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 therefore 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. If anything, the use of Bow East for rail freight is more important now 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 directly aligns with the strategic policies of 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.
WHY IS A CONCRETE PLANT PROPOSED FOR THIS LOCATION?
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 two plants on a rail-linked site 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 vehicle movements and longer journeys.
Of the 9 concrete plants in central east London, 7 have their aggregates supplied by road. Our proposals at Bow East would mean these 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. Development of our proposals would ultimately lead to the closure of one or more of these road-fed plants.
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.
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 number of movements per day would be limited to 528 (an average of 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).
A limit of 528 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 limit would be in place to ensure that the number of lorry movements is suitable for the local highway network, taking into consideration all environmental factors. A rail-linked site like Bow East is already helping to keep thousands of lorry movements off London’s 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 (than on Marshgate Lane).
However, following concerns expressed during the consultation so far about the use of Wick Lane, we are in discussions with all parties, including Transport for London and Borough Highways departments, to review this thinking. 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 on both access routes.
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.
When considering the possibility of a Wick Lane access in the longer term, we are carrying out a transport assessment which looks at potential effects on pedestrians and cyclists as a result of the proposed development. This will also make recommendations for highway improvements for pedestrians and cyclists on Wick Lane which would be fully implemented should that become an access at any point in future.
WHAT IS BEING DONE ABOUT DRIVER BEHAVIOUR AND TRAINING?
The current lorry movements to and from the site are not operated by the joint venture and we aren’t able to comment on specific examples. However, if the proposed development at Bow East was to be approved there could be much tighter controls on the vast majority of HGVs and their drivers, and all activities at the site would have to comply with an agreed Management Plan, setting out required standards. All the lorries operated by the joint venture would be Fleet Operator Recognition Scheme (FORS) compliant, which requires high levels of best practice in safe, sustainable transport both for vehicles and drivers.
Additionally, the three joint venture partners are Construction Logistics & Community Safety (CLOCS) ‘Champions’ and members of the Mineral Products Association (MPA), both of which require them to take responsibility for the health and safety of vulnerable road users – pedestrians, cyclists and motorcyclists – beyond their sites. Associating with these types of schemes is an example our collective commitment to road safety.
WHAT MEASURES ARE PROPOSED TO CONTROL DUST?
Several measures are proposed to address air quality concerns through containment within walls and buildings; suppression systems that prevent material becoming airborne; and a rigorous management regime to maintain a clean site – this does not happen on the site currently.
The design includes enclosures to inhibit the flow of wind 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. Within the plant itself, finer material that could become airborne would be contained or filtered. For example, cement brought into the site would be stored in sealed designated silos for containment, all of which would have the modern filter standards 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. For all elements of the proposed development, extensive monitoring would be undertaken at multiple points within and around the site to ensure that air quality is not affected by the site activities.
The proposed operations 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 would fully accord with. If the proposed operations did not comply with the air quality standards as set out in the conditions, the Environment Agency could revoke the permit and cease operations.
It is also worth noting that members of staff working at concrete plants are subject to safe levels of air quality by strict HSE regulations. This is done by monitoring the air quality at the site and immediately adjacent to it. By demonstrating there are no air quality risks immediately on the site we are able to show there is no impact on air quality in the surrounding area.
See also question regarding emissions.
WHAT MEASURES ARE PROPOSED TO CONTROL EMISSIONS?
The production of concrete manufacture itself produces no emissions as the process is electrically powered and involves the mixing of aggregates and cement with water.
By bringing aggregates into London by train – directly to an on-site concrete plant – truck movements are minimised. Every train which brings aggregates into London by rail keeps up to 75 truck movements off the road, reducing congestion and improving air quality. Movement of freight by rail reduces emissions and is a net air quality benefit. The vehicles we’re proposing to use are the cleanest available vehicles with ‘Euro 6’ engines already approved for Ultra Low Emission Zones and the total vehicle movements would be capped and therefore lower than current activities at the site or previous proposals. Our proposals would lead to a 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 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 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 REDUCED?
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 design 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 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 acceptable. We are also proposing the installation of storage bay walls and additional planting at the site perimeter, which could potentially further help to reduce the effects of light impact from operations on site.
HOW WOULD CONCERNS AND COMPLAINTS ABOUT THE SITE BE HANDLED?
Under our proposals the 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 and any issues addressed centrally.
Our intention is to set a new 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 trucks would leave the gate 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. 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 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 detailed 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. Ready-mixed concrete plants are relatively modest in size and there are thousands of them in 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’ 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. 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 and stored in silos until it is needed in concrete.
Whilst there is a negative perception of concrete because of the way the cement is manufactured, concrete has natural thermal mass properties which have been proven to reduce the need for cooling and heating. Since more than 90% of a typical building’s carbon is generated during the course of its life (rather than during its construction) concrete has better sustainability credentials than you might think.
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 led by 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 ancillary to the main use of the Strategic Industrial Land (SIL). Such meanwhile uses are, therefore, expected to include business (B1) and non-freight related storage and distribution (B8).
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 summer 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, a week-long public exhibition 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 therefore 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 to London’s logistics system and infrastructure which are essential to the city’s success and international competitiveness.
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.
NB The Bow East site is outside the Queen Elizabeth Olympic Park.
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.
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 every way, reflecting the sensitive location of the site, its proximity to the Olympic Park and the expectations of local residents and organisations. Overall this proposal is smaller, cleaner and tidier than what’s there today and 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.