I am writing on behalf of myself and my neighbours to express concern and register our objections and total opposition to the construction methodology statement that has been submitted to you to satisfy condition 5 of the planning permission granted on the above mentioned site.

Are reasons are clear.

The basis of the CMS (and development proposal) is factually incorrect.

The CMS states that the club had “on site parking for 20 cars and obviously would generate a fair amount of traffic from cars and deliveries for beer, drinks, food and other supplies to serve the club” yet nothing is further from the truth.

I have lived in Highgate Road and overlooked both the site and Little Green Street since the 1970’s and know that no such car park or traffic movements existed.

Demolished buildings on the club site created the so called ‘car park’ and a change in level caused by their ground slabs makes it difficult for larger vehicles to even turn around. Deliveries to the ‘club’ were always made by a small brewery lorry carefully backing up Little Green Street only once or twice a month.

Even when fully operational the majority of people using the ‘club’ lived locally and walked to the site making it possible for the vacant ground to be used for parking by a few local residents in College Lane . On some evenings club members also used the spare ground but at no time in 31 years have I ever seen 20 cars parked on the site or vehicles use Little Green Street in the volume and manner described by the developer. It is neither possible nor true.

Little Green Street is an important and busy pedestrian public right of way that should not be used as a construction (and vehicular) ‘access road’ for the development of this back land site.

The “London Borough of Camden Department of Technical Services Paper”, (published in the 1970’s when the majority of this inaccessible site was developed) states clearly that “vehicular access from Little Green Street is for emergency use only” and “pedestrian ways are designed throughout the area with access via Little Green Street to Highgate Road ”.

The same is true to-day. Little Green Street and the adjacent Highgate Road pedestrian crossing are used daily by a large number and wide variety of people coming and going from Ingestere Road and College Lane . School children, mums, dads, pram pushers, dog walkers, boys on bikes and the elderly accessing the post office, local shops and doctor’s surgery on the opposite side of Highgate Road all use this important pedestrian route.

The statistics included in Appendix 12 (Pedestrian Survey) clearly demonstrate this yet no analysis of the data or summary conclusion has been included by the consultants in the CMS report, presumably to avoid highlighting the importance of this route to the movement of local people.

The tiny houses in Little Green Street have equally small bow fronted windows that over-sail a bollarded “pavement” now too narrow to walk down. People therefore have to walk up and down the centre of the street and we wish to maintain our and their right to do this. This is a public pedestrian right of way which should not be suspended to accommodate the needs of construction vehicles because a developer wants to construct on an inaccessible site.

The CMS is ill considered and will cause major traffic jams on Highgate Road . It is also totally unworkable in Little Green Street.

The proposals in the CMS will seriously disrupt an important TFL route, probably for more than four years. Restricting a substantial part of Highgate Road to the two north bound lanes will create even more traffic jams on a road that already blocks during rush hours and deprive the area of a bus lane and two much used bus stops.

Temporary traffic lights to the north of the zebra crossing and water filled traffic barriers forming a low loader waiting area and materials unloading and handling bay will cordon off the houses in Little Green Street and Highgate Road, making them a part of the construction site and blocking their doors and access.

For many years it has not been possible to park cars in Highgate Road has between 7am and 7pm , Monday to Saturday. We have all learnt to live with these restrictions to ensue traffic flows on this major route. We see no reason why these arrangements should be suspended to accommodate this totally unworkable solution for a developer who simply wishes to make money from an inaccessible back land site.

The CMS says that his vehicles will approach and exit Little Green Street from the direction of Kentish Town because of its proximity to the zebra crossing – put there by L B C as a consequence of the importance of Little Green Street as a pedestrian route – yet in doing this their vehicles appear to be travelling in the opposite direction to their intended destination with no explanation of where or how and they will eventually turn.

The turning circle of the vehicles exiting the site (NOT indicated on drawing no 025562/001) will also cause vehicles to go on the opposite side of the Highgate Road , facing oncoming traffic and causing even more chaos, delays and potential danger to cars and pedestrians alike.

The traffic management drawings in the report rename Little Green Street as “Little Green Lane”. The CMS proposals clearly do not work and we seriously question the competence of the consultants and wonder if they have yet to visit the site!

The developer has failed to explore in detail alternative viable construction methods (possibly contravening European legislation.)

We have no desire to force construction vehicles onto the Ingestere Estate but we do believe that the analysis of the ‘ Alternative Site Access Route ‘(Section 19 pages 15 & 16) is totally inadequate.

We are told that the developer, Camden planners and Camden housing department have all carefully looked at the possible option of an alternative access from the Ingestere Estate yet the reasons given why this alternative access option is not practical or viable and the email correspondence itemised in Appendix 12 seems to indicate the very opposite.

The loss of one or two parking spaces on an estate with 125% car provision is hardly significant and there is at least one other route through the estate which and has proper width roads with pavements built to accommodate vehicles using the Council maintenance depot included in the estate development and passes only one or two residential properties that are set back from the pavements. (see plan attached).

In our opinion the CMS should be rejected on the grounds stated and the developer should do what others have to do when wanting to develop an inaccessible back land site. He should continue to site assemble in order to acquire further property or land, maybe in Lady Somerset Road, through which he can construct a proper and adequate access road and produce a realistic and sane CMS.

I have been reviewing the impact of the Construction Method Statement for the Former British Rail Staff Club site which proposes to use the turning into and out of Little Green Street into Highgate Road as the major construction access – I am a resident of LGS and a non car owner (by choice) and therefore am happy to rely completely on public transport for my daily inner London transport requirements. Currently, there appears to be a growing problem with northbound traffic in the stretch of Kentish Town road from the junction with Royal College Street to Fortess Road junction. A further reduction created by the proposed site construction method , and loss of the bus lane , would render the entire bus journey, from the Royal College Street junction north to Gordon house Road ,slower than pedestrian speed for considerable periods of each day.

I ask you to take this observation into your consideration of the proposed CMS for the small site which will have such a major impact on the area for over three years. I have advised Camden that in my opinion, it is not the place of a Construction Method Statement to resolve problems which should have been designed out at the initial scheme design stage. It may well be that the approved scheme is un-buildable without creating a disproportionate and unacceptable impact on the environment and transport systems of the area. This is a problem for the applicant to resolve, not the community.

I write on behalf of the association. Having met, we object to the Construction Methodology Statement (revised 7^th August 2007) on the following grounds.

Earlier objections to this CMS complained that it rested on unproven assumptions about the impact of such large movements of plant and material upon the social and physical fabric of the surrounding community. Work has now been done by both the developer and by the residents to test those assumptions. It is now clear to everyone, including we believe to the developers themselves, that the arithmetic fails these proposals.

Geometry

Submissions more expert than ours, especially the masterly summary by Michael Coombes of Alan Baxter and Associates (21.9.2007) show that the geometry and dimensions of Little Green Street and Highgate Road forbid the operations proposed, in practice and in law. The CMS should be rejected on these grounds alone.

The developers, realising as they do that access through LGS is actually impractical, recently petitioned the Council to use Ingestre Road instead. (Even they say in this CMS that such permission may be withheld "….for safety reasons….". ) The Council rightly refused this use on the grounds of nuisance and hazard to the people on the Estate. Ingestre road is far wider than LGS and has wide pavements too. It follows that the Council cannot refuse access through Ingestre Road and grant it through LGS.

Frequency

The proposed frequency of traffic described in the CMS would in itself be unacceptable. However, the volume of material to be moved and the frequency of trucks accessing Little Green Street are falsely represented in the developers' submission, as again other more expert replies have shown. The frequency is at least twice that promised in the CMS. Either the developers cannot do simple arithmetic or their representations are deliberately untruthful. Either disqualifies them as people to be trusted with the safety of others.

The human impact

We wish to stress that however conclusive those calculations may be, this is more than a question of arithmetic. The CMS proposes effectively to close LGS to pedestrian use during working hours (8.00 to 6.00) for a period of years. The residents of LGS, several of whom have infant children to convey in buggies, will have to seek permission from a banksman to leave or to regain their houses. They will be unable to access the street with their own vehicles. No removal will be possible. No wheelchair user will be able access the street. This is a serious matter, which would be unacceptable for a period of weeks. To exclude Camden residents from the proper enjoyment and safety of their homes for a period of years is a fundamental breach of their human rights. We look to our elected representatives on Camden Council to safeguard those rights and protect us from such an unacceptable level of suffering and hazard.

Accident hazard

There is still no proper risk assessment attached to these proposals, just the familiar list of good intentions to make good the damage they say they are likely to do. One kind of damage that will never be made good will be that likely to be done to pedestrians, including the many children using College Lane and Little Green Street to access nearby schools. It is obvious to everyone that the intensity of plant movement up and down the Street will exclude pedestrian use, including crossing it through College Lane. It will simply be too dangerous to venture down or across. But some pedestrians, typically children, are bound to try and will be placed at once in danger.

The extent of the numbers exposed to hazard is underestimated in the CMS. A 'pedestrian survey' is appended to the CMS. The present writer is a professional survey researcher who has carried out social surveys for Government for 40 years. The survey reported in the CMS is pitiable nonsense. It was carried out in an ad hoc and inaccurate fashion by a relative of the developers. We are denied any report of its methods but the enumerator admitted that it excluded movements in and out of the houses. It otherwise blatantly undercounted. It ignored wheelchair and child carriage use. It was combined with attempts to get local residents to sign a petition in support of the development. It is worthless and should be discarded.

Other risks remain un-assessed. Damage to the water table and the risk of flood remain un-addressed and no hydrology has been done. Camden now has a highly restrictive policy on the excavation of basements yet none of these restrictions seem to have been addressed to this plan. Only casual mention is made of monitoring the condition of houses adjacent to the site. Yet we know College Lane stands on made-up ground. At the time of writing, Number 3 has just been evacuated to allow emergency underpinning to the house and to the rear of The Vine public house. Hardly a house in College Lane, and not this one, has escaped subsidence over the past 30 years.

Health hazard

We remain of the view that the re-introduction a plan to place a large rubbish facility, storing the rubbish of 30 dwellings, actually next to No.30 College Lane and within 1.5 metres of numbers 8, 9, 10, and 11 is a breach of various provisions of Public Health Acts.

Conclusion

As we have become so much better acquainted with the real dimensions of this proposal and its implications; and as we have studied the Inspector's judgement more and more closely, it has become clear that the Inspector himself took a deeply serious view of the problems involved in building this development.

The Inspector felt he could not deny planning permission for the development in situ; but he saw clearly that the problems of access and operation were insurmountable within reasonable cost. Had he known at the time that LGS was only 2.5 metres wide, rather than the false dimensions he was given, he probably would have ended the venture then and there. As it was he handed the problem back to Camden Council who, entirely within their legal powers, are now free to rule that it is not possible to build this much on this site in this way without causing unacceptable levels of hazard and hardship to the surrounding community of Camden residents. We insist that it is the Council's right and the Council's duty to reject this CMS.

It may be feared that such a ruling will create an impasse that will eventually have to yield one way or another. But the solution to the current impasse is simple and accessible. The developers, whose insistence upon this scale of development and their underground car park is the sole source of these problems, must return to their drawing board. They must design a lightweight car-free development that is in keeping with the car-free address it occupies - College Lane - a lane that has remained free of all such traffic since it began in 1790. This might just reduce the level of building activity to one that everyone can live with for long enough.

Meanwhile, we insist again that no political authority can allow so many of those citizens whose welfare depends upon their judgement, to suffer the years of hazard and loss this development will bring upon them.

I wish to register my objection to the latest building method statement for the old railway club on land adjacent to College Lane Kentish Town NW5 1BJ for the following reasons :-

My family and I have lived in this pretty, quiet backwater for around 20 years and although being a pedestrian only Lane, we have enjoyed the fact that we could drive up Little Green Street, allowing us to pack or unload our car without much hindrance from anybody. There is enough room, if one is careful, to turn around and drive out safely on to the very busy main Highgate Road . However, with the prospect of this development, I do not believe this will be possible and we will be expected to lift and carry heavy items 200 yards down College Lane from Lady Somerset Road where, if one cannot find a parking space, will end up being ticketed or even towed away. Almost overnight, our day to day lives will be disrupted. This is just not acceptable.

In view of the safety aspects of these large lorries driving up and down Little Green Street almost every 4 minutes, trying to turn on to the main road is also ludicrous, it's hard enough trying to do it in a family car.

The amount of disruption this will cause is unimaginable. Traffic will tail back in both directions for miles. The width of the lanes being described in this document is nothing short of scary as large buses and lorries always use this road. You only need to stand near the pedestrian crossing for a short while before seeing either a fast accelerating ambulance, police car or fire engine speed past you. Delays on this stretch of road could be a matter of life and death to people in need of their services.

I cannot see that the large vehicles being used on this construction site will be able to negotiate the minute entrance to Little Green Street without causing damage to the Grade II listed houses, a Conservation area of high importance, or the garden wall of the house opposite.

The impact on local people trying to gain access to their properties, shops and places of work will be catastrophic, not to mention the school children from many of the nearby schools who regularly use Little Green Street as an access route to Highgate Road and the zebra crossing at the end of Little Green Street. Also, what provision is being made available for people in wheel chairs, mums with buggies and small children?

The amount of vehicle traffic proposed causing a danger to children, the elderly and infirm, let alone to the residents, who will endure years of misery through noise, dirt, mud, dust and high levels of stress, is unthinkable. There are many children in the Lane who have the freedom to play in this area, as well as those who work from home - what impact will this scheme have on them?

I am extremely concerned what impact the excavation of such a gigantic crater in front of our house will have on the surrounding land, properties and flora and fauna, not to mention the very old, now protected, London Plane tree. I am also very worried about possible flooding due to this work and the company’s expertise to deal with such a hazard should it arise and the need for it to be dealt with quickly. Should any emergency arise needing any of the emergency services, access to our houses will be limited and could put us at risk.

Some houses in College Lane are already starting to suffer from subsidence and the worry here is that, with this amount of traffic, they could be easily damaged by vibration from large vehicles and demolition of the existing buildings.

In view of the length of time it has taken this developer to reach this point, I have very little confidence in this company’s ability to carry out this work safely should this project be given final approval. I have heard many people say this is an accident waiting to happen. The residents will have to endure years of misery and be constantly worried that these works will not be properly monitored or enforcement action taken swiftly if things don’t go according to plan.

I therefore ask you to reject this proposal on the grounds, that a scheme of such magnitude, and the problems associated with it's construction and limited access to the site , is unworkable and either an alternative access route is found to this site or a new, smaller, car free planning proposal be submitted.