Representation by Jamie Osborn
- Date submitted
- 17 June 2021
- Submitted by
- Members of the public/businesses
Councillor Jamie Osborn, Green Party I am a Norwich City councillor and Norfolk County councillor. This submission is made independently as my personal submission, and is separate to the Green Party submission, already made. I object to the scheme for the following reasons: A. In combination with the Norwich Western link (NWL) road, the scheme would increase capacity, traffic growth and emissions contrary to national policies for climate change, air quality and modal shift towards walking, cycling and public transport. B. The impact of the Covid 19 pandemic on travel patterns and road capacity need has not been assessed. C. The application, Environmental Impact Assessment, and traffic modelling baselines all assume the NWL is already built. To give an accurate assessment of the impact of the schemes, each of these should start from the current situation which is that no NWL, nor A47NTE exists. D. The traffic modelling needs to start from the current situation and sensitivity test all options that include either an NWL or an A47NTE. E. The NWL study area overlaps with the scheme area. The implications for the A47NTE from the loss of 30% of AADT vehicle kilometers, a proxy for traffic levels and carbon emissions, from the NWL models between the 2019 Option Selection Report ([redacted]) and the 2021 Outline Business Case ([redacted]) needs to be fully assessed. F. The scheme fragments and displaces nature and wildlife habitats, wet grazing meadows, protected species (notably bats). G. A nationally significant breeding colony of barbastelle bats, a European protected species, has been identified by NCC as potentially qualifying for SSSI or SAC status ([redacted], PDF page 85). Full assessment of the in-combination impacts of A47NTE and NWL on this colony is required. H. In-combination, and cumulative impacts, for biodiversity, ecology, and air quality with at least six other road infrastructure schemes near to Norwich and East Norfolk need full assessment. I. 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. J. 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.