I write on behalf of the association. Having met, we object to the Construction Methodology Statement (revised 7^th August 2007) on the following grounds.

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.