Representation by Climate Emergency Planning and Policy CEPP (Climate Emergency Planning and Policy CEPP)
- Date submitted
- 17 June 2021
- Submitted by
- Members of the public/businesses
Dr Andrew Boswell, Climate Emergency Planning and Policy As an independent environmental consultant specialising in science, policy, and law, I object to the A47NTE scheme for these reasons: A. In combination with the Norwich Western link (NWL) road, the scheme would increase capacity and traffic growth (APP-140, s3.5.1; AADT data at APP-140, s4.5 & s4.9) contrary to national policies for climate change, air quality and modal shift towards walking, cycling and public transport. B. Data, assumptions and projections in the traffic and economic modelling do not take account of the impact of the Covid 19 pandemic on travel patterns and road capacity need. C. The application, EIA, and traffic modelling baselines assume the NWL is already built. D. EIA baseline should express the current environmental situation which is NO_NWL and NO_A47NTE. E. Do-Minimum (DM) traffic model should codify the current situation (ie: NO_NWL + NO_A47NTE). Sensitivity testing requires THREE Do-Something models: (NO_NWL + A47NTE), (NWL + NO_A47NTE), (NWL + A47NTE). F. Major discrepancies are observed between Norfolk County Council (NCC) NATS traffic models run 2015 and 2019 baseline years for the NWL study area. At 2019-baseline, there is substantially lower (c. -30%) vehicle kilometres ([redacted]) over the 2015-baseline ([redacted]). G. The substantive traffic reduction at the 2019 baseline indicates that A47NTE capacity requirement (APP-140, s3.5.1 and based on 2015-baseline) needs greater assessment. H. Notwithstanding C, D, E, F & G above, the relationship between the scheme and a possible NWL is confused (especially at APP-142, s9.2). I. The scheme fragments and displaces nature and wildlife habitats, wet grazing meadows, protected species (notably bats). J. NCC identifies near-by a nationally significant breeding colony of barbastelle bats, which would qualify for SSSI or SAC status [redacted], PDF page 85). The in-combination impacts of A47NTE and NWL on this European protected species have not been assessed. K. In-combination, and cumulative impacts, for biodiversity, ecology, and air quality have not been assessed with at least six other road infrastructure schemes near to Norwich and East Norfolk. (Note Natural England on the EIA Scoping, APP-163, PDF page 163). The recent judgement of Pearce v Secretary of State BEIS [2021] demonstrates that the Courts accept the importance of cumulative environmental impact assessment. L. Carbon emissions need to be cumulatively assessed both locally within the Norwich area (in combination effects with the six other possible schemes identified above), and nationally with up to 100 other schemes planned by Government, including under RIS2. M. 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 UK Tyndall Centre, the NPPF 148 planning requirement to “radical reductions of greenhouse gas emissions”, and the NCC Environmental Policy. N. Note, the relevant NPS requires that the scheme be assessed against national carbon reduction targets and the UK's international commitments in place at the time when a DCO application is determined.