Representation by Norwich Green Party Group of City and County Councillors (Norwich Green Party Group of City and County Councillors)
- Date submitted
- 15 June 2021
- Submitted by
- Members of the public/businesses
Norwich and Norfolk Green Party councillors (twelve councillors) object: Scheme is over-engineered at considerable loss to the local and global environment. AADT flows in base scenario are modest compared to many parts of SRN. Highway is currently operating just below available capacity during AM and PM peaks eastbound. We request travel analysis data to show scope for influencing travel behaviour along corridor. Highways England A47 studies found travel along corridor is predominantly local. The scheme is intended to increase road capacity and facilitate traffic growth. Traffic surveys, traffic model and traffic forecast use inputs that pre-date the Covid-19 pandemic. The latter has most likely resulted in permanent flexible working and a change in travel patterns, with fewer car commuting trips at peak times. It is likely that future traffic growth, time savings and economic benefits have been over-estimated and a larger scheme designed than is necessary. The DM and DS models are unreliable and sensitivity tests do not take sufficient account of and uncertainties. We request new surveys, updated traffic model and revised forecast. The large increase in greenhouse gas emissions is incompatible with 2015 Paris Agreement and new legally-binding target of 78% cut in emissions over 1990 levels by 2035. Even so, the estimated increase excludes emissions from several sources, for example, vegetation removal and traffic from developments facilitated by scheme. Moreover, this is one of three A47 schemes close to Norwich undergoing examination simultaneously (North Tuddenham, Thickthorn, Blofield). In total, seven road schemes are planned for construction in Greater Norwich/ East Norfolk by 2025. The synergistic effect of significant new road capacity on induced traffic and their cumulative impacts on climate change would be considerable, but the NWL is the sole road scheme referenced in Cumulative Effects Assessment (6.1). HE must assess cumulatively impacts of full set of schemes on GHG emissions. A ‘Large Adverse’ impact on biodiversity would reinforce UK’s position as one of the most nature depleted countries. The scheme involves fragmentation or loss of diminishing wildlife habitats and unquantifiable adverse impacts on protected species. Eg bats and water voles would suffer direct mortality. It would see further urbanisation of ancient countryside around Norwich. The three A47 schemes and NWL would have a deleterious cumulative impact on biodiversity and landscape. This has not been recognised and should be assessed. We object to Wood Lane junction for connecting NWL with A47. Surveys record a nationally significant barbastelle bat colony in NWL area. Responding to A47/A11 Thickthorn upgrade, NCC acknowledges that the colony size would qualify for pSAC status. Planning approval of NWL is by no means certain. HE should assess ‘Without NWL’ in core design and consider ‘With NWL’ as an alternative scenario. A smaller junction without NWL would reduce land-take, biodiversity loss and GHGs. HE acknowledges lower environmental impact of on-line dualling but has opted for off-line dualling to reduce driver inconvenience during construction, at greater cost to the local environment. HE has not tested lower cost measures for addressing road safety and encouraging modal shift.