Dear Ms Castle,

I wish to object to the latest Construction Methodology Statement (CMS) for the development of the former British Railway Staff Club in College Lane NW5 which was prepared by PTP Architects in relation to Appeal Decision APP/X5210/A/02/1097183  

This CMS appears to address condition 5 of the inspector's report, specifically "The statement  (CMS) shall include the measures to be taken to protect existing property, the access arrangements for demolition, excavation and construction the hours of work parking of vehicles and the delivery of materials and plant to the site."

The CMS says nothing about condition 6, which concerns proposed vehicle access and turning facilities. I assume the developers will be submitting their plans for those separately. The inspector acknowledged the huge difficulties of using Little Green Street for any vehicles, which is why he included these conditions. The trouble is he made two serious errors when compiling his report, which fundamentally effect the practicalities of meeting the conditions.

The first error is that he made his decision on the assumption that the carriageway of Little Green Street was 3m wide. It is 2.52m wide.

The second is that in his explanation of how vehicles are to get in and out of the site he wrote (para 24):

 "I appreciate that the road is not sufficiently wide for two vehicles to pass and that on occasions it would be necessary for vehicles to wait at either the north-east end of Little Green Street or in Highgate Road. In this regard the visibility along Little Green Street is good when either emerging from the appeal site or when entering Little Green Street from the south along Highgate Road. There would be adequate space for a vehicle to wait near the entrance to the site or within the main road and as the street is less than 40m in length I do not consider that the waiting time would be unreasonable, even where a service vehicle may be involved."

That is plainly factually incorrect. No-one emerging from the site entrance can see the bottom of Little Green Street until they have turned almost a 90 degree corner into Little Green Street. The entrance to the site is parallel to College Lane, at right angles to Little Green Street, and set back from Little Green Street by several metres. Equally, anyone driving into the site from Highgate Road cannot tell whether anyone is coming out of the site until they have reached the top of Little Green Street. Waiting at the entrance from Highgate Road will tell you nothing. We see this every day when visiting trade vehicles, stuck for a loading or parking space, take a gamble on parking just outside the site gate. It is impossible to tell whether that "parking space" is occupied until you have reached the top of Highgate Road, by which time it is too late, and they have to reverse all the way back into Highgate Road.

The developer makes a big deal about his banksmen ensuring the protection of pedestrians between the hours of 9.30am and 4.30pm but later admits that there will be "no noisy work outside the hours of 8am to 6pm and 8am to 1pm on Saturdays". The CMS says nothing about how vehicles will be controlled during those hours or what will happen as construction workers get to and from work.  In referring to the vehicle use after the proposed development being the same as when it was in use as a club, the inspector fails to point out that the club was only ever in use on Friday and Saturday evenings.  At the time, contrary to folklore, it did cause quite a lot of angry reversing as visitors tried and failed to enter or leave the club in one uninterrupted journey. I realise that it is too late to challenge the factual errors contained in the inspector's report and overturn his decision, but that does not mean that those factual errors have gone away.
Just because he thought the road was bigger than it is doesn't mean that it is big enough. And just because he thought visibility was good when emerging from the site (para. 24) doesn't mean that it is.

Here's why Little Green Street cannot be used as an access route for construction vehicles:

1)    The basic geometry of Little Green Street and Highgate Road make the safe operation of works as proposed impossible. Little Green Street is too narrow and Highgate Road too busy to accommodate the size and frequency of vehicles required. See Michael Coombs's letter for details.

2)    Even as claimed, the proposed frequency of vehicles proposed for Little Green Street  in Phase 1 (demolition and excavation) is unfeasible, unworkable and unsafe. It would mean lorries making an unknown number of trips (is it four is it 7 ?) an hour up and down Little Green Street for a minimum of 68 weeks, with other, unspecified construction vehicles travelling up and down for almost four years. Even the smallest lorries the developer plans to use fill the carriageway completely leaving no room for pedestrians, cyclists or pushchairs.

3)    The developers have got their sums wrong again. Michael Coombs shows that in working out the frequency of the vehicles using Little Green Street the developers have confused the number of lorry loads (involving one vehicle in and one out) with lorry trips (a single journey). This means they will either have to double the 68 week demolition and excavation time, or double the number of lorries they use.

4)    Little Green Street was only ever considered as an access route because the developer thought the road was 3-3.6m wide when it is in fact only 2.5 to 2.9m wide. The developer's futile attempts to try to overcome that basic mistake has led to the ludicrous proposal that a road classified as suitable for "occasional domestic vehicles", the same as a domestic driveway, should now accommodate enough vehicles to demolish and excavate a 0.35 hectare site and build twenty houses, ten flats and an underground car park on it.

5)     The CMS only gives details of how the developer thinks he can get the smaller lorries in and out of Little Green Street,. It gives no details of how he intends to get the larger ones, including low loaders, a concrete batching plant, and a pile driver, in and out.

6)     The proposed CMS fails to record the water table which could lead to disastrous flooding to the houses in College Lane and Calver Court.

7)     The CMS fails to include the protection of the trees both on and off the site (If, as it claims, the CMS will abide by BS5837 (Trees in relation to Construction recommendations)  the developer would not be able to excavate or disturb the ground in any way within a 12.6m radius of the London Plane Tree protected by a tree protection order just inside the entrance of the site. That would make the excavation of the underground car park impossible.

All these technical points and more are included in Michael Coombs' letter attached. Even if these problems were ever solved, the developer's proposals would still represent an unacceptably dangerous, disruptive, environmentally and socially intolerable idea for the following reasons:

1.    While the developer demolishes the club and excavate the underground car park, the road will be impassable to anyone but the developer and his staff. By the developer's own admission no-one living in Little Green Street would be able to leave their house between the hours of  9.30am and 4.30pm Monday to Friday for at least 68 weeks  without the aid and permission of a banksman with a flag. Michael Coombs has already shown that the excavation is likely to take twice as long, and  the developer's own figures say the construction will take almost four years. We have four children aged between three and 14 and the idea that we all have to open our front door directly into the path of lorries for four years is ridiculous, dangerous, and unreasonable.

2. The same restrictions would apply to any of the hundreds of pedestrians, cyclists,  and babies in prams who use Little Green Street every day to get from Ingestre Road, Fortess Road, and College Lane into Highgate Road.

3. As well as physically preventing people from using the road safely and normally it would present an unacceptable level of noise, disruption and general chaos to an otherwise safe and quiet cobbled lane.

4. Despite the developer's assurances that using smaller lorries will protect the ancient and fragile houses in Little Green Street from damage of vibration we have no way of knowing what the cumulative effect of so many lorries will be.  

5. With so many lorry journeys over such a long time trying to fit into such a narrow space, it is inconceivable that drivers, however careful and conscientious, will not have an accident.  A commitment to repairing any damage is meaningless. The people living in and around the road, and the houses along it, are irreplaceable.

6. The futile attempt to pretend that Little Green Street is capable of carrying construction traffic involves the colonisation of Highgate Road to a dangerous and unacceptable level, Not only will the north bound bus lane be suspended for over a year to accommodate one person's overblown ambitions, but the lane widths will have to be physically narrowed by water filled barriers to an unsafe and unacceptable width.

In their misguided attempt to use vehicles which they believe can fit down Little Green Street, the developer is hoping to extend the construction period to almost four years - inflicting an intolerable amount of noise dirt and disruption to everyone living on Little Green Street, Ingestre Road estate, College Lane, Highgate Road and Lady Somerset Road.

Despite a promise secured by Frank Dobson from Moira Gibb that this CMS would be considered as a health and safety, conservation and environmental problem, Camden Council appears to continue to treat this as a fascinating engineering problem to be solved, rather than a misguided, dangerous and futile idea, which can and should be thrown out.  The planning inspector gave planning permission for the development on condition that measures were taken to protect existing property, the access arrangements for demolition excavation and construction vehicles, the hours of work parking of vehicles and the delivery of materials and plant to the site. And that those measures be approved by the local authority. There is no way the proposals as set out in the current CMS can be approved.

I have a job, a family and plenty of other things I would rather be doing rather than getting up at 5 in the morning to plough through piles of paper to prove the blindingly obvious. Please throw this out once and for all.