Northwick Park...EIA Scoping Opinion Request for the redevelopment of the site in line with the requirements of the EIA Regulations and relevant EIA guidance. This includes submitting

Prepared for: Network New Build Limited

Date: August 2019

Northwick Park EIA Scoping Report

Trium Environmental Consulting LLP 69-85 Tabernacle Street London EC2A 4BD +44 (0) 20 3887 7118 [email protected] www.triumenvironmental.co.uk Project Reference: TEC0091

This report has been prepared for the Client by Trium Environmental Consulting LLP with all reasonable skill, care and diligence and in accordance with the Client’s particular and specific instructions. This report is issued subject to the terms of our Appointment, including our scope of Services, with the Client.

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CONTENTS INTRODUCTION ..................................................................................................................................... 1

Legislation and the Need for an EIA .................................................................................................... 4 Use of Competent Experts .................................................................................................................. 4 Structure of the EIA Scoping Report ................................................................................................... 5

EIA AND THE SCOPING PROCESS ..................................................................................................... 6 EIA Purpose and Process ................................................................................................................... 6 The Scoping Process .......................................................................................................................... 7

SITE AND SURROUNDING ENVIRONMENTAL CONTEXT ................................................................. 8 Site Location ........................................................................................................................................ 8 Surrounding Environmental Context ................................................................................................. 12 Potential Environmental Sensitivities / Sensitive Receptors ............................................................. 14

THE PROPOSED DEVELOPMENT ..................................................................................................... 15 Masterplan Application ...................................................................................................................... 15 Detailed Application ........................................................................................................................... 16 Highway Works Application ............................................................................................................... 16

PLANNING CONTEXT .......................................................................................................................... 17 Planning Policy Context ..................................................................................................................... 17

EIA METHODOLOGY ........................................................................................................................... 21 EIA Approach and Methodology ........................................................................................................ 21 Baseline Conditions ........................................................................................................................... 21 Phasing of the Proposed Development ............................................................................................. 22 Demolition and Construction ............................................................................................................. 22 Completed Development ................................................................................................................... 23 Proposed EIA Strategy – Approach to Assessment of Applications ................................................. 26 Cumulative Effects and Effect Interactions ........................................................................................ 27 Alternatives ........................................................................................................................................ 29

DETERMINING EFFECT SIGNIFICANCE – TERMINOLOGY AND APPROACH .............................. 30 Reference to ‘Impact’ and ‘Effect’ ...................................................................................................... 30 Receptor Sensitivity and Magnitude of Impact .................................................................................. 30 Identification of a Resultant Effect ..................................................................................................... 30 Effect Scale ....................................................................................................................................... 31 Effect Nature ...................................................................................................................................... 31 Geographic Extent of Effect............................................................................................................... 31 Effect Duration ................................................................................................................................... 32 Direct, Indirect and Reversible Effects .............................................................................................. 32 Identification of Significant Effects ..................................................................................................... 32

SCOPE OF EIA - SUMMARY ............................................................................................................... 33 Topics Scoped In ............................................................................................................................... 33 Topics Scoped Out ............................................................................................................................ 33

TOPICS TO BE SCOPED IN ................................................................................................................ 34 Air Quality .......................................................................................................................................... 34

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Climate Change ................................................................................................................................. 40 Daylight, Sunlight, Overshadowing, Light Pollution and Solar Glare ................................................ 42 Health ................................................................................................................................................ 46 Noise and Vibration ........................................................................................................................... 48 Baseline ............................................................................................................................................. 48 Potential effects ................................................................................................................................. 48 Potential Sensitive Receptors............................................................................................................ 49 Scope of assessment ........................................................................................................................ 50 Socio Economics ............................................................................................................................... 54 Townscape and Visual Impact Assessment ...................................................................................... 58 Traffic and Transport ......................................................................................................................... 65 Wind Microclimate ............................................................................................................................. 70

TOPICS TO BE SCOPED OUT ............................................................................................................ 75 Archaeology (Buried Heritage) .......................................................................................................... 75 Aviation .............................................................................................................................................. 77 Built Heritage ..................................................................................................................................... 78 Daylight, Sunlight and Overshadowing (Internal) .............................................................................. 79 Ecology and Biodiversity ................................................................................................................... 79 Geoenvironmental (Ground Conditions, Groundwater) ..................................................................... 81 Land Take and Soils .......................................................................................................................... 85 Project Vulnerability – Accidents or Disasters ................................................................................... 85 TV and Radio Interference ................................................................................................................ 87 Water Resources, Drainage and Flood Risk ..................................................................................... 89

FORMAT AND CONTENT OF THE EIA ............................................................................................... 93 REQUEST FOR AN EIA SCOPING OPINION ..................................................................................... 95

APPENDICES APPENDIX A - Site Location and Redline Planning Application Boundary .......................................... 96 APPENDIX B– Cumulative Schemes ................................................................................................... 97 APPENDIX C – Information for Inclusion within an ES: Way Finding................................................. 100 APPENDIX D – Archaeological Desk-Based Assessment ................................................................. 101 APPENDIX E - Preliminary Ecological Appraisal ................................................................................ 102 APPENDIX F - Geoenvironmental Desk Study ................................................................................... 103 APPENDIX G - Aerodrome Safeguarding Assessment ...................................................................... 104 APPENDIX H – Best Practice Mitigation – Water Resources, Drainage and Flood Risk ................... 105 APPENDIX I – Detailed UXO Threat and Risk Assessment ............................................................... 106

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INTRODUCTION Network Homes on behalf of the One Public Estate (University of Westminster, Brent Council and

London North West University Healthcare NHS Trust) (hereinafter referred to as the ‘Applicant’) is seeking to gain approval for a set of planning permissions for the proposed redevelopment of an area of land that is broadly bound by the following features:

• To the north, by Northwick Park London Underground Station and associated railway lines;

• To the east, Northwick Park, an area of open amenity space which is designated ‘Metropolitan Open Land’ (MOL);

• To the south, a continuation of the area of open amenity space to the east, comprising Northwick Park and a golf course; and

• To the west, by the existing University of Westminster (Harrow Campus), and Northwick Park and St Mark’s Hospitals, as well as Watford Road (A404).

The total area to be covered by the planning permissions covers an area of 17.48 hectares (ha) and falls within the administrative boundary of the London Borough of Brent (LBB) – hereafter referred as ‘the site’. The site is located on the boundary of the LBB and the London Borough of Harrow (LBH), which is located to the north (boundary being Kenton Road (A4006) and to the west Watford Road (A404).

The location of the site in the context of the surrounding area is shown in Figure 1.

Figure 1 Site Location Plan

The redevelopment of the site will be the subject of a masterplan, where a co-ordinated approach to the design of the site in terms of layout, form and massing has been undertaken in response to the opportunities and constraints of the surrounding environmental context. The proposed applications for

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the redevelopment of the site, (refer further details within section ‘The Proposed Development’ of this report), will comprise the following:

• Masterplan Application

- Application for Outline planning permission;

- Residential led, mixed use regeneration comprising demolition of existing residential units and construction of up to 2,600 new residential and student units in a series of buildings ranging in height to a maximum of 15 storeys, together with community facilities, retail & leisure facilities, energy centre and associated highway improvements, open space, landscaping and public realm works.

- Refer to ‘Boundary Plan – Masterplan’ (refer Appendix A for the redline boundary) and Figure 2 below, which shows the indicative boundary for the application.

Figure 2 Boundary for Masterplan Application

• Detailed Application

- Application for Full planning permission;

- This application forms part of the first phase of the application for the Outline planning permission;

- Residential led mixed use regeneration comprising of demolition of existing buildings and construction of up to 700 homes in a series of buildings up to 15 storeys in height. Together with community facilities (D1), Retail (A1-A3), energy centre and associated highway improvements, open space, landscaping and public realm works.

- Refer to ‘Boundary Plan – Detailed’ (refer Appendix A for the redline boundary) and Figure 3 below, which shows the indicative boundary for the application.

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Figure 3 Boundary for Detailed Application

• Highway Works Application


- Junction Improvements works to A404 (Watford Road) and road widening to enable two-way traffic on Northwick Park spine road, and cycle, pedestrian highway improvements together with associated landscaping and public realm works;

- Refer to ‘Boundary Plan – Detailed’ (refer shaded area) and Figure 4 below, which shows the indicative boundary for the application.

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Figure 4 Boundary for Highway Works Application

Legislation and the Need for an EIA The Proposed Development falls within the classification of Schedule 2, 10(b) (Infrastructure Projects

– Urban Development Projects) of The Town and Country Planning (Environmental Impact Assessment) Regulations 20171 (amended 20182) (hereafter referred to as the ‘EIA Regulations’).

Given the size and scale of the masterplan and taking into account the nature of the site and surrounding environmental context, it is considered that there is the potential for significant environmental effects to arise. The development proposed is therefore considered to constitute ‘EIA development’ under the EIA Regulations, and so an Environmental Statement (ES) will be prepared addressing the masterplan.

Use of Competent Experts Trium Environmental Consulting LLP (Trium) has been commissioned by the Applicant to prepare an

EIA Scoping Opinion Request for the redevelopment of the site in line with the requirements of the EIA Regulations and relevant EIA guidance. This includes submitting a Scoping Opinion Request Report (hereafter referred as the ‘Scoping Report’) to the London Borough of Brent (LBB) that sets out the proposed scope of the EIA and the content and approach to preparing the ES that will be submitted to accompany the application for full planning permission.

The EIA Regulations require that in order to ensure the completeness and quality of the ES, ‘(a) the developer must ensure that the environmental statement is prepared by competent experts;’ and ‘(b) the environmental statement must be accompanied by a statement from the developer outlining the

1 The Town and Country Planning (Environmental Impact Assessment) Regulations 2017 2 The Town and Country Planning and Infrastructure Planning (Environmental Impact Assessment) (Amendment) Regulations 2018

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relevant expertise or qualifications of such experts.’ Trium consider that these requirements are equally important and relevant to the EIA scoping process in addition to the preparation of the ES. As such, in accordance with this requirement, the following statement is provided:

“Trium is an environmental consultancy specialising in urban regeneration and property development projects in the UK, with a specific focus in London. Trium’s Partners and Employees have extensive experience in managing the environmental issues and impacts surrounding large scale, high profile urban regeneration development projects. The Partners and Employees of Trium have, over the course of their careers to date (including with former employers), project directed, managed or contributed to over 300 EIAs within the retail, residential, leisure, commercial, cultural, infrastructure and industrial sectors.”

Further information on Trium’s lead EIA practitioner and EIA team (both Trium’s EIA coordination team and the wider EIA technical assessment team), including details on their expertise and qualifications will be appended to the ES.

Structure of the EIA Scoping Report This Scoping Report is structured as follows and provides:

• A summary of the EIA purpose and process including EIA Scoping;

• A description of the location of the site and the surrounding area’s environmental context;

• An overview of the Proposed Development;

• An outline of the potential environmental sensitivities and receptors;

• An outline of the planning context;

• A description of the EIA methodology;

• The approach to determining the significance of effects;

• A description of the environmental topic areas that are considered to potentially result in significant effects on the environment and an explanation of the proposed scope and assessment methodology that will be adopted to predict the magnitude of potential impacts and the resultant scale, nature, geographic extent and duration of potential effects, and the effect significance within the EIA;

• A description of the environmental topic areas that are considered unlikely to result in significant environmental effects, and whilst they will be addressed within the EIA, a full assessment is not required;

• Confirmation of the proposed structure of the ES; and

• Request for an EIA Scoping Opinion.

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EIA AND THE SCOPING PROCESS EIA Purpose and Process

Environmental Impact Assessment is a process carried out which examines available environmental information to ensure that the likely significant environmental effects of certain projects are identified and assessed before a decision is taken on whether a project is granted planning permission. This means environmental issues can be identified at an early stage and projects can then be designed to avoid or to minimise significant environmental effects, and appropriate mitigation and monitoring can be put in place.

Regulation 4 of the EIA Regulations sets out the EIA process. Specifically, Regulation 4(2) states that “the EIA must identify, describe and assess in an appropriate manner, in light of each individual case, the direct and indirect significant effects of the proposed development on the following factors:

• (a) population and human health;

• (b) biodiversity;

• (c) land, soil, water, air and climate;

• (d) Material assets, cultural heritage and the landscape;

• (e) The interaction between the factors referred to in sub-paragraphs (a) to (d).”

The likelihood for significant effects on the aforementioned factors, generated by the potential impacts from the development proposed during both the demolition and construction works, and once it is complete and operational, is considered within the following relevant environmental matters addressed within this Scoping Report:

• Air Quality;

• Archaeology (buried heritage assets);

• Aviation;

• Built Heritage (above ground heritage assets);

• Climate Change;

• Daylight, Sunlight, Overshadowing, Light Pollution and Solar Glare;

• Ecology and Biodiversity;

• Geoenvironmental (including contamination, land take and soils);

• Health;

• Noise and Vibration;

• Project Vulnerability;

• Socio Economics;

• Townscape, and Visual;

• Traffic and Transport;

• Electronic Interference;

• Waste;

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• Water Resources; and

• Wind Microclimate.

The method behind the EIA process generally3 takes into account the existing conditions of the area into which the development is being introduced (the baseline) and makes reasonable predictions of the likely change (the impact – in terms of magnitude) that may occur, during both its construction and when the development is completed and operating as proposed. The predicted impact is considered in terms of key environmental and social aspects (receptor / resource) found within the surrounding area, and based on their sensitivity to change, the resulting change experienced by the receptor / resource (the effect) is then determined. Any mitigation measures required in order to reduce or eliminate adverse effects are then considered and assessed, with the resulting residual effect being determined as significant or not. The likely significant effects are then reported (within an environmental statement) for consideration by the relevant planning authority when considering whether to grant planning permission for a development.

The Scoping Process EIA Scoping forms one of the first stages of the EIA process. Requesting an EIA Scoping Opinion from

a local planning authority, under Regulation 15 of the EIA Regulations, involves the preparation of a Scoping Report and its submission to the local planning authority is part of a formal request for their opinion on the content or ‘scope’ and approach to the EIA. The purpose of scoping is to identify:

• the important environmental issues and topics for consideration in the EIA;

• the baseline conditions and assessment methodology to be used for assessment;

• any potentially sensitive receptors that may be affected by the development being proposed;

• the appropriate spatial boundaries of the EIA: the site and surrounding environmental context;

• the information necessary for decision-making; and

• the potential significant effects which are likely to result from the development both during its demolition and construction and operation.

In accordance with the requirements of the EIA Regulations4 and the Town and Country Planning (Development Management Procedure) Order 20155, it is expected that this Scoping Report will be issued by the LBB to the consultation bodies to be consulted as part of the EIA Scoping process. It is also assumed that the LBB will also issue the Scoping Report to other non-statutory and key, local stakeholders and interest groups who are deemed to similarly have an interest in the development proposed.

The process of consultation is a key requirement of the EIA process and the views of statutory consultees and other stakeholders will help to identify specific issues, as well as identifying additional information in their possession, or of which they have knowledge, which may be of assistance in progressing the EIA.

The ES will append the Scoping Opinion and include a summary of any other consultation undertaken as part of the EIA process.

3 There may be exceptions to the general approach described. Where there are exceptions, this will be clearly described within the relevant methodology section, outlining both the departure from the general EIA methodology and the description of the alternative approach. This is discussed further within ‘EIA Process and Methodology’ section of this Scoping Report. 4 Refer Part 4, Regulation 15(4) (Scoping opinions of the local planning authority) 5 Refer Part 4, article 18 (Consultations before the grant of planning permission) and Schedule 4 (Consultations before the grant of permission)

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SITE AND SURROUNDING ENVIRONMENTAL CONTEXT Site Location

The site is broadly bound by the following features:

• To the north, by Northwick Park London Underground Station and associated railway lines;

• To the east, Northwick Park, an area of open amenity space which is designated ‘Metropolitan Open Land’ (MOL);

• To the south, a continuation of the area of open amenity space to the east, comprising Northwick Park and a golf course; and

• To the west, by the existing University of Westminster (Harrow Campus), and Northwick Park and St Mark’s Hospitals, as well as Watford Road (A404).

The masterplan is comprised of the following parcels of land ownership, as represented in Figure 5.

Figure 5 Masterplan – Land Ownership

The site is currently occupied by a number of uses associated with the Northwick Park Hospital and St Mark’s Hospital, and the University of Westminster (Harrow Campus). The following description of the site is described by way of the land ownership boundaries for ease of reference.

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University of Westminster

The existing buildings located within the northern portion of the area is comprised predominantly of student accommodation, with the entrance (and associated amenities such as café) leading from the Northwick Park Station located at the eastern portion of the area. The area to the south of these buildings is open space, comprised of grassed amenity areas and trees. A sports hall and storage facility are located along the western boundary, and with the main university campus to the west of the site boundary.

Network Homes

The area is comprised of residential uses within the southern portion, with a number of dwellings provided for Hospital Trust employees, working at the adjacent hospital.

Along the northern portion of this residential area, is the Olympic Medical Institute (associated with the adjacent hospital), and beyond this is the existing social club, car park and the Northwick Park Day nursery and pre-school facility, as well as individual units associated with the hospital (i.e. occupational health department). Towards the northern portion of the area is an open car park for hospital staff, and further units associated with the hospital.

At the northern portion of the area is the existing energy centre for the hospital (referred to as ‘Boiler House Land’), with associated buildings including a chimney. Figure 8 provides an aerial of the Network Homes land.

London Borough of Brent

Open space, forming part of Northwick Park, with pathways leading from Northwick Park Station to both the University of Westminster campus, and to wider Northwick Park along the eastern boundary of the site; this path provides a link to the ‘Capital Ring Walk’ which is located along the southern boundary of the site6 (running east-west orientation). A photo of the open space is included in Figure 9.

6 This portion of the Capital Ring Walk (a defined network of walking routes around London (15 sections) which connects the 33 London boroughs and their greenspaces is section 9 (Greenford to South Kenton) – refer website (https://tfl.gov.uk/modes/walking/capital-ring)

Figure 7. View from open space toward the UoW Campus

Figure 8. View of Network Homes existing housing and car park

Figure 9. View south from Northwick Park Station

https://tfl.gov.uk/modes/walking/capital-ring

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NHS Hospital Trust

Existing one-way ring road for vehicular traffic which provides access and movement around the hospital and linking out onto Watford Road. The section of the ring road subject of the Highway Works Application is the stretch of ring road along the northern boundary of the NHS hospital site, with works extending to include the junction with the A404 Watford Road. Part of the ring road is shown in Figure 10.

Site Environmental Context

Key features and designations associated with the site are presented in Table 1.

Key Environmental Features and Designations Environmental Topic Key features and designations

Traffic and Transport • The site has a Public Transport Accessibility Level (PTAL) rating of between 5 for the northern and north-eastern portion of the site, which reduces to a 2 for the southern portion of the site.

Air Quality • The Brent Air Quality Management Area (AQMA) was designated for exceedances in annual mean nitrogen dioxide and 24-hour mean Particulate Matter PM10 levels.

• The majority of the site is not located within the AQMA (i.e. the Network Homes area), however part of the western portion of the area for the Highway Works Application is located within the AQMA, as is a small portion of land within the northwest corner of the site (within the land owned by the UoW).

• The AQMA area is defined by the main road networks, including Watford Road (A404) and Kenton Road (A4006) located to the north of the site.

Water • The site is located within an area designated as ‘Flood Zone 1’ - area with a low probability of flooding (rivers and sea)7.

• The site has areas of Flood Zone 3a - high probability for surface water flooding8 which appears to occur along the hard surface areas within the site (i.e. ring road, Nightingale Avenue).

• Extending across the site (northern portion, with the UoW area) on east-west orientation, is a culverted watercourse (linking with identified watercourses along the eastern boundary of the site, and also extending out beyond western boundary of site (a drain), on opposite site of Watford Road)9.

• The EA’s Groundwater Source Protection Zone Map confirms that the site is not located within a Source Protection Zone.

Ecology • The site is partially located within an area designated as a ‘Site of Importance for Nature Conservation’ (SINC) (Grade 1) - known as the Northwick Park and Ducker Pool SINC (ref. BI03). The SINC area comprises the open space to the south of the site, as well as extending up on the eastern boundary of the site (some of site along this boundary is included). The open space located at the north-eastern corner of the site (within the LBB area) is also included, as well as open space within the University of Westminster boundary and part also on Network Land.

• The site is not located within the boundaries of any other statutory or non-statutory sites, including Special Areas of Conservation (SAC), Special Protection Areas (SPA), Ramsar sites, Sites of Special Scientific Interest (SSSI), National Nature Reserves (NNR) and Local Nature Reserves (LNR).

7 Land and property in this flood zone would have a high probability of flooding without the local flood defences. These protect the area against a river flood with a 1% chance of happening each year, or a flood from the sea with a 0.5% chance of happening each year. 8 Source: https://flood-map-for-planning.service.gov.uk/ 9 Source: West London Strategic Flood Risk Assessment – Surface Water Flood Risk, https://metis.maps.arcgis.com/apps/webappviewer/index.html?id=b071bc3722024087b3ba905b8550bb55

Figure 10. View looking west from the western boundary of the Network Homes area

https://flood-map-for-planning.service.gov.uk/

https://metis.maps.arcgis.com/apps/webappviewer/index.html?id=b071bc3722024087b3ba905b8550bb55

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Environmental Topic Key features and designations • Part of the site is subject to a group Tree Preservation Order (TPO).

Archaeology • The site is not located within an Archaeological Priority Area (APA) and does not contain a site of Archaeological Importance.

Heritage • There are no listed heritage buildings (Grade I or Grade II) within the site boundary or within 500m of the site.

• The site is not located within a Conservation Area.

Planning Designations • Current Local Plan – The site is within site allocation 15. Northwick Park Hospital. • The Draft Brent Local Plan – The site is within site allocation ref. BNWGA1 Northwick Park

Growth Area.

Relevant Site Planning History

A number of planning applications have been submitted over the years falling within the masterplan area. The following is a summary of the notable applications received and considered by the LBB.

Masterplan Area

Received - Jun 2005

Application received (in June 2005) for Outline planning permission for the demolition of various buildings and erection of replacement hospital with ancillary facilities, including car-parking, energy centre and landscaping, and formation of altered access to Watford Road and provision of / alterations to access roads and pedestrian routes within and adjacent to hospital and university site (matters for determination: means of access) (as accompanied by a Transport Statement by Faber Maunsell dated 3 May 2005, Planning & Design Statement by Faber Maunsell dated May 2005 and Environmental Statement by Faber Maunsell dated May 2005).

The application was never determined and was withdrawn in October 2012.

University of Westminster

A number of planning applications have been submitted in relation to the provision of student accommodation and associated facilities to be used by the University of Westminster’s Harrow Campus. A summary is provided below.

• Application for Outline Planning permission (ref. 02/2683) was submitted in October 2002 for the erection of a single-storey extension to the main reception building, a six-storey building to provide 160 units of student accommodation, a two-storey sport hall extension, a 6-storey educational building with up to 3,500m² being available for commercial Class B1 offices, a replacement two-storey entrance security building, a two-storey extension to the refectory/bar building, a seven-storey educational building to replace a workshop, provision of an all-weather games area and 2 tennis courts, with a reduction in on-site car-parking from 485 to 307 spaces and associated landscape works (details for consideration: siting of buildings and landscape strategy).

- The application was never determined and was withdrawn in August 2004.

• Application (ref. 02/3323) for the erection of two 5-storey buildings, providing 140 student accommodation units was submitted in December 2002, and granted consent in March 2003.

• Application (ref. 04/1365) for the erection of two 5-storey buildings, providing 150 student accommodation units was submitted in May 2004, and granted planning permission in July 2004.

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• A hybrid planning application (ref. 10/2767, submitted October 2010) for the demolition of part of the University of Westminster's Harrow Campus and the erection of new buildings and refurbishment of existing buildings, comprising:

- Full planning permission for the demolition of 6,980m² of existing floor space and the erection of 3,435m² of new educational floor space (Use Class D1) in new buildings ranging in height from one to two storeys, the refurbishment of existing buildings, including new external cladding, new hard and soft landscaping, improvements to the entrance adjacent to Northwick Park Underground Station and construction of a Multi-Use Games Area; and

- Outline planning permission for a further 3,545m² of new educational floor space (matters to be approved: land use, quantum of development and means of access, with layout, scale, appearance and landscaping reserved).

- Application was granted planning permission in March 2012.

Network Homes

Nursery

An application (ref. 09/2608, submitted December 2009) for the demolition of existing creche and erection of a single storey creche with associated play area and perimeter fencing adjacent to hospital car park. Application was granted planning permission in February 2010.

Residential area in the southern portion

An application (ref. 09/2246) for the erection of a 4-storey building on land adjacent to Kodak Court, comprising 26 flats (11 one-bedroom, 13 two-bedroom, 2 three-bedroom) and communal garden; and the provision of access to the public footpath running alongside Northwick Park Golf Course via Northwick Close. Application was granted planning permission in February 2010.

Surrounding Environmental Context The environmental context of the area surrounding the site is relatively open, which is largely the result

of the ‘Metropolitan Open Land’ (MOL) designation for the areas of land located to the east and south of the site.

To the north of the site is Northwick Park Station, providing London Underground services and whose rail line serves as the northern boundary to the site.

Another key feature of the local context is Northwick Park Hospital and the St Mark’s Hospital, whose buildings and layout (in terms of the road network) are a dominant feature to be taken into consideration. Similarly, the existing University of Westminster campus located to the west of the site, is also a key element particularly when approaching the site from Northwick Park Station. Visually, the height of the chimney stack associated with the Boiler House land, is also a visually prominent local feature when accessing the site from both Northwick Park Station and from Northwick Park itself.

A summary of the key features and designations associated with the surrounding environmental context are presented within Table 2.

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Surrounding Environmental Context Environmental Topic Key features and designations

Socio Economics • There are numerous schools within the local area including: • Primary School – Harrow Primary School (280m north, within LBH), Byron Court (500m

south); • Secondary School - Harrow High School (300m northwest), Harrow School (650m west) (both

in LBH). The closest secondary school in LBB is Wembley High Technology College (1.2km south);

• The University of Westminster’s Harrow Campus (adjacent to the site); • GP Surgeries - There are GPs surgeries within the surrounding area, with the closest being

Kenton Bridge Medical Centre (630m north) and Northwick Surgery (730m north) (both in LBH). The closest GP surgery in LBB is Uxendon Crescent Surgery (1.4km east);

• Open Space – the closest being Northwick Park (MOL designation) to the east and south of the site.

Traffic and Transport

• Highway - Vehicular access to the site is from the Watford Road (A404) to the west of the site.

• London Underground - Northwick Park station (Metropolitan line) is located directly adjacent to the site at the north-eastern corner of the site. Kenton station, located 430m north of the site, is served by Bakerloo line and Overground.

• The Northolt RAAF airport is located 7.1km to the southwest. • Walking – Capital Ring Walk, located along the southern boundary of the site. The path

which runs from Northwick Park Station, along the eastern boundary of the site, is known as ‘Pryors Path’10.

• There are a number of off-road cycle routes in the vicinity of the Site including lengths alongside the eastern boundary of the site, and through the site in an east to west direction.

• Bus routes: the ring road surrounding the hospital is served by route 186 (serves between St Marks Hospital and Brent Cross Shopping Centre, with stops at London Underground stations including Harrow and Wealdstone, Canons Park, Edgeware and Mill Hill Broadway.

• Along Watford Road, bus routes stopping outside the hospital include 182 (to Brent Cross Shopping Centre) and 143 (between Brent Cross Shopping Centre and Archway station).

• To the north of the site, along Northwick Avenue (outside the entrance to Northwick Park Station), there is the H9, H10, H18 and H19 (circular route by way of Harrow Bus Station, via London Underground stations including Harrow and Wealdstone, Rayners Lane, South Harrow).

Air Quality • The Brent Air Quality Management Area (AQMA) was designated for exceedances in annual mean nitrogen dioxide and 24-hour mean Particulate Matter PM10 levels.

• The AQMA area is defined by the main road networks, including Watford Road (A404) and Kenton Road (A4006) located to the north of the site.

• The closest air quality monitoring station (within LBH – Pinner Road) is located to the northwest of the site (approx. 3.2km and is a London Air Quality Network Monitoring Site. The monitoring location is a roadside monitoring location.

Water • Identified watercourses / drain along the eastern boundary of the site, and also extending out beyond western boundary of site, on opposite site of Watford Road)11

• The surrounding context is located within an area designated as ‘Flood Zone 1’ - area with a low probability of flooding (rivers and sea)12;

• The area to the east adjacent to the site has areas of Flood Zone 3a - high probability for surface water flooding13 - appears to follow the records / mapping of a watercourse along the eastern boundary of the site.

• A small waterbody is located to the south of the site (within the golf course area). In this area there is also another identified watercourse, which travels south but also connects to the watercourse that runs north-south (along the eastern boundary of the site).

10 Source: http://www.londongardensonline.org.uk/gardens-online-record.php?ID=BRE020# 11 Source: West London Strategic Flood Risk Assessment – Surface Water Flood Risk, https://metis.maps.arcgis.com/apps/webappviewer/index.html?id=b071bc3722024087b3ba905b8550bb55 12 Land and property in this flood zone would have a high probability of flooding without the local flood defences. These protect the area against a river flood with a 1% chance of happening each year, or a flood from the sea with a 0.5% chance of happening each year. 13 Source: https://flood-map-for-planning.service.gov.uk/

http://www.londongardensonline.org.uk/gardens-online-record.php?ID=BRE020

https://metis.maps.arcgis.com/apps/webappviewer/index.html?id=b071bc3722024087b3ba905b8550bb55


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Environmental Topic Key features and designations

Ecology • The SINC (Grade 1) - known as the Northwick Park and Ducker Pool SINC (ref. BI03), comprises the open space to the south of the site, as well as extending up on the eastern boundary of the site and within the UoW open space land.

• Designated ‘Wildlife Corridors’ are located along the rail lines, located both to the north of the site, and the east (eastern edge of Northwick Park).

• The Brent Reservoir / Welsh Harp Local Nature Reserve is located 3.8km to the east of the site, and the Fryent Country Park, located approximately 1.97km to the east. The Grove Farm Local Nature Reserve is located 2.26km to the south. The Brent Reservoir and Brent Reservoir Sites of Scientific Interest are located to the east of the site, by approximately 4.1km, and the Bently Priory SSI is located to the north of the site by 4.2km.

• The Harrow Park (formerly Flambards) Registered Park and Garden, includes the Harrow School Golf Course, which is located approximately 695m to the west of the site.

• The closest Site of Special Scientific Interest Risk Zone is located approximately 450m to the south west.

Archaeology • The closest Archaeological Priority Area is located approximately 1.25km to the south.

Heritage • The closest Conservation Area (Sudbury Court Conservation Area), is located approximately 390m to the south.

• The closest listed buildings are the Grade II Listed Chalgrove, Farthings, and Heathfield buildings, approximately 520m to the west of the site.

Potential Environmental Sensitivities / Sensitive Receptors When undertaking an EIA, it is important to identify potential environmental receptors which may be

impacted by the Proposed Development and may need to be considered as part of the assessment.

The environmental receptors that may be sensitive to change are identified and discussed within the scope of each technical topic in this EIA Scoping Report (hereafter referred to as ‘sensitive receptors’). The sensitive receptors outlined within this EIA Scoping Report have been identified at the time of writing as part of the EIA scoping process, however these will be reviewed during preparation of the ES and may be subject to change.

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THE PROPOSED DEVELOPMENT The redevelopment of the site is proposed to be subject of three separate planning applications. This

will see the submission of the following:

• Masterplan Application;


• Detailed Application;


- This application forms part of the first phase of the Masterplan application (for the Outline planning permission);

• Highway Works Application;

- Application for Full planning permission.

Where relevant, general reference to the total combined development proposed as part of the Masterplan Application and the Detailed Application will be hereafter referred as ‘the Proposed Development’.

Masterplan Application The development for the Masterplan Application will involve demolition of some of the existing buildings

and structures to facilitate the provision of new build, and providing for a range of land uses, including residential, commercial (i.e. retail), non-residential and community facilities, and assembly and leisure uses. Up to 2,500 new residential and student units is proposed in a series of buildings, with the residential component provided across a range of unit sizes and tenures (i.e. private, affordable).

Within the Masterplan site involving the University of Westminster land, there will be a mix of demolition and retention of existing buildings falling within the boundary, with the new build catering for a flexible range of land uses involving a mixture of new teaching space as well as leisure facilities and student accommodation.

The scheme is still in the early design stages and a full strategy for the heights will be developed following feedback from the consultation and discussions with the Local Planning Authority. However, the intention is to keep the eastern and southern edges (nearest to Northwick Park and the golf course) lower with the heights rising towards the existing massing of the hospital and university buildings. Heights in this area are intended to be comparable to the existing buildings on the hospital and university land. The current design is evolving and subject to consultation. However, for the purposes of this scoping opinion, maximum heights are tested. Current design proposes low level building heights on the park edge - ranging from 3 to 12 storeys across the majority of the site. The tallest landmark building will be up to 15 storeys in height.

The Masterplan seeks to increase the permeability of the area for pedestrians and cyclists with new connections to existing routes and local transport such as Northwick Park station, South Kenton station and nearby bus stops. The development will provide some car parking, but the proposals will encourage the future population to use more sustainable modes of transport wherever possible. Parking will be mostly situated off-street to enhance the public realm.

The Masterplan will provide new green and amenity spaces for residents and visitors to enjoy; these will include areas for seating and new planting helping to improve the outside environment.

Relocation of Northwick Park Sports Pavilion

The Masterplan application proposes the relocation of the Northwick Park Sports Pavilion to the

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Northern portion of the Masterplan application site (refer to land owned by LB Brent on “Boundary Plans”). Relocating the building would allow for improved sports facilities (changing rooms) as well as providing additional community benefits. This relocation would allow the existing Pavilion building to be removed and the area of land on which it sits to be returned to open space (in accordance with its MOL designation).

Detailed Application The application for full planning permission for the area comprising the Detailed Application sites A1

and A2 (the detailed application extent encompassing areas A1 and A2 is shown on Figure 3 and Appendix A) will be for the redevelopment of the area currently comprising the car park, the social club, the Northwick Park Nursery and Preschool, and non-residential units (in connection with NHS hospital – Use Class D1). The application boundary also includes the current energy centre / boiler house serving the Hospital (which is being relocated onto Hospital land).

The development proposed as part of the Detailed Application will involve demolition of the existing buildings and construction of new build to provide for a residential led (Use Class C3), mixed use development comprising retail space (Use Class A1-A3), and re-provision of the nursery or community facility (Use Class D1-D2).

The Detailed Application will provide discrete plots with new build blocks varying in height, with building heights ranging from 3 to 12 storeys, with the tallest building up to 15 storeys . The development comprising the Detailed Application will provide a total floorspace of up to 55,500 square meters (m2) gross internal area (GIA) and to provide between 600 and 700 residential units.

Car parking for the development comprising the Detailed Application will be mostly situated off-street to enhance the public realm, by way of ‘podium car parking’ (i.e. cars parked beneath the new build blocks at ground level), but parking will be limited to encourage new residents to use more sustainable modes of transport wherever possible. The provision of amenity space for residents and visitors will be located at podium level, and landscaping details will be provided for the podium areas, as well as within the public realm along pedestrian and vehicle routes.

Highway Works Application The area comprising the Highway Works Application is the stretch of ring road along the northern

boundary of the NHS Hospital site (comprising Northwick Park Hospital, and St Mark’s Hospital), with works extending to include the junction with the A404 Watford Road (proposed upgrade), as well as works along Watford Road itself and the Hospital’s existing accesses from Watford Road.

Subject to discussions with TfL, there would be changes to the existing three bus stops and three bus stands to the west of the Hospital buildings adjacent to Watford Road. There will be no loss of stops or stands.

The works to the road will improve facilities which do not adequately provide for the current uses, facilitate the movement of the additional traffic generated by the Proposed Development, and will include cycle provision, footways and traffic lanes (on the local roads). The proposed upgrade to the junction on Watford Road will enable a right-turn entry which will remove U-turning traffic at Northwick Park roundabout and improve the flow of traffic along the corridor.

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PLANNING CONTEXT Planning Policy Context

The EIA will consider legislation and relevant national and local planning policy guidance as summarised below

It is noted that whilst relevant policies identified from the key planning policy documents will, in some instances, help inform the scope and the methodology of the technical assessments within the EIA; it is not the purpose of the ES to appraise the Proposed Development against relevant national, regional and local planning policy standards / targets. The compliance with and performance of the Proposed Development against the relevant planning policies will be appraised within the Planning Statement, which will be a standalone document that is submitted to accompany the planning application(s).

Where planning policy informs the scope and the methodology of the technical assessments of the EIA, the policies will be presented in the ES (in the relevant technical topic chapters) and discussed as necessary. Any policy detail required to support the relevant impact assessment scope, methodology or assessment of effects, will either be provided within the technical topic chapter itself or within an appendix to the ES.

National Planning Policy and Guidance

The EIA will have regard to the National Planning Policy Framework (NPPF)14. The NPPF sets out the Government's economic, environmental and social planning policies for England. The policies contained within the NPPF articulate the Government’s vision of sustainable development, which are intended to be interpreted at a local level, to meet the requirements of local aspirations.

The EIA will also refer to, as relevant to the EIA technical topics, the Planning Practice Guidance (PPG), which is an online resource. The PPG aims to make planning guidance more accessible, and to ensure that the guidance is kept up to date.

National Planning Policy Framework (2019)

The revised National Planning Policy Framework was last updated in June 2019 and sets out the government’s planning policies for England and how these are expected to be applied. This revised Framework replaces the previous NPPF first published in March 2012. Its substantive replacement was published on 24 July 2018 and updated 19 February 2019 and 19 June 2019.

Regional Planning Policy and Guidance

The ES will have regard to the following key regional strategic planning documents. Any additional regional planning policy and guidance documents considered relevant to the technical assessments which are covered by the EIA will also be considered:

• The London Plan: The Spatial Development Strategy for Greater London Consolidated with Alterations Since 2011 (March 2016) – hereafter referred as ‘the London Plan’;

• An updated Draft London Plan had been first published for public consultation (ended in March 2018), and resulted in an updated version being published with some ‘minor suggested changes’ (August 2018). The Draft London Plan then proceeded to the next stage of ‘Examination in Public’ (EiP), which commenced January 2019 and the final session was held May 2019. This process has resulted in ‘further suggested changes’ being accounted for within an updated ‘consolidated’ version (published July 2019), which shows all of the Mayor's suggested changes following the EiP of the draft London Plan.

14 Source: https://www.gov.uk/government/publications/national-planning-policy-framework--2

https://www.gov.uk/government/publications/national-planning-policy-framework--2

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- The current London Plan is still the adopted Development Plan for London, but the Draft London Plan is a material consideration in planning decisions. The significance given to it is a matter for the decision maker, but it gains more weight as it moves through the process to adoption.

- Where appropriate, the Draft London Plan will be taken into account within the ES and the assessments.

• Supplementary Planning Guidance (SPG) (i.e. further guidance on policies in the London Plan that can’t be addressed in sufficient detail in the plan itself).

Local Planning Policy and Guidance

Current Local Plan

Key local planning policy documents that will be considered throughout preparation of the ES as relevant include those documents that make up the Local Plan for the LBB:

• London Borough of Brent ‘Core Strategy’ (2010);

- The Core Strategy was adopted by LBB as the first of a suite of Development Plan Documents (DPD) forming the Local Development Framework (LDF).

- The Core Strategy sets out the spatial vision of how Brent should be in 2026 and how this will be achieved, by setting how the overarching spatial strategy and key planning policies, which will shape new development in the borough. It sets out the basic planning strategy for future development of the borough, and aims to protect the borough’s suburban character and its open spaces whilst promoting growth and regeneration mainly in five growth areas. Strategic policies include the number of houses to be built and additional to be provided jobs in the Borough.

• London Borough of Brent ‘Development Management Policies’ (2016);

- This Development Management Policies document sets out the Council’s policies which along with other policies within the National Planning Policy Framework, London Plan, Brent Local Plan (including the Core Strategy) and Neighbourhood Plans, will be used for the determination of planning applications for development in the borough.

• Site Specific Allocations DPD (2011)

- This DPD sites in Brent. This DPD sets out the planning policies and guidance for the future development of over 70 key opportunity sites around the borough, including identifying uses and development principles for major development. The planning policy for these sites is based upon the principles for development established by the Brent Core Strategy (2010). The DPD provides more detailed planning guidance for the development of sites that will deliver new housing, commercial or community facility development, and indicates what uses are appropriate for each site as well as setting out the special requirements that developers have to consider in drawing up proposals.

Draft Local Plan

Since the principal elements of the Local Plan were adopted (Core Strategy 2010, Site Allocations 2011), the national policy (through the NPPF and PPG) has undergone some fundamental changes. In addition, there has also been some fundamental changes to the London Plan (i.e. the borough’s annual housing target increased).

To address the changes, the LBB has started work on a new Local Plan review. The review is proposing to replace many of the existing Local Plan policies, and it seeks to simplify the Plan and make it more

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understandable.

The LBB have produced a ‘Preferred Options Local Plan’, which was issued for consultation between November 2018 and January 2019. This draft set out the main issues facing the borough and policies that will manage the future development of the borough until 2041 and beyond. It built on a range of options set out in the previous draft, and also identified sites to be allocated for development.

In terms of next steps, the LBB will consider all representations made during the consultation. The main issues raised and how the LBB has addressed them will be set out in an updated version (Proposed Submission Consultation). Any changes proposed as a result of the consultation and other factors will be included in a final draft of the Local Plan, known as the ‘Publication version’ (for submission and examination).

Indicative timescales for the draft Local Plan is for submission and examination in 2019, and adoption in 2020. Given the current status of the Draft Local Plan, it does not currently have sufficient weight for consideration in the ES. However, where appropriate the Draft Local Plan would be considered for certain assessments and clearly outlined within the relevant ES Chapter.

LBB Site Allocation – Masterplan

Local Plan

The current Local Plan identifies that the Northwick Park Allocation Area (known as Northwick Park Hospital 15) includes both hospitals and the associated hospital infrastructure (including residential dwellings and social infrastructure to the east), as well as the Ducker Pool to the south. This allocation area does not include the infrastructure associated with the University of Westminster (Harrow Campus). The Allocated Use is identified as the following:

Redeveloped hospital with ancillary retail and leisure uses. Community use (Use Class D1) and enabling residential development may be appropriate alternative uses for parts of the site that are surplus to the requirements of the new hospital. Development should be in accordance with an agreed masterplan. Development should have regard to and improve cycle routes running from east to west and north to south and the bus access should be relocated so as to remain in close proximity to the entrance of the hospital. Step free access to the local Underground station will also be sought. Proposals should conserve and enhance the Nature Conservation designation and the Metropolitan Open Land designation of the Ducker Pond part of the site.

Draft Local Plan

As part of the review to the Local Plan, the proposed site allocation for Northwick Park has also been reviewed. Within the Draft Local Plan, the masterplan area is situated within the Site Allocation: BNWGA1 – Northwick Park Growth Area. The proposed site allocation area covers the previous allocation area (with the exception of the Ducker Pool), with the additional inclusion of the Northwick Park Pavilion, Northwick Park Station, and the University of Westminster Campus land. The allocated use is identified as the following:

Growth Area - the site has been allocated for mixed used development. Additional residential development to enable upgrades/ refurbishment to the existing and retained Northwick Park Hospital and University of Westminster facilities. A replacement sports pavilion, small amount of commercial floorspace, and possibly new small-scale non-acute medical facilities to also be provided on site.

The allocation proposes an indicative capacity for approximately 3,600 units, of which 2,600 are net additional.

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Other Guidance

Any additional planning policy and guidance documents considered relevant to the technical assessments which are covered by the EIA will also be considered.

In addition, where relevant to the assessment, the technical chapters will also present a summary of any pertinent recognised industry guidance documents.

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EIA METHODOLOGY EIA Approach and Methodology

In addition to the EIA Regulations, there is also guidance available that has been referenced where appropriate, including but not limited to:

• at a European level, reference has been made to the European Commission’s (EC) various EIA guidance documents available here: http://ec.europa.eu/environment/eia/eia-support.htm

• at a domestic level, reference has been made to the Department for Communities and Local Government’s (DCLG) overarching PPG;

• in addition, the Department for Transport ‘Design Manual for Roads and Bridges Volume 11: Environmental Assessment’ has been referred to as applicable;

• in relation to publications from professional bodies, reference has been made to IEMA publications as these include best practice/suggested improvements to the EIA process. This includes:

- IEMA’s ES Review Criteria (COM3-6);

- ‘Guidelines for Environmental Impact Assessment’ (2004);

- ‘Special Report into the State Environmental Impact Assessment Practice in the UK’ (2011);

- ‘Shaping Quality Development’ (2015);

- ‘Delivering Quality Development’ (2016); and

- ‘Delivering Proportionate EIA’ (2017).

• whilst primarily written for major infrastructure projects, reference is also made to guidance notes published by the National Infrastructure Planning where appropriate, as these can include relevant/helpful information;

• whilst written for applications submitted within the London Borough of Tower Hamlets (LBTH), reference is also made to ‘Tower Hamlets Council EIA Scoping Guidance’15, as it includes useful information; and

• applicable case law.

In accordance with the EIA Regulations and best practice guidance documents, the EIA will comprise an assessment for each of the relevant technical topics against an appropriate baseline condition of the site and surrounding area, using methods of prediction including established standards and industry guidelines and techniques confirmed as part of the EIA Scoping process. In all cases, the source data and guidance used to establish the baseline conditions and assessment methodology will be clearly set out within the ES.

Baseline Conditions Baseline assessments will utilise any existing and available information, as well as new information

either collected through baseline surveys undertaken during the course of the EIA process or additional information provided as part of the EIA Scoping Opinion and consultation process. This information will be used to present within the ES (within the individual technical chapters) an up to date description of

15 Source: https://www.towerhamlets.gov.uk/Documents/Planning-and-building-control/Development-control/Revised_Scoping_Guidance_V2_Final.pdf

https://www.towerhamlets.gov.uk/Documents/Planning-and-building-control/Development-control/Revised_Scoping_Guidance_V2_Final.pdf

https://www.towerhamlets.gov.uk/Documents/Planning-and-building-control/Development-control/Revised_Scoping_Guidance_V2_Final.pdf

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the current baseline conditions of the site and surrounding area.

In most cases, the baseline represents the existing baseline conditions i.e. the environmental conditions of the site and surrounding area at the time of the assessment (i.e. in the assessment year of 2017/2018). Certain topics however may require the use of annualised data (e.g. air quality, where a data set is from the preceding year) or model assumptions to define the baseline conditions. This is particularly relevant to the assessment of effects relating to road traffic, specifically highways, air quality and noise effects. In all cases, the source of the baseline data and the justification for its use will be clearly described within the ES.

Evolution of the Baseline / Do Nothing Scenario

As per the requirements of the 2017 EIA Regulations, consideration as to how the existing baseline conditions may evolve in the future in the absence of the Proposed Development (i.e. the “Do Nothing Scenario”) will be presented in the ES (within the individual technical chapters). An outline of the proposed approach adopted in the ES will be described within ES Chapter 2: EIA Methodology (Volume 1). The likely evolution of the baseline conditions in the absence of the Proposed Development will be quantified where possible, and where it is not possible, a qualitative review will be presented.

Phasing of the Proposed Development As appropriate to the topic in question, the technical chapters of the ES will address the phased delivery

of the Proposed Development (i.e. sequenced works programme addressing the construction at different timescales of discrete development plots within the site).

An outline of the proposed approach adopted in the ES will be described within the EIA Methodology ES Chapter (Volume 1).

Demolition and Construction The ES (within a non-technical chapter titled ‘Demolition and Construction’) will provide an outline of

the anticipated demolition and construction programme and related activities and aspects (i.e. demolition and enabling works, substructure works, superstructure works etc., demolition waste volumes and construction material quantities, HGV movements and HGV routing). In addition, key environmental controls and management measures relevant to the Proposed Development (including relevant codes of construction practice) will be presented.

Timeslice Methodology

It is currently envisaged that the demolition and construction programme will present the works for each development plot being phased in terms of start and completion. The proposals for the demolition of existing buildings and infrastructure and the construction of the Proposed Development will be assessed based on programme of works that is considered to be reasonable and achievable and which acknowledges the phased delivery of the scheme.

Reflecting the programme, the EIA will assume that multiple demolition and construction activities are occurring on site at any one time across the various development plots within the site. The timescales for the works and assumptions made about sequencing of works, plant and equipment and road traffic (HGV) movements will be clearly defined within the ES. The ES will identify a selection of ‘timeslices’ with each timeslice representing a point in time when multiple works are occurring across the site. The ‘timeslice’ approach will be adopted to gain an understanding of the potential for ‘nuisance’ effects to sensitive receptors throughout the duration of the demolition and construction works.

The timeslice methodology also enables any intermediate stages of the Proposed Development, for example where parts of the scheme are complete and occupied whilst other parts are still undergoing construction. In terms of sensitive receptors, it enables consideration of both existing and new receptors

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introduced as part of the Proposed Development, over the course of the phased construction works.

An outline of the proposed approach adopted in the ES will be described within the EIA Methodology ES Chapter (Volume 1). As appropriate to the topic in question, each technical chapter of the ES will outline the approach taken to the assessment of the demolition and construction works and how addressed the phased delivery of the Proposed Development.

Approach to Assessment

This information will inform the demolition and construction impact assessments. Throughout the demolition and construction impact assessments, the assumption will be made that the standard environmental controls required under legislation and best practice guidance are met as a matter of course.

The assessment of the potential for likely significant effects arising during the demolition and construction works will be addressed within each of the individual technical assessment chapters of the ES and will assess against the defined Baseline Condition (described earlier). The demolition and construction assessments presented within the technical chapters of the ES will identify the need for any additional or bespoke environmental management or mitigation measures in order to avoid, prevent, reduce or off-set any significant adverse effects identified.

Where required, a description of any proposed monitoring arrangements will also be presented and would define (where appropriate) the procedures regarding the monitoring of the relevant significant adverse effects, the types of parameters to be monitored and the monitoring duration.

All the measures proposed within the technical chapters will be compiled and presented in a mitigation and monitoring schedule (to be presented as a separate chapter within the ES).

It is anticipated that any required demolition and construction related environmental management / mitigation and monitoring measures would be secured and controlled through an appropriate Construction Environmental Management Plan (EMP) (or equivalent) and it is proposed that the requirement for these documents be secured by means of suitably worded planning conditions to be attached to the permissions (if granted). Key mitigation and management controls that would later form part of a CEMP will be presented in the ES to help define the policies, procedures and management framework for the implementation of any identified specific environmental management and mitigation controls and monitoring.

Completed Development As discussed earlier, the redevelopment of the site is proposed to be subject of three separate planning

applications. This will see the submission of the following:

• Masterplan Application;


• Detailed Application;


- This application forms part of the first phase of the Masterplan application (for the Outline planning permission);

• Highway Works Application;

- Application for Full planning permission.

The planning strategy for the planning applications is to adopt a ‘layered’ approach, which involves submitting the Masterplan Application (Outline), Detailed Application (Full) and Highway Works

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Application (Full) separately, but at the same time.

It is proposed that all three planning applications will be catered for within a single ES to be prepared, with the particulars for each application addressed by assessment scenarios to be considered within the assessments of the ES Chapter.

Masterplan Application (Outline Planning Permission)

The development for the Masterplan Application will be set within the outline parameters set out in the Parameter Plans which will be submitted for approval as part of the outline planning application, and the accompanying Design Guidelines and Development Specification and Framework (DSF).

Outline proposals will involve any number of the following ‘matters’ being reserved to be defined in later, subsequent ‘Reserved Matters Applications’ to the Council:

• Scale of Development – will identify the maximum height, width and length parameters of the buildings in relation to their surroundings (provided by Parameter Plan).

• Layout of Development –the way in which buildings, routes and open spaces are provided, situated and orientated in relation to each other (provided by Parameter Plan);

• Appearance –the visual appearance of the Proposed Development, including the architecture of the external built form, façade treatment, materials, lighting, colour, texture, etc. (provided by Design Guidelines);

• Landscaping - the design, treatment and materiality of the public realm (provided by Parameter Plans and Design Guidelines); and

• Means of Access - the accessibility of the site for vehicles, cycles and pedestrians in terms of positioning and treatment of accesses and circulation routes and how these fit into surrounding network (provided by Parameter Plan).

In addition, Masterplan Application (Outline Planning Permission) will seek approval for an Amount of Development. This is the quantum (amount) of floorspace proposed for each use class (provided by Development Specification); in some cases, flexibility across a range of uses classes maybe sought.

Subsequent ‘Reserved Matters Applications’ will need to be made to the LBB to agree the design details that have been ‘reserved’ for later approval. The ‘Reserved Matters Applications’ will constitute ‘subsequent applications’ under the EIA Regulations. In planning and EIA terms this is therefore a multi-stage consent process.

Supporting Documentation

To allow for a robust assessment of the likely environmental and socio-economic effects within the ES of the development comprising the Masterplan Application will be based on a number of key planning application documents that will define and describe the development for the Masterplan Application (in relation to the ‘matters’ set out above), as follows:

• A Development Specification –will define and describe the principal components of the development proposed. It will include information associated with the amount of development and the proposed use classes comprising the development of the Masterplan Application.

• Parameter Plans –will provide outline parameters associated with the scale and layout of development proposed as part of the Masterplan Application;

• Access and Circulation Plans – will define the hierarchy of routes into and across the site for different vehicles types as well as details associated with access arrangements;

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• Design Code - contain the design principles that add further a further level of detail and definition to the Parameter Plans, to help inform and control future reserved matters applications with regard to layout, scale, appearance and landscaping. The Design Code will provide details of the anticipated quality and resolution of the resulting development. For clarity, the Design Code will set out the mandatory design controls.

• Design and Access Statement – this document will explain the design rationale, vision and objectives for the Proposed Development.

Methodology for Parameter Based Assessment

A methodology for the assessment of the scale and layout parameters would be developed for the purposes of the EIA. The technical assessments will ensure that a realistic worst-case scenario is assessed, supplemented by an assessment of the illustrative scheme where appropriate. This will be clearly set out in each chapter of the ES.

Scale and Layout

In relation to the scale and layout dependent studies of the EIA, the 3-dimensional envelope tested is the upper limit (maximum extent) of development in terms of scale and layout or in relation to a building-based parameter. The maximum permissible development (in terms of scale and layout or “massing”) is generally considered to represent a reasonable worst-case scenario as a larger development massing leads to, for example, increased view obstruction, greater overshadowing or daylight / sunlight reductions.

Amount of Development & Uses

The EIA, for example in relation to socio-economics and job creation, will consider the maximum provision of retail floorspace and the minimum provision of leisure floorspace. In addition, the socio-economics assessment of the EIA will consider job creation effects under a maximum leisure floorspace and a corresponding lower level of retail provision. This will ensure that the two ‘extremes’ in terms of the commercial element of the Proposed Development are tested where required.

In relation to traffic and transport, the assessment will consider the retail / leisure split in floorspace that generates the highest number of trips, thus testing a reasonable worst case.

The EIA will also address the flexibility sought with respect to the range of the number of residential units proposed.

The technical aspects of the EIA that will apply the amount of development (i.e. the proposed floor areas, which in turn are used to derive the number of residential units proposed) and land uses for the purposes of the assessment of impacts are as follows:

• Socio-Economics - specifically in relation to retail provision, employment creation, population and child yield estimates and so demand for social infrastructure (e.g. doctors, dentists, school places, open space etc.) and additional local spending; and

• Traffic & Transportation - specifically in relation to trip generation and model split (and so indirectly, Noise and Vibration and Air Quality in relation to the assessment of road traffic noise and air quality impacts).

Detailed Application and Highway Works Application (Full Planning Permission)

The ES will present a description of the Proposed Development in order to provide suitable context to enable the assessment of potential and likely significant environmental effects. Enough information on the Proposed Development, in terms of the key aspects (see below), will be presented to allow an understanding of the development being proposed, in order to enable the assessment of potential and

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likely significant environmental effects of the completed and operational development.

The ES will present information on the details of the development sought for approval as part of the Detailed Application and Highway Works Application (including but not limited to):

• Layout – building footprints;

• Means of access and egress and circulations – vehicular and pedestrian and cyclist accessibility into, out of and around the site;

• Scale – i.e. the massing, specifically heights of buildings;

• Amount of development – i.e. floors areas and uses classes, hotel room numbers;

• Appearance – architectural detail and materiality of the Proposed Development;

• Amenity space – amount of on-site provision;

• Ecological enhancements;

• Flood resilience measures;

• Energy strategy and plant locations;

• Deliveries and servicing strategy (including estimates of the types and quantities of waste anticipated, waste storage, handling and collection);

• Parking provision;

• Sustainability (including climate change resilience and adaptation (as relevant)); and

• Utilities (including water supply and wastewater / surface water drainage volume estimates).

The Detailed Application will be the subject of plans, sections and elevations to allow for a robust assessment of the likely environmental and socio-economic effects within the ES. For the Highway Works Application, details relating to the proposed highway works will be presented in a suite of appropriate plans / drawings

Proposed EIA Strategy – Approach to Assessment of Applications The planning strategy for the Proposed Development will be undertaken as a ‘layered’ planning

approach, involving the submission of the three separate planning applications at the same time.

It is understood that the applications for the Detailed Application and the Highway works are to be considered as ‘standalone’ applications i.e. that they can come forward in the absence of development of the Masterplan Application site. It is also understood that the implementation of the Highway works is likely to commence first, with the development comprising the Detailed Application shortly after. It is expected that by completion of the Detailed Application, the Highway works will also be complete.

The implementation of the Masterplan site is to come forward in phases (following the Detailed Application and the Highway works), with work starting on site A2 and programmed with sub-phases planned to progress continuously across the land subject to the two detailed planning applications, and then across the remainder of the Network owned land to the south.

Scenarios for testing in the EIA

To cater for the planning strategy, the EIA will assess the following scenarios:

• Main Assessment;

- Scenario 1 - Detailed Application + Highway works;

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- Scenario 2 - Detailed Application + Highway works + Masterplan Application;

Note – As the application for the Highway works is being submitted separately, there is the potential scenario that it may not be granted whilst the application for the Detailed Application is granted permission, or vice-versa. Whilst this can occur, it is understood as part of the wider agreements that the implementation of the Highway works is required to facilitate the development of the Detailed Application site, and the Masterplan Application site. Therefore, it is assumed for the purpose of the EIA that both the applications for the Detailed Application and the Highway works would be granted and both are implemented.

• Cumulative Assessment

- Scenario 3 - Detailed Application + Highway works + Committed Development schemes

- Propose to assess qualitatively (professional judgement of the assessor) based on the results of the quantitative assessments from the other scenarios (i.e. Scenarios 1, 2, 4). This is based on the current understanding of the nature and scale of other development schemes identified to date, and their location (i.e. not located adjacent to the site).

• Scenario 4 - Detailed Application + Highway works + Masterplan Application + Committed Development schemes.

Cumulative Effects and Effect Interactions The EIA will identify the potential for (a) Cumulative Effects and (b) Effect Interactions which are

described below.

Cumulative Effects

The EIA Regulations require that, in assessing the effects of a particular development proposal, consideration should also be given to the likely significant effects arising from the “cumulation with other existing and/or approved projects” (Schedule 4, 5(e)).

Cumulative effects can occur as interactions between the effects associated with several projects in an area (i.e. Committed Developments) which may, on an individual basis be insignificant, but together (i.e. cumulatively), result in a significant effect. Cumulative effects arising from the Proposed Development in combination with identified Committed Developments will be considered throughout the ES. Each individual technical chapter of the ES will present an assessment of the cumulative effects of the Proposed Development coming forward alongside the Committed Developments.

An initial search of Committed Developments located within a 1km radius from the site has been considered, as this spatial extent is conservatively considered appropriate for assessing cumulative effects in this context.

It is acknowledged that for certain topics of the EIA (i.e. townscape and visual), there may be a need to consider more distant schemes within the assessment. This is entirely appropriate, given the view locations associated with the townscape and visual effects assessment.

Similarly, with regards to traffic and transport considerations, major schemes beyond the 1km radius may also be included within the future baseline to acknowledge the spatial connection with the Proposed Development via the local road network. It should be noted that the approach to the assessment of cumulative effects in terms of traffic flows is synonymous with the impact assessment methodology by virtue of the fact that deriving a future road traffic baseline would account for road traffic movements associated with the cumulative developments as background road traffic growth, many of which are likely to be more than 1km distant on the road network from the site. This approach is entirely

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appropriate, given the potential for wider reaching traffic and transport impacts through the highway network.

Generally, the schemes to be included within the cumulative effects assessment will either have :

• Full planning consent or a resolution to grant consent; or

• Provide floorspace of more than 10,000m2 (Gross External Area (GEA)) of mixed-use floorspace, or

• Provide over 150 residential units.

These parameters have been set to allow all the schemes coming forward (i.e.. within the planning system) within the area of the site to be subject to an initial screening exercise to determine the schemes that, based on the scale of redevelopment (amount and mix of uses), could potentially have a cumulative effect with the Proposed Development and should be considered further within the cumulative effects assessment of the EIA.

By applying these parameters to all the schemes coming forward, the cumulative effects assessment of the EIA becomes more focused on the larger schemes (i.e. those with the potential to interact in a cumulative manner), rather than trying to assess all, including the smaller, domestic applications such as loft and garage conversions and changes of use.

Each technical chapter of the ES will consider the potential for cumulative effects associated with the list of schemes identified and will be clear on those schemes that are accounted for within the assessment (i.e. a smaller spatial extent less than the 1km radius may be appropriate). Where this occurs, the methodology or reasoning for the approach taken will be presented in the ES Chapter.

Other schemes that are under construction, where the construction works are significantly progressed or where early phases are occupied, will be factored into the baseline conditions.

It is acknowledged that there may be other development schemes (in addition to those identified) that may have been recently submitted for planning but not yet determined that may be significant enough to warrant consideration within the cumulative effects assessment. The requirement to include any specific schemes that fall within this category should be identified by the LBB through the EIA Scoping Opinion. Should other development schemes that are at the pre-application stage or that have been submitted for planning but not yet determined be identified by the LBB for inclusion in the cumulative effects assessment (in addition to those identified), it should be acknowledged by the LBB that the ES will address these as far as is reasonably practicable16 and that the assessments will be based on the information available on these schemes that is within the public domain.

A preliminary list of Committed Developments for consideration within the EIA has been identified and is presented in Appendix B of this Scoping Report.

In-Combination Effects / Effect Interactions

Effect interactions occur as interactions between effects associated with just one project, i.e. the combination of individual effects arising as a result of the Proposed Development, for example effects in relation to noise, airborne dust or traffic on a single receptor.

Effect Interactions from the Proposed Development itself on particular receptors at the site and within the surrounds will be considered during the demolition and construction works and also once the Proposed Development is completed and operational. Dependent on the relevant sensitive receptors, the assessment will focus either on key individual receptors or on groups considered to be most

16 Where considered appropriate – the assessment of these schemes may be undertaken in a qualitative manner, with the lack of certainty noted in each assessment.

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sensitive to potential effect interactions. The potential interaction of residual effects that are of minor, moderate or major scale, will be considered within this assessment. Residual effects which are negligible, or neutral will be excluded from this assessment as by virtue of their definition, they are considered to be imperceptible.

There is no established methodology for assessing the impact of cumulative effects on a particular receptor. Therefore, a significance threshold will not be applied to the combination of individual effects; instead the effect interaction will be discussed and where possible, professional judgement will be applied to determine whether the effect interaction is considered significant.

Consideration of effect interactions will be presented within the ES in a separate chapter (i.e. Effect Interactions (Volume 1)).

Alternatives In addition, the EIA Regulations require (Schedule 4) that the ES provides “a description of the

reasonable alternatives […] relevant to the proposed project and its specific characteristics” which have been considered by the Applicant and “an indication of the main reasons for selecting the chosen option, including comparison of environmental effects”.

The ES will consider the ‘Do Nothing’ / ‘No Development Alternative’ which relates to leaving the site in its current state. The environmental pros and cons of the ‘Do Nothing’ / ‘No Development Alternative’ shall be identified.

The ES will also consider any ‘Alternative Sites’ that have been considered by the Applicant; and will address why the selected site is the most appropriate from an environmental perspective.

The ES will summarise the evolution of the Proposed Development, the alternatives considered, and key modifications made during the design process. Environmental considerations which have influenced this process will be discussed, and a qualitative comparison will be undertaken of the different design options and their relevant environmental effects. Matters that will be considered in terms of design evolution include land uses, layout, building heights and massing. The preferred design alternative, culminating with the Proposed Development being sought for approval, will be discussed.

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DETERMINING EFFECT SIGNIFICANCE – TERMINOLOGY AND APPROACH Reference to ‘Impact’ and ‘Effect’

It is noted that the terms ‘impact’ and ‘effect’ are distinctly different. Having gained an understanding of the likely impact it is then important to know whether the change in environmental or socio-economic conditions results in a significant environmental effect. The impacts of the Proposed Development may or may not result in significant effects on the environment, depending on the sensitivity of the receptor and possible other factors (such as duration). The assessment of the likely significant effects of the development is a requirement identified by Schedule 4 of the EIA Regulations.

Receptor Sensitivity and Magnitude of Impact To achieve a consistent approach across the different technical disciplines addressed within the ES

(Volume 1), assessments will broadly define the sensitivity of the receptors that could be affected by the Proposed Development and the magnitude of impact or change from the baseline conditions in order to derive the resultant effect. Technical specialists will use their own approach or amend the approach stated below based on what is appropriate for their assessments.

Terminology to describe the sensitivity of receptors and magnitude of impact or change from the baseline conditions is broadly as follows:

• High;

• Medium;

• Low;

• Very Low; or

• No Impact (in relation to magnitude of impact or change only).

Where there is no impact/change, no assessment will be required due to there being no potential for significant effects.

Each of the technical assessment chapters of the ES (Volume 1) will provide further detail on the definition of each of the above terms specific to the topic in question and will also provide the criteria, including sources and justifications, for quantifying the different levels of receptor sensitivity and ‘impact magnitude’. Where possible, this will be based upon quantitative and accepted criteria (for example, national standards for air quality and noise), together with the use of value judgement and expert interpretation.

Identification of a Resultant Effect The basis for determining the resultant effect generally takes into account the sensitivity of the receptor

and magnitude of impact or change from the baseline conditions. A generic matrix that combines the sensitivity of the receptor and the magnitude of impact to identify the resultant effect is provided within Table 3.

Resultant Effects

Receptor Sensitivity Magnitude of Impact

High Medium Low Very Low

High Major Major Moderate Minor

Medium Major Moderate Minor Negligible

Low Moderate Minor Negligible Negligible

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Receptor Sensitivity Magnitude of Impact


Very Low Minor Negligible Negligible Negligible

Effect Scale The categories and definitions of the ‘scale’ of the resultant effect i.e. definitions of Major, Moderate,

Minor and Negligible effects will be adjusted to suit the technical topic in question; where this is the case revised definitions of effect scale will be presented in the technical assessment chapters of the ES (Volume 1) and in ES Volume 2.

Where there is no impact to a receptor and therefore ‘no effect’, this will be stated.

Table 4 provides the broad definition of the ‘scale’ of the resultant effect.

Broad Definitions of the Scale of the Resultant Effect Type of Effect Description

Major These effects may represent key factors in the decision making process. Potentially associated with sites and features of national importance or likely to be important considerations at a regional or district scale. Major effects may relate to resources or features which are unique and which, if lost, cannot be replaced or relocated.

Moderate These effects, if adverse, are likely to be important at a local scale and on their own could have a material influence on decision-making.

Minor These effects may be raised as local issues and may be of relevance in the detailed design of the project, but are unlikely to be critical in the decision-making process

Negligible Effects which are beneath levels of perception, within normal bounds of variation or within the margin of forecasting error, these effects are unlikely to influence decision-making, irrespective of other effects.

Effect Nature Table 5 provides definitions of the ‘nature’ of the resultant effect i.e. definitions of Adverse and

Beneficial.

Definition of the Nature of the Resultant Effect Type of Effect Description

Adverse Detrimental or negative effects to an environmental / socio-economic resource or receptor. The quality of the environment is diminished or harmed.

Neutral The quality of the environment is preserved or sustained or there is an equal balance of adverse and beneficial effects.

Beneficial Advantageous or positive effect to an environmental / socio-economic resource or receptor. The quality of the environment is enhanced.

Geographic Extent of Effect The ES (Volumes 1 and 2) will identify the geographic extent of the identified effects. At a spatial level,

‘site’ or ‘local’ effects are those affecting the site and neighbouring receptors, while effects upon receptors in the LBB beyond the vicinity of the site and its neighbours are considered to be at a ‘district / borough’ level. Effects affecting Greater London are considered to be at a ‘regional’ level, whilst those which affect different parts of the country, or England as a whole, are considered being at a ‘national’

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level.

Effect Duration For the purposes of the ES, effects that are generated as a result of the demolition and construction

works (i.e. those that last for this set period of time) will be classed as ‘temporary’; these maybe further classified as either ‘short term’ or ‘medium-term’ effects depending on the duration of the demolition and construction works that generate the effect in question. Effects that result from the completed and operational phases of the Proposed Development will be classed as ‘permanent’ or ‘long-term’ effects.

Direct, Indirect and Reversible Effects The ES will identify whether the effect is ‘direct’ (i.e. resulting without any intervening factors) or ‘indirect’

or ‘secondary’ (i.e. not directly caused or resulting from something else).

Whether the effect is ‘reversible’ or ‘irreversible’ is also identified.

Identification of Significant Effects Following identification of an effect, the scale of the effect, its nature, geographic extent and duration

and whether the effect is direct or indirect using the above summarised terminology, a clear statement will then be made within the ES (Volumes 1 and 2) as to whether the effect (pre-mitigation) is significant or not significant. Each technical topic addressed within the ES will be clear on which effects are significant and those which are not. This is likely to differ across technical topics.

Following identification of whether the potential or ‘unmitigated’ effects are significant or not, the requirement for any mitigation to either eliminate or reduce likely significant adverse effects will be identified.

Where mitigation measures are identified to either eliminate or reduce likely significant adverse effects, these will be incorporated into the Proposed Development, for example either through the design, or will be translated into demolition and construction commitments; or operational or managerial standards / procedures.

The ES will then highlight whether the ‘residual’ effects remain significant following the implementation of suitable mitigation measures and will classify these in accordance with the terminology defined above.

As a general rule, the following applies:

• ‘Moderate’ and ‘Major’ effects are ‘significant’; and

• ‘Minor’ and ‘Negligible’ effects are ‘not significant’.

In all cases, the overall approach and specific methods of predicting the likely magnitude of impact and resultant scale, nature, geographic extent, duration etc. and significance of an effect will be set out in each of the EIA technical assessments / ES technical topic chapters. Where used, recognised specific predictive methods will be referenced. Any assumptions or limitations to knowledge will be stated.

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SCOPE OF EIA - SUMMARY This section provides a summary of the environmental technical topics ‘scoped-in’ and ‘scoped-out’ of

the EIA. Further detail on each topic is provided in the following sections of this EIA Scoping Report.

Those topics where likely significant effects are anticipated to arise in connection with the Proposed Development and therefore be addressed in the EIA have been scoped in, and a description is provided which outlines the proposed scope and methodology of assessment to be undertaken for the respective environmental topic.

Where appropriate, reference is also made to other relevant planning application documents, such as the Sustainability Statement, Energy Strategy, etc.

Topics Scoped In • Air Quality;

• Climate Change;

• Daylight, Sunlight, Overshadowing, Light Pollution and Solar Glare;

• Health;

• Noise and Vibration;

• Socio-Economics;

• Traffic and Transport;

• Townscape and Visual Impact Assessment; and

• Wind Microclimate;

Topics Scoped Out • Archaeology (Buried Heritage);

• Aviation;

• Built Heritage;

• Daylight, Sunlight, Overshadowing (Internal);

• Ecology and Biodiversity;

• Geo-environmental (Ground Conditions, Groundwater);

• Land Take and Soils;

• Project Vulnerability - Accidents or Disasters;

• TV and Radio Interference; and

• Water Resources, Drainage and Flood Risk.

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TOPICS TO BE SCOPED IN Air Quality

The Air Quality Assessment will cover potential effects associated with the construction and operational phases, and determine whether the Proposed Development is ‘air quality neutral’.

Baseline

The LBB has declared an Air Quality Management Area (AQMA) covering the entire area south of the North Circular Road and all housing, schools and hospitals along North Circular Road, Harrow Road, Bridgewater Road, Ealing Road, Watford Road, Kenton Road, Kingsbury Road, Edgware Road, Blackbird Hill, Forty Lane, Forty Avenue and East Lane, due to exceedances of annual mean NO2 and daily mean PM10 objectives. Part of north western section of the Proposed Development lies within this AQMA, as shown in Figure 10 below. The Proposed Development also lies within close proximity of Harrow AQMA, which has been declared for the whole borough, also for exceedances of annual mean NO2 and daily mean PM10 objectives.

The LBB monitors concentrations of NO2 and PM10 at four automatic monitoring stations within the borough. None of these sites are within close proximity to the Proposed Development site. 25 passive diffusion tubes are used throughout the borough to monitor annual mean NO2 concentrations. The nearest monitoring location is located on A4006 Kenton Road and measured an annual mean NO2 concentration below the objective in 2017.

Figure 10 Declared AQMAs and Nearest Local Authority Monitoring Location

Potential Effects

Construction

The air quality assessment will list recommended mitigation measures to apply during demolition and

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construction works, based on the level of risk identified in the construction dust risk assessment. With recommended mitigation measures in place, it is expected that residual construction dust and PM10 effects would be not significant.

Relevant guidance from the Institute of Air Quality Management (IAQM)17 states that “experience from assessing the exhaust emissions from on-site plant (also known as non-road mobile machinery or NRMM) […] suggests that they are unlikely to make a significant impact on local air quality and in the vast majority of cases they will not need to be quantitatively assessed”. Significant effects as a result of NRMM emissions can thus be discounted. However, suitable mitigation measures for site plant will be presented as part of the mitigation measures based on advice presented in the IAQM177 and Greater London Authority (GLA)18 guidance documents.

Operation

The overall air quality effects associated with the operational phase of the Proposed Development will be determined based on predicted impacts at receptors and professional judgment. Where possible, and if significant effects are predicted, mitigation measures will be proposed so that residual effects are not significant.

Potential Sensitive Receptors

For the assessment of the operational Proposed Development, suitable receptor locations (both existing and introduced) will be identified based on detailed maps, satellite imagery, and plans of the Proposed Development. The locations selected will be dependent on the layout of the Proposed Development, the exact location of the exhaust/s serving any proposed centralised energy plant (if included), and the volume and routing of traffic generated by the Proposed Development. Receptors will be identified to represent a range of exposure, including worst-case locations.

Receptors (including future receptors introduced as part of Cumulative Schemes) will include residential dwellings and educational establishments in the study area, for example along Watford Road and Kenton Road and within St. Mark’s Hospital, Northwick Park Hospital and University of Westminster - Harrow Campus. The study area will be defined by comparing the predicted traffic generation of the Proposed Development to screening criteria published by the Institute of Air Quality Management (IAQM)19. A review of roads where changes in traffic flow exceed these criteria will be undertaken to determine the extent of the study area, and sensitive receptors will be selected close to each of these roads.

All receptors where the air quality objectives apply will be considered to be ‘high’ sensitivity receptors and will be taken into account as part of the assessment; receptors considered to be of a lower sensitivity will not be addressed within the assessment. Figure 11 identifies likely receptors. These are indicative locations, and final receptors will be determined when undertaking the assessment, based on roads affected by increases in traffic and areas with greatest impacts from energy plant emissions (if included).

17 IAQM (2016) Guidance on the Assessment of Dust from Demolition and Construction v1.1 18 GLA (2014) The Control of Dust and Emissions from Construction and Demolition SPG 19 Moorcroft and Barrowcliffe et al (2017) Land-Use Planning & Development Control: Planning For Air Quality v1.2

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Figure 11 Possible Receptor Locations

The assessment of on-site construction activities will consider the potential for impacts within 350 m of the site boundary and within 50 m of the routes to be used by construction vehicles up to 500 m from the site entrance/s20. Relevant receptors in the area include residential dwellings, St Mark’s Hospital, Northwick Park Hospital, University of Westminster - Harrow Campus, Harrow High School, Harrow Primary School and Carrick House Nursing Home (high sensitivity receptors); as well as the shops on Kenton Road and Harrow School Playing Fields (medium sensitivity receptors) and Harrow Hill Golf Course (low sensitivity receptor). Receptors will be identified based upon the distance bandings set out in GLA guidance21. Figure 12 shows the extent of the 350 m band around the site boundary, and thus provides an indication of receptors potentially affected by construction dust.

20 GLA (2014) The Control of Dust and Emissions from Construction and Demolition SPG, Available: https://www.london.gov.uk/what-we-do/planning/implementing-london-plan/supplementary-planning-guidance/control-dust-and. 21 GLA (2014) The Control of Dust and Emissions from Construction and Demolition SPG

https://www.london.gov.uk/what-we-do/planning/implementing-london-plan/supplementary-planning-guidance/control-dust-and

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Figure 12 Area Considered as Part of the Demolition and Construction Assessment

Scope of Assessment

The scope of the air quality assessment will include:

• The determination of baseline air quality conditions through examination of local monitoring data and other publically available data;

• The identification of relevant sensitive receptor locations for the construction and operational phases of the Proposed Development;

• A qualitative assessment of impacts of the Proposed Development on dust soiling and concentrations of PM10 resulting from activities during the construction period;

• Consideration to the potential impacts of emissions from heavy duty vehicles during the construction period;

• A quantitative assessment of the impacts of the completed and operational Proposed Development on concentrations of NO2, PM10 and PM2.5 from development-generated road traffic emissions in the proposed year of opening;

• A quantitative assessment of concentrations of NO2, PM10 and PM2.5 that future users of the completed and operational Proposed Development will be exposed to in the year of opening; and

• An air quality neutral assessment, in accordance with the requirements of Policy 7.14 of the London Plan22.

22 Mayor of London (2016) The London Plan (consolidated with alterations since 2011)

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Construction Impacts

The potential impacts from dust generated during the construction phase of the Proposed Development will be considered using the approach presented in the IAQM Guidance for assessing impacts from construction activities17, upon which the GLA’s guidance document on the Control of Dust during Construction and Demolition18 is based. Cumulative impacts arising from committed developments being constructed in the study area concurrently to the construction of the Proposed Development will also be considered.

The number of heavy duty vehicles (HDV) that will be in operation during the construction phase of the Proposed Development will be considered in the context of the guidance from IAQM and Environmental Protection UK (EPUK & IAQM)19. Where the number of HDVs is greater than the relevant screening criterion (25 Annual Average Daily Traffic (AADT) in an AQMA) on roads with relevant exposure, then detailed dispersion modelling will be considered to determine worst-case impacts on concentrations of NO2, PM10 and PM2.5 at existing sensitive receptor locations. Whether this is required or not will be determined once construction traffic flows are known.

Operational Impacts

The dispersion model ADMS-Roads will be used to quantify the impacts that road traffic emissions associated with existing and development-generated road traffic, will have on air quality at existing and proposed receptor locations.

The scenarios that will be considered as part the assessment will include:

• Current baseline scenario;

• Opening Year – without development scenario, but with cumulative developments; and

• Opening Year – with development scenario, also with cumulative developments.

Given the ‘layered’ approach to the planning applications, if considered necessary to provide a better understanding of the potential air quality impacts, an interim assessment scenario/s will be considered, taking account of the phasing of both the detailed and masterplan applications.

Background pollutant concentrations will be determined using data derived from the Background Maps published by Defra23.

Meteorological data will be taken from the RAF Northolt meteorological station. The year of meteorological data to be used in the dispersion model will be selected to match the latest with available local monitoring data.

The baseline road model output will be verified against appropriate monitoring data from the local authority, and an adjustment factor will be determined, in line with the methodology set out in the LAQM TG (16)24 guidance document.

The operational assessment will include a sensitivity test for the prediction of NO2 road traffic impacts to address elevated real-world nitrogen oxides emissions from certain diesel vehicles. This test will be carried out by applying adjustments to the ‘official’ emission factors and assumes that future-year technology might be less effective than has been assumed.

Potential Impact of On-Site Combustion

The energy strategy for the proposed development is not yet finalised. Should the strategy include on-site combustion plant, consideration will be given to the potential effects of emissions from the plant,

23 Defra (2019) Local Air Quality Management (LAQM) Support Website 24 Defra (2016) Review & Assessment: Technical Guidance LAQM.TG16

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and an assessment will be carried out in accordance with the guidance set out in EPUK and IAQM guidance19.

Impact of Railway Emissions

The Metropolitan railway line passes along the northern edge of the Proposed Development site and the Bakerloo and Overground railway lines are approximately 270 m to the east of the Proposed Development site. These lines are electrified and are not listed in Defra’s guidance24 as one of the railway lines with a heavy traffic of diesel passenger trains (i.e. which have the potential to significantly impact air quality). It is thus unlikely to significantly affect air quality conditions at the site of Proposed Development and a detailed assessment of railway emissions is scoped out of the air quality assessment. The air quality assessment will, however, include the general contribution from railway emissions to pollutant concentrations in the study area; as such emissions are included in Defra background maps.

Air Quality Neutral Assessment

The GLA has published Supplementary Planning Guidance on Sustainable Design and Construction25

aimed at ensuring that new developments are ‘Air Quality Neutral’. This will involve the calculation of emissions associated with the buildings and with the transport generated by their use. These emissions will then be compared with published benchmarks. Any excess emissions over and above the benchmarks will need to be reduced by mitigation or off-set.

Overall Significance and Mitigation

The predicted concentrations will be compared with the relevant air quality objectives and any exceedances will be highlighted. The overall effects significance will be evaluated using criteria recommended by the EPUK and IAQM19. Where possible, mitigation measures will be proposed in order to ensure that residual effects are not significant.

Appropriate mitigation measures, as listed in the GLA guidance document on construction dust18 will be proposed for the construction phase of the Proposed Development, based on the level of risk identified by the construction dust assessment.

Cumulative Effects

The potential for cumulative effects associated with the Proposed Development and other committed development will be addressed within the ES, for both demolition and construction related effects, and effects associated with completed and operational scheme.

25 GLA (2014) Sustainable Design and Construction Supplementary Planning Guidance

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Climate Change Recent changes to the EIA Regulations has introduced the requirement for the consideration of climate

as part of the EIA process. The EIA Regulations seek to account for climate by requiring a description of ‘the impact of the project on climate’ and ‘the vulnerability of the project to climate change’ (Schedule 4, paragraph 5(f)).

The Proposed Development’s Potential Impact on Climate

The approach to assessing the potential impact of the Proposed Development on climate will be undertaken in accordance with the Institute of Environmental Management and Assessment (IEMA) guidance ‘Assessing Greenhouse Gas Emissions and Evaluating Their Significance’26 (2017). This guidance sets out a ‘good practice’ approach to achieving a proportionate assessment of a development’s potential impact on climate and communicating the results in terms of a notional percentage contribution relative to a carbon budget, together with appropriate mitigation.

The guidance presents a series of principles developed by IEMA, which highlight that all Green House Gas (GHG) emissions contribute to climate change, and that the combined effect of all emissions draws us closer to the scientifically defined environmental limit for climate change. The guidance therefore suggests that, in the absence of any defined threshold or significance criteria, any GHG emissions or reductions from a project be considered as significant. The guidance also reinforces a key principle of EIA which is to reduce the impact of a project’s emissions at all stages of the lifecycle through mitigation.

Consistent with the guidance, the approach taken in the EIA will be to quantify the net GHG emissions27 from the Proposed Development and compare against an existing carbon budget (defined either at a global, national, regional, local or sectoral level) in order to contextualise the project’s carbon contribution by developing a sense of the scale of the emissions anticipated.

The ES will present the carbon mitigation being proposed, which will follow the principles of the carbon management hierarchy (i.e. avoid, reduce, off-set), in order to reduce as far as reasonably practicable, the anticipated GHG emissions over the Proposed Development’s lifecycle.

The assessment of GHG emissions (essentially a carbon footprint or ‘inventory’ of the Proposed Development) and an outline of the carbon mitigation measures proposed will be presented in a technical report and included within ES Technical Appendices (Volume 3). Relevant information out of this report (specifically relating to carbon mitigation measures) will be presented within the ES Chapter describing the Proposed Development (ES Chapter 4 - The Proposed Development (Volume 1)) and the chapter that outlines the demolition and construction works (ES Chapter 5 - Demolition and Construction (Volume 1)).

The Potential Impact of Climate Change on The Proposed Development

The approach to assessing the potential impact will be undertaken in accordance with the IEMA guidance ‘Climate Change Resilience and Adaption’ (2015)’28, which presents a framework for the consideration of climate change resilience and adaption in the EIA process. It recognises a need for a proportionate approach to the assessment, due to the uncertainties associated with predicting how the environment will respond to climate change.

The guidance advises on inter alia, defining the future climate scenario, the integration of climate change adaption into the design, and the process for EIA. The guidance also provides advice on the execution of the impact assessment across the technical topics, including the identification of the

26 IEMA (2015). Assessing Greenhouse Gas Emissions and Evaluating Their Significance (website: https://www.iema.net) 27 Determining the net GHG emissions contribution accounts for the existing GHG emissions within the project boundary prior to the project commencing, against the predicted project emissions. 28 IEMA (2015). Climate Change Resilience and Adaption (website: https://www.iema.net)

https://www.iema.net/

https://www.iema.net/

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climate related parameters which are likely to influence the project in question, and the anticipated changes to those parameters under a future climate scenario.

Consistent with the guidance, the EIA will describe a future climate scenario which will be developed through the use of the future climate projections published by the Met Office (through the UK Climate Projections (UKPC09) website29). The results include projections for variables including annual mean temperatures, and annual changes in summer and winter precipitation.

To describe the predicted future climate, it is proposed that the medium emissions scenario (A1B) for the 2080s will be utilised as the future baseline. The medium emissions scenario (A1B)30 is based on a future world of rapid economic growth and the rapid introduction of new and more efficient technologies, with a balance of non-fossil and fossil intensive energy technologies. The 2080s covers the years 2070 – 2099 and this is the timeframe considered most relevant to the Proposed Development. The projected change to the range of climatic conditions will adopt the 50% probability level, which is a central estimate adopted given the level of uncertainty associated with predicting the modelled scenarios.

The future climate change scenario will be considered within the ES across each of the technical topics being presented, and the level of assessment and methodology will be proportional to the available evidence base. The aim of the assessment will be to consider whether the effect on receptors (under the current condition, without climate change) are likely to be different under an alternative future climate regime; in particular, to identify whether the potential impacts of the Proposed Development will be worse or improve under the future baseline, and therefore if these changes alter the significance of effects identified for the Proposed Development under the current condition (without climate change). A key aspect of the assessment (within each of the technical topics presented) will be to identify the likely effect of those receptors considered more vulnerable to changes in climate, having taken into account the resilience and adaptive measures (being either design or management) which are proposed for the scheme in order to mitigate the risk presented by climate change.

Due to the level of uncertainty in both the future climate projections and how the future climate conditions may affect sensitive receptors, the assessment will be qualitative, based on objective professional judgement, unless where there is published, accepted quantifiable methods available (i.e. in relation to the assessment of flood risk).

The ES will present the adaption and resilience measures proposed as part of the description of the Proposed Development ES Chapter (Volume 1) and also report the process of design for the resilience and adaptive measures developed for the scheme as part of the consideration of alternatives (within the Alternatives and Design Evolution ES Chapter (Volume 1).

29 UKCP18 Guidance: Representative Concentration Pathways https://www.metoffice.gov.uk/binaries/content/assets/mohippo/pdf/ukcp18/ukcp18-guidance-rcp.pdf 30 As defined in the IPCC Special Report on Emissions Scenarios (SRES) (IPCC, 2000)

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Daylight, Sunlight, Overshadowing, Light Pollution and Solar Glare The application considers both a Detailed and Masterplan Applications for the site. As such, the

daylight, sunlight, overshadowing and solar glare assessment will consider the following scenarios:

• Scenario 1: Detailed Application + Highway Works Application (‘Detailed Application’)

• Scenario 2: Masterplan Application + Detailed Application + Highway Works Application (‘Masterplan Application’)

In addition, daylight and sunlight within the proposed residential dwellings will be considered, however this will be dealt with in a standalone report.

Baseline

The baseline daylight and sunlight conditions within each of the relevant surrounding sensitive receptors will be defined under the existing site conditions, by reference to the Vertical Sky Component (VSC), No-Sky Line (NSL) and Annual Probable Sunlight Hours (APSH) methods.

In order to consider baseline overshadowing conditions, the relevant existing surrounding outdoor amenity areas will be assessed using the Sun on Ground and Transient Overshadowing assessments. The Sun on Ground assessment will determine the proportion of the existing areas that currently see at least 2 hours of sunlight across their area on the 21st of March. The Transient Overshadowing assessment will provide a visual representation of the baseline shadow path at key times of the year.

With regards to solar glare, the existing buildings on-site are neither high-rise nor reflective; therefore, it can be said that there would no adverse instances of reflected solar glare in the baseline condition. Where this is the case, assessment is generally not deemed necessary.

Potential Effects

Demolition and Construction

The potential daylight, sunlight, overshadowing and solar glare associated with the Proposed Development that are anticipated to occur during the demolition and construction period of works are considered to be as follows (and as relevant to the scope of the assessment in terms of receptors identified below):

• Temporary changes to the daylight and sunlight amenity within surrounding residential properties and other properties identified which have a reasonable expectation to natural light;

• Temporary changes to overshadowing of surrounding outdoor amenity spaces; and

• Adverse reflected solar glare to drivers on surrounding roads.

Completed and Operational

The potential daylight, sunlight, overshadowing and solar glare effects associated with the Proposed Development that are anticipated to occur once the Proposed Development is completed and operational, are considered to be as follows (and as relevant to the scope of the assessment in terms of receptors identified):

• Changes to the duration and quality of daylight and sunlight amenity to surrounding residential properties and other properties identified which have a reasonable expectation to natural light;

• Changes to the incidence and duration of overshadowing experienced by surrounding outdoor amenity spaces;

• Adverse solar glare to drivers on surrounding railway lines, as a result of reflections from façade treatments of the Proposed Development

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Daylight and Sunlight

Residential receptors identified on nearby streets are considered sensitive in relation to daylight and sunlight and will therefore be included within the assessment. The following properties (sensitive receptors) will be included within the assessment of the Detailed Application (Scenario 1):

• Relevant neighbouring properties on Northwick Avenue;

• Relevant neighbouring properties on Nightingale Avenue, St Marks Close, and Northwick Close;

• Relevant student housing (Harrow Halls of Residence); and

• Northwick Park Hospital.

With regard to the assessment of the Masterplan Application (Scenario 2), the following properties (sensitive receptors) will be considered:

• Relevant neighbour properties on Northwick Avenue;

• Northwick Park Hospital.

Overshadowing

Areas of amenity space are considered most sensitive to overshadowing effects resulting from the Proposed Development. Owing to the southerly location of the sun path, only open spaces located from north-west through to north-east of the site require consideration in relation to overshadowing.

The following areas of amenity space have been identified as sensitive receptors in relation to the Detailed Application (Scenario 1) and will therefore, be included within the assessment:

• Relevant gardens serving properties on Northwick Avenue;

• University of Westminster Playing Fields; and

• Northwick Park.

The following areas of amenity space have been identified as sensitive receptors in relation to the Masterplan Application (Scenario 2) and will therefore, be included within the assessment:

• Relevant gardens serving properties on Northwick Avenue; and

• Northwick Park.

Should the TOS on the 21st of March indicate that the potential sensitive receptors previously identified will not be subject to additional shading, these receptors will not be assessed further within the EIA (with reasoning provided within the chapter regarding this approach).

Solar Glare

Signals or junctions on railways will be considered as part of the solar glare assessment. The assessment will consider drivers (sensitive receptors) on the railway line to the north of the site (serving the Metropolitan Line).

Scope of Assessment

The assessments will be carried out in accordance with the Building Research Establishment (BRE) Guidelines: Site Layout Planning for Daylight and Sunlight 2011, A Guide to Good Practice, Second

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Edition 201131, The analysis will be undertaken from a 3D computer model constructed using specialist software.

The daylight, sunlight, overshadowing and solar glare effects of the Proposed Development will be assessed against the baseline condition.

Demolition and Construction

Owing to the evolving and changing nature of demolition and construction activities, the assessment of potential effects during the demolition and construction of the Proposed Development on daylight, sunlight, overshadowing and solar glare to existing receptors will not be modelled, as the full effects would only be realised once the Proposed Development is completed and operational. Therefore, a qualitative assessment will be undertaken using professional judgement.

Completed and Operational

Daylight and Sunlight

In line with the BRE Guidelines, in the first instance an approach which adopts the ‘25o line’ will be used to determine whether the receptor would experience noticeable impacts. The ‘25o line’ is taken from the centre point of the lowest neighbouring window and if the angle is less than 25o for the whole of the development then it is unlikely to have a substantial effect. Where the proposal does not subtend the ‘25o line’, further technical analysis using the VSC and NSL assessments will be undertaken for the Proposed Development, for the relevant sensitive receptors identified.

The sunlight amenity to the surrounding relevant receptors will be considered by reference to the APSH method of assessment. Due to the southerly rotation of the sun, this assessment will consider those windows which face the site and are located within 90 degrees of due south.

The nature (beneficial or adverse), scale (negligible, minor, moderate or major) and ultimately the significance of daylight and sunlight amenity effects will be determined using professional judgement considering factors such as proximity to the site, coupled with the height of proposed buildings which may affect neighbouring receptors and with reference to Appendix I of the BRE Guidelines.

Overshadowing

The overshadowing analysis on the surrounding areas of amenity space will be undertaken by reference to the Transient Overshadowing (TOS) and Sun on Ground (SoG) methods of assessment.

For the TOS assessment, the path of shadow will be mapped for the Proposed Development on the following dates, as suggested by the BRE Guidelines:

• 21st March (Spring Equinox);

• 21st June (Summer Solstice); and

• 21st December (Winter Solstice).

The SoG assessment will consider the area of the amenity spaces that receive at least 2 hours of direct sunlight on 21st March (Spring Equinox).

The nature (beneficial or adverse), scale (negligible, minor, moderate or major) and ultimately the significance of overshadowing effects will be determined using professional judgement considering factors such as proximity to the site and height of proposed buildings which may affect neighbouring receptors.

31 British Research Establishment, 2011.Guidelines: Site Layout Planning for Daylight and Sunlight, A Guide to Good Practice, Second Edition.

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Solar Glare

The time, duration and date of solar glare effects to drivers on surrounding transport routes will be considered alongside the angle from the drivers’ focal point.

As there are no fixed thresholds for adverse solar glare, the nature (beneficial or adverse), scale (negligible, minor, moderate or major) and ultimately the significance of glare effects will be determined using professional judgement considering factors such as proximity to the site and height of proposed buildings which may affect neighbouring receptors.

Cumulative Effects

Should there be cumulative schemes of a significant scale located within 100m of the site, which may have the potential to interact with daylight, sunlight, overshadowing and solar glare levels anticipated to be generated by the Proposed Development, an additional assessment would be undertaken to consider the cumulative effects of the Proposed Development and cumulative scheme on the existing receptors identified above. Further to this, should the cumulative schemes include future sensitive receptors, the effect of the Proposed Development on such receptors will also be considered.

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Health The EIA Regulations requires that the EIA must ‘…identify, describe and assess in an appropriate

manner… the significant effects of the proposed development [in terms of] - human health,…’ (Regulation 4(2) and Schedule 4(4)).

It is proposed that significant effects of the Proposed Development in terms of human health will be comprehensively considered throughout the ES within individual assessments and that a separate health assessment would not be required as part of the preparation of the ES.

The following technical assessments are identified where potential impacts and effects on human health has been considered and can be referred to include:

• ES Chapter 5 – Demolition and Construction –

- It is proposed that for the period of demolition and construction works, a Construction Environmental Management Plan (CEMP) and Logistics Plan (CLP) would be prepared in advance of works commencing on-site to manage the potential impacts from the works and subsequent construction of the Proposed Development. The CEMP would include key matters relating to health impact including public safety, and amenity and site security.

• ES Chapter 6 – Socio-Economics –

- Considers the impact of the Proposed Development on the local social infrastructure arising from the new residential population, such as doctors (GPs), amenity and playspace areas, etc. Consideration also to the local economy in terms of employment opportunities and local spending, which in turn has direct and indirect benefits on the population at the local and borough spatial level. Also accounted for is the new provision of new open space and public realm to benefit both future occupants and visitors to the site, as well as the wider community.

• ES Chapter 7 – Traffic and Transport –

- Considers the impact of the Proposed Development on existing and future road users, in terms of driver delay, and delays to cyclists and their amenity. The assessment also takes account of pedestrians along the surrounding road network, in terms of delays, their amenity, fear and intimidation; their potential for severance from places and other people; and to the risk for accidents and their safety.

• ES Chapter 8 – Air Quality –

- Considers the potential impact on human health (both receptors external to the site, and for future occupants and visitors at ground floor and upper levels) in terms of air quality, in the form of dust generated during the demolition and construction works, and from introduced sources associated with the Proposed Development, including the energy centre and transport emissions (i.e. servicing) when operational.

• ES Chapter 9 – Noise and Vibration –

- Considers the impact of the Proposed Development on human health from noise and vibration generated during the demolition and construction works, and on completion of the Proposed Development - particularly the effect of change in noise and vibration levels at highly sensitive receptor locations (i.e. residential) within the site and surrounding local area.

• ES Chapter 10 – Daylight, Sunlight and Overshadowing, Light Pollution and Solar Glare –

- Considers the change in the daylight and sunlight amenity condition to surrounding external receptors (particularly residential properties) as a result of the massing

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introduced by the completed Proposed Development, as well as the likelihood for overshadowing to surrounding open spaces affecting the amenity of future users. The consideration of the potential impact of light pollution on neighbouring residential properties is also considered, as well as an assessment of solar glare in, from a safety aspect, with respect to road users (i.e. vehicles, cyclists) and pedestrians at road junctions, and train operators along signalized railways.

• ES Chapter 11 – Wind Microclimate –

- Considers the change in the wind microclimate experienced by both future occupants and visitors to the site, in terms of across the public realm areas and entrances to the buildings, as well as to pedestrians and road users (i.e. cyclists) the external to the site, who travel along thoroughfares and surrounding roads.

• Phase 1 Geoenvironmental Assessment (ES Appendix)

- Identifies the potential land quality risks and constraints associated with the Proposed Development. In particular, the report assesses the potential risk of contaminated land on human health based on a ‘source-pathway-receptor’ analysis - for a risk to be present, there must be a viable contaminant linkage; i.e. a mechanism whereby a source impacts on a sensitive receptor via a pathway. Receptors considered include – human health (future site users); site neighbours; and construction workers.

• Flood Risk Assessment (ES Appendix)

- Prepared to identify the susceptibility of the land being redeveloped to flooding and the risk to future occupants of the site, and ensuring the safe development and secure future occupancy of the site – in particular, ‘more vulnerable’ uses such as residential, health, and education. It is a requirement for development to address the potential risk of flooding and manage accordingly to ensure that the development is and remains safe throughout its lifetime (i.e. it has an appropriate degree of protection) and does not increase flood risk elsewhere (i.e. to other vulnerable uses).

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Noise and Vibration The Noise and Vibration Impact Assessment will provide an assessment of the effects of the Proposed

Development on noise and vibration receptors.

The Proposed Development has the potential to cause permanent noise and vibration nuisance to surrounding sensitive receptors, including those that are introduced.

Noise and vibration resulting from demolition and construction activities associated with the development also have the potential to cause temporary nuisances to surrounding sensitive receptors, and the introduced receptors during the later phases of the development.

Baseline Noise monitoring surveys will be undertaken to obtain baseline information relevant to the site and the

surrounding area. The survey measurement positions are shown in Figure 13, with locations A, B and C with long-term noise monitoring, locations 1 to 4 with sample noise monitoring, and location V with vibration monitoring.

Figure 13 Noise monitoring positions

The measurements will comprise long-term unattended noise monitoring (covering a period of at least

6 days) and attended daytime sample noise and vibration measurements.

The long-term and sample noise measurements will be completed using 15-minute sample periods, completed in 1/3 octave bands, are A and Z-weighted, and include all typical sound pressure level parameters eg, Leq, Lmax, L90 etc.

The sample vibration measurements will be completed for individual train passby events. The acceleration levels in three axes will be, which can be used to assess the Vibration Does Values (VDVs) and re-radiated noise levels.

Potential effects Potential noise and vibration effects during the demolition and construction works and the operation of

the development that will be addressed by the noise and vibration impact assessment include:

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• Demolition and Construction:

- Temporary noise and vibration nuisance because of demolition and construction works associated with daytime and (if required) night time works

- Noise nuisance to existing surrounding sensitive receptors from road vehicle movements generated during the demolition and construction works, associated with daytime and (if required) night time works

- Cumulative construction noise and vibration effects associated with demolition and construction works associated with the development being undertaken simultaneously with construction works on other surrounding development sites.

• Operational Development:

- Assessment of environmental noise effects on the occupants of the completed residential development;

- Traffic related noise effects once the development is completed and operational – associated with road traffic movements;

- Noise generated from building services plant;

- Vibration from nearby trainlines affecting the occupants of the completed residential development;

- Noise associated with amplified music from the leisure hub; and

- The assessment of environmental noise effects on the occupants will inherently include sources associated with the hospital, e.g. noise generated by road vehicles, servicing and building services plant.

• Cumulative Assessment:

• The cumulative operational impacts associated with this and other proposed schemes within the locality will be established and assessed. This will principally be in relation to building services noise and any increases in road traffic along local roads with the assessments undertaken in line with the methods outlined in Sections 5.1 and 5.3.

Potential Sensitive Receptors The assessments (construction and completed development/operational) will consider the following

surrounding sensitive receptors:

• Northwick Park Hospital;

• University of Westminster, Harrow Campus;

• 2-94 Northwick Avenue;

• Northwick Park;

• 37-57 Lulworth Avenue;

• 20 and 29 Conway Gardens;

• 20 – 32 Windermere Avenue;

• 138 and 147 The Fairway;

• 29-150 Norval Road; and

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• The Phase 1 receptors.

Scope of assessment The noise and vibration assessment will include the elements described below.

General

The noise and vibration impact assessment will be presented in the form of an ES chapter (within ES Volume 1) and will be supported by relevant technical information (survey data and calculations) presented in an appendix in ES Volume 3.

Identification of potentially sensitive noise and vibration receptors on and around surrounding the site and categorisation of their ‘sensitivity’ will be undertaken in accordance with EIA terminology, as illustrated in Table 6.

Receptor sensitivity Sensitivity of receptor Description

High Residential properties, hospital wards, music studios and libraries

Medium Hospital (treatment and outpatient), university teaching areas

Low Public gardens, retail and commercial buildings The Magnitude of Impact shall be defined in accordance with recognised noise and vibration guidance

and corresponding EIA terminology – High, Medium, Low, Very Low.

The relationship between the magnitude of impact and the receptor sensitivities is determined by the significance evaluation matrix shown in Table 7.

Significance of effects Sensitivity of

Receptor Magnitude of Impact


High Major Moderate Minor Negligible

Medium Moderate Minor Negligible Negligible

Low Minor Negligible Negligible Negligible

In terms of nature and scale of effects, these will be defined as either adverse, beneficial or neutral in nature.

The scale of effects will refer to guidance within the Noise Policy Statement for England (NPSE). The decision making includes identifying whether the overall effect of the noise exposure generated by a development is, or would be, above or below the significant observed adverse effect level and the lowest observed adverse effect level. The definitions for the different effect levels are outlined below:

• Significant Observed Adverse Effect Level (SOAEL): The level of noise exposure above which significant adverse effects on health and quality of life occur;

• Lowest Observed Adverse Effect Level (LOAEL): The level of noise exposure above which adverse effects on health and quality of life can be detected; and

• No Observed Effect Level (NOEL): The level of noise exposure below which no effect at all on health or quality of life can be detected.

Typically, effects (either before or after mitigation) that are major or moderate in scale shall be considered as ‘significant effects’ i.e. exceeds the LOAEL.

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Demolition and construction

The assessment of demolition, and construction noise and vibration effects are described as follows:

• Estimation of noise generated (impact magnitude) during each principal phase of the demolition, demolition and construction works and an assessment of the likely effects on surrounding sensitive receptors pre-mitigation. The assessment will be based on the “ABC” methodology set out in British Standard BS 5228:2009, as interpreted within Table 8;

• Road traffic associated with the demolition, demolition and construction works will be assessed using the same approach as described in Section 5.3 for general increases in road traffic;

• Classification of the pre-mitigated nature, scale and significance of noise and vibration effects;

• Identification of appropriate Best Practicable Means mitigation / any other required mitigation and re classification of the residual effects (post mitigation) nature, scale and significance; and

• Details of plant and equipment to be used throughout the demolition and construction works including % on times and sound power levels shall be presented within the ES.

Description of the magnitude of impact rating for assessing the likely and residual effects of demolition and construction noise and vibration

Magnitude of Impact Daytime noise levels (07:00-19:00) Vibration Levels

Very low Lower than ambient [1] LAeq or less than LAeq 60 dB.

Peak particle velocity (PPV) less than 0.3 mm/s

Low Higher than ambient LAeq less than LAeq 65 dB.

PPV regularly exceeding 0.3 mm/s, but less than 1.0 mm/s.

Medium Higher than ambient and between LAeq 65-70 dB

PPV regularly exceeding 1.0 mm/s, but less than 10.0 mm/s.

High Higher than ambient and greater than LAeq 70 dB

PPV regularly exceeding mm/s.

[1] Ambient noise levels assumed to be less than LAeq,12hr 60 dB

Operational

The assessment of operational noise effects are described as follows:

• The operational noise affects will be assessed with respect to the 2019 baseline measurements and where appropriate the baseline for the development year.

• For the assessment of noise associated with road traffic, reference will be made to the Calculation of Road Traffic Noise (CRTN). Further advice is also given in the Design Manual for Roads and Bridges (DMRB) for road traffic noise assessment.

• Significance criteria for assessing all traffic are presented in Table 9, which is based on the IOA / IEMA ‘Guidelines for Noise Impact Assessment.’

Description of the magnitude of impact rating for assessing the effect of increases in ambient noise

Magnitude of Impact Increase in noise level (dBA) Description

Very low <1.0 Noise increase is unlikely to be discernible.

Low 1.0 - 2.9 A slight increase in noise levels may be perceived in affected buildings and outdoor recreational areas

Medium 3.0 - 4.9 Increase in noise levels is likely to be noticeable in affected buildings and outdoor recreational areas.

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High >5.0 Increase in noise levels is likely to be clearly perceptible and could have a significant effect on the continued use

of a building.

• For the assessment of building services noise, reference will be made to the use of BS 4142:2014. Criteria for the assessment are set in accordance with BS 4142 and the Institute of Acoustics (IOA) / Institute of Environmental Management and Assessment (IEMA) ‘Guidelines for Noise Impact Assessment, as identified in Table 10.

Description of the magnitude of impact rating for assessing the effects of building services plant noise

Magnitude of Impact Increase in noise level (dBA) Description

Very low <1.0 Noise increase is unlikely to be discernible.

Low 1.0 - 2.9 A slight increase in noise levels may be perceived in affected buildings with openable windows and outdoor

recreational areas.

Medium 3.0 - 4.9 Increase in noise levels is likely to be noticeable in affected buildings with openable windows and outdoor

recreational areas.

High >5.0 Increase in noise levels is likely to be clearly perceptible in affected building with openable

windows and outdoor recreational areas.

• For the assessment of site suitability for residential development, reference will be made to BS8233:2014 (Table 11) for noise.

Magnitude of Impact - Internal Noise Levels Within Dwellings Magnitude of Impact Increase in noise level (dBA) Description

Very low <1.0 Complies with BS 8233

Low 1.0-4.9 Internal noise limits comply with ‘reasonable’ standard set out in BS 8233

Medium 5.0-10.0 Internal noise limits up to 5 dB higher than ‘reasonable’ standard set out in BS 8233

High >10.0 Internal noise limits 10 dB higher than ‘reasonable’ standard set out in BS 8233

• For the assessment of suitable external residential amenity, reference will be made to the use of BS8233:2014 (Table 12).

Magnitude of Impact - Noise in Designated Residential Amenity Spaces (other than private balconies)

Magnitude of Impact Noise Level (dBA) Description

Very low ≤50 Meets the lower recommended value in BS 8233

Low 51-55 Meets the upper guideline value in BS 8233

Medium 56-60 Noise levels that are just noticeable above the upper guideline value in BS 8233

High ≥61 Would be noticeably above the upper guideline value in BS 8233

• For the assessment of vibration from trains within the development, reference will be made with respect to the residential criteria from BS 6472-1, as identified in Table 13.

Description of the magnitude of impact rating for assessing the effects of vibration in the proposed residential properties

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Magnitude of Impact VDV m/s1.75 for 16h day*

VDV m/s1.75 for 8h night*

Description

Very low <0.2 <0.1 Adverse comment is not expected

Low 0.2-0.4 0.1-0.2 Low probability of adverse comment

Medium 0.4-0.8 0.2-0.4 Adverse comment possible

High >0.8 >0.4 Adverse comment probably

The assessment of vibration in the offices will apply a multiplying factor of 2 to the values presented in Table 6.

• Assessment of events noise associated with the Proposed Development will be completed with reference to the IOA’s Good Practice Guide on the Control of Noise from Pubs and Clubs and related published IOA articles.

• The magnitude of impact criteria for events noise associated with the Proposed Development’s leisure hub is given in Table 14.

Magnitude of Impact Criteria Relating to the Use of the Leisure Hub Magnitude of Impact Noise Level Description

Very low LAeq does not exceed the background LA90 level, LA10 does not exceed the background

LA90 level in any 1/3 octave band between 40 Hz and 160 Hz

Entertainment noise barely audible

Low LAeq does not exceed the background LA90 level

Low frequency noise audible, but noise sources are not identifiable

Medium LAeq does not exceed the background LA90 level by more that 5 dB

Entertainment noise generally audible

High LAeq does not exceed the background LA90 level by more that 10 dB

Entertainment noise clearly audible

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Socio Economics Overview

The likely significant effects generated by the Proposed Development will be examined and accompanied by an assessment of their likely scale and nature, and whether they are ‘significant’ or not. The assessment will address the direct and indirect employment opportunities generated during the construction and operational phases, as well as the residential impacts through the provision of housing. The assessment will consider the likely population and child yields of Proposed Development, with any associated impacts upon social infrastructure, including health and education facilities, as well as open space and play space. It will also consider the indirect impacts of the employment and residential uses, such as employment generated by residential spending.

To the extent that any significant negative impacts are identified, appropriate mitigation measures would be detailed, along with resulting residual effects after mitigation measures have been taken into consideration.

Baseline

The socio-economic baseline conditions for the existing site and the environment surrounding it will be established with reference to a policy review and a desk-top review. The policy review will outline the relevant local and regional, social and economic policies for the area. This review will include (but may not be limited to) the following planning policy documents:

• National: National Planning Policy Framework (2019);

• Regional: The London Plan 2016, the draft new London Plan 2018;

• Local: Brent Council Local Plan 2010-2026; and

• Local: Brent neighbourhood planning protocol.

Baseline conditions will be assessed at several geographic levels, including the local area (the immediate area around the site), the borough (Brent), regional (London) and national (Great Britain) levels. This review will consider available information relating to the site from current owners regarding existing use, published and safeguarded information from database records, such as the Census, Office for National Statistics (ONS), National Online Manpower Information Service (NOMIS), the Index of Multiple Deprivation (IMD), as well as other local data sources. Information will be processed utilising geographic information systems (GIS) methodology.

The baseline analysis will summarise the socio-economic context of the site under three broad categories:

• Demographics: population, age profile, household composition, deprivation and crime, residential qualifications, housing supply, housing tenures, house prices, and housing need (including affordable);

• Economy and labour market: employment, sectoral employment, unemployment and claimant count, labour skill levels, economic activity, provision of commercial and leisure space; and

• Social infrastructure: education provision (early years, primary, secondary, tertiary), primary and secondary healthcare provision (including performance of Northwick Park Hospital – the nearest A&E), elderly care provision, public realm, play space, and open space (including nearby Northwick Park).

The baseline will also consider the current social and economic activity supported at the site found within the University of Westminster area (i.e. education, café) and within the Network Homes area (i.e.

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residential, medical units, social club, pre-school nursery).

As with any dataset, the socio-economic baseline will change over time. The socio-economic ES chapter will define the existing baseline socio-economic conditions of the environment surrounding the site. The most recent published sources will be used – data sources published in 2019 will be used where possible, but where this is not available the next best alternative (i.e. the most up to date) will be used as a proxy. This will be clearly described in the ES.


The sensitivity of receptors is dependent upon the baseline conditions (i.e. the extent to which unemployment, skills deficit or social infrastructure issues etc. are present in an area and thus how much jobs, spending or infrastructure are needed in that area). It is not possible to ascribe specific ‘values’ or a quantifiable scale of ‘sensitivity’ to all socio-economic receptors due to their diversity in nature and scale.

The socio-economic assessment will therefore focus on the qualitative “sensitivity” of each receptor, and on their ability to respond to change based on recent rates of change and turnover. For example, very high house prices and persistent under-delivery of housing or low skills would be deemed very sensitive receptions because they represent very significant and persistent socio-economic problems in the context of the local environment. Whilst the sensitivity of each receptor may be defined qualitatively, wherever possible this will be based upon quantitative evidence and the effects will be assessed quantitatively wherever possible (see next section for more detail).

Receptors are likely to include, but may not be limited to:

• Construction employment;

• Unemployment;

• Local expenditure;

• Local jobs;

• Housing provision (including affordable and student accommodation);

• Commercial and leisure provision;

• GP and A&E provision;

• Education provision and skill levels;

• Open and play space provision; and

• Crime and deprivation.

Potential Effects

The socio-economic chapter will identify the effects that entail beneficial impacts alongside those that may be adverse and require additional mitigation measures. The chapter will examine the following effects at relevant levels of geography:

• Demolition and Construction

- Construction employment;

- Local spend of the construction workers; and,

- Local jobs.

• Completed Development

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- Operational employment, and resulting indirect and induced employment;

- Local spend of the operational workers;

- Local jobs;

- Contribution towards retail/commercial, leisure and community floorspace;

- Impacts upon housing targets (including affordable housing and student accommodation), along with associated population accommodated by the Proposed Development;

- Residential expenditure and associated induced jobs;

- Effect on the local provision of education;

- Effect on the local provision of health care;

- Effect on the local provision of play space;

- Effect on the local provision of open space; and

- Crime and antisocial behaviour.

The assessment will identify positive and negative effects, including those that may require mitigation measures. If mitigation is required, mechanisms for their achievement will be identified.

The assessment will consider the implications of the project phasing, although it is not expected to have a significant impact on the socio-economic effects. Areas where it might be relevant to consider the phasing include the timing of the effects – such as the construction and operational employment opportunities – and how the construction of Phase 1 could temporarily affect the existing residents’ accessibility to nearby social infrastructure and other services.

Scope of Assessment

The socio-economic assessment will consider four different scenarios as outlined below:

• Potential effects:

- Scenario 1 – Detailed Application + Highway Works Application; and

- Scenario 2 – Masterplan Application + Detailed Application + Highway Works Application.

• Cumulative assessment:

- Scenario 3 - Detailed Application + Highway Works Application + Committed Development schemes; and

- Scenario 4 - Masterplan Application + Detailed Application + Highway Works Application + Committed Development schemes.

Where relevant, the socio-economic effects identified will be quantitatively and qualitatively appraised against relevant national standards, trends and policy requirements.

In accordance with the HCA Additionality Guide32, the likely effects of the Proposed Development will be considered at various geographic scales (i.e. local, borough, regional and national), which will be clearly described in the ES chapter.

Mapping techniques, as well as flow diagrams and matrices (all identified by ‘EC Guidelines on Indirect and Cumulative Impacts’33 as useful assessment methods), will be used wherever possible to ensure

32 Homes and Communities Agency (2014), Additionality Guide Fourth Edition 2014, HCA 33 Office for Official Publications of the European Communities (1999), Guidelines for the Assessment of Indirect and Cumulative Impacts as well as Impact Interactions

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that assumptions and interdependencies between impacts and effects are clearly presented within the assessment.

Modelling and accepted metrics, such as employment densities, average worker expenditure and indirect multipliers, will be used in order to calculate primary, secondary and indirect effects. Key guidance used will be the HCA Employment Density Guide for estimating direct employment impacts, and the HCA Additionality Guide, which will be used to estimate indirect and induced impacts.

For the elements of Masterplan Application (Outline Planning Permission), the Proposed Development will be assessed under a ‘worst-case’ scenario. The parameters used to assess the project will differ by effect. For example, operational employment would be assessed based on minimum parameters and the use class which yields the least jobs (where uses are flexible), as this would generate the lowest, and therefore most conservative, estimate of operational jobs. Whereas the assessment of social infrastructure (education, health and open/play space provision) would use maximum parameters as these would generate the most residents and put increased pressure on social infrastructure

Where standard or accepted methods do not exist, benchmarking exercises will be undertaken, professional experience and judgement will be applied and presented clearly and transparently, along with any assumptions made.

Alongside the potential effects, the socio-economic assessment will also consider the cumulative effects of the Proposed Development in conjunction with other relevant cumulative schemes identified in in the area (Appendix B). This would assess total quantum of commercial and residential provision along with the workforce and population accommodated by each cumulative scheme, and their relative impacts.

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Townscape and Visual Impact Assessment Overview

The Townscape and Visual Impact Assessment (TVIA) will provide an assessment of the effects of the Proposed Development on townscape and visual receptors. The TVIA’s study area will include both the site and its wider surrounding context at a 1-kilometre radius; this has been determined through establishing a zone of theoretical visibility (ZTV) around the site and considering the scale of the Proposed Development. Further long distant visual receptors and representative views will be considered where identified and relevant.

Baseline

In determining the site’s baseline conditions and potential sensitive receptors to the Proposed Development, a desk-based review of relevant planning legislation, policy and guidance; characterisation studies; OS maps; and aerial mapping has been undertaken, along with a field study carried out in July 2019.

The site can be broadly split up into five parcels:

• University of Westminster area (student accommodation - to the north of the site);

• Public area of open space (to the northeast corner of the site, to the south of Northwick Park Station);

• Ring road (northern section, running along on north side of the Northwick Park Hospital, east-west orientation);

• Network Homes area (northern portion including infrastructure associated with Northwick Park Hospital (i.e. Boiler House), car park, social club); and

• Network Homes area (southern portion, comprising the residential housing (Northwick Park Village)).

At a national level the site falls within National Character Area 111 - North Thames Basin34 and at a regional level the London’s Natural Signatures: The London Landscape Framework35 recognises it as falling within the Landscape Character Type of the Barnet Plateau. Both the North Thames Basin and Barnet Plateau cover a wide area and, whilst they serve to provide useful background and context, the scale is such that there would be no notable effect resulting from the Proposed Development.

LB Brent have not undertaken a landscape or townscape character assessment for the borough. The TVIA will therefore consider the townscape features that contribute to the existing character of the established study area. Shaping Neighbourhoods: Character and Context SPG36 sets out how to assess character areas. It builds on the Policy 7.4 Local Character of the London Plan. It sets out four principles:

• Character is all around us and everywhere has a distinctive character;

• Character is about people and communities;

• Places are connected and overlap – boundaries and transitions are important; and

• The character of a place is a dynamic concept.

Townscape character areas (TCA) within the study area have been established. These are based on a

34 http://publications.naturalengland.org.uk/publication/4721112340496384 35 Natural England (2011) London’s Natural Signatures: The London Landscape Framework 36 Greater London Authority (2011) Shaping Neighbourhoods: Character and Context SPG

http://publications.naturalengland.org.uk/publication/4721112340496384

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combination of the dominant land use, built form, layout and landform and has identified, along with consideration of aesthetic and perceptual factors, four TCAs that are listed below and illustrated in Figure 14:

• TCA1 – Institutional Use and Open Space;

• TCA2 – Early 20th Century Suburb;

• TCA3 – Harrow Town Centre; and

• TCA4 – Harrow-on-the-Hill.

The site includes a tall chimney (associated with the Boiler House, northern portion of the Network Homes area) and there are also a number of taller buildings associated with the adjacent Northwick Park Hospital and the University of Westminster. These features, along with the surrounding area’s landform, vegetation and built form, help to inform the site’s ZTV. In summary the site’s ZTV is limited to between 500 and 750 metres to the north, east and south. The raised landform of Harrow-on-the-Hill, however, increases the visibility from the west to around a kilometre.

Within the ZTV visual receptors, which are defined as individuals and / or defined groups of people who have the potential to be affected by the Proposed Development, are likely to included:

• Users of public rights of way (PRoW);

• Users of areas of open space, including publicly accessible areas;

• Users of raised sections of the Underground or Railway Line;

• Residents, workers or students of properties that have windows facing the site; and

• Users of roads that are orientated towards the site.

To inform the visual assessment a range of representative views from these visual receptors will be assessed. Their selection will be based on regional and local planning policies, along with the following:

• accessibility to the public;

• potential number and sensitivity of viewers who may be affected;

• viewing direction, distance and elevation;

• nature of the viewing experience; and

• relationship to a designated heritage asset.

There are no listed buildings located on-site and the site does not fall within or adjacent to a conservation area. The study area contains Harrow-on-the-Hill, to the west, which has a high heritage significance, with around 80 statutorily listed buildings, a group of contiguous conservation areas and a Registered Park and Garden. Northwick Circle Conservation Area is located within the study area, to the northeast, and Sudbury Court Conservation Area, to the south. These heritage assets will assist in determining the value of the townscape character areas and representative views to be assessed.


The Proposed Development will introduce a new land use of the site, along with new massing, scale and height to the site as well as providing new and improved public realm.

Townscape Character Area Receptors

The sensitive Townscape Character Areas (TCA) receptors that will be considered in the TVIA include (but are not limited to) the following (shown in Figure 14):

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• TCA1 – Institutional Use and Open Space;

• TCA2 – Early 20th Century Suburb;

• TCA3 – Harrow Town Centre; and

• TCA4 – Harrow-on-the-Hill.

Figure 14 Townscape Character Areas

The Proposed Development, due to its position, will have a direct effect on the identified TCA1 – Institutional Use and Open Space. There is also the potential to indirectly effect the context of the other TCAs. The conclusions of this element of the assessment will be informed by conclusions drawn from the visual assessment.

Visual Receptor Representative Views

Consultation will be undertaken with LBB as part of pre-application engagement regarding the selection of visual receptor representative views. These include (but are not limited to) the following (shown in

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Figure 15):

• Representative view 1 – taken from the southern platform of Northwick Park Underground Station;

• Representative view 2 – located on the northern pavement of Northwick Avenue;

• Representative view 3 – positioned on the eastern boundary of Northwick Park on a PRoW, adjacent to a footbridge over the Underground railway line;

• Representative view 4 – taken from the southeast corner of Northwick Park on the London Outer Orbital Path, in the vicinity of South Kenton Station;

• Representative view 5 – situated on a PRoW on the southern boundary of Northwick Park, bordering Sudbury Court Conservation Area;

• Representative view 6 –taken from the western pavement of Watford Road at the entrance to ‘Play Golf’;

• Representative view 7 – located on the western pavement of where the A409 meets the Northwick Park roundabout, opposite Harrow High School;

• Representative view 8 – positioned at the junction of two PRoW leading from Peterborough Road to Watford Road;

• Representative view 9 – taken from the eastern end of Music Hill at the intersection of PRoWs located within Harrow School Sports Grounds;

• Representative view 10 – located on a PRoW that runs from Music Hill to Pebworth Road, overlooking Harrow School Farm;

• Representative view 11 – situated close to the Parish Church of St Marys Church on Church Hill Road within Harrow School Conservation Area;

• Representative view 12 – positioned on the High Street looking in between the Harrow School Chapel and Vaughan Library within Harrow School Conservation Area;

• Representative view 13 – within Sudbury Court Conservation Area, at the junction of Abbots Drive and Audrey Gardens;

• Representative view 14 – taken within John Billam Sports Ground, close to Kenton Hall;

• Representative view 15 – located on the southeast edge of Northwick Circle Conservation Area, at the junction of The Ridgeway and Woodcock Hill; and

• Representative view 16 – long distance view from County Park and Wood Farm identified with LB Harrow Local Plan Policy DM3 as a protected long-range view from open space.

The Proposed Development has the potential to have a direct effect on theses visual receptor representative views.

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Figure 15 Proposed Visual Receptor Representative Views

Potential Effects

The Proposed Development will give rise to a new built form and appearance to the site, which would likely affect views and the townscape quality and context within, and surrounding, the site. Therefore, the EIA will address the following potential townscape and visual impacts, and subsequent likely effects:

• Temporary visual intrusion during the demolition and construction of the Proposed Development on the townscape character area receptors and the visual receptor representative views;

• Permanent effect of the completed and operational Proposed Development in relation to the removal of the site’s trees, structures and buildings on the townscape character area receptors and the visual receptor representative views;

• Permanent effects of the completed and operational Proposed Development on the quality and character of townscape character area receptors, and on the visual receptor representative views; and

• Cumulative effects taking into account developments in the wider area in combination with the Proposed Development on the townscape character area receptors and the visual receptor representative views.

Mitigation measures to reduce the potential for likely significant effects during the demolition and construction of the Proposed Development will be implemented, via a Construction and Environmental

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Management Plan, prior to the commencement of any demolition and construction works.

To reduce the potential for likely significant effects once the Proposed Development is completed and operational, mitigation measures will be embedded into the design of the Proposed Development. These measures will likely relate to the layout and scale of the Proposed Development.

Scope of Assessment

The Guidelines for Landscape and Visual Impact Assessment (GLVIA)37, subsequently referred to as ‘GLVIA3’, states that this type of assessment provides a tool for identifying and assessing the “significance of and the effects of change resulting from development on both the landscape as an environmental resource in its own right and on people’s views and visual amenity”. It goes on to emphasise that the assessment has two interlinked elements that include landscape, as a resource; and visual amenity. The effects of both will be addressed as part of this assessment. The European Landscape Convention38 defines landscape as including villages, towns and cities and the GLVIA3 states that ‘townscape’ refers to areas where the built environment is dominant.

The TVIA will be undertaken with reference to GLVIA39 and other relevant guidance including Natural England’s An Approach to Landscape Character Assessment40 and Shaping Neighbourhoods: Character and Context SPG41. Structured, informed and reasoned professional judgement will be used to take account of quantitative and qualitative factors. This is widely accepted as best practice and is based on analysis of desk-based research and field assessment.

At the baseline stage the TVIA will establish the existing conditions through desk-based analysis and field study of the townscape character receptors, along with the visual amenity of the Site from within the surrounding area’s visual receptors. The latter visual assessment will be undertaken through considering a series of representative views, in which independent visualisers will insert accurate representations of the Proposed Development, based on the sensitivity of locations and the likelihood of visibility. This will enable a 360-degree assessment of the scale of the Proposed Development. The location of the representative viewpoints will be agreed with LBB to inform the assessment and draft locations are set out in Figure 15 and will be verified views. The following will be prepared from each view:

• Existing – the representative view as it currently occurs;

• Proposed – the representative view with the Phase 1 (detailed planning application) Proposed Development inserted as either a wireline or rendered form;

• Proposed – the representative view with the Masterplan (outline planning application) Proposed Development inserted as a wireline;

• Cumulative – the representative view with the Phase 1 (detailed planning application) Proposed Development inserted in wireline or rendered form along with the identified cumulative schemes shown as a wireline form; and

• Cumulative – the representative view with the Masterplan (outline planning application) Proposed Development inserted in wireline along with the identified cumulative schemes shown as a wireline form. Following the baseline identification of the townscape character receptors

37 The Landscape Institute and the Institute for Environmental Management and Assessment (2013) Guidelines for landscape and Visual Impact Assessment, 3rd Edition. 38 Council of Europe (2007) The European Landscape Convention 39 The Landscape Institute and the Institute for Environmental Management and Assessment (2013) Guidelines for landscape and Visual Impact Assessment, 3rd Edition. 40 Natural England (2014) An Approach to Landscape Character Assessment Guidance 41 Greater London Authority (2011) Shaping Neighbourhoods: Character and Context SPG

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and the visual receptor’s representative views the sensitivity of each to the Proposed Development is judged by considering its value and its susceptibility to change. Susceptibility is the ability of the receptor to accommodate change without undue consequences for the maintenance of the baseline situation and/or the achievement of planning policies and strategies.

The assessment of effects will take into account the Proposed Development’s interaction with the existing townscape character receptors and the effect of the Proposed Development on the visual amenity experienced by visual receptor’s representative views at two stages:

• the demolition and construction stage; and

• the completion of the development stage.

The magnitude of the change to the existing townscape character receptors and visual receptor’s representative views as a result of the Proposed Development at these two stages will take account of factors including the proximity, scale and contribution to these receptors. The magnitude of the change resulting from the Proposed Development will be assessed as high, medium, low or negligible.

To determine the significance of effect consideration will be given to the townscape character receptors and visual receptor’s representative views sensitivity combined with the magnitude of change, this will be based on best practice guidance, along with professional judgment and experience. The significance of effect will be judged to be minor, moderate or major. It is considered that ‘major’ to ‘moderate’ significance of effects are significant and ‘moderate to minor’, ‘minor’ to ‘negligible’ significance of effects are less significant. Effects that are assessed to be less significant are not disregarded and will still be considered within the TVIA.

The significance of effect has been further categorised as beneficial, neutral or adverse. Adverse effects are those that undermine the value of the townscape character or visual receptor’s representative view. Whereas beneficial effects are those that contribute to the identified value. Neutral effects are those where the effect would be neither beneficial nor adverse or a balance of adverse and beneficial influences.

The assessment will also take into consideration any potential mitigation measures included to determine the significance of any residual effects.

Cumulative assessment

An overall assessment of cumulative effects (i.e. the effect of the Proposed Development taking into account other Committed Developments) will also be provided. The approach to cumulative assessment will consider the effects of the Proposed Development in combination to the Committed Development.

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Traffic and Transport The planning application will also be supported by a Transport Assessment (TA); as the traffic and

transport assessment presented in the ES draws on the TA, the TA will be presented in ES Volume 3 (Appendix).

Baseline

Current Baseline

The site currently comprises the following uses:

• c.697 Hospital staff car parking spaces within two car parks and on-street along the Hospital ring road;

• c.695 purpose-built shared living dwellings;

• student accommodation, sporting and teaching facilities; and

• Ancillary Hospital facilities including a boiler house, refuse storage, social club and nursery.

There are a number of pedestrian routes through the Site, primarily alongside existing roads but also connecting with Northwick Park station and to Pryors Path, which borders the Site to the east and connects with other public rights of way (PRoW) comprising the Capital Ring. There is a relatively narrow PRoW along the southern boundary of the University’s land.

Regarding cycle provision, there are a combination of shared use routes with toucan crossings on Watford Road and on-carriageway provision with poor quality road markings and delineation along the Hospital’s ring road.

The Site has varying public transport accessibility levels (PTALs), with PTAL 5 to the north and north-east, which reduces to PTAL 2 to the south and south-east.

There are three underground stations in close proximity to the Site:

• Northwick Park (Metropolitan line) – 285m walking distance from centre;

• Kenton (Bakerloo and Overground lines) – 850m; and

• South Kenton (Bakerloo and Overground lines) – 1.2km.

Harrow-on-the-Hill national rail station is 1.8km from the Site, a 23-minute walk, or one stop on the Metropolitan line from Northwick Park station.

Two bus services (182, 483) operate along Watford Road only, with two northbound stops and a single southbound stop provided. A further four services stop only within the large bus facility to the west of the Hospital (with the Hospital grounds) adjacent to Watford Road (223, H9, H10, H14). One service (186) routes through the Site along the Hospital ring road. Proposed changes to these bus services are currently subject to public consultation by TfL.

The Site is accessed from the A404 Watford Road which broadly comprises four lanes (two lanes in each direction) between Northwick Park Roundabout to the north and the Hospital’s southernmost access to the south. South of this it becomes one lane in each direction to John Lyon Roundabout.

Both Northwick Park Roundabout and John Lyon Roundabout are four-arm priority roundabouts. Watford Road forms part of the LBB’s strategic road network.

There are three accesses from Watford Road. All arriving vehicles (for the University, Hospital and residential), except emergency vehicles, enter from the northernmost junction. All northbound traffic departs from the central access. All southbound traffic departs from the southernmost access, which

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emergency vehicles also enter at. There is no right-turn entry for the site from Watford Road.

The University and residential (within the Network Homes area – south of the site) elements each take access from the Hospital ring road.

The University of Westminster area comprises an internal road which provides access to staff, student and visitor car parking as well as delivery and servicing areas.

The residential part within the Network Homes area (southern portion of the site) comprises several streets with on-street parking throughout.

A Vissim microsimulation traffic model has been developed by LBB which comprises the Watford Road corridor between Northwick Park Roundabout and John Lyon Roundabout. Traffic survey data from April 2015 was used to develop this.

Further surveys of the highway network around the Hospital and along Watford Road, including Northwick Park Roundabout and John Lyon Roundabout, have been carried out at the end of June 2019. These will be used to test the suitability of 2015 data within the Vissim model.

Pedestrian and vehicle surveys have also been carried out of the existing residential part of the Site and the Hospital staff car park to the north of the social club. Respectively, these will be used to assess the capacity of Northwick Park station and understand current Hospital staff and residential vehicle trip generation.

Collision data for the most recent 36-month period will be acquired from TfL across the same extent as was and will be subject to traffic surveys, in addition to the Active Travel Zone.

Public transport data will be determined through a PTAL assessment of the site. An assessment of the existing public transport capacities within the vicinity of the site will be undertaken using TfL’s Railplan data and Bus Origin and Destination Surveys (BODS) data for bus capacity assessments.

Future Baseline

The current baseline data will be used to determine and assess two future baseline scenarios. The ‘future baselines’ will include Committed Development schemes that may affect the transport networks in the study area.

At TfL’s request, TfL’s strategic transport models are to be used to determine the expected impacts of the Proposed Development and the methodology for each model will be agreed with TfL officers throughout the process.

TfL’s strategic models, including the London Transportation Studies (LTS) model, Railplan and West London Highway Assignment Model (WeLHAM), will be used to inform the expected trip generation of the Proposed Development and assign trips onto the network. These models are substantial in their size, however the detailed study area for the WeLHAM will likely comprise a two-kilometre radius of the site.

Committed Development schemes are included within TfL’s future baseline strategic modelling and it is not possible to disaggregate the schemes from the future baseline, so no future baseline with development (excluding cumulative schemes) can be prepared.

There will be four scenarios comprising two future years, accounting for ‘without’ (Do Nothing) the Proposed Development, and ‘with’ (Do Something) the Proposed Development

• Scenario (a) - Future Baseline (Do Nothing) (for the year of completion of the development associated with the Detailed Application);

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• Scenario (b) - Future Baseline (Do Something) including Detailed Application + Highway Works Application (for the year of completion of the development associated with the Detailed Application);

• Scenario (c) - Future Baseline (Do Nothing) (for the year of completion of the development associated with the Masterplan Application); and

• Scenario (d) - Future Baseline (Do Something) + Masterplan Application + Detailed Application + Highway Works Application (for the year of completion of the development associated with the Masterplan Application).

A Vissim microsimulation model will be used to understand impacts of the Proposed Development on the local highway network; principally the Watford Road corridor between Northwick Park Roundabout and the John Lyon Roundabout. The extent of this model is shown in Figure 16.

This Vissim model will assess in detail the impacts of the development comprising the Highways Works Application.

Figure 16 Vissim Model Extent

Northwick Park Roundabout

John Lyon Roundabout

Northwick Park Hospital

Watford Road

Watford Road

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Information relating to the Proposed Development’s expected population and employment numbers will be inputted into the LTS model to determine future trips, where these trips will be to and from, when the trips will be made and using which mode.

The LTS model uses GLA forecast assumptions on population and employment, amongst other inputs, to model future trips. Consideration is therefore given to committed developments within the local area and across London, and their impacts on the transport networks.

The Railplan and WeLHAM models will then use the number of trips and their expected origins and destinations from LTS and calculate routes through the highway network based on journey times and distance.

The WeLHAM model outputs will then be used to inform the future year assessments for the Vissim modelling.

Potential Effects

The assessment will address the potential for the following effects with regard to traffic and transport:

• Short- or medium-term disturbance to receptors arising from the demolition and construction works and associated traffic including an assessment of vehicle trips, movements and safety during the demolition and construction works period.

• Changes to the flows of traffic on the local highway network when the Proposed Development (Scenario (b) - Detailed Application and Scenario (d) Detailed Application and Masterplan Application) is operational and any consequential effects on driver delay or highway safety.

• Change in the demand arising from the completed Proposed Development (Scenario (b) - Detailed Application and Scenario (d) Detailed Application and Masterplan Application) on public transport services.

• Effects on pedestrian and cycling journeys, accessibility and facilities.

• Effects on pedestrians in terms of severance, delay, amenity, fear and intimidation.


The potential receptors are those people making journeys within the relevant study area for each mode; pedestrians, cyclists, public transport users and road users.

For each effect to be assessed, receptors are identified in each study area. The sensitivity of receptors for transport effects will be defined as shown in Table 15.

Existing and Introduced Sensitive Receptors Effect Sensitivity Description

Negligible Receptors which are very lightly used (by all users or particularly by vulnerable road users) relative to other receptors within the study area or those which have a very high capacity to accommodate change without significant effects arising.

Low Receptors which are lightly used (by all users or particularly by vulnerable road users) relative to other receptors within the study area or those which have a high capacity to accommodate change without significant effects arising.

Moderate Receptors which are used (by all users or particularly by vulnerable road users) to an average level relative to other receptors within the study area or those which have a moderate capacity to accommodate change without significant effects arising.

High Receptors which are heavily used (by all users or particularly by vulnerable road users) relative to other receptors within the study area or those which have a low capacity to accommodate change without significant effects arising.

The strategic models that will be used are substantial in size, however the detailed study area for the

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WeLHAM will likely comprise a two-kilometre radius of the site. The Vissim model study area will be the site and the public highway comprising Watford Road between and including Northwick Park Roundabout and John Lyon Roundabout. Assessed public transport nodes will include bus stops around the Hospital and on Watford Road, Northwick Park station and South Kenton station.

Scope of Assessment

The ES will summarise the results of the TA in accordance with the requirements of the EIA Regulations and current best practice for undertaking EIA traffic and transport assessments; primarily the Guidelines for the Environmental Assessment of Road Traffic (Institute of Environmental Assessment (now IEMA), 1993). The ES chapter will address the potential impacts of traffic during the demolition and construction and operational phases, by adopting the following criteria:

• Severance;

• Delay (Driver, Pedestrian, Cycle, Public Transport);

• Amenity;

• Fear and Intimidation; and

• Accidents and Safety.

Where necessary, measures will be identified to mitigate any potential adverse impacts on traffic and transport.

The TA will be undertaken in accordance with current planning policies and TfL’s new Healthy Streets TA best practice guidance. The assessment will utilise land use, floor area and unit mix parameters to forecast the number of trips to and from the site by mode in peak hours for both the Proposed Development (Scenario (b) - Detailed Application and Scenario (d) Detailed Application and Masterplan Application).

The TA will outline the existing transport conditions at and surrounding the Site. This will include an evaluation of the accessibility of the site by public transport and the capacity of the surrounding highway network, including traffic flows and any planned improvements to the local network.

The number of trips generated by the Site will be compared against the Proposed Development when operational – (Scenario (b) - Detailed Application and Scenario (d) Detailed Application and Masterplan Application). Net trips by all relevant modes of transport will be assessed and impacts will be appraised.

The forecast number of trips generated during demolition and construction, including HGV trips, will be assessed.

The development comprising the Masterplan Application (Outline planning permission) will be assessed based on maximum parameters to determine a worst-case assessment scenario.

A Stage 1 Road Safety Audit will be completed and provided as part of the TA to indicate that the development comprising the Highway Works Application meet the necessary safety requirements for all users.

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Wind Microclimate Baseline

Winds for the London area are predominantly from the south west, with a secondary peak from the north east during spring. Winds are typically stronger in the winter season, and lighter throughout the summer. Wind roses for the London area per season, combine data obtained from Gatwick, Stansted and Heathrow airports over a period of 30 years, Figure 17.

Figure 17 Seasonal wind roses for London (in Beaufort Force) - (Radial axis indicates the hours for which the stated Beaufort Range is exceeded).

To understand and quantify the baseline conditions at the site, a Computational Fluid Dynamics (CFD) model will be developed reflecting the existing built form of the site and the surrounding area within a minimum 400m radius of the centre of the site. This model will be run to allow the baseline wind microclimate conditions to be quantified.

The baseline results from the CFD simulations will be combined with long-term meteorological climate data for the London area, corrected to the site to understand the baseline conditions specific to the site having regard to its location within London. Simulations will be conducted in the absence of any hard or soft landscaping, in order to provide a conservative result.

Potential Effects

Undesirable wind speeds can make spaces uncomfortable or unsafe for pedestrian use. The potential effects associated with the interaction of the local wind microclimate conditions with the Proposed

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Development are considered to be as follows:

• During demolition and construction works, potential for undesirable wind speeds at:

- ground level in publicly accessible areas bordering the demolition / construction compound/s, specifically pedestrian thoroughfares and any areas of public open / amenity space; and

- buildings in proximity to the demolition / construction compound/s, with specific reference to building entrances and pedestrian routes around buildings.

• Once the Proposed Development is complete and operational, potential for undesirable wind speeds at locations:

- Within the site, specifically:

ground level - pedestrian thoroughfares and public realm / amenity space; and

accessible elevated levels i.e. roof terraces.

- External to the site, specifically:

ground level pedestrian thoroughfares;

bus stops;

pedestrian crossings;

areas of public open / amenity space; and

surrounding buildings - with specific reference to building entrances and pedestrian routes around buildings.

Sensitive Receptors

The site and nearby surrounding area will be examined with reference to sensitive locations, where receptors are the people that may use these spaces (i.e. pedestrians and cyclists) such as;

• On-site and off-site thoroughfares and crossings;

• Cycle paths;

• Entrances;

• Bus stops and taxi ranks;

• Amenity areas at ground level; and

• Terraces.

Outline Scope of Assessment

The assessment will quantify the potential changes to the local wind environment from the baseline conditions to those as a result of the Proposed Development (at locations both on-site and within the surrounding area) in terms of pedestrian comfort. The comfort conditions will be quantified in relation to the location’s 'usability' for a range of pedestrian activities, as defined by the Lawson Comfort Criteria.

Mean wind speeds will be examined around the Proposed Development and surroundings. This will allow for a direct comparison to be made between the results of the baseline simulation (noting the existing use of the site) and the results of the simulations of the Proposed Development, (noting the intended end uses). This will also allow for a comparison of off-site results, to determine the effect of the Proposed Development on the surrounding area.

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The assessment will focus in particular on end uses that are potentially sensitive to wind microclimate conditions, such as pedestrian footpaths or ‘thoroughfares’, entrance locations for buildings, and space with amenity use e.g. for outdoor seating. Wind directions covering the full (360°) range of approach angles will be considered.

Approach to the Assessment of Demolition and Construction Effects

As demolition and construction works progress, the conditions on and around the site would be expected to gradually transition between those of the Baseline and the completed Proposed Development. Generally, for wind microclimate assessments in London, the potential impacts during demolition and construction are assessed using the professional judgement of an experienced wind engineer, based on an assessment of the background wind climate at the site and an understanding of the effects of wind in the built environment. A qualitative approach will be taken to the assessment of the demolition and construction works.

Quantifying the Future Conditions with the Proposed Development

To understand the future wind conditions at the site, CFD simulations will be carried out to examine wind conditions once the Proposed Development is fully constructed and operational.

The following scenarios will be simulated which account for the development proposed across the three applications in various combinations:

• Main Assessment:

- Scenario 1 – Detailed Application + Highway Works Application;

- Scenario 2 – Masterplan Application + Detailed Application + Highway Works Application;

• Cumulative Assessment:

- Scenario 3 – Detailed Application + Highway Works Application + Committed Development schemes; and

- Scenario 4 – Masterplan Application + Detailed Application + Highway Works Application + Committed Development schemes.

Mean wind speeds will be measured throughout the site and the surrounding area. The analysis and interpretation will focus on this site and nearby off-site locations which may be affected by the Proposed Development. As discussed above, these locations include:

• Within the site, specifically:

- ground level around the Proposed Development - the focus being on pedestrian thoroughfares, building entrances and amenity spaces; and

- possible accessible elevated levels i.e. roof terraces.

• External to the site, specifically:

- ground level pedestrian thoroughfares;

- bus stops;

- pedestrian crossings;

- areas of public open / amenity space; and

- surrounding buildings - with specific reference to building entrances and pedestrian routes around buildings.

The results from the CFD simulations will be combined with long-term meteorological climate

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background data for the London region. Simulations will be conducted in the absence of any hard or soft landscaping, in order to provide a conservative result.

The results from the CFD simulations will be benchmarked against the Lawson Comfort Criteria to determine the suitability of the different areas, both within and surrounding the site, for sitting, standing, entering a building, leisure walking, business walking or crossing the road – See Table 16. Based on the results of the CFD simulations and assessed against the Lawson Comfort Criteria, the suitability of the conditions and the likely effect at particular locations, both within and off-site, will be determined relative to the significance criteria, Table 17.

Lawson Comfort Criteria Key Comfort Category Threshold Description

Sitting 0-4 m/s Light breezes desired for outdoor restaurants and seating areas where one can read a paper or comfortably sit for long periods

Standing 4-6 m/s Gentle breezes acceptable for main building entrances, pick-up/drop-off points and bus stops

Strolling 6-8 m/s Moderate breezes that would be appropriate for strolling along a city/town street, plaza or park

Walking 8-10 m/s Relatively high speeds that can be tolerated if one’s objective is to walk, run or cycle without lingering

Uncomfortable >10 m/s Winds of this magnitude are considered a nuisance for most activities, and wind mitigation is typically recommended

Strong Winds: 0.025% (2.2hours per annum) of 15m/s wind speeds or greater for a mixed-use development.

Effect Assessment Criteria Recorded Conditions Likely Effect

Wind Conditions are 3 categories calmer than desired Major beneficial

Wind Conditions are 2 categories calmer than desired Moderate beneficial

Wind Conditions are 1 category calmer than desired Minor beneficial

Wind Conditions are similar to those desired Negligible

Wind Conditions are 1 category windier than desired Minor Adverse

Wind Conditions are 2 categories windier than desired Moderate Adverse

Wind Conditions are 3 categories windier than desired Major Adverse

The adopted scale for the significance criteria is a logical comparison of the measured wind environment with the desired wind environment. An adverse effect implies that a location has a wind environment that is unsuitable for its intended use and mitigation should therefore be considered.

The minor, moderate and major categories indicate the severity of the difference between the desired microclimate and the actual microclimate. As an example, if the desired wind conditions at a particular location are required to be suitable for standing, but the predicted wind conditions are suitable for strolling, the difference between the desired and predicted wind condition is one category windier than desired. In this case, the significance of the effect would be identified as minor adverse. Any adverse effect would be material to the planning decision process because it implies that a location, or area, has a wind microclimate that is unsuitable for the desired use of that area.

Wind effects due to development are usually ‘felt’ within the Site boundary or the immediate surrounding streets and are due to the building massing and orientation. Consequently, all reported effects are

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considered to be direct, local and long-term/irreversible unless there is a change in the massing or climate.

The potential for strong winds to occur will also be addressed for all the scenarios examined. Strong winds are considered to be significant as soon as the threshold is exceeded, regardless of the magnitude of exceedance.

Should mitigation measures be required to provide wind conditions within a particular area / space to be suitable for their intended use, or are required to mitigate against predicted strong winds, the areas identified requiring mitigation measures will be developed in consultation with the Design Team. Where necessary, mitigation measures will be tested through additional rounds of CFD simulations. Following mitigation, the significance of any residual effects will be classified using the same criteria discussed above (Table 17).

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TOPICS TO BE SCOPED OUT Archaeology (Buried Heritage)

An Archaeological Desk-Based Assessment (DBA) has been produced (see Appendix D) for the site in order to understand any existing buried heritage value and potential impact as a result of the Proposed Development. The DBA examined a variety of evidence for buried remains of heritage interest, and to identify archaeological constraints on the future development of this site and for the formulation of a mitigation strategy if required. A walk over of the site was undertaken in June 2019 to support preparation of the DBA.

The site does not contain any World Heritage Sites, Scheduled Monuments, Registered Park and Gardens or Historic Battlefields either within or the area surrounding the site. The site is not within an Archaeological Priority Area (APA) or Conservation Area. The closest Conservation Area to the site is the Sudbury Court Conservation Area, located approximately 390m to the south of the site.

Part of the site, in the north-eastern corner, is part of Northwick Park, an area of open space located adjacent to the site to the east. The park is a Greater London Historic Environment Record (GLHER) Non-Designated Monument, which was established by the Middlesex County Council and Wembley Borough Council in 1936.

Available Records

A review of available heritage records for the local study area has identified 6 undesignated heritage assets, comprising primarily of find-spots dating from the Prehistoric to Post-Medieval periods (for further information please see Appendix D), as well as the grounds of the 20th century Northwick Park which borders the site along its southern and eastern edges.

Available records indicate limited evidence of prehistoric activity within the site and surrounding area, with finds (such as worked flint and Iron Age potsherds) located approximately 730 – 750m south-west of the site. There is some evidence within the surrounding area which dates to the Roman Period, with some tile fragments identified approximately 480m west, and a coin hoard approximately 2km to the west of the site.

Records from the 18th century indicate that the site was comprised of farmland, with a track running in an east to west direction through the northern part of the site. The track connects to buildings in connection with Sheepcote Farm (an undesignated heritage asset – falling within the western portion of the area of the Highway Works Application, near Watford Road)) to the surrounding area. The fields within the site have been identified within the records as being utilised for either arable land or meadow and pasture. The 1800 Milne map shows the established roads, Sheepcote Farm and the original Harrow settlement, indicating that these features will have been present prior to this period.

A find-spot of brickwork, nails and a late 17th century coin, located approximately 50m to the south of the site, suggest evidence of a former structure having been present previously. However, the earliest map available for the area (from 1800) does not provide any evidence that such a structure at the location existed.

Until the mid-1800s, there appears to have been little change to the site and surrounding area, with the exception of the removal of the access track from Sheepcote Farm and some modifications to the field boundaries. In the wider area, evidence of development is present with the establishment of the railway line (which exists today – north/south orientation) approximately 300m east of the site, and the Harrow School Bathing Place (an undesignated heritage asset) approximately 200m west of the site.

In the late 1800s, the railway line which currently borders the northern boundary of the site was constructed. By the mid-1930s, the Northwick Park Golf Course had taken over much of the farmland

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between Watford Road and the railway line to the east of the site (which included parts of the site). And by the year 1923, the Northwick Park Station (served by the underground) was opened, beginning the urban expansion of the surrounding area, as evidenced by the housing constructed to the east and north of the railway lines.

Aerial photograph for the year 1945 shows evidence of a military camp situated partially within the north-western corner of the site (falling within the existing UoW campus, and the UoW area of the site). Apart from this, the first substantial development of the site first occurs with the construction of the Harrow Technical College in 1959, including residential accommodation. The Northwick Park Hospital was constructed from 1962 and the residential units located to the south of the site were constructed in 2001.

Assessment

Available records indicate very little evidence of remains from the pre-post medieval periods in the vicinity of the site, and given the level of disturbance (i.e. resulting from development of the site) within the site , it is considered that the potential for the survival of any archaeological remains dating from the prehistoric, Roman, early historic and medieval period to be Low.

In terms of the post medieval period and modern periods, the former Sheepcote Farm originates from at least late 18th century, however considerable modern development in the area of the Highway Works Application is considered likely to have adversely impacted on the survival of any remains. Should there be the potential of any remains having survived, they would be considered a heritage asset of at least Local Importance. It is therefore considered that there is a Medium potential of encountering remains within this part of the site.

Overall, the DBA has established that archaeological evidence within the site and its study area is very limited. Furthermore, much of the site has potentially been subject to a range of below-ground disturbance arising from recent development which remains in place today.

There is considered to be a Medium potential for the remains of Sheepcote Farm to survive within the Highway Works Area of the site. However, the overall potential for the survival of other archaeological deposits from all periods is thought to be Low.

Given the low level of information regarding the archaeological resource and the lack of previous investigations on the site and surrounding area, the potential for unknown archaeological remains dating to the Pre-historic to Medieval periods cannot be ruled out.

Due to the uncertainty regarding the survival of remains across the site, it is proposed that a programme of archaeological works (i.e. Archaeological Trial Trench Evaluation) is undertaken to investigate the levels of previous impacts and establish the survival or absence of below-ground archaeological remains within the site. This would enable any significant archaeological remains to be identified, assessed and recorded, with the details be agreed in advance before works commence on-site. The exact scope and extent of the programme of archaeological works (i.e. a Written Scheme of Investigation) would be prepared under the terms of a standard archaeological planning condition(s) set out under the granting of planning permission, and the mitigation would be informed should archaeological remains be encountered (and dependant on their scale, extent and importance) requiring an appropriate level of archaeological watching brief / field work, evaluation (if required) and reporting (as agreed with the LPA).

Given the results of the DBA and the mitigation proposed, the redevelopment of the site is unlikely to generate any significant archaeological (buried heritage assets) related effects. The likely effects can be adequately managed so as not to cause unacceptable harm to any surviving assets and it is likely that the residual archaeological effects would not be significant.

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On this basis, an archaeological impact assessment is proposed to be scoped out of the EIA. The DBA will be submitted in support of the planning application and the Demolition and Construction ES Chapter (Volume 1) will reference the mitigation discussed above.

Aviation An aerodrome safeguarding assessment has been undertaken for the site and is presented in Appendix

G. The below presents a summary of the key findings and conclusions drawn.

The site is located adjacent to Northwick Park Hospital, beneath the north-easterly take-off and south-westerly approach flight paths to the north-east of Northolt Aerodrome, approximately 6.5 km from the runway end. The site is therefore in an area subject to aerodrome safeguarding, the process by which airspace required for safe and efficient take-off and landing at airports is maintained free of new development. Specific height limits apply at the site, according to international standards and recommended practices. The site is also located at the extreme limit of the safeguarding zone for Heathrow Airport at nearly 15 km from the aerodrome reference point (mid-point of the northern runway) that serves as the reference point for defining the relevant height limit.

From the perspective of aviation safeguarding, building heights will generally be the primary consideration. With respect to height constraints associated with operations at the airport, the notable criteria associated with the site is in terms of the Obstacle Limitation Surfaces (OLS). The OLS are a set of planar surfaces arranged about the runway and flight paths to and from it. Penetrations of the OLS are generally not permitted but penetrations of some surfaces may be allowed where it can be shown that these would not adversely affect the safety or regularity of aircraft operations. For example, where new developments reach up to the limits defined by the OLS, cranes used to support construction will, by necessity, exceed the OLS. Temporary penetrations of the OLS by cranes during construction may be permitted where they can be shown not to have any significant impacts on the safety and efficiency of operations. In practice, cranes that penetrate the OLS may be considered to be acceptable where they comply with the relevant guidance and criteria.

The assessment has concluded that, when taking into account ground level across the site, the development proposed has up to 100 m above local ground level allowance without infringing the OLS criteria. The proposed height of the new build for the Proposed Development is materially below this limit and is therefore considered to comply with the requirements of the OLS at the site.

Details regarding the construction of the site, including the use and height of temporary cranes to construct the new build, are not yet known however it is likely that the height of the temporary cranes will fall below the most restrictive OLS, and therefore will not give rise to any material impact on the safety of operations.

Consideration is given to the safeguarding of radar equipment employed for the support of air traffic control42. A preliminary review indicates that Proposed Development would not provide obstructions to the radar coverage, however it is assumed that NATS (National Air Traffic Service) would be consulted as part of any planning application. If potential adverse impacts were identified, NATS would be expected to request that a condition be attached to any permission arising from an application for the proposed development requiring that a radar mitigation scheme is agreed by the developer with NATS prior to commencement. This is an established approach which has previously been adopted to address the impacts of other tall building developments.

Bird hazard management is a further element of aerodrome safeguarding (for Northolt Aerodrome) that may require consideration. The primary hazard that may give rise to serious consequences is therefore

42 New tall buildings can give rise to two adverse impacts: interruption of radar coverage behind the buildings where airspace is shielded by them; reflections of signals from aircraft that lead to the generation of “false targets” along the line of the buildings

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a multiple bird strike involving larger species, including in particular water birds such as gulls, geese and swans which may potentially be encountered in flocks by aircraft during take-off and landing operations. Therefore, the general guidance in respect of the avoidance of water and potential nest sites that may attract these species will be adopted as part of the landscaping design.

It can be concluded that there are not likely to be any adverse effects on operations at Northolt Aerodrome or Heathrow Airport as a result of the Proposed Development, and further aviation assessments are not deemed necessary. The consideration of the Proposed Development’s impact on aviation is therefore proposed to be scoped out of the EIA.

Built Heritage There are no designated heritage assets on, or adjacent to, the site and the Masterplan Application and

Highway Works Application areas are not within an archaeological priority area. Any temporary or permanent effects on heritage would therefore be limited to the potential changes to the setting of nearby heritage assets, in terms of affecting their significance.

Northwick Park Hospital (built in the 1960s and opened in 1970) is situated adjacent to the site to the east (of the Network Homes area) and south (of the University of Westminster area). It was designed by John Weeks, of Llewelyn-Davies and Weeks Architects. It is of some architectural interest as an experiment in flexible design and is part of the story of the development of UK hospitals, but is not regarded as having any strong heritage claim. The hospital’s size and height make it a conspicuous landmark and the Boiler House chimney (located within the site – northern portion of the Network Homes area) can be identified from some distance. None of the associated hospital buildings located in and around the hospital, including those that fall within the site (within the Network Homes area) are considered to be of any interest.

The settlement of Harrow-on-the-Hill is approximately 1 km to the west of the site, within the London Borough of Harrow. Harrow-on the-Hill is of very high heritage significance, with a long and well-documented history and comprises approximately 80 statutorily listed buildings. The nucleus of the old town is the centrepiece of a group of eight contiguous conservation areas, referenced as Harrow-on-the-Hill, which includes Harrow Park (registered Grade ll on Historic England’s Historic Parks and Gardens Register). The topography of the conservation area – the hill rising to the Parish Church of St Marys, and the winding High Street – plays an important part in the character of the area, strengthened by the density of mature trees. The park (not open to the public) is well screened and is mostly used as a golf course.

Highly graded listed buildings include the Parish Church of St Mary’s Church (grade I) and a group of principal Harrow School buildings – including the Speech Room, Chapel, Vaughan Library and War Memorial Building (all Grade ll*). The school buildings form a group at the foot of the Parish Church, on the High Street.

To the northeast of the site, within LB Brent is the Northwick Circle Conservation Area, a mature and generally well-preserved inter-war suburb arranged in a radial plan around the central circle. Sudbury Court Conservation Area is positioned to the south of the site, separated from it by Northwick Park, and is another inter-war suburb with a similar mix of semi-detached houses on fairly generous plots. In both areas, street and garden trees help to unite and soften the hard surfaces of the roads, pavements and paved front gardens. There are no listed buildings in either conservation area; the nearest listed building to Sudbury Court Conservation Area, the Windermere public house, which is not intervisible with the site.

There are long views west from Northwick Park to Harrow on the Hill. Some of the lower buildings can be glimpsed but the principal landmark is the spire of the Parish Church of St Mary’s, which rises above

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the trees and can be seen from every direction. LB Harrow planning policies single out the views of the church from the northern section of the borough. The elevated position of the High Street allows certain views of the Central London skyline, including Wembley Stadium, Westminster and the City. The Hospital buildings and Boiler House chimney can only be glimpsed in certain gaps in the High Street and has no appreciable effect on the setting of the group of Harrow-on-the-Hill conservation areas.

Effects summary

The Proposed Development is considered to be sufficiently distant from any designated heritage asset to have no material impact on their settings, and therefore potentially their significance.

Views from publicly accessible positions in Harrow-on-the-Hill are anticipated to be limited to glimpsed views between buildings or trees. The primacy of the spire of St Mary’s Church as the principal landmark will not be challenged by the Proposed Development.

On this basis, an impact assessment on built heritage matters is proposed to be scoped out of the EIA.

Daylight, Sunlight and Overshadowing (Internal) The potential for daylight and sunlight availability within the newly proposed residential units and within

the newly created public realm within the site is dependent on the design of the Proposed Development, and is a design consideration, rather than an EIA issue. As there is no baseline scenario to assess or compare with, the assessment of internal daylight and sunlight condition within the proposed residential units and the quality of the internal amenity areas (from overshadowing) within the site will not form part of the EIA. These matters will be presented as a separate standalone report which will be prepared and submitted within the ES Appendix. A summary of the results will also be presented within the ES Chapter.

Ecology and Biodiversity A Preliminary Ecological Appraisal (PEA), involving a Phase 1 Habitat Survey of the Masterplan site

and of the area comprising the Highway Works Application, was undertaken on the 13th June 2019 (hereafter referred as ‘the survey’) To support the ecological assessment, a Bat Survey43 was also undertaken during the site visit as part of the PEA. The PEA prepared has been produced with reference to the guidelines for preliminary ecological appraisal (2017)44 and with Biodiversity – Code of Practice for Planning and Development (BSI, 2013)45.

The PEA is presented in Appendix E of this Scoping Report.

The survey identified and mapped the existing habitats present on site. The survey involved inspecting the site for evidence of, and its potential to support, protected or notable species, as well as for evidence of invasive plant species. The survey also mapped the existing habitats present on site. In addition, ecological databases46 were accessed for records of protected species and sites of nature conservation value within a 1km search area of the site.

The aim of the PEA is to provide baseline ecological information for the site, including the identification of broad habitat types within and directly adjacent to the site boundary, highlighting the potential for protected or particularly notable species, and to outline any requirements that may risk contravention of legislation or policy relating to protected species and nature conservation, including recommending

43 Undertaken in accordance with: English Nature (2004). Bat Mitigation Guidelines Version 2004. English Nature, Peterborough; and Bat Conservation Trust (2016). Bat Surveys- Good Practise Guidelines, 3rd Edition. Bat Conservation Trust, London. 44 CIEEM (2017) Guidelines for Ecological Impact Assessment in the UK and Ireland: Terrestrial, Freshwater and Coastal, 2nd edition. Chartered Institute of Ecology and Environmental Management, Winchester 45 British Standards Institution (2013). BS42020 – Biodiversity – Code of practice for planning and development 46 Greenspace Information for Greater London (GIGL)

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mitigation and/or enhancement measures.

The results of the desk-based search identified the following:

• The site is not subject to any statutory nature conservation designations;

• There are no statutory nature conservation designations within 1km of the site.

• A non-statutory nature conservation designations (a Site of Importance for Nature Conservation (SINC)) is located adjacent to, and along the boundary of the south and east of the site. The SINC falls partially within the site along the eastern boundary, as well as being within the north-east corner of the site (i.e. existing grass area adjacent to the UoW and Northwick Park Station (Zone B1 and Zone C)). The SINC is broadly designated for habitats including a copse of deciduous woodland, ponds, neutral grassland, old hedgerows and scattered mature trees.

The survey undertaken identified the site as including numerous buildings of various construction and use. Buildings were largely comprised of mixed materials, with all non-residential structures supporting flat roofs of either roofing felt, fibreglass, or plastics. Pitched roofs were present on modern residential builds. It was also identified that there is railway infrastructure along the northern boundary, and buildings and hardstanding associated with the Northwick Park Hospital are situated to the west of the Network Homes area, and south of the UoW area.

Hardstanding and car-parking was pervasive throughout the site, in conjunction with landscaped areas, including garden beds, individual tree specimens up to mature in age, areas of amenity grassland, and small areas of scrub. Contiguous areas of trees up to mature in age were present on traffic islands on the western boundary of the site.

To the east and the south of the site, adjacent to the site boundary, habitats identified included hedgerows, mature trees and dense scrub, and a wet ditch (located along the eastern boundary of the site). These habitats were identifies as being high in ecological value.

Overall, the results of the survey identified the majority of the site was considered to be very low in ecological value for habitats, though noting that some elements of high ecological value are present (as noted above).

Results from the bat scoping survey identified the majority of the site as being be very low in suitability for foraging bats, however habitats on the eastern and southern boundaries of the Network Homes area (particularly within the hedgerows and nearby ponds) were considered to provide a moderate suitability for foraging and commuting bats.

Also identified as having features of ecological potential were in connection with the Social Club, where this building is considered to have low bat roosting potential, as well as having mature trees (potential bat roosting features), boundary habitats and deadwood located in the area.

The wet ditch located along the eastern boundary of the site was identified as of low suitability for water voles, with no evidence of water vole activity observed.

The majority of the site was considered to be of very low suitability for other protected and priority species, such as badgers and hedgehogs. The exception is the areas along the eastern and southern boundaries of the site (the Network Homes area), and the newly sown meadow (within the UoW area), however no evidence of activity from such species was identified during the site visit.

The majority of the site was considered to be very low in ecological value or potential to support nesting birds. The Herring gull (Larus argentatus), a red-listed Bird of Conservation Concern (BoCC) species, and the Less black backed gull (Larus fuscus), an amber-listed BoCC species, were both identified during the site visit. It is considered likely that the flat roofs within the site may be used by these gulls,

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as well as other common species, though no evidence of this was identified during the site visit. Nesting of common and widespread species may also occur within the scattered trees and hedgerow.

Habitats on, or adjacent to, the site featured habitats very low in suitability for reptiles, such as the common lizard.

The proximity of the site to three existing ponds (within 500m of the southern boundary) suggest the potential presence of amphibians, including Great crested newts (Triturus cristatus). Of the three ponds, only two could be accessed during the site survey. In accordance with relevant guidance, both ponds were assessed for Great Crested Newt suitability, with one pond having a rating of ‘good’ and the other a ‘poor’ rating47. It is understood that these ponds had previously been stocked with ornamental fish species until they had been fished out by a heron earlier in 2019. When considering the low likelihood of colonisation in such a short period of time since the removal of the fish (which was most likely hampered by the poor connectivity to local ponds), the presence of and therefore potential for impacts to amphibians is considered to be very low.

The majority of the site area (buildings and hardstanding) was considered to be of very low ecological value for invertebrates. Although it was noted that mature scattered trees, wooded road ‘islands’, scrub and hedgerow provided moderate ecological value for invertebrates, with deadwood and dead standing wood observed in these locations.

The survey identified the presence of two invasive plant species, as listed under Schedule 9 of the Wildlife and Countryside Act 1981 (as amended). The Japanese knotweed (Fallopia japonica) was identified in a single location on the site (within Zone A2), and cotoneaster (Cotoneaster horizontalis) was located at various locations within garden beds throughout the site.

Overall, the findings of the PEA conclude that the site, as a whole, is of low ecological value for habitats, and the habitats were considered to be of low suitability for a variety of species which have the potential to be found within the site. However, the survey did identify some discrete locations within the site that do provide some ecological value, largely in areas located along (and beyond) the eastern and southern boundaries (of the Network Homes area) of the site, which are also designated as a SINC.

A number of measures are recommended within the PEA to both avoid or mitigate the impact on ecology and biodiversity during the demolition and construction works, as well as to provide opportunities to enhance the ecological value of the site, which would form part of the design and landscaping measures as the scheme evolves. Measures proposed for biodiversity enhancement will be described in the Proposed Development ES Chapter (Volume 1).

Based on the findings presented in the PEA, and the measures proposed to avoid or mitigate during construction, it is considered that the proposed development of the site does not have the potential to generate any significant ecological effects, and that through appropriate design, the development proposed provides opportunities for biodiversity enhancement which would benefit the site and local area relative to the existing condition. As such, it is proposed to scope the topic of ecology out of the EIA.

Geoenvironmental (Ground Conditions, Groundwater) A Geotechnical and Geo-Environmental Desktop study (also referred as a ‘Phase 1 Desk Study’) has

been undertaken for the site, based on a walkover of the site (31st May 2019) and drawing on several sources, including an Envirocheck report48 (providing survey records, historic maps and technical

47 Rating was determined through a Habitat Suitability Index assessment, as developed by Oldham et al. 2000 48 Note – the site area presented within the Envirocheck Report has conservatively adopted a larger area than what is proposed as the ‘site’ for the purpose of the Proposed Development (i.e. the area of the Masterplan Application and Highway

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information from a variety of databases). In addition, The Phase 1 Desk Study has also reviewed geo-environmental reports that have previously been prepared for areas within the site and have been referred to where appropriate.

The Phase 1 Desk Study is intended to identify the likely source-pathway-receptor pollutant linkages and provides a qualitative indication of the level of risk posed by potential ground contamination at the site. From this assessment, recommendations for mitigation and further surveys and reporting are identified.

The Phase 1 Desk Study is presented in Appendix F to support the summary presented below.

Baseline Description

The geology at the site comprises Made Ground underlain by deposits of the London Clay Formation, over the Lambeth Group, in turn over the Upper Chalk at depth.

Available geotechnical records indicate that the site and surrounding area is made up of the following (strata in the following order from ground level, and estimated depth, in metres (m)): Made Ground (mixture of cohesive and granular deposits; up to 3.0m); London Clay (soft to firm becoming stiff with depth silty grey clay with occasional sand partings, gypsum and shell fragment; between 13.00 and 24.00m); Lambeth Group (very stiff mottled variably coloured clay, with interbedded layers of very dense sand can occur with depth; 24.0 – 44.0m); and Upper Chalk (white and light grey weathered chalk, becoming stronger with depth; > 150.00m).

Review of the historical use of the site and surrounding area has identified the following:

• the majority of the site historically comprised undeveloped open land, with Sheepcote Farm and associated buildings (located within the Highway Works Application area), ponds and tank to the west of the site.

• In 1935, the farm became a Club House, with a Football Ground and Northwick Park Golf Course occupying the rest of the site.

• In 1958, development occurred in the north western site area (to the west of the proposed UoW area to be redeveloped as part of this application) and comprised Harrow Technical College and offices; noting that the Club House is no longer present in this period. Drains appear across the site, originating from the ponds and orientated north west-south east.

• By 1974, the Harrow Technical College and office buildings were replaced by new buildings labelled as ‘Harrow College of Technology and Art’, and ponds and drains that existed previously are no longer present. During this time, the southern half of the site (within the Network Homes area (A2 and A3 areas)) was occupied by Northwick Park Hospital and Clinical Research Centre and buildings with 3 tanks, a chimney and electrical sub-station located in the north east.

• From the 1970’s until present, the Hospital has expanded towards the east and the College (now the University of Westminster (UoW)), which also expanded towards the east. The Clinical Research Centre to the south of the site (within the Network Homes area (A3 area)) was replaced by the residential development (i.e. Northwick Park Village) in the late 1990s.

Potential on-site contamination sources from the review have identified:

Works Application). Where relevant, references are made to clarify where features fall outside the site for the Proposed Development.

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• areas of infilling and Made Ground associated with the development of the site (and surrounding areas), including infilled ponds and ditches, and sloped / raised areas;

• electrical sub-stations (southern portion of site, within Network Homes area);

• Boiler House with associated chimney and tanks (within northern portion of Network Homes area);

• Fuel tanks and storage areas; and

• Car parks.

Preliminary information indicates that the area in and around the site was subject to some bombing (though not covered by the London County Council Bomb Damage Maps), with a high explosive bomb recorded close to Proyers Path, which is located adjacent to the north-eastern corner of the site. Other high explosive bombs were also noted on Kenton Road, Northwick Avenue and Rushout Avenue. Due to the proximity of potential targets (two railway lines), and the bombings recorded in the site’s vicinity, further consideration of the need for a further detailed assessment was undertaken by a specialist.

A preliminary review of the UXO was undertaken during the Phase 1, which recommended the completion of a further investigation by a UXO specialist. As such, a detailed UXO desktop survey was undertaken in July 2019, which identified that parts of the site are situated within a high risk area for UXO. This has been appended to this Scoping Report in Appendix I.

Within the area surrounding the site, the Phase 1 has identified several contaminative sources or historical incidents, although comments for the historical incidents (i.e. pollution to controlled waters, burning of organic material) conclude that given the length of time (i.e. 20+ years ago) and location, these incidents are not a significant risk to the site. Sources that have been considered include:

• Registered radioactive substances (Northwick Park Hospital - presence of radioactive material is common place in hospital settings, and it is assumed that this has been properly controlled and that there has been no illegal dumping within the site).

• Presence of a railway and associated embankment running along the northern boundary, may be considered as a contamination source which can affect the northern part of the site.

Overall, the Phase 1 Desk Study concludes that the general risk of contamination of receptors (i.e. construction workers, future on-site users, neighbours) and resources (i.e. groundwater) is considered to be low-moderate or moderate for the Masterplan Application site, and low for the Highway Works Application site.

The Proposed Development

The Proposed Development is not proposing the provision of basements, but works in the ground are expected as part of construction, including sub-structure / foundation works and piling.

Taking into account the nature of the site and its historical use, and the Proposed Development being proposed, the following matters are to be considered in terms of design and mitigation:

• Undertaking an intrusive Phase 2 Site Investigation (i.e. involving laboratory testing) and subsequent stages of investigation and site remediation (if required), to be made in the form of planning conditions. This would include a written programme of ground investigation for the presence of soil and groundwater contamination and landfill gas, and following agreement on the written programme, an investigation shall be carried out in accordance with the approved programme and the results and a written scheme of remediation measures (if necessary) shall be submitted to and approved by the local planning authority.

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• The ground investigations will be undertaken prior to the commencement of works on-site and will further inform the foundation / piling works, which will confirm the appropriate piling methods and foundation design to mitigate geotechnical risk.

• The Phase 2 investigations will include a risk assessment of the contamination at the site, which would be undertaken by comparing measured levels of soil contamination with generic assessment criteria established through industry guidance and best practice.

• Should significant areas of contamination be identified during the further site survey / investigation work, a Remedial Strategy (including options appraisal) for the remediation of soils on-site, or their appropriate removal; off-site treatment (where practicable); and / or disposal off-site will be agreed as appropriate in advance of any remediation work. The remediation framework will identify remediation requirements for protection of human health and controlled waters as well as identifying any areas that require remediation to be undertaken.

• Should a Remedial Strategy be implemented, a verification process (verification plans and reporting to the local authority) will be undertaken to confirm that the strategy has remediated the soils to a level acceptable for the intended end use of the site (based on site specific criteria).

• Off-site disposal of soils will include segregation of soil types (contaminated or otherwise) into stockpiles and removed via an approved waste contractor and in accord with the regulatory requirements, including the Hazardous Waste Regulations and Landfill Regulations (i.e. any contaminated soil would be disposed of off-site at a location appropriate to the level of contamination present and the waste classification determined from chemical analysis).

• An assessment for the potential for ground gas and volatile vapours will be completed during the further intrusive site investigation work.

• The detailed UXO Threat and Risk Assessment identified a number of mitigation measures to minimise the risks of UXO. These mitigation measures include the preparation of an Operational UXO Emergency Response Plan, UXO Safety and Awareness briefings, a non-intrusive UXO Survey and / or EOD Banksman support and Intrusive UXO Survey where trial pits, excavations, piling and bore holing into previously undisturbed ground is required. These measures will be included within the Demolition and Construction Chapter and the Mitigation and Monitoring Schedule of the ES (Volume 1).

Overall, the proposed ground works across the site, associated with the preparatory ground works and foundation excavations during the construction of the Proposed Development, will result in the appropriate treatment of the identified areas of contamination (i.e. soils and materials), and is considered to result in residual beneficial effects to the local environment, through reducing the net contaminant loading at the site and surrounding area.

Health and Safety procedures appropriate to the contamination status of the site will also be implemented during construction in order to avoid or reduce potential effects to human health (i.e. construction workers and to neighbours / general public) and the wider environment.

Furthermore, a number of additional mitigation measures (refer Appendix F) are proposed to be adopted on-site, particularly with regards to storage, handling and disposal of potentially polluting chemicals associated with the demolition and construction phase and also building maintenance and plant rooms when the Proposed Development is operational. These measures are to be provided within the ‘Mitigation and Monitoring’ chapter of the ES.

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The mitigation measures will be managed through a Construction Environmental Management Plan (CEMP); Site Waste Management Plan (SWMP); Emergency Response Plan (ERP); and Health and Safely Plans (H&SP). These plans will all be completed by the Principal Contractor/s and sub-contractors prior to demolition and construction activities and agreed in advance with the planning authority. The mitigation measures implemented will be reviewed regularly to best suit the practices being undertaken across the site.

It is anticipated that the proposed mitigation / management and monitoring measures will be secured by the LBB through appropriately worded pre-commencement planning conditions, which will be attached to the planning permission.

In conclusion, based on the findings of the study undertaken to date and the proposed mitigation and management measures, it is considered that the Proposed Development is unlikely to give rise of significant residual adverse effects in respect of geo-environmental matters (Land Contamination, Ground Conditions and Groundwater). On this basis, a ground conditions impact assessment is scoped out of the EIA. The planning application will however be supported by the Phase 1 Desk Study to meet the LBB’s planning application validation requirements.

Land Take and Soils Consideration has been given to the potential for any effects arising because of the Proposed

Development on ‘Land Take’ and ‘Soils’.

With regard to the consideration of ‘land’ (for example land take49), when describing factors likely to be significantly affected by the development, the Proposed Development represents an opportunity to redevelop a brownfield site within London in a sustainable manner. The site is not a ‘greenfield site’; it is not natural or semi-natural land that is being ‘taken up’ by urban development. In addition, the site does not represent open or publicly accessible space used as a recreational resource within an already built-up environment. As a result, no likely significant adverse effects associated with ‘land take’ will arise because of the redevelopment of the land comprising the Proposed Development.

With regards to ‘Soil’, consideration of the geo-environmental conditions associated with the site is discussed within this Scoping Report (refer section ‘Geoenvironmental (Ground Conditions, Groundwater)’) and Geo-Environmental Phase 1 Desk Study (refer Appendix F). The Phase 1 Desk Study concludes further site intrusive investigations (i.e. Phase 2 Site Investigation, involving laboratory testing), in order to ascertain the extent and degree of contamination. Should significant areas of contamination be identified during the further site survey/investigation work, a Remedial Strategy (including options appraisal) for the remediation of soils on-site, or their appropriate removal; off-site treatment (where practicable); and/or disposal off-site will be agreed (i.e. appropriate waste management licensing and disposal routes for the material that will be removed) as appropriate in advance of any remediation work. The remediation framework will identify remediation requirements for protection of human health and controlled waters as well as identifying any areas that require remediation to be undertaken.

The redevelopment of the site therefore provides an opportunity to remediate the site, through the removal of the soils arising from the bulk earthworks required to facilitate redevelopment of the site. Contaminated soils would be disposed of appropriately offsite.

Project Vulnerability – Accidents or Disasters With reference to Regulation 4(4) and Schedule 4 of the EIA Regulations, this Scoping Report also

49 Land take is referred as being the loss of agricultural, forest and other semi-natural and natural land to urban and other artificial land development

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considers whether there are likely to be any significant effects on the environment or the project arising from the vulnerability of the Proposed Development to major accidents or disasters.

Available guidance (IEMA Quality Mark Article ‘Assessing the Risks of Major Accidents and Disasters in EIA (WSP, 2016)) defines major accidents and disasters as follows:

“man-made and natural events which are considered to be likely and are anticipated to result in substantial harm that the normal functioning of the project is unable to cope with/rectify”.

Paragraph 8 of Schedule 4 of the EIA Regulations (as amended) provides further description of the information to be provided in the ES in relation to these events. In line with this description it is understood this information would in particular be considered to be of key importance for the assessment of major industrial and/or infrastructure schemes which could pose significant risks to society and the environment in the event of a major accident or a natural disaster which would impede its normal function (e.g. nuclear / petrochemical installations, major transport infrastructure such as tunnels, bridges or airports, etc.). While the Proposed Development does not fall into either of these scheme categories, the project’s vulnerability to such events has nevertheless been taken into consideration in order to ascertain the potential risks to future site users and surrounding human and environmental receptors.

For any new development, a project’s vulnerability to major accidents and natural disasters should be considered both in terms of the likelihood of the project itself to cause a major man-made accident, and in terms of the project being affected by an external man-made accident or by a natural disaster. In all these cases it is furthermore important to consider whether any aspect of the proposed development’s design or operation could worsen the effects of any such events on nearby receptors.

The London Resilience Partnership (LRP) has developed the London Risk Register, which lists a range of natural hazards and man-made accidents/incidents and assesses the risks they pose to the London area based on their potential impact and likelihood. As well as assessing the risk of these events, the London Risk Register also provides an outline of the control measures already in place to avoid, manage and respond to them. These measures range from specific laws and regulations intended to avoid or manage the potential causes of major accidents and natural disasters, to government agency programmes intended to prevent, inspect and monitor these causes, as well as a variety of response plans, forecasting and early warning systems. The effective implementation of these plans, programmes, legislative tools and guidance is considered to reduce the risk of these events to a level which is as low as reasonably possible.

Due to the nature and surroundings of the Proposed Development, many of the events listed in the Register (e.g. wildfires, animal diseases, etc.) are not considered relevant or likely to pose a risk to future site users or surrounding receptors. The remaining events in the Register will be managed, or altogether avoided, through the aforementioned established regulatory framework and the control measures implemented at the local and/or national government level, with the support of specialist government agencies.

In some cases, this risk management process will be further supported with project-specific information and assessments which form part of the EIA and the wider planning process. This includes the assessment of potential weather-related events, such as those relevant to the wind microclimate and solar glare assessments, which under certain conditions could pose a risk to pedestrians and/or vehicle users. Likewise, the requirement for a Flood Risk Assessment within the planning application will address the flood related risks as listed in the London Risk Register.

In line with the above, within the context of the events assessed in the London Risk Register, it is considered that the vulnerability of the Proposed Development to major accidents and natural disasters

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will be adequately managed throughout the lifetime of the project. As such, it is considered that the vulnerability of the Proposed Development to such events, is in itself, unlikely to result in any further significant effects on introduced site users or surrounding environmental and human receptors.

The EIA for the Proposed Development will therefore not specifically consider the issue of major accidents and natural disasters any further.

TV and Radio Interference Interference to certain telecommunications systems (e.g. television (TV), mobile phone and radio) can

arise from buildings physically blocking and absorbing associated signals. Therefore, a loss or degradation of the reception of such systems can result from the introduction of new buildings, and is often referred to as ‘electronic interference’, with the affected area referred to as the ‘shadow area’.

For assessment purposes, domestic dwellings where TV is watched or radio is listened to as an amenity, are identified as sensitive receptors. Places where the provision of TV or radio form part of a commercial premises (e.g. hotels, offices and shops), are not identified as sensitive receptors50.

Terrestrial (land based) TV signals are transmitted in digital format (Digital Terrestrial TV (DTTV) i.e. freeview). The site receives DTTV signals from the Crystal Palace transmitter mast, located approximately 23.5km to the south-east of the site; any resultant DTTV shadow areas will therefore be located to the north-west of the site.

From review of the site and surrounding context, there are several tall buildings in close proximity to the site (for example, Northwick Park Hospital, a tall building associated with the University of Westminster Harrow Campus), which generate an existing baseline DTTV shadow area (see Figure 18 below).

50 This differentiation has been consistently used by the relevant United Kingdom (UK) government agencies (currently Office of Communications (OFCOM)) since the inception of TV services in the UK.

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Figure 18 Existing Baseline DTTV Shadow Area

On review of the proposed massing and height arrangement for the development comprising the Masterplan Application, it has been identified that the taller buildings will be located toward the existing hospital site, whilst the lower rise buildings are situated towards the outer parts of the site, such as towards Northwick Park.

Based on this arrangement, it is not anticipated that the DTTV shadow generated as a result of the Proposed Development would fall outside the existing baseline DTTV shadow area, with the exception of the proposed 15 storey building, due to its height and location within the site. Dependant on the final height, massing and location of this building within the site, there is the potential for some residential dwellings located to the north-west of the site to be impacted by the potential DTTV shadow area. Those residential dwellings who are likely to be most noticeably impacted would be those located in closest proximity to the site, with the scale of the impact reducing with distance away from the site. This is due to ‘knife-edge diffraction’. This diffraction mechanism is a process whereby signals appear to bend (or ‘diffract’) behind a structure and eventually meet, like that of a knife-edge as opposed to a straight block. Therefore, the residential dwellings likely to experience potential impacts are those located along Northwick Avenue and Kenton Road (reducing with increased distance from the site).

For residential dwellings located within the predicted DTTV shadow area, measures are available to mitigate the potential adverse impact, including: upgrading of the existing DTTV aerials by increasing their height and gain; the provision of a non-subscription satellite service (available from the BBC and ITV (‘Freesat’) or Sky for a one-off cost); or linking affected residential dwellings up to the existing available CATV network at a one-off cost (CATV is available in the area surrounding the site). These measures are straight forward to implement and would remove the potential adverse impact to DTTV reception. The disruption of DTTV reception to the north-west of the site should be monitored, in order to determine whether any adverse effects are experienced as a direct result of the Proposed

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Development. A Complaints Register Scheme for the reporting of disruption or loss of DTTV reception as a result of the Proposed Development will be submitted to and approved in writing by the Local Planning Authority. The developer will take responsibility with respect to the entire complaints process.

Initially it is advised that via local community meetings and / or via a notice on the site fence (with a phone number clearly displayed), that any person with a possible interference issue can log their complaint with the developer’s dedicated contact. The reports of any interference must be logged accurately and in detail. Every month, the log will have the full details of all complaints. Each complaint will be reviewed in order to determine whether the interference issues are a direct result of the Proposed Development; in order to gain sufficient evidence for this, a pre-commencement baseline DTTV reception survey should be undertaken of the anticipated DTTV shadow area based on the final scheme details, with an additional DTTV survey undertaken post-completion.

Satellite TV services to the UK are provided by geo-stationary satellites, which are primarily located within the Astra 28.2o E satellite cluster. Due to the geostationary positioning of the satellites in relation to Sutton, satellite TV shadow areas will fall to the northwest of the site.

Due to the positioning of the Proposed Development it is anticipated that the satellite TV shadow generated as a result of the Proposed Development will fall to the northwest of the site.

It is considered that the predicted satellite TV shadow is not anticipated to fall over any residential dwellings. It is considered that no risk of loss or degradation to satellite TV reception would be expected as a result of the Proposed Development.

Whilst there is the potential for some impact to occur (as a result of a potential loss or degradation to DTTV reception received by residential dwellings locate to the north-west of the site), taking into account the size and extent of potential impacts and the availability of standard measures to monitor and remedy potential impacts, the likely residual effects on DTTV reception to surrounding receptors are not considered to be significant. On this basis, consideration of electronic interference (TV and Radio) effects are scoped out of the EIA.

Water Resources, Drainage and Flood Risk There are surface water features within the local area surrounding the site. This includes a pond

approximately 200m southwest of the site boundary and a further pond approximately 980m southwest of the site. Two ponds which are part of the Middlesex County Golf Union also lie approximately 300m southeast of the site. Brent Reservoir is approximately 4km southeast.

Flood Risk and Surface Water Drainage

Flood risk is regulated through the NPPF which outlines the need for a site-specific Flood Risk Assessment (FRA) to be produced for all sites located within Flood Zone 2 and 3, bigger than one hectare or with critical drainage problems.

Based on the Environment Agency’s (EA) ‘Flood Map for Planning’51 the site occupies an area of approx. 17.4 ha and is located within Flood Zone 1 - an area assessed as having a low probability of flooding from rivers and sea (less than 1 in 1,000 annual probability).

The EA also provides mapping for the risk of surface water flooding, which identifies that there are areas, predominantly along the eastern and southern areas (within the Network Homes area) of the site, which have a high probability for surface water flooding (risk zone 3a). Mapping shows the extent of potential flooding along the hard surface areas within the site (i.e. ring road and Nightingale Avenue).

Extending across the northern portion of the site (within the UoW area) on an east-west orientation, the

51 Source: https://flood-map-for-planning.service.gov.uk/ - Accessed June 2018


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maps identify a culverted watercourse. This links with identified watercourses outside the eastern boundary of the site (within Northwick Park), and also extending out beyond the western boundary of the site (a drain), on the opposite side of Watford Road.

The EA maps show the maximum extent of flooding from artificial sources (i.e. reservoirs) occurring to the south of the site, but does not extend to falling within the site. Therefore, the risk of flooding from artificial sources is considered to be low.

Given the FRA criteria referenced in the NPPF, an FRA will be prepared for the Proposed Development and will be submitted in support of the planning application(s). The FRA will be prepared in line with the NPPF requirements, and will present matters including:

• details of any historical flooding events;

• acceptability of the proposed land use in relation to known flood zones;

• indicative volume of surface water runoff likely to be generated by the development;

• details of SuDS surface water drainage; and

• details of flood resilience and resistance measures as appropriate.

The FRA will include details of the outline surface water drainage strategy which will be the primary means to control the quality and quantity of surface water runoff from the new development in line with local policy and London Plan requirements. The strategy will also consider the options available for the management of surface water runoff in line with the drainage hierarchy, which will include minimising at source (i.e. through the use of sustainable drainage systems (SuDS)) through to attenuation and discharge to the public sewer network. It is expected that the drainage strategy presented will be further finalised during the detailed design stage as part of a standard condition attached to any future planning permission granted.

Through a well informed and considered design process with regard to flood risk and surface water drainage considerations, coupled with appropriate measures through the design to manage the residual flood risk at the site following redevelopment, no likely significant effects associated with flooding and surface water drainage are anticipated.

The results and conclusions of the FRA (including accounting for climate change resilience with regard to flood risk and surface water drainage) will be presented in the Proposed Development ES Chapter (Volume 1).

Groundwater – Flooding and Impact

Groundwater flooding is caused by water within sub-surface permeable strata and is generally a localised issue based on the topography of the site and underlying hydrogeology and water table levels.

Information available for the site and surrounding area (refer Phase 1 Report, presented in Appendix F) indicates areas of Made Ground over a general sequence of London Clay Formation, over the Lambeth Group, in turn over the Upper Chalk at depth.

The potential for shallow groundwater is low given the sequence of the London Clay Formation (unproductive strata - to a depth of 24m), until the base of the London Clay layer is reached and the interface with the Lambeth Group, where granular layers may occur that can be water bearing. The Lambeth Group can also have a high degree of variability in composition (vertically and horizontally) and can contain groundwater (Secondary A Aquifer).

Geological information also identifies that there is a ‘Chalk layer’ which provides for a ‘Principal Aquifer’; and that this layer is located deep below ground level (>150m below ground level (bgl)). Benefitting

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from low permeable clay layers higher up in the geological sequence impeding the hydraulic continuity between the shallow groundwater and deeper groundwater (i.e. protection from surface pollutants), and given the depth of the Chalk layer, the Principal Aquifer is generally considered to provide groundwater of high quality and support abstractions for public water supply. In general, the groundwater flood risk from the chalk aquifer is considered to be low. However, given its classification as a Principal Aquifer in terms of water quality, it is considered to be a resource of high importance in terms of its sensitivity to potential impacts (i.e. contamination).

Whilst there is no basement being constructed, there is the potential for contamination of groundwater resources through sub-structure works during construction (i.e. piling). Subject to details (as part of the final, detailed design) relating to the proposed substructure works, there is the potential that the final piling solution may pierce the low permeable clay layer, striking either water bearing granular lenses at the interface with the Lambeth Group, as well as groundwater within the Lambeth Group itself. Appropriate practice and measures are proposed to mitigate the risk of contamination. However, given the variability, it is considered that there is unlikely to be significant water body beneath the site and, taking into account the depth to the Chalk Layer, the potential for contamination migration via groundwater (reaching the Principal Aquifer) is considered unlikely.

As part of best practice, a list of these measures is outlined within the Appendix H of this Scoping Report and will be adopted in order to mitigate any impact on groundwater and the potential risk of contamination. It is envisaged that these measures would be included within the CEMP prepared for the site.

Additional consideration is also discussed in the Phase 1 Geotechnical and Geo-Environmental Desktop Study (see Appendix F).

The measures outlined within Appendix H, to be implemented during the period of construction works, will be presented within the ‘Mitigation and Monitoring’ ES Chapter (Volume 1).

During construction of the substructure, it is proposed that suitable protection in terms of the potential interception of shallow groundwater will be implemented. The basement would be designed (as part of the detailed design) and constructed to incorporate a level of waterproofing to prevent the risk of water ingress.

Should groundwater be intercepted, it is considered that whilst there may be the potential for a small rise in the water table through the introduction of below ground structures, in the long term the groundwater level would eventually equalise and it is not expected for there to be any widespread change in the shallow groundwater level. Consequently, it is considered that the proposed works would have a negligible effect on shallow groundwater level.

Wastewater (Foul Drainage)

Foul water discharge rates to the existing TWUL network52 are expected to increase as a consequence of the Proposed Development relative to the existing condition. The consideration of foul drainage, and the strategic options for foul water management at the site, will be accounted for within the outline surface water drainage strategy referred earlier.

The anticipated increase in foul flows generated by the Proposed Development would be compensated by the expected reduction in the rate of surface water discharged to the drainage / sewer network. Further measures, including the installation of water efficient fixtures and fittings, can further help reduce the volume of foul water generated on-site and therefore reduce the overall magnitude of the impact of the Proposed Development on the public drainage network. The Proposed Development ES Chapter

52 Understood that Thames Water provides sewerage services

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(Volume 1) will present the estimated increase in waste water generated at the site based on assumptions of the likely population occupying the buildings. The waste water volume estimates do not account for the use of water efficient fixtures and fittings (they are based on standardised average levels of water demand), and so would assume a reasonable worst case for the Proposed Development.

It is expected that during the detailed design stage, TWUL would be consulted regarding connection to the public drainage network as part of preparing a Utilities Assessment. The assessment (undertaken by TWUL) would confirm the capacity of the local sewer network and details relating to the point of connection, with the aim to identify any requirement to upgrade the local sewer network (if required).

Where there is existing capacity available in the local sewer network, it is considered the increased peak foul flows will result in a low magnitude of impact and therefore have a likely minor effect (not significant) on TWUL infrastructure local to the site. If it is determined that capacity within the local sewer network needs to be increased, then agreement between the Applicant and TWUL would involve works to upgrade the local sewer network and therefore, following these works, any likely effect would remain not significant.

Water Demand

There is a potential impact in the form of increased potable water demand resulting from the Proposed Development relative to the existing condition.

The Proposed Development ES Chapter (Volume 1) will present the estimated increase in water demand associated with the Proposed Development once complete and occupied. The estimated water demand calculations do not account for the use of water efficient fixtures and fittings, which are expected to be implemented as part of the completed Proposed Development, and so would assume a reasonable worst case for the Proposed Development.

Affinity Water53 produce Water Resource Management Plans (WRMP)54 which sets out forecasts for water supply and demand, and outlines the strategy proposed to meet consumers’ needs into the future (note: Plan is published every five years to show how to supply enough water to meet demand over the next 25 years). As part of the production of the WRMP, Affinity Water has taken into account the projected future growth within its defined catchment area through various data and information sources, which can include Government census data, past trends and local authorities’ forecasts of future population growth. The forecasts determine the most likely scenarios for growth and it is therefore considered that the potential impact of the Proposed Development on water demand would be accounted for within the strategic forecasts (i.e. the Proposed Development being inherently part of the growth and development forecasted within the supply area).

To inform the detailed design stage, consultation with Affinity Water may result in the need to carry out flow and pressure tests for daily peak demand estimations for the Proposed Development. This will assess the available capacity in the local supply network and determine whether any infrastructure work is necessary to support the Proposed Development and provide an indication of any cost of upgrades to the network. This may be undertaken as part of the detailed design stage (if required).

Following the inclusion of water efficiency measures to reduce water usage, in addition to the implementation of the WRMP (i.e. management and provision of water supply to accommodate future growth), it is considered that sufficient measures will be in place for water demand to be met and so no likely significant effects are anticipated.

53 The site falls within the water supply area for Affinity Water (source: https://www.affinitywater.co.uk/our-supply-area-moving-home.aspx) 54 Source: https://stakeholder.affinitywater.co.uk/our-future-plans.aspx

https://www.affinitywater.co.uk/our-supply-area-moving-home.aspx

https://www.affinitywater.co.uk/our-supply-area-moving-home.aspx

https://stakeholder.affinitywater.co.uk/our-future-plans.aspx

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FORMAT AND CONTENT OF THE EIA The proposed scope and structure of the ES is as follows:

• ES Volume 1: Main ES – a document which forms the main body of the ES and which comprises of the following non-technical and technical chapters:

- Chapter 1. Introduction and EIA Methodology;

- Chapter 2. Alternatives and Design Evolution;

- Chapter 3. The Proposed Development;

- Chapter 4. Demolition and Construction;

- Chapter 5. Socio-Economics;

- Chapter 6. Traffic and Transport;

- Chapter 7. Air Quality;

- Chapter 8. Noise and Vibration;

- Chapter 9: Daylight, Sunlight, and Overshadowing;

- Chapter 10. Wind Microclimate;

- Chapter 11. Effect Interactions;

- Chapter 12. Likely Significant Effects and Conclusions;

- Chapter 13. Mitigation and Monitoring Schedule;

- Chapter 14. Glossary and Abbreviations.

• ES Volume 2: Townscape and Visual Impact Assessment – a separate townscape and visual impact assessment (TVIA) document that will be accompanied by a full set of views and verified images, as agreed with LBB as part of this EIA Scoping Process:

• ES Volume 3: Technical Appendices – comprises background data, technical reports, tables, figures and surveys. The following appendices are currently envisaged

- Appendix Introduction and EIA Methodology:

Annex 1: EIA Scoping Report (and Appendices);

Annex 2: EIA Scoping Opinion & Related Correspondence;

- Appendix Socio-Economics:

Annex 1: Health Impact Assessment;

- Appendix Air Quality:

Annex 1: Supporting Technical Data;

- Appendix Noise and Vibration:

Annex 1: Supporting Technical Data;

- Appendix Daylight, Sunlight, Overshadowing, Light Pollution and Solar Glare:

Annex 1: Daylight and Sunlight Technical Data;

Annex 2: Overshadowing Technical Data;

Annex 3: Light Pollution Technical Data;

Annex 4: Solar Glare Technical Data;

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- Appendix Wind Microclimate:

Annex 1: Wind Microclimate Technical Report;

- Appendix Flood Risk and Drainage:

Annex 1: Flood Risk Assessment;

Annex 2: Drainage Strategy;

- Appendix Climate Change:

Annex 1: GHG Emissions Assessment;

- Appendix Ecology:

Annex 1: Preliminary Ecological Assessment.

- Appendix Ground Conditions:

Annex 1: Phase 1 Land Contamination Assessment.

- Appendix Archaeology:

Annex 1: Archaeological Desk Based Assessment.

• ES Non-Technical Summary (NTS) - this will be a separate document providing a concise description of the Proposed Development, the alternatives considered, any identified mitigation measures and the residual likely significant environmental and socio-economic effects.

Schedule 4 of the EIA Regulations sets out the information for inclusion within an ES. In response to this Schedule of the EIA Regulations, a ‘way-finding’ table which sets out the information for inclusion within an ES and where this information will be presented within the ES will be included within Volume 3 of the ES (as referenced within Appendix C of this scoping report).

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REQUEST FOR AN EIA SCOPING OPINION This Report requests a Scoping Opinion of the LBB pursuant to Regulation 15 of the EIA Regulations.

The EIA Scoping Report suggests a comprehensive scope of work based on previous experience of the assembled team of specialists and existing knowledge of the site. The LBB and consultees are invited to consider the contents of this Report and comment accordingly within the five-week period prescribed by the EIA Regulations.

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APPENDIX A - Site Location and Redline Planning Application Boundary

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APPENDIX B– Cumulative Schemes Cumulative Scheme List

The EIA Regulations require that, in assessing the effects of a particular development proposal, consideration should also be given to the likely significant effects arising from the “cumulation with other existing and/or approved projects” (Schedule 4, 5(e)) (i.e. Cumulative Schemes).

To ensure that cumulative impacts and effects are assessed as comprehensively and realistically as possible, the EIA would only consider other ‘Cumulative Schemes’. The Cumulative Schemes that will be considered within the ES will typically be located within a 1-kilometre (km) radius from the centre of the site.

The Cumulative Schemes identified will be guided by the following criteria:

• Full planning permission or a resolution to grant permission;

• Produce an uplift of more than 10,000 square metres (Gross External Area (GEA)) of mixed-use floorspace, or over 150 residential units.

In addition, any office to residential conversions (granted under the General Permitted Development Order) giving rise to >150 residential units will be considered

Note that the above criteria form a guide in the absence of any formal EIA cumulative scheme guidance. Additional factors which are taken into account to help determine which schemes are included (or excluded) include (amongst others) for example, distance of the scheme from the Site, and nature and scale of the development for the scheme. Where relevant, the assessment within the respective chapter may only identify a selection of Cumulative Schemes for the assessment (i.e. because of distance to the Site), or alternatively identify additional schemes for inclusion (i.e. beyond the 1 km radius) - a clear reason and rationale for doing so.

Where a Cumulative Scheme benefits from multiple consents, the scheme that is the latest permission would be assessed (refer highlighted row). This approach excludes applications for non-material amendments (s96A) – by virtue of the nature of the amendment involved (but have been included for record / reference purposes only). Where the Committed Scheme is subject to a new application that has not yet been determined, qualitative consideration would be given to the implications of the new application if at an advanced stage of planning determination.

Cumulative effects arising from the Proposed Development, in combination with Cumulative Schemes, will be considered throughout the ES. The potential for cumulative effects arising during the demolition and construction works and once the Proposed Development is complete and operational will be considered. Each individual technical chapter of the ES will present an assessment of the cumulative effects of the Proposed Development coming forward alongside the Cumulative Schemes.

For the Proposed Development, the following preliminary list of Cumulative Schemes have been identified for consideration.

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Cumulative Schemes

Map Ref

Application Reference

Site Address / Reference

Postcode Borough Description Application Status

1 P/0737/15 51 College Road HA1 1AA Harrow

Redevelopment of the former Harrow Post Office to provide 318 flats (C3), 862 sq. metres floorspace for retail (A1), financial & professional services (A2), restaurants and cafes (A3) pubs and bars (A4), hot food take-aways (A5), business (B1) and non-residential institutions (D1) uses and 1,672 sq. metres floorspace for

library (D1) use in buildings of up to 20 storeys (134.5 metres aod) in height; 2,413 sq. metres public realm including new public square; basement and surface servicing and parking (total 50 car spaces, 3 motorcycle spaces and 521 cycle spaces); principal vehicular access from William Carey Way and secondary vehicular access from College Road. Proposal also includes combined heat & power plant; hard and soft landscaping,

balconies and roof gardens; and demolition of former post office buildings. (Resident Permit Restricted)

Approved 01/01/2017. Works have

started

2 P/3118/11

Equitable House & Lyon House, Lyon

Road

HA1 2EW Harrow

Demolition Of Equitable House And Lyon House And Erection Of Seven New Buildings Of Various Heights Ã¯Â¿Â½ Single Storey (Lodge), Six Storeys (Blocks A And B), Eight Storeys (Blocks F And H), Ten Storeys

(Blocks C And D/e) And 14 Storeys (Block G) - For A Mixed Use Development, To Provide 238 Private And 49 Affordable Residential Flats, 3,050.8 Square Metres Of Commercial Floorspace Split Into 1,503 Square Metres

Of Office Space (Class B1a) And 1,547.8 Square Metres Mixed (Classes D1 And Mix Of A1, A2, And A3), Three Vehicular Accesses From Lyon Road And St John's Road, 123 Car Parking Spaces, Landscaping And

Public Realm Improvements To Lyon Road And St John's Road

Approved 31/03/2015.

Works have

started.

3 P/4332/17

Former Cumberland

Hotel & Victoria Hall, St. John's

Road

HA1 2JN Harrow

Redevelopment of the former Cumberland Hotel, Victoria Hall and houses on Victoria Close to provide 569 m2 for the new Victoria Hall community facilities (Use Class D2), 204 residential flats (Use Class C3), 78.9 m2

floorspace for a flexible retail unit along St Johns Road (Use Classes A1-A3, B1, C3, D1 and D2) in buildings up to 16 storeys in height; a pedestrian link between Sheepcote Road and St Johns Road and associated

plaza; basement and ground floor servicing and parking; amenity space, hard and soft landscaping; and plant room

Approved 14/08/2018.

Works have

started

4 P/0291/16

Sonia Court, Gayton Road Car Park &

Former Library Site, Gayton

Road

HA1 2HH Harrow Redevt: Demolition of existing buildings & erection of 355 flats (5 buildings of 5, 6, 8, 9 and 11 storeys) with

477 sq. m commercial and community use space (Flexible uses comprising A2, A3, B1 and D1); parking; new public open space, landscaping etc

Approved 04/04/2016. Works have

started.

Northwick Park

99

Cumulative Schemes Map

1

2

3

4

500m

1,000m

Northwick Park

APPENDIX C – Information for Inclusion within an ES: Way Finding Refer to ES Volume 3, Appendix Introduction and EIA Methodology, Annex 1

Northwick Park

APPENDIX D – Archaeological Desk-Based Assessment Refer to ES Volume 3, Appendix Archaeology, Annex 1

Northwick Park

APPENDIX E - Preliminary Ecological Appraisal Refer to ES Volume 3, Appendix Ecology, Annex 1

Northwick Park

APPENDIX F - Geoenvironmental Desk Study Refer to ES Volume 3, Appendix Ground Conditions, Annex 1

Northwick Park

APPENDIX G - Aerodrome Safeguarding Assessment Refer to ES Volume 3, Appendix Aviation, Annex 1

Northwick Park

APPENDIX H – Best Practice Mitigation – Water Resources, Drainage and Flood Risk

Northwick Park

APPENDIX I – Detailed UXO Threat and Risk Assessment

Trium Environmental Consulting LLP 69-85 Tabernacle Street London EC2A 4BD +44 (0) 20 3887 7118 [email protected] www.triumenvironmental.co.uk Project Reference: TEC00012