WEMBLEY MATTERS News and views on local politics, the environment, climate change, culture and local history
Readers who have followed with concern Wembley Matters coverage of raw sewage in the Wealdstone Brook and concerns over the River Brent, and who have been frustrated by what many saw as Thames Water's tardy response may be interested in the Thames representative's response to a question from Cllr Georgiou last night. Adequate?
There were two main issues at Brent Scrutiny yesterday evening, both vital to the safety of Brent residents. The meeting was chaired by vice chair Cllr Kasangra as Cllr Roxanne Mashari, the chair, is unwell with long covid.
The first item came under 'Topical Issue' and was a follow up to a previous Scrutiny discussion about the impact of flooding, particularly in the Kilburn area. Thames Water appeared to answer questions but unfortunately the Environment Agency, despite requests to attend, did not.
This is important because Thames Water are responsible for sewer flooding, Brent Council for surface water flooding, and the Environment Agency for river flooding. Clearly the 3 factors interact with each other, so a joint approach is necessary along with services such as the London Fire Brigade.
Mike Benke, (Thames Water Local Government Liaison Officer) and Alex Nickson (Lead Responder on July 12th Flooding) addressed the meeting and answered questions.
The July 12th rainfall was much more intense that had been planned for. Thames Water said that they had not responded as well as customers had a right to expect - they had just not been quick enough. They had been overwhelmed on the day and their response had not been good enough.
Thames had already implemented changes such as an increase in resources at call centres and were looking for other sustainable solutions and property protection measures.
Cllr Johnson asked how, with a housing target of 3,200 dwelling, Thames would work with the borough to ensure drainage was adequate. The Committee were clearly shocked to hear the Thames Water were not a statutory consultee on planning applications - they didn't have to be consulted on large developments, but councils do consult them. Thames are pro-active in looking at where developments are proposed. Thames was not anti-development by any stretch but tried to get developers to engage with them. They offer a free pre-application advice service on how to make developments sustainable. However, developers are under no obligation to consult with Thames.
Cllr Kasangra felt Thames should be a statutory consultee. Nickson said that in a perfect world they would be. He remarked that it was not just large development: the cumulative impact of small changes, such as paving over of gardens could be more significant than some large developments.
Thames has appointed an Independent Review into the July 12th events. It was arm’s length to ensure independence despite Thames Water funding it. The three experts will procure evidence from independent professional advisers. It would report in April or May with a particular focus on the Maida Vale areas.
Of 14 recommendations made by the internal review into July 12th nine had been implemented so far and Thames was 'planning for the worst rather than hoping for the best' and working with agencies including the London Fire Brigade. Some actions had been tested during August and October storms without any serious flooding. They would provide the council with an update on the outstanding 5 actions. They were working to improve their communication of events via social media.
A Brent officer said that the council were currently updating their flood planning and looking at attenuation of flood risk via green spaces. They were scoping the whole borough looking at major areas in danger of flooding and nearby green spaces. The surface flood risk plan for the whole borough would be updated and they were also working with neighbouring boroughs on a surface water management plan.
Cllr Mashari had sent in a question asking why Brent was not included in sewer infrastructure upgrade plans. Nickson said he was not aware that Brent was not being covered and would go back to colleagues for a response. There was a rolling programme of works on sewers with a low capacity for growth.
Cllr Hylton asked about the release of sewage into the River Brent. Thames Water said that was currently legal when capacity reached a certain point, but they no longer felt that this was acceptable. They were working with the government, Ofwat and the Environment Agency to change the system.
Thames Water had updated system whereby residents could provide details of instances of flooding. Prior to July complainants were asked to send in a questionaire response, now a website has been set up and they could complete it on-line but to avoid digital exclusion a written response could still be made. A record of the responses would be submitted to the Independent Review.
Cllr Janice Long raised the issue of burst water mains and the resulting flooding of roads. In some cases, traffic continued to use the road and the resulting back wash was the course of the flooding of homes lining the road. She asked that in such circumstances roads should be closed. Nickson said this was an excellent point and could be done as a result of liaison between the borough, Thames Water, the Police and the Fire Brigade.
The Committee made three information request:
1. To receive the Independent Review into the events of and response to the floods of July when that is made available
2. To also receive Thames Water's response to that review
3. To receive an update report to the Council's multi-agency flood plan and to make a committee date for this
4. Receive a report on the level of funding in Brent for drainage repairs compated to other London boroughs.
In addition they made a recommendation that the Planning Department of Brent Counciul work more closely with Thames Water on drainage issues arising from planning applications.
The review of Fire Safety is the second item on the above video (beginning at 1.01:15) and was not as comprehensive as the Flood item.
A Brent council tenant who listened carefully to the discussion said:
The scrutiny committee did not seem to know much about the subject they were discussing with the biggest fault being they made no mention as to how residents will be involved, which was the main focus of the Building Safety bill and they failed to even mention Dame Judith Hackitt's three reports on Building Safety and the Fire Safety Act which updated the Fire Safety Order (2005.
Their 'experts' seemed to believe that it is only new buildings that the Building Safety bill applies to but that is not the case, as it also applies to current buildings.
Although they mentioned cladding, no one mentioned fire doors but to be generous the absentee technical officer might have brought them into the discussion and Cllr. Conneely tried to raise issues like fire doors but was told it was a 'housing issue'.
They were also vague about the training competences required but if they had read the Health & Safety reports on Building Safety led by Mr. Baker, the Regulator, they would understand that any new Inspectors would need to start from level 7 (Honours Degree) and have post grad qualifications in Fire Safety and related areas. That is why it is so hard to find suitable candidates, as most surveyors only have an honours degree but nothing higher.
I could go on, but I suppose it was a start, but I would give it a 3 rating (out of 10) as the council needs to start reading all the material that has already been published, although they seem to be waiting for someone to guide them to it.
As Dame Hackitt said only 10% of councils are 'on the ball' e.g. Camden but unfortunately Brent is within the remaining 90%.
Details of the proposed legislation HERE
Wembley Matters has recently been focusing on the potential impact of severe weather events on potential flooding in the north LINK and south LINK of the borough so it is welcome to hear that neighbouring boroughs Harrow and Barnet are taking action on the Silk Stream catchment that feeds into the Welsh Harp. Without mitigation torrential rainfall carried by the Silk Stream could have a major impact on the Welsh Harp and lead to the opening of sluices at the dam with the excess water flowing down the River Brent.
This is Thames21 account of the project and consultation:
A major six-year partnership project will work with nature to reduce the risk of flooding in the Silk Stream catchment and wider River Brent.
The Silk Stream Flood and Resilience Innovation (SSFRI) is a partnership project, led by Harrow and Barnet Councils with involvement from Thames21, Thames Water, Environment Agency, Greater London Authority, Canal and River Trust, Brent Catchment Partnership, Friends of the Silk Stream Resident Group, Silk Stream Flood Action Group and others. The project is funded by the government’s Flood and Coastal Resilience Innovation initiative and is one of 25 related schemes across England.
The project will explore opportunities to build new wetlands, restore stretches of river and create new areas of natural drainage to increase flood resilience as well as create a host of other benefits, including improved water quality, beautiful public spaces that will boost health and wellbeing and much needed habitat for wildlife.
We need your help!
To be successful we need the knowledge and insight of local people. Throughout the project there will be multiple opportunities for local people to help shape project proposals. We’ll also be creating opportunities to learn more about rivers and the wildlife they support and to get actively involved in improving rivers and building flood resilience. To find out more about our plans and how you can get involved and influence what we do, use the link below to add yourself to the project mailing list.
The Silk Stream Catchment
The Silk Stream is a major tributary of the River Brent, rising on the Harrow Weald and Barnet Plateau and joining the Brent at the Welsh Harp Reservoir. It has several tributaries including Burnt Oak Brook and Edgware Brook. The Silk Stream is an important resource for wildlife and, along with Burnt Oak Brook, is designated a Site of Importance for Nature Conservation. Welsh Harp Reservoir where the Silk Stream meets the Brent is a Site of Special Scientific Interest due to the diversity of breeding water birds that it supports.
Flooding is a serious concern in the catchment and it’s estimated that over 1000 properties are at risk. As the catchment has become increasingly urbanised with natural vegetation replaced by hard surfaces, water is less able to soak into the ground and during intense rainfall events water levels can rise rapidly, causing flooding.
Pollution is another problem that affects the Silk Stream, coming from a variety of sources including plumbing misconnections and connectivity between the surface water and foul sewers. During high rainfall events the sewers reach capacity and these problems are intensified.
How will the project help?
Traditional approaches to managing flood risk have focused on concrete flood defences but there is a growing movement towards natural flood management (NFM) which works with nature to slow the flow of water entering rivers, create natural flood storage and reconnect rivers to their flood plains.
The project will see the creation of new wetlands in several parks in the Silk Stream catchment which will help build flood resilience, improve water quality, boost biodiversity and provide valuable blue/green spaces for people to enjoy.
Sustainable Urban Drainage Systems (SUDS) such as rain gardens will be created in the urban streetscape to help remove pollutants from road run-off and slow the flow of water entering the surface water sewer system.
The project will also enlist the help of Thames Water, using innovative ‘thermosensors’ to discover where surface water is entering the foul network as part of efforts to address sewer flooding and the serious issues pollution that affect the catchment.
By using a variety of solutions and looking at the catchment as a whole the project will create tangible environmental benefits and allow for learning that can help replicate these benefits across the broader Brent Catchment and beyond.
Get involved
Contact us at silkstream@thames21.org.uk if you have any questions to find out how you can get involved.
River Brent catchment area
GLA Brent flood risk areas LINK
A press release from the London Mayor, Sadiq Khan, on September 23rd reported on Climate Vulnerability Mapping carried out ahead of COP26. LINK
It said:
The boroughs at particularly high risk, meaning that the risk of both flooding and overheating are very high, jeopardising lives and livelihoods are:
A combination of factor contribute to flooding including over-flowing rivers; reduced permeability due to development, including reduced green space and the paving over of gardens, and drainage systems unable to cope with extreme weather events.
Aware of this, Brent Friends of the Earth last week conducted a Flood and Nature Awareness walk from Wembley Park to Stonebridge Park along the Wealdstone Brook and the River Brent. This article provides some of the background requested by the walkers.
The top image above shows the catchment area of the River Brent with Wembley at its centre. The lower image is the flood risk of all types captured in the Climate Vulnerability Mapping. Unfortunately there is no data for the immediate Wembley regeneration area but the 'High Risk' vulnerability is clear. The map is interactive so you can zoom into different areas by following the link.
The maps below whilst not so up to date gives more detail - the darker the blue the more vulnerable to flooding. Light blue is surface flooding:
Ten years ago Brent Council's Surface Water Management Plan said: LINK
Finally, a combination of poor historical planning decisions, urban creep and infill development has had a further detrimental impact on the ability of the Borough to hold back the rain where it falls, Thames Water have calculated that there has been a 17% increase since 1971 in impermeable area across North West London, as residents have added extensions or have paved over front gardens. This results in greater volumes of surface water for each rain event entering the system. This effect accumulates further down the system where the increasing volumes create greater pressures on the below ground piped assets, tending to result in overland flood flows, increasing frequencies and levels of discharges at overflows and flooding of peoples properties with contaminated foul and commercial wastewaters.
The amount of impermeable land in the borough must have increased greatly since then.
Wikipedia records fluvial flooding LINK:
Local resident John Timms who has studied the 1977 flood in detail says that in fact the flow of the Wealdstone Brook had already increased significantly before the Welsh Harp sluice gates were opened and had caused flooding in Kenton and flooding followed down river with the draiage system unable to cope.
Laurie Pavitt, MP for what was then Brent South presented a petition to the House of Commons:
With your permission, Mr. Speaker, and that of the House, I beg leave to present a petition signed by 588 of my constituents who seek relief from the acute anxiety that arises especially among the elderly, in my area whenever there is a heavy downpour of rain.
The petition sheweth That 71 households were flooded with sewerage water following the heavy rainfall on 16th and 17th August 1977. That this disaster has caused severe physical, mental and financial distress, and that investigations reveal that these floods were not unexpected, and according to expert engineering opinion the risk of further flooding has been rapidly increasing due to extensive new building developments and drainage systems. Planned and approved alleviation works have not been implemented and the reason given for this failure has been the shortage of finance. At a time of cuts in public expenditure which affect all citizens, the people of Stonebridge have had the additional burden of living through a disaster which has destroyed the contents of the ground floors of their homes, with all the consequent hardship and suffering. Nor will they have the wherewithal to replace their losses, as most families have a weekly wage and live from week to week.
The petition concludes: Wherefore your petitioners pray that your honourable House by legislation or otherwise ensure that:
(1) full compensation be paid adequately to restore that which was lost.
(2) the Ministry of Agriculture, Fisheries and Food shall, in conjunction with the Greater London Council, seek to implement a satisfactory flood alleviation scheme as a matter of urgency.
(3) temporary works and an effective flood warning system be put into operation immediately and that the lowering of the 1126 water level in the reservoir known as the Welsh Harp shall have high priority.
If you or your family were affected by these floods, and particularly if you have any photographs, John Timms is keen to hear from you for his research. Write to me at martinrfrancis@virginmedia.com and I will pass it on.
This was the background to our walk which started on the bridge over the Wealdstone Brook on Bridge Road.
Wealdstone Brook serving as a green corridor from Bridge Road (north side)
Brook Avenue, named after Wealdstone Brook which flows alongside it, is the site of planned tower blocks on the station car park (currently subject to a Public Inquiry) but has also been ear-marked in the Local Plan as a potential site for development between the avenue and the brook.
The surburban side of Brook Avenue where gardens back on to the brook
The modification to the Local Plan both suggests development of the site, including a larger Premier Inn, and enhancement of the brook area:
The Premier Inn site provides the opportunity to provide a more defined edge to Wembley Park Drive/Brook Avenue and introduce an active frontage containing main town centre uses.
The site is adjacent to a mixture of residential and commercial buildings up to ten storeys. Within this context, development that is taller than the existing two storey suburban dwellings will be acceptable to the eastern side of the site, stepping down towards the residential buildings to the west of the site which is identified as an intensification corridor along Forty Avenue.
· A minimum of 8m setback from Wealdstone Brook will be sought. Development will be required to positively contribute to the biodiversity, improve access to the waterway and provide an appropriate landscaped setback which may include public open space.
· The building line should be closer towards Brook Avenue.
The brook flows beneath Bridge Road to the College of North West London on the south side. Here it emerges into a small green space with mature trees and some landscaping.
College of North West London Grounds
The College building is adjacent to a major redevelopment site called the 'Fulton Quarter' which includes the retail park, McDonalds and the former studios, currently the temporary Troubadour theatre. The College site is also due to be redeveloped.
According to John Timms in the 1977 flood this park of the brook reached a height of 11-1/2 feet.
However, the modifications to the Local Plan concentrate on surface water:
The site is in flood zones 2 and 3a and susceptible to surface water flooding. All proposed development will require a detailed Flood Risk Assessment (FRA). Development must be consistent with the recommendations of the Brent Strategic Flood Risk Assessment Level 2.
Due to the site’s location in Flood Zone 3a, the ‘sequential approach’ at site level should be applied to steer more vulnerable development such as residential, student accommodation, hotels, and certain community uses towards areas of lowest risk within the site; north west area and southern edge.
Associated infrastructure including water attenuation tanks, and the diversion of any utilities and services to accommodate the development.
· Green and sustainable infrastructure should be part of the development process and the development.
Most significantly a paragraph follows in bold that is repeated for many of the developments, including Brook Avenue, covered in the Local Plan Modifications, which really requires additional scrutiny. Who in Brent will provide it?
Waste water facilities enhancement Thames Water has indicated the scale of development is likely to require upgrades to the wastewater network. Thames Water will need to be engaged at the earliest opportunity to agree a housing and infrastructure phasing plan to ensure essential infrastructure is delivered prior to the development creating identified additional capacity requirements.
The Fulton Quarter (yellow) with CNWL and Wealdstone Brook bottom left. Numbers equal storeys.
The Wealdstone Brook is culverted beneath Olympic Way and emerges next to 1 Olympic Way which has recently been converted from office accommodation to housing. Previously, as with the neighbouring Michaela School building, and as planned for the Fulton Quarter, the ground floor was not occupied, presumably because of the flooding risk.
Wealdstone Brook emerges from beneath 1 Olympic Way
The brook is canalised here and very soon is out of view as a platform has been erected over it:
Now the brook meanders either side of North End Road with the attractive low rise Empire and Danes Court contrasting with the high rise developments. Soon we come across an interesting new development that was faced with the problem of potential flooding. It is on the former Amex site and as you can see from the diagram surrounded on what is almost three sides by the Wealdstone Brook.
The planners recognised the flood risk:
The NPPF requires the Exception Test to be applied in the circumstances shown in Table 3 of the ‘Planning Practice Guidance: Flood Risk and Coastal Change’. Paragraph 102 of the NPPF makes clear that all elements of the test must be passed for development to be permitted. Part 2 of the test requires the applicant to 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.
The flood modelling prepared by the applicant shows that North End Road would be inundated in both the 1 in 100 35% climate change event and the 1 in 100 70% climate change event, which appears to be the only access/egress route. This means that safe refuge within the development is required for future occupants as safe access and egress cannot be achieved.The finished floor levels of the development have been raised above the 1 in 100 chance in any year, including an allowance for climate change flood extent. This means that floodwater is unlikely to enter the property during a 1 in 100 chance in any year plus climate change flood extent.The applicant has overcome the EA’s previous objection by submitting an acceptable emergency flood plan framework to the local planning authority that deals with matters of evacuation and refuge to demonstrate that people will not be exposed to flood hazards.
Since the development was completed North End Road has been reconnected with Bridge Road at a very steep junction which in extreme torrential rain could see a flood of water coming down the road.
This development also raises a continuing problem - that of the pastekl drawings of the development versus the harsh reality. The long term plan to utilise and enhance the Wealdstone Brook as a feature was addressed in the application's depiction of a waterside walk. At the time it was unclear whether this would be open to the public - another long-term plan. It was festooned with Private notices when we dropped by. Compare the artists's impression with the reality.
The brook now runs past industrial buildings and another ptential development site named rather anonymously 'Central Place' -. It is between Fulton Road and Fifth Way with Wealdstone Brook to the north. There is a big warehouse and car park occupying the site.
The Local Plan Modification states (NB items in bold:
North of the site is the SINC Grade II Wealdstone brook. The site is recognised as a waterside development, as such, developers will be required to contribute towards restoration and naturalisation of the Brook, improve access to the waterway, provide appropriate landscaped setback, enhance water quality and biodiversity.
· Small sections of the site is susceptible to surface water flooding. The site is also adjacent to flood zone 3a (fluvial and tidal) so an appropriate buffer zone along the brook will remove the developable area of the site of any major risks.
A critical trunk sewer runs through this site which would need to be considered.
A buffer strip of at least 10m wide should be retained for a publicly accessible brook side park to allow for a cycle way/footpath, associated landscaping, tree planting and street furniture as agreed in consultation with the Environment Agency and Brent Council.
Infrastructure Requirements
· Developers would be required to contribute towards restoration and naturalisation of the SINC Grade II Wealdstone brook.
· Further master planning work will provide additional requirements.
· Green and sustainable infrastructure should be part of the development process and the development.
· Thames Water has indicated the local water network capacity in this area may be unable to support the demand anticipated from this development. Upgrades to the wastewater network are likely to be required. Thames Water will need to be engaged at the earliest opportunity to agree a housing and infrastructure phasing plan to ensure essential infrastructure is delivered prior to the development creating identified additional capacity requirements. Public sewers cross or are close to the site. The risk of damage during construction must be minimised. It must be ensured that development doesn't inhibit access for maintenance or the services in any other way.
There is quite a lot of vagueness in all this and as we have seen pretty plans sometime turn into something much less and there does not seem to be a reliable process, with staff availability low after government cuts,to make sure promises are delivered.
As a result over concerns over potential flood danger as a result of climate change and severe weather events, now with the addition of Sadiq Khan's warning, I have put two questions to November's Full Council meeting:
In the light of the increased prevalence of extreme weather events as a result of climate change and recent flooding in the borough, as well as a large number of new developments and increasing numbers of paved over gardens, does Brent Council:
Intend to work with partners including the Environment Agency and Thames Water to review and revise Brent Council’s
1) Flood Risk Management Strategy
2) Surface Water Management Plan
and advise property owners and developers on mitigation measures?
Look out for Part 2 where we walk from Brent River Park to the North Circular at Stonebridge
NOTE
In case you feel you need to know more about how to react in a flood as a reesult of reading this article this is the guidance from Brent Council:
Be Aware. Be Prepared. The time to think is now don't wait until it happens.
See how putting a grab bag may will help you to respond see the preparing for an emergency page.
If your house is potentially at risk from flooding here are some key things to remember.
If you are in a flood risk area find out if you can
sign up to the Environment Agency's free 24 hour Floodline Warnings Direct
service by calling Floodline on 0345 988 1188 (or Type Talk: 0345 602 6340).
You can select to receive warnings by phone, text or email.
Keep details of your insurance policy and the emergency contact numbers for
your local council, emergency services and Floodline quick dial number
somewhere safe - preferably as part of your emergency flood kit.
Know how to turn off your gas, electricity and water mains supplies.
If a flood is forecasted, take valuable items upstairs and take photos for insurance purposes.
Leave internal doors open, or ideally, remove them and store them upstairs.
Outside the house
Move anything not fixed down into a safer location, e.g. dustbins, garden chemicals car oil and similar.
Move your car to higher ground to avoid damage.
Weigh down manhole covers outside the house to prevent them floating away and leaving a hazardous hole.
See our page about who to call regarding drains and gullies for more advice.
For more information on preparing for a flood and other publications visit the Environment Agency's website
Sandbags
We do not supply sandbags or flood protection products directly to the public.
Builder's Merchants and DIY Stores may have sandbags available.
If you can't obtain sandbags, you can make them yourself by filling things like compost bags, old pillowcases or carrier bags filled with earth or sand.
https://www.brent.gov.uk/emergencies/severe-weather/flooding/
