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Response to Cricklewood Railway land for the transportation of aggregates by rail planning application.

400 Cricklewood Railway Yard, Land At Rear Of 400 Edgware Road Edgware Road Cricklewood NW2 6ND London NW2 6ND

Ref. No: 17/5761/EIA | Status: Pending Consideration

Freight on Rail thanks Barnet Council for the opportunity to comment.

Freight on Rail, a partnership of the rail freight industry, the transport trade unions and Campaign for Better Transport, works to promote the economic, social and environmental benefits of rail freight to local, devolved and central Government.

Freight on Rail fully supports theCricklewood aggregates terminal proposal on the following key grounds:-

  1. Rail offers a safer cleaner low carbon solution to transporting aggregates into London and for removing waste which reduces road congestion significantly. Broadly each train saves about 85 HGV trips.
  2. These are designated operational railway lands which have been safeguarded for railfreight  purposes in the Barnet UDP for many years, which has both good rail and road connections. Adopted UDP 12.3.24

    “The site presents strategic opportunities for maintaining and increasing rail freight to serve North London and improving links to London’s airports. It is essential that this resource makes a positivecontribution to the regeneration of the area. Rail freight should be taken into account in the waythat employment land is developed, while ensuring that the adverse effects of noise pollution aremitigated. The freight facility will bring significant environmental benefits to the borough, Londonand beyond, by reducing the number of lorries on the road. The Department for Transport will bean important consultee to ensure rail freight facilities are developed satisfactorily.”
  3. The fact that there are very few suitable alternative sites where aggregates can be brought into London for use in construction projects must be taken into account. If this terminal is not built, the construction materials will be transported by HGVs instead with much greater air, CO2 pollution as well as road congestion and potential road collisions.
  4. The wider socio-economic benefits to London, the South-east and the country as a whole need to be factored into the decision as stated in the National Planning Policy Framework of 2012.
  5. This strategic location which is essential to the £4.5 billion Brent Cross re-generation  where between 7000 – 8000 apartments are to be built with materials carried by rail to the terminal.  Without the rail terminal, building this scale of housing would not be viable as all these construction materials would have to be delivered by HGV.. This terminal needs to be considered in terms of the national, regional and local commitment and policy to build more housing, taking into account the fact that the housing development will have good passenger rail connections for the residents.
  6. Congestion Benefits of rail freight-
    There will be three trains in and out of Cricklewood terminal Monday to Friday. Each aggregates freight train to and from Cricklewood rail terminal can remove up to 85 HGVs from congested strategic roads as 1,700 tonnes will be carried on each train. Infact, each train can transport enough materials to build 30 houses, according to the Mineral Products Association.
  7. The maximum truck movements a day will be 452 in and out of the terminal.
  8. Hours of operation will be limited to 7am to 7pm Monday to Friday and &am to 1.00pm Saturdays. There are no operational time limitations at present for the site.
  9. The facility has been designed to the latest standards in terms of noise amelioration, fencing and screening to minimise any adverse impacts on its neighbours.
  10. Rail freight is tried and tested in the capital with demand for more rail services. Almost 50 per cent of London’s aggregates are now moved by rail, combining limestone and granite with sea-dredged sand and gravel and specialist materials such as gritstone. As well as bringing in materials in a sustainable way, rail will be used to remove construction waste.

    Rail was part of the logistics solution for CrossRail where materials were delivered by rail and spoil removed by rail. Similarly, rail was used during the construction of the Olympics to and from DB Cargo’s Bow East site.
  11. In line with Government Policy

    The Department for Transport Rail Freight Strategy of 2016 stated its support for expanding rail freight services.

    DfT quote states shifting freight from road to rail can result in significant CHG emission savings as well as economic and safety co-benefits 1.

    National Planning Policy Framework 2012 Page 9 paragraph 31-
    Local authorities should work with neighbouring authorities and transport
    providers to develop strategies for the provision of viable infrastructure necessary to support sustainable development, including large scale facilities such as rail freight interchanges

  12. Draft London Plan issued in November 2017, for consultation, strongly makes the economic, safety and environmental case for increasing the use of rail freight and gives direction to London boroughs to this effect.
    Freight Transport Policy

    C Wharves and railheads involved in the distribution of aggregates should be safeguarded in line with Policy SI9 Safeguarded waste sites, Policy SI10 Aggregates and Policy SI5 Water infrastructure.
    D Consolidation and distribution sites at all scales should be designed to enable 24-hour operation to encourage and support out-of-peak deliveries.

    E Development proposals for new consolidation and distribution facilities should be supported provided that they:
    1) deliver mode shift from road to rail or water without adversely impacting passenger services (existing or planned) and without generating significant increases in street-based movements
    2) reduce traffic volumes within London
    3) reduce emissions from freight and servicing trips
    4) enable sustainable last-mile movements, including by cycle and electric vehicle.

    F Development proposals should facilitate sustainable freight and servicing, including through the provision of adequate space for servicing and deliveries off-street. Construction Logistics Plans and Delivery and Servicing Plans will be required and should be developed in accordance with Transport for London guidance and in a way which reflects the scale and complexities of developments.

    G Developments should be designed and managed so that deliveries can be received outside of peak hours and in the evening or night time. Appropriate facilities are required to minimise additional freight trips arising from missed deliveries and thus facilitate efficient online retailing.

    H At large developments, facilities to enable micro-consolidation should be provided, with management arrangements set out in Delivery and Servicing Plans.

    I Development proposals must adopt appropriate construction site design standards to enable the use of safer, lower trucks with increased levels of direct vision on waste and landfill sites, tip sites, transfer stations and construction sites.

    Supporting Text

    When planning freight movements, development proposals should demonstrate through Construction Logistics Plans and Delivery and Servicing Plans that all reasonable endeavours have been taken towards the use of non-road vehicle modes. Where rail and water freight facilities are available, Transport for London’s freight tools should be used when developing the site’s freight strategy.

    Transport for London’s guidance on Construction Logistics and Delivery and Servicing Plans should be adhered to when preparing planning applications. Plans should be developed in line with this guidance and adopt the latest standards around safety and environmental performance of vehicles. The plans should be monitored and managed throughout the construction and operational phases of the development. TfL’s freight tools including CLOCS (Construction Logistics and Community Safety) should be utilised to plan for and monitor site conditions to enable the use of vehicles with improved levels of direct vision. This should be demonstrated through a Site Assessment within a Construction Logistics Plan. Development proposals should demonstrate ‘good’ on-site ground conditions ratings or the mechanisms to reach this level.

    Aggregates Policy
    An adequate supply of aggregates to support construction in London will be achieved by:1) encouraging re-use and recycling of construction, demolition and excavation  waste within London
    2) extracting land-won aggregates within London
    3) importing aggregates to London by sustainable transport modes
    4) meeting the target of 95 per cent recycling/re-use of construction, demolition and excavation waste by 2020 and recycling 50 per cent of that waste as aggregates by 2020

    Development Plans should make provision for the maintenance of a landbank (i.e. seven years’ supply) of at least five million tonnes of land-won aggregates up to 2041, in particular through a landbank apportionment of:1) at least 1.75 mt to London Borough of Havering
    2) at least 0.7 mt to London Borough of Redbridge
    3) at least 1.75 mt to London Borough of Hillingdon
    4) at least 0.7 mt to London Borough of Hounslow.

    All Mineral Planning Authorities in London should identify and safeguard aggregate resources in Development Plans, including aggregate recycling facilities.

    To reduce the environmental impact of aggregates, Development Plans should:
    1) ensure that appropriate use is made of planning conditions dealing with aftercare, restoration and re-use of minerals sites following extraction, with particular emphasis on promoting green infrastructure, especially biodiversity

    2) safeguard wharves and/or railheads with existing or potential capacity for aggregate distribution and/or processing to minimise

    9.10.1 London needs a reliable supply of construction materials to support continued growth. National planning policy requires Mineral Planning Authorities to maintain a steady and adequate supply of aggregates. These include land-won sand and gravel, crushed rock, marine sand and gravel, and recycled materials. Most aggregates used in the capital come from outside London, including marine sand and gravel and land-won aggregates, principally crushed rock from other regions. There are relatively small resources of workable land-won sand and gravel in London.

    9.10.2 A realistic landbank figure (i.e. seven years’ supply) of at least 5 million tonnes of land-won aggregates for London throughout the Plan period has been apportioned to boroughs as set out in the policy above. There remains some potential for extraction beyond the four boroughs identified in Policy SI10 Aggregates, including within the Lee Valley, and boroughs with aggregates resources should consider extraction opportunities.

    9.10.3 Aggregates are bulky materials so Development Plans should maximise their use and re-use and minimise their movement, especially by road. The objective of proximity dictates the best and most local use of materials that can be extracted in London. The re-use/recycling of building materials and aggregates is a significant and well established component of the circular economy advocated in Policy SI7 Reducing waste and supporting the circular economy and reduces the demand for natural materials.

    9.10.4 Boroughs should protect existing, planned and potential sites for aggregate extraction and transportation. Existing and future wharf capacity is essential, especially for transporting marine-dredged aggregates, and should be protected in accordance with Policy SI15 Water transport. Equally important are railway depots for importing crushed rock from other parts of the UK. Railheads are vital to the sustainable movement of aggregates and boroughs should protect them.

    9.10.5 Sites for depots may be particularly appropriate in preferred industrial locations and other employment areas. Boroughs should examine the feasibility of using quarries as CD&E recycling sites once mineral extraction has finished.

  13. Job creation and re-generation benefits of aggregates terminals

    24 full time jobs at the terminal with additional jobs for drivers to and from the facility and further indirect employment locally. 
  14. Road Freight is a big CO2 emitter

    There is a significant opportunity to reduce transport emissions by shifting freight from road vehicles to rail. In total, road freight (Heavy Goods Vehicles and light vans) was responsible for one third of total greenhouse gas emissions from transport in 2015. Source EIS (2017) ‘Final UK greenhouse gas emissions national statistics: 1990-2015

    As rail freight produces 76% less CO2 emissions than the equivalent HGV journey, increasing rail freight is an important part of the DfT’s policy to reduce freight’s emissions and help the UK meet its legally binding Climate Change targets. Source DfT Rail Freight Strategy September 2016

    HGVs contribute 17 per cent of surface access CO2 emissions, despite making up only 5 per cent of road vehicles whereas both passenger and freight rail together are less than 2 per cent. Source DfT Rail Freight Strategy September 2016

    Energy efficiency is directly related to carbon dioxide emissions, rail is significantly more energy efficient than other modes with the exception of shipping. A tonne of goods can travel 246 miles by rail as opposed to 88 miles by road on a gallon of fuel 
    Source Network Rail Value of Freight July 2010.

    While electric technology means car and van emissions can be reduced significantly, the DfT has stated that it expects the existing technology to be predominant well into the next decade.
  15. Air quality benefits of rail freight

    Rail freight can be part of the solution to reduce air pollution. Currently, 40,000 people die prematurely in the UK from diesel fumes wide-spread air quality violations, especially in cities like London and Manchester which are already exceeding their NOX emissions limits.
    Rail produces 90 per cent less PM10 particulates and up to 15 times less nitrogen dioxide emissions than HGVs for the equivalent journey. Highways England figures show that HGVs are producing around 50% of the nitrogen oxide pollution from road pollution on the strategic road network even though they only make up 5 per cent of road miles driven in the UK.

    HGVs account for around 21% of road transport NOx emissions while making up just 5% of vehicle miles – DfT Freight Carbon Review February 2017.

    Non exhaust particulates from HGVs will remain a big problem with HGVs

    While the latest euro VI engines have reduced NOx emissions from truck engines considerably around 60 per cent of particulates come from non-exhaust emissions from brakes and tyres for which there is no current solution.

    Freight Transport: Average emissions in grams per tonne-kilometre



















    PM10 particulate matter of less than 10 microns;
    CO carbon monoxide;
    NOx oxides of nitrogen;
    CO2 emissions
    VOC volatile organic compounds.  Source RSSB 2007

  16. Noise Pollution
    Far fewer people negatively impacted by rail noise than road noise.
    DfT stats: only around 40,000 people are impacted by rail noise, but around 700,000 people are impacted by road noise.
  17. The safety case for rail

    Rail freight is also far safer than HGVs which are almost seven times more likely than cars to be involved in fatal crashed on local roads. Source: Traffic statistics table TRA0104, Accident statistics Table RAS 30017, both DfT

    This graph shows HGV involvement rate in fatal crashes on different road types over the past ten years, where conditions are very different, based on the percentage of miles they represent.

    Graph showing Involvement in fatalities - HGVs iver 3.5 tonnes compared to all traffic

    We believe that there should be a healthy streets approach to the local area with protected cycle lanes and safer junctions and crossings for pedestrians as part of the project.

    DfT analysis of costs of fatal collisions in 2015

    Department for Transport statistics

    Average value of prevention1 of reported road accidents2 by road type:


    GB 2015


    Accident Type

    Built-up roads3

    Non Built-up roads4


    All Roads










    ll Roads






  18. Reduction in road infrastructure costs

    Rail freight also reduces the road infrastructure costs for local, devolved and central Government as the standard 44 tonne 6 axle 16.5 metre HGV because of their weight are 138,000 times more damaging than a Ford Focus to road infrastructure. Source 4th power Law


1. DfT Freight Carbon Review February 2017. P43 Key messages

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