Dear Ms Castle

We are writing to strongly object to the Construction Methodology Statement (CMS) for the development of the former British Railway Club site adjacent to College Lane, NW5 in relation to Appeal Decision APP/X5210/A/02/1097183.

There are simple reasons why the proposed development makes no sense to anyone who knows the area and why the CMS has always been seen as a work of fantasy. At its core, the CMS should not be approved because:

• Little Green Street (LGS) is too narrow and fragile to support the construction traffic proposed and all new residents access traffic thereafter.
• The original plans that were submitted were factually incorrect, describing LGS as a 3m wide carriageway, when in fact it is 2.52m.
• The Health & Safety of all who use and live in LGS would be put at serious risk.
• LGS is part of the Dartmouth Park Conservation zone and is one of the oldest Georgian streets in North London . The very fabric of this area as well as the homes on the street would be damaged, potentially irreversibly.

Common sense dictates why the proposed plans are so vociferously opposed by residents and locals alike. However, in response to the recently submitted CMS, we would like to object to the following based on the Formal Decision by the Planning Inspector. As part of a ten-point recommendation, he stated that the development could not be granted if:

Point 5: “The statement shall include the measures to be 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”. This has not been adequately answered.

Point 6: “Development shall not commence until details of the junction of the proposed vehicular access and the highway and the turning facilities within the site have been approved in writing by the local planning authority”. This also has not been suitably dealt with and as detailed below, it has already been recommended that it is not possible to disrupt Highgate Road for the duration of the works.

These two points form the basis for our key objections.

Objection 1 - Access for construction vehicles

Little Green Street, part of the Dartmouth Park Conservation zone, is a single lane highway, deemed a ‘private driveway’ under planning guidelines, because of its narrow width. It is deemed suitable only for light vehicular access, pedestrians and cyclists.

The construction vehicle trips listed are a gross underestimation, the CMS states 9200 Trips (6.1 Table 1) that totals over 18,000 journeys past our home.

In an internal letter dated 12^th September 2002 , Stephen Burke from Camden Council states the road is highly unsuitable for the extra vehicular access required by the development, so how on earth can it now be suitable for over 18,000 heavy lorries over a 68-week period.

Michael Coombs also highlights in his letter dated 21 September 2007 , serious discrepancies that greatly increase any estimated journeys during the demolition, excavation and concreting phases.

Again, Stephen Burke carried out a safety audit on the street as a suitable access route for the development. He stated that “the narrow width of LGS makes it unsuitable for the passage of moving traffic’ based on Design Bulletin 32 1992. In addition he stated that ‘the applicant should prepare a Transport Impact Statement to include a safety audit of the access, as required by UDP policy TR19. Nowhere in this or past CMS applications has this been carried out.

Incredibly, Appendix 3 of the Scott Wilson letter dated 25^th June, included in the CMS, even states that “no road safety audit is required” at the proposed access site junction of LGS and Highgate Road . This is clearly ill informed.

The CMS has no margin for any error with the movement of these lorries, that is tens of thousands of trips over the development period and every one must make every turn perfectly and safely into and out of LGS, while negotiating heavy traffic on Highgate Road and pedestrian movement.

I have included a video with this submission of a lorry entering the street. This is simply to illustrate the turn required to enter the street and the proximity of the houses to the truck – particularly on the south side of the street.

Objection 2 – Disruption

The proposed Construction Traffic will impede on essential vehicular access to LGS; deliveries of groceries, parcels, furniture and white goods, access for essential property maintenance and repair, builders, gas, water, electric, cable utilities and any future need for scaffolding – all of these will need to be reviewed for how they can be completed.

How can we also access our street? Are we to assume that we cannot without permission for up to four years? If this is the case where can we park when dropping things off – not Highgate Road as this will be single lane traffic? This would be quite unacceptable.

Presently the aforementioned traffic must reverse out of LGS onto Highgate Road . What will happen during construction access? I presume lorries will have to queue on Highgate Road ? In addition the CMS states that the banks men will only be responsible for their own vehicles! (P.6 5.3).

There is also no mention of dealing with wheelchair or buggy access. We regularly have elderly relatives to stay who require walking frames and assistance as well as friends with young children. Access for them would be impossible to manage if works go ahead. We have no other entry or exit doorways into the building, so we would be both trapped in the building and kept away during the day when traffic is heavy.

Again, in the letter dated 12 September 2002 , Camden itself states that LGS is unsuitable for anything other than light vehicular access due to the possibility of 2 vehicles meeting each other on the street.

Have utility companies been informed? The utilities on LGS are unlikely to withstand this extra construction traffic. Our home has already had a collapsed gas mains in the street that has led to the closure of the street for over a week while the problem was rectified. Our water mains is also located in the street – the middle of the carriageway – no plans for managing this have been submitted should a new road surface be pit down.

The plans will be disruptive to those who use the street daily. A zebra crossing on Highgate Road , immediately as you turn right out of LGS is used regularly by pedestrians, school children, mothers, pushchairs, wheelchairs, elderly residents and cyclists and was originally positioned there for safety and convenience reasons.

A Pedestrian survey was undertaken and submitted to demonstrate local reaction and usage numbers. However, the survey was not independently audited and looking at the survey more closely reveals that the surveyor was acting for a company registered to the same business address as the developer.

In addition, they failed to record much of the pedestrian traffic on LGS that we have on CCTV time and date stamped. Finally on this point, the surveyor stated on several occasions that he would not record residents or visiting friends as ‘numbers’ – apparently this was not necessary.

Enormous disruption will be seen on the Highgate Road and all surrounding roads that will naturally become the new ‘cut-through’ for any traffic seeking to avoid the construction congestion. Current traffic at peak times on this road is often at a standstill, so any proposed single lane schemes, with speed restrictions and roadside barriers for a 68-week period is going to stretch this enormously.

There is also no reference to what emergency vehicles will do – as we have the Kentish Town fire station just a few hundred yards down the road, this will certainly be a problem. Have the local Police, Fire and Ambulance services been consulted? Have also Transport for London been consulted, as it appears suspension of bus lanes and cycle paths will be required?

Objection 3 – Damage to property

The CMS does not provide any sufficient measures to protect our historic property. Additionally, nowhere does the CMS provide conclusive proof that our Grade II listed home will not be damaged. Much of the terminology used is very vague and there are several gross inconsistencies.

The safe use of LGS frequently refers to damage to the road and pavement, not to our houses. It is Camden Council’s duty to protect our home and the historic nature of the site. Inflicting an unprecedented amount of construction vehicles within inches of our front doors and houses is not protection – negligence of a Council’s responsibility to safeguard constituents is a better description. We remind you our houses do not have foundations and rest on a clay bed that has already been shown in the Scott Wilson report to be considered as ‘soft’ and ‘easily moulded with fingers’.

While the vehicles are smaller and lighter, 18,000 trips will have significant impact on the structure of our homes. Furthermore, the likelihood of actually proving damage to our house because of construction access is slim and would require a protracted battle; the CMS states the developer will only be held accountable for proper and unreasonable use, how would this be proven within a court of law? What financial commitment is in place to protect our home? This is especially important, as our Insurer will cease our policy should these works go ahead.

It must be noted that the CMS references the Scott Wilson letter August 2^nd 2007 and reports that the properties of LGS are unlikely to suffer any damage due to construction traffic. It does not state this anywhere. It merely says vibration impact will be minimised. However, in the Scott Wilson letter dated 25^th June 2007 (based on the same light vehicular access) the report clearly says IT IS NOT POSSIBLE TO QUANTIFY HOW MUCH VIBRATION WILL BE GENERATED. Our home is not designed to withstand such a ludicrous amount of construction traffic or the cumulative affect of simply increasing the volume with a reduced weight travelling at low speeds. As residents, we can only describe what we see daily – a bus or lorry travelling along the Highgate Road can sometimes shake pictures of walls. If this is the case what will the traffic in the street do?

Finally, there is no mention of the subterranean River Fleet that passes at the top of LGS and down College Lane , or potential issues that may arise due to the water table. A number of houses in College have had excavation work carried out in the last 12 months and have hit problems with flooding or subsidence. Surely, deep excavation for underground parking would create similar problems. A Hydrology report would provide the details required here and we’re surprised that this hasn’t been submitted.

Objection 4 – Health & Safety

There is a clear disregard for the Health and Safety of all residents as well as pedestrians and road users of LGS, College Lane and Highgate Road . Simply put, the level of construction traffic and type of vehicles poses a real threat to all and will be only a matter of time before an accident, potentially fatal, occurs.

Number 3, as all other houses on LGS, has a front door that opens directly onto our living area. We will open this door into the proposed traffic flow, as have no alternative exits. The danger this creates is clear and for us too much, we will simply have to move for the duration of the works.

Objection 5 – Gross infringement

During the construction period we would be unable to sell our house for a period nearing 4 years. This is unacceptable. Circumstances may demand that we have to move in the future and with these works, it will not be possible.

We both frequently work from home. But the noise and environmental concerns raised by this volume of construction traffic, 50 cm from our front door would be completely unacceptable and render working incredibly difficult.

We also have a simple right to enjoy our home and feel safe and secure within it. Camden Council have a duty in their planning process not to infringe on Protocol 1 Article 1 of the Human Rights Act unless it is for the greater public good which this development clearly isn’t.

A person has the right to the peaceful enjoyment and use of their property. A public authority cannot impose restrictions on a person’s use of their property (unless proven for public interest).

The article requires public authorities to strike a fair balance between the public interest / common good and the rights of individual property owners. Being locked in our home by construction traffic for nearly 4 years is a gross infringement of this right. The guidelines on this act state a public authority must try to ensure that policies or decisions do not interfere with peaceful enjoyment of possessions or restrict the use of possessions. I expect Camden Council to uphold this.

Conclusion

Living with the shadow of the decision looming is deeply stressful, as is dealing with the paperwork, the constant objections and personal expense – we have spent a significant amount of money to consult with experts and carry out independent surveys. It must be noted here that the developer confirmed he would cover some of these costs, yet has so far reneged on any payments – is this a sign of things to come?

Camden Council do have the authority to reject this CMS, but have so far paid little attention to the absurdities of the plan and instead, support the process to complete the development. This is not a matter to be purely decided by Highways.

This is the third time we have objected; yet our arguments remain both consistent and clear. This time however, we fear that the plans submitted are regarded as a ‘done deal’ by the developer and Camden Council and therefore have, at our own expense retained expert’s witnesses to support our previous and recent objections. The very fact that all architectural, engineering, legal and to some extent political advise that we have sought has been supportive of our original arguments, rendering it all the more difficult to accept why this can be approved. Please recommend that an alternative route be identified and save Little Green Street.

We have never been ‘anti’ a development of the Railway club and have always been reasonable in our arguments. This should not be our problem, but one for the developer to reappraise his construction plans and question the need for underground parking and number of houses which we see simply as over development.

Good urban design, imaginatively approached, helps to make places more attractive and a pleasure to live in. Why can’t this problem be tackled with a pinch of creativity and a splash of common sense – everyone should then be happy?

Finally, please visit the petition hosted at www.littegreenstreetcom. This presents the measure of public opinion, with over 2,000 names unanimously and strongly in objection to the plans. It is clear that this is as much a political decision as well as a technical one that voters are monitoring.

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.

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.

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

4] Arrangements for those of restricted mobility

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 5] Measures taken to protect existing property and trees.

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]

http://planningonline.camden.gov.uk/WAM/showCaseFile.do;jsessionid=DB64AB3B89B1AFA373AA864A5E4FAD8B?action=show&appType=Planning&appNumber=2007%2F4036%2FP