Representation by South Norfolk Council (South Norfolk Council)
- Date submitted
- 16 June 2021
- Submitted by
- Members of the public/businesses
This letter sets out South Norfolk Council’s Relevant Representation in respect of the application made by Highways England for a Development Consent Order for alterations to a section of the A47 between North Tuddenham and Easton (the Scheme). The adopted Joint Core Strategy for Broadland, Norwich and South Norfolk seeks to enhance the transport system in order to develop the role of Norwich as a Regional Transport Node. This is to be achieved by, amongst other things, promoting improvements to the A47. This strategic aim is echoed in the emerging Greater Norwich Local Plan (GNLP), which supports strategic infrastructure improvements that support the growth needs of the area. The emerging GNLP specifically refers to improvements to the A47 between North Tuddenham and Easton as one of the schemes that will help the plan achieve its aims. The Regulation 19 Publication of the GNLP was undertaken between 1 February 2021 and 22 March 2021 and is anticipated to be examined between November and December 2021 and adopted in September 2022. As such, the North Tuddenham to Easton dualling scheme is given in principle support by the existing and emerging development plan. The potential for the scheme to deliver economic growth is strongly supported by the District Council. These benefits, in combination with the wider programme of A47 improvements being proposed by Highways England, include: • help to boost the economic prosperity of a large part of the East of England and contribute to national economic growth. • Shorter and more reliable journey times along the road and onwards to the Midlands. • Reduce delay, congestion and inefficiency. • Attracting more customers for businesses and attracting new businesses. • supporting existing businesses to grow and become more productive and profitable. • allowing businesses to invest with confidence. • encouraging more visitors to the region. • creating more jobs. However, whilst the District Council is supportive of the scheme in principle, there is the potential for impacts that will require detailed consideration through the examination process ahead of any final decision on the Development Consent Order. Matters of particular interest to the District Council through the examination stage are considered to be: • Access to the Food Enterprise Park • Landscape and visual impact • Impacts arising from noise, air quality and vibration. • Impacts on designated heritage assets Access to Food Enterprise Park The Food Enterprise Park (FEP) (referred to as the Food Enterprise Zone (FEZ) in the application documents) is a 100 acre development site, the first 46 acres of which benefits from a Local Development Order to encourage and support food production, processing and agriculture through the co-location of commercial enterprises. The FEP is considered to be a strategically important employment site which has the potential to support significant economic growth in Greater Norwich and Norfolk more generally. Earlier iterations of the Scheme proposed by Highways England included provision of a spur off the southern most roundabout at the proposed Norwich Road junction. This spur would have allowed direct access to be provided from the FEP onto the strategic road network. In previous responses to the scheme the Council has made clear that direct access to the strategic road network is an integral element of delivering the FEP vision in its entirety and would be extremely supportive of this. Direct access into the FEP as previously proposed would avoid the need for vehicles associated with the FEP (including heavy goods vehicles) to use local roads and would make the FEP a more attractive prospect for future occupants thereby accelerating the delivery of the site and its associated economic benefits. If an access to the FEP is not provided at this point there is likely to be an unacceptable increase in heavy goods movements through the village of Easton. The scheme, as submitted, does not facilitate direct access from the strategic road network into the FEP and Highways England have adopted the position that they are not responsible for its provision, nor is its provision necessary to deliver the FEP. The Council would continue to request that the Scheme includes this important access. Landscape and Visual Impact The key landscape issues are considered to be: • Impacts of scheme on existing vegetation; hedgerows and trees • Effect of the engineering and landform on the landscape character, in particular the relatively gentle landform. • Whether there are significant adverse visual effects for sensitive receptors, e.g. users of PROWs, that cannot be sufficiently mitigated • Appropriateness of proposed Environmental Masterplan Hedgerows and Arboricultural implications: The Council welcome that the submission has identified where ‘important’ (and other) hedgerows will be lost as a result of the scheme. Policy DM4.8 of the South Norfolk Development Management Polices Document presumes in favour of ‘important’ hedgerows except in cases where there is an overriding justification; in this instance it is agreed that the proposed improvements to the A47 constitute an overriding justification. Where it is necessary to remove sections of ‘important’ hedgerows for construction working margins – and the ‘importance’ was due to an historical line, it would be preferable to have the line re-instated after construction by replanting (if the original form of the land is unchanged). There is inevitable tree loss as a result of this scheme which is impossible to avoid in such a landscape. Pleased to see that whilst some category A trees are scheduled for removal, no Veteran trees appear to be implicated. Concern about potential construction compounds being within root protection areas of retained trees (including category As); would like to see this avoided if at all possible. Landscape Character There are no significant adverse landscape effects anticipated within the South Norfolk section of the scheme. Visual Effects There are no significant adverse visual effects anticipated within the South Norfolk section of the scheme. Environmental Masterplan The sensitive design and integration of hard landscape features, such as barriers requires careful consideration. Notwithstanding the highway maintenance requirements, it would be preferable for fencing in more visible locations to be set with planting that will soften the built elements. The Council has reservations about the proposed formal approach to planting around the Easton pedestrian/cycle bridge; this is not an urban area as the annotation suggests. Will it be possible to view St Peter’s Church Easton from the pedestrian/cycle crossing and/or its approach(es)? If not, is this desirable/possible? What is the function of the spur of former Church Lane to the north of the proposed Easton pedestrian/cycle bridge? Is this necessary? Impacts arising from Noise, Air Quality and Vibration Whilst the project is in a predominantly rural area, the scheme has the potential to impact on the amenity of local residents during the construction and operational phases as a result of noise, emissions and vibration. Although the Council raises no specific issues on these matters at this stage, we may wish to make representations on these issues through the examination process and ensure that these issues are adequately addressed in the Development Consent Order. Impact on Heritage Assets The Council supports the protection of milestones during the construction of the Scheme as is proposed by the applicant. The decision maker should, as required by Section 66 (1) of the Planning (Listed Buildings & Conservation Areas) Act 1990, have special regard to the desirability of preserving the setting of the building or any features of special architectural or historic interest which it possesses. Conclusion The Council is strongly supportive of the scheme in principle subject to further consideration of the issues identified above. The Council wishes to continue to work pro-actively with the applicants as the application is progressed through to Examination to try to resolve any issues in respect of the above.