Hounslow Local Plan. Flood Risk Sequential Test August 2014

Hounslow Local Plan Flood Risk Sequential Test August 2014

Contents 1. Introduction 3 2. The sequential test 3 Appendix 1: Sequential test of the proposed site allocations 6 For further information on the Local Plan, please refer to the council s website: www.hounslow.gov.uk Alternatively, contact the Planning Policy team: LDF@hounslow.gov.uk 020 8583 5202 Planning Policy London Borough of Hounslow Pavilion CF, Civic Centre Lampton Road Hounslow TW3 4DN

1. Introduction 1.1 This document forms the sequential test of the site allocations to be included in the Local Plan being prepared by London Borough of Hounslow, and has been prepared to meet the requirements of the National Planning Policy Framework ( the NPPF ) and the National Planning Practice Guidance ( the NPPG ). The proposed site allocations are set out in the Local Plan Submission draft, which was published 7 March 2014. The sequential test considers those sites within Hounslow s flood plain, which is established in the borough s Strategic Flood Risk Assessment (SFRA), the Level 2 SFRA undertaken for the Brentford Area Action Plan and the most recent Environment Agency mapping. The Local Plan has also been subject to Sustainability Appraisal (incorporating Strategic Environmental Assessment), which includes flood risk considerations. 1.2 The Local Plan Submission draft - together with the Sustainability Appraisal, other consultation documents and the SFRAs can be viewed on the council s website at: www.hounslow.gov.uk/localplan. 2. The sequential test 2.2 The aim of the sequential test as set out in the NPPF and NPPG - is to steer vulnerable new development towards areas at the lowest risk of flooding. It sets out a sequential approach in order to achieve this, with the overall aim of steering new development to Flood Zone 1. If this cannot be achieved, local planning authorities should take into account the flood risk vulnerability of land uses and consider reasonably available sites in Flood Zone 2, applying the Exception Test if required. Then, only where there are no reasonably available sites in Flood Zones 1 or 2 should the suitability of sites in Flood Zone 3 be considered, taking into account the flood risk vulnerability of land uses and applying the Exception Test if required. 2.3 The NPPG defines each flood zone. These are defined in the supporting facts below. Supporting facts Flood zones Flood Zone 1 low probability This zone comprises land assessed as having a less than 1 in 1,000 annual probability of river or sea flooding (<0.1%). Flood Zone 2 medium probability This zone comprises land assessed as having between a 1 in 100 and 1 in 1,000 annual probability of river flooding (1% 0.1%), or between a 1 in 200 and 1 in 1,000 annual probability of sea flooding (0.5% 0.1%) in any year. Flood Zone 3a high probability This zone comprises land assessed as having a 1 in 100 or greater annual probability of river flooding (>1%), or a 1 in 200 or greater annual probability of flooding from the sea (>0.5%) in any year. Flood Zone 3b the functional floodplain. This zone comprises land where water has to flow or be stored in times of flood.

2.4 The NPPG also provides a flood risk vulnerability classification for land uses. Each use of classified as one of the following: essential infrastructure ; highly vulnerable ; more vulnerable ; less vulnerable ; or water-compatible development. The Local Plan Proposed Submission proposes more vulnerable development, including housing, health services and education, as well as a range of less vulnerable and water compatible uses. The proposed site allocations do not include essential infrastructure or highly vulnerable uses. 2.5 Also, the NPPG provides a flood risk vulnerability and flood zone compatibility matrix, which establishes whether a particular use requires the sequential and exceptions tests to be applied. This table is shown in the supporting facts below. Supporting facts Flood risk vulnerability and flood risk compatibility Flood Zones Flood Risk Vulnerability Classification Essential infrastructure Highly vulnerable More vulnerable Less vulnerable Water compatible Zone 1 Zone 2 Exception Test required Zone 3a Exception Test required Exception Test required Zone 3b * Exception Test required * * Key: Development is appropriate Development should not be permitted. Notes: This table does not show the application of the Sequential Test which should be applied first to guide development to Flood Zone 1, then Zone 2, and then Zone 3; nor does it reflect the need to avoid flood risk from sources other than rivers and the sea; The Sequential and Exception Tests do not need to be applied to minor developments and changes of use, except for a change of use to a caravan, camping or chalet site, or to a mobile home or park home site; Some developments may contain different elements of vulnerability and the highest vulnerability category should be used, unless the development is considered in its component parts. In Flood Zone 3a essential infrastructure should be designed and constructed to remain operational and safe in times of flood. * In Flood Zone 3b (functional floodplain) essential infrastructure that has to be there and has passed the Exception Test, and water-compatible uses, should be designed and constructed to: remain operational and safe for users in times of flood; result in no net loss of floodplain storage; not impede water flows and not increase flood risk elsewhere.

2.6 Each of the strategic site allocations included in the Local Plan Submission draft has been subject to the sequential test. These are set out in the appendix of this document. Sites that located outside of the flood plain (i.e. located in Flood Zone1) are grouped, as all types of development are compatible in these locations. However, a separate table has been prepared for each of the sites either partially of wholly located in Flood Zones 2 to 3b is included. Of the 71 site allocations included in the Local Plan Submission draft, 14 are located in the flood plain. Of these 14, some are located only partially within the flood plain, whilst others are mostly of completed within either Flood Zone 2 or Flood Zone 3. 2.7 The council has been working with the Environment Agency during the preparation of the Local Plan, including consultation on the sequential test. The Environment Agency has provided further evidence to support the sequential test, including detailed design consideration which should inform development proposals. 2.8 This sequential test of Hounslow s Local Plan considers that the proposed site allocations pass the sequential and exceptions test. In many cases, more vulnerable development can be directed using the sequential approach to those parts of the site outside of the flood plain, or at a lower risk of flooding. For those sites at a higher risk of flooding, exceptional circumstances are demonstrated. It should also be noted that development proposals on these sites will be further subjected to flood risk considerations through the application of the Local Plan s policy on flood risk and surface water management, as well as the requirements of the NPPG and other policy provisions, such as those in the London Plan.

Appendix 1 This appendix provides an assessment of the site allocations against the sequential test, and where appropriate, the exceptions test. All sites located in Flood Zone 1 01 Dukes Meadow 02 500 Chiswick High Road 03 Empire House 04 Hogarth Business Park 11 Albany Riverside 13 Lionel Road 16 Commerce Road 17 Brentford Waterside 18 Morrisons Supermarket and Car Park 20 Alexandra House 22 Brentford Bus Depot 28 Europa House 29 Swan Court 31 Rugby Road 33 Nazareth House

Sites 05 Wheatstone House 06 BSkyB 07 Gillette 08 Boston Manor House and Park 09 Gunnersbury Park 10 Reynard Mills 12 Alfa Laval 14 Brentford Football Club 15 Brentford Police Station 19 Thames Water 23 69-77 Boston Manor Road 24 632-652 London Road 25 Scout Hut at Star Road 26 South West of Gillette Corner 27 John Busch House and the Telephone Exchange 29 Swan Court 30 174 Twickenham Road 32 Former West Thames College 35 Royal Mail Delivery Office 36 Bath Road 37 Bell Road 38 Central House 39 High Street Quarter 40 Hounslow House 41 Kingsley Road 42 Lampton Road 43 London Road North 44 London Road South - Site A 45 London Road South - Site B 46 Civic Centre 47 Staines Road East 48 Staines Road West 49 Vacant Site, Hanworth Road 50 Bus Garage 51 Upstage 52 Lampton House 53 Pears Road 54 Cavalry Barracks 55 Hounslow West Station 56 Bombardier Aerospace 57 Staines Road 59 Sutton Lane Indoor Bowls Club 61 The Hartlands 62 Heston Leisure Centre 63 Rectory Farm 64 Cranford Lane 65 Master Robert Hotel 67 Feltham Arenas 68 Feltham Ex-Servicemens Club 69 Fern Grove 70 Ashmead Depot, Hounslow Homes 71 Hanworth Library Flood Zone These sites are located in Flood Zone 1. This assessment concludes that these sites pass the sequential all are located in Flood Zone 1.

Site Allocation Flood Zone Highest vulnerability of proposed use Reasonable alternative site/s available in same or lower flood zone? 01 - Dukes Meadow Protection of the openness of the MOL with appropriate enhancement of sporting facilities. Open air recreational and relevant ancillary buildings to create a hub of sporting activity. The site is located within Flood Zone 3b Water compatible No Dukes Meadows is an established open space used for sports and recreation. This allocation supports the retention of and enhancement of existing sports facilities on the site, maintaining openness and promoting public access to the open space. Exceptions test The sequential test is passed no exceptions test required. Site allocation passes the sequential test. Planning recommendations The Strategic Flood Risk Assessment includes planning recommendations for sites in this flood zone at paragraph 6.4.3. Design considerations The Environment Agency has provided the following design considerations: Maximise setback of development to provide 16 metre undeveloped buffer strip wherever feasible; Safeguard space for future defence upgrade/replacement/realignment and floodplain management in line with the recommendations within the Hammersmith Policy Unit (Action Zone 1) Thames Estuary 2100 (TE2100) plan; Designs on the site should allow for increased height of tidal flood defence to allow for climate change in accordance with TE2100 Implementation Guidance. The current TE2100 advice is for future raising due to climate change to 6.25m AOD by 2065 and 6.70m AOD by 2100; Naturalise/enhance the bank profile where possible (Please see Thames Strategy Kew to Chelsea for possible design approaches to riverbank design for this specific location); and Design and layout of proposed development based on the sequential approach with more vulnerable uses (residential) located to the least risk areas of the site.

Site Allocation 02-500 Chiswick High Road Residential and commercial Flood Zone The small section of the site is located within Flood Zone 2 Highest vulnerability of proposed use Reasonable alternative site/s available in same or lower flood zone? More vulnerable No most of the site allocations included in the Local Plan are outside of Flood Zones 2, however a number of sites located in this zone are included as they are located within existing settlements and provide an opportunity for consolidation or regeneration. Development on this site is considered central to achieving the Local Plan s vision and spatial strategy (particularly for this district). Exceptions test The sequential test is passed no exceptions test required as more vulnerable development is permitted within Flood Zone 2. In addition, only a very small part of the site is located in this Flood Zone This assessment concludes that this site passes the sequential, as more vulnerable development is permitted in Flood Zone 2. In addition, only a very small part of the site is located in this Flood Zone. This site is of strategic significance as it is located on the edge of Chiswick town centre, and in a prominent location on Chiswick High Road; as such, its redevelopment is considered central to achieving the Local Plan s strategy for Chiswick. This site also has the potential to meet the borough s growing housing need, and has also been identified through The London SHLAA 2013 as it has a potential housing capacity during the plan period. Development proposals will require the preparation of a Flood Risk Assessment and if possible, development should be directed to part of site with lower residual risk of flooding using the sequential approach. Planning applications should draw on the SFRA, the NPPG and Local Plan policies (particularly EQ3). Planning recommendations The Strategic Flood Risk Assessment includes planning recommendations for sites in this flood zone at paragraphs 6.4.6 and 6.4.7.

Site Allocation Flood Zone Highest vulnerability of proposed use Reasonable alternative site/s available in same or lower flood zone? 03 - Empire House Hotel, office and retail with some residential The site is located within Flood Zone 3a More vulnerable No most of the site allocations included in the Local Plan are outside of the Flood Zone 3, however a number of sites located in this zone are included as they are located within existing settlements and provide an opportunity for consolidation or regeneration. Development on this site is considered central to achieving the Local Plan s vision and spatial strategy (particularly for this district). Exceptions test It must be demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk, informed by a Strategic Flood Risk Assessment where one has been prepared. A site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall. This site is of strategic significance as it is a large, vacant site within Chiswick Town Centre and provides an opportunity for improving the mix of uses in the Centre through redevelopment as a hotel, office and larger floor plate retail accommodation. As such, its redevelopment is considered central to achieving the Local Plan s strategy for Chiswick. Development proposals will require the preparation of a Flood Risk Assessment and if possible, development should be directed to part of site with lower residual risk of flooding using the sequential approach. Planning applications should draw on the SFRA, the NPPG and Local Plan policies (particularly EQ3). This assessment concludes that this site passes the sequential test and (in principal) the exceptions test development proposals will be dependent on the implementation of Local Plan Policy EQ3 ( Flood risk and surface water management ) to address flood risk issues. Planning recommendations The Strategic Flood Risk Assessment includes planning recommendations for sites in this flood zone at paragraph 6.4.5.

Site Allocation Flood Zone Highest vulnerability of proposed use Reasonable alternative site/s available in same or lower flood zone? 04 - Hogarth Business Park Residential and commercial The site is located within Flood Zone 3a More vulnerable No most of the site allocations included in the Local Plan are outside of the Flood Zone 3, however a number of sites located in this zone are included as they are located within existing settlements and provide an opportunity for consolidation or regeneration. Development on this site is considered central to achieving the Local Plan s vision and spatial strategy (particularly for this district). Exceptions test It must be demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk, informed by a Strategic Flood Risk Assessment where one has been prepared. A site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall. This is a large site within Chiswick and therefore its redevelopment is considered central to achieving the Local Plan s strategy for Chiswick. This site also has the potential to meet the borough s growing housing need, and has also been identified through The London SHLAA 2013 as it has a potential housing capacity during the plan period. Development proposals will require the preparation of a Flood Risk Assessment and if possible, development should be directed to part of site with lower residual risk of flooding using the sequential approach. Planning applications should draw on the SFRA, the NPPG and Local Plan policies (particularly EQ3). This assessment concludes that this site passes the sequential test and (in principal) the exceptions test development proposals will be dependent on the implementation of Local Plan Policy EQ3 ( Flood risk and surface water management ) to address flood risk issues. Planning recommendations The Strategic Flood Risk Assessment includes planning recommendations for sites in this flood zone at paragraph 6.4.5.

Site Allocation Flood Zone Highest vulnerability of proposed use Reasonable alternative site/s available in same or lower flood zone? 11 Albany Riverside Residential and retention of appropriate commercial uses, including reprovision of the Arts Centre either on-site or within Brentford Town Centre. The site should be developed comprehensively in order to optimise the residential capacity of the site as a whole. This will help achieve regeneration of the overall area and avoid the sterilisation of individual elements of the site. The site is located within Flood Zone 3a and adjacent to Flood Zone 3b More vulnerable No most of the site allocations included in the Local Plan are outside of the Flood Zone 3, however a number of sites located in this zone are included as they are located within existing settlements and provide an opportunity for consolidation or regeneration. Development on this site is considered central to achieving the Local Plan s vision and spatial strategy (particularly for this district). Exceptions test It must be demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk, informed by a Strategic Flood Risk Assessment where one has been prepared. A site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall. This is a large site within Brentford and therefore its redevelopment is considered central to achieving the Local Plan s strategy for Brentford, which includes regeneration of the town centre and waterside environments. Waterman s Arts Centre is of strategic importance as a cultural and leisure facility in Hounslow; as such, a town centre location would be more suitable and would leave this site available for redevelopment in line with the spatial strategy. Development proposals will require the preparation of a Flood Risk Assessment and if possible, development should be directed to part of site with lower residual risk of flooding using the sequential approach. Planning applications should draw on the SFRA, the NPPG and Local Plan policies (particularly EQ3). This assessment concludes that this site passes the sequential test and (in principal) the exceptions test development proposals will be dependent on the implementation of Local Plan Policy EQ3 ( Flood risk and surface water management ) to address flood risk issues. This site was previously allocated for mixed use redevelopment in the Brentford Area Action Plan (adopted 2009). The Level 2 SFRA undertaken for the Area Action Plan reiterates this sequential test, stating that more vulnerable development in this location will need to satisfy the exceptions test. Planning recommendations The Strategic Flood Risk Assessment includes planning recommendations for sites in this flood zone at paragraph 6.4.5.

Design considerations The Environment Agency has provided the following design considerations: Safeguard space for future defence upgrade/replacement/realignment and floodplain management in line with the recommendations within the Twickenham Policy Unit (Action Zone 1) Thames Estuary 2100 (TE2100) plan; Designs on the site should allow for increased height of tidal flood defence to allow for climate change in accordance with TE2100 Implementation Guidance; The current TE2100 advice is for future raising due to climate change to 6.25m AOD by 2065 and 6.70m AOD by 2100; and Design and layout of proposed development based on the sequential approach with more vulnerable uses (residential/education) located to the least risk areas of the site, landward of the defence.

Site Allocation Flood Zone Highest vulnerability of proposed use Reasonable alternative site/s available in same or lower flood zone? 13 Lionel Road Community Football Stadium with enabling residential and commercial development. The site is partially located within Flood Zone 3a (along the railway cutting).. More vulnerable No most of the site allocations included in the Local Plan are outside of the Flood Zone 3, however a number of sites located in this zone are included as they are located within existing settlements and provide an opportunity for consolidation or regeneration. Development on this site is considered central to achieving the Local Plan s vision and spatial strategy (particularly for this district). Exceptions test It must be demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk, informed by a Strategic Flood Risk Assessment where one has been prepared. A site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall. This is a large site within Brentford and therefore its redevelopment is considered central to achieving the Local Plan s strategy for Brentford. In addition, the redevelopment would provide a suitable site for Brentford Football Club, which is a high priority for the council. Planning permission has been granted for a community football stadium with enabling residential development. Detailed development proposals will require the preparation of a Flood Risk Assessment and if possible, development should be directed to part of site with lower residual risk of flooding using the sequential approach. Planning applications should draw on the SFRA, the NPPG and Local Plan policies (particularly EQ3). This assessment concludes that this site passes the sequential test and (in principal) the exceptions test planning permission has been granted for a community football stadium with enabling residential development. Detailed development proposals will be dependent on the implementation of Local Plan policies (or the existing development plan until the Local Plan is adopted) to address identified constraints. The Level 2 SFRA undertaken for the Brentford Area Action Plan reiterates this sequential test, stating that more vulnerable development is acceptable in this location. Planning recommendations The Strategic Flood Risk Assessment includes planning recommendations for sites in this flood zone at paragraphs 6.4.5 and 6.4.7. Design considerations The Environment Agency has provided the following design considerations:

Surface water drainage scheme compliant with Council s recommendations of the Surface Water Management Plan. Critical Drainage Area identified therefore opportunity to provide additional surface water storage which could aid local flood risk management; Design and layout of proposed development based on the sequential approach with more vulnerable uses (residential) located to the least risk areas of the site.

Site Allocation Flood Zone Highest vulnerability of proposed use Reasonable alternative site/s available in same or lower flood zone? 16 Commerce Road To include a mix of residential, commercial, waterside leisure, education and community uses. The site is located mostly within Flood Zones 2, with a small part of the site located in Flood Zone 3b. More vulnerable No most of the site allocations included in the Local Plan are outside of the Flood Zone 3, however a number of sites located in this zone are included as they are located within existing settlements and provide an opportunity for consolidation or regeneration. Development on this site is considered central to achieving the Local Plan s vision and spatial strategy (particularly for this district). Exceptions test It must be demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk, informed by a Strategic Flood Risk Assessment where one has been prepared. A site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall. This is a large site within Brentford and therefore its redevelopment is considered central to achieving the Local Plan s strategy for Brentford. There is a Planning consent has been partly implemented with residential development completed on the southern part of the site and it is considered that there is potential for educational or employment uses on the northern end of the site. This site has been identified in the Council s School Place Planning Site Review as an appropriate location for the provision of new school places, for which there is a significant demand. Detailed development proposals will require the preparation of a Flood Risk Assessment and if possible, development should be directed to part of site with lower residual risk of flooding using the sequential approach. Planning applications should draw on the SFRA, the NPPG and Local Plan policies (particularly EQ3). The exceptions test is required as more vulnerable development is proposed and part of the site is located in Flood Zone 3 however, this forms only a small portion of the site. This assessment concludes that this site passes the sequential test and (in principal) the exceptions test development proposals will be dependent on the implementation of Local Plan Policy EQ3 ( Flood risk and surface water management ) to address flood risk issues. The Level 2 SFRA undertaken for the Brentford Area Action Plan reiterates this sequential test, stating that more vulnerable development in this location will need to satisfy the exceptions test. Planning recommendations The Strategic Flood Risk Assessment includes planning recommendations for sites in this flood zone at paragraphs 6.4.4 and 6.4.6. Design considerations

The Environment Agency has provided the following design considerations: Development must include a minimum 8 metres setback of buildings from the GUC and creation of additional flood storage; Design and layout of proposed development based on the sequential approach with more vulnerable uses (residential) located to the least risk areas of the site. Surface water drainage scheme compliant with Council s recommendations of the Surface Water Management Plan.

Site Allocation Flood Zone Highest vulnerability of proposed use Reasonable alternative site/s available in same or lower flood zone? 17 Brentford Waterside Retail-led mixed town centre use including residential, with an appropriate level of provision for town centre car parking The site is located within Flood Zone 3b, with smaller areas located in Flood Zone 2 and Flood Zone 1. More vulnerable No most of the site allocations included in the Local Plan are outside of the Flood Zone 3, however a number of sites located in this zone are included as they are located within existing settlements and provide an opportunity for consolidation or regeneration. Development on this site is considered central to achieving the Local Plan s vision and spatial strategy (particularly for this district). Exceptions test It must be demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk, informed by a Strategic Flood Risk Assessment where one has been prepared. This is a large site within Brentford town centre and therefore its redevelopment is considered central to achieving the Local Plan s strategy for Brentford and the wider borough. The redevelopment of this site for retail led mixed use town centre development is key to the successful regeneration of Brentford town centre and should enhance the town centre s role as a District centre within the borough s town centre network and fulfil an important community, cultural and social role for Brentford s existing and new residents. This site also has the potential to meet the borough s growing housing need, and has also been identified through The London SHLAA 2013 as it has a potential housing capacity during the plan period. A site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall. Detailed development proposals will require the preparation of a Flood Risk Assessment and if possible, development should be directed to part of site with lower residual risk of flooding using the sequential approach. Planning applications should draw on the SFRA, the NPPG and Local Plan policies (particularly EQ3). This site is located in a Flood Zone 3b, however it is a key site within Brentford that is considered central to the regeneration of the District centre and broader spatial strategy for the borough. This assessment concludes that this site passes the sequential test and (in principal) the exceptions test development proposals will be dependent on the implementation of Local Plan Policy EQ3 ( Flood risk and surface water management ) to address flood risk issues. This site was previously allocated for mixed use redevelopment in the Brentford Area Action Plan (adopted 2009). The Level 2 SFRA undertaken for the Area Action Plan reiterates the more vulnerable development should in principal not be permitted on this site, and states that robust planning arguments that demonstrate the absence of any alternative suitable sites within a zone of lesser flood risk should be made where redevelopment comes forward.

Planning recommendations The Strategic Flood Risk Assessment includes planning recommendations for sites in this flood zone at paragraphs 6.4.4, 6.4.6, and 6.4.7 Design considerations The Environment Agency has provided the following design considerations: Maximise setback of development to provide 16 metres undeveloped buffer strip wherever feasible; Tidal flood defences through the site need to remain continuous at statutory defence height in line with the recommendations of the Twickenham Policy Unit (Action Zone 1) of the Thames Estuary 2100 Plan. Designs on the site should allow for increased height for tidal flood defence to allow for climate change in accordance with TE2100 The current TE2100 advice is for future raising due to climate change to 6.25m AOD by 2065 and 6.70m AOD by 2100; Restore riverside wall and defence to good condition with environmental enhancement. Design and layout of proposed development based on the sequential approach with more vulnerable uses (residential) located to the least risk areas of the site; A reduction in the building platform area and the removal of buildings away from natural overland flood routes, reducing obstructions to the flow; The provision of a dry access route for pedestrians (i.e. above the 100 year plus climate change flood level) and the development of a dedicated emergency response plan in case of flooding; The integration of sustainable drainage techniques to reduce the rate and volume of runoff from the site; and The raising of floor levels and the introduction of flood proofing to minimise flood damages.

Site Allocation Flood Zone Highest vulnerability of proposed use Reasonable alternative site/s available in same or lower flood zone? 18 Morrisons Supermarket and Car Park Retail-led mixed town centre use, with an appropriate level of provision for town centre car parking Most of the site is located in Flood Zone 1, however small sections of the site are located within Flood Zones 2 and 3b. Less vulnerable No there is an existing supermarket on this site. This allocation proposes the redevelopment of this existing town centre site for continued retail use. Exceptions test The sequential test is passed no exceptions test required. Site allocation passes the sequential test however, it should be noted that any mixed use proposals including housing would change the vulnerability of the proposed use to more vulnerable, and the exceptions test would be required as small areas of the site are located in Flood Zone 3b. This site was previously allocated for mixed use redevelopment in the Brentford Area Action Plan (adopted 2009). The Level 2 SFRA undertaken for the Brentford Area Action Plan reiterates this sequential test, stating that more vulnerable development is acceptable in this location. Planning recommendations The Strategic Flood Risk Assessment includes planning recommendations for sites in this flood zone at paragraphs 6.4.4, 6.4.6, and 6.4.7

Site Allocation Flood Zone Highest vulnerability of proposed use Reasonable alternative site/s available in same or lower flood zone? 20 Alexandra House Expansion of an existing primary school. Most of the site is located in Flood Zone 1, however small sections of the site are located within Flood Zones 2 and 3a. More vulnerable No most of the site allocations included in the Local Plan are outside of the Flood Zone 3, however a number of sites located in this zone are included as they are located within existing settlements and provide an opportunity for consolidation or regeneration. Development on this site is considered central to achieving the Local Plan s vision and spatial strategy (particularly for this district). Exceptions test It must be demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk, informed by a Strategic Flood Risk Assessment where one has been prepared. This site has been identified through the council s School Place Planning Site Review as an appropriate location for the expansion of existing primary provision in the Brentford school place planning area, for which there is a significant demand. It is an available brownfield site in an area of need for both primary and secondary places. A site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall. Detailed development proposals will require the preparation of a Flood Risk Assessment and if possible, development should be directed to part of site with lower residual risk of flooding using the sequential approach. Planning applications should draw on the SFRA, the NPPG and Local Plan policies (particularly EQ3). The exceptions test is required as more vulnerable development is proposed and part of the site is located in Flood Zone 3 however, this forms only one part of the site. This assessment concludes that this site passes the sequential test and (in principal) the exceptions test development proposals will be dependent on the implementation of Local Plan Policy EQ3 ( Flood risk and surface water management ) to address flood risk issues. Planning recommendations The Strategic Flood Risk Assessment includes planning recommendations for sites in this flood zone at paragraphs 6.4.5, 6.4.6, and 6.4.7 Design considerations The Environment Agency has provided the following design considerations: Design and layout of proposed development based on the sequential approach with more vulnerable uses (education) located to the least risk areas of the site; and Surface water drainage scheme compliant with Council s recommendations of the Surface Water Management Plan.

Site Allocation Flood Zone Highest vulnerability of proposed use Reasonable alternative site/s available in same or lower flood zone? 22 Brentford Bus Depot Provision of school places if bus depot can be reprovided on an appropriate site at TfL s agreement. Most of the site is located in Flood Zone 1, however a small part of the site are located within Flood Zone 2. More vulnerable No there is an existing bus depot on this site, and the allocation continues this use, unless reprovision provides the opportunity education uses. This allocation proposes the redevelopment of this existing town centre site for continued retail use. Exceptions test The sequential test is passed no exceptions test required. This assessment concludes that this site passes the sequential test, as more vulnerable development is permitted in Flood Zone 2, of which a small part of the site is located in. Development proposals will be dependent on the implementation of Local Plan Policy EQ3 ( Flood risk and surface water management ) to address flood risk issues. Planning recommendations The Strategic Flood Risk Assessment includes planning recommendations for sites in this flood zone at paragraphs 6.4.6, and 6.4.7 Design considerations The Environment Agency has provided the following design considerations: Design and layout of proposed development based on the sequential approach with more vulnerable uses (education) located to the least risk areas of the site; and Surface water drainage scheme compliant with Council s recommendations of the Surface Water Management Plan.

Site Allocation Flood Zone Highest vulnerability of proposed use Reasonable alternative site/s available in same or lower flood zone? 28 Europa House Residential and office The site is located within Flood Zones 3a and 3b, with smaller parts located in Flood Zone 2 and Flood Zone 1. More vulnerable No most of the site allocations included in the Local Plan are outside of the Flood Zone 3, however a number of sites located in this zone are included as they are located within existing settlements and provide an opportunity for consolidation or regeneration. Development on this site is considered central to achieving the Local Plan s vision and spatial strategy (particularly for this district). Exceptions test It must be demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk, informed by a Strategic Flood Risk Assessment where one has been prepared. This is a prominent waterside site within Isleworth and therefore its redevelopment is considered central to achieving the Local Plan s strategy for Isleworth. This site also has the potential to meet the borough s growing housing need, and has also been identified through The London SHLAA 2013 as it has a potential housing capacity during the plan period. A site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall. Detailed development proposals will require the preparation of a Flood Risk Assessment and if possible, development should be directed to part of site with lower residual risk of flooding using the sequential approach. Planning applications should draw on the SFRA, the NPPG and Local Plan policies (particularly EQ3). This site is located in a Flood Zone 3b, however it is considered a key site within Isleworth, and therefore central to the identity of this part of borough. This assessment concludes that this site passes the sequential test and (in principal) the exceptions test development proposals will be dependent on the implementation of Local Plan Policy EQ3 ( Flood risk and surface water management ) to address flood risk issues. Planning recommendations The Strategic Flood Risk Assessment includes planning recommendations for sites in this flood zone at paragraphs 6.4.4, 6.4.5, 6.4.6, and 6.4.7 Design considerations The Environment Agency has provided the following design considerations: The sequential approach to layout should be taken and all more vulnerable development should be located outside of FZ3b; Maximise setback of development to provide 16 metre undeveloped buffer strip wherever feasible;

Tidal flood defences through the site need to remain continuous at statutory defence height in line with the recommendations within the Thames Estuary 2100 (TE2100) plan. Designs on the site should allow for increased height of tidal flood defence to allow for climate change in accordance with TE2100 Implementation Guidance. The current TE2100 advice is for future raising due to climate change to 6.25m AOD by 2065 and 6.70m AOD by 2100; Site redevelopment should aim to restore riverside wall and defence to good condition with environmental enhancement in line with Water Framework Directive objectives, such as the provision of intertidal habitat; Design re-development with regard to the recommendations from the Twickenham Policy Unit and Action Zone 1 in the TE2100 Plan.

Site Allocation 29 Swan Court Residential, commercial and car parking Flood Zone Approximately half of the site is located in Flood Zone 1, however the remaining sections of the site are located within Flood Zones 2 and 3b. Highest vulnerability of proposed use Reasonable alternative site/s available in same or lower flood zone? More vulnerable No most of the site allocations included in the Local Plan are outside of the Flood Zone 3, however a number of sites located in this zone are included as they are located within existing settlements and provide an opportunity for consolidation or regeneration. Development on this site is considered central to achieving the Local Plan s vision and spatial strategy (particularly for this district). Exceptions test It must be demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk, informed by a Strategic Flood Risk Assessment where one has been prepared. This is a prominent waterside site within Isleworth and therefore its redevelopment is considered central to achieving the Local Plan s strategy for Isleworth. This site also has the potential to meet the borough s growing housing need, and has also been identified through The London SHLAA 2013 as it has a potential housing capacity during the plan period. A site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall. Detailed development proposals will require the preparation of a Flood Risk Assessment and if possible, development should be directed to part of site with lower residual risk of flooding using the sequential approach. Planning applications should draw on the SFRA, the NPPG and Local Plan policies (particularly EQ3). This site is located in a Flood Zone 3b, however it is considered a key site within Isleworth, and therefore central to the prosperity of this part of borough. This assessment concludes that this site passes the sequential test and (in principal) the exceptions test development proposals will be dependent on the implementation of Local Plan Policy EQ3 ( Flood risk and surface water management ) to address flood risk issues. Planning recommendations The Strategic Flood Risk Assessment includes planning recommendations for sites in this flood zone at paragraphs 6.4.4, 6.4.6, and 6.4.7 Design considerations The Environment Agency has provided the following design considerations: The sequential approach to layout should be taken and all more vulnerable development should be located outside of FZ3b; Maximise setback of development to provide 16 metre undeveloped buffer strip wherever

feasible; Tidal flood defences through the site need to remain continuous at statutory defence height in line with the recommendations within the Thames Estuary 2100 (TE2100) plan; Designs on the site should allow for increased height of tidal flood defence to allow for climate change in accordance with TE2100 Implementation Guidance. The current TE2100 advice is for future raising due to climate change to 6.25m AOD by 2065 and 6.70m AOD by 2100; Site redevelopment should aim to restore riverside wall and defence to good condition with environmental enhancement in line with Water Framework Directive objectives such as the provision of intertidal habitat; and Design re-development with regard to the recommendations from the Twickenham Policy Unit and Action Zone 1 in the TE2100 Plan.

Site Allocation Flood Zone Highest vulnerability of proposed use Reasonable alternative site/s available in same or lower flood zone? 31 Rugby Road Commercial and residential Most of the site is located in Flood Zone 2, with small sections of the site are located within Flood Zones 3a and Flood Zone 1. More vulnerable No most of the site allocations included in the Local Plan are outside of the Flood Zone 3, however a number of sites located in this zone are included as they are located within existing settlements and provide an opportunity for consolidation or regeneration. Development on this site is considered central to achieving the Local Plan s vision and spatial strategy (particularly for this district). Exceptions test It must be demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk, informed by a Strategic Flood Risk Assessment where one has been prepared. A site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall. This is a prominent site within Isleworth adjacent to Twickenham Stadium, and therefore its redevelopment is considered central to achieving the Local Plan s strategy for Isleworth. This site also has the potential to meet the borough s growing housing need, and has also been identified through The London SHLAA 2013 as it has a potential housing capacity during the plan period. Detailed development proposals will require the preparation of a Flood Risk Assessment and if possible, development should be directed to part of site with lower residual risk of flooding using the sequential approach. Planning applications should draw on the SFRA, the NPPG and Local Plan policies (particularly EQ3). The exceptions test is required as more vulnerable development is proposed and part of the site is located in Flood Zone 3 however, this forms only a small part of the site. This assessment concludes that this site passes the sequential test and (in principal) the exceptions test development proposals will be dependent on the implementation of Local Plan Policy EQ3 ( Flood risk and surface water management ) to address flood risk issues. Planning recommendations The Strategic Flood Risk Assessment includes planning recommendations for sites in this flood zone at paragraphs 6.4.5, 6.4.6, and 6.4.7 Design considerations The Environment Agency has provided the following design considerations: The sequential approach to layout should be taken and all more vulnerable development should be located to flood zone 2 wherever possible; There is a main river flowing through this site (Whittton Brook). Any proposed development will need to be set back a minimum of 8 metres from the top of bank of the main river;

There is a small Flood Storage Area present on this site which needs to be factored into the design and layout of the development; and Any development on this site should seek to deliver ecological enhancements to the Whitton Brook in line with the Water Framework Directive objectives.

Site Allocation 33 Nazareth House Residential with affordable extra care housing and supported living units. Flood Zone Approximately half of the site is located in Flood Zone 1, however the remaining sections of the site are located within Flood Zones 2 and 3b. Highest vulnerability of proposed use Reasonable alternative site/s available in same or lower flood zone? More vulnerable No most of the site allocations included in the Local Plan are outside of the Flood Zone 3, however a number of sites located in this zone are included as they are located within existing settlements and provide an opportunity for consolidation or regeneration. Development on this site is considered central to achieving the Local Plan s vision and spatial strategy (particularly for this district). Exceptions test It must be demonstrated that the development provides wider sustainability benefits to the community that outweigh flood risk, informed by a Strategic Flood Risk Assessment where one has been prepared. A site-specific flood risk assessment must demonstrate that the development will be safe for its lifetime taking account of the vulnerability of its users, without increasing flood risk elsewhere, and, where possible, will reduce flood risk overall. This is a prominent waterside site within Isleworth and therefore its redevelopment is considered central to achieving the Local Plan s strategy for Isleworth. Planning permission has been granted for residential use with a large proportion for home care provision. This development has the potential to meet the borough s growing housing need, and has also been identified through The London SHLAA 2013 as it has a potential housing capacity during the plan period. Detailed development proposals will require the preparation of a Flood Risk Assessment and if possible, development should be directed to part of site with lower residual risk of flooding using the sequential approach. Planning applications should draw on the SFRA, the NPPG and Local Plan policies (particularly EQ3). Part of this site is located in a Flood Zone 3b, however it is considered a key site within Isleworth, and therefore central to the identity of this part of borough. This assessment concludes that this site passes the sequential test and (in principal) the exceptions test development proposals will be dependent on the implementation of Local Plan Policy EQ3 ( Flood risk and surface water management ) to address flood risk issues. Planning recommendations The Strategic Flood Risk Assessment includes planning recommendations for sites in this flood zone at paragraphs 6.4.4, 6.4.6, and 6.4.7 Design considerations The Environment Agency has provided the following design considerations: Design and layout of proposed development based on the sequential approach with more

vulnerable uses (residential) located to the least risk areas of the site, e.g. Flood Zone 2; Maximise setback of development to provide 16 metre undeveloped buffer strip wherever feasible; Tidal flood defences through the site need to remain continuous at statutory defence height in line with the recommendations within the Thames Estuary 2100 (TE2100) plan. This is a particularly important constraint to consider on this site as the defence line runs through the development site. The defence line in this area is retreated away from the river wall and follows the ground contour. The current defence level in this area is 5.94m AOD and TE2100 advice is for future raising due to climate change to 6.25m AOD by 2065 and 6.70m AOD by 2100; Designs on the site should allow for increased height of tidal flood defence to allow for climate change in accordance with TE2100 Implementation Guidance; and Site redevelopment should aim to incorporate environmental enhancement in line with Water Framework Directive objectives. Design re-development with regard to the recommendations from the Twickenham Policy Unit and Action Zone 1 in the TE2100 Plan.