I am writing on behalf of myself and my neighbours to express concern and register our objections and total opposition to the construction methodology statement that has been submitted to you to satisfy condition 5 of the planning permission granted on the above mentioned site.

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.