Checklist included in the Level 1 SFRA. The drainage

strategy for the site must be considered early in the site planning process to ensure adequate inclusion of Sustainable Drainage Systems (SuDS).

SuDS should aim to achieve greenfield run off rates, providing management and attenuation features that ensure that surface water runoff is

managed as close to the source as possible in accordance with the London Plan drainage hierarchy.

Permeable surfaces should be increased, and open space maximised to ensure space for water to flow during times of flood. Within flood zone 3a

(surface water), flood plain compensation must account for predicted flood depths for the 1 in 30yr and 1 in 100yr Risk of Flooding from Surface

Water mapping or depth predicted for the site.

Set-back Distance

An 8m wide undeveloped buffer strip should be retained along main rivers to provide access for maintenance. Finished Floor Levels

If residential development cannot be avoided within the flood extent, finished floor levels should be set at least 300mm freeboard above the 1 in 100 flood level plus an appropriate allowance for climate change. Internal access to higher floors is required. It important to consider the implications of diverting the water on the flood risk of the rest of the site. Resilience and Resistant Measures

A number of flood resistance and resilience measures can also be implemented into new developments to mitigate potential flooding. These could include:

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installing electrical equipment above flood level

installing flood doors and barriers, to ensure water stays out of a property to a given height

providing adequate flood risk management infrastructure. Space should be left in developments for flood risk management infrastructure to be maintained and enhanced.

Access/Egress

Safe dry access to and from the site should be provided for the lifetime of the property, factoring in the impacts of climate change. In this case the lifetime of the property is 100 years. Emergency Planning

The majority of the site is in an EA flood warning area. Details will be required on the flood related risks that will remain once the proposed mitigation measures have been implemented, and how the risks will be managed over the development’s lifetime. Flood warnings and/ or flood alerts need to be considered along with the emergency evacuation procedures in the design and layout of the proposed development. Developments will be required to sign up to the Environment Agency flood warning system. Details will be required on flood warning and emergency evacuation procedures as well as details regarding safe refuge areas above ground floor if dry egress routes for evacuation cannot be guaranteed. This should consider the safety of people within the building and also the safety of people around the building and in adjacent areas, including those who are less mobile. LLFA Consultation

It is recommended that potential developers contact the Environment Agency and Brent Council as the LLFA for further information prior to taking forward site specific plans. Site Specific FRA A Site Specific Flood Risk Assessment will be required which meets the requirements of the Flood Risk Assessment Submission Checklist in the Level 1 SFRA. The Site Specific FRA should be informed by modelling to assess the flood frequency, depth, velocity and speed of onset.

Summary

Based on the strategic assessment of flood risk and the recommendations for mitigation measures set out above, it is considered that proposed development on this site could be suitably designed to satisfy part 2 of the Exception Test subject to submission of a detailed Site Specific FRA.

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Site Name: Stadium Retail Park

& Fountain Studios

Site

Allocation

Ref.

BCSA2

Location: Wembley Park

Drive, HA9 8TS

Site Area

(ha):

1.67

Proposed Use: Residential and

commercial

Vulnerability

Classification:

More vulnerable

Fluvial flooding

Flood zone 2 Flood zone 3a Flood zone 3b

49% 0 0

The Wealdstone Brook runs 50 metres to the north of the site and is a source of fluvial flooding. The east of the site is within flood zone 2.

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Surface water flooding

Flood zone 3a 37%

Surface water ponding is

predicted in the centre of

the site during the 1 in 30-

year pluvial event or

greater. An overland flow

path is observed along the

surrounding road network.

The majority of the ground

coverage in the site is

impermeable as it is heavily

urbanised. This can

compound surface water

flooding as the runoff rate is

greater on impermeable

grounds compared to

permeable areas. In

addition, less water is able

to drain away through

infiltration, which increases

the surface water flood risk

in these areas.

The Environment Agency’s

surface water depth

modelling identifies the

potential for depths of 0 -

900mm on the site during

the 1% annual chance.

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Climate Change

Main River 35%

Climate Change

Surface Water 1 in

30yr

Surface

Water 1 in

100yr

(increase)

0 37% 24%

Geology and Groundwater

Groundwater susceptibility <25%

The site is underlain by Thames Group (also referred to as London Clay) bedrock, a composition of silty clay/mudstone, sandy silts and sandy

clayey silts of marine origin. Thames Group generally has a low hydraulic conductivity which means water does not easily move through it.

However, because of this characteristic and poor drainage, ponding can occur if London Clay is downhill of aquifer outcrops. The Environment

Agency identify the susceptibility of ground water flooding in this location as between 25 and 50%. The site is in a Critical Drainage Area and the

north eastern corner of the site has increased potential for elevated groundwater.

Other Sources

Sewer 77% site

Reservoir 0

Canal 0

Sewer flooding can occur due to sewer infrastructure failure or due to an increased flow and volume of water entering a sewer system which

exceeds its hydraulic capacity, causing the system to surcharge. If sewer outfall points are either blocked or submerged due to high water levels,

water can back up in a sewer system and cause flooding. These issues can result in water overflowing from gullies and drainage inspection holes,

causing flooding in the local area. The south of the borough has a combined sewer, leading to increased environmental risks where flooding

occurs. Thames Water Utilities Ltd provide surface water, foul and combined sewer systems in the borough.

Site Layout and Design

More vulnerable uses should be restricted to areas of lowest flood risk to the south west of the site. Lower vulnerability uses including landscaping

open space should be located to the east of the site.

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A positive reduction in the risk of flooding must be demonstrated as part of any development. It must be demonstrated that proposed development

does not result in an increase in maximum flood levels, within adjoining properties.

Surface Water

A drainage strategy will be required which accords with the Drainage Strategy Submission Checklist included in the Level 1 SFRA. The drainage

strategy for the site must be considered early in the site planning process to ensure adequate inclusion of Sustainable Drainage Systems (SuDS).

SuDS should aim to achieve greenfield run off rates, providing management and attenuation features that ensure that surface water runoff is

managed as close to the source as possible in accordance with the London Plan drainage hierarchy.

Permeable surfaces should be increased, and open space maximised to ensure space for water to flow during times of flood. Within flood zone 3a

(surface water), flood plain compensation must account for predicted flood depths for the 1 in 30yr and 1 in 100yr Risk of Flooding from Surface

Water mapping or depth predicted for the site.

Finished Floor Levels

If residential development cannot be avoided within the flood extent, finished floor levels should be set at least 300mm freeboard above the 1 in 100 flood level plus an appropriate allowance for climate change. Internal access to higher floors is required. It important to consider the implications of diverting the water on the flood risk of the rest of the site. Resilience and Resistant Measures

A number of flood resistance and resilience measures can also be implemented into new developments to mitigate potential flooding. These could include:

installing electrical equipment above flood level

installing flood doors and barriers, to ensure water stays out of a property to a given height

providing adequate flood risk management infrastructure. Space should be left in developments for flood risk management infrastructure to be maintained and enhanced.

Access/Egress

The east of the site is in an EA flood warning area. Safe dry access to and from the site should be provided for the lifetime of the property, factoring in the impacts of climate change. In this case the lifetime of the development is 100 years.

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Emergency Planning

Details will be required on the flood related risks that will remain once the proposed mitigation measures have been implemented, and how the risks will be managed over the development’s lifetime. Flood warnings and/ or flood alerts need to be considered along with the emergency evacuation procedures in the design and layout of the proposed development. Details will be required on flood warning and emergency evacuation procedures as well as details regarding safe refuge areas above ground floor if dry egress routes for evacuation cannot be guaranteed. This should consider the safety of people within the building and also the safety of people around the building and in adjacent areas, including those who are less mobile. LLFA Consultation

It is recommended that potential developers contact the Environment Agency and Brent Council as the LLFA for further information prior to taking forward site specific plans. Site Specific FRA A Site Specific Flood Risk Assessment will be required which meets the requirements of the Flood Risk Assessment Submission Checklist in the Level 1 SFRA. The FRA should be informed by EA data on flood depth, speed and direction.

Summary

Based on the strategic assessment of flood risk and the recommendations for mitigation measures set out above, it is considered that proposed development on this site could be suitably designed to satisfy part 2) of the Exception Test subject to submission of a detailed site specific FRA.

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SFRA Level 2 required due to surface water

Site Name: Turpin’s Yard Site Allocation Ref. BSESA31

Location: Oakland Road, NW2

6LL

Site Area (ha): 0.4

Proposed Use: Residential and

employment

Vulnerability

Classification:

More vulnerable

Fluvial flooding

Flood zone 2 Flood zone 3a Flood zone 3b

0 0 0

Surface water flooding

Flood zone 3a 25%

Surface water ponding is predicted on hard standing in the centre of the site during the 1 in 30-year pluvial event or greater. An overland flow

path is observed along the surrounding road network. Surface water flooding occurs as a result of high intensity rainfall when water is ponding

or flowing over the ground surface before it enters the underground drainage network or a watercourse. The majority of the ground coverage in

the site is impermeable car parking or storage. This area is subject to ponding.

The Environment Agency’s surface water depth modelling identifies the potential for depths of 0 - 900mm on the site during the 1% annual

chance.

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Climate Change

Main River 35% Climate

Change

Surface Water 1 in 30yr Surface Water 1 in

100yr (increase)

0 25% 10%

Surface water flooding will increase as a result of climate change.

Geology and Groundwater

Groundwater susceptibility 0

Other Sources

Sewer 87% site

Reservoir 0

Canal 0

Sewer flooding can occur due to sewer infrastructure failure or due to an increased flow and volume of water entering a sewer system which

exceeds its hydraulic capacity, causing the system to surcharge. If sewer outfall points are either blocked or submerged due to high water

levels, water can back up in a sewer system and cause flooding. These issues can result in water overflowing from gullies and drainage

inspection holes, causing flooding in the local area. The south of the borough has a combined sewer, leading to increased environmental risks

where flooding occurs. Thames Water Utilities Ltd provide surface water, foul and combined sewer systems in the borough. Thames Water hold

no records of incidents of sewer flooding on this site.

Site Layout and Design

More vulnerable uses such as residential development should be avoided in areas identified to be at risk of surface water flooding; instead

lower vulnerability uses including landscaped open space should be located here.

A positive reduction in the risk of flooding must be demonstrated and flood flow routes improved and not restricted. It must be demonstrated

that the proposed development does not result in an increase in maximum flood levels, within adjoining properties.

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Surface Water

A drainage strategy will be required which accords with the Drainage Strategy Submission Checklist included in the Level 1 SFRA. The

drainage strategy for the site must be considered early in the site planning process to ensure adequate inclusion of Sustainable Drainage

Systems (SuDS). SuDS should aim to achieve greenfield run off rates, providing management and attenuation features that ensure that surface

water runoff is managed as close to the source as possible in accordance with the London Plan drainage hierarchy.

Permeable surfaces should be increased, and open space maximised to ensure space for water to flow during times of flood. Within flood zone

3a (surface water), flood plain compensation must account for predicted flood depths for the 1 in 30yr and 1 in 100yr Risk of Flooding from

Surface Water mapping or depth predicted for the site.

Finished Floor Levels

If residential development cannot be avoided within the flood extent, finished floor levels should be set at least 300mm freeboard above the 1 in 100 flood level plus an appropriate allowance for climate change. Internal access to higher floors is required. It important to consider the implications of diverting the water on the flood risk of the rest of the site. Resilience and Resistant Measures

A number of flood resistance and resilience measures can also be implemented into new developments to mitigate potential flooding. These could include:

installing electrical equipment above flood level

installing flood doors and barriers, to ensure water stays out of a property to a given height

providing adequate flood risk management infrastructure. Space should be left in developments for flood risk management infrastructure to be maintained and enhanced.

Access/Egress

Safe dry access to and from the site should be provided for the lifetime of the property, factoring in the impacts of climate change. In this case the lifetime of the development is 100 years.

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63

Emergency Planning Details will be required on the flood related risks that will remain once the proposed mitigation measures have been implemented, and how the risks will be managed over the development’s lifetime. Flood warnings and/ or flood alerts need to be considered along with the emergency evacuation procedures in the design and layout of the proposed development. Details will be required on flood warning and emergency evacuation procedures as well as details regarding safe refuge areas above ground floor if dry egress routes for evacuation cannot be guaranteed. This should consider the safety of people within the building and also the safety of people around the building and in adjacent areas, including those who are less mobile. LLFA Consultation

It is recommended that potential developers contact Brent Council as the LLFA for further information prior to taking forward site specific plans. Site Specific FRA A Site Specific Flood Risk Assessment will be required which meets the requirements of the Flood Risk Assessment Submission Checklist in the Level 1 SFRA. The FRA should be informed by EA data on flood depth, speed and direction. Summary

Based on the strategic assessment of flood risk and the recommendations for mitigation measures set out above, it is considered that proposed development on this site could be suitably designed to satisfy part 2 of the Exception Test subject to submission of a detailed site specific FRA.

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Site Name: Park Avenue Garage Site Allocation Ref. BCSA25

Location: St Paul’s Avenue, NW2 5TG Site Area (ha): 0.23

Proposed Use: Residential Vulnerability

Classification:

More vulnerable

Fluvial flooding

Flood zone 2 Flood zone 3a Flood zone 3b

0 0 0

Surface water flooding

Flood zone 3a 25%

Surface water ponding is predicted on the western boundary and eastern corner of the site during the 1 in 30-year pluvial event or greater. An

overland flow path is observed along the surrounding road network The majority of the ground coverage in the site is impermeable as it is

heavily urbanised. This can compound surface water flooding as the runoff rate is greater on impermeable grounds compared to permeable

areas.

The Environment Agency’s surface water depth modelling identifies the potential for depths of 0 - 1200mm on the site during the 1% annual

chance.

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Climate Change

Main River 35% Climate

Change

Surface Water 1 in 30yr Surface Water 1 in 100yr

(increase)

0 25% 2%

Climate change is likely to result in a slight increase in surface water flooding on the site.

Geology and Groundwater

Groundwater susceptibility 0

Other Sources

Sewer 54% site

Reservoir 0

Canal 0

Sewer flooding can occur due to sewer infrastructure failure or due to an increased flow and volume of water entering a sewer system which

exceeds its hydraulic capacity, causing the system to surcharge. If sewer outfall points are either blocked or submerged due to high water

levels, water can back up in a sewer system and cause flooding. These issues can result in water overflowing from gullies and drainage

inspection holes, causing flooding in the local area. The south of the borough has a combined sewer, leading to increased environmental risks

where flooding occurs. Thames Water Utilities Ltd provide surface water, foul and combined sewer systems in the borough. Thames Water hold

no records of incidents of sewer flooding on this site.

Site Layout and Design

Residential development should be avoided in areas identified to be at risk of surface water flooding; instead lower vulnerability uses including

landscaped open space should be located here.

A positive reduction in the risk of flooding must be demonstrated and flood flow routes improved and not restricted. It must be demonstrated

that the proposed development does not result in an increase in maximum flood levels, within adjoining properties.

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Surface Water

A drainage strategy will be required which accords with the Drainage Strategy Submission Checklist included in the Level 1 SFRA. The

drainage strategy for the site must be considered early in the site planning process to ensure adequate inclusion of Sustainable Drainage

Systems (SuDS). SuDS should aim to achieve greenfield run off rates, providing management and attenuation features that ensure that surface

water runoff is managed as close to the source as possible in accordance with the London Plan drainage hierarchy.

Permeable surfaces should be increased, and open space maximised to ensure space for water to flow during times of flood. Within flood zone

3a (surface water), flood plain compensation must account for predicted flood depths for the 1 in 30yr and 1 in 100yr Risk of Flooding from

Surface Water mapping or depth predicted for the site.

Finished Floor Levels

If residential development cannot be avoided within the flood extent, finished floor levels should be set at least 300mm freeboard above the 1 in 100 flood level plus an appropriate allowance for climate change. Internal access to higher floors is required. It important to consider the implications of diverting the water on the flood risk of the rest of the site. Resilience and Resistant Measures A number of flood resistance and resilience measures can also be implemented into new developments to mitigate potential flooding. These could include:

installing electrical equipment above flood level

installing flood doors and barriers, to ensure water stays out of a property to a given height

providing adequate flood risk management infrastructure. Space should be left in developments for flood risk management infrastructure to be maintained and enhanced.

Access/Egress

Safe dry access to and from the site should be provided for the lifetime of the property, factoring in the impacts of climate change. In this case the lifetime of the property is 100 years.

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Emergency Planning

Details will be required on the flood related risks that will remain once the proposed mitigation measures have been implemented, and how the

risks will be managed over the development’s lifetime. Flood warnings and/ or flood alerts need to be considered along with the emergency

evacuation procedures in the design and layout of the proposed development.

Details will be required on flood warning and emergency evacuation procedures as well as details regarding safe refuge areas above ground floor if dry egress routes for evacuation cannot be guaranteed. This should consider the safety of people within the building and also the safety of people around the building and in adjacent areas, including those who are less mobile. LLFA Consultation

It is recommended that potential developers contact Brent Council as the LLFA for further information prior to taking forward site specific plans. Site Specific FRA A Site Specific Flood Risk Assessment will be required which meets the requirements of the Flood Risk Assessment Submission Checklist in the Level 1 SFRA. The Site Specific FRA should be informed by EA data on flood depth, speed and direction. Summary

Based on the strategic assessment of flood risk and the recommendations for mitigation measures set out above, it is considered that proposed development on this site could be suitably designed to satisfy part 2 of the Exception Test subject to submission of a detailed Site Specific FRA.

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Site Name: Hereford & Exeter Court Site Allocation Ref. BSESA8

Location: 1-124 Hereford House & 1-

32 Exeter Court Carlton Vale

Site Area (ha): 0.8

Proposed Use: Residential and open space Vulnerability

Classification:

More vulnerable

Fluvial flooding

Flood zone 2 Flood zone 3a Flood zone 3b

0 0 0

Surface water flooding

Flood zone 3a 36%

Surface water ponding is predicted on around the building footprint on impermeable surfaces such as car parking and the highway during the 1

in 30-year pluvial event or greater. The majority of the ground coverage in the site is impermeable as it is heavily urbanised. This can

compound surface water flooding as the runoff rate is greater on impermeable grounds compared to permeable areas. In addition, less water is

able to drain away through infiltration, which increases the surface water flood risk in these areas.

The Environment Agency’s surface water depth modelling identifies the potential for depths of 0 - 900mm on the site during the 1% annual

chance.

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Climate Change

Main River 35% Climate

Change

Surface Water 1 in 30yr Surface Water 1 in 100yr

(increase)

0 36% 17%

Climate change will increase surface water flooding on this site.

Geology and Groundwater

Groundwater susceptibility 0

Other Sources

Sewer 86% site

Reservoir 0

Canal 0

Sewer flooding can occur due to sewer infrastructure failure or due to an increased flow and volume of water entering a sewer system which

exceeds its hydraulic capacity, causing the system to surcharge. If sewer outfall points are either blocked or submerged due to high water

levels, water can back up in a sewer system and cause flooding. These issues can result in water overflowing from gullies and drainage

inspection holes, causing flooding in the local area. The south of the borough has a combined sewer, leading to increased environmental risks

where flooding occurs. Thames Water Utilities Ltd provide surface water, foul and combined sewer systems in the borough. Thames Water

have recorded instances of sewer flooding on the site.

Site Layout and Design

Lower vulnerability uses including landscaped open space should be directed to areas at risk of surface water flooding.

A positive reduction in the risk of flooding must be demonstrated and flood flow routes improved and not restricted. It must be demonstrated

that the proposed development does not result in an increase in maximum flood levels, within adjoining properties.

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Surface Water

A drainage strategy will be required which accords with the Drainage Strategy Submission Checklist included in the Level 1 SFRA. The

drainage strategy for the site must be considered early in the site planning process to ensure adequate inclusion of Sustainable Drainage

Systems (SuDS). SuDS should aim to achieve greenfield run off rates, providing management and attenuation features that ensure that surface

water runoff is managed as close to the source as possible in accordance with the London Plan drainage hierarchy.

Permeable surfaces should be increased, and open space maximised to ensure space for water to flow during times of flood. Within flood zone

3a (surface water), flood plain compensation must account for predicted flood depths for the 1 in 30yr and 1 in 100yr Risk of Flooding from

Surface Water mapping or depth predicted for the site.

Finished Floor Levels

If residential development cannot be avoided within the flood extent, finished floor levels should be set at least 300mm freeboard above the 1 in 100 flood level plus an appropriate allowance for climate change. Internal access to higher floors is required. It important to consider the implications of diverting the water on the flood risk of the rest of the site. Resilience and Resistant Measures A number of flood resistance and resilience measures can also be implemented into new developments to mitigate potential flooding. These could include:

installing electrical equipment above flood level

installing flood doors and barriers, to ensure water stays out of a property to a given height

providing adequate flood risk management infrastructure. Space should be left in developments for flood risk management infrastructure to be maintained and enhanced.

Access/Egress

Safe dry access to and from the site should be provided for the lifetime of the property, factoring in the impacts of climate change. In this case the lifetime of the property is 100 years.

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Emergency Planning

Details will be required on the flood related risks that will remain once the proposed mitigation measures have been implemented, and how the risks will be managed over the development’s lifetime. Flood warnings and/ or flood alerts need to be considered along with the emergency evacuation procedures in the design and layout of the proposed development. Details will be required on flood warning and emergency evacuation procedures as well as details regarding safe refuge areas above ground floor if dry egress routes for evacuation cannot be guaranteed. This should consider the safety of people within the building and also the safety of people around the building and in adjacent areas, including those who are less mobile. LLFA Consultation

It is recommended that potential developers contact Brent Council as the LLFA for further information prior to taking forward site specific plans. Site Specific FRA A Site Specific Flood Risk Assessment will be required which meets the requirements of the Flood Risk Assessment Submission Checklist in the Level 1 SFRA. The Site Specific FRA should be informed by EA data on flood depth, speed and direction. Summary

Based on the strategic assessment of flood risk and the recommendations for mitigation measures set out above, it is considered that proposed development on this site could be suitably designed to satisfy part 2 of the Exception Test subject to submission of a detailed Site Specific FRA.

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Site Name: Neasden Station Growth

Area 1

Site Allocation Ref. BEGA1

Location: Neasden Lane NW10 2UJ Site Area (ha): 0.73

Proposed Use: Residential and employment Vulnerability

Classification:

More vulnerable

Fluvial flooding

Flood zone 2 Flood zone 3a Flood zone 3b

0 0 0

Surface water flooding

Flood zone 3a 74%

Surface water ponding is predicted on large impermeable surface used as yard space during the 1 in 30-year pluvial event or greater. Exceptions

include areas of tree planting. This can compound surface water flooding as the runoff rate is greater on impermeable grounds compared to

permeable areas. In addition, less water is able to drain away through infiltration, which increases the surface water flood risk in these areas. An

overland flow path is observed along the railway line to the north.

The Environment Agency’s surface water depth modelling identifies the potential for depths of 0 - 900mm on the site during the 1% annual

chance.

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Climate Change

Main River 35% Climate

Change

Surface Water 1 in 30yr Surface Water 1 in

100yr

0 74% 44%

Surface water flooding will increase as a result of climate change.

Geology and Groundwater

Groundwater susceptibility 0

Other Sources

Sewer 92% site

Reservoir 0

Canal 0

Sewer flooding can occur due to sewer infrastructure failure or due to an increased flow and volume of water entering a sewer system which

exceeds its hydraulic capacity, causing the system to surcharge. If sewer outfall points are either blocked or submerged due to high water levels,

water can back up in a sewer system and cause flooding. These issues can result in water overflowing from gullies and drainage inspection

holes, causing flooding in the local area. The south of the borough has a combined sewer, leading to increased environmental risks where

flooding occurs. Thames Water Utilities Ltd provide surface water, foul and combined sewer systems in the borough.

Site Layout and Design

The site is proposed for mixed-use development. More vulnerable uses should be located on upper floors and less vulnerable uses at ground

floor. Open space and soft landscaping should be increased.

A positive reduction in the risk of flooding must be demonstrated and flood flow routes improved and not restricted. It must be demonstrated that

the proposed development does not result in an increase in maximum flood levels, within adjoining properties.

Surface Water

A drainage strategy will be required which accords with the Drainage Strategy Submission Checklist included in the Level 1 SFRA. The drainage

strategy for the site must be considered early in the site planning process to ensure adequate inclusion of Sustainable Drainage Systems

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(SuDS). SuDS should aim to achieve greenfield run off rates, providing management and attenuation features that ensure that surface water

runoff is managed as close to the source as possible in accordance with the London Plan drainage hierarchy.

Permeable surfaces should be increased, and open space maximised to ensure space for water to flow during times of flood. Within flood zone

3a (surface water), flood plain compensation must account for predicted flood depths for the 1 in 30yr and 1 in 100yr Risk of Flooding from

Surface Water mapping or depth predicted for the site.

Finished Floor Levels

If residential development cannot be avoided within the flood extent, finished floor levels should be set at least 300mm freeboard above the 1 in 100 flood level plus an appropriate allowance for climate change. Internal access to higher floors is required. It important to consider the implications of diverting the water on the flood risk of the rest of the site. Resilience and Resistant Measures A number of flood resistance and resilience measures can also be implemented into new developments to mitigate potential flooding. These could include:

installing electrical equipment above flood level

installing flood doors and barriers, to ensure water stays out of a property to a given height

providing adequate flood risk management infrastructure. Space should be left in developments for flood risk management infrastructure to be maintained and enhanced.

Access/Egress

Safe dry access to and from the site should be provided for the lifetime of the property, factoring in the impacts of climate change. In this case the lifetime of the property is 100 years. Emergency Planning

Details will be required on the flood related risks that will remain once the proposed mitigation measures have been implemented, and how the

risks will be managed over the development’s lifetime. Flood warnings and/ or flood alerts need to be considered along with the emergency

evacuation procedures in the design and layout of the proposed development.

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Details will be required on flood warning and emergency evacuation procedures as well as details regarding safe refuge areas above ground floor if dry egress routes for evacuation cannot be guaranteed. This should consider the safety of people within the building and also the safety of people around the building and in adjacent areas, including those who are less mobile. LLFA Consultation

It is recommended that potential developers contact Brent Council as the LLFA for further information prior to taking forward site specific plans. Site Specific FRA A Site Specific Flood Risk Assessment will be required which meets the requirements of the Flood Risk Assessment Submission Checklist in the

Level 1 SFRA. The Site Specific FRA should be informed by EA data on flood depth, speed and direction.

Summary

Based on the strategic assessment of flood risk and the recommendations for mitigation measures set out above, it is considered that proposed development on this site could be suitably designed to satisfy part 2 of the Exception Test subject to submission of a detailed Site Specific FRA.

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Site Name: Neasden Station Growth

Area 2

Site Allocation Ref. BEGA1

Location: Neasden Lane, NW10

2UG

Site Area (ha): 1.73

Proposed Use: Residential and

employment

Vulnerability

Classification:

More vulnerable

Fluvial flooding

Flood zone 2 Flood zone 3a Flood zone 3b

0 0 0

Surface water flooding

Flood zone 3a 52%

Surface water ponding is predicted on large expanses of imperable surface used as yard space during the 1 in 30-year pluvial event or greater.

This can compound surface water flooding as the runoff rate is greater on impermeable grounds compared to permeable areas. In addition, less

water is able to drain away through infiltration, which increases the surface water flood risk in these areas. An overland flow path is observed

along the railway line to the north.

The Environment Agency’s surface water depth modelling identifies the potential for depths of 0 - 1200mm on the site during the 1% annual

chance.

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Climate Change

Main River 35% Climate

Change

Surface Water 1 in 30yr Surface Water 1 in

100yr (increase)

0 52% 12%

Climate change will increase surface water flooding on the site.

Geology and Groundwater

Groundwater susceptibility 0

Other Sources

Sewer 62% site

Reservoir 0

Canal 0

Sewer flooding can occur due to sewer infrastructure failure or due to an increased flow and volume of water entering a sewer system which

exceeds its hydraulic capacity, causing the system to surcharge. If sewer outfall points are either blocked or submerged due to high water levels,

water can back up in a sewer system and cause flooding. These issues can result in water overflowing from gullies and drainage inspection holes,

causing flooding in the local area. The south of the borough has a combined sewer, leading to increased environmental risks where flooding

occurs. Thames Water Utilities Ltd provide surface water, foul and combined sewer systems in the borough.

Site Layout and Design

Mixed-use development is proposed on the site. More vulnerable uses should be located on upper floors and less vulnerable, such as

employment space, on ground floors. Open space and soft landscaping should be directed to areas of flood risk.

A positive reduction in the risk of flooding must be demonstrated and flood flow routes improved and not restricted. It must be demonstrated that

the proposed development does not result in an increase in maximum flood levels, within adjoining properties

Surface Water

A drainage strategy will be required which accords with the Drainage Strategy Submission Checklist included in the Level 1 SFRA. The drainage

strategy for the site must be considered early in the site planning process to ensure adequate inclusion of Sustainable Drainage Systems (SuDS).

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SuDS should aim to achieve greenfield run off rates, providing management and attenuation features that ensure that surface water runoff is

managed as close to the source as possible in accordance with the London Plan drainage hierarchy.

Permeable surfaces should be increased, and open space maximised to ensure space for water to flow during times of flood. Within flood zone 3a

(surface water), flood plain compensation must account for predicted flood depths for the 1 in 30yr and 1 in 100yr Risk of Flooding from Surface

Water mapping or depth predicted for the site.

Finished Floor Levels

If residential development cannot be avoided within the flood extent, finished floor levels should be set at least 300mm freeboard above the 1 in 100 flood level plus an appropriate allowance for climate change. Internal access to higher floors is required. It important to consider the implications of diverting the water on the flood risk of the rest of the site. Resilience and Resistant Measures

A number of flood resistance and resilience measures can also be implemented into new developments to mitigate potential flooding. These could include:

installing electrical equipment above flood level

installing flood doors and barriers, to ensure water stays out of a property to a given height

providing adequate flood risk management infrastructure. Space should be left in developments for flood risk management infrastructure to be maintained and enhanced.

Access/Egress

Safe dry access to and from the site should be provided for the lifetime of the property, factoring in the impacts of climate change. In this case the lifetime of the property is 100 years. Emergency Planning

Details will be required on the flood related risks that will remain once the proposed mitigation measures have been implemented, and how the risks will be managed over the development’s lifetime. Flood warnings and/ or flood alerts need to be considered along with the emergency evacuation procedures in the design and layout of the proposed development.

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Details will be required on flood warning and emergency evacuation procedures as well as details regarding safe refuge areas above ground floor if dry egress routes for evacuation cannot be guaranteed. This should consider the safety of people within the building and also the safety of people around the building and in adjacent areas, including those who are less mobile. LLFA Consultation

It is recommended that potential developers contact Brent Council as the LLFA for further information prior to taking forward site specific plans. Site Specific FRA A Site Specific Flood Risk Assessment will be required which meets the requirements of the Flood Risk Assessment Submission Checklist in the

Level 1 SFRA. The Site Specific FRA should be informed by EA data on flood depth, speed and direction.

Summary

Based on the strategic assessment of flood risk and the recommendations for mitigation measures set out above, it is considered that proposed development on this site could be suitably designed to satisfy part 2 of the Exception Test subject to submission of a detailed Site Specific FRA.

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Site Name: Neasden Station Growth Area

3

Site Allocation Ref. BEGA1

Location: Neasden Lane, NW10 2UE Site Area (ha): 0.28

Proposed Use: Residential and employment Vulnerability Classification: More vulnerable

Fluvial flooding

Flood zone 2 Flood zone 3a Flood zone 3b

0 0 0

Surface water flooding

Flood zone 3a 58%

Surface water ponding is predicted on hard standing in the south west of the site during the 1 in 30-year pluvial event or greater. An overland flow

path is observed along the surrounding road network. The majority of the site comprises impermeable surfaces with the exception of an area of

landscaping to the south. The adjacent railway lines can be a source of run off. This can compound surface water flooding as the runoff rate is

greater on impermeable grounds compared to permeable areas. In addition, less water is able to drain away through infiltration, which increases

the surface water flood risk in these areas.

The Environment Agency’s surface water depth modelling identifies the potential for depths of 0 - 1200mm on the site during the 1% annual

chance.

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Climate Change

Main River 35% Climate

Change

Surface Water 1 in 30yr Surface Water 1 in 100yr

(increase)

0 58% 41%

Climate change will result in a significant increase in surface water flooding on the site.

Geology and Groundwater

Groundwater susceptibility 0

Other Sources

Sewer 100% site

Reservoir 0

Canal 0

Sewer flooding can occur due to sewer infrastructure failure or due to an increased flow and volume of water entering a sewer system which

exceeds its hydraulic capacity, causing the system to surcharge. If sewer outfall points are either blocked or submerged due to high water levels,

water can back up in a sewer system and cause flooding. These issues can result in water overflowing from gullies and drainage inspection holes,

causing flooding in the local area. The south of the borough has a combined sewer, leading to increased environmental risks where flooding

occurs. Thames Water Utilities Ltd provide surface water, foul and combined sewer systems in the borough.

Site Layout and Design

More vulnerable uses should be located on upper floors and less vulnerable uses at ground floor. Open space and soft landscaping should be

located on areas of flood risk.

A positive reduction in the risk of flooding must be demonstrated and flood flow routes improved and not restricted. It must be demonstrated that

the proposed development does not result in an increase in maximum flood levels, within adjoining properties.

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Surface Water

A drainage strategy will be required which accords with the Drainage Strategy Submission Checklist included in the Level 1 SFRA. The drainage

strategy for the site must be considered early in the site planning process to ensure adequate inclusion of Sustainable Drainage Systems (SuDS).

SuDS should aim to achieve greenfield run off rates, providing management and attenuation features that ensure that surface water runoff is

managed as close to the source as possible in accordance with the London Plan drainage hierarchy.

Permeable surfaces should be increased, and open space maximised to ensure space for water to flow during times of flood. Within flood zone 3a

(surface water), flood plain compensation must account for predicted flood depths for the 1 in 30yr and 1 in 100yr Risk of Flooding from Surface

Water mapping or depth predicted for the site.

Finished Floor Levels

If residential development cannot be avoided within the flood extent, finished floor levels should be set at least 300mm freeboard above the 1 in 100 flood level plus an appropriate allowance for climate change. Internal access to higher floors is required. It important to consider the implications of diverting the water on the flood risk of the rest of the site. Resilience and Resistant Measures

A number of flood resistance and resilience measures can also be implemented into new developments to mitigate potential flooding. These could include:

installing electrical equipment above flood level

installing flood doors and barriers, to ensure water stays out of a property to a given height

providing adequate flood risk management infrastructure. Space should be left in developments for flood risk management infrastructure to be maintained and enhanced.

Access/Egress

Safe dry access to and from the site should be provided for the lifetime of the property, factoring in the impacts of climate change. In this case the lifetime of the property is 100 years. Emergency Planning

Details will be required on the flood related risks that will remain once the proposed mitigation measures have been implemented, and how the risks will be managed over the development’s lifetime. Flood warnings and/ or flood alerts need to be considered along with the emergency evacuation procedures in the design and layout of the proposed development.

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Details will be required on flood warning and emergency evacuation procedures as well as details regarding safe refuge areas above ground floor if dry egress routes for evacuation cannot be guaranteed. This should consider the safety of people within the building and also the safety of people around the building and in adjacent areas, including those who are less mobile. LLFA Consultation

It is recommended that potential developers contact Brent Council as the LLFA for further information prior to taking forward site specific plans. Site Specific FRA A Site Specific Flood Risk Assessment will be required which meets the requirements of the Flood Risk Assessment Submission Checklist in the Level 1 SFRA. The Site Specific FRA should be informed by EA data on flood depth, speed and direction.

Summary

Based on the strategic assessment of flood risk and the recommendations for mitigation measures set out above, it is considered that proposed development on this site could be suitably designed to satisfy part 2 of the Exception Test subject to submission of a detailed Site Specific FRA.

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Site Name: 438-444 Neasden

Lane & 1-24 Pit

House

Site

Allocation

Ref.

N/A intensification corridor

Location: Press Road, NW10

0DA

Site Area

(ha):

0.45

Proposed Use: Residential and

commercial

Vulnerability

Classification:

More vulnerable

Fluvial flooding

Flood zone 2 Flood zone 3a Flood zone 3b

0 0 0

Surface water flooding

Flood zone 3a 46%

Surface water ponding is predicted on land surrounding the buildings to the south of the site during the 1 in 30-year pluvial event or greater. An

overland flow path is observed along the surrounding road network. Surface water flooding occurs as a result of high intensity rainfall when water

is ponding or flowing over the ground surface before it enters the underground drainage network or a watercourse. Although the land surrounding

the properties is predominantly landscaped, the surrounding road network can compound surface water flooding as the runoff rate is greater on

impermeable grounds compared to permeable areas. In addition, less water is able to drain away through infiltration, which increases the surface

water flood risk in these areas.

The Environment Agency’s surface water depth modelling identifies the potential for depths of 0 - 300mm on the site during the 1% annual

chance.

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Climate Change

Main River 35%

Climate Change

Surface Water 1 in

30yr

Surface

Water 1 in

100yr

(increase)

0 46% 0

Geology and Groundwater

Groundwater susceptibility 25-50%

The site is underlain by Thames Group (also referred to as London Clay) bedrock, a composition of silty clay/mudstone, sandy silts and sandy

clayey silts of marine origin. Thames Group generally has a low hydraulic conductivity which means water does not easily move through it.

However, because of this characteristic and poor drainage, ponding can occur if London Clay is downhill of aquifer outcrops. The Environment

Agency identify the susceptibility of ground water flooding in this location as between 25 and 50%. The site is in a Critical Drainage Area.

Other Sources

Sewer 100% site

Reservoir 0

Canal 0

Sewer flooding can occur due to sewer infrastructure failure or due to an increased flow and volume of water entering a sewer system which

exceeds its hydraulic capacity, causing the system to surcharge. If sewer outfall points are either blocked or submerged due to high water levels,

water can back up in a sewer system and cause flooding. These issues can result in water overflowing from gullies and drainage inspection holes,

causing flooding in the local area. The south of the borough has a combined sewer, leading to increased environmental risks where flooding

occurs. Thames Water Utilities Ltd provide surface water, foul and combined sewer systems in the borough. They hold no records of historic

sewer flooding instances within this site as of 2017.

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Site Layout and Design

More vulnerable uses should be located on upper floors and less vulnerable uses at ground floor. Open space and soft landscaping should be

located on areas of flood risk.

A positive reduction in the risk of flooding must be demonstrated and flood flow routes improved and not restricted. It must be demonstrated that

the proposed development does not result in an increase in maximum flood levels, within adjoining properties.

Surface Water

A drainage strategy will be required which accords with the Drainage Strategy Submission Checklist included in the Level 1 SFRA. The drainage

strategy for the site must be considered early in the site planning process to ensure adequate inclusion of Sustainable Drainage Systems (SuDS).

SuDS should aim to achieve greenfield run off rates, providing management and attenuation features that ensure that surface water runoff is

managed as close to the source as possible in accordance with the London Plan drainage hierarchy.

Permeable surfaces should be increased, and open space maximised to ensure space for water to flow during times of flood. Within flood zone 3a

(surface water), flood plain compensation must account for predicted flood depths for the 1 in 30yr and 1 in 100yr Risk of Flooding from Surface

Water mapping or depth predicted for the site.

Finished Floor Levels

If residential development cannot be avoided within the flood extent, finished floor levels should be set at least 300mm freeboard above the 1 in 100 flood level plus an appropriate allowance for climate change. Internal access to higher floors is required. It important to consider the implications of diverting the water on the flood risk of the rest of the site. Resilience and Resistant Measures

A number of flood resistance and resilience measures can also be implemented into new developments to mitigate potential flooding. These could include:

installing electrical equipment above flood level

installing flood doors and barriers, to ensure water stays out of a property to a given height

providing adequate flood risk management infrastructure. Space should be left in developments for flood risk management infrastructure to be maintained and enhanced.

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Access/Egress

Safe dry access to and from the site should be provided for the lifetime of the property, factoring in the impacts of climate change. In this case the

lifetime of the development is 100 years.

Emergency Planning

Details will be required on the flood related risks that will remain once the proposed mitigation measures have been implemented, and how the risks will be managed over the development’s lifetime. Flood warnings and/ or flood alerts need to be considered along with the emergency evacuation procedures in the design and layout of the proposed development. Details will be required on flood warning and emergency evacuation procedures as well as details regarding safe refuge areas above ground floor if dry egress routes for evacuation cannot be guaranteed. This should consider the safety of people within the building and also the safety of people around the building and in adjacent areas, including those who are less mobile. LLFA Consultation

It is recommended that potential developers contact Brent Council as the LLFA for further information prior to taking forward site specific plans. Site Specific FRA A Site Specific Flood Risk Assessment will be required which meets the requirements of the Flood Risk Assessment Submission Checklist in the Level 1 SFRA. The Site Specific FRA should be informed by EA data on flood depth, speed and direction.

Summary

Based on the strategic assessment of flood risk and the recommendations for mitigation measures set out above, it is considered that proposed development on this site could be suitably designed to satisfy part 2) of the Exception Test subject to submission of a detailed site specific FRA.

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Site Name: Queensbury LSIS and Morrisons

Site Allocation Ref. BNSA3

Location: Honey Pot Lane, NW9 Site Area (ha): 8.24

Proposed Use: Residential and commercial Vulnerability Classification: More vulnerable

Fluvial flooding

Flood zone 2 Flood zone 3a Flood zone 3b

15% 0 0

The Wealdstone Brook runs through the south of the site in a culvert and is a source of flooding. The majority of the site has a low probability of fluvial flooding. However, low lying areas adjoining the Wealdstone Brook are at risk of flooding and within flood zone 2.

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Surface water flooding

Flood zone 3a 14%

Surface water ponding is predicted on the highway during the 1 in 30-year pluvial event or greater. An overland flow path is observed along the surrounding road network. The majority of the ground coverage in the site is impermeable, comprising a large expanse of car parking and industrial units. This can compound surface water flooding as the runoff rate is greater on impermeable grounds compared to permeable areas. In addition, less water is able to drain away through infiltration, which increases the surface water flood risk in these areas. The Environment Agency’s surface water depth modelling identifies the potential for depths of 0 - 900mm on the site during the 1% annual chance.

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Climate Change

Main River 35% Climate Change Surface Water 1 in 30yr Surface Water 1 in 100yr (increase)

0 14% 7%

Geology and Groundwater

Groundwater susceptibility <25%

The site is underlain by Thames Group (also referred to as London Clay) bedrock, a composition of silty clay/mudstone, sandy silts and sandy clayey silts of marine origin. Thames Group generally has a low hydraulic conductivity which means water does not easily move through it. However, because of this characteristic and poor drainage, ponding can occur if London Clay is downhill of aquifer outcrops. The Environment Agency identify the susceptibility of ground water flooding in this location as between 25 and 50%. The site is within a Critical Drainage Area.

Other Sources

Sewer 74% site

Reservoir 0

Canal 0

Sewer flooding can occur due to sewer infrastructure failure or due to an increased flow and volume of water entering a sewer system which exceeds its hydraulic capacity, causing the system to surcharge. If sewer outfall points are either blocked or submerged due to high water levels, water can back up in a sewer system and cause flooding. These issues can result in water overflowing from gullies and drainage inspection holes, causing flooding in the local area. The south of the borough has a combined sewer, leading to increased environmental risks where flooding occurs. Thames Water Utilities Ltd provide surface water, foul and combined sewer systems in the borough. Thames Water have recorded incidents of sewer flooding in the south western corner of the site.

Site Layout and Design Vulnerable uses should be restricted to areas of lowest flood risk. Residential development should be avoided to the south defined as Flood Zone 2, and in areas identified to be at risk of surface water flooding; instead lower vulnerability uses including landscaped open space should be located here. Overland flow paths should not be obstructed. Subject to the recommendations of the Site Specific FRA, development should seek to deculvert and naturalise the Wealdstone Brook. A positive reduction in the risk of flooding must be demonstrated and flood flow routes improved and not restricted. It must be demonstrated that the proposed development does not result in an increase in maximum flood levels, within adjoining properties.

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Surface Water A drainage strategy will be required which accords with the Drainage Strategy Submission Checklist included in the Level 1 SFRA. The drainage strategy for the site must be considered early in the site planning process to ensure adequate inclusion of Sustainable Drainage Systems (SuDS). SuDS should aim to achieve greenfield run off rates, providing management and attenuation features that ensure that surface water runoff is managed as close to the source as possible in accordance with the London Plan drainage hierarchy. Permeable surfaces should be increased, and open space maximised to ensure space for water to flow during times of flood. Within flood zone 3a (surface water), flood plain compensation must account for predicted flood depths for the 1 in 30yr and 1 in 100yr Risk of Flooding from Surface Water mapping or depth predicted for the site. Set-back Distance An 8m wide undeveloped buffer strip should be retained along the Wealdstone Brook to provide access for maintenance. The EA should be contacted to obtain an Environmental Permit for main rivers, further information can be found on their website: www.gov.uk/guidance/flood-risk-activities-environmental-permits Finished Floor Levels If residential development cannot be avoided within the flood extent, finished floor levels should be set at least 600mm freeboard above the 1 in 100 flood level plus an appropriate allowance for climate change. Internal access to higher floors is required. It important to consider the implications of diverting the water on the flood risk of the rest of the site. Resilience and Resistant Measures A number of flood resistance and resilience measures can also be implemented into new developments to mitigate potential flooding. These could include:

installing electrical equipment above flood level installing flood doors and barriers, to ensure water stays out of a property to a given height providing adequate flood risk management infrastructure. Space should be left in developments for flood risk management infrastructure to be maintained and enhanced.

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Access/Egress Safe dry access to and from the site should be provided for the lifetime of the property, factoring in the impacts of climate change. In this case the lifetime of the development is 100 years. Emergency Planning The south of the site is within a flood alert area. Details will be required on the flood related risks that will remain once the proposed mitigation measures have been implemented, and how the risks will be managed over the development’s lifetime. Flood warnings and/ or flood alerts need to be considered along with the emergency evacuation procedures in the design and layout of the proposed development. Details will be required on flood warning and emergency evacuation procedures as well as details regarding safe refuge areas above ground floor if dry egress routes for evacuation cannot be guaranteed. This should consider the safety of people within the building and also the safety of people around the building and in adjacent areas, including those who are less mobile. LLFA Consultation It is recommended that potential developers contact the Environment Agency and Brent Council as the LLFA for further information prior to taking forward site specific plans. A Site Specific FRA will be required which meets the requirements of the Flood Risk Assessment Submission Checklist in the Level 1 SFRA. The FRA should be informed by modelling to assess the flood extent, depth and speed. Site Specific FRA A Site Specific Flood Risk Assessment will be required which meets the requirements of the Flood Risk Assessment Submission Checklist in the Level 1 SFRA. The Site Specific FRA should be informed by EA data on flood depth, speed and direction.

Summary

Based on the strategic assessment of flood risk and the recommendations for mitigation measures set out above, it is considered that proposed development on this site could be suitably designed to satisfy part 2 of the Exception Test subject to submission of a detailed Site Specific FRA.

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Appendix A – Screening Assessment Site Allocations P

olic

y N

o.

Site

Nam

e

Pro

po

sed

Use

Vu

lne

rab

ility

Cla

ssif

icat

ion

Site

Are

a (s

qm

)

FZ2

(%

of

site

are

a)

FZ3

a (F

luvi

al &

Tid

al -

% o

f si

te

are

a)

FZ3

b (

Flu

vial

& T

idal

- %

of

site

are

a)

Mai

n R

ive

r 3

5%

CC

(%

of

site

are

a)

FZ3

a (S

urf

ace

Wat

er -

% o

f si

te

are

a)

1 in

30

yr R

oFS

W E

xten

t (%

of

site

ar

ea)

Surf

ace

Wat

er F

loo

d R

isk

Incr

eas

e d

ue

to

Clim

ate

Ch

ange

Gro

un

dw

ate

r Su

sce

pti

bili

ty

Ban

din

g

Sew

er

Flo

od

ing?

Re

serv

oir

Flo

od

ing?

Seq

ue

nti

al T

est

Re

qu

ire

d?

Exce

pti

on

Te

st R

eq

uir

ed

?

Leve

l 2 S

FRA

Rec

om

me

nd

ed?

BCSA1 The Torch/ Kwikfit Mixed-use

More vulnerable 3823

< 25% 100% No No No

BCSA1 ASDA Wembley Mixed-use More vulnerable 30794 6% 6% 2%

< 25% 89% Yes Yes No

BCSA2

Stadium Retail Park (Fulton Quarter) Mixed-use

More vulnerable 16771 49% 37% 37% 24%

< 25% 77% Yes Yes Yes

BCSA3 Brook Avenue (south) Mixed-use

More vulnerable 4020 1% 2% 2% 2% 7% 7% 3%

< 25% 76% Yes Yes No

BCSA3 Brook Avenue (north) Mixed-use

More vulnerable 14997 82% 68% 6% 79% 80% 80% 25%

< 25% 100% Yes Yes Yes

BCSA4 Fifth Way/ Euro Car Parts Mixed-use

More vulnerable 12909 1% 1%

< 25% 77% Yes Yes No

BCSA5 Olympic Office Centre Mixed-use

More vulnerable 4467 3% 3%

< 25% 100% Yes Yes No

BCSA6 Watkin Road Mixed-use More vulnerable 14098 88% 17% 70% 18% 18% 10%

< 25% 97% Yes Yes Yes

BCSA7 Wembley Park Station (North) Mixed-use

More vulnerable 6989

< 25% 54% No No No

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BCSA7 Wembley Park Station (South) Mixed-use

More vulnerable 7024 4% 4%

< 25% 55% Yes Yes No

BCSA8 Wembley Retail Park Mixed-use

More vulnerable 50698 11% 11% 6%

< 25% 78% Yes Yes No

BCSA9 First Way Mixed-use More vulnerable 44420 2% 2% 1%

< 25% 93% Yes Yes No

BCSA10 York House School and employment

More vulnerable 7911

< 25% 89% No No No

BCSA11

College of North West London Wembley Mixed-use

More vulnerable 3740 79% 17% 16% 68% 68% 68% 36%

< 25% 21% Yes Yes Yes

BCSA12 Land to South of South Way Mixed-use

More vulnerable 16520 2% 2%

< 25% 58% Yes Yes No

BCSA13

Former Malcolm House, Empire Way Mixed-use

More vulnerable 2152

< 25% 80% No No No

BCSA14 St Josephs Social Club Mixed-use

More vulnerable 3740 41% No No No

BCSA15

Site W10 Wembley Masterplan Mixed-use

More vulnerable 5752

< 25% No No No

BCSA17

Southway Motors/Fourway Supplies/ Midnight Motors, South Way Mixed-use

More vulnerable 3372

< 25% 82% No No No

BEGA1

Neasden Stations Growth Area Mixed-use

More vulnerable 41456 1% 1% 51% Yes Yes No

BEGA1

Neasden Stations Growth Area Mixed-use

More vulnerable 16233 4% 4% 2% 100% Yes Yes No

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BEGA1 Neasden Station Growth Area 1 Mixed-use

More vulnerable 7316 74% 74% 44% 92% Yes Yes Yes

BEGA1 Neasden Station Growth Area 2 Mixed-use

More vulnerable 17308 52% 52% 12% 62% Yes Yes Yes

BEGA1 Neasden Station Growth Area 3 Mixed-use

More vulnerable 2278 58% 58% 41% 100% Yes Yes Yes

BEGA1

Neasden Stations Growth Area Mixed-use

More vulnerable 26578 5% 5% 2% 79% Yes Yes No

BEGA1

Neasden Stations Growth Area Mixed-use

More vulnerable 6668 14% 14% 3% 75% Yes Yes No

BEGA2 Staples Corner Growth Area Mixed-use

More vulnerable 427236 1% 1% 1%

>= 25% <50% 80% Yes Yes No

BESA1 Coombe Road Mixed-use More vulnerable 13546 100% 26% 1% 100%

>= 25% <50% 94% Yes Yes Yes

BESA2 Cricklewood Bus Garage Mixed-use

More vulnerable 15131 5% 5% 2% 58% Yes Yes No

BESA3 Gower House Blackbird Hill Mixed-use

More vulnerable 2310

>= 25% <50% 100% No No No

BESA4

4-9 Gladstone Parade, Edgware Road Mixed-use

More vulnerable 1727 12% 12% 87% Yes Yes No

BNSA1 Capitol Way Valley Mixed-use

More vulnerable 126121 6% 6% 2%

< 25% 85% Yes Yes No

BNSA2

Colindale Retail Park, Multi-Storey Car Park, Car Showroom Mixed-use

More vulnerable 40285

< 25% 81% No No No

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and Southon House

BNSA3 Queensbury LSIS and Morrisons Mixed-use

More vulnerable 82380 15% 14% 14% 7%

< 25% 74% Yes Yes Yes

BNSA4 Former Mecca Bingo Site Mixed-use

More vulnerable 1667

< 25% 74% No No No

BNSA5

Kingsbury Library and Community Centre Mixed-use

More vulnerable 5360

< 25% 52% No No No

BNSA6 Ex-Volkswagen Garage Residential

More vulnerable 3511

< 25% 76% No No No

BNSA7

Kingsbury Trade Centre - Enterprise, Hand Car Wash, Printers Mixed-use

More vulnerable 1870 100% No No No

BNWGA1 Northwick Park Growth Area Mixed-use

More vulnerable 305159 3% 3% 1% 47% Yes Yes No

BNWSA1

Kenton Road Sainsbury's and adjoining land Mixed-use

More vulnerable 24461 1% 1%

< 25% 100% Yes Yes No

BSESA1 Austen Mixed-use More vulnerable 2605 19% 19% 4% 53% Yes Yes No

BSESA2 Blake Mixed-use More vulnerable 6806 12% 12% 4% 78% Yes Yes No

BSESA3 Carlton House Mixed-use More vulnerable 2942 53% No No No

BSESA4 Carlton Infant School Residential

More vulnerable 4144 6% 6% 3% 100% Yes Yes No

BSESA5 Craik Residential More vulnerable 2720 54% No No No

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BSESA6 Crone & Zangwill Residential

More vulnerable 5151 4% 4% 66% Yes Yes No

BSESA7 Dickens Residential More vulnerable 4161 12% 12% 2% 67% Yes Yes No

BSESA8 Hereford House & Exeter Mixed-use

More vulnerable 8974 36% 36% 17% 86% Yes Yes Yes

BSESA9 Kilburn Park Junior School Open space

Water compatible 4662 73% No No No

BSESA10 Neville & Winterleys Residential

More vulnerable 3468 100% No No No

BSESA11 Old Granville Open Space Mixed-use

More vulnerable 2247 8% 8% 100% Yes Yes No

BSESA12 Wordsworth & Masefield Mixed-use

More vulnerable 5627 70% No No No

BSESA13 John Ratcliffe House Mixed-use

More vulnerable 1161 100% No No No

BSESA14

William Dunbar & William Saville House Residential

More vulnerable 6442 85% No No No

BSESA15

UK Albanian Muslim Community and Cultural Centre Mixed-use

More vulnerable 607 98% No No No

BSESA16 OK Club Mixed-use More vulnerable 1660 42% No No No

BSESA17

Cricklewood Broadway Retail Park Mixed-use

More vulnerable 23198 13% 13% 2% 96% Yes Yes No

BSESA18

245 - 289 Cricklewood Broadway Mixed-use

More vulnerable 5743 96% No No No

BSESA19 Gaumont State Cinema Community

Less vulnerable 6786 63% No No No

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BSESA20 Kilburn Square Mixed-use More vulnerable 11013 92% No No No

BSESA21

Willesden Green Sainsbury's and garages Mixed-use

More vulnerable 12472 2% 2% 81% Yes Yes No

BSESA22 Queen's Parade Mixed-use More vulnerable 632 100% No No No

BSESA23

Former Willesden Green police station Mixed-use

More vulnerable 1380 98% No No No

BSESA24 Kilburn Station arches Employment

Less vulnerable 551 100% No No No

BSESA25 Park Avenue Garage Mixed-use

More vulnerable 2347 25% 25% 2% 54% Yes Yes Yes

BSESA26

Park Avenue North Substation Residential

More vulnerable 3434 2% 2% 85% Yes Yes No

BSESA27 Car wash Strode Road Residential

More vulnerable 627 100% No No No

BSESA28 80 Strode Road Residential More vulnerable 1839 71% No No No

BSESA29

Willesden Telephone Exchange Mixed-use

More vulnerable 2832 5% 5% 2% 90% Yes Yes No

BSESA30 61-65 Shoot up Hill Mixed-use

More vulnerable 2935 100% No No No

BSESA31 Turpin's Yard Mixed-use More vulnerable 3773 25% 25% 10% 87% Yes Yes Yes

BSESA32

45 - 54 Cricklewood Broadway Mixed-use

More vulnerable 786 100% No No No

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BSESA33

123 - 129 Cricklewood Broadway Mixed-use

More vulnerable 680 100% No No No

BSESA34

Kilburn Park Underground Station Mixed-use

More vulnerable 947 5% 5% 3% 97% Yes Yes No

BSESA35

303 - 309 Cricklewood Broadway Mixed-use

More vulnerable 2701 100% No No No

BSSA1 Asiatic Carpets Mixed-use More vulnerable 34713 1% 1% 1% 86% Yes Yes No

BSSA2

B&M Home Store & Cobbold Industrial Estate Mixed-use

More vulnerable 29997 3% 3% 90% Yes Yes No

BSSA3 Church End Local Centre Mixed-use

More vulnerable 9720 1% 1% 78% Yes Yes No

BSSA4

Chapman's and Sapcote Industrial Estate Mixed-use

More vulnerable 31425 16% 16% 93% Yes Yes No

BSSA5 Willesden Bus Depot Mixed-use

More vulnerable 9653 85% No No No

BSSA6

Argenta House & Wembley Point Mixed-use

More vulnerable 12203 100% 99% 72% 100% 36% 36% 20%

>= 25% <50% 87% Yes Yes Yes

BSSA7 Bridge Park & Unisys Mixed-use

More vulnerable 27199 100% 100% 100% 15% 15% 4%

>= 25% <50% 57% Yes Yes Yes

BSSA8 McGovern's Yard Mixed-use

More vulnerable 3695 83% No No No

BSSA9 Barry's Garage Mixed-use More vulnerable 5558 3% 3% 2% 90% Yes Yes No

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BSSA10

Dudden Hill Community Centre Mixed-use

More vulnerable 1974 2% 2% 53% Yes Yes No

BSSA11 Euro car rental Residential More vulnerable 4518 16% 16%

>= 25% <50% 98% Yes Yes No

BSSA12 296-300 High Road Mixed-use

More vulnerable 898 100% No No No

BSSA13

Learie Constantine Centre Mixed-use

More vulnerable 318 100% No No No

BSSA14 Morland Gardens Residential

More vulnerable 3026

< 25% 79% No No No

BSSA15 Harlesden Station junction Mixed-use

More vulnerable 665 13% 13% 12%

< 25% 100% Yes Yes No

BSSA16 Mordaunt Road Mixed-use More vulnerable 1103

< 25% 96% No No No

BSSA17

Harlesden Railway Generating Station Employment

Less vulnerable 1601 6% 6%

< 25% 25% Yes Yes No

BSSA18

Harlesden Telephone Exchange Mixed-use

More vulnerable 3958 10% 10% 5% 76% Yes Yes No

BSSA19 Chancel House School More vulnerable 7998 11% 11% 4% 100% Yes Yes No

Harlesden NP

Car sales at junction of High Street and Furness Road Mixed-use

More vulnerable 835 100% No No No

Harlesden NP

Land at Challenge Close Mixed-use

More vulnerable 1964 100% No No No

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Harlesden NP Harley Road Mixed-use

More vulnerable 868 89% No No No

Harlesden NP

Former Willesden Ambulance Station Mixed-use

More vulnerable 772 No No No

Harlesden NP

Salvation Army Hall & Manor Park Works Mixed-use

More vulnerable 1910 2% 2% 100% Yes Yes No

Harlesden NP Harlesden Plaza Mixed-use

More vulnerable 9293 95% No No No

BSWSA1 Alperton Industrial Sites Mixed-use

More vulnerable 14520

>= 25% <50% 43% No No No

BSWSA1 Alperton Industrial Sites Mixed-use

More vulnerable 21854 1% 1% 1%

< 25% 98% Yes Yes No

BSWSA1 Alperton Industrial Sites Mixed-use

More vulnerable 17533 3% 3% 3%

>= 25% <50% 90% Yes Yes No

BSWSA2 Sainsbury's Alperton Mixed-use

More vulnerable 30688 1% 1%

>= 25% <50% 66% Yes Yes No

BSWSA3 Atlip Road Mixed-use More vulnerable 12374 7% 7%

>= 25% <50% 59% Yes Yes No

BSWSA4 Sunleigh Road Mixed-use More vulnerable 19028

>= 25% <50% 83% No No No

BSWSA5 Abbey Industrial Estate Mixed-use

More vulnerable 26317 1% 1%

>= 25% <50% 94% Yes Yes No

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BSWSA6 Beresford Avenue Mixed-use

More vulnerable 9585 8% 8% 1%

>= 25% <50% 68% Yes Yes No

BSWSA7 Northfields Mixed-use More vulnerable 91644 20% 1% 1% 8% 6% 6% 6%

>= 25% <50% Yes Yes No

BSWSA8 Wembley High Road Mixed-use

More vulnerable 30088 99% No No No

BSWSA9 Former Copland School Mixed-use

More vulnerable 8401 2% 2% 2% 73% Yes Yes No

BSWSA10 Elm Road Mixed-use More vulnerable 29818 5% 3% 86% Yes Yes No

BSWSA11

Wembley Cutting North, Mostyn Avenue Residential

More vulnerable 1242 100% No No No

BSWSA12

Keelers Service Centre, Harrow Road, Wembley Mixed-use

More vulnerable 733 3% 3% 96% Yes Yes No

BSWSA13

Wembley Police & Fire Stations and Wembley Community Hospital Mixed-use

More vulnerable 38943 1% 1% 91% No No No

BSWSA14 Sudbury Town Station car park Residential

More vulnerable 2149 100% No No No

BSWSA15

Employment Land on Heather Park Drive Mixed-use

More vulnerable 5477 2% 2%

>= 25% <50% 85% Yes Yes No

BSWSA16

Carphone Warehouse 416 Ealing Road Mixed-use

More vulnerable 4995 1% 1%

>= 25% <50% 67% Yes Yes No

BSWSA17 Former Wembley Youth Mixed-use

More vulnerable 9619 2% 2%

< 25% 97% Yes Yes No

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Centre/ Dennis Jackson Centre London Road

N1 Kingsbury Town Centre Sites Mixed-use

More vulnerable 15632 3% 3% 1% 78% Yes Yes No


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