What is being proposed at Cricklewood?
The proposal is for a new modern ready-mixed concrete ‘batching’ plant to be set up on one part of the wider Cricklewood Rail Freight Facility (RFF). The RFF is currently permitted to be used for the rail transportation and storage of aggregates and waste spoil arising from local building and construction.
The concrete plant would be supplied by aggregates (principally gravel and sand) by train. The aggregates would be unloaded and stored on site within enclosed bays until it is needed to make the concrete.
In addition, the state-of-the-art design of the plant would ensure adherence to the strict environmental standards in place in areas such as air quality and noise reduction, with adaptations to the local road network already in place to improve road safety.
Location and Layout
The concrete plant would be located on ‘Plot 3’, one of the four plots within the wider RFF site. The area is approximately 0.42 hectares (which is a little over half a typical football pitch). As a result of the public consultation on our original proposal we made a number of compromises to the plant design to reduce the visual impact in nearby properties, including the removal of some of the elements of our proposal to reduce the size of the proposed plant.
Our revised design has involved re-orienting the plant layout so the tallest parts of the plant are as far away as possible from the Railway Terraces Conservation Area. This will have the net visual effect of further lowering the highest parts of the plant on the horizon when viewed from the Railway Terraces to the south.
Producing concrete involves combining aggregates (eg gravel, sand and rock) with cement and water plus small amounts of additives (eg fibres) that control the performance of the final concrete mix. The aggregate would be delivered directly from trains into enclosed (walled) storage bays and then, using a front end loader, fed into the covered storage hoppers from where it is transferred by covered belt conveyors into covered storage ‘bins’.
Approval will be sought to operate the concrete plant from 7am to 7pm on Mondays to Fridays and from 7am to 2pm on Saturdays. These hours are the same as consented for the wider rail sidings development.
In reality there would be busy times and quieter times, depending on the local demand on any given day. There would be no concrete batching plant operations on Sundays and Public Holidays.
A detailed assessment of the potential effects on local air quality (including dust and traffic emissions) has been carried out by DB Cargo as part of the development of the wider Rail Freight Facility and agreed through the planning process as part of that application. Our proposals will not generate any additional net emissions and will comply with all of the monitoring requirements and limits set in the wider site permission.
We recognise that air quality is a primary concern and we have built in air quality mitigation measures into the design of our proposals ‘from the ground up’. These include ensuring that any potentially ‘dusty’ activities are enclosed where practicable, the use of dust suppression systems (fine spray at key locations), keeping the ground clean (especially areas where vehicles will be operating) and minimising drop heights from loading equipment when handling materials.
Vehicles used will be regularly maintained and engines switched off when stationary. Furthermore, the concrete mixers would all have the latest Euro VI engines which are the cleanest available and the only ones approved for us in Ultra Low Emissions Zones (ULEZ) such as London.
Aggregates deliveries to the proposed site would be by rail, bringing huge benefits in terms of air quality. Each train delivery keeps between 75 and 85 lorries off the roads depending on the length of the train, and UK Government rail freight studies have found that a typical aggregates train is proven to have on average 76% lower carbon emissions than the equivalent road transport. Particulate emissions from rail transport are an average of 90% lower than the equivalent road journey. (Source: UK Government Rail Freight Strategy 2016)
The plant itself would be a modern design which comes with the latest technology to eliminate the air quality impacts sometimes associated with older plants. We would be required to obtain and maintain an environmental permit from the Local Authority for the operation of our proposed concrete plant, which will include requirements for how we operate and will ensure that we do not generate unacceptable emissions.
Furthermore, the London Plan requires that new developments be classified as ‘air quality neutral’. Assessment against benchmark emissions identified for buildings and transport show that the Proposed Development can be certainly considered as ‘air quality neutral’.
Landscape and Visual Impact
As part of our original planning application we undertook an assessment of the potential for the plant to have a visual impact. This took into account the nature of the surrounding area as well as the screening already proposed under the existing planning permission 17/5761/EIA (as amended by 19/3098/NMA) for the wider RFF site.
Following significant local consultation an application for a suitable replacement to the collapsed ‘ecobarrier’ has been submitted by site operator DB Cargo. We anticipate that the new visual and acoustic screening will be agreed before our application for a concrete plant is determined by Barnet planning committee.
Our original concrete plant design was already lower than other similar plants and would have been largely screened by nearby buildings and the wider RFF site screening. After consultation with neighbours, we redesigned the plant to take account of concerns about the potential for visual impact, especially the height of the cement silos.
To give an indication of how the site would look from the outside we worked with local representatives to identify key viewpoints and created photomontages showing what would be seen if the proposal were to go ahead.
Detailed noise assessment and monitoring has been undertaken as part of the development of the wider RFF, and a noise monitoring scheme and maximum acceptable noise levels has been agreed. Our proposal will comply with all of these noise requirements.
An assessment of the potential noise generated by our proposed development has been undertaken. Calculations show that the plant will operate within the noise limits set out in the planning conditions as a result of mitigation measures incorporated into the design of our plant and equipment, and the mitigation measures provided for the wider rail freight development.
All plant and equipment would be designed to minimise noise and we would, therefore, comply with the standards set out in the site management plan that has been agreed as part of the recently approved planning permission for the site.
Following significant local consultation, an application for a suitable replacement to the collapsed ‘ecobarrier’ has been submitted by site operator DB Cargo. We anticipate that the new visual and acoustic screening will be agreed before our application for a concrete plant is determined by Barnet planning committee.
Detailed assessment of the potential for light pollution was undertaken as part of the wider RFF site development. Our proposals will comply with all of the lighting requirements placed on the wider RFF and we will use the same sort of low light spill illumination.
While our operating hours will be restricted to those permitted for the wider RFF the concrete plant will need to operate in the dark during the winter months and some lighting will be needed for safety reasons.
Recognising the concerns expressed about the proximity of the concrete plant to the Railway Terraces Conservation Area, as part of our revised planning application we commissioned a further independent heritage appraisal by a suitably qualified heritage expert. Using the statutory assessment method this was designed to examine the potential effects of the proposed scheme on local archaeology and cultural heritage, in line with the National Planning Policy Framework.
The assessment considered both direct and indirect effects of the proposal, especially on the Railway Terraces Conservation Area. The report identifies that the Conservation Area is around 100m from the boundary of the planned development area and roughly 200m from the proposed concrete plant itself. Views from within the conservation area are dominated to the north by the ‘Cricklewood Curve’ railway embankment, plus modern developments and new acoustic barrier.
Acknowledging that the Conservation Area itself forms an ‘island’ within an otherwise busy urban setting, the assessment concludes that the concrete plant would have no adverse impact on the character or appearance of the conservation area. It states that the proposed development would not change the setting, nor would it introduce an industrial use that would have any adverse effect on the area. The overall effect of the proposal would be neutral from a Heritage perspective.