Representation by Stop Wensum Link (Stop Wensum Link)
- Date submitted
- 17 June 2021
- Submitted by
- Members of the public/businesses
Submissions in relation to the proposed construction of A47 North Tuddenham to Easton (‘Proposed development’) I am a solicitor and a member of the steering committee of the Stop Wensum Link (’SWL’) action group. I make for and on behalf of SWL the following submissions. The Proposed Scheme, together with at least six other infrastructure schemes planned (1) /approved (2) within Norfolk, needs to be evaluated to measure the likely impact of cumulative CO2 emission levels in the context of relevant climate change commitments and obligations: these include the Norfolk County Council Environment Policy, and UK national (3) and international Climate Change obligations. The Norwich Western Link (NWL) is the only road scheme referenced in the Cumulative Effects Assessment (APP-054), and only for noise, vibration and air quality. The Infrastructure Planning (Environmental Impact Assessment) Regulations 2017 impose a general duty to consider cumulative impacts and climate change. Furthermore the carbon emission projections of Proposed Scheme need to be assessed as part of the large number of road schemes forming part of the RIS2 Scheme. The proposed Scheme will undoubtedly have an impact on the environment and biodiversity (4). In determining the level of impact as well as the design and implementation of appropriate mitigation and compensatory measures, it is our submission that baseline assessment should not be confined to this and the NWL schemes only, but should also encompasses the other major infrastructure projects that are proposed to take place within Norfolk. There is evidence currently before Norfolk County Council, for instance, which shows an interdependency of barbastelle bat colonies within the County that could if not adequately addressed lead to a population reduction of this highly protected species. There is also linked impacts in relation to the ecological condition of the River Wensum SAC given the works proposed in and around the River Tud. The traffic and economic modelling relied upon is based on data, assumptions and projections that pre date the Covid 19 pandemic. It our submission that the impact of the pandemic has lead to high levels of home-working, a shift towards Internet-based meetings, and strong reductions of traffic on the roads. It is likely that future traffic growth, time savings and economic benefits have been over-estimated and a larger scheme design than is necessary. It will be our wish to expand upon the following submissions and to interrogate within the context of these submissions the evidence adduced in support of the Proposed Scheme. Footnotes 1 A47 Blofield, A47 Tuddenham, A47 Thickthorn, Long Stratton By-Pass, Norwich Western Link, A47 Gt Yarmouth Junction Improvements at Vauxhall and Gapton 2 Gt Yarmouth third river crossing 3 Climate Change Act 2008 (2050 Target Amendment) Order 2019: the UK parliament passed legislation which replaced a previous target of an 80% reduction in GHG emissions by 2050 with a more ambitious target to reduce the UK’s net emissions to zero by 2050 – the so called “Net Zero” target 4 Graded as ‘Large Adverse’