Details of the construction methodology statement (revised 7^th August 2007) pursuant to condition 5 of planning permission dated 23/06/03

(Reg. No. PEX0100663R2) for the erection of 20 dwellings.

I object to the application for the reasons set out below.

I have lived on Little Green Street for over 20 years, and experienced the Former British Rail Staff Club in operation and the problems with vehicular traffic, which the handful of cars associated with its use, managed to generate on a regular basis, including vehicular damage to my property (Metropolitan Police Report No C1514). The CMS proposes that Little Green Street is to be used as the main construction access for tens of thousands of construction vehicle movements over the next three to four years without affording a segregated pedestrian access or identifying proposals to overcome the risks to damage to property as a result of this proposed use of the street.

(CMS Appendix 2, Revised Traffic Calculations 10-7-07, Schedule No 1 – minimum programme Updated 2August 2007)

Little Green Street forms part of the strategic pedestrian footpath network at the crossroads of routes linking the older north-south College lane route continuing into Grove Terrace and onwards to Hampstead Heath with the east-west route from Tufnell Park, to the shops, schools and transport systems of Highgate road. The physical constraints of Little Green Street render the footpaths dysfunctional for the majority of users, making the narrow single lane carriageway, a shared surface.

Little Green Street is also a Cul De Sac which presents further difficulties for the proposed CMS to resolve, and at this point I am mindful to remind the Council of previous advice published in ‘A Plan For Camden – The Environmental Code’ with regard to the special problems associated with dead end streets and the need to create a safe environment for pedestrians. Item 36.2 states ‘The shared surface should not be part of a strategic footpath network’. Item 37.1 concerning vehicular movement, advises that in design, it is necessary to avoid the need ‘during construction for builders’ vehicles to use the roads servicing completed buildings’ The CMS, part of the design documentation, fails to resolve either of these issues. I am not aware of any standard that reduces these quality aspirations.

It would appear that the main failing of the CMS is that its preparation has been separated completely from the design process of the project, and is exposed to address risks which could have been designed out. The document is an afterthought chasing its own trail of cause and effect. The statistics involved are truly are staggering:

• In order to prepare the gently sloping site just to be able to begin construction, the volume of waste material to be excavated is the equivalent of 85 times the total volume of my house - the associated vehicles all passing within the length of an A4 sheet of paper from my living room and bedroom windows at a sustained rate of 1 every 4 minutes for the first 68 weeks of a total programme which extends into a fourth year.

• The open cast excavation of 1600m2 to a depth of 3.8meters leading to a further 285 m2 to a depth of 4.5 meters deep will require substantial perimeter retention especially along the southern site boundary, a dewatering system and some powerful machinery to maintain the supply rate of predicted vehicular movements in and out of LGS onto Highgate Road. ( Appendix 11 Excavation drawing No1). The CMS shows no planned location for the significant wheel washing operation which the heavy flow of vehicles will demand if LGS is not to become a river of mud flowing into Highgate Road.

• The Appeal Decision which requested the CMS under Condition 5, either recognised the impossibility of the delivery aspect of this project and selected to disguise it by the requirements of the Condition, or simply got it wrong. I favour the latter.

• The width of Little Green Street. (Appeal Decision item 23), is critical to the evaluation of its suitable use. The Decision Report refers to DB32 and yet the fact that the width of the street was not checked by more than one responsible party is a sign of the lack of due care expressed in the preparation of the proposal, and is further evidence of the separation of the construction methodology from the design.

• Appeal Decision item 27 states that ‘I have therefore concluded that the proposed development would not be unduly harmful to the Highway safety in Little Green Street or the free flow of traffic in Highgate Road.’ Whilst I appreciate that this statement may relate (incorrectly in my view) to the completed development, it shows a lack of understanding of the disproportionate and irreparable cost to the established environment necessary in order to secure the development in the first place. DOE Area Improvement Note No 9 states ‘..the intrinsic character of an area gives it its identity….obviously such character must not be swept away in the name of improvement’ The separation of the CMS from the scheme design continues through the lack of imaginative thought which the Appeal Decision item 16 cites as being needed, but without compromise to the environment.

• There will be major risks to the safety of pedestrians in LGS and considerable disruption to traffic in Highgate Road for years during construction and beyond the completion of the development. Priority control over the shared access will no longer be self regulating. Essential services to LGS and College Lane will threaten access to the development. The CMS illustrates the potential for chaos in Highgate Road in Appendix 3, drawings CS-025562/001 – 004 all revision A. The dimensioned width of Highgate Road shown on Drg 001 is incorrect, and the clear lane widths are un-achievable. There is no attempt to segregate vehicular construction and pedestrian traffic either in LGS or at its junction with HGR.

• Item 7.7 of the CMS refers to the above drawings as illustrating the ‘suitability of this (the selected 6.5 tonne most frequently used) vehicle for turning in and out from HGR into LGS. It does not. If the exit tracking is the same as the entry tracking, each left turn into HGR (CMS item 1.2) will sweep across the northbound lane in HGR against the direction of the traffic at a frequency of 1 every 8 minutes. Nothing in the submissions to date associated with this development encourages me to believe that the developer understands the implications of the operational requirements to maintain the implied frequency of traffic movements or the impact on Highgate Road.

• Protection to the London Plane Tree covered by a TPO is alluded to but the implications of compliance with the requirements of BS are not demonstrated to have been understood.

• Despite the heavy traffic flow immediately adjacent to listed buildings and those over 150 years old no surveys have been carried out.

• Consultation with the Police does not appear to have taken place contrary to the statement in Appendix 3 item 4, p4/6 which states ‘Prior to any formal applications being submitted the Police will be consulted for their views on safety and traffic matters’

Nothing in the CMS has altered the statements and conclusions contained in the internal LBC report dated 12 SEPT 2002 to the Development Control Team from Forward Planning and Projects Transport Planning which concludes that the application be refused on grounds that ‘the site does not have safe access’.

The community surrounding the application site is at a loss to understand why the implications of incorrect data should be continually transferred down through the democratic process to the last responsible moment, without anyone in authority having the power to intervene, to stop this madness.