A. Barnet Council needs to ensure that the developer has an obligation to build rail freight facilities
Barnet Council must ensure that the freight facilities must be certain. Freight on Rail believes that the development only be given consent on the basis that the developer, the council, Network Rail and the operators all sign up to a Section 106 Agreement under The Town and Country Planning Act 1990. As a legally binding agreement (which can’t be changed without the agreement of all signatories), it would govern the design, building and operation of the facility. The extent to which it has to be paid for by the developer can also be covered. This can be reinforced by a “Grampian” condition under which a given part of the development cannot be brought into use until something else is done. Freight on Rail does not consider that a planning condition, which can be ignored or appealed against, would be sufficient.

Steps must be taken to ensure that the developer doesn’t just build the highly valuable shops and residential space and somehow overlook the rail freight need. The scheme has to be integrated and no one part should proceed without the whole being certain.

B Need for policy giving absolute right to run rail freight services from rail freight facility and waste transfer station.
Freight on Rail believes that in order to protect both the rail freight facilities and the rail connected waste transfer station there should be an absolute right to run rail freight services from both sites as they represent the only viable strategic rail site in this part of the capital. There is a danger that unless these sites are preserved exclusively for rail freight use, under the same lease terms as prior to the redevelopment, this national strategic rail freight site could be lost if the developer were able to charge unviable rates to the rail freight operators. Rail freight services at Cricklewood have been blighted in recent years by the uncertainty as a result of the redevelopment plans and new lease terms which are making it difficult for the rail freight industry to plan and invest. However there is no doubt about the demand for such rail freight services, nor the importance of this site for rail freight.

C. Waste Transfer station should have status of rail freight facility
If rail connected waste removal ceases at Cricklewood, the site should revert to rail freight facilities to handle the increasing demand for consumption of goods in the capital, as stated in the Mayor’s plans to accommodate the expected growth in London’s population over the next ten years. Again, there is no doubt about the demands for rail freight services on this site if the waste transfer operation ceased. It is imperative that the rail connectivity of this facility is maintained.

D. Climate Change makes reduction of carbon dioxide from freight imperative
Since the concept of Brent Cross extension was formulated, there has been a sea-change in governmental and public perceptions of the need to reduce carbon dioxide emissions in order to avoid climate change. This has meant that rail freight’s role in reducing freight transport emissions has been recognized and so has the priority to accommodate more freight on rail been recognised by Government. This change has been reinforced by recent rises in the price of fossil fuels and the demand for greater efficiency in transport, as well as in new buildings, is ever more apparent. In that context, rail freight must not be relegated to the status of a secondary consideration. A new facility for freight which can cater for future and existing demand and used exclusively for that purpose can contribute to a reduction in road miles for vehicles servicing the capital. It is desirable in its own right. As an element of this scheme it is essential. There are other facilities but in such a densely populated area more need to be planned now to cope with rising demand. The loss of the potential site at Cricklewood cannot be countenanced and the function must be safeguarded.

E. National strategic nature of both rail freight facilities
Cricklewood rail lands represent a national strategic site for rail freight which allows freight to be brought into and out of the capital in a sustainable way which can also reduce road congestion. There is no comparable strategic site with the right road and rail connections in north London. There are very few sites of a suitable size within the M25 to fulfill the role of a smaller terminal with adequate road or rail access. Cricklewood is both existing operational railway land and has existing operational facilities and is the only obvious location in North London.

F. Using rail freight during construction phase
Environmental Statement has not studied options for using rail during the during the 20 year construction period for bringing in construction materials and removing construction waste. We believe that using rail freight where practical, which will not only reduce emissions but also reduce HGV movements during this process and should therefore be made a planning condition. Planning permission for Terminal Five at Heathrow was given on condition that rail was used for bringing in construction materials. TfL has stated its support for this approach. The planning application and accompanying documents (eg Code of Consultation Practice) make only a fleeting reference to use of rail freight during site construction.
See section 7 construction phase for more details.

When asked about using rail freight during construction Mr Jonathan Joseph of the developers said the following. “We will do as much as is economically and practically possible.”

We therefore believe that Barnet Council need to make rail use, where applicable, for bringing in construction materials and removing waste a planning condition. We will also be consulting TfL and GLA on this matter. It would appear that the existing rail freight facilities will be available until phase 5 when the new rail and bus stations will be built. The precedent was set with the Terminal Five and Olympics construction agreement.

G. Bring forward phasing of rail freight facilities to phase one
A new rail linked waste handling facility, served by the A5/Diverted Geron Way, to be built west of Midland Mainline (MML), is part of the first phase called the Primary Development Package (PDP). It will replace the Hendon Waste Transfer Station east of MML and facilitate redevelopment of railway and industrial land for residential use.

However, a new rail-based inter-modal freight facility, served by a new access off A5 Edgware Road to replace eexisting rail freight facilities to the east of MML which will be relocated to a new site west of MML only has construction earmarked for Phase 4, as yet unprogrammed. Freight on Rail wants to see this facility brought forward to phase 1 as previously indicated and notes that the developers say they would consider bringing the date forward. We believe that this should be carried out on environmental and economic grounds. The imperative to reduce carbon emissions makes the case for this as well as the fact that the rail freight operators state that there is considerable demand for rail freight at Cricklewood from customers.

Freight on Rail wrote to developers and Barnet on 25th May 2007 and the developers in July 2007 stating that these rail freight facilities should be brought forward to phase 1 making the following points:-

Provision of new rail freight facilities is in line with National Government policy is to reduce carbon emissions from freight ref TasT, Regional policy ref London Plan and Policy 3C.4 Land for Transport, local policy Barnet UDP.

that existing rail freight facilities have over the last ten years been blighted with a situation where only short- term leases could be awarded for rail freight traffic.
There is significant demand for rail freight facilities at this location.

More details are given in sections 5 and 6

We believe that the developer should provide a great deal more information about the timing and the use of the rail freight facility and evidence that he has taken the opinions of the rail freight operators as to the most effective form of new facilities for the area. How does the developer intend to provide the facilities.

H. What safeguards will be put in place to ensure that the new facilities will be used for rail-freight and not for road-only freight?
Freight on Rail has asked for safeguards and TfL has stated that it expects to see a condition of use that it could only be used for rail served usage in its response to the ORR consultation on the Network Rail disposal of railway lands.

Freight on Rail believes that this condition needs to be written into planning permission.

When Freight on Rail asked Jonathan Joseph of Crickelwood Redevelopment what safeguards will be put in place to ensure that the new facility will be used for rail-freight and not road-only freight in June 2008 it received the following response- “This has not yet been considered but as a large part of the new facility is expected to be integral with the rail sidings, this possibility is considered to be unlikely”.

J. Rail freight facility should be open access

K. Lease arrangements
Leases for replacement facilities need to be on the same terms as previous leases on the existing site.

To ensure that rail is used the rents charged must not be too high. FoR did raise this issue with Barnet Council, TfL and GLA last year in writing and believes that this a crucial issue to resolve if rail freight services are to be viable at this location. If charges are too high, rail freight will not be feasible which means that the country has lost the opportunity to reduce carbon emissions from freight distribution and a reduction of HGV movements in the heart of the capital which cannot be replicated elsewhere in north London.

2. Rail Freight Facilities and Waste Transfer Station in line with national, regional and local policies

Developing these rail freight facilities is in line with national policy and climate change challenges identified in Towards a Sustainable Transport Strategy (TasT) and the SRA rail freight interchange policy which was endorsed by the Secretary of State for Transport in October 2005 after the SRA had been abolished. The SRA’s strategy for freight to enable modal shift to reach Government targets requires 3-4 large scale Strategic Rail Freight Interchanges around the M25 where major road and rail radials intersect. These can be supplemented with smaller locations within the M25, taking advantage (where possible) of existing railway land or facilities.

GLA policy supports both facilities at regional level and Barnet Council UDP and development Framework supports the two facilities at local level.

The importance to the national economy, the environment and society has been recognised by the London Sustainable Distribution Partnership (LSDP) in its letter to Barnet Council outlining the reasons for retention and development to expand the rail freight facilities at Cricklewood as soon as possible.

Endorsement by London Sustainable Distribution Partnership set up by the Mayor to advise the GLA.
Letter from Peter Hendy Chair of LSDP March 2004
There are very few sites of a suitable size within the M25 to fulfill the role of a smaller terminal with adequate road or rail access. Cricklewood is both existing operational railway land and has existing operational facilities and is the only obvious location in North London.

The LSDP is therefore writing to support the case for redevelopment and expansion of both the rail freight facilities and the rail connected waste transfer station at Cricklewood. The existing railway land at Cricklewood represents the last available site in North London for a rail freight terminal with any scope for expansion.

We are keen to see the Cricklewood Redevelopment provide a practical and viable replacement for the existing rail freight facilities. Rail freight activity at Cricklewood has been restricted to its present level for several years as a result of the London Borough of Barnet’s aspirations for regenerating the area. This uncertainty has made it impossible for rail’s full potential to move freight to and from North London via railhead facilities at Cricklewood to be reached. While we recognise the importance of regeneration in this part of North London, this must be balanced against the need to ensure the continued operation of sustainable freight facilities…

In conclusion, the Cricklewood railway yards and sidings are of strategic significance at local, regional and national levels and their continued use for sustainable freight operations needs to be assured – both for existing business and future expansion.

Without strategic sites, such as Cricklewood, freight cannot be shifted from road to rail. In line with GLA policy and the Stern Review recommendations, this rail freight facility can help reduce carbon emissions in the capital. Proposals for redeveloping this site have been underway for some years now so we believe that it is crucial that the rail freight facility is part of phase one, in line with the condition given to Network Rail by the ORR for the disposal of the existing rail lands. ORR stated that the existing rail freight facilities must be replaced elsewhere on the redevelopment before the existing sites are released.

Because of blight, including the fact that only short term leases can be awarded to customers on the existing rail freight facilities, we believe that it is crucial that the new rail freight facilities are built in phase 1 and that the existing rail freight facilities are used for bringing in construction materials and removing building waste.

The London Plan
A key policy which supports both rail connected facilities is :

Policy 3C.4 Land for Transport
“……….Only approving changes of use of land from transport and transport support functions if it is no longer required and is unlikely to be required in the future for this purpose, or if equally good alternatives are provided”

Both rail connected waste transfer station and rail freight facilities are supported by Supplementary Planning Guidance Land for Transport (GLA, 2007) elaborates on Policy 3C.4:

“In the event of alternative development proposals coming forward on sites currently or last in use for rail freight purposes, the Borough will need to agree with DfT Rail, Network Rail and the Mayor (GLA and TfL) whether:

the site may still or potentially could be required for rail freight use;
b) an equivalent, suitable alternative site for rail freight use has been made available elsewhere;
c) use of the site for rail freight is no longer required or unlikely to be required in the future.

Where rail freight is no longer required, use for alternative transport or transport related purposes should first be considered and assessed before other uses are considered. In each case other strategic London Plan priorities relevant to the site must be considered………” 1.

Freight on Rail would point that the rail freight services at Cricklewood have been blighted in recent years by the uncertainty as a result of the redevelopment plans and new lease terms which are making it difficult for the rail freight industry to plan and invest. Therefore terms such as “former”, “vacant”, “disused” or “under-used”
are misleading.

However there is no doubt about the demand for such rail freight services, nor the importance of this site for rail freight. Regardless of its current status, the planning authority will need to consider whether the rail freight land is “unlikely to be required in the future for this purpose, or if equally good alternatives are provided”. It should also be noted that before the redevelopment process was started there was a thriving rail freight facility at Cricklewood.

London Borough of Barnet Unitary Development Plan (Adopted 2006) Chapter 12 Cricklewood, Brent Cross and West Hendon Regeneration Area

In developing the regeneration area, Policy C7 Transport Improvements requires the provision of:

iii. A new railway station and new bus station at Cricklewood …..
v. An upgrade of the rail freight facilities, to increase the potential for the distribution of goods by rail, for use by businesses in North London.
vi. Provision of an enhanced, rail-linked waste transfer station serving North London”.

3. ORR Agreement to Disposal of Cricklewood Railway Lands

The ORR agreed to disposal of lands and to replacement rail freight facilities in line with Network Rail’s application in April 2006.

ORR stated that a condition of the disposal by Network Rail of the existing railway lands is that replacement rail freight facilities are built elsewhere on the redevelopment site. ORR consents to the disposal as described in Network Rail’s submission subject to the condition that Network Rail ensures that the network change procedure is completed prior to disposal.
This condition makes the case even stronger for bringing forward the construction of the replacement rail freight facilities. The reason the current rail freight facilities have been underused is not a reflection on demand for rail freight services at this location but instead a result of planning blight which meant that customers could only be offered short term contracts.

With regard to access arrangements, the application states, “Full rights of access to the network and station will be maintained or, where necessary have been secured, to the operational railway, rail linked facilities and the new railway station. Existing accesses will not be closed until agreed alternatives are provided”.

4. Railway Lands Development Zone Proposals 2.

Rail connected waste transfer station

It is important to highlight the commitment that the existing facility will not close until the new facility has been constructed and the rail connection is operational. It is also imperative the Freightliner is granted a long lease on the same terms as previous one at existing site, on the new facility to replace its existing leasehold interest.

We stress that paragraph 2.2 of Annex D of the environmental statement states that the waste facility is part of the Primary Development package, however paragraph 2.5 then puts it back to phase 4 which we believe is wrong and needs to be fully clarified by Barnet Council.

5. Implementation
Freight on Rail supports the fact that the rail connected waste handling facilities and a new all movement junction with the A5 should be in the PDP ref (Parameter Plan 019) P175 BXC01including a new all movement junction off the A5, will give access to the Waste Handling Facility.

However, appendix 10 of the ES (spreadsheet) - indicates that the new A5 access to the new waste facility won't be completed until April 2022 which is wrong

We understand from the developers that the Construction/operation of new waste handling facility is anticipated late in Phase 1 who stated that a great deal will depend on the conclusion of the PFI contract by North London Waste Authority. The new waste facility should be rail connected from inception of operations. The existing facility will remain open until the new facility is ready for operation.

Rail freight facilities should be brought forward to Phase 1.
The developers have not mapped out a pre-set phasing programme beyond the PDP. However, Freight on Rail believes that the rail freight facilities should be constructed during phase 1 for a number of reasons as previously mentioned, not least because the ORR stated that the disposal of the Network Rail lands was conditional on there being replacement facilities for both the waste transfer station and the rail freight facilities. Appendix 10 of the ES indicates that it won't be completed until April 2022

Rail freight facility should be brought forward to phase 1
Paragraph 3 of NR’s application headed timescales states the railway facilities will only be surrendered as commitments are given to bring forward any applicable replacement facilities to an agreed specification.

The start of development adjacent to the MML in the Brent Terrace and Railway Land zones is earmarked for Illustrative Phase 4. According to the Environmental Statement, the phase includes the development of rail and waste handling facilities on the western side of the railway line which we believe is wrong. Therefore Freight on Rail seeks clarification here as we understand that the waste transfer station is due for construction in the initial phase which makes the Environmental Statement incorrect. See footnote 3

A new bridge over the mainline railway will be installed and the railway sidings will be constructed in Brent Terrace zone. Access for construction traffic will be from Staples Corner along the A5 into each area.3.

The development partners state they would also consider bringing the freight facilities in earlier to coincide with the waste facility going on line to process waste brought in from outside the area for processing.4 Freight on Rail and its members has lobbied for the rail freight facilities to be brought forward 5.

Vehicular access to the Rail Freight facility will be provided from a new junction off the A5. A5/Diverted Geron Way which could be brought forward given that this access road is not dependent on any other development.

Responses from RPS Group provided by Jonathan Joseph, Development Manager RPS Group,17 June 2008 on the question of developing the new facility and associated A5 junction and A5 link road at an earlier date?

Possibly, depending on tenant demand. We are beginning to consider this.

Letter to Ros Ward Barnet Council 22nd May 2007 re Phasing of rail freight facilities

Firstly, we are writing with regard to the proposed phasing outlined by the Brentcross Cricklewood pre planning consultation. We were alarmed to see that the rail freight facilities are now part of phase four of the redevelopment. Previously we understood that would be part of phase two as stated in the Development Framework.

We do not believe that any delay in developing the rail freight facilities is acceptable. Rail freight should have continuity of operation. Rail freight has increased by over 60 per cent in the past ten years and there is huge demand for rail freight terminals in the London area, as recognised by the SRA Rail Freight Interchange Guide of March 2004 and by the London Sustainable Distribution Partnership (LSDP), see extracts from letter below in which the LSDP outlined the reasons for retention and development to expand the rail freight facilities at Cricklewood as soon as possible. Without strategic sites, such as Cricklewood, freight cannot be shifted from road to rail in line with GLA policy.....

A new A5 link road will cross the MML on a bridge south of the waste facility and connect with a new North-South Spine Road in Brent Terrace zone, linking with Station Quarter to the north and Claremont Road to the south.

6. Development Triggers

Triggers relating to waste and freight development.
i) Waste Transfer Station
This is to be provided in the Primary Development Package. The trigger is: The existing Waste Transfer Station shall not be redeveloped until a new Waste Handling Facility has been completed unless otherwise agreed in writing with the LPA.

ii) Waste Handling Facility Rail Sidings with Gantry Crane
Rail sidings and an associated gantry crane are to be provided adjacent to the waste handling facility. The trigger is: The Waste Handling Facility shall not be opened prior to the practical completion of the Waste Handling Facility Rail Sidings with Gantry Crane, unless otherwise agreed in writing with the LPA.

iii) A5 Junction to Waste Handling Facility
The provision of the new all movement junction on the A5 is an essential part of the access to the Waste Handling Facility. The trigger is: The Waste Handling Facility shall not be opened prior to the practical completion of the A5 Junction to Waste Handling Facility, unless otherwise agreed in writing with the LPA.

No triggers are identified for the development of rail freight facilities.
Apart from any relocation and clearance of operational buildings on the new site, the rail freight facility and A5 access are not currently dependent on other developments so we urge you to require the applicants to consider an earlier start date to coincide with the construction of the new rail connected waste transfer station in the PDP.

Freight on Rail believes that Barnet Council should get a concrete commitment from the developer to construct the replacement modern general merchandise freight rail freight facilities in an early time-specific phase of the development.

Section 106 Agreement needed to ensure that rail freight facilities actually get built.

Barnet should ensure that the development only be given consent on the basis that the developer, the council, Network Rail and the operators all sign up to a Section 106 Agreement under The Town and Country Planning Act 1990. As a legally binding agreement (which can’t be changed without the agreement of all signatories), it would govern the design, building and operation of the facility. The extent to which it has to be paid for by the developer can also be covered.

This can be reinforced by a “Grampian” condition under which a given part of the development cannot be brought into use until something else is done. Freight on Rail does not consider that a planning condition, which can be ignored or appealed against, would be sufficient.

Steps must be taken to ensure that the developer doesn’t just build the highly valuable shops and residential space and somehow overlook the rail freight need.

7. Construction Phases – Use of Rail Freight
Rail freight has considerable potential for transporting construction/demolition waste and building materials to and from the development site in order to reduce the numbers of HGVs. The PDP will see a peak in construction traffic numbers. 6.
The application specifies that,

"Where possible, construction materials should be selected with regard to the environmental impact associated with their use. This will favour the following approaches:

- Sourcing materials from as close to the site as possible, to reduce the emissions of greenhouse gases from vehicles, and to reduce long distance transportation”; 7.

However, the application lacks any firm commitment to utilising rail freight in the scheme development, instead options for rail use will be considered in conjunction with a possible Consolidation Centre.8.

The Outline Construction Method Statement overlooks the potential for rail freight and concentrates on HGV movements. The statement contains a Heavy Goods Vehicle Histogram based on all the major delivery vehicles anticipated arriving and leaving site to supply building materials, plant and equipment. 9. No histogram has been prepared for rail freight.

There are also plans for establishing a Transport Advisory Group whose task will include the monitor and review of the transport impacts of the Scheme, including during construction. 10.

Freight on Rail believes that the opportunities to use the sidings on the upside as a rail served construction depot should be fully investigated now by Barnet Council, TfL and GLA and FoR will be pleased to advise on any issues.

Avoid or Reduce Significant Adverse Effects
The ES fails to consider the potential for utilizing rail freight in mitigating the impacts of traffic and CO2 emissions during the construction phases. Although use of rail freight would involve lorry movements in and around the site, the number travelling to and from the site would be lower.

Freight on Rail questions in June 2008 to developers about availability and accessibility of existing rail freight facilities

a) Will the existing rail freight facilities east of MML continue to operate until the new facility has been built to the west of MML?
Answer from developer - Yes.
If yes, which road/s would provide access to the existing rail freight facilities until the new one is open?
Answer from developer - Existing road access would continue during this period and is quite adequate.

Will the access road/s to the existing rail freight facility be suitable for carrying any extra HGVs to the facility for transporting building materials/construction waste by rail?

No improvement to the roads is currently contemplated but we are intending to facilitate a consolidation centre on site. The capability of the existing roads is of a standard to support current and anticipated HGV traffic.

8. Environment Statement (ES)
The EIA Regulations require that an ES includes, as a minimum, the following:
Outline of the main alternatives

The ES omission of a key statement from The London Plan, Cricklewood Brent Cross Opportunity Area, namely, “the future use of railway lands will be influenced by Policy 3C.4 –Land for Transport”, will need to be read against the ES stated benefits of relocating rail freight to west of the MML and an assessment of the development as a whole.

“Cricklewood/Brent Cross. A Planning Framework has been completed and endorsed by the Mayor and Barnet Council. This area combines the former railway land to the north, and the industrial land to the east of Cricklewood Station, together with Brent Cross regional shopping centre across the A406 North Circular Road and its wider hinterland. The planning framework seeks the redevelopment of Brent Cross as a town centre complementing the roles of other centres nearby. This would entail an extended mix of town centre activities including housing. The planning framework makes provision for at least 5,000 additional homes together with local ancillary services and a rail station on the Cricklewood site. Any new development should be phased with improved public transport and accessibility across the area. The future use of the railway lands will be influenced by Policy 3C.4 – Land for Transport”. 11.

(NB. The last sentence marked in bold is omitted from the ES quote which we are highlighting 12).
It is crucial that both facilities which will be run 24/7 are designed in a way which mitigates the impact of rail freight to safeguard the interests of local residents.

Environmental Statement is wrong on timing of waste transfer station see section5

Triggers for Physical Infrastructure Related to the Railway Lands Development Zone

Each physical and social infrastructure item which forms part of the development will be triggered by a certain quantum of development or a specific event.

Barnet Council need to ensure that the developer is obliged to build the rail freight facility.
We believe that Barnet Council should ask the developer for a great deal more information about the timing and uses of the proposed rail freight facility and should
iv) A5 Junction to Rail freight Facility
The rail freight facility in the Railway Lands zone is to be served by a new access off
the A5. The trigger is: The new Rail Freight Facility in the Railway Lands zone shall not be occupied until practical completion of the A5 Junction to Rail Freight Facility, unless otherwise agreed in writing with the LPA.

v) A5 Junction & RoadBridge Over MML
48. Access into the western side of the site will be significantly enhanced by the creation
of a new link road from the A5 across a bridge over the railway line. The delivery of these items is dependant upon the redevelopment of the Brent Terrace zone and delivery of the new Spine Road, otherwise the link will only provide access to the rail stabling sidings. Development on the existing rail lands in the Brent Terrace zone is envisaged to provide around 1,850 residential units. The following triggers are proposed:
No more than 1,000 residential units in the Brent Terrace Zone shall be occupied prior to the practical completion of the RoadBridge over the MML, unless otherwise agreed in writing with the LPA.

vi) Spine Road North & South

The Brent Terrace zone is to be served by a new Spine Road which will connect High Street South with Claremont Road and also provide access to the A5, via the new RoadBridge over the MML. The triggers proposed relate to the development of Brent Terrace

Zone: No more than 750 residential units north of the new Road Bridge over the MML in the Brent Terrace zone shall be occupied prior to practical completion of the Spine Road North, unless otherwise agreed in writing with the LPA.

Freight on Rail explanation

Freight on Rail is a partnership between transport trades unions, rail freight industry and Transport 2000. It works to promote the economic, social and environmental benefits of rail freight both nationally and locally. It advocates policy changes that support the shift to rail and provides information and help on freight related issues. In particular, it aims to help local authorities through all stages of the process such as planning a rail freight strategy, accessing grants and dealing with technical matters.

The members are as follows: - Rail Freight Group, Direct Rail Services, EWS, Freightliner, RMT, ASLEF, TSSA, UNITE and Campaign for Better Transport

Philippa Edmunds 27th June Freight on Rail Tel: 020 8241 9982
email Philippa@freightonrail.org.uk www.freightonrail.org.uk

1. The London Plan, SPG, Land for Transport Functions, GLA, 2007 para 12.4.

2. BXC01 Development Specification and Framework p. 92-95

3. Environmental Statement Vol 2 Annex D Construction Method Statement 2.5. Lack of clarity in ES which refers to development of waste facilities in Phase 4.

4. Environment Statement Vol 2 2.2.22 Building 63 – Waste Handling Facility

5. Freight on Rail letter to Ros Ward Barnet Council 22nd May 2007 and letter to Jonathan Joseph Cricklewood Redevelopment 090707

6. Environmental Statement Non-Technical Summary 2.2.2

7. Development Specification and Framework Appendix 8 Approach to Construction Materials Protocol c)

8. Environment Statement Appendix 8 – Approach to Construction Materials Protocol (p 231)

9. Environment Statement Annex D Construction Method Statement: Anticipated Development Programme p.163

10. Environment Statement Vol 2, Annex C, Draft Code of Construction Practice.

11. The London Plan 2008 Policy 3C.4 p. 127

12. Environment Statement vol 1 5.42