BREAKING: Call for multi-agency action on threat of severe flooding of the Wealdstone Brook in Kenton

 

The course of the Wealdstone Brook causing concern over flood risk

Following a series of  recent first hand observations of the Wealdstone Brook between Becmead Avenue in Harrow and the Falcon Way bridge in Brent, John Timms MBE – a local expert hydrologist with a wealth of knowledge and 35 years of experience on hydrology issues including the Wealdstone Brook - and John Poole, a local Kenton resident for 50 years whose garden also backs on to the Wealdstone Brook, have both concluded that they are very concerned about the potential impact of a severe storm event in the Kenton area of the Brent catchment.

 

The lack of Wealdstone Brook base and bank maintenance and observed obstructions in the brook have led us to conclude that there is the potential for a serious flooding event the next time there is a torrential downpour which can cause the brook to fill up rapidly, for the water in the brook to move at a speed approaching 2.5 metres per second and a discharge of 20 cubic metres per second, for the foul surface and foul sewer network to reach maximum capacity quickly and overflow creating a major flooding event in the area.

 

On the 16^th and 17^th of August 1977 1,200 homes and business were flooded to a depth of up to 1.5 metres in the Brent catchment. The factors that exacerbated the flooding then are still present 45 years later and John Poole personally witnessed the event in 1977.

 

We are issuing this joint statement because, although Thames Water is presently carrying out its legal duties in locating and dealing with sewage and surface water pollution of the Wealdstone Brook in Harrow and Brent, we do not believe that the agencies with responsibility for maintaining flood risks in the area, namely Harrow and Brent councils, Thames Water and the Environment Agency, are taking the necessary action to reduce the risks from potential flooding in the area.

 

We have photographic evidence of potential obstructions in the Wealdstone Brook which, during a severe storm event, may cause blockages of culverts along the open length of the brook, which is mainly in Brent, with consequential flooding of residential and public properties.

 

We call upon Brent and Harrow Councils, Thames Water and the Environment Agency to find ways of working together with local stakeholders to urgently find a resolution to these issues of the maintenance of the Wealdstone Brook in order to reduce the risks of flooding in the future. This should include recommendations to improve resilience to future flooding events as well as implementing locally the final recommendations in July 2022 of the Independent Review into the severe flooding in London on 12 July 2021 and 25 July 2021.

 

Climate change means extreme storms will produce significant London flooding in the future, Independent Review concludes- even if all its recommendations are implemented

 The Stage 4 report of the Independent London Flood Review, commissioned by Thames Water, has now been published.

 

After reporting on its recommendations (see below) it is noteworthy that it concludes:

 

An important finding of the Review is that, even if all of our recommendations were taken up by the relevant organisations, we would still predict significant flooding when this type of extreme storm events occur, and due to climate change these events are predicted to become more frequent. As a result, the various organisations that have responsibility for managing flood risk will need to plan, work and invest together to reduce the impacts of flooding in the future.

 

As Kilburn was hit by the double whammy of surface water and sewer water lfooding, and there are other potential flood areas in the borough as posts on Wembley Matters have indicated, it is imperative that Brent Council Scrutiny investigates the issue further in the light of the Review's recommendations

 

Non-technical summary  (Full Report HERE)

Lidding Road planning application near Wealdstone Brook, returns to Planning Committee after Thames Water commentary

 The planning application for the development of garages at Lidding Road in the north of Brent was deferred last December after councillors heard representations from the Friends of Woodcock Park on sewer capacity and flooding in the area of the development which is close to the Wealdstone Brook. LINK

 The application was for demolition of the existing garages and redevelopment to provide 3 self-contained
flats and 5 dwelling houses; with associated car parking, cycle storage, refuse
storage, amenity space and landscaping

The application is back at Planning Committee on April 20th with a detailed response from Thames Water. Officers continue to recoemmend approval of the application.

Officers' Report extracts:

Members will be aware that the application was first reported to Committee at the meeting on 15 December 2021 where the committee agreed to defer a decision on the application in order to:

1. seek further details and assurance from Thames Water in relation to the impact of the proposed development on drainage and the maintenance of the sewerage infrastructure and how these would be mitigated;
 

2. seek further details on the location of the flooding incidents identified within the Flood Risk Assessment; 

 

3. seek further details on the proposals to alleviate concerns regarding the access of construction traffic to the site via Gooseacre Lane as part of the Construction Method Statement and Logistics Plan to be secured via condition.

Impact of the proposed development on drainage and the maintenance of the sewerage infrastructure and how these would be mitigated

 

In the Committee members raised concerns regarding flood risk impacts on the site. Specific concerns were raised regarding the potential for the voids under the houses to be blocked by residents; the ability for Thames Water to access and service the pipes where necessary. Additionally members raised concerns over the potential impact of the development on pollution in the Wealdstone Brook and further details were requested regarding any projects to clean the Brook.

Since the application was deferred, further comments were received from Thames Water regarding impacts of the development. It should be noted that these comments relate only to flooding that may rise from foul or surface water flooding. Flooding from other sources (such as the Brook) fall outside the statutory responsibility of Thames Water.

They consider that there is sufficient capacity and that the flow expected from the development would be exceptionally small. They have specified that they have no concerns over the risk of foul water flooding as part of the development. Additionally, they consider that the development would not result in an increase to the pollution of the Wealdstone Brook.

With regard to the concerns raised by residents about the sewers, Thames Water have specified the following:

We acknowledge concerns raised by residents about the performance of the foul sewers in this area. These have not been caused by the capacity of the sewers but by sewer blockages. Sewers are only designed to take water from toilets, sinks, baths and showers along with human waste and toilet tissue. Everything else should be put in the bin.

Sewer blockages in this area are predominantly due to fats, oils and grease being inappropriately put down the sewer. This then clogs the pipes, which causes the foul water to back up and eventually flood out of the sewer.

Sewer capacity is when the pipe is too small to accommodate flow and it can eventually back up and eventually cause flooding. Increased flow to the foul sewer from new developments has the potential to increase the risk of flooding due to sewer capacity. From our knowledge of the current flow in the sewer in question and the expected increase due to this development we are confident that the receiving sewer has sufficient capacity to accommodate the proposed flows. If we had concerns that capacity did not exist to serve this development, it would initiate Thames Water funded modelling investigations. Our initial assessment of this site shows this is not necessary.

They also note that with regards to surface water flooding there would be an overall reduction in flood risk due to the increased flow rates identified in the drainage strategy.

With regards to access to the sewers, Thames Water have confirmed that the applicants have engaged with them during the course of the development and a build-over agreement has been proposed. Thames Water raise no objections or concerns in regards to this and note that such matters are usually dealt with post-approval via Building Regulations.

The applicant has also advised that they already have details of the existing line, level and condition of the existing sewers within the development boundary prior to development, from undertaking drainage CCTV condition and utilities surveys in 2020. The flood risk consultant has therefore suggested that a post-construction drainage CCTV and conditions survey is undertaken of the Thames Water assets within the redline boundary to confirm that there has been no damage to the existing sewers during construction. Any damaged and/or blocked pipes could then be reported to Thames Water for repair. Such details could be conditioned to any forthcoming consent.

With regards to pollution in the Wealdstone Brook, colleagues in the Parks team have provided further information on the existing circumstances. They note that most of the pollutants in the water would have originated upstream and flowed down into Brent towards the River Brent.

Brent Parks Service are working on an early-stage scheme to improve the structural and wildlife diversity and amenity section of the Brook through woodcock Park. Additionally, the catchment area of the brook is mainly located in Harrow and Harrow Council has ongoing projects to improve the brook.

Thames Water have an on-going programme looking at addressing the issues with water quality in the Wealdstone Brook, and have specified the following:

We recognise that there is a significant issue with water quality in the Wealdstone Brook. We host a “Friends of the Wealdstone Brook” quarterly meeting where residents, the Environment Agency, Lead Local Flooding Authorities are other interested stakeholders can meet and engage on the issue. This allows us to share water quality data for the watercourse, our operational activity and longer-term investment plans with interested stakeholders. The group is attended by the NERC funded CAMELLIA project (Community Water Management for a Liveable London) consisting of many academic partners including Imperial College, British Geological Survey, and Oxford University. We completed an extensive Catchment Study on the Wealdstone Brook in 2016/17 that assessed the root cause of poor water quality and flood risk in the area. Following that study, we have a long-term list of improvements we propose to make to the sewer system. As water quality and flood risk are intrinsically linked, we have to start by creating capacity in the river system. We are in discussions with Harrow Council about a potential scheme to do that.

 

Once details are available, we will share them. We hope to promote a similar scheme with Brent Council in the future. Thames Water conclude their further advice by confirming that they have adequately assessed the impact  that the proposed development will have on the sewer system and that they are confident that the development will not cause a deterioration to the level of service residents receive at present.

Location of the flooding incidents identified within the Flood Risk Assessment

In the committee members noted that the flood risk assessment identified 66 flooding events at postcode ‘HA3 0’. It should be noted that this postcode zone encompasses a larger area stretching from Kingsbury to Northwick Park and including the area between Kenton Road and Preston Road.

In response to the above, the applicants have requested a Sewer Flooding History Enquiry from Thames Water. This has selected 1 Lidding Road as the centre point but encompasses a wider area around this address. The report notes that there have been no recorded flooding events in the area as a result of surcharging public sewers.

With regards to the potential for the voids to be blocked, the applicants have agreed that a planning condition can be attached requiring a verification report to confirm that the relevant measures have been implemented on site. This is intended to include a drainage maintenance schedule which can incorporate checks to the void structure.

Notwithstanding that, the voids are closed in by ‘hit-and-miss’ brickwork leaving several small gaps for water to escape. The gaps are considered small enough to avoid large objects from being inserted into the void space. Additionally, these voids would be located under all plots 1-6. As such, officers consider that the likelihood of the voids to be fully blocked and therefore resulting in undue flooding impacts is low and suitably addressed by the suggested condition

 

 

UPDATED: South Kilburn: Flagship or neglect?

Guest post by Pete Firmin, chair, Alpha, Gorefield and Canterbury Tenants’ and Residents’ Association.

 

Brent Council – with the support of planners and architects - likes to praise its regeneration of South Kilburn as a model for others.

 

Yet, beyond the issue of the dubious quality of some of the new housing built in the area, raised in Wembley Matters many times, there is also a big issue around general neglect of the area.

 

To be clear, the area described here, a small part of South Kilburn, is not due for `regeneration’ anytime soon. It does not figure in any masterplan. Not that, even if it was, this would excuse the level of neglect shown here.

 

Everything here has been reported to Brent Council, individual officers and Councillors dating back to November of last year if not earlier.

 

To start at the steps at the corner of Coventry Close and Kilburn High Road. These broken steps have been reported with no response received.

 

 

This rubbish dump has been growing steadily for the best part of a year and reported many times on the Cleaner Brent App. It just gets closed quickly with no explanation. It is not directly on Brent land but is clearly a health hazard.

 

 

This patch of ground (known to residents as the Bermuda Triangle) was created when regeneration hit the area 7 years ago. They still haven’t sorted out whether Brent or Catalyst is responsible for its upkeep, so it just accumulates rubbish.

 

 

Clearly Brent’s responsibility, overflowing like many bins along Cathedral Walk footpath.

 

Mattresses abound, this one was photographed by an estate officer two weeks ago. It is propped up by the metal frame for previous recycling bins. We were promised when they were replaced (a year ago) that they would be removed.

 

 

Broken pane of glass in door of Gorefield House, reported last November.

 

The wonderful bin store next to Gorefield House. Erected by Catalyst during regeneration. For their residents they put up a brick  bin store, but Brent tenants only get a wooden one, which has been falling apart since it was put up. Too near the flats, overflowing bins, never fully cleared. We’ve been told someone in an office worked out how many bins are needed for the number of households…..

 

 

5 of these 7 lights along a footpath created in regeneration have been out for more than 5 months. We’ve been told the issue has been escalated…..

 

 

Damage caused by the flash flood last July. Brent had to be pestered to do anything at all, but we have been left with this botched job which is causing accidents. 

 

 

I could go on, like the numerous street lights not working (one of which has never been connected to the mains), the lift out of order for over a year, and much else, but I hope you get the picture one of a Council which doesn’t seem to care.

 

Pete Firmin

 

EDITOR'S NOTE: Pete's problems in getting responses is well illustrated by this exchange that took place only yesterday.

 

 

 

Thames Water and Environment Agency will attend Brent's January Scrutiny Committee to answer urgent questions on the flooding threat

 

  Recording of November 10th Public Realm and Resources Scrutiny Commitee

The recent Resources and Public Realm Scrutiny Committee heard a heart-rending story from a local resident about her experience in the recent Kilburn floods and from Brent Council officers about the authority's responsibilities regarding flooding and fluvial and surface water occurrences. 

Unfortunately the Council's main partners, the Environment Agency and Thames Water did not attend but will do so in January 2022. The officers' Report can be found HERE.

 

Ruined household items after the July floods on Westminster side of Kilburn Park Road (My London News)

The importance of hearing directly from Thames Water is highlighted by this extract from the My London News coverage of the July floods LINK:

Speaking to the subcontractors working for Thames Water attempting to lower water levels in the drains next to her property, [Aimee] asked about the chances of it happening again, to which one engineer reportedly told her: “The whole system has been compromised. Of course it will happen again.”

Aimee, who is eight months pregnant, claims an engineer employed directly by Thames Water then took the subcontractors to one side in order to speak with them alone.

The following day, she says she was visited by a Thames Water employee who 'looked more senior' and told her the subcontractors 'should not have said that'.

But, when pushed, Aimee claims the engineer couldn't say the flooding would not happen again.

Post flood 'repair' photographed recently on my visit to South Kilburn Estate

As readers will know Wembley Matters has published a number of articles recently on flooding in the area in the light of the number of increased extreme weather events as a result of climate change. I posed a question to the November 22nd Full Council on this and the question and response are below:

1. Question from Martin Francis to Councillor Krupa Sheth, Lead Member for Environment

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:

(1) Intend to work with partners including the Environment Agency and Thames Water to review and revise Brent Council’s

(a) Flood Risk Management Strategy
(https://www.brent.gov.uk/media/16406897/flood-risk-strategy-sept-2015.pdf)

(b) Surface Water Management Plan
(https://www.brent.gov.uk/media/3501160/W8.3%20Brent%20Surface%20Wate
r%20Management%20Plan.pdf)

(2) Advise property owners and developers on mitigation measures?

Response:

Under the Flood and Water Management Act 2010, Brent Council is responsible for reducing the risk of flooding from surface water, groundwater and ordinary watercourses as a Local Lead Flood Authority (LLFA). To continue to meet our responsibilities we:

· Develop, maintain, regularly update and apply a local Flood Risk
Management Strategy. The overarching aim of the strategy is to enable the long-term management of flooding arising from rivers, surface water and groundwater in the borough and to communicate the risks and consequences of flooding to our residents and businesses.

· Maintain a register of flood risk management assets (structures that have an effect on flood risk management). This includes all flood risk management assets such as culverts, watercourses and holding tanks. All drainage assets, including the Council maintained and maintained by Thames Water and Environment Agency are logged on Flood Station.

· Provide overall management for highway drainage (road gullies) on designated public highway. As Highway Authority, we manage the 20,700 road gullies within the borough via a cyclical cleansing regime, and also respond reactively to any defect or blockages on the network.

· Implement small scale schemes to address localised flooding problems such as broken gullies or gully pipes, or localised gully capacity problems. Larger scale capacity problems are within the remit of Thames Water who are responsible for the main drainage system.

· Respond to planning applications - As lead local flood authority, we are a statutory consultee for major developments and in accordance with the GLA plan for Sustainable drainage we ensure that a significant betterment (i.e. improved drainage arrangements) is incorporated into new developments.

This in turn reduces the risk of surface water flooding on our public highways.

· Produce and maintaining a flood risk asset register - All of our drainage assets are located on an asset register, which includes all non-tributary watercourses, culverts and attenuation tanks.

· Issue land drainage consents on ordinary watercourses and carry out enforcement - All works undertaken non-statutory main rivers must obtain consent form the council so we are able to oversee and audit all processes to ensure sustainable measure are undertaken.

· Investigate significant local flooding events - As a lead local flood authority, we investigate all major flooding incidences and record the data.

As LLFA the council works in partnership with utility companies, Environment Agency and others in order to ensure that all appropriate measures are taken to mitigate flood risk. Plans are regularly reviewed and updated as risks and other factors change.

As a Category One Responder under the Civil Contingencies Act, the council has a responsibility to warn, inform and advise the public before during and after emergencies have occurred. We publicise warnings of severe weather and provide advice and information for residents on the council website to assist them prepare for potential severe weather events such as those that may cause flooding. The information provided also outlines what assistance the council is able to offer as well as measures that people can take to protect their own homes.

 

Suggestions for flood mitigation measures in South Kilburn in the face of over-development

 An attempt at an Underground style map of London's 'lost rivers' and sewers (Heritage Magazine)

A follow-up post to  David Walton’s 'After the July floods urgent action needed on the depleted flood defences of South Kilburn as densification continues'. Proposed here are some sustainable environmental actions for Brent Master Developer to apply to its large South Kilburn site.

Brent as the South Kilburn Master Developer relentlessly prepares building designs, complete with planning permissions,  gift wrapped for hard to trace private enclosure, for freehold buyers/ builders on publicly owned existing South Kilburn flood defences.  All this amidst existing publicly owned social housing. Surely it constitutes major government intervention in the markets. the direct opposite of what government claims it stands for?

 

What makes off-shored private equity so worthy of being made this special case?

 

On the South Kilburn floodplain, government has designated a very large site/ growth area/ tall building zone; with 'site allocations’, Brent designed with planning permissions already in place ready for sale to private developers. The key for South Kilburn residents’ human rights, safety and future wellbeing must be that the River Westbourne and its tributaries existence should no longer be ignored by government.  Decision makers are frantically trading proposed new building site allocations with planning permissions in this flood plain zone. A third of England's flood defences are in private hands, but what about the two thirds which are in public hands and under government guardianship?

 

The deliberate denial of obvious flood risk, when comprehensive natural flood defences were designed and were protectively already in place (the estate’s original housing in designed flood protection park land), is an apocalyptic 'cancel- for- market' strategic device not used before in London. And not unlike using inflammable materials to cheaply build new homes or attempting to allow a deadly virus with no vaccine or cure to rip through society for herd immunity, this human exploitation scandal also deserves an emergency re-think, if all buildings in this water world area of London both old and new are not to be, by this environment cancel sleight of hand rendered  'sick buildings' by year 2041.

 

All South Kilburn natural flood defences which have survived this brutal public flood defence's land transfer to the market must in 2021 be strongly protected, highly valued and CIL upgraded as recreation and natural water store public spaces. While flood defences already been destroyed and replaced by new 'sick building private enclosures',  CIL funded replacements nearby must be installed in a new spirit of  real world UK climate emergency action. And why not restore residents on a partnership board for South Kilburn's very large site to steer and oversee the 35+ new 'sites' towards 2041?  The age of highly lucrative ignoring of environmental concerns and residents’ total exclusion to enable  'smooth process', clearly needs to end given the emergency situation which has become all too apparent to everyone living here. You walk past new blocks and smell the damp!

 

A basic principle for the large South Kilburn site, given its extensive flooding history and ever rising floodplain water table, should be that water is retained safely on site and that roads are no longer designed to function as sewage canals bringing ever more water down from Camden and St John's Wood and then exporting that excess on to parts of Maida Vale from South Kilburn land.

 

Living roof gardens, water butts and genuine estate wide active growing initiatives should be urgent policy for all developments (old and new) - the principle being to control water before it overloads London's crumbling Victorian drainage system from this mega density 36,000 new town called South Kilburn ‘Colony’. In Costa Rica a pioneering Earthshot winning project pays local citizens to restore natural ecosystems and has led to incredible levels of environmental protection and awareness. Why is this considered impossible in South Kilburn’s very large site development?

 

 The River Westbourne flows above Sloane Square station

 

1. This 'very large site' of clearances/ new builds ongoing since 2005 is mainly car-free housing given that two underground stations and a rail station are located in this zone. Instead of increasing adopted roads (sewage flood canals) in grids (the current hardscape in Brent’s rigid plan)- perhaps generous scale green, plant growing, active travel routes is the progressive and climate response and the  best way to develop movement and to link this with protecting and improving the plan that currently neglects surviving South Kilburn flood defence parkland?

 

All Brent highways land in South Kilburn tall building zone's 45 hectares can be re-purposed as flood defence active travel, plant growing ,widened green corridors.

 

As well as this being good for Brent taxpayer's long-term, just look at the 'sick buildings' scandals throughout South Kilburn, where for example it now costs more to repair buildings new built on a flood defence than it originally cost to first build them! A ‘flood risk always reduced from now on ‘approach as proposed here would be good for Carlton vale, good for Maida vale, good for Bayswater and good for Knightsbridge, where the River Westbourne and its tributaries flow.

 

2. Building on every South Kilburn space should be seriously questioned.

Where will extra water gathering on this floodplain go if not into people's homes (old and new) given the water always present near the surface? South Kilburn Land simply never dries-out!

 

Government should no longer environmentally cancel the River Westbourne and its tributaries as policy. COP 26 and Brent Councils own long declared 'Climate Emergency' need to become real (not zoned) for South Kilburn peoples’ lives and this estate of 'sites' all too obvious flood risk environment recognised. Note my neighbours’ living at ground level are flooded out and living in temporary accommodation along with many other local flood families. Dehumidifiers are still drying these flats out and it is November!

3. Opportunities to upgrade rather than total destroy South Kilburn's entire surviving rivers flood defence system also include:

a. Making more space for water. Higgins, a developer at Chippenham Gardens village, South Kilburn where the River Westbourne and the Malvern join is building 56 flats on top of this flood risk basin to Brent Master Developers’ design. Local people have managed to protect the historic flood defence local (reduced in size) park also located here (this based on veteran trees being preserved). However, Brent remains rigidly opposed to improving the flood defence 'pond' potential of this green space by expanding its size, scale, space, volume and depth, by re-purposing three adjacent parking bays and then squaring this off as replacement for flood defence land lost to the new Higgins development.

Plenty of children live in flats above and in basements below, the 50 plus Victorian shops of Chippenham Gardens local centre without gardens or balconies. As it currently stands this green space flood defence will be considerably reduced in size by Brent’s over-building ( so no play equipment space anymore) and will also be design ineffective in its core purpose of protecting lives and homes in this densely populated key local centre (where 11 routes and 3+ rivers meet) from sewage flood major risk liability. Given July floods such disregard of this very specific flood defence improvement 2021 opportunity seems reckless and ill advised.

 

b. Give Local Green Space Designation to South Kilburn Public Open Space, Brent Kilburn’s only remaining park scale natural flood defence. This large park forms an excellent rain garden, pooling surface flood waters for a week then gradually absorbing them. Vital to public health and safety of this very large site and clearly should no longer be Brent 'banked' as surplus brownfield flood defence land for sale with Brent building designs/ planning permissions.

This 100+ veteran tree woodland space must be strong protected with a Local Green Space Designation policy by Brent being climate actioned  for 2021. (The grass cutting tractor could also leave 2 metre of space wild around all 100+ trees to better support the local ecosystem and increase flood waters soak-up speeds yet further).

c. The removal of the large roundabout park of 40 trees flood defence on Kilburn Park Road in 2008 which also used to retain, pond and absorb flood waters has as a result become sewage flooded with highly problematic sick buildings instead.

Westminster has a retirement home that has become a ‘development site' with green space opposite this Brent major flood defence loss. Tanked/sealed underground car parks (once pumped of rising flood plain ground water), mean that Westminster developers can send its entire future excessive water problem on and into Brent homes, particularly into a brand new high density housing scheme which Brent has recently purchased! This Westminster 'site' could work well as a new underground flood water storage defence instead. Veteran trees on this site also need protecting.

Beyond this, Westminster is also re-developing its Carlton Vale Estate NW6 high quality social housing- to become towers instead? This re-development will also have a catastrophic effect on Brent's floodplain downstream. especially if the River Westbourne and tributaries remain ignored by all key decision makers as is the case in 2021.

Brent should challenge Westminster on these all too obvious sewage flood liabilities being adversely across borough boundary grown. The National Planning Policy Framework (section 14. clauses 152 to 169) form an excellent starting point.  While in a similar way Westminster should challenge Brent about the sewage flooding of Maida Vale Shirland Road directly downstream of South Kilburn’s large site with many rivers.  

d. If South Kilburn wasn't a developer colony where "development will look after itself" other solutions could be sought. In Slovakia I know a town adjacent to an historic flood risk river where the local council helps fund ground water pumps in all gardens to systematically lower the town's water table. It also encourages flood plain allotments on its land. Pumped ground water is used for gardens, allotments and for domestic toilets allowing substantial savings on water bills for locals as expensive tap water is not being needlessly wasted.

e. De-paving and permeable pavers should be required throughout South Kilburn very large site, with replacement of existing poor design new hard landscapes as a remedial measure. similar to the replacement of inflammable cladding and inflammable insulation retrofit that is already happening.

4. Given there will be five times the number of homes by 2041 on floodplain unilateral forced as South Kilburn - should the only new 'community infrastructure' in South Kilburn be tall building zone housing and a 'go elsewhere' zonal policy for all else even flood defences?

How can local estate people living a multiple excluded/ deprived estate zoned existence be expected as individuals to own this deliberate and knowing major government escalation of estate flood risk rooted in an unreasonable planned choice to cancel environmental underground rivers as environmental realities, for the brutal short term and soon to be permanent crisis economic gains? Why should City of Westminster residents own this growing cross borough boundary disaster either?

Add South Kilburn zone concentrated inflammable cladding, inflammable insulation, inflammable structure, build quality crisis and incremental withdrawal of health/ services-all points instead to a humane rethink of what "South Kilburn people getting what they deserve" should actually mean? The UN has in October 2021 declared the right to a safe, clean, healthy and sustainable environment a human right and is to appoint an expert to monitor human rights in this context of climate emergency.

Is a 6,000 social housing estate set in flood defence parkland in year 2000 set to become a 36,000 new town towered on 45 public owned hectares by year 2041, with no flood defences retained? Or can this part of London do better regarding protecting human rights and reducing exploitations growing forwards?

Instead of the current land war on estate residents, a war on excessive flood plain water needs to be declared. A new urban construction model of flood management, strengthening ecological infrastructure and drainage systems is clearly essential in very large site South Kilburn zone given the catastrophic liabilities and consequences of creating a giant cross borough boundary sick buildings area (the present reckless direction of travel/ let the market decide process).

Cities like Tokyo and Singapore are planned and designed to handle one-in-100-year storms. Why is London captured in such pre-Enlightenment wilful regression regarding its own new building of very large site towns such as South Kilburn Colony towards 2041? Regents Park is an impressive part of the flood defences for Central London, while Kilburn Park (South Kilburn) flood defence for Central London has been totally cancelled for profit. Who is liable in 2021 and who will pay for what happens in the future and the damages caused?  

 

David Walton

 

FLASK (Flood Local Action South Kilburn)