QUESTIONS AND ANSWERS
Here are some of the more common questions we are being asked about our proposal. If you have a question which isn’t answered below then please contact us and we will endeavour to respond promptly. We will periodically add further questions and answers to the list below:
WHY IS THIS SITE USED FOR INDUSTRIAL FREIGHT?
Cricklewood Rail Freight Facility (RFF) is one of a limited number of sites across London suitable for handling bulk materials due to its location, size and links to main rail and road networks. It is a safeguarded rail site for freight use, and any change of use is restricted. As the London Plan highlights, such sites are protected as they are essential to the city’s success and international competitiveness.
In addition, the site is identified as a rail freight terminal in the Brent Cross masterplan as it will be essential to support local construction and commerce. With the need for redevelopment – and the air quality benefits of rail over road transport – the need to use rail sites like Cricklewood for freight is more important than ever.
London needs a reliable supply of aggregates and concrete to support its continued growth and improvement. The capital uses about 10 million tonnes of sand, gravel, rock and recycled aggregates every year, most of which is used in concrete. Without this material, many of the city’s iconic landmarks of recent decades would not exist, and the development of London would be restricted.
WHY IS A CONCRETE PLANT PROPOSED AT CRICKLEWOOD?
Concrete is essential for construction and it requires ‘batching’ plants to be as close as possible to building sites where the concrete is needed. Once mixed, concrete must be used within a couple of hours and, in a busy city like London, can only travel a short distance. An area of major redevelopment like Brent Cross will need large volumes of concrete for construction. Road miles and emissions from meeting this demand are far lower if the concrete is produced locally on a rail-fed source.
Cricklewood Rail Freight Facility (RFF) is particularly suited to supporting London’s construction supply chain because of its proximity to rail and road networks. Locating a concrete plant at Cricklewood RFF means that aggregates required to make concrete would be delivered by rail (rather than road) which helps to minimise vehicle movements, congestion and emissions. Our proposal for a concrete plant at Cricklewood RFF would result in fewer HGV movements and miles to meet the local demand for concrete.
Until February 2021, Capital Concrete operated a concrete plant at Brent Terrace, across the railway line (behind Brent Cross retail park), which has supplied the local market for many years supporting new development in the area. This site was forced to close as a result of a Compulsory Purchase Order to make way for the redevelopment of Brent Cross.
Consequently, the local demand for ready-mixed concrete is now having to be met from plants elsewhere in London, resulting in significantly more HGVs travelling over longer distances as well as a corresponding increase in congestion and emissions. This could be and would be minimised by locating a concrete plant at Cricklewood Rail Freight Facility.
The proposed concrete plant at Cricklewood therefore directly aligns with the strategic policies of both the London Plan and local plan by maintaining the rail-related use of the site. The proposal would fulfil a vital role supplying concrete to meet regeneration, infrastructure and housing needs in North London, rather than such developments being supplied by concrete plants reliant on road delivered aggregates.
WHAT IS THE BENEFIT OF RAIL OVER ROAD TRANSPORT?
Each train delivery keeps between 75 and 85 lorries off the roads (depending on the length of train, lorry and material) and rail freight is proven to have on average 76% lower carbon emissions than the equivalent road journeys. Particulate emissions from rail transport are 90% lower than the equivalent road journey.
Therefore, a plant at Cricklewood Rail Freight Facility is far more preferable to one which requires aggregates to be delivered by road. Cricklewood RFF occupies a key location in north west London, allowing the use of the railway network to bring in the construction materials required for the continued regeneration of this area.
WHY DO WE NEED ANOTHER CONCRETE PLANT IN THE AREA?
The proposed concrete plant would be a replacement for our existing plant just across the railway line on Brent Terrace (behind the retail park) which has supplied local construction for many years. This current site is required to close by Barnet Council as part of the redevelopment of Brent Cross and will cease to operate in the near future. Unlike the current site, the proposed new site has the advantage of being rail-linked which will significantly reduce the number of vehicle movements and miles on local roads. We strongly believe that this is a good thing for the local area.
HOW MANY LORRY MOVEMENTS WOULD THERE BE WITH THE PROPOSAL?
We understand that lorry movements are an area of concern and so careful consideration has been given to vehicles moving to and from the proposed plant. The existing planning permission for operating the site (DB Cargo) has a strict cap on total vehicle movements and our proposed concrete plant would mean no additional vehicle movements above what is currently approved.
The concrete plant proposal would work within these existing agreed limits and will not add any additional vehicle movements to the local road network. If the concrete plant were not located at the Cricklewood RFF then aggregates would be imported into the RFF by rail and distributed by road to other concrete plants within the local area, resulting in a net increase in road movements in comparison to an on-site rail-fed concrete plant.
Because this site is rail linked, overall vehicle movements in the area would be reduced because we would be replacing a concrete plant which is supplied with aggregates by road (near Brent Cross) with one which is supplied by rail. Rail-linked sites in London are already helping to keep thousands of lorry movements off the roads, and both Central Government and London planning policies are seeking to increase the use of rail freight in London.
WHAT MEASURES ARE PROPOSED TO IMPROVE HIGHWAY SAFETY?
The previously approved planning permission for the site (DB Cargo) enabled highway upgrades to be made at the entrance to the site, improving site access and safety for all road users and pedestrians. Given that no additional vehicle movements are proposed beyond those already consented, the recent improvements will allow safe use of the junction.
HOW WILL YOU ENSURE LORRIES ARE OPERATING SAFELY?
The recently approved planning permission for the site (DB Cargo) includes a site management plan requiring all activities to meet the highest standards, including tight controls on HGVs and their drivers. Capital Concrete is also accredited by the Fleet Operator Recognition Scheme (FORS) and operates to the FORS Silver standard. This requires high levels of best practice in safe, sustainable transport both for vehicles and drivers.
Additionally, the company is a ‘CLOCS Champion’ (Construction Logistics & Community Safety Scheme) which require us to take additional responsibilities for the health and safety of vulnerable road users – such as pedestrians, cyclists and motorcyclists – when our vehicles are out on the roads.
WHAT MEASURES ARE PROPOSED TO CONTROL DUST?
Air quality is an area of particular attention. We are determined to keep fine material in check, not least because of the importance we place on the health and safety of our own workforce based on our sites every day.
The proposed concrete plant would be highly advanced and feature numerous environmental controls to keep fine materials such as cement powder well contained within the system. These controls would be in addition to significant containment and mitigation measures that have been built into the management plan for the existing site, including a rigorous and independent dust monitoring regime in line with national standards and with compliance thresholds agreed with the local authority. Our proposed activity would operate within those same limits.
Assessments carried out by air quality consultants show there would be no impact on air quality. Furthermore, all activities would be subject to an Environmental Permit which would set out the conditions with which the proposed development must comply. In the unlikely event that operations did not comply with the air quality standards, the authorities could revoke the permit and stop operations.
Full details of the air quality assessment can be found within the planning application documents on the London Borough of Barnet planning pages:
View the planning application.
See also question regarding emissions.
WHAT MEASURES ARE PROPOSED TO CONTROL EMISSIONS?
The production of ready-mixed concrete itself produces no emissions as the process is electrically powered and involves the mixing of aggregates and cement with water in an enclosed chamber.
By bringing aggregates into London by train – directly to a ‘rail-fed’ concrete plant – truck movements would be minimised. Every train which brings aggregates into London by rail keeps between 75 and 85 lorries off the roads (depending on the type of train, lorry and material), reducing congestion and helping to improve air quality. Movement of freight by rail helps to reduce emissions and is a net air quality benefit compared to road transport.
In addition, the concrete delivery lorries we’re proposing to use are the cleanest available with ‘Euro 6’ engines already approved for ULEZ (Ultra Low Emission Zones) and the total vehicle movements would be capped to already agreed levels. This, combined with reduced vehicle movements and miles, means our proposals would lead to a net reduction in emissions and an improvement in air quality. Under the agreed DB Cargo site management plan for the whole site air quality will be closely monitored and we are confident that we can demonstrate that there are no unacceptable air quality impacts as a result of the proposed operations.
WHAT MEASURES ARE PROPOSED TO CONTROL NOISE?
Ahead of the submission of the planning application, in addition to the noise modeling that took place as part of the original RFF planning application in 2017, further noise modeling has been carried out by specialist consultants at a concrete plant similar to that proposed at Cricklewood RFF.
The conclusion of the noise assessment, after taking the local context into account, is that the proposed operations represent a low noise impact. This is due in part to the design of the existing site plus the additional mitigation measures incorporated into the concrete plant proposal itself.
We can confirm that plant and equipment would be designed to minimise noise and we would be fully compliant with the standards set out in the site management plan that has been agreed as part of the planning permission for the site (DB Cargo). The design of the concrete plant itself incorporates noise reduction considerations at every stage of the process.
Full details of the noise assessment can be found within the planning application documents on the London Borough of Barnet planning pages:
View the planning application
WHAT WOULD BE THE VISUAL IMPACT OF THE CONCRETE PLANT?
Our proposals are designed to have little or no visual impact from an external perspective. The tallest parts of the proposed plant (the silos) would not be particularly visible from external viewpoints and would not be seen at all from street level on Edgeware Road. From the neighbouring properties to the southeast the plant would largely be hidden behind landscaping/screening at the perimeter of the site.
The proposed plant has been located on the plot to minimise visual impact from the southeast and it is relatively far into the site from the northwesterly direction. Across the tracks to the northeast, the site is largely hidden by trees and shrubs along Brent Terrace. The design has been modified to take on board comments about particular viewpoints and to minimise the visual impact of the proposals. We explain this fully in our planning application.
For more information visit the Landscape & Visual Impact section of Our Proposal
HOW WILL THE IMPACT OF LIGHTING BE ADDRESSED?
All night-time lighting would be of the same type as that approved for use on the site as set out in the existing planning permission. Lighting would be designed to minimise and mitigate the impact of light on the surrounding properties. Operating hours will be restricted to the currently consented hours, so no activity is proposed between 7pm and 7am.
HOW WOULD CONCERNS AND COMPLAINTS BE HANDLED?
Any concerns about the site would be handled as set out in the existing site management plan. Any reported issues would be investigated promptly and action taken where necessary. Our intention is to maintain a high standard for the way this site is operated and build a positive and open relationship with our neighbours where any issues can be easily discussed and quickly addressed.
WHAT ARE THE PROPOSED WORKING HOURS OF THE SITE?
The proposed concrete plant would operate within the agreed hours for the wider DB Cargo site, from 7am until 7pm on weekdays (and Saturdays between 7am and 2pm when required by local demand). No concrete would be produced outside these times. There would be no concrete batching activity on Sundays and Public Holidays.
WHAT IS THE DIFFERENCE BETWEEN CONCRETE AND CEMENT?
Concrete is the world’s most versatile and popular building material, essential for building homes, schools and hospitals, places of work and leisure, transport networks, and power and water systems. Concrete is made by mixing aggregates, cement and water, plus ‘admixtures’ which control the characteristics of the mix and its setting time. Concrete has been used since Roman times for constructing homes and public infrastructure.
As building heights have increased in London and cities around the world, the use of concrete is becoming ever more important – most buildings, and tall ones in particular, cannot currently be constructed without concrete. Concrete is essential to delivering the housing growth and regeneration for London and particularly for areas of intense redevelopment like that proposed at Brent Cross.
Concrete plants are relatively modest in size and there are many hundreds of them across the UK. It’s here that concrete is mixed then loaded into lorries (which most people call ‘cement mixers’). It is then delivered to site where it is poured or pumped and ‘goes off’ (or cures) in situ. Ready-mixed concrete must be poured as quickly as possible to prevent it setting in transit – that is the reason readymix plants need to be close to where the concrete is needed. Concrete generally travels less than 3 miles in London.
Cement is a fine grey powder and just one ingredient in concrete. Cement is usually made in large industrial plants – usually in rural locations – by blending limestone and shale (clay) at high temperature to form ‘clinker’ which is then ground into a fine powder. There are just a dozen cement plants in the whole of the UK and as a country, we also import some cement from overseas. The UK cement industry has pioneered many innovations to reduce the carbon footprint of cement manufacture and a number of cement producers have recently made commitments to become carbon neutral by 2050.
CONCRETE IS BAD FOR THE CLIMATE, ISN’T IT?
Whilst there is a negative perception of concrete because of the embodied CO2 from the manufacture of cement, no other product can match concrete for performance, versatility and availability. In fact, research shows there is little or no difference in environmental performance between concrete and other structural materials over the lifetime of a building. And concrete, unlike other structural products, is also indigenous, made almost entirely with ingredients sourced and produced in the UK.
Advances are being made in concrete design and cement manufacture which mean that the environmental impact of concrete is reducing. This includes the use of cement alternatives in new highly technical concrete mix designs. Capital Concrete would offer lower CO2 cement and cement-free concrete options to its customers from the proposed development at Cricklewood RFF. (See recent news on www.brett.co.uk)
Also, concrete has inherent thermal mass properties which means it has a cooling effect in hot weather and an insulating effect in cold conditions. It is therefore proven to outperform other materials in buildings where thermal mass is designed as part of the cooling system. Because less energy is needed for heating and cooling in concrete buildings, any additional embodied carbon from its manufacture can be offset many times over.
WHAT WOULD HAPPEN TO THE SITE IF A CONCRETE PLANT ISN’T BUILT?
The site already has planning consent as a rail depot for handling aggregate and waste spoil from local construction sites. If a concrete plant wasn’t built at Cricklewood RFF then a lot more of the space would be used for the storage of loose aggregates.
In addition, Capital Concrete would then have to find another location for its replacement concrete plant in the area but this would almost certainly supplied with aggregates by road and would inevitably mean more truck movements and road miles would be generated in meeting the demand for concrete in the local area.
WHO HAS BEEN CONSULTED REGARDING THE PROPOSALS?
Our planning application follows local public consultation from June to August 2020. This was adapted in accordance with Government guidance relating to the coronavirus pandemic. Besides this website and direct email correspondence with local representatives and neighbourhood groups, we conducted a door-to-door maildrop to 700 addresses around the site. We have held a number of online video consultation sessions and socially-distanced site visits to one of our other concrete plants in North London.
The feedback we received during the consultation led to a number of changes to our original proposal. In particular, this includes redesigning the plant layout to enable the height of the cement silos to be reduced and improve the overall look of the site from external viewpoints. We submitted our planning application at the start of October 2020. You can view the planning application (reference 20/4817/FUL) by searching on the planning page of the London Borough of Barnet where you can also make comments. Whilst our planning application is being determined, we continue to welcome questions so please do get in contact us by email.
HOW DOES THE PROPOSAL FIT WITH THE LONDON PLAN?
The London Plan sets out ambitious targets for Housing (Chapter 4), Social Infrastructure (Chapter 5) and Sustainable Infrastructure (Chapter 9) for which large volumes of aggregate and concrete will be required. It also states the clear policy to move essential construction freight off the road and onto the rail network to cut congestion and reduce lorry miles on London’s roads (Chapter 10). Our proposal provides solutions in all of these areas in the most sustainable way possible.
The site has a special designation in the London Plan as a strategic rail freight site. This means its use as an important industrial site is protected; any change of use is restricted and bound by legislation and contractual agreements. As the London Plan highlights, freight sites are given protection because of their importance to London’s logistics system and infrastructure which are essential to the city’s success.
The proposed development aligns with the strategic policies of the London Plan by maintaining the rail-related industrial use of the site. The proposed development would fulfil a vital role of supplying concrete to infrastructure and housing developments in East London.
WHO ARE THE COMPANIES INVOLVED?
Capital Concrete is a joint venture company owned by its management team, Brett Group, along with Breedon Group. Brett and Breedon are well-established British businesses with long track records of responsible operation. Capital Concrete was formed by Brett in 2018 to include its concrete activities within London and to provide a focus for the business on the London area.
Representatives of Capital Concrete are working with DB Cargo to optimise the development of the rail freight facility to meet the local need for construction materials. Under our proposals, DB Cargo would continue to run train loading and unloading operations at the site and the overall activity at the site would be capped at the level the site can operate at today under the existing permissions.