Representation by Christine Way
- Date submitted
- 17 June 2021
- Submitted by
- Members of the public/businesses
I object to the proposed scheme for these reasons: A. Increasing capacity means an increase in traffic growth in the Norwich area which is contrary to the national policies for climate change and a shift towards walking, cycling and public transport. B. Since the pandemic levels of home-working and internet based meetings has increased resulting in a significant reduction in traffic which may well continue. Therefore the data, assumptions and projections used for traffic and economic modelling are outdated and a reassessment is needed. C. The Environmental Impact Assessment should be made using the current situation as the baseline and not assume that the Norwich Western link is already built. 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. There are discrepancies in vehicle kilometres between the NATS 2015 model used and recent modelling by Norfolk County Council based on the newer NATS 2019 model which should be examined and reconciled. F. The scheme involves fragmentation, loss or displacement of diminishing wildlife habitats such as wet grazing meadows and protected species, notably bats and the urbanisation of mature countryside. G. In-combination, and cumulative impacts, for biodiversity, ecology, air quality and carbon emissions have not been assessed with at least six other road infrastructure schemes near to Norwich and East Norfolk. Carbon emissions need to be cumulatively assessed both locally within this area, and nationally with up to 100 other schemes planned. The recent judgement of Pearce v Secretary of State BEIS [2021] demonstrates that the Courts accept the importance of cumulative environmental impact assessment. H. 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”. I. 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.