site specific allocations pps25 sequential test - brent sequential … · 1.2. the sequential test...

Final Brent Sequential Test Flood Risk Report 1 03/01/2008

Site Specific Allocations PPS25 Sequential Test FINAL VERSION

Summary The following section sets out Brent’s approach to fulfilling the requirements of Planning Policy Statement

25 when allocating land in the Site Specific Allocations document. The first section analyses the flood risk at

all sites (based upon the delineated flood zone within which the site falls), and PPS25 applied to identify the

planning constraints posed as a result of flood risk. This analysis is contained in the attached spreadsheet and

illustrates that relatively few of the sites allocated for development are affected by flood risk. Of those, two

were identified at preferred options stage which would require the application of the exception test and

therefore a level 2 SFRA.

Five sites were added at submission stage following representations submitted as part of public consultation.

One site, SSA 113, Wembley Point, fell wholly within flood zones 2 and 3, according to the Level 1 SFRA

therefore in order to develop this site the sequential test, exception test and a Level 2 SFRA required to

inform this would need to be undertaken and satisfied.

1. Sequential Test

1.1. In accordance with the provisions of PPS25, the Council has applied the sequential test to all of the

sites allocated in Brent’s Site Allocations DPD Preferred Options document. The Council has also

undertaken the sequential test for the new sites allocated as a result of the consultation on the

Preferred Options version of this document. A table has been produced which illustrates the flood risk

associated with each site allocation and the corresponding appropriate land use - see Annex B. The

table highlights the highest flood risk affecting any site. The majority of sites allocated are not

affected by fluvial flood risk zones 2 or 3.

1.2. The sequential test was undertaken using the flow chart at Figure 3.1 in the draft Practice Guide

Companion to PPS25, and PPS25 Land Use Vulnerability Classifications attached for reference at

Annex A. 9 sites out of the 70 allocations are affected by flood risk areas to some degree. The

sequential test shows that for 7 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 2 of these sites,

SSA 7 (Unisys, Wembley) and SSA 37 (Durkin Storage, North End Road) require the undertaking of an

exception test and a level 2 SFRA to inform this test.

1.3. All sites affected by flood risk from the Preferred Options stage are analysed in detail at section 2.

1.4. Following public consultation on the Preferred Options site allocations a further 5 sites were included

within the Submission Version of the SSA DPD. The sequential test has been applied to these sites

and the results can also be found at annex B. 1 site, site 113 (Wembley Point) is wholly affected by

flood zones 2, 3a and 3b. Therefore it was anticipated that an exception test would need to be

undertaken, and to inform the application of this test, a level 2 SFRA will need to be carried out. The

site allocation text refers to development on this site being subject to the undertaking of the

sequential test and level 2 SFRA to inform the application of the exception test. As mentioned above,

the sequential test has been undertaken and this indicates that an exception test would need to be

completed subject to the results of the level 2 assessment.


2. Detailed Assessments of Site Allocations affected by Flood Risk Zones 2 and 3

2.1. The following section contains detailed assessments of the sites affected by flood risk zones 2 and 3 as

identified by our consultants Jacobs as part of the SFRA and application of the sequential test. The

following sheets have almost all been extracted directly from the SFRA document.

SSA 3 – Twyford Tip

Site Information Proposed Land Use: Redevelopment for waste management / transfer / processing facility / energy

generation and subsidiary industrial employment development.

PPS25 Vulnerability Classification: Less Vulnerable – proposals wouldn’t include landfill/hazardous waste

Sequential Test: Intended use is suitable.

Area of Site (Ha):

5.3

Overview of Flood Risks

• Majority of the Site is in Low Probability Flood Risk Zone.

• Some low lying areas fall into High and Medium Probability Flood Risk Zones.

• Source of Flooding – River Brent

• There is an unnamed drain within the site which could bring maintenance issues and increase flood risk.

• Hard surfaces of the new development could increase runoff to the water courses.

Planning Issues

Potential Minerals and Waste Site

EA FZ Map 0.1% AEP

Modelled Flood Outline 1% AEP

Key: Modelled Flood

Outline 5% AEP

Site Specific

Allocation High Probability

Zone 3a

Medium Probability

Zone 2

Climate Change

Zone 3a

Key:

Functional Floodplain

Zone 3b


• The Site appears suitable for intended use provided contamination issues are addressed.

• A buffer zone between top of the bank and the development should be allowed. The Environment Agency would require an 8m wide strip.

• Encroachment into functional flood plain will not be permitted.

Flood Risk Assessment Requirements Developers should submit a site specific flood risk assessment which includes following:

• Flood Risk should be minimised at the design stage ensuring that the proposed layout and form does not include any buildings or structures

within identified high risk areas.

• Threshold floor levels should be above predicted 1 in 100 year flood levels plus an allowance for climate change.

• SUDS should be required to limit runoff to that of undeveloped and natural land.

• Overland flow paths should not be obstructed by buildings.

• Flood storage should not be displaced and compensated if lost.

• Safe dry access and egress should be provided.

SSA 7 - Unisys

Site Information Proposed Land Use: Comprehensive mixed use development including community uses,

environmentally sensitive B1 uses, sport and recreation and residential

development.

PPS25 Vulnerability Classification: Mixed uses may vary from Water compatible, Less Vulnerable to More

Vulnerable


EA FZ Map 0.1% AEP


Key: Modelled Flood

Outline 5% AEP

Site Specific


Zone 3a

Medium Probability

Zone 2

Climate Change

Zone 3a

Key:


Zone 3b

113


Sequential Test: Intended uses are not suitable.

Only water Compatible uses are appropriate in this zone 3b.

Essential Infrastructure require an Exception Test

Area of Site (Ha):

2.85


• Site lies in the Functional Flood Plain.


• Frequent flooding of the site could be possible as it is within the flood plain with 1 in 20 annual probability of flooding.

Planning Recommendations

• The area that lies in the functional flood plain should be guarded against future development. In this area only water compatible uses and

Essential Infrastructure (subject to an Exception Test) should be allowed.

• It is recommended to carry out a Level 2 SFRA for this Site in which detailed nature of the flood hazard at the Site should be considered:

The Level 2 SFRA should look at:

o flood probability

o flood depth

o flood velocity

o rate of onset of flooding

o existence of flood defences/residual risk

The output of a Level 2 SFRA should include an appraisal of current conditions of flood defence infrastructure and their probability and consequence

of overtopping or failure, maps showing distribution of flood risk across the site, guidance on satisfying the Exception Test and guidance on the

preparation of a site specific FRA.

A more detailed Site Specific Flood Risk Assessment should be submitted by the developers in which:

• Detailed modelling to assess the risk of flooding from the River Brent is carried out

• An assessment of flood extent, depth and speed will be carried out

• An assessment whether the existing buildings are permeable to flood waters

• The design would ensure new developments will not displace flood storage and obstruct flow routes

• Design the Site sequentially moving new developments away from high risk areas

• Section C of the Exception Test will be met (safe dry access and egress should be provided)

• SUDS will be implemented

Flood Risk Assessment Requirements • Encroachment into the functional flood plain should not be allowed when designing the layout and form of the structures. Development

should be steered to low risk areas of the Site following a sequential design approach.

• 8m buffer zone should be provided.

• Loss of flood plain storage due to new development should be compensated.

• Flow routes should not be obstructed.

• SUDS should be implemented.



SSA 23 – Morrisons Car Park

Site Information Proposed Land Use: Family Housing. Alternatively mixed use including residential and retail floor

space

PPS25 Vulnerability Classification: Vary from More Vulnerable (Housing) to Less Vulnerable (Retail)

Sequential Test: Residential use is not suitable in zone 3a and hence should be directed to low

risk areas of the site. Other intended (less Vulnerable) uses appear suitable.

Area of Site (Ha): 2.3

Overview of Flood Risks • Majority of the site is in the Low Probability Zone.

• Source of Flooding – Wealdstone Brook

• Low lying areas adjoining the Brook lie in the Medium and High Probability Zones.

Planning Issues

• The low risk areas of the site appears suitable for intended use.

• A buffer zone between top of the bank and the development should be allowed. The Environment Agency would normally require an 8m wide

strip.

• Deculvert the river at this Site and make it a feature of the Site, as part of the development

• Encroachment into functional flood plain should not be allowed.










EA FZ Map 0.1% AEP


Key: Modelled Flood

Outline 5% AEP

Site Specific


Zone 3a

Medium Probability

Zone 2

Climate Change

Zone 3a

Key:


Zone 3b


SSA 32 – Northfields Industrial Estate

Site Information Proposed Land Use: Mixed use redevelopment for intensified industrial employment and enabling

residential development.

PPS25 Vulnerability Classification: Mixed uses vary from Less Vulnerable (i.e., industrial) to More vulnerable (i.e.,

residential).

Sequential Test: Residential developments are not suitable in Zones 3b & 3a and hence should

be directed to low risk areas of the site.

Industrial uses are suitable outside the zone 3b.

Area of Site (Ha) 8.5

Overview of Flood Risks • Areas adjoining river is in the Functional Flood Plain. Some low lying areas are in High and Medium Probability Zones.


• Majority of the site is in the Low Probability Zone.

Planning Issues • The Site appears suitable for intended use provided vulnerabilities are considered.

• A buffer zone between top of the bank and the development should be allowed. The Environment Agency would normally require and 8m

wide strip.











EA FZ Map 0.1% AEP


Key: Modelled Flood

Outline 5% AEP

Site Specific


Zone 3a

Medium Probability

Zone 2

Climate Change

Zone 3a

Key:


Zone 3b


SSA 37 – Durkin Storage Building, North End Road

Site Information Proposed Land Use: Mixed use including residential and workspace for creative industries

including managed affordable workspace to support the wider regeneration

of the Wembley Park area.

PPS25 Vulnerability Classification: Mixed uses vary from Less Vulnerable (i.e., Industry) , More Vulnerable (i.e.,

Residential) to Highly Vulnerable (Basements)

Sequential Test: Residential (more vulnerable) uses are not suitable.

More vulnerable uses require an Exception Test.

Highly vulnerable uses are not permitted.

Less vulnerable uses are suitable.

Area of Site (Ha):

0.5


• The site lies in the High Probability Zone. Some parts adjacent to the watercourse could lie in the Functional Flood Plain.


Planning Issues

• The Site appears suitable for intended uses other than Residential and Highly Vulnerable uses

• Residential Developments should pass an Exception Test.

• Encroachment into the Functional Flood Plain should not be permitted.


strip.




EA FZ Map 0.1% AEP


Key: Modelled Flood

Outline 5% AEP

Site Specific


Zone 3a

Medium Probability

Zone 2

Climate Change

Zone 3a

Key:


Zone 3b


o flood probability

o flood depth

o flood velocity














Flood Risk Assessment Requirements • Loss of flood plain storage due to new development should be compensated.

• Threshold floor levels should be kept above predicted 1 in 100 year flood levels plus an allowance for climate change.

• Flow routes should not be obstructed




SSA 39 – Alpine House

Site Information Proposed Land Use: Mixed use development including low carbon or zero emission housing and

new light industrial managed affordable work space.

PPS25 Vulnerability Classification: Vary from More Vulnerable (Housing) to Less Vulnerable (industry)

Sequential Test: Residential use is not suitable in zone 3a and hence should be directed to low

risk areas of the site. Other intended uses appear suitable.

Area of Site (Ha):

0.9




• Low lying areas adjoining the Brook lie in the Medium and High Probability Zones.

Planning Issues • The low risk areas of the site appears suitable for intended use.


strip.











EA FZ Map 0.1% AEP


Key: Modelled Flood

Outline 5% AEP

Site Specific


Zone 3a

Medium Probability

Zone 2

Climate Change

Zone 3a

Key:


Zone 3b


SSA 49 – Barn Hill Garages

Site Information Proposed Land Use: Residential development within woodland setting in northern section with

access route and improvements to landscaping and planting at the southern

section.

PPS25 Vulnerability Classification: More Vulnerable

Sequential Test: Intended use is not suitable in zone 3a and hence should be directed to low

risk areas of the site.

Area of Site (Ha): 0.08




• Low lying areas adjoining the river lie in the Medium and High Probability Zones.

Planning Issues • The low risk areas of the site appears suitable for intended use.


strip.









Safe dry access and egress should be provided.


EA FZ Map 0.1% AEP


Key: Modelled Flood

Outline 5% AEP

Site Specific


Zone 3a

Medium Probability

Zone 2

Climate Change

Zone 3a

Key:


Zone 3b


SSA 101 – Shubette House

Site Information Proposed Land Use: Mixed use development including residential, hotel, office, workspace and

leisure and food and drink.

PPS25 Vulnerability Classification: Mixed uses vary from Less Vulnerable (i.e., Offices) to More Vulnerable (i.e.,

Residential)

Sequential Test: Site appears to be suitable for intended use.

Area of Site (Ha):

0.89

Overview of Flood Risks • Majority of the Site appears to be in Low and Medium Probability Zones.

• Source of Fooling – Wealdstone Brook

• Some areas in the margins to the north may lie in Zone 3a.

Planning Issues • The Site appears suitable for intended use.


strip.








• Flood storage should not be displaced nor runoff increased.



EA FZ Map 0.1% AEP


Key: Modelled Flood

Outline 5% AEP

Site Specific


Zone 3a

Medium Probability

Zone 2

Climate Change

Zone 3a

Key:


Zone 3b


SSA 105 – Brook Avenue

Site Information Proposed Land Use: The amalgamation and assembly of development parcels delivering a higher

density residential use.

PPS25 Vulnerability Classification: More Vulnerable

Sequential Test: Residential uses are not suitable in Zones 3b and 3a and hence should be

directed to low risk areas of the Site.

Area of Site (Ha):

0.9


• The low lying areas adjoining river is within functional flood plain. Some areas are in High and Medium Probability zones.


• Part of the site is in Low Probability Zone.

Planning Issues • Areas outside zone 3a ( i.e. probability <1%) are suitable for residential use.


strip.








• Flood storage should not be displaced nor runoff increased.



EA FZ Map 0.1% AEP


Key: Modelled Flood

Outline 5% AEP

Site Specific


Zone 3a

Medium Probability

Zone 2

Climate Change

Zone 3a

Key:


Zone 3b


SSA 113 – Wembley Point

Site Information Proposed Land Use: Comprehensive mixed use development including commercial, community

uses, B1 uses and residential development.

PPS25 Vulnerability Classification: Mixed uses may vary from Water compatible, Less Vulnerable to More

Vulnerable

Sequential Test: Intended uses are not suitable on parts of the site.

Only water Compatible uses are appropriate in zone 3b.

Essential Infrastructure require an Exception Test

Area of Site (Ha):

0.3Ha


• Site lies in the Functional Flood Plain.


• Frequent flooding of the site could be possible as half lies within the flood plain with 1 in 20 annual probability of flooding.

Planning Recommendations

• The area that lies in the functional flood plain should be guarded against future development. In this area only water compatible uses and

Essential Infrastructure (subject to an Exception Test) should be allowed.



o flood probability

o flood depth

o flood velocity


EA FZ Map 0.1% AEP


Key: Modelled Flood

Outline 5% AEP

Site Specific


Zone 3a

Medium Probability

Zone 2

Climate Change

Zone 3a

Key:


Zone 3b

113















Flood Risk Assessment Requirements • Encroachment into the functional flood plain should not be allowed when designing the layout and form of the structures. Development

should be steered to low risk areas of the Site following a sequential design approach.

• 8m buffer zone should be provided.

• Loss of flood plain storage due to new development should be compensated.

• Flow routes should not be obstructed.




3. Application of Exception Test & Level 2 SFRA Information 3.1. Following the application of the sequential test, SSA 7 (Unisys) and SSA 37 (Durkin Storage, North End

Road) from the Preferred Options document were highlighted as sites that would need to pass the

Exception Test in order to be developed. SSA113 (Wembley Point) was also identified as requiring an

exception test and level 2 SFRA.

3.2. To inform the application of the exception test a level 2 SFRA has been undertaken for these sites and

a summary of the results of each assessment is provided below, the full text of these assessments can

be found at annex C of this report.

Exception Test

3.3. Annex D of PPS25 identifies that for the Exception Test to be passed:

a) It must be demonstrated that the development provides wider sustainability benefits to the community

that outweigh flood risk , informed by an SFRA where one has been prepared. If the DPD has reached

the “submission” stage – see figure 4 of PPS12: Local Development Frameworks – the benefits of the

development should contribute to the Core Strategy’s Sustainable Appraisal;

b) The development should be on developable previously developed land or, if it is not on previously

developed land, that there are no reasonable alternative sites on developable previously-developed

land; and

c) A FRA must demonstrate that the development will be safe, without increasing flood risk elsewhere,

and, where possible, will reduce flood risk overall.

3.4. It is the Council’s responsibility to satisfy parts A and B of the Exception Test. Part C of the test is

informed by the SFRA and in particular the Level 2 SFRA. This part of the test must be satisfied by the

developer to the satisfaction of the Environment Agency and Council. This part of the test requires the

developer to carry out a full Flood Risk Assessment for the site, which is informed by the level 2 SFRA

information.

Level 2 Summary: SSA 7 – Unisys

3.5. The Level 2 SFRA indicates that approximately one third of the site falls within Zone 3b Functional

Floodplain with the remaining proportion falling within Zone 3a (High Probability). The flood depths

within the site are up to 600 mm 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 25.41m AOD in the 5% (1 in 20 year) and 1% (1 in 100

year) events respectively. The minimum ground level within the site is 24.8m AOD immediately

adjacent to the A406.

3.6. The site should be considered as “Zone 3b Developed” as defined in Brent’s SFRA. The SFRA

recommends “Zone 3b Developed” can be developed for “less vulnerable” uses such as: retail, offices,

restaurants, industry and assembly and leisure or the equivalent existing use, following the application

of the sequential and exception tests. However this would only apply to currently developed parts of


the site, as the land surrounding the buildings contain important flow paths and/or flood storage areas

that must be retained (see section 6.4.5, Brent SFRA).

3.7. The EA may accept more vulnerable uses on the developed parts of zone 3b subject to technical

design solutions and mitigation measures approved by the EA and provided that there is a significant

flood risk benefit on or off-site as a result of the development and safe access and egress for each

residential unit for up to a 1 in 100 year flood (+climate change). Measures expected to be used

include: reduction of building footprint, floor levels raised above the flood level (if floor levels were

previously at ground level), the reconfiguration of the site to improve flood flow routes and overall

vulnerability to flooding is decreased. However more vulnerable development would only be

considered at the EA’s discretion where appropriate, therefore close consultation with the EA is

essential.

3.8. In order to develop “more vulnerable “uses on the 3a part of this site the exception test will need to be

satisfied – parts A and B by the Council and part C by the developer (a full Flood Risk Assessment will

be required informed by a level 2 SFRA).

Level 2 Summary: SSA 37 – Durkin Building, North End Road

3.9. The Level 2 SFRA for this site has indicated the site actually falls entirely within Flood Zone 2, contrary

to the estimate flood levels contained in the Level 1 SFRA which indicated two thirds of the site would

fall into Flood Zone 3a. The predicted peak design flood event are 30.89m AOD and 31.92m AOD in

the 1% (1 in 100year) and 0.1% (1 in 1000 year) design event, assuming a 20% increase in peak flow as

a result of climate change is 31.23m AOD. The minimum ground level within the site is 31.5m AOD.

3.10. The site would only be flooded in the 1 in 1000 year event to a maximum flood depth of 400mm. The

depth of this flow would be relatively shallow and the velocity of the overland flow is no greater than

2.1m/s for the 1 in 1000 event.

3.11. The site is allocated for mixed uses including residential and workspace for creative industries. These

uses are acceptable in PPS25 terms as they classed as “more vulnerable” and “less vulnerable” uses

respectively. Therefore an exception test is not required for this allocation but a developer would be

expected to undertake a full Flood Risk Assessment.

Level 2 Summary: SSA 113 - Wembley Point

3.12. The Level 2 SFRA for this site actually indicates that half of the site falls within Flood Zone 2,

approximately half is Flood Zone 3a and there is a small strip of Flood Zone 3b to the southern margins

of the site adjacent to Wembley Brook. This is contrary to the Level 1 SFRA findings which indicated

that the southern half of the site was functional flood plain (Flood Zone 3b). The predicted peak design

flood events are 24.9m AOD for 1 in 20 year events (5%), 25.3m AOD for 1 in 100 year event (1%) and

25.6m for 1 in 1000 year event (0.1%). The car park on the site will therefore only flood in the 1% and

0.1% events reaching levels of approximately 25.23m AOD and 25.50m AOD respectively. The

maximum flood depth on the car park is estimated to be approximately 0.75m in the 1% design event

and 0.95m during the 0.1% design event.


3.13. The site is allocated for residential and complementary uses not in the functional flood plain. As the

level 2 SFRA has indicated, approximately half the site is Flood Zone 2 (medium probability of

flooding). According to PPS25 all uses apart from “highly vulnerable” uses are appropriate in this zone.

The south western half of the site is classified as Flood zone 3a. Only water compatible uses and less

vulnerable uses are appropriate without the application of the exception test. The Council does not

consider it appropriate to apply the exception test at this site, as the residential element of any future

development can be accommodated on the north eastern half of the site where it would be located on

flood zone 2. Less vulnerable commercial uses, subject to other planning considerations, will be

acceptable on the south western part of the site. The parts of the site which are flood zone 3b should

be protected for flood storage purposes, in line with Brent’s SFRA (December 2007) paragraph 6.4.4.

3.14. In light of the above it is therefore considered an exception test is not required for this allocation but a

developer would be expected to undertake a full Flood Risk Assessment and to site uses as outlined

above, in accordance with table D.3 of PPS25.

Exception Test: SSA 7 – Unisys

3.15. Part A – The Sustainability Appraisal for the Preferred Options SSA Report demonstrates that the site

has wider sustainability benefits. These include:

� The site is located in a part of Stonebridge that has been identified as in 10% most deprived

area.

� The site has a high PTAL rating between 5 and 4 and is located only 140m from Stonebridge

Station and 10m from the nearest bus stop. The Sustainable Communities agenda promotes

higher density development in areas of high transport accessibility.

� The site is also within 400m of open space of more than 2 Ha and 900m from a GP. Therefore

the existing amenity and social infrastructure available to serve the site is satisfactory.

� The site is not in an environmentally sensitive location and does not affect any listed buildings

or conservation areas.

� The site is brownfield land.

3.16. There is an established hope value for the site from a previous application (which was granted

planning permission in 1997 and renewed in 2002) for change of use from office to hotel use. The

Unisys part of the site was also the promoted for hotel and office use in the Adopted 2004 UDP. This

part of the site has remained vacant for over 8 years and the office buildings are now vulnerable to

vandalism and are a blight on the townscape. This important regeneration site has not realised its

potential, it is highly visible when entering the Wembley or Stonebridge areas, and when passing

through the borough on the A406 and is an opportunity to provide a signpost, iconic development to

promote the area and the borough.

3.17. The southern half of the site is occupied by a Sports Centre maintained by the Council, (Bridge Park)

which is in need of modernisation and improvement to enable it to effectively serve the local

population. The building is a converted bus garage (converted in the 1970s), not designed for use as a

sports centre, and consequently is in dire need of rebuilding. In addition a quantum of enabling

development, such as residential development, would be required in order to viably redevelop the


sports centre. The ideal solution would be to develop part of the site for housing which would assist in

funding a new sports and community centre on part of the site, with floorspace for community groups

and employment projects that currently use Bridge Park, with potentially residential units above.

3.18. The redevelopment would also assist in the retention of employment, and creating new employment

in an area with one of the highest levels of unemployment. This would assist in achieving a positive

score in terms of Brent’s Sustainability Objectives (see annex D), particularly in terms of reducing

economic disparities, providing the opportunity of employment and encourage sustainable economic

growth (Objectives 18-22). The development would also perform well in terms of the conservation

and enhancement of land quality and soil resources objective (Objective 17). A new development

would also enhance the townscape of the area, therefore scoring positively against objective 13 of

Brent’s Sustainability Objectives. A new sports and community centre would improve access to

services (Objective 8), provide everybody with good quality surroundings (Objective 5), encourage a

sense of local community (Objective 7), assist in improving the health of the local population

(objective 2), improve the education and skills of the local community (Objective 3) and provide

opportunity to live in a decent home (Objective 4).

3.19. Part B - The site is located on previously developed land which is developable as parts are vacant and

available (Unisys buildings) and Bridge Park Sports Centre is in need of re-building. The Council views

this site as an important gateway site to Wembley, in need of redevelopment. The western half of the

site is currently covered by vacant office buildings, which are not well maintained and do not positively

contribute to the townscape. There are no other nearby sites that would be sustainable to develop for

a sports and community centre that would serve the existing community, for whom it is important to

retain the facilities in the locality.

3.20. Part C – The detailed level 2 SFRA findings are included at annex C. This provides requirements for

any FRA for the site and also generic development control recommendations. Part C of the exception

test requires a full Flood Risk Assessment which must be undertaken by the developer.

4. Conclusions

4.1. The majority of site allocations have satisfied the requirements of the sequential test, therefore

have been considered appropriate to be included in the Submission Version of the Site Specific

Allocations document. 3 sites were largely located within Flood Zones 2, 3a or 3b and therefore did

not satisfy the sequential test and an exception test was required. The level 2 SFRA for SSA37

(Durkin Storage) indicated that the site was actually only located on Flood Zone 2 (medium

probability of flooding) therefore the uses proposed were deemed appropriate provided a Flood

Risk Assessment (FRA) was undertaken by the developer, and an exception test is not required for

this site. This is also the case for SSA113 (Wembley Point) where again the level 2 SFRA indicated

that half the site was in Flood Zone 2, which would be appropriate for more and less vulnerable uses.

Most of the remaining area of the site lies in flood zone 3a, where less vulnerable uses are

acceptable.

4.2. However the level 2 SFRA for SSA7 (Unisys) still indicated half the site was functional flood plain.

Therefore the Council undertook parts A and B of the exception test for this site but in order to

develop this site any developer would need to undertake an FRA to satisfy part C of the exception

test.

ANNEX A: PPS25 Sequential Test Flow Chart (Source : Development & Flood Risk: Practice Guide Companion to PPS25 (February 2007), Figure 3.1 “Application of the Sequential

Test”, pg 67)

Source: PPS25 – Appendix 2, Table D, December 2006

ANNEX B : Sequential Test Table

ANNEX C : Level 2 SFRA Results

ANNEX D : Brent’s Sustainability Objectives

Objective Criteria

Will it reduce poverty and social exclusion in those areas most affected?

Prosperity and Social Inclusion 1. To reduce poverty and social exclusion

Will it improve affordability of essential services?

Will it improve access to high quality health facilities?

Will it encourage healthy lifestyles and provide opportunities for sport and recreation?

Will it reduce health inequalities?

Health

2. To improve the health of the population

Will it reduce death rates?

Will it improve qualifications and skills of the population?

Will it improve access to high quality educational facilities?

Education and Skills

3. To improve the education and skills of the population

Will it help fill key skill gaps?

Will it increase access to good quality and affordable housing?

Will it encourage mixed use and range of housing tenure?

Will it reduce the number of unfit homes?

Housing

4. To provide everybody with the opportunity to live in a decent home

Will it reduce homelessness?

Will it improve the satisfaction of people with their neighbourhoods as places to live; encouraging ‘ownership’?

Will it improve residential amenity and sense of place?

Will it reduce actual noise levels?

Quality of surroundings

5. To provide everybody with good quality surroundings

Will it reduce noise concerns?

Will it reduce actual levels of crime? Crime Prevention and & Community Safety

6. To reduce crime and anti-social activity Will it reduce the fear of crime?

Will it encourage engagement in community activities?

Will it foster a sense of pride in area?

Will it increase the ability of people to influence decisions?

Will it improve ethnic relations?

Will it encourage communications between different communities in order to improve understanding of different needs and concerns?

Community Identity

7. To encourage a sense of community; identity and welfare

Will it encourage people to respect and value their contribution to society?

Will it improve accessibility to key local services?

Will it improve the level of investment in key community services?

Will it make access more affordable?

Social

Accessibility

8. To improve accessibility to key services especially for those most in need

Will it make access easier for those without access to a car?

Will it reduce traffic volumes?

Will it increase the proportion of journeys using modes other than the car?

Traffic

9. To reduce the effect of traffic on the environment

Will it encourage walking or cycling?

Will it improve the quality of inland water? Water Quality & Resources

10. To improve water quality; conserve water resources and provide for sustainable sources of water supply

Will it reduce water consumption?

Will it improve air quality?

Will it help achieve the objectives of the Air Quality Management Plan?

Air Quality

11. To improve air quality

Will it reduce emissions of key pollutants?

Will it conserve and enhance habitats of borough or local importance habitats and create habitats in areas of deficiency?

Will it conserve and enhance species diversity; and in particular avoid harm to protected species?

Will it maintain and enhance sites designated for their nature conservation interest?

Will it maintain and enhance woodland cover and management?

Biodiversity

12. To conserve and enhance biodiversity

Will it encourage protection of and increase number of trees?

Environmental

Landscape & Townscape Will it improve the landscape and ecological quality and character of open spaces?

Objective Criteria

Will it enhance the quality of priority areas for townscape and public realm enhancements?

Will it minimise visual intrusion and protect views?

13. To maintain and enhance the character and quality of landscapes and townscapes

Will it decrease litter in urban areas and open spaces?

Will it protect and enhance Conservation Areas and other sites; features and areas of historical and cultural value?

Will it protect listed buildings?

Historic Environment & Cultural Assets 14. To conserve and where appropriate enhance the historic environment and cultural assets

Will it help preserve and record archaeological features?

Will it reduce emissions of greenhouse gases by reducing energy consumption?

Will it lead to an increased proportion of energy needs being met from renewable sources?

Will it reduce emissions of ozone depleting substances?

Will it minimise the risk of flooding from rivers and watercourses to people and property?

Climate Change

15. To reduce contributions to climate change and reduce vulnerability to climate change

Will it reduce the risk of damage to property from storm events?

Will it lead to reduced consumption of materials and resources?

Will it reduce household waste?

Will it increase waste recovery and recycling?

Will it reduce hazardous waste?

Waste Management

16. To minimise the production of waste and use of non-renewable materials

Will it reduce waste in the construction industry?

Will it minimise development on greenfield sites?

Will it ensure that where possible; new development occurs on derelict; vacant and underused previously developed land and buildings?

Will it ensure land is remediated as appropriate?

Will it minimise the loss of soils to development?

Will it maintain and enhance soil quality?

Land and Soil

17. To conserve and enhance land quality and soil resources

Will it reduce the risk of subsidence?

Will it encourage new business start-ups and opportunities for local people?

Will it improve business development and enhance productivity?

Will it improve the resilience of business and the local economy?

Will it promote growth in key sectors?

Will it promote growth in key clusters?

Growth

18. To encourage sustainable economic growth

Will it enhance the image of the area as a business location?

Will it reduce short and long-term local unemployment?

Will it provide job opportunities for those most in need of employment?

Will it help to reduce long hours worked?

Employment

19. To offer everybody the opportunity for rewarding and satisfying employment

Will it help to improve earnings?

Regeneration

20. To reduce disparities in economic performance and promote sustainable regeneration

Will it promote regeneration; reducing disparity with surrounding areas?

Will it encourage indigenous business?

Will it encourage inward investment?

Investment

21. To encourage and accommodate both indigenous and inward investment

Will it make land and property available for business development?

Will it reduce commuting?

Will it improve accessibility to work by public transport; walking and cycling?

Will it reduce journey times between key employment areas and key transport interchanges?

Economic

Efficient Movement

22. To encourage efficient patterns of movement in support of economic growth

Will it facilitate efficiency in freight distribution?

site specific allocations pps25 sequential test - brent sequential … · 1.2. the sequential test...

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