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.

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