Dear Adele Castle,

Application Ref: 2007/4036/P

Associated Ref: 2006/0449/P

The Former Railway Workers Club, College Lane

We write in response to the currently submitted Construction Methodology Statement [CMS] by the developer’s team for the Former Railway Workers Club on College Lane. We write to object in the strongest possible terms.

Our reasons, which we wish you to carefully consider, fall into the following groups:

1] Little Green Street is not a suitable access

2] Direct effects on our house and family

3] The basic geometry and safe operation of works on Little Green Street and Highgate Road.

4] Safety

5] Environment

Objection 1] Little Green Street is not a suitable Access

The new details in CMS dated August 7^th 2007 make it possible to identify the true scale of the mistaken measurement of Little Green Street. The CMS continues to propose that Little Green Street is the only site access.

Little Green Street was only ever considered to be an access because its width was mistakenly represented in Camden’s own evidence to the planning inspector. This mistake was sadly also borne out by ordnance survey maps, and information put forward by the developer, as 3 – 3.6m wide.

Your department and the developer now accept that the width is only 2.5 – 2.9m wide.

The mistake has resulted in a minimum of 13000 vehicle journeys and at least 60 – 68 weeks of haulage being proposed. From the developer’s own figures 70% of the construction traffic is for the excavation of a basement car park and underground habitable rooms and the required concrete for it. In separate submissions from Alan Baxter Associates even these figures are shown to be an underestimation by an incredible factor of twice the figure put forward in the appendices.

This basement design feature only exists because all parties mistakenly quoted the road width. Despite acknowledgement of the actual width, no inventive strategy has been considered for avoiding this unnecessary and dangerous bulk of material passing within inches of our homes and children and all those who use Little green Street daily, including countless school children, toddler and babies.

The proposal in the CMS is to haul excavated material and concrete up and down the street for years in smaller loads, into a flow of traffic and pedestrians on Highgate Road that the developer fails to measure - or even guess at.

On 12^th September 2002 Stephen Burke of Camden Highways produced a document for John Davies of the Development Control Team in which car access to the project was analyzed and rejected due to the then known figures for traffic on Highgate road. This document shows that your department and highways were acutely aware of the problems, understood the weight of traffic on Highgate Road and based on traffic figures from 2000 turned it down and asked that amongst many other traffic limiting requirements: The applicant should prepare a Transport Impact Statement to include a Safety Audit of the Access, as required by UDP policy TR19. The safety Auditor could then be liable in the event of a claim being made against the Planning Authority, following an accident attributable to the layout of the access.

Your department has failed to ask for this with regard to the CMS, even though construction traffic represents a far more onerous safety issue than that considered in 2002.

Objection 2] The impact on our house and family

When the pedestrian survey was undertaken by the Waterstone Corporation [Appendix 13] residents of the street arranged for a video camera to be focused on their representatives to record for ourselves what was going on. This confirmed our suspicions that no resident of Little Green Street was recorded, neither were cyclists, buggies or wheelchairs counted.

Further, the incredible number of users of Highgate Road was left uncounted despite Camden’s Highways Consultancy unit having specifically requested this information. We strongly urge that this survey be rejected as inadequate.

The CMS shows that the inhabitants of the south side of the street will be imprisoned in our homes for the duration of the project, and that the road will be effectively closed to pedestrians.

Even where we to spend money to re build the ground floor doors such that they could be safely used, I doubt we could make the security system work or satisfy our insurers. It is simply unreasonable to suggest that for 4 years or more we should have to use the house in this way.

The problems of access for residents of 10, 9a and 9b are ignored completely. Residents have no option but to use Little Greens Street with 300mm between the front doors and the site traffic for the development, front doors which open directly into the front rooms of the property or stairs, provide no safe refuge in the form of a hallway or porch.

If this proposal were allowed our safety will have been ignored, we would simply have to move out. All of us.

Objection 3] The basic geometry Little Green Street and Highgate Road make the safe operation of works as proposed impossible.

The submitted CMS proposes that it is safe and possible to use Highgate Road for access based on drawings, which show it to be 10.2m wide and suitable for three lanes width, with water barriers to separate lanes. Each lane is shown as 3.4 metres wide and shows the possibility of a turning circle for a single 6.5 ton truck apparently working on a diagram scaled at 1:500. Works are claimed to comply with Traffic Safety Measures and Signs for Road Works and Temporary Situations [See Appendix 3 Capita Symonds Methodology for Traffic Safety of Construction Vehicles]

Note: All the drawings from Capita Symonds drawings are labelled: This drawing has been prepared for illustration purposes only to support the Methodology Statement

In the region where Highgate Road is shown the road actually measures 10m reducing to 9.4 metres wide. The width of the proposed water filled barriers is 500mm wide. This results in a maximum useable lane width of 3m at its widest point only. A C2 London bus is 2.83m wide – many vehicles using Highgate Road are this and wider as it is a B road, which skirts the local lorry exclusion zone.

Objection 3a] The proposals fail to ensure a minimum of 3.25m operational lane widths. [Highgate Road would need to be widened by at least 750mm to comply]

Traffic Safety Measures and Signs for Road Works and Temporary Situations Part 1: Design 2006, Section D3.3 Lane Widths

Objection 3b] The proposals fail to provide any provision on Highgate Road or Little Green Street for the needs of non-motorised road users in the following areas:

1] Impact on frontages i.e.:

* Houses with no pavements,

* Deliveries to shops,

* Bus stops etc

2] Adequacy of Lane widths for cyclists past the works

3] The needs of children, from the many local schools

Traffic Safety Measures and Signs for Road Works and Temporary Situations Part 1: Design 2006, Section D3.32.1 Non-Motorised road users –

Objection 3c] The proposals fail to avoid the use of lane widths that would be of danger to cyclists. Traffic Safety Measures and Signs for Road Works and Temporary Situations Part 2: Operational Issues 2006, Section 03.14 Cyclists

(3:14:2 [between 2.75m and 3.25 m should be avoided].

Objection 3d] Contrary to statements made in Item 7.7 on page 7 of the Summary the diagrams do not illustrate the suitability of vehicles or otherwise for vehicles turning out of Little Green Street in to Highgate Road. We contest that the most frequently used vehicle will cross into the northbound lane every time it leaves the site.

It is proposed that all traffic leaving from LGS will turn left on Highgate Road. Little Green Street is at its narrowest at this point. Therefore vehicles will have to project well into Highgate Road before affecting the turning manoeuvre in order to avoid rear wheels mounting the footpath. Further complicated by the fact that garden walls block at this point driver’s vision.

Objection 3e] In order to effect the traffic control system the north bound bus lane is to be suspended and the general area the subject to a 10mph speed limit for 68weeks north and south, with intermittent disruption to the south bound bus stop.

Objection 4] The proposed frequency of use of Little Green Street in Phase 1 of works is unfeasible, unworkable and unsafe.

There seems 2-fold error in the figures in Table 5 of the summary [page 12]. This is covered in Michael Coombs’ Letter to your department on our behalf.

This is simply unrealistic and points to either a gross underestimation of their program and/or the number of vehicles required, either way making an unacceptable situation worse.

Objection 5a] Movement due to construction vehicle induced vibration.

The CMS states that vibration damage from construction vehicles is unlikely.

The houses lining Little Green Street an the site along College Lane are all over 150 years old, underpinned only in exceptional cases.

The choice of a lightweight vehicle is reasonable. However, since it is a very imprecise science and given the age of the buildings, through the 68 week period there should be a continual monitoring exercise would say at 10 week, 30 week, 68 week review in order to intervene in what would be damage to buildings some of which are listed and to all of which they have a duty of care.

Objection 5b] direct impact of and from longer, wider and overhanging loads has not been assessed.

The CMS fails to demonstrate how longer and wider loads will be transferred from Highgate Road to the construction site.

The CMS fails to demonstrate how low loader deliveries will be manoeuvred on Highgate Road without stopping traffic flow, north and south, closing the pedestrian crossing and blocking Little Green Street.

The CMS fails to demonstrate how longer loads, such as 6m long reinforcement bars, unspecified sized piling rigs, the 10 metre long concrete batching plant [the entire width of Highgate Road] could possibly access LGS especially considering they would probably come on a vehicle with a combined size of one third the length of Little Green Street.

Comment 5c] Ground Water Flood:

Whilst proposing to dig 75% of the site to a depth greater than one story of the proposed development below existing ground level, the CMS fails to record the water table or the method of dealing with any ground water issues.

Camden ’s own policies require specific reports from accredited specialists to ensure that the proposed basement and its excavation cause no demonstrable harm. The CMS fails to provide any information on this. As your own department has recognised elsewhere, in such situations a Hydrology Report to ensure that ground water and the water table are not adversely affected is required. No such information forms part of the submission.

Comment 5d] Trees

The CMS fails to include the protection of the trees both on and off site. All trees at the entrance to the site need to be considered and protected.

The CMS says it will abide by BS5837 [Trees in Relation to Construction - Recommendations]. This BS asks for the provision of the appropriate and safe rooting environment for that tree. In this case on the basis of a 1m-diameter trunk you would need to do nothing to excavate or disturb the plant in any way within a 12.6m radius of that tree. [This protection area seems to have been confused by the applicant with the tree canopy who’s radius 8m - so a larger area than that shown]

The CMS fails in the light the above to show how it is possible to construct and manage the entrance of the site or to construct the ramp to the basement ramp [starting just 2.5m from the centre of the protected tree trunk] without causing 20% root loss for the tree with the high probability of killing it.

We understand that you take matters in relation to the damage to trees very seriously. Simply the current application should be refused and a redesign demanded. Without this the trees will die and another case of trees dying due to construction work based on unsound planning decisions will have occurred.

Objection 5e] Wheel washing drainage.

The CMS fails to show how it will deal with the fact that LGS has no street drainage and buildings 650mm below street level. The excavation will cause mud on both Highgate Road and Little Green Street.

The CMS fails to locate a suitable wheel washing plant that will respect the restriction in relation to the trees, and manage the site entrance. No drainage proposals are included to stop mud washing down into Highgate Road where the only drainage gully for the whole area exists.

The environmental Health impact of the smell, the dust, the noise, the fumes are uncommented upon. All these things will invade our houses in this time to an unreasonable and unmonitored degree,

In conclusion, the CMS must be rejected for any one of the large number or grounds listed above and by others. Our human rights are not being respected in considering the impact of this ill-founded scheme on the residents and wider community.

It is simply not possible to construct the development that has planning permission.

The only conclusion is to find another route or another scheme.

Yours sincerely

Peter Thomas, Catherine du toit, Daniel [aged 8] and Atyeo [aged 2]