FREQUENTLY ASKED QUESTIONS
WHY IS INDUSTRIAL ACTIVITY STILL TAKING PLACE AT BOW EAST?
The strategic significance of Bow East as a rail freight site has long been recognised. The site has a special designation in the London Plan as ‘Strategic Industrial Location’ (SIL). This means its current use is protected; any change of use is restricted and bound by legislation and contractual agreements. As the London Plan highlights, SILs are given protection because of their importance to London’s logistics system and infrastructure – these are essential to the city’s success and international competitiveness. With increasing pressures to build residential accommodation, and the air quality benefits of rail over road transport, if anything the need to use Bow East for rail freight is more important than ever.
Further protection of the industrial status of Bow East is set out within the London Legacy Development Corporation (LLDC) Local Plan. This identifies Bow East as a SIL with a safeguarded rail head and associated bulk freight distribution uses. It states that appropriate land uses are general industrial (B2), storage and distribution (B8) including open air storage, and waste management. It also identifies aggregate handling and concrete manufacture as suitable uses, and explains that only rail-related developments and associated ancillary uses will be supported.
The proposed concrete plant development at Bow East directly aligns with the strategic policies of both the London Plan and Local Plan by maintaining the rail related industrial use of the site. The proposal would fulfil a vital role supplying concrete to meet infrastructure and housing needs in East London, rather than new developments being supplied by concrete plants reliant on road delivered aggregates.
See also question about the London Plan and Legacy Vision.
2. WHY IS A CONCRETE PLANT PROPOSED HERE?
Bow East is of particular importance to London’s construction supply chain. London needs a reliable supply of bulk materials to support its continued growth and improvement. The capital uses approximately 10 million tonnes of sand, gravel, crushed rock and recycled aggregates every year, the majority of which is used to make concrete. Without this material, the development and growth of London would become restricted and many of the city’s new iconic landmarks would not exist.
Concrete is essential for construction. The nature of ready-mixed concrete requires ‘batching’ plants to be as close as possible close to building sites where the concrete is needed. There are currently gaps in the market which today have to be supplied from further afield, or from sites that are not rail linked, requiring more vehicle movements on local roads and longer journeys.
Each train delivery keeps around 75 lorries off the roads, so a plant at Bow East is preferable to a plant which requires aggregates to be delivered by road. Bow East occupies a unique location in central east London, allowing the use of the railway to bring in the construction materials required for the continued regeneration of this area. There are no other suitable or available rail sidings in this area which could be used for this purpose, and no scope to create new ones.
WHY DO WE NEED ANOTHER CONCRETE PLANT?
It is common – in fact preferable – to have concrete plants on rail-linked sites like Bow to meet local demand while minimising vehicle movements. There are currently gaps in the market which today have to be supplied from further afield, or from sites that are not rail linked, requiring more overall vehicle movements and longer journeys.
Of the nine operational concrete plants in central east London, seven have the majority of their aggregates supplied by road. Our proposals at Bow East would mean such aggregate deliveries would be taken off the road and instead concrete could be made with aggregates supplied by rail. This would reduce road journeys and congestion on local roads, with an overall reduction in emissions. If a concrete plant were to be opened at Bow East it is envisaged that activity at sites that are not rail linked would reduce.
Each train delivery keeps up to 76 lorries off the roads, so a plant at Bow East is preferable to a plant which requires aggregates to be delivered by road. Bow East occupies a unique location in central east London, allowing the use of the railway to bring in the construction materials required for the continued regeneration of this area.
HOW MANY LORRY MOVEMENTS WOULD THERE BE?
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. Under the new proposals the total number of vehicle movements per day would be limited to an average of 528 (that’s 264 deliveries plus return journeys). This is a big reduction compared with current activities which have the capacity to generate an average 800 HGV movements per day with no upper limit. (Note that the current vehicle movements are outside the control of the joint venture partners).
This limit would include all truck movements to and from the site whether they are linked to the proposed concrete plant or other deliveries to and from the site. This would provide certainty and control over transport, taking into consideration environmental factors. Rail-linked sites in London are already helping to keep thousands of lorry movements off the roads.
WHAT ROAD(S) WOULD LORRIES USE TO ACCESS THE SITE?
There are two possible road access points to Bow East – the current access at the eastern end of the site (Marshgate Lane) and a second access through Bow West at the western side of the site (Wick Lane).
Our initial proposal was to use Marshgate Lane for the first few years (with a series of highway upgrades to improve road safety) and then switch to Wick Lane in the longer term (after existing lease agreements on Bow West have expired). In this case Marshgate Lane would only be used for employees’ cars and local deliveries. Wick Lane is seen by some as a more suitable access point because it offers immediate access to the main A12 dual carriageway and would therefore mean HGVs and other road users sharing a much smaller stretch of road (compared to Marshgate Lane). However, following concerns expressed during the consultation so far about the use of Wick Lane, we have continued discussions with a number of parties to review this thinking and Marshgate Lane is looking like the preferred option for access.
We are also undertaking a comprehensive transport assessment as part of our proposals which will review existing traffic, potential future traffic and traffic capacity at key points.
WHAT MEASURES ARE PROPOSED TO IMPROVE HIGHWAY SAFETY?
We are committed to upgrading the access on Marshgate Lane and we will work with the highways authorities to agree suitable designs with additional features which will improve safety for all road users and pedestrians.
A number of options have been explored, including a footbridge that would link the footpath coming from Puddling Mill Lane station up onto The Greenway. The footbridge has been rejected during the course of our consultation, but we have designed a signalised junction which will help to keep people and cyclists safe on Marshgate Lane.
HOW WILL YOU ENSURE LORRIES ARE OPERATING SAFELY?
If the proposed development at Bow East was to be approved there would be tight controls on HGVs and their drivers, and all activities relating to the site would have to meet the highest standards. The joint venture partners are all Fleet Operator Recognition Scheme (FORS) accredited and operate to the FORS Silver standard as a minimum. All the lorries operated by the joint venture would be FORS compliant, which requires high levels of best practice in safe, sustainable transport both for vehicles and drivers.
Additionally, the three businesses are Construction Logistics & Community Safety (CLOCS) ‘Champions’ which require them to take additional responsibilities for the health and safety of vulnerable road users – such as pedestrians, cyclists and motorcyclists – beyond their sites. In any cases where there is cause for concern, under our proposal it will be quick and easy to report issues either by phone or email, with clear accountability on site to take action to address concerns.
WHAT MEASURES ARE PROPOSED TO CONTROL DUST?
Air quality is an area of particular attention, partly because we recognise it’s a major concern in this part of London, but also because of the importance we place on the health of our own people who work on our sites day-in, day-out.
For this reason, numerous additional measures are proposed to control air quality through (1) containment within walls and enclosures; (2) suppression systems that prevent material becoming airborne; and (3) a rigorous management regime to maintain a clean site.
For example the proposed design includes enclosures to inhibit the breeze (and thus ‘wind whip’) across stored materials. Rainwater would be ‘harvested’ for use in an automatic spray system to dampen stored materials and operating areas to prevent dust generation. Mains water would be used only if insufficient rainwater can be harvested. Within the plant itself, finer material that could become airborne would be contained or filtered. For example, cement powder would be stored in sealed silos with advanced filters delivering greater control and containment than older systems.
A comprehensive air quality assessment is being undertaken as part of the planning application. This considers fully any impact of the proposal on air quality in the area. We are proposing to undertake extensive ongoing air quality monitoring at multiple points within and around the site to ensure and to demonstrate that site activities do not lead to unacceptable air quality.
The proposed operation of the concrete batching plant would be subject to an Environmental Permit which would fully assess air quality. Once issued, the permit would set out the conditions which the proposed development must comply with. If the proposed operations did not comply with the air quality standards as set out in the conditions, the authorities could revoke the permit and cease operations.
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 up to 76 trucks off the road, reducing congestion and helping to improve air quality. Movement of freight by rail reduces emissions and is a net air quality benefit.
In addition, the delivery vehicles we’re proposing to use are the cleanest available vehicles with ‘Euro 6’ engines already approved for ULEZ (Ultra Low Emission Zones) which is not the case today. Furthermore, the total vehicle movements would be capped and therefore lower than current activities or previous proposals. Our proposals would lead to a net reduction in emissions and an improvement in air quality.
WHAT MEASURES ARE PROPOSED TO CONTROL NOISE?
The proposed layout puts the concrete batching plant at the southern end of the site near the Great Eastern mainline viaduct, so as far away as possible from neighbouring residential areas. In addition, we are looking into noise reductions at every stage of the process, although it is not possible to eliminate all noise.
Operating hours of the concrete batching plant would be limited to Monday to Friday between 7am and 7pm (and Saturdays between 7am and 1pm when required). There would be no concrete batching plant operations on Sundays and Public Holidays.
The current rail unloading activity is carried out by DB Cargo under ‘permitted development’ and is not part of our planning application, so it is expected to remain as per the existing operations on site – 24 hours per day, 7 days per week when necessary. However, in the interests of minimising night-time noise, whenever possible, trains would be scheduled to unload between 7am and 8pm. However some loading/unloading outside of these hours is unavoidable, as the activity must fit within the available rail freight paths on the network.
In addition, the amount of material imported to the site would be limited to 1.15 million tonnes per year, a big reduction in capacity compared to current operations, and the loading and unloading of trains would therefore be reduced, including at night.
A noise assessment is being undertaken as part of this planning application and will fully consider the noise effects of the proposal on the surrounding area.
HOW WILL THE IMPACT OF LIGHTING BE ADDRESSED?
Although we do not currently operate the site (and have no control over existing lighting) we see our proposal as an opportunity to review lighting and have designed a scheme which takes concerns on board.
A lighting assessment is therefore being carried out as part of our planning application. This contains an analysis of all external lighting within the development area, plans for lighting requirements on the proposed site, and a review of the effect lighting may cause on neighbouring locations.
The assessment includes details of the location, type, number and intensity of the lighting, and the proposed hours when the lighting would be switched on. A sensitively designed lighting scheme which is subject to a full assessment will ensure any effects on neighbouring properties are minimised. We are also proposing the installation of storage bay walls and additional planting at the site perimeter, which could further help to reduce light spread from operations on site.
HOW WOULD CONCERNS AND COMPLAINTS ABOUT THE SITE BE HANDLED?
Under our proposals the entire Bow East site would be operated under a single site management plan with clear accountability and communications channels. This means that questions and concerns would be able to be raised via a single point of contact (via email or phone) and any issues addressed centrally. Every complaint deserves a response, and our management plan will ensure that each complaint is logged, investigated and responded to within a reasonable time.
Our intention is to set a high standard for the way this site is operated and we will look to engage with the communities surrounding the site to build a positive and open relationship where issues can be easily discussed and quickly addressed.
WHAT ARE THE PROPOSED WORKING HOURS OF THE SITE?
The proposed concrete plant would operate from 7am until 7pm on weekdays (and Saturdays between 7am and 1pm when required). No concrete would be produced outside these times. There would be no batching plant operations on Sundays and Public Holidays.
The current rail unloading activity is carried out by separate contractors under ‘permitted development’ and is not part of our planning application, so it is expected to remain as per the existing operations on site – 24 hours per day, 7 days per week when necessary.
However, in the interests of minimising night-time noise, whenever possible trains would be scheduled to unload between 7am and 8pm, although some loading/unloading outside these hours is unavoidable as the activity must fit within the available rail freight paths on the network.
In addition, the amount of material imported to the site would be limited to 1.15 million tonnes per year, a big reduction in capacity compared to current operations, and the loading and unloading of trains would be reduced, including at night.
WHAT ARE THE PROPOSALS FOR IMPROVING THE LANDSCAPING OF THE SITE?
The proposed design of the development incorporates a landscaping scheme which enhances the site and compliments the proposed structures. The design allows for boundary improvements around the perimeter with landscaping to be implemented particularly along the edge of the Greenway.
Another key area of proposed planting would be along the northern side of the proposed concrete plant between the plant and the river. This would offer a degree of visual screening. We are also exploring the potential to use hops plants as one landscaping feature along the northern Greenway boundary, which provides a functional role as well as screening to the planting.
The role of landscaping within the proposed development will be fully set out in the Design and Access Statement which will be produced to support the planning application. Details of the landscape design are also included in the proposed landscaping plans which will also from part of the application.
WHAT IS THE DIFFERENCE BETWEEN PLANTS THAT MAKE CONCRETE AND CEMENT?
Concrete is the world’s most versatile and popular building material, essential for building homes, places of work and leisure, schools and hospitals, 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.
Ready-mixed concrete plants are relatively modest in size and there are hundreds of them in the UK. It’s here that concrete is mixed then loaded into lorries (which some 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’s the reason readymix plants must be located close to where the concrete is needed. Concrete generally travels an average of 3 miles or less in Central London. All high-rise developments require significant quantities of concrete, and much of the concrete being supplied into the developments in the Bow area currently comes from plants with aggregates fed by road. Our proposals will reduce road journeys generated in meeting this demand.
Cement is a fine grey powder which is key ingredient in concrete. Cement is usually made in large industrial plants 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 – usually in rural locations – and as a country we also import cement from overseas. Cement is transported to concrete plants by tankers and stored in silos until it is needed in concrete.
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. Research shows there is little or no difference 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. On this site we have an opportunity to create the concrete plant of the future which uses more sustainable transport (rail) to import more sustainable materials (recycled aggregates / cement substitutes) using renewable energy sources.
(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 forms part of the cooling strategy. Because less energy is needed for heating and cooling in concrete buildings, any additional embodied carbon can be offset many times over.)
WHAT WOULD HAPPEN TO THE LAND NOT USED BY THE CONCRETE PLANT?
The proposed development comprises a concrete batching plant, associated structures and a workspace building on Marshgate Lane. The long-term aspiration is that the remainder (more than half) of the site will be released for other developments through the ‘masterplanning’ process undertaken by the landowner, Network Rail, in cooperation with the London Legacy Development Corporation and the Greater London Authority. This is essentially the area of land which runs along the Greenway. These ‘other developments’ could include a variety of uses which have yet to be determined in the masterplan.
While this process takes place, a number of ‘meanwhile’ uses could be proposed for these areas. In order to comply with the adopted development plan, these small-scale meanwhile uses must be commercial activities which comply with the designation of the land as Strategic Industrial Land (SIL). Such meanwhile uses are, therefore, expected to include business (B1) and non-freight related storage and distribution (B8). These meanwhile uses would not include aggregate freight or bulk rail freight activity.
Should any such interim use of these areas involve the use of HGVs, these would fall within the lorry movement limits applied to the overall site (see question relating to lorry movements) and they would be subject to scrutiny by the appropriate authorities.
WHEN WILL A PLANNING APPLICATION BE SUBMITTED?
We intend to submit a planning application submission in the Autumn of 2019. In the meantime, our pre-planning consultation is ongoing and we are talking to a variety of groups and individuals, refining our proposals in the run up to making our planning application. As new information regarding our plans becomes available it will also be posted on our website.
WHO HAS BEEN CONSULTED REGARDING THE PROPOSALS?
We consulted first with immediate neighbours in the streets around Bow East along with those who made representations to the planning authority about the previous proposals. This has included a mailshot to more than 500 addresses, public exhibitions at The View Tube, meetings with a range of local organisations and creation of this website where we can provide updates.
Our consultation is ongoing and we welcome comments and questions at any time. To date the discussions we have had with local organisations and individuals has helped to influence our proposals and will continue to do so throughout the process.
HOW DOES THE PROPOSAL FIT WITH THE LONDON PLAN AND LEGACY VISION?
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 ‘Strategic Industrial Location’ (SIL). 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, SILs are given protection because of their importance as employment areas and because of their contribution 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?
There are three joint venture partners – Breedon, Brett and S Walsh & Sons. All three are well established British businesses with long track records of responsible operation. Representatives of the three firms are working with the landowner Network Rail and primary leaseholder DB Cargo. Under our proposals DB Cargo would continue to run train loading and unloading operations at the site, but the overall activity at the site would be capped at a lower level than the site can operate today and the whole site would come under a single set of controls.
WHY WOULD THIS APPLICATION BE SUCCESSFUL WHEN PREVIOUS ONES WEREN’T?
A lot was learnt from the previous planning applications. Our new proposal is different in almost every way, reflecting the sensitive location of the site, its proximity to the Olympic Park and the developments that have grown around this freight site. Overall this proposed development would be a smaller, lower capacity, better screened, more contained and tighter controlled operation than what’s there today, and on a fraction of the scale of previous proposals.
Through the consultation process we hope to explain how these new proposals differ and why they’re an improvement, as well as taking on board comments and suggestions as we develop the proposal. Our proposal is exactly the kind of activity for which this site is designated and they will both improve and make better use of the site.
HOW ARE YOU ADDRESSING THE PREVIOUS OBJECTIONS?
We believe our new proposal is a compromise that addresses the concerns raised previously, whilst making good use of this important rail freight site to bring in materials needed for regeneration and development. We have continued – and will continue – to take on board concerns, comments and feedback in order that the proposal that is finally submitted offers the best all round solution.