Representation by Anne Robinson
- Date submitted
- 15 June 2021
- Submitted by
- Members of the public/businesses
I object to the proposed scheme for the following reasons: 1. The case for the scheme (at 3.5.1) says that it will increase capacity. New roads generate new traffic by up to 47% increases, as conclusively shown by CPRE’s scrutiny of Highways England’s own schemes (The End of the Road? Challenging the road building consensus - Report for CPRE, March 2017, Sloman et al). Such traffic growth would increase carbon emissions and air pollution and undermine modal shift to more sustainable modes. 2. The traffic and economic modelling uses data, assumptions and projections from before the Covid 19 pandemic and Brexit. Recent and future levels of home-working, the shift towards Internet-based meetings, and strong reductions of traffic on the roads due to COVID impacts and changed patterns of journeys due to Brexit all need to be assessed against the supposed need for “increased capacity”. 3. The Infrastructure Planning (Environmental Impact Assessment) Regulations 2017 require the environmental statement to start from the existing environmental baseline but the application and traffic modelling assume that the Norwich Western link is already built. 4. The A47 dualling links with the Norwich Western link. The relationships between the two road proposals has not been fully explored but needs to be through the examination. 5. The traffic modelling is based on the NATS 2015 (baseline year 2015) model. Recent modelling by Norfolk County Council based on the newer NATS 2019 (baseline year 2019) model reports substantially lower (c. -30%) vehicle kilometres within the scheme area. The discrepancies need to be examined, and the models fully reconciled. 6. The scheme would fragment and destroy important wildlife habitats such as wet grazing meadows and lead to displacement of protected species, particularly bats. 7. The cumulative impacts on biodiversity, ecology, air quality and carbon emissions have not been assessed for the scheme with the (at least six) other road infrastructure schemes near to Norwich and East Norfolk. Carbon emissions must be cumulatively assessed both locally, and nationally with up to 100 other schemes planned. The Courts accept the importance of cumulative environmental impact assessment (Pearce v Secretary of State BEIS 2021). 8. The Paris agreement, the legally binding 2050 net-zero carbon emissions target set by the UK’s Climate Change Act 2008, the UK’s Sixth Carbon Budget, science-based carbon budgets from the Tyndall Centre, and NPPF 148 all require radical reductions of greenhouse gas emissions. How the scheme would contribute to such reductions must be scrutinised through the examination. 9. The area north of the scheme has a nationally significant breeding colony of barbastelle bats which would qualify for, but is not yet protected by, SSSI or SAC status (page 85 in NCC submission to PINS on the A47/A11 Thickthorn Junction, June 3rd, at http://bit.ly/NCC_PlanDeleg_June2021). The 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.