Representation by Emma Tristram
- Date submitted
- 15 June 2021
- Submitted by
- Members of the public/businesses
I object to the proposed scheme for these reasons: A. The case for the scheme (at 3.5.1) says that it will increase capacity which means that it will increase traffic growth. ''If road capacity increases, peak-period trips also increase until congestion again limits further traffic growth. The additional travel is called “generated traffic.”' (Todd Littman, Victoria Transport Policy Institute) This is incompatible with the Government's goals on climate change and modal shift. B. The traffic and economic modelling uses data, assumptions and projections from before the Covid 19 pandemic. Recent and future levels of home-working, and the shift towards Internet-based meetings, mean that traffic figures for the scheme (which are based on a 2015 baseline) are out of date. C. The scheme involves fragmentation, loss or displacement of diminishing wildlife habitats such as wet grazing meadows and protected species, notably bats and the urbanisation of mature countryside. Today's news shows that George Eustice has stated in response to the Dasgupta Report that all new infrastructure projects must have a positive effect on nature. D. Carbon emissions need to be cumulatively assessed both locally within this area, and nationally with up to 100 other schemes planned. Phil Goodwin, emeritus professor of transport policy at UCL, said in a deposition for the Transport Action Network legal case against the roads programme that “the total emissions of carbon from RIS2 schemes reported by Highways England in its separate scheme appraisals give a number which is roundly 100 times greater than that suggested by DfT witnesses.' E. Norfolk County Council has identified that the area north of the scheme has a nationally significant breeding barbastelle colony of bats, recently found. The in-combination, and cumulative impacts, of the A47 dualling with the Norwich Western link road on this European protected species should be assessed under Part 3, Section 40 of the Natural Environment and Rural Communities Act 2006.