Here’s the statement I gave at the public inquiry this week into the proposals for a concrete factory in Cranford Way, Hornsey:

As Member of Parliament for Hornsey & Wood Green, the western side of the application will affect many of my constituents, who have made it plain to me – as I am sure they will also do to you, that they believe, and rightly in my view – that should this inquiry overturn Haringey Council’s decision to refuse planning permission it will mean that their quality of life will be greatly diminished.

Whilst there are issues of noise, pollution and ecology – I leave those to be argued by experts as to their calculated impact and to local residents as to their perceived impact but to speak to the areas where I have more specific knowledge – the Mayor’s strategies and traffic.

I want to start with the opening statement from Queen’s Counsel for the appellant.

The opening thrust of the statement was about the importance of sustainability and how the Mayor of London supports this scheme.

I have not seen the letter of support from Mr Livingstone. I would very much like to see exactly what his words of support actually are – not just that his plan supports movement by freight – but his words on this specific application. There is a substantive difference between the Mayor writing and saying ‘I support London Concrete’s application’ and the appellant claiming he has the Mayor’s support because the Mayor’s strategies for London recommends moving freight from road to rail. I believe that Joanne McCartney, the GLA member for Enfield and Haringey – who I spoke to on Wednesday morning – believes that the Mayor does not specifically support this scheme, and will be making a statement later today.

I would like to see what support the applicant actually has over and above the publicly stated strategic guidance for transport in London to see raw materials transport by freight rather than road – which if you will excuse me saying – is a no-brainer.

Having spent four of the last five years as a London Assembly member, prior to being elected to Parliament to represent Hornsey & Wood Green in May this year, I am well aware of the need to move from road to freight. It is the right strategic approach to planning. And it is indeed part of the Mayor’s strategy for London.

However, the nature of a strategic framework is such that it needs to be applied locally subject to local conditions. And I am sure the Mayor of London did not intend that this would give rise to a concrete factory in the midst of residents, schools and children walking to school.

And I am sure that the Mayor of London if he were fully cognizant of the local situation and came to see it for himself (an invitation he failed to respond to from myself) that the benefits of bringing aggregates in by rail three times a week will be completely undermined by the dis-benefits of the hundreds of HGV journeys per week it will spawn in the heart of this high density residential area.

As I understand it London Concrete have estimated 56 vehicle movements daily (which is a rate at only 50% of plant capacity). These are huge HGVs totally unsuitable for this location. Moreover, that estimate by London Concrete of the number of vehicle movements is hardly set in stone and in my view is more than likely to rise. Not only is there a history of a planning permissions starting with a particular number of movements and then going back within a short time with an application for more vehicle movements – but when questioned at one of the public forums, the representatives for London Concrete did not even know the size of the vehicles to be used.

It is completely spurious to use strategic intent to argue against local conditions and impact – and that is why the decision of the local planning authority and the overwhelming views of local residents are so important and which will, I hope, hold sway.

During my time as a London Assembly member, for four of the five years I was also Chair of Transport. I don’t believe that the transport study’s findings are accurate based on my own knowledge of the local traffic situation.

I believe that the transport report looked at the turn vehicles will have to make from Cranford Way into Church Lane. However, the report did not look in any substantive way at the turn the HGVs will have to make at the top of Church Lane – virtually doubling back on themselves to go down the other leg of the one way system into Tottenham Lane. This is a nightmare that, if allowed, will cause jams and possible accidents. I believe this particularly dangerous turning point for the lorries needing to exit the area back to a main road is not properly examined in the existing report. Church Lane residents will also have to endure a great impact in terms of traffic, noise, pollution and vibration – which will exacerbate an already worsening situation.

I would expect this, together with the base vehicle movements, the unsuitability of the roads and the other vehicle movements bringing staff and customers, to make this location unsuitable for this type of development.

There are times of the day when I believe that bus journey times in Tottenham Lane will increase substantively – and that is against the strategic thrust of the Mayor’s transport strategy.

Public transport and particularly the swift passage of buses have been and are the major priority in the Mayor’s transport strategy. I believe that the impact on bus journey times will be significant at peak flow traffic times of the day.

Moreover, this is an area with schools and children walking to school. The whole effort to create safe routes to school – a priority of the Council, the Government and the GLA which will be jeopardized and noise and disturbance will plague local residents.

I also have some difficulty believing that London Concrete’s claim that they will only sell and transport concrete within Haringey. Great difficulty – and wonder what happens if for the first year they supply Haringey and then expand their activities for example? What action will be taken then against them?

The working day will be 7am-7pm and include Saturdays. The amenity of the area will be seriously compromised by the operation of the plant.

Economic dangers also exist. Employment in Haringey is a key issue and the local economy is also threatened by this application. The current industrial estate has a few vacant sites. They are unable to fill such sites, as potential businesses do not want to take sites near to the proposed concrete factory. As I understand it, the meat business and possibly already others have stated that they will have to move out.

I leave noise, pollution and ecology – which are all in my view substantive issues where detriment will be caused – to those who know more about those areas and can argue the case more conclusively than I – but those issues to will impact on local residents.

In conclusion, I don’t believe there are any conditions that Haringey could impose that would make granting this application acceptable and ask you as the Inspector to listen to all of the argument and moreover, to use your knowledge of planning to uphold the decision of Haringey Council and reject the application for this inappropriate sitting of a concrete plant.