Representation by Dr Larch Maxey
- Date submitted
- 15 June 2021
- Submitted by
- Members of the public/businesses
I object to this proposed road scheme for these reasons: A. As someone who has researched, practiced and taught transport policy and planning since 1993 it is clear that this scheme will lead to more traffic, accelerating the risk of climate induced societal collapse and increasing premature deaths from air pollution. Indeed, the case for the scheme (at 3.5.1) says that it will increase capacity ie allow m ore traffic. This scheme therefore breaches national policies for climate change and modal shift towards walking, cycling and public transport. B. The scheme employs modelling data, assumptions and projections from before the Covid 19 pandemic, e.g. for traffic and economic projections. 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 need to be assessed against the supposed need for “increased capacity”. This is particularly true when considered against the overriding policy imperatives to reduce emissions and pollution and thus enhance not undermine these traffic reducing trends. C. The environmental statement should start from the current situation, not, as this application currently does, from an assumption that the Norwich Western link is already built. The application and traffic modelling thus fail to comply with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017, by failing to take the current environmental and infrastructure context as the starting point. As is clear throughout the planning system we must avoid planning by stealth and anything that smacks of corruption and failure to uphold the highest standards of probity and process. D. My above point re the need to avoid planning by stealth also relates to the A47 dualling's links with the Norwich Western link. The application fails to adequately explore the relationship between the two road proposals, and such relationships and, why they have thus far been largely ignored, needs to be fully examined. E. 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. F. Given that we are in a nature, or ecological emergency as well as a climate emergency, as noted by parliament in 2019 and the loss of nature alone threatens human extinction, the scheme's destruction and fragmentation of rare habitats such as wet grazing meadows and those home to protected species, notably bats, needs careful examination. As has been well established in the literature and practice associated developments risk exacerbating this scheme's tendency to detrimentally urbanise mature, rare and biodiverse countryside. G. I urge that this inspection exercise take the larger view and avoid piecemeal landing be stealth. In-combination, and cumulative impacts, for biodiversity, ecology, air quality and carbon emissions have not been assessed with at least six other road infrastructure schemes near to Norwich and East Norfolk. Carbon emissions need to be cumulatively assessed both locally within this area, and nationally with up to 100 other schemes planned. The recent judgement of Pearce v Secretary of State BEIS [2021] demonstrates that the Courts accept the importance of cumulative environmental impact assessment. H. Carbon emissions should be tested against inter/national legislation and guidance including the Paris agreement, the legally binding target under the Climate Change Act 2008 to meet net-zero carbon emissions by 2050, the UK Sixth Carbon Budget (6CB), science-based carbon budgets from the Tyndall Centre, NPPF 148 which requires the planning system contribute to “radical reductions of greenhouse gas emissions”. I. Norfolk County Council has identified that the area north of the scheme has a nationally significant breeding barbastelle colony of bats, recently found, which although not yet afforded SSSI or SAC status would otherwise qualify as such (see: page 85 in NCC submission to PINS on the A47/A11 Thickthorn Junction, June 3rd, at http://bit.ly/NCC_PlanDeleg_June2021). 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.