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 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.

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.

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.

The proposal to suspend the northbound bus lane and divide the Highgate Road into 3 lanes is even more alarming to the school. We are only one of 155 schools in London to have achieved the Sustainable Level in the School Travel Accreditation scheme but our work in persuading children to walk to school will be extremely difficult if the area is subject to dangerous traffic conditions, which will surely be the result of these proposals.

I did not address in my earlier letter Condition 6 (Section 40. (6)) of the Planning Inspector’s decision granting conditional planning permission of the above site which says that the “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” except to say that the information provided in the CMS was incorrect and that the police, fire and ambulance services and Transport for London had not been asked what they thought about the Highgate Road being obstructed for at least three years.

Having looked at certain papers that I saw when using the Freedom of Information Act 2000, I now see that the Council agreed Planning Officer Adele Castle’s suggestion, approved by one Tim Cronin, that the above condition had been complied with on 2 June 2004. That the Council should have agreed the recommendation, least of all that it should have been made, shows serious lack of attention to duty by everyone concerned.

The Delegated Report prepared by Adele Castle and authorised by Tim Cronin which is not dated but which bears the stamp ‘RECOMMENDATION AGREED ON BEHALF OF THE COUNCIL, 2ND JUNE 2004” says nothing about the junction of the proposed vehicular access and the highway — Highgate Road — except that “It is proposed to enter the site via the existing access from Highgate Road”.

I strongly object to what is suggested in the CMS, believing that much of the information contained in it is misleading or not correct and that what is proposed — that Little Green Street should be the access for construction traffic — would be a gross interference with my human rights to respect for my family life and home and peaceful enjoyment of the latter. I ask you to reject the application.

I should first say that I do not understand why any application or CMS is being considered. You know that the permission granted by the Planning Inspector was based on a mistake as to the width of Little Green Street and/or cannot be put into effect. The permission granted was said to take into account or to comply with Design Bulletin 32 — Residential Roads and Footpaths (DB32) which states that a road or carriageway that is less than 2.75 metres wide may serve as a private driveway (not as the access to a car-park for over 20 cars, least of all to a construction site). The information provided by Camden Council was that the street was 3 to 3.6 metres wide and an extrapolation from Ordnance Survey maps suggests that it is 3 metres wide and has pavements 1.6 metres wide. It is, in fact, 2.5 metres wide and has little or no pavements on either side. The Council should have used its power to revoke or modify planning permission under Section 97 of the Town and Country Planning Act 1990 long ago.

I refer to assertions made and information given in the CMS

1. Section.1 .1 of the CMS states that Little Green Street will be the access to the site and that there are “no alternative routes available for access” because Camden Council has refused access through the lngestre Estate on health and safety grounds. I do not think that the development in its present form should ever be permitted but the idea that access through Little Green Street, through which most people from the lngestre Estate, those living on College Lane and the street itself and others pass, is healthier or safer than through the estate is absurd. The roads on the estate are the usual width of a road, unlike Little Green Street, and have pavements, etc.

2. It is said in the CMS, S.4, that “it is essential that road surface improvement works be undertaken in the near future to improve the quality of the surface and its appearance”. Essential to whom? I and anyone that I know who uses Little Green Street are quite happy with the road as it is.

3. The fact that the proposed developers have found a lorry that weighs only
6.5 tons and could apparently travel up and down Little Green Street without mishap does not mean that the new CMS is in any way acceptable. 5,400 trips of the vehicle, (S.6.1), an extraordinary number of movements by a vehicle that will prevent any other movement on the street, or more than half of proposed trips, have largely to do with excavation for an underground car-park. Why is a supposedly environmentally conscious Council considering allowing this sort of disruption for people who live on and use the street for a car-park? Any development should surely be car-free?

4. S.9 of the CMS makes it clear that far larger and heavier vehicles will actually be used. As someone who watched the small vehicle used by the proposed developers when making exploratory holes in Little Green Street almost crash into a wall of No. 124 Highgate Road and have to manoeuvre back and forth into Highgate Road, I wonder what is going to happen when such a vehicle comes down the street.

5. In S. 14 to S.16 of the CMS it accepts that the development will involve a “trip” of a lorry through Little Green Street every 15 minutes, every weekday for at least three years, more likely three years and seven months. Each trip will, in fact, be two passages of any vehicle, i.e. a vehicle every 7and I2 minutes, if the figures given in the CMS are correct. This cannot be acceptable. I refer later in this letter to the breach of the human rights of residents of Little Green Street that this means.

6. S. 20.2 of the CMS asserts that “the properties of LGS are unlikely to suffer any damage due to construction traffic”. This is an astonishing assertion given that the houses have, to date, weathered on the road two feet or less from their walls only the smallest of rubbish collection or delivery lorries three times a week, not anything like what is implied by construction of the development through Little Green Street. The information provided as to access to Little Green Street from Highgate Road, where larger vehicles are to be waiting, is not correct; it makes no mention of the effect on the road of water filled barriers and their effect on the bus lane and police and ambulance services which use Highgate Road every day. I understand that, extraordinarily, none of the police, the ambulance or fire service or Transport for London has been told that the proposed development involves the obstruction of Highgate Road for a minimum of three years. Planning decisions have to take into account the human rights of those affected by them, specifically, Article 8, the right to respect for private and family life, one’s home and correspondence, and Article 1 Protocol 1, the right to peaceful enjoyment of one’s property or possessions. A public authority may not interfere with the exercise of these rights except for reasons of national security etc. and any interference must strike a “fair balance” between the public interest and individuals’ rights. No thought at all has been given to the human rights of the residents of Little Green Street by those preparing the CMS except that in S.22 it is said that “upon completion of construction work” any damage to the houses on the street will be made good and there will be insurance to cover this. Our rights will clearly be breached.

If the CMS were approved, the residents of Little Green Street would, effectively be imprisoned in their homes for three or four years. The street and its paving are so narrow that it can be difficult to leave one’s house if a lorry is in the road, least of all to go up or down it. No one with a child or with any disability would be able safely to go out. The noise would be intolerable; the structure of the street means that noise reverberates. The dust and dirt would be ghastly. Any passing lorry blocks out the light of downstairs rooms. The Grade 11 listed buildings are likely to be damaged, either by a lorry driving into one or as a result of constant vibration; construction experts consulted by people living on the street believe they will be. If my house, which has original 1760’s beading and woodwork, is damaged it will not be easy to repair and what are residents to do if their houses are damaged and the proposed developers expect to carry out remedial work only once construction is completed? My husband and I may want to move in the next few years. Apart from the impossibility of selling our house if a construction vehicle is to be passing every few minutes and the effect on its price, any removal van would have to battle with the builders’ lorries.

The interference with residents’ rights to respect for and peaceful enjoyment of their homes will be excessive and is not balanced by any public interest associated with the development of the Railway Club site as presently proposed. The payment of compensation would not make the disruption implied by approval of the CMS acceptable but those who will most suffer the effects of it have not even been offered compensation to make the interference with their rights more proportionate as the law and the Council’s duty of care require.

I ask you to reject the CMS dated 1” August 2007 and finally to recognise that the permission granted by the Planning Inspector cannot be implemented.

John Davies Development Control Team Town Hall Extension, 6^th Floor

Stephen Burke, Ext: 5896

12^th September 2002

Former BR Staff Association Club, College Lane , NW5

Demolition of vacant clubhouse and construction of 20 mews houses arranged in terraces of 2 and 3 storeys with lower ground levels and a block of 10 flats comprising studio, 2, 3 and 4 bedroom fiats. The provision of underground car parking with ramped access from the site entrance off Little Green Street

Reference: PEX0100663/R2

Key points:

1. Highgate Road is heavily trafficked. The most recent screen line count was taken in 2000, at a point just south of Little Green Street. This gave a 2-way 24 hr traffic flow in excess of 10,000 vehicles per day and 2-way hourly flows varying between 9.00 and 1,100 vehicles per hour.

2. The applicant has produced a report detailing the expected traffic generation for residential use and various uses under Use Class 02.

Transport observations

Introduction

The application is to redevelop a backland site to the east of Highgate Road for housing. The site was formerly used as a social club but has lain vacant for some time. The proposal would comprise 30 dwellings with 13 parking spaces,

Traffic generation

I have interrogated the TRAVL database for surveys of residential sites in London and the average trip rate was 2.0 two-way Journeys per dwelling per weekday. Some care is needed in applying these rates. Trip generation is largely determined by car ownership, which would be restricted in the proposed development. Obviously, the application of these rates to the whole site would produce an over estimate since many of the units would be car-free. We could just apply the rate to the units with parking. However, since residents would pay a premium for theses units, the level of car owner ship is likely to be high, i.e. approaching 100%. However, the average level of car ownership of sites in the London survey was only 58% so this would result in an underestimate. A correction could be made by factoring up the trip rate by the level of car ownership in the surveys. This would give a trip rate 3.5 two-way journeys per dwelling per weekday.

Taxi trips were recorded separately in the TRAVL surveys. The average London rate was 0.05 trips dwelling per weekday, although this would probably be higher with car-free housing, say 0.1 trips dwelling per weekday.

Deliveries were not included in the surveys.

The expected generation would be around 50 two-way journeys per weekday.

Access.

It is proposed to use Little Green Street as a vehicular access. Little Green Street is an adopted highway with a narrow footway on the northern side. The width of the footway varies between 0.8 and 1.3 m and the width of the carriageway varies between 3.0 and 3.6 m. The carriageway is less than the minimum width required for two vehicles to pass. Little Green Street is a pedestrian through route, which links both College Green and Ingestre Road with Highgate Road . A zebra crossing has recently been placed in Highgate Road , opposite Little Green Street, in response to pedestrian demand.

The narrow width of Little Green Street makes it unsuitable for the passage of moving traffic. The minimum width given in Design Bulletin 32 1992 paragraph 3.17 is the width necessary for two vehicles to pass on another, i.e. 4.1 m.

Design Bulletin 32 1992 provides scope for narrowing to as much as 3.0 m in special circumstances with certain provisos. The first being that the narrowing should be no more than 15 m in length and atso there should be suitable passing bays (DB32 Paragraph 3.20). Neither of these conditions would be met on the proposed scheme since the narrow carriageway would be approximately 65 m in length.

The problems associated with the long single carriageway are as follows.

• Vehicles will inevitably meet on the access road.

• Neither vehicle would have priority so it would be unclear which one should reverse.

• Both reversing manoeuvres would be unsafe. The vehicle intending to leave the site would have to reverse around a corner into a pedestrianised area. Alternatively, the vehicle intending to enter the site would have to reverse back over a pedestrian footway and into to Highgate Road . This would endanger both pedestrian and traffic in Highgate Road . Highgate Road was a heavy traffic flow throughout much of the day. The driver may have a considerable wait for a suitable gap to appear in the traffic flow.

Furthermore, it would be necessary to reverse onto a zebra crossing, presenting an additional hazard to pedestrians.

• Vehicles approaching the site from the southeast would have to wait in the middle of Highgate Road for an opportunity to turn right. Following the recent installation of a zebra crossing, the point where vehicles would wait is now an area that should be kept clear and has the appropriate zigzag demarcation. Waiting vehicles would obscure both driver and pedestrian and visibility, thus compromising safety for the users of Highgate Road .

• Drivers about to turn right into Little Green Street would need to concentrate on the oncoming traffic, awaiting a suitable gap before proceeding. If an exiting vehicle were to appear in Little Green Street at that point in time, as it conceivably could, the right turning driver would be faced with a difficult dilemma. Stopping immediately could place the right- turning car in the path of oncoming traffic while proceeding would place the car in direct conflict with the exiting vehicle, since there is no space on Little Green Street for either vehicle to wait.

• Even if a directional priority were to be applied to Little Green Street through a Traffic Management Order, it would only apply to the access road but not to vehicles approaching from Highgate Road or the private land within the site. In any case, such orders are normally only applied where there is a safe space for vehicles to wait.

The proposed development would result in the access road taking two-way traffic and as shown previously, the expected traffic flow would not be insignificant. The safety hazards detailed above mean that the access is clearly unsuitable for the proposed use. I would therefore recommend a refusal on the grounds that the site does not have a safe access.

Refuse collection

The drawings show a "turning circle" at the northwest end of the site. The area is lot adequate to allow a refuse vehicle to carry out a three-point turn. Without a turning facility, refuse vehicles would have to reverse considerably longer the K3m distance recommended by DB32 Paragraph 3.55. To overcome this problem, there would need to be a suitable turning head, preferably on adopted highway. This would involve the creation of a new section of highway through an agreement under Section 38 of the Highways Act linked to a S106 agreement. The developer would need to dedicate the land and fund the highway works. Highway Engineering would need to be consulted.

The maximum carry distance between a bin storage area and a refuse vehicle i s governed by UDP Standard DS9, is 25m. The bin area shown at the Southwest corner of the site greatly exceeds this distance.

Access for fire appliances

London Fire & Emergency Planning Authority (LFEPA) Fire Safety Guidance Note 29 recommends that turning facilities required on a cul-de-sac exceeding 20m. Accordingly, the turning facility referred to previously in the section on Refuse collection should allow a fire tender to execute a three-point turn.

There are different standards governing the access width required for fire tenders. BS 5588-1:1990 recommends a minimum carriageway width 3.66 m, or 2.75 m if it is clear of parked cars. LFEPA recommend a minimum carriageway width 3.7 m. London Fire Brigade should be consulted since the access does not satisfy the most stringent of these requirements.

The maximum fire hose distance between the tender and the front door of any dwelling, recommended by both BS 5588 and LFEPA is 45m. This clearly cannot be achieved with the proposed layout.

Assessment and Comparison of Traffic Generation Potential

The above document, dated January 2002, has been submitted by Buchanan Consulting Engineers. The document compares the traffic generation of residential development with potential uses within Use Class D2.1 would comment as follows.

• The current traffic generation of the site is zero and has been for some time. No information is provided for when the site was last in use. Therefore a valid comparison has not been made between the existing and proposed scenarios.

Within the report, an attempt has been made to predict the potential traffic generation for a fitness centre and a community centre by extrapolating values from a national database (TRICS). None of the sites in the database are in London ; they are located in areas that are more car dependant. Similar sites in London would probably have a lower generation rate.

The sites in the database were presumably a) built in areas where there was a verified demand and b) were successful. There is no evidence to suggest that similar activities in the application backland site would be as successful in generating patronage. The questionable suitability of the site together with the use of out of London data suggests that the generation rates have been over estimated.

Any attempt to resurrect the site for D2 use would probably be subject to

planning approval and the safety of the access would need to be assessed as part of the approval process. This could lead to a refusal.

• No data is given on the level of car ownership for the residential sites in the (TRIGS) survey but as with the TRAVL database, it was probably considerably less than 100%. The generation data has been applied only to the component of the development with parking, where car ownership is likely to be 100% but using data from housing with a lower car ownership. The result is that the residential traffic generation has probably been underestimated.

• The survey takes no account of deliveries or taxis and these would also add to the total traffic generation.

I understand the applicant would be likely to appeal any refusal. We should then set down certain requirement in case a future appeal is allowed.

• There needs to be an adequate turning facility for refuse collection vehicles and fire appliances.

• The site needs to be subject to a car-free / car-capping agreement.

• Refuse should be stored within carry distance of collection vehicles.

• The required distances between fire appliances and dwellings should not be exceeded.

• 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.

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

Date of consultation letter received: 10 September.

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

Summary

The Planning Inspector clearly realised that access would be a potential barrier to development, and so insisted on a suitable construction methodology as a precondition to any development. The previous draft CMS methodology contained inadequate information; the current more detailed (but still often inaccurate) information conclusively shows that it is not possible to use Little Green Street as the access for construction of the proposed development. The detailed proposals fail to ensure the safety of residents and other pedestrian or cycle users of Little Green Street and College Lane. They disrupt a major and heavily used part of the strategic footpath network. They fail to show that the listed houses in Little Green Street will not be damaged. They will not enhance the character of the conservation area. In addition the proposals would have clearly unacceptable impact on traffic and safety for users of Highgate Road for several years. The proposals are not merely inconvenient; they are clearly unsafe.

The access problems show that a fundamentally different design is needed if there is to be successful and safe development on this site. It is not the job of the Council to seriously compromise on safety, risk destroying part of a unique conservation area and severely inconvenience the many thousand daily users of Highgate Road and surrounding streets in order to help the developer. It is the job of the developer to show that he can safely fulfil the condition. He has failed to do this; he should stop trying to defend the indefensible. He should instead look again at what development is possible, given the fundamental constraints on access to this landlocked site. If he is not able or willing to do this, he should sell the site to a developer with the capability of so doing.

Michael Coombs has already submitted an objection on behalf of Little Green Street residents that I fully support. He addresses the fundamental issues about the inadequate width of the road and the dangers to the historic buildings. This rest of this letter covers additional issues.

Additional points of detail.

1. The proposals will cause horrendous traffic problems on Highgate Road for at least 68 weeks (taking the developers own figures) and probably at least double that (taking the revised figures suggested by our analysis of the spoil and trips required).

The water filled barriers and proposed one way traffic system (which requires effective single traffic for considerably further than the barriers) will:

Mean the loss for the duration of the current bus stop near to Little Green Street – it cannot be relocated, because of the current refuges, roads and driveways.

Mean more serious tailbacks and congestion; already traffic queues in the morning can back up as far as the current bus stop near Little Green Street. There will be an impact on emergency vehicles – Highgate Road is often currently used for police and ambulance in particular, because of the location of the Royal Free hospital.

Disrupt the existing on street deliveries to the shops on Highgate Road.

Extend and disrupt travel to school patterns for thousands of children who use buses or are driven up or down Highgate Road, and for many commuters who take the 214 and C2.

The narrow width of the single lanes that will be left after the barriers are erected will not allow cars and buses to overtake bicycles. Cyclists will be at risk, as cars will undoubtedly still try to overtake.

The full extent of traffic disruption is nowhere highlighted in the CMS; indeed, proposals for traffic management are inaccurate and unworkable in several key places. The level of disruption is either not understood (in which case there should be grave doubts about the entire proposed traffic management plan is clearly inadequate) or has been deliberately ignored (in which case the CMS is clearly inadequate).

For example, Item 7.7 of the CMS refers to drawings as illustrating the ‘suitability of the selected 6.5 tonne (most frequently used) vehicle for turning in and out from HGR into LGS. It shows instead the problem. If the exit tracking is the same as the entry tracking, each left turn into Highgate Road (CMS item 1.2) will sweep across the northbound lane in Highgate Road, against the direction of the traffic at a frequency of 1 every 8 minutes. Highgate Road can be busy at all hours.

This is not the only inaccuracy in the traffic management plans for Highgate Road; for example, the dimensioned width of Highgate Road shown on drawing 001 is incorrect, and the clear lane widths are un-achievable.

2. There is no safe refuge provided or proposed for pedestrians in Little Green Street. The scheme fails to provide for safe access and egress for residents and visitors, particularly serious for any with a disability requiring a wheelchair or walking frame, or those with a large or double buggy. I cannot see how the proposals meet provisions of the Disability Discrimination Act.

You cannot get a wheelchair or a double buggy (or indeed many single buggies) on the narrow pavement in Little Green Street (the bay windows, lampposts and bollards prevent it) and you cannot pass a bicycle or single buggy on the pavement without stepping into the street. Those who use walking frames also often have to use the road surface.

The developer says that a ‘safe refuge’ is not necessary because two banksmen will always ensure pedestrian priority. But they will not know when a resident or visitor wishes to leave a house. People and their accompanying wheelchairs, buggies, bicycles etc will have to leave the houses first and attract attention somehow – without there being a safe refuge to go out onto. A safe refuge is needed on both sides of the road (severely reducing the available width) as on both sides of the street there are front doors opening immediately onto the road from houses with NO alternative access.

In addition, a banksman cannot see who is walking along College Lane while they are also looking at who is exiting the main site. College Lane pedestrians will be able to – and given the number of children and young people in the area undoubtedly will - walk into and across Little Green Street at the same time that vehicles are being let into it.

3. The hours of work are suggested as being‘ outside’ peak pedestrian useage – but include one of the two peak times for that useage

The (incomplete) pedestrian survey shows that peak afternoon useage is when school finishes – that is, between 3 and 4.30. So the proposal to finish using the street for access at 4.30 does not (as it suggests) deal with the school collection and pupils returning home peak time.

(P. S. Those who live in Little Green Street or were visitors to houses in the street were not counted as street users in the survey.)

4. Camden Council’s own officers have made clear that the current proposals for construction access are unsafe.

a) In 2002 the Council’s own traffic planners produced a detailed memorandum that concluded that ‘the site does not have safe access’. It also suggested that a Transport Impact Statement and Safety Audit of the access were required so that ‘the safety auditor could be liable in the event of a claim being made against the Planning Authority, following an accident attributable to the layout of the access’. [1]

There is no such safety audit – presumably because any professional would take one look at the proposals and realise that accidents attributable to the layout were likely, both during and after construction.

b) In 2007 the estate officer for Ingestre Road replied to a developer request for consideration of access through Ingestre Road estate. The developer has submitted the exchange as part of his evidence.

She replied in writing that the Housing Department would not consider it because the health and safety of residents and those who used the estate as a cut through between Acland Burgley and Highgate Road, including many children, came first.

The relevant road access via Ingestre Road estate is twice as wide as Little Green Street and has adequate pedestrian refuge space– either a double width pavement or a full width pavement on both sides of the road. All those who use the estate roads as a cut through between the state and Highgate Road also use Little Green Street as part of that cut through. If the view of the Council is that use of estate roads cannot be contemplated because health and safety is paramount, it is difficult to see how the Council can argue that Little Green Street can be safely used.

5. Camden Councils own published standards suggest that the road is completely unsuitable for use by construction traffic.

In ‘A Plan For Camden – The Environmental Code’ the Council discusses 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’. Little Green Street is part of such a 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 houses serviced by Little Green Street (in Little Green Street and College Lane) have been completed for between 100 and 200 years. The CMS clearly fails to resolve the issues covered 36.2 and 37.1.

6. Comments about the previous and current impact on the area of the site are incorrect.

I have lived at No 5 Little Green Street for over 15 years, and experienced the former British Rail Staff Club in operation and the subsequent slow deterioration of the empty site.

a) The developer suggests that the site is an eyesore that he should be allowed to improve. It is only a partial ‘eyesore’ because as owner he has carried out no regular maintenance and allowed some build up of uncleared rubbish and untamed plant growth. Given that most of the site is hidden by a hedge (maintained by College Lane residents, not the developer) the site is not a particular problem for the area, and that partial problem is not difficult to solve.

b) Former lorry useage was one open backed lorry at most twice a week –with a driver who knew the route. Former car useage was not trouble free – especially when cars met in the street and one had to back. Damage to one or other car was not uncommon. Luckily it was limited; and they were cars, not lorries. The bollard at the entrance to Little Green Street was almost permanently broken because it was hit so often.

Conclusion.

The detailed proposals in this CMS are still inaccurate, showing that the developer does not employ suitable professionals. Even the inaccurate details submitted show that access using Little Green Street as proposed is dangerous and unacceptable. The CMS should be refused.

[1] Memo from Forward Planning and Projects Transport Planning, 12/09/02