2.1. Overview

This section provides an overview of the flood risk policies and requirements on national, regional and sub-regional levels. A local level policies and requirements overview is provided for each of the six Boroughs. The source material is hyperlinked wherever possible, with only the key information stated within this SFRA. The policies referenced in this section may be superseded in time. To ensure that development proposals are in line with the most up to date policy, it is advised that developers, planning consultants and Local Planning Authority officers keep abreast of any changes.

2.2. Key Policies and Requirements

2.2.1. National

National Planning Policy Framework

The National Planning Policy Framework (NPPF) was published in March 2012 by the Department for Communities and Local Government. The document sets out the government’s planning policies for England and how these are expected to be applied. The NPPF provides guidance for Local Authorities to implement localised plans to meet the challenges presented by, amongst others, climate change, flooding and coastal change whilst achieving sustainable development. Paragraphs 94 and 99-104 specifically relate to development and flood risk, with Paragraph 100 outlining the importance of a SFRA:

“Local Plans should be supported by Strategic Flood Risk Assessment and develop policies to manage flood risk from all sources, taking account of advice from the Environment Agency and other relevant flood risk management bodies, such as Lead Local Flood Authorities and internal drainage boards. Local Plans should apply a sequential, risk-based approach to the location of development to avoid where possible flood risk to people and property and manage any residual risk, taking account of the impacts of climate change.”

The NPPF introduces the Sequential and Exception Tests as the means to direct new development proposals to areas with the lowest probability of flooding wherever possible. This SFRA provides the basis for applying these tests. Guidance for the application of these tests within the six Boroughs can be found in Section 4.2.

A Draft Revised NPPF was published in March 2018. The document incorporates a number of proposals brought forward in the Housing White Paper. Part of the revised text in the draft provides a new paragraph on SuDS in major developments. The document states that SuDS should be incorporated as part of major developments unless there is clear evidence that they would be inappropriate. The Draft Revised NPPF is currently under consultation. The consultation draft states that SuDS used should:

  • Take account of advice from the lead local flood authority.
  • Have appropriate proposed minimum operational standards.
  • Have maintenance arrangements in place to ensure an acceptable standard of operation for the lifetime of the development.
  • Where possible, provide multifunctional benefits.

Flood Risk and Coastal Change Planning Practice Guidance

The ‘Flood Risk and Coastal Change’ section of the Planning Practice Guidance (PPG) was initially published in March 2014 and operates in conjunction with the NPPF. As it is intended to serve as a living document, it is subject to periodic updates. This section of the PPG advises users on how to take account of and address the risks associated with flooding and coastal change in the planning process. The section, made up of 86 paragraphs, defines flood risk and how to address all sources of risk. It provides information on how flood risk should be taken into account in the preparation of local plans and what SFRAs should include. Where relevant, specific PPG paragraphs are referenced throughout this SFRA in the relevant sections. The current version of the PPG includes new and updated paragraphs from 2015 and 2016.

Flood and Water Management Act 2010

The Flood and Water Management Act (FWMA) 2010 provides a better, more sustainable and consistent management of flood risk in England and Wales. The FWMA was enacted following the Pitt Review of the 2007 flooding experienced across the country.

The FMWA defines the necessity of co-operation between relevant authorities at national, regional and local levels. It defines the roles of Risk Management Authorities (RMA), the bodies with flood risk-related responsibilities in England and Wales. RMAs includes the Environment Agency (EA), Internal Drainage Boards, Water and Sewerage Companies and Lead Local Flood Authorities (LLFAs). As LLFAs, the Boroughs have several responsibilities under the FWMA:

  • Developing and implementing a Local Flood Risk Management Strategy (LFRMS) – see Section 2.2.4 for information about the six borough’s LFRMSs.
  • Investigating and recording key local flood incidents
  • Maintain a flood risk asset register
  • Coordinate the management of flooding from local risk sources (surface water, groundwater and ordinary watercourses)
  • Regulation of works on Ordinary Watercourses
  • Sharing of information about flood risk

Flood Risk Regulations (2009)

The Flood Risk Regulations (FRR) 2009 set out duties for LLFAs and the EA to produce Preliminary Flood Risk Assessments (PFRAs), flood risk maps which show flooding extents and hazards, and flood risk management plans. These FRR requirements are completed on a six-year cycle and achieve the country’s legal obligations of the European Union (EU) Floods Directive 2007. The Floods Directive’s objective is to provide a consistent approach to flood risk management across Europe. Further information about the Thames Flood Risk Management Plan is found within Section 2.2.2, links to the six borough’s PFRAs and flood risk maps are found within Section 2.2.4.

2.2.2. Regional

The London Plan

The London Plan, last updated in March 2016 (at the time of writing, March 2018), is the Greater London Authority’s (GLA) spatial development strategy plan for London. It sets the framework for development in London over the next 20-25 years, linking key economic, environmental, transport and social priorities. The London Plan was first published in 2004 and has undergone various alterations since.

The London Plan sets out several objectives put forward by the Mayor of London. One of the objectives is to ensure London is a city that becomes a world leader in improving the environment. This includes responding to climate change, which is covered in Chapter Five of the London Plan. Within this chapter are several policies that cover flood risk and water resource matters relevant to this SFRA:

Chapter Seven provides further policies that cover flood risk and water resources. The Blue Ribbon Network (BRN) sub-chapter covers London’s strategic network of natural and semi-natural water spaces, providing policies on the usage, protection and restoration of the BRN.

The GLA’s associated Sustainable Design & Construction Supplementary Planning Guidance (SPG) provides guidance that supports the London Plan policies. Chapter 3.4 of the SPG focuses on flooding and provides links to guidance about sustainable drainage systems (SuDS).

A new London Plan is currently being drafted and expected to be finalised in 2019. Chapter 9 of the draft document covers sustainable infrastructure and includes several policies relating to flood risk and water management, including ‘Policy SI12 Flood risk management’, ‘Policy SI13 Sustainable drainage’ and ‘Policy SI17 Protecting London’s waterways’. Once the new London Plan has been finalised and adopted this SFRA may need to be updated to reflect any changes in key policies. Table 2-2 highlights the key flood risk policies in the both the current and draft London Plan documents. The table summarises the current differences between the two that may trigger future updates for the SFRA.

Table 2-2. Current and Draft London Plan Flood Risk Policy Comparison

Current PolicyDraft New PolicyKey Policy Differences
Policy 5.3: Sustainable Design and ConstructionNo equivalent policy proposedN/A
Policy 5.11: Green Roofs and Development Site EnvironsPolicy G5 Urban greeningThe new policy does not specify objectives for green roof and green wall implementation but does highlight high-quality landscaping and nature-based sustainable drainage as greening measures for major development proposals.
The new policy also states that boroughs should develop an Urban Greening Factor to identify the amount of greening required in new urban developments.
Policy 5.12 Flood Risk ManagementPolicy SI12 Flood risk managementThe new policy highlights development proposals for utility services, stating that they should be designed to remain operational under flood conditions. The buildings should also be designed to facilitate quick recovery following a flood event.
Policy 5.13 Sustainable DrainagePolicy SI13 Sustainable drainageThe new policy introduces a new level in the drainage hierarchy, bringing the number of levels to 8. New hierarchical level placed at number 5 is 'rainwater attenuation above ground (including blue roofs)'. The rest of the hierarchy remains the same.
The new policy also emphasises the need for permeable surfaces in new developments, stating that proposals for impermeable paving should be refused where appropriate. This includes proposals for impermeable paving on small surfaces such as front gardens and driveways.
No equivalent policy Policy D10 Safety, security and resilience to emergencyThe policy states that proposals should maximise building resilience and minimise potential physical risks that arise from flood related hazards.
No equivalent policy Policy G1 Green InfrastructureThe policy specifies that Boroughs should prepare green infrastructure strategies that integrate objectives relating to flood management.
No equivalent policy Policy GG6 Increasing efficiency and resilienceThe policy states that buildings and infrastructure should be designed to adapt to climate change, utilise water efficiently and reduce flooding impacts.
No equivalent policy Policy SD2 Collaboration in the Wider South EastPolicy stated that collaboration with the wider South East region of the country will occur to tackle issues related to climate change, including water management and flood risk.

London Regional Flood Risk Appraisal

The London Regional Flood Risk Appraisal (RFRA), last updated in August 2014, is an accompaniment to the London Plan. It provides a strategic overview of all sources of flooding in London and addresses its probability and consequences. The findings of the London SFRA supports information presented in the London Plan, and provides details which shape the Plan’s policies. The London RFRA was first published in October 2009.

The 2014 London RFRA provides several revised recommendations, which are meant to be used as a monitoring tool on a borough-wide or London-wide level. Progress against these fourteen recommendations is reported annually in the London Plan Annual Monitoring Report. All monitoring recommendations are categorised under one of the following:

  • Fluvial Flood Risk (Recommendations 1 to 5)
  • Surface Water Flood Risk (Recommendation 6)
  • Foul Sewer Flood Risk (Recommendation 7)
  • Groundwater Flood Risk (Recommendation 8)
  • Reservoir Flood Risk (Recommendation 9)
  • Specific Development Areas (Recommendation 10)
  • Main Road Network and Airports (Recommendation 11)
  • Emergency Services (Recommendation 12)
  • Schools (Recommendations 13)
  • Utilities (Recommendations 14)

The contents of the London RFRA are also designed for spatial planners, developers, emergency planners, and infrastructure and utility operators. One of the aims of the London RFRA is to provide spatial planners and emergency planners with a shared understanding and common baseline of information.

A new London RFRA  is currently being drafted and is expected to be finalised in 2019. It provides important evidence that underpins the new draft London Plan. Further revised monitoring recommendations are provided, intended to improve local risk policies and Drain London activities. It is suggested that these recommendations are incorporated into future Local Plan policies and documents once finalised.

Thames Catchment Flood Management Plan

The Thames Catchment Flood Management Plan (CFMP) was published in December 2009 by the EA. Its purpose is to provide an overview of current and future flooding within the River Thames’ catchment area. The Thames CFMP also sets out strategic policies to manage those flood risks over the next 50 to 100 years with climate change in mind.

All six boroughs fall under Sub-area 9, London catchments, in the Thames CFMP (See Figure 2-1). The boroughs fall into either the River Brent sub-area (Barnet, Brent, Ealing and Harrow) or the River Crane sub-area (Ealing, Harrow, Hillingdon and Hounslow). The Thames CFMP preferred policy for the London catchments is Policy Option 4, summarised as effectively managed flood risk areas where further actions are needed to keep pace with predicted climate change.

Three of the boroughs also fall under Sub-area 5: River Pinn sub-area (Hounslow and Hillingdon) and Lower Lee tributaries sub-area (Barnet). The Thames CFMP preferred policy for Sub-area 5 is Policy Option 6 where partnership actions are needed to store and manage runoff in locations with environmental or overall flood risk reduction benefits. The Policy Option states that the approach to flood risk management in these places uses the natural protection already provided by the river channel and the open spaces in the floodplain.

Figure 2-1. Thames CMFP Sub-Area Grouping (Thames CMFP Map)

Three of the boroughs also fall under Sub-area 5: River Pinn sub-area (Hounslow and Hillingdon) and Lower Lee tributaries sub-area (Barnet). The Thames CFMP preferred policy for Sub-area 5 is Policy Option 6 where partnership actions are needed to store and manage runoff in locations with environmental or overall flood risk reduction benefits. The Policy Option states that the approach to flood risk management in these places uses the natural protection already provided by the river channel and the open spaces in the floodplain.

Thames Estuary 2100 Plan

The Thames Estuary 2100 (TE2100) project was established in 2002 by the EA to manage and reduce tidal flood risk through the 21st Century. The inclusion of other sources of flooding, including high river flows and surface water flooding implications on the estuary, resulted in the publishing of the TE2100 Plan in August 2011. A TE2100 5 Year Monitoring Review document was published in October 2016 which provides a five-year review of the TE2100 Plan. The TE2100 Plan, and associated documents, provide recommendations and actions for flood risk management for London and the Thames estuary through to the end of the century and beyond.

Of the six boroughs, only Hounslow lies within the TE2100 policy area, falling under Action Zone 1 (‘West London’). The Plan introduces two policies that are applicable to Hounslow to strategically manage flood risk from tidal and high river flow sources in the TE2100 Plan area:

  • P3: Continue with existing or alternative actions to manage flood risk. We will continue to maintain flood defences at their current level accepting that the likelihood and/or consequences of a flood will increase because of climate change.
  • P5: Take further action to reduce the risk of flooding (now or in the future).

There are also six recommendations for implementation by the Borough. Further details can be found under the Hounslow section in Section 2.2.4 of this document.

Thames River Basin Management Plan

The Thames River Basin Management Plan (RBMP) is part of a series of river basin district (RBD) documents that aim to provide a framework for the protection and enhancement of the benefits provided by the water environment. Prepared by the EA, RBMPs fulfil the requirements of the EU’s Water Framework Directive (WFD) and are updated on a six-yearly cyclical basis.

The current Thames RBMP was produced in 2015 and is the second of a series of six-yearly cyclical planning documents. It covers the entire Thames river system, and includes contributory and interconnected rivers, lakes, groundwater and coastal waters. The document provides a set of measures as part of the main programmes, and local measures for catchments within the Thames RBD. As highlighted under the Thames CFMP, the six boroughs fall under either the London Brent catchment or the London Crane catchment. Hillingdon also falls within the Colne catchment and Barnet has a small overlap with the River Lee catchment (via the Pymme’s Brook tributary of the River Lee). As part of the local measures sections, priority WFD issues, contributions to environmental outcomes for 2021, and future aims are all highlighted. Further information about local priorities can be obtained from the Brent Catchment Partnership, the Crane Valley Partnership and the Colne Catchment Action Network.

Thames River Basin Flood Risk Management Plan

The Thames River Basin Flood Risk Management Plan (FRMP) are a set of documents published by the EA in March 2016. They are produced in line with Flood Risk Regulations (2009) and the EU Floods Directive (2007). These documents are updated on a six-yearly basis, with the current cycle running from 2015 to 2021. They set out how RMAs will work with communities to manage flood and coastal risk over the next 6 years within the RBD.

The objectives of the Thames River Basin FRMP are grouped into environmental, social, and economic. They build on the aims and objectives of The National Flood and Coastal Erosion Risk Management Strategy for England, published in 2011 by the EA, and align to the Councils’ LFRMSs (see Section 2.2.4 for further information). A set of measures have been produced to work towards achieving specific objectives. These measures fall under one of four different categories:

  • Preventing risk
  • Preparing for risk
  • Protecting from risk
  • Recovery and review

Full details regarding these objectives and measure categories can be viewed in Sections 4 and 8 of Part A of the Thames River Basin FRMP.

The Thames Strategy

The Thames Strategy, Kew to Chelsea, was commissioned in 1999 to help provide the basis for a more holistic approach to planning, management and use in Thames riverside areas between Kew and Chelsea. The document provides policy recommendations that fall under several categories, including ‘The River Channel’, ‘Shaping Development’, and ‘Biodiversity’. These policy recommendations have been devised with the requirements and objectives set out in line with the 1997 Strategic Planning Guidance for the River Thames (RPG3B/9B) and is intended to provide the basis for managing long term change.

The Thames Landscape Strategy, Hampton to Kew, was established in June 1994 and further updated in 2012. The document provides objectives to work towards the overarching aim of understanding the river landscape and to respecting its character – both natural and man-made aspects. A 2017-2020 Action Plan has recently been published.

Of the six boroughs, only Hounslow falls within the catchment area of both Thames Strategies. Any Thames-side developments should ensure they align with both Strategies’ strategic aims and projects.

London Sustainable Drainage Action Plan

The London Sustainable Drainage Action Plan (LSDAP) was published in 2016. Its overarching objective is to address how the capital’s increasing population, land use changes and climate change projections, will impact upon flood risk. The existing drainage systems across London is typically over utilised through increased surface water runoff and greater foul water discharges. To reduce the increasing risk of flooding, the GLA produced the LSDAP to better use the existing and planned drainage infrastructure. The LSDAP promotes the benefits of retrofitting traditional piped drainage features with SuDS and demonstrates how rainwater can be used as resource instead of a waste product.

Focusing over a 20 year period, 40 actions have been included within the LSDAP for the GLA to work in partnership with RMAs including the EA, Thames Water, Transport for London and London Boroughs. The actions range from wider policy improvements and delivery of SuDS projects to the identification of opportunities to better implement SuDS in schools, housing and transport schemes. The Boroughs strongly support the LSDAP and this SFRA’s push for greater inclusion of SuDS within developments directly align to many of the actions.

2.2.3. Sub-Regional

West London Waste Plan

Waste and Mineral Planning Authorities must take flood risk into account when allocating land for development. In line with PPG paragraph 008, this SFRA should be used to achieve this requirement.

With the objective of providing consistency with national government policy and the London Plan, the London Boroughs of Brent, Ealing, Harrow, Hillingdon, Hounslow and Richmond upon Thames have jointly prepared the West London Waste Plan (WLWP) as planning authorities.  The document was adopted in July 2015 and provides guidance, information and policies that work in conjunction with the Councils’ Local Plans. Within the WLWP, ‘Policy WLWP 4 – Ensuring High Quality Development’ states that for all waste development proposals:

“There will be no increased flood risk, either to the immediate area or indirectly elsewhere. Where necessary, this is to be demonstrated by a Flood Risk Assessment.”

North London Waste Plan

Barnet is taking part in the North London Waste Plan (NLWP). The London Boroughs of Barnet, Camden, Enfield, Hackney, Haringey, Islington and Waltham Forest are jointly drawing up the NLWP.  A draft version of the Plan was published in July 2015 and consulted upon the same year. Work on the proposed submission version is likely to resume shortly. Within the draft NLWP, one of the requirements of ‘Policy 6: Assessment Criteria for waste management facilities and related development’ states that applications for waste management facilities should demonstrate that:

The development does not increase flood risk, and aims to reduce risk.

Old Oak and Park Royal Development Corporation

The Old Oak and Park Royal Development Corporation (OPDC) is a Mayor of London Development Corporation set up to create a new community hub and centre through the delivery of new homes and jobs. The Old Oak and Park Royal area falls within the boroughs of Brent, Ealing and Hammersmith & Fulham.

In 2016, the OPDC produced a set of draft Local Plan documents for the regeneration project which have undergone consultation. Central to these is the Draft Local Plan, which serves as the key planning policy document for the area. The Plan highlights sub-areas within the Old Oak and Park Royal area and provides preferred policy options to manage new developments within those places. Of the ten sub-areas, Policies P1, P2, P4, P5, P6, P8, P9 and P10 highlight managing flood risk. Policy EU3 (Water) is the main overarching policy linked to management for the overall area. Amongst the listed requirements, the policy states that development proposals will be required to:

“Implement the flood risk management measures identified in the relevant borough’s Surface Water Management Plans and protect existing flood management assets.”

 

To support the Draft Local Plan, the OPDC have also produced a set of supporting evidence base documents. Amongst these documents is the Integrated Water Management Strategy which reviews flood risk sources and water infrastructure coverage. The document provides a framework and a set of strategic recommendations regarding water demand, drainage and flood risk. These recommendations have been used to produce the water management and policy elements in the Draft Local Plan.

Heathrow Airport

Heathrow Airport have undertaken an SFRA and Surface Water Management Plan (SWMP). These documents focus on addressing flood risk within the entire Airport area. This objective has been addressed through identifying the sources of flood risk and implementing measures to achieve the outcomes that Heathrow agreed with the EA. Cross-boundary cooperation with Hillingdon and Hounslow is important in ensuring that flood risk objectives are met. For further information, it is recommended that the relevant LPA is contacted as these documents are not publicly available.

2.2.4. Local

This section provides an overview of Borough-specific policies and requirements. Borough-specific Flood Risk Assessment guidance can be found in Section 4.5 of this SFRA. The following four are the key documents relating to flood risk which must be referenced when development is being proposed:

  • Local Plan – As highlighted in Section 2.2.1, the NPPF states that Local Plans are vital components for delivering sustainable development within their area. In addition to remaining consistent with the principles and policies set out in the NPPF, Local Plans for London Boroughs also need to work in conjunction with the London Plan. Table 2-2 summarises any key Borough-specific policies within the Local Plans relating to flood risk which supplements national, regional or sub-regional requirements. This SFRA provides an evidence base for proposing appropriate policies to be implemented within Local Plan documents.
  • Local Flood Risk Management Strategy – As highlighted in Section 2.2.1, the FWMA requires LLFAs to develop a LFRMS in alignment with National Strategy. These local strategies assess the local flood risk, set out objectives for managing local flooding, summarise responsibilities of RMAs and demonstrate how wider environmental objectives will be achieved. Table 2-2  summarises any Borough-specific policies within the Borough’s LFRMSs relating to potential development which improves upon national, regional or sub-regional requirements. This SFRA delivers several of the LFRMS objectives set out by Boroughs to manage flood risk in the local area.
  • Preliminary Flood Risk Assessment – Preliminary Flood Risk Assessments (PFRAs) are designed to help inform the strategic management of local flood risks. They identify key flood risk areas within each borough and summarise past flooding incidents where significant. Potential impacts of climate change and the identification of possible long-term developments enabled Flood Risk Areas to be defined. PFRAs fulfil statutory requirements in the FRR, which implement the requirements of the EU Floods Directive as highlighted in Section 2.2.1. All of the original 2011 PFRAs for London boroughs were written as part of the Drain London project to ensure consistency, and one ‘London Flood Risk Area’ was created. Each Borough’s PFRAs were reviewed in 2017 and updates made where required as part of the six-year FRR cycle. This SFRA provides an evidence base for the next cycle of PFRAs.
  • Surface Water Management Plan – Surface Water Management Plans (SWMPs) were created in 2011 as part of the Drain London project to outline the preferred management strategy for surface water runoff for each Borough. Each Council’s SWMP describes predicted and historic flooding from sewers, drains, groundwater, and runoff from land, small water courses and ditches sources following heavy rainfall. Each SWMP is broken down into a four-phase approach: Phase 1 – Preparation; Phase 2 – Risk Assessment; Phase 3 – Options; and Phase 4 – Implementation and Review. The SWMPs defined Critical Drainage Areas for each Borough and recommended potential mitigation options that could be incorporated into future flood alleviation schemes. Each borough’s SWMP includes an action plan and most are available via their respective websites. In all cases the actions plans were used to create updated proposed objectives and measures for LLFAs to manage and mitigate local flood risks in their LFRMSs. For this reason, specific SWMP actions relating to future development have not been listed in this SFRA, but should be referenced in site-specific Flood Risk Assessments and drainage strategies as necessary. The SWMP provides an evidence base that informs the Local Strategy and the SFRA with flood risk information and location specific surface water management recommendations.

Table 2-3. Borough Specific Document Overview

BARNET

Policy / StrategyPolicy / Strategy Details and Requirements
Barnet Local PlanBarnet's Local Plan features a suite of Development Plan Documents and Supplementary Planning Documents. Central to this is the 'Core Strategy', published in September 2012. The document includes the 'vision' for the Local Plan and fundamental objectives and policies. Information in sections '18.12 - Flooding and Water Management' and '18.13 - Water Quality and Supply' provide details on flood risk. These sections feed into 'Policy CS13: Ensuring the efficient use of natural resources'. This policy ultimately seeks to minimise Barnet's contribution to climate change, respect environmental limits and improve quality of life. The sixth aim of the policy is key to managing flood risk in the borough, it states:
"We will make Barnet a water efficient borough and minimise the potential for fluvial and surface flooding by ensuring development does not cause harm to the water environment, water quality and drainage systems. Development should utilise Sustainable Urban Drainage Systems (SUDS) in order to reduce surface water run-off and ensure such run-off is managed as close to its source as possible subject to local geology and ground water levels."

The Development Management Policies document is part of the set of documents which makes up the Local Plan. The 'Environmental considerations for development' section provides guidance which feeds into 'Policy DM04: Environmental Considerations'. Part 'g' of the policy is linked to flood risk, and states:
"Development should demonstrate compliance with the London Plan water hierarchy for run off especially in areas identified as prone to flooding from surface water runoff. All new development in areas at risk from fluvial flooding must demonstrate application of the sequential approach set out in the NPPF (paras 100 to 104) and provide information on the known flood risk potential of the application site."
Local Flood Risk Management StrategyA draft version of Barnet's LFRMS (May 2017) is currently undergoing public consultation. The key aim of the LFRMS is to "establish a series of objectives which can be taken forward to deliver effective local flood risk management through measures and actions." To achieve this, the document lists ten local objectives in Section 4.2. The first objective is to "prevent risks of flooding in new developments". The following associated measures are proposed:
- Prevention of flood risk in new developments should be tackled at the planning process stage. Enhance flood resilience measures and encourage the use of SuDS wherever possible.
- Ensure that local planning policy sets out the minimum requirements for flood risk mitigation measures within development, including areas at risk of local sources of flooding, particularly within CDAs.
- Develop protocols for implementing the statutory consultee role with regard to management of surface water and implementation of SuDS within new development as part of the planning process.

BRENT

Policy / StrategyDetails and Requirements
Brent Local PlanBrent's Local Plan is a suite of planning documents that sets out the strategy for future development in the borough. Central to this is the 'Core Strategy' which was adopted in July 2010. The section 'Tackling Climate Change and Achieving Sustainable Development' highlights flood risk and Brent's 2008 SFRA. This section is linked to Policy 'CP19: Brent Strategic Climate Change Mitigation and Adaptation Measures'. Policy 'CP15: Infrastructure to Support Development' also feeds into flood risk mitigation.

The Local Plan also features a Development Management Policies document which was adopted in November 2016. The document features an 'Environmental Protection' section which includes information and policies to protect certain features of the environment, such as those relating to water. Policies 'DMP 9A: Managing Flood Risk' and 'DMP 9B: On Site Water Management and Surface Water Attenuation' to address flood risk, providing requirements key to FRAs and planning applications.
Local Flood Risk Management StrategyBrent's LFRMS was published in 2015. The document is designed to improve the understanding of the risks of flooding in the borough. It provides a source of information that can be utilised to identify effective ways of managing flood risk. The second objective of the LFRMS is "reducing the risk of flooding for people and businesses in Brent". To achieve this objective, the following key actions have been put forward:
- Continue to closely monitor gully cleansing programme. Consider a more targeted approach to gully clearing, based on silt levels.
- Drawing up of an asset register of the most significant flood assets in the borough.
- Designation of significant assets to ensure they are maintained in current form where necessary.
- In order that Brent's flood risk planning is co-ordinated with the rest of London, Brent will continue to attend Regional meetings, Drain London and LoDEG (London Drainage Engineering Group) has been established by all 33 London Boroughs and meetings are held quarterly
Further objectives and associated actions can be found in Appendix G of the document.

EALING

Policy / StrategyDetails and Requirements
Ealing Local PlanEaling's Local Plan is a collection of documents that sets out how the borough will develop up to 2026. Central to this is the 'Development Strategy 2026', adopted by the Council in April 2012. The document sets out a vision for the future development of the borough and covers a 15-year plan period. Within the Local Plan, 'Policy 1.2: Delivery of the Vision for Ealing 2026', 'Policy 5.2: Protect and Enhance Metropolitan Open Land (MOL)' and 'Policy 5.3: Protect & Enhance Green Corridors' are directly linked to flood risk management in the borough.

The Local Plan features a Development Management: Development Plan Document which was adopted in December 2013. The document features a 'Climate Change' section which aims to guide certain environmental based decisions for planning applications. This section contains 'Policy 5.12: Ealing Local Variation - Flood Risk Management' which provides requirements and guidance to address flood risk as part of developments proposals.
Local Flood Risk Management StrategyEaling's LFRMS was published in 2016. The document aims to provide clarity and direction around how flood risk is managed in Ealing. It provides five objectives for flood risk management and a set of linked actions to achieve those objectives. The third objective of the set is to "Prevent the increase of flood risk through inappropriate development". The following actions are proposed:
- Continue to ensure that all developments in flood risk areas are appropriate.
- Identify sustainable drainage retrofitting opportunities.
- Develop Local Sustainable Drainage Guidance.
- Begin to review flood plain conditions

HARROW

Policy / StrategyDetails and Requirements
Harrow Local PlanHarrow's Local Plan - Core Strategy was adopted in February 2012. An objective of the Core Strategy is to "manage the Borough's contribution to climate change and increase resilience to flooding". The document sets out some actions as to how this can be achieved, including:
- Directing development away from areas of high flood risk and increase natural and sustainable drainage.
- Achieving sustainable design and construction in all new development.

The Core Strategy has a set of Core Policies of actions to be taken by the Harrow and its partners. These Core Policies are either suites of spatial policies relating to 'sub areas' within Harrow (Core Policies 2 to 10) or are a set of unified objectives which form an overarching core policy for the entire borough of Harrow (Core Policy 1). In addition to the overarching Core Principle CS1, each Core Principle addresses flood risk as an objective with the exception of the Core Policy suite for Harrow-on-the-Hill and Sudbury Hill (Core Policy 3).

The Development Management Policies document is part of the Local Plan. It ensures that there is a clear policy framework in place to work alongside the Core Strategy and its objectives. Requirements and guidance are provided to resist developments that do not align with the Core Strategy's direction. The 'Environmental Sustainability' section provides four policies linked to flood risk:
- Policy DM 9: Managing Flood Risk
- Policy DM 10: On Site Water Management and Surface Water Attenuation
- Policy DM 11: Protection and Enhancement of River Corridors and Watercourses
- Policy DM 12: Sustainable Design and Layout
Each policy features guidance, associated information and key policy/guidance that drives each policy within the document.

The Harrow and Wealdstone Area Action Plan was adopted in July 2013 and is part of the Local Plan. It is there to help guide development change in the Harrow and Wealdstone area by providing detailed standards and policies to be used in the planning application review process. Policy AAP9 of the document provides guidance on flood risk and sustainable drainage, setting out requirements for:
- Major development proposals on Non-Allocated Sites in identified flood risk areas
- Proposals on Allocated and Non-Allocated Sites requiring a site-specific FRA
- Major developments and proposals promoting a comprehensive Change of Use
Local Flood Risk Management StrategyHarrow's LFRMS was published in 2016. It outlines the priorities for local flood risk management and provides a delivery plan to manage the risk over the next five years. The document provides a set of objectives and highlights how collaboration is vital to deliver the LFRMS. Objective three of the local objectives set for managing flood risk in the borough is "to improve the way in which we provide long term sustainability and flood risk reduction and mitigation through development to ensure the economic prosperity and protection of residents, business and infrastructure." To achieve this objective, the following action plan is proposed:
- Working with planners and Local Development Framework (LDF) team to keep pace with Planning Legislation and how it affects flood risk management including updating the information that is provided to developers and single applicants.
- Develop an online standing local advice for flood risk assessment, SuDS matrix for developers and single applicants.
- Continue to support the concept of flood risk reduction through sustainable development by undertaking a more holistic and inclusive approach to river, surface water and sewer modelling.

HILLINGDON

Policy / StrategyDetails and Requirements
Hillingdon Local PlanHillingdon's Local Plan is a collection of documents that provide the foundation for how planning will be controlled in the borough. The two primary documents are 'Local Plan Part 1 - Strategic policies' and 'Local Plan Part 2'.

Local Plan Part 1 was adopted in November 2012 and outlines the Council's vision for 2026. Section 8 provides Core Policies around environmental improvement, in which 'Policy EM6: Flood Risk Management' is included.

Local Plan Part 2 is comprised of a set of documents, including 'Development Management Policies', 'Site Allocations and Designations', and 'Polices Map'. The documents were published for consultation in autumn 2015 and will be submitted for examination in summer 2017 with consultation comments and proposed modifications. The 'Development Management Policies' document provides detailed policies that will form the basis of the Borough's decisions on individual planning applications. Section 6 provides development management guidance and policies linked to environmental protection and enhancement. Of these policies, 'Policy DMEI 9: Management of Flood Risk' provides policy and guidance on flood risk matters.
Local Flood Risk Management StrategyHillingdon's LFRMS was published in 2016. It provides an overview of previously undertaken flood risk studies. It is supported by other documents such as the PFRA, SWMP and SFRA. Appendix 3 of the LFRMS provides a set of objectives, measures and actions. Objective three of the six objectives states "Development in Hillingdon understands and takes account of flood risk issues and plans to reduce flood risk." The measures associated with this objective are:
- Influence the local plan and creation of suitable policies on flood risk.
- Secure contribution to flood risk reduction from new developments.
- Major landowners to develop site wide long-term plans for managing water.
- Continue influencing developments through the planning process to ensure they meet the requirements of National Standards for Sustainable Drainage and London Plan requirements.
Local Development Framework Background Technical ReportHillingdon's Local Development Framework Background Technical Report was published in April 2008. The document references the current national policy documents Mineral Planning Statements (MPS), with 'MPS1: Planning and Minerals' the most significant of these. MPS1 paragraph 17 highlights flooding and the water environment with regards to mineral planning. As of March 2014, the MPSs were superseded and replaced by the overarching NPPF.

HOUNSLOW

Policy / StrategyDetails and Requirements
Hounslow Local PlanThe Hounslow Local Plan was adopted in September 2015. The Local Plan is designed to form part of the planning framework of the Borough until 2030.

Volume 1 lists a set of objectives and corresponding Local Plan policies. Objective Seven is based on 'Ensuring Environmental Quality' and as part of that, 'Policy EQ3 - Flood risk and surface water management' is designed to mitigate flood risk. The policy states the Borough's approach, how the policy will be achieved, and what is expected of development proposals. This policy is further supported by additional information which helps to guide its delivery.

Volume provides a set of site allocations. The document features information regarding Flood Zones, for sites located in Flood Zones 3b, 3a or 2.
Local Flood Risk Management StrategyThe Hounslow LFRMS was agreed and implemented in 2014. Hounslow's LFRMS provides details on how the Borough will manage flood risk alongside its partners. The overall aim of managing flood risk is driven by a set of objectives and guiding principles. The document provides six local flood risk objectives. The document's third objective seeks to "prevent the increase of flood risk through inappropriate development", and the fifth seeks to "Identify and implement flood mitigation measures in areas at risk from surface water flooding where additional funding can be secured."
The strategy provides actions that the Borough and other key stakeholders will take to manage potential flood risk in within the borough. Key future actions to improve flood risk management include:
- Flood investigations reports for any major new flood incidents.
- Publication of significant flood assets in the borough.
- Designation and maintenance of structures and features that provide flood alleviation.
TE2100 Local Council Briefing DocumentHounslow's TE2100 Local Council Briefing Document was published in 2015. As highlighted in Section 2.2.2 of this document, the TE2100 Plan has six recommendations specifically for Hounslow: Recommendations 1, 2, 3, 6, 7 and 8. To help explain the requirements and recommendations of the TE2100, the TE2100 Local Council Briefing Document provides ideas and suggestions of key policy messages. These policy messages could be incorporated into Hounslow's strategic planning documents to ensure that the recommendations of TE2100 are implemented in new developments.