Representation by Gil Murray
- Date submitted
- 17 June 2021
- Submitted by
- Members of the public/businesses
I object to the proposed scheme for these reasons: A. 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 need to be assessed against the supposed need for “increased capacity”. B. When the Northern Distributor Road (NDR) was first proposed it was as a circular road around Norwich (with the Southern Bypass). Permission for this was refused because the Wensum valley is a wildlife site of European importance. The NDR was then redesigned as a distributor road and the traffic modelling claimed that the traffic would go from the NDR to the A47 via Postwick, not to the west of Norwich. Immediately the NDR was opened this proved to be wrong and the Norwich Western Link was proposed, despite this route having already been refused. We need a satisfactory explanation why the traffic modelling was wrong last time before we can believe it this time. C. The application for this scheme and traffic modelling assume that the Norwich Western link is already built, when in fact that route has previously been refused. To comply with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017, the environmental statement should start from the current situation now as the environmental baseline. D. The A47 dualling links with the Norwich Western link. The application does not fully explore the relationships between the two road proposals, and needs to be fully examined at the examination. E. When the NDR was proposed it was said that this would reduce traffic in the north of Norwich and free up space for more bus priority schemes. This has not been done. These should be done before more car schemes are proposed. F. 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. G. 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”. H. 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 [redacted]). 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.