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.

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.

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?

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.

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.

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.

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.