A47 – A11 Thickthorn Junction

Representations received regarding A47 - A11 Thickthorn Junction

The list below includes all those who registered to put their case on A47 - A11 Thickthorn Junction and their relevant representations.

SourceRepresentation - click on an item to see more details
Members of the Public/Businesses
Andrew M Cawdron
"One is concerned about the road building proposals in the County on the grounds of (a) cumulative effect of the combined scheme proposals and their impact upon eco systems and the environment including all forms of pollution, the loss of habitat, vegetation and agricultural land. (b) the disruption and modifications proposed to the watercourse. (c) the lack of any planned, positive attempt to reduce transporattion movements when this is one of the larger generators of carbon emissions. (d) the lack of any appraisal which seriously addresses "growth" as the accepted idea, when the planet is a finite resource and our County is similarly part of it (e) the failure of "mitigation" that cannot prevent disruption to ecosystems during the years of survey, construction and after for generations to come."
Members of the Public/Businesses
Ministry Of Defence DIO Safeguarding Team
"Proposal: the creation of one new connector road between the A11 and A47 with the aim of rerouting traffic away from the existing Thickthorn Junction, relieving congestion, improving the environment, and improving journey times. Notice of section 56 issue. Location: A47/A11 Thickthorn junction, Norwich Grid Ref’s: E 618495 N 305473 E 619073 N 304843 E 617762 N 304708 Thank you for consulting the Ministry of Defence (MOD) on the above proposed development which was received by on the 27/05/2021. I can confirm the MOD has no safeguarding objections to this proposal as received on 27/05/2021"
Members of the Public/Businesses
Norfolk Constabulary
"I am the Traffic Management Officer for Norfolk Constabulary and in this respect I am keen to ensure that the roads of Norfolk are made as safe as possible for all road users. This includes improved road safety, reduction in road collisions and casualties on the road network. Also, increased driver/traveller journey time reliability and reduce driver stress and fatigue levels. I would look to support this application to increase the safety aspects on this part of the Norfolk road network."
Members of the Public/Businesses
National Grid
"Representation by National Grid Electricity Transmission Plc in relation to the A47/A11 Thickthorn Junction Project (“the Project”) National Grid Electricity Transmission Plc (“NGET”) wishes to make a relevant representation to the Project in order to protect its position in relation to infrastructure which is within and in close proximity to the proposed Order limits. NGET’s rights to retain its apparatus in situ and rights of access to inspect, maintain, renew and repair such apparatus located within or in close proximity to the Order limits must be maintained at all times and access to inspect and maintain such apparatus must not be restricted. The documentation and plans submitted for the Project have been reviewed in relation to impacts on NGET’s existing apparatus and land interests located within this area. The following assets, which form an essential part of the electricity transmission network in England and Wales are within, or in close proximity to, the Order limits: Overhead Lines • 4VV (400kV) overhead line route - Norwich Main to Walpole Towers 4VV209 to 4VV213 and associated span. NGET requires protective provisions to be included within the DCO to ensure that its interests are adequately protected and to ensure compliance with relevant safety standards. NGET is liaising with the Promoter in relation to the protective provisions for inclusion within the DCO, along with any supplementary agreements which may be required. National Grid will keep the Examining Authority updated in relation to these discussions. As a responsible statutory undertaker, NGET’s primary concern is to meet its statutory obligations and ensure that any development does not impact in any adverse way upon those statutory obligations. NGET reserves the right to make further representations as part of the examination process but in the meantime will negotiate with the Promoter with a view to reaching a satisfactory agreement."
Members of the Public/Businesses
Anne Robinson
"1. The scheme would generate traffic growth. New roads generate new traffic by up to 47% increases, as conclusively shown by CPRE’s scrutiny of Highways England’s own schemes (The End of the Road? Challenging the road building consensus - Report for CPRE, March 2017, Sloman et al). Such traffic growth would increase carbon emissions and air pollution and undermine modal shift to more sustainable modes. 2.The Paris agreement, the legally binding 2050 net-zero carbon emissions target set by the UK’s Climate Change Act 2008, the UK’s Sixth Carbon Budget, science-based carbon budgets from the Tyndall Centre, and NPPF 148 all require radical reductions of greenhouse gas emissions. How the scheme would contribute to such reductions must be scrutinised through the examination. 3. Carbon emissions need to be cumulatively assessed with the 100 other schemes planned by the Government, including under RIS2, and with the schemes Norwich CC plans to bring forward."
Members of the Public/Businesses
Climate Emergency Planning and Policy (CEPP) (Climate Emergency Planning and Policy (CEPP))
"Dr Andrew Boswell, Climate Emergency Planning and Policy As an independent environmental consultant specialising in science, policy, and law, I object to the A47/A11 Thickthorn Junction (A47THI) scheme: A. In combination with the Norwich Western link (NWL) road, two other RIS2 schemes (A47 North Tuddenham to Easton (A47NTE) and the A47 Blofield to North Burlingham), the scheme would increase capacity and traffic growth 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. Environmental assessment requires rework with an EIA baseline that expresses the *current* environmental situation which is NO_NWL and none of the RIS2 schemes. D. Do-Minimum (DM) traffic model should codify the *current* situation (ie: NO_NWL + none of the RIS2 schemes). Sensitivity testing should then look at all possible options in a mathematical orthogonal sense. E. Major traffic reductions are observed between Norfolk County Council (NCC) NATS traffic models run 2015 and 2019 baseline years. A47THI capacity requirement needs greater assessment as it is based on the 2015 baseline year. F. The scheme fragments and displaces nature and wildlife habitats, and has a “large adverse” effect with impacts on veteran trees, deciduous woodland, hedgerows, bats and barn owls. The cumulative impacts on biodiversity with NWL and other RIS2 schemes has not been assessed. G. NCC identify a nationally significant breeding colony of barbastelle bats, which would qualify for SSSI or SAC status (http://bit.ly/NCC_PlanDeleg_June2021, PDF page 85). The in-combination impacts of A47NTE, NWL and this scheme on this European protected species have not been assessed. H. 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. The recent judgement of Pearce v Secretary of State BEIS [2021] demonstrates that the Courts accept the importance of cumulative environmental impact 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 the UK obligations under the Paris agreement including the UK’s Nationally Determined Contribution (NDC), 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”, the statutory duty on Highways England under the Infrastructure Act 2015 section 5(2) to have regard for the environment, and the NCC Environmental Policy. K. The NPS requires that the scheme is assessed against national carbon reduction targets and the UK's international commitments in place at the time when a DCO application is determined."
Members of the Public/Businesses
Emily Scott Bolton
"I object to the A47/A11 Thickthorn Junction (A47THI) scheme: A) We need to invest in the public transport system before building the road infrastructure B) After Covid-19 less people are travelling by car to work - therefore a review of all planned roads should be made C) There will be large adverse effects with impacts on ancient trees, deciduous woodland, hedgerows, bats and barn owls identified in application itself D) We should be working towards reducing our carbon footprint not increasing it. If you build more roads you will get more traffic."
Members of the Public/Businesses
Jamie Osborn
"In combination with other planned road schemes, this scheme would increase traffic growth contrary to national policies for climate change, air quality and modal shift towards walking, cycling and public transport."
Members of the Public/Businesses
Brown & Co on behalf of Jason Graver
"On behalf of Mr Graver, we wish to consolidate the issues that need to be resolved including: 1. Boundary The attenuation lagoon will be retained by Highways England but we need to agree that the roadway between Cantley Lane South and the lagoon will be owned by Jason Graver. We need confirmation that there will be a highways boundary fence line on the north side of the access roadway as far as the lagoon. This needs to be a replacement for the green metal mesh fencing that exists on Mr Graver's current boundary. Being grazing land, albeit a little grazed recently we would like confirmation that Highways England will relocate Mr Graver's post and rail fence to the south side of the roadway with gates on both entrances. We need to confirm the gate specification on Cantley lane South. 2. Landscaping We need confirmation that Highwyas England will plant a hedge on Mr Graver's retained land south of the post and rail fence. 3. Lagoon works We need to know the phasing for the lagoon works and the drainage connection so we can assess and manage the disturbance to the fishing. 4. The holiday cottage We need to understand the phasing for the works to the stream so we can work out when the cottage will be occupiable. 5. New farm access We are concerned that an area to be used for a new farm access is huge, presumably because it is for unrestricted HGV use. We question whether it is possible to create an access around the overhead powerlines with enough room to manoeuvre having entered the site. Having unrestricted access at the moment from the north, Mr Graver is keen to retain unrestricted access and we imagine this is what has led to the road improvement works along Cantley Lane South as far as the new entrance. We consider moving the entrance further north would give more room to avoid the overhead power lines and create a better entrance, even if it is slightly further away from the buildings. We would like to meet on site with the engineers to arrange a sensible proposal. 6. Entrance, gate posts and gates For Mr Graver's existing entrance he used reclaimed bricks with reinforced pillars. Although Highways England has agreed to replicate these, we need confirmation that they propose the same specification. The alternative is for HE to meet Mr Graver's costs to do the work himself. Although we have had reasonable communication, we need to settle these practical details as soon as possible."
Members of the Public/Businesses
Technical Support Officer for the Norfolk Local Access Forum on behalf of Norfolk Local Access Forum
"The Norfolk Local Access Forum recommends that the bridge joining the two parts of Cantley Lane (Work 35) should be at least one car’s width wide, have high meshed sides with a height of 60 inches for safety. If roofed for safety, the roof must be high enough for a horse and rider (11ft with further allowance for head clearance). Additionally, to prevent horses being ‘spooked’ as they enter the roofed area (when their footfall noise changes) the surface needs to be one they are confident with i.e. soil or tarmac. Ideally also please do provide a mounting block at either end for riders who dismount and then have to get back up - 12 Breeze blocks in step fashion - away from the over-head part or hazard. (If a mounting block is not used any wooden railing will be used by the riders which would result in wear.) There are some cushioned anti-slip surfaces which would be ideal"
Members of the Public/Businesses
Brown & Co on behalf of Big Sky Developments Ltd
"Although discussions continue, the owners wish to be represented to ensure that the impact of the scheme is mitigated. As the affected property is an active residential housing development site for 350 houses, the owners need reassurance that: 1. as the works will remove the land required for playing fields and public open space. The owners need to be sure the loss of the recreation area and playing field is replaced either with an alternative site suitable to South Norfolk Council and Cringleford Parish Council, or more likely that a commuted sum is agreed with the relevant authorities and paid by the acquiring authority. 2. the boundaries are protected to prevent residents and the public being at risk from access to the highway cutting and works. 3. that noise mitigation measures are installed to ensure the new properties are not detrimentally affected by the increased noise from the works. 4. that the Cantley Lane pedestrian over-bridge is screened on the north side of the works to prevent over-looking of the nearest houses."
Members of the Public/Businesses
Bidwells on behalf of M P Kemp Limited
"The existing B1172 road is a busy stretch of road which is becoming busier, particularly as further development takes place in the Wymondham area. Therefore, it will be very difficult and dangerous for traffic to join the B1172 road from the proposed Cantley Lane link road via a T junction. We note that there are no proposals for a roundabout or signalised junction, but that a ‘Ghost Island’ junction form has been proposed. The safest and most sensible solution to deal with traffic at this junction is by way of a roundabout as previously suggested and M P Kemp Limited would request this be included in the plans for the A47/A11 Thickthorn junction improvements."
Members of the Public/Businesses
Birketts LLP on behalf of Mr & Mrs Graham Thompson
"Mr & Mrs Thompson own and occupy property adjoining and affected by the proposed Development. They wish to OBJECT to the application in its current form due to the extent of the proposed new access to their property which is insufficient, lack of lawful means of access and lack of rights for services which will be required as a result of the Development. Negotiations are ongoing with Highways England in this regard to resolve the objection. So far as they are not resolved full details will be confirmed in Written Representations. Subject to resolution of the access issues affecting their property the following amendments and conditions are requested in the interests of highway safety and amenity, further details and reasoning of which will be confirmed in Written Representations: 1) Point H on Sheet 3 of the Traffic Regulation Plans, drawing number HE551492-GTY-LSI-000-DR-CH-35003 to be moved south of the Development at the junction with Cantley Lane South to the point south of the Railway Bridge. This would involve extending the Order Limits on the plan from the point marked G south to the other side of the bridge. 2) Amendment of the Scheme to allow retention of the hedge along the southern boundary of The Sycamores in the interests of biodiversity and screening. 3) Conditions being imposed to ensure that construction working hours and large vehicle movements in close proximity to their property (and any other residential properties) are restricted to specified hours during the week in the interests of amenity. 4) Conditions being imposed to ensure suitable sound proofing and temporary screening is used to reduce the impact of construction noise and dust on the amenity of the area. 5) Conditions being imposed to ensure roads are kept clear of construction debris in the interests of amenity. 6) A condition requiring a Scheme for noise mitigation in the form of barriers and boundary treatments in the vicinity of their property to ensure noise generated by the scheme is reduced so far as is possible and those measures are retained in the interests of amenity. 7) A condition requiring the installation of light barriers between the highway and their property to reflect lights from oncoming vehicles turning onto the new link road away from their property in the interests of amenity. 8) A condition restricting the use of lighting in the vicinity of their property without express permission in the interests of amenity."
Members of the Public/Businesses
Addleshaw Goddard LLP on behalf of Network Rail Infrastructure Limited
"APPLICATION BY HIGHWAYS ENGLAND FOR THE A47/A11 THICKTHORN JUNCTION DEVELOPMENT CONSENT ORDER 202[X] PLANNING INSPECTORATE REFERENCE: TR010037 SECTION 56 PLANNING ACT 2008: RELEVANT REPRESENTATION OF NETWORK RAIL INFRASTRUCTURE LIMITED This is the section 56 representation of Network Rail Infrastructure Limited (Network Rail) provided in respect of Highways England's (Promoter) application for a development consent order (Order) for the A47/A11 Thickthorn Junction Scheme (Scheme). Network Rail is a statutory undertaker and owns, operates and maintains the majority of the rail infrastructure of Great Britain, including the Breckland Line which crosses the A47 to the south east of Fishing Lake, Keswick and Intwood (Railway). The Order sought by the Promoter includes consent and powers to improve the junction between the A47 and the A11 by adding 2 new link roads to ease congestion in the area. The Promoter seeks authority and powers in the draft Order for works to be carried out to the section of the A47 which passes over the Cringleford Rail Bridge and intends to acquire all interests and rights in the overbridge to the extent owned by Network Rail. The Promoter also seeks to acquire temporary rights to use Network Rail owned land for the purposes of carrying out works. Network Rail wishes to ensure that the Scheme will not have a detrimental impact on the operation of the Railway and that the safety of the Railway is maintained during the construction, operation and ongoing maintenance requirements of the Scheme. As the Promoter proposes to carry out works to the Cringleford Rail Bridge and in close proximity to the Railway, Network Rail wishes to object to the making of the Order on the ground that the proposed works might interfere with the safe and efficient operation of the Railway. In order for Network Rail to be in a position to withdraw its objection Network Rail will require adequate protective provisions and/or requirements to be included within the Order and an agreement with the Promoter to ensure that the works for the Scheme are carried out in regulated manner to prevent adverse impacts to the Railway and which regulate the following: a) the protection of the Railway from adverse impacts during construction of the Scheme; b) the liability of the Promoter for any necessary repairs and upgrades to the Railway as a result of its use by construction and operational traffic associated with the Scheme, including terms which protect Network Rail's statutory undertaking; and c) a safe system of work for large vehicles working adjacent to the Railway. Network Rail is continuing to review the Promoter's plans, draft Order and application documents, and will continue to work constructively with the Promoter to clarify any issues raised. The Examining Authority and the Secretary of State will need to be satisfied that railway safety and operations will not be compromised by the making of the Order. Network Rail requests that the Examining Authority treats Network Rail as an Interested Party for the purposes of the Examination, and reserves the right to produce additional and further grounds of concern when further details of the Scheme and its effects on Network Rail's assets are available."
Members of the Public/Businesses
Norfolk County Council
"While the County Council supports the principle of upgrading the existing A47/A11 Thickthorn Junction, there are a number of detailed issues in respect of, amongst other things, local highway and access matters, flood risk and environmental management, and potential impact on delivery of council services that will need to be resolved ahead of any final decision on the DCO. The most significant item of concern relates to unresolved issues around the county council taking on responsibilities for assets including significant new infrastructure comprising a link from the B1172, across the A11 trunk road and Norwich-Cambridge railway line, to Cantley Lane south and the proposed classification of this new link as a B class road. In summary the County Council supports the principle of upgrading the existing A47/A11 Thickthorn Junction subject to the implementation of appropriate highway, historic environment, and surface water conditions / requirements being resolved through the DCO process. NB the County Council will be submitting a full detailed statement to the Planning Inspectorate highlighting all issues it wishes to be resolved through the above process, through the Local Impact Report."
Members of the Public/Businesses
Norwich Cycling Campaign
"We have concerns about the provision for cyclists. We will consider the project in detail as soon as the following become available: * The final engineering diagrams *The Walking cycling and Horse-riding assessment and review *Local representations *Road Safety Audit stages 1 and 2 We will also consider the project in light of the official policy documents, including: *Gear Change *LTN 1/20 *Relevant sections of the Design Manual for Roads and Bridges *Greater Norwich Local Cycling and Walking Infrastructure Plan Anthony Clarke"
Members of the Public/Businesses
Richard Hawker
"1) Need for scheme – justification by traffic pressure. Simple AADT traffic numbers are useful, but of limited value. I can find no turning movements figures, nor origin and destination data. There is no information on the ‘detailed zoning system’ (para 4.2.4). If these are available, they should be accessible in this DCO, as part of the justification. The data given is a mix of 6-year-old data and later (2015 NATS, plus some 2016, some 2019), none post-COVID. For this large project and others nearby, an up-to-date comprehensive area survey is surely essential. There are several anomalies with the figures and projections for 2025 and 2040. In-depth discussion would be beneficial. 2) There appears to be no reasoned Justification for the specific scheme design offered. Only a ‘single option’ was offered originally. I can find no documentation of the possibly cheaper and less damaging alternatives which correspondents have offered. The large-radius links from A11S arm to A47E arm, with removal of the connections to Cantley Lane, have necessitated the resultant environmental and economic cost of the Cantley Lane Link. Why was there no discussion of retaining the connections and the existing footbridge by modifying the link design? Also, moving Cantley Stream will have inevitable environmental damage, and I believe this can and should be avoided. 3) The Park and Ride carpark is to be expanded yet the usage appears to be a small percentage of the available places. Why is there no analysis of this, nor about NCC’s wish for expansion? If the road project is needed due to congestion of the roundabout, and this expansion will increase its usage, other routes to access the carpark should be looked at. 4) A stated aim of government is to encourage modal shift to more healthy modes of travel, and those producing less CO2. How can this scheme can do anything other than encourage more car-usage ? 5) Administrative and clerical. It is stated that there was a statutory consultation in June/July 2019, though nowhere did the 2019 brochure state this. I responded to this, yet I did not know about a consultation Feb/Mar 2021. Perhaps no-one else did, as no responses were received. Elsewhere it states that there was a statutory consultation in 2018. I can find no other record of this. Much duplication of the background to the scheme and its possible funding, in several sections. Surely once is adequate; the DCO is a huge document to read. It is also quite difficult to locate required documents. The Examination library is a huge help, but one cannot then use the PINS ‘APP-xxx’ numbers in the search function. It is a little confusing that HE also uses APP for its own document references. The 6.3 section on Environment includes a tremendous number of documents, which could usefully be split into other sections. END"
Members of the Public/Businesses
Tim Hancock Associates on behalf of Shell U.K. Limited
"Dear Sir I confirm that I am instructed by Shell U.K. Limited in relation to its fuel filling station property, known as Shell Cringleford (“the Service Station”), located immediately to the west of and adjoining Thickthorn Interchange at the junction of the A47 and A11 trunk roads, near Norwich. My client operates the Service Station which provides roadside facilities to motorists using the A47, A11 and other local routes. The Service Station forms part of a service area with an adjoining restaurant and motorists hotel. The service area is a key facility occupying a transient location, serving the needs of both motorists using these routes and local traffic travelling in the vicinity of Norwich. Under the current scheme proposals, motorists travelling north-east on the A11 and then east on the A47 will no longer directly pass the service area and will not therefore be able to conveniently make use of the facilities. I would like to hold discussions with the promoting authority to discuss measures for mitigating the adverse effects of the scheme on the site, including the provision of advanced warning signs. In my experience of developing and managing service areas, sites whose access is controlled by traffic lights tend to be less successful, as motorists over time will avoid sites where access is inconvenient. The introduction of traffic light controlled junctions at the intersection of the B1172 with the roundabout junction is likely to adversely affect the trading performance of the Service Station. In the circumstances, my client reserves the rights to make further representations against the effects of the scheme on its property. Without prejudice to this position, my client would welcome to opportunity to discuss the proposals in more detail. Yours sincerely Tim Hancock"
Members of the Public/Businesses
Stop Wensum Link
"David Pett Solicitor advising Stop Wensum Link (SWL) Road campaign group. On behalf of SWL , I object to the A47/A11 Thickthorn Junction (A47THI) scheme on the following grounds: Generally The Scheme will, when viewed along side other planned projects within Norfolk [Norwich Western link (NWL) road, two other RIS2 schemes (A47 North Tuddenham to Easton (A47NTE) and the A47 Blofield to North Burlingham)], increase capacity and traffic growth contrary to national policies for climate change, air quality and modal shift towards walking, cycling and public transport. Carbon Emissions 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. They also need to be tested against the UK obligations under the Paris agreement including the UK’s Nationally Determined Contribution (NDC), 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”, the statutory duty on Highways England under the Infrastructure Act 2015 section 5(2) to have regard for the environment, and the NCC Environmental Policy. Furthermore, the NPS requires that the scheme is assessed against national carbon reduction targets and the UK’s international commitments in place at the time when a DCO application is determined. It is important to view the above against the message issue by the UK Committee on Climate Change (‘CCC') in June 2021 to the effect "building back better" must include climate adaptation considerations, and not attempt to integrate these later when, given the trajectory, it may be too late.  Covid 19 Data, assumptions and projections in the traffic and economic modelling fail to have regard to the impact Covid 19 pandemic will inevitably have on future travel patterns and road capacity requirements Environmental Looking at the environmental impact in isolation and without regard to the other local based projects listed above will inevitably lead to incorrect and highly misleading assessments making it difficult if not impossible to provide effective mitigation and compensatory measures. In turn this could result in the unnecessary loss of veteran trees, deciduous woodland, hedgerows, bats and barn owls. The recent judgement of Pearce v Secretary of State BEIS [2021] demonstrates that the Courts accept the importance of cumulative environmental impact assessment. In particular, Norfolk County Council has identified the presence of a nationally significant breeding colony of barbastelle bats, which would qualify for SSSI or SAC status (http://bit.ly/NCC_PlanDeleg_June2021, PDF page 85). The in-combination impacts of A47NTE, NWL and this scheme on this European protected species have yet to be assessed."
Members of the Public/Businesses
Bidwells LLP on behalf of The Trustees of The CM Watt Residual Trust
"As the key highway junction, providing access to and around the City of Norwich, investment to improve the Thickthorn Junction’s efficiency is important to the City and wider County. The Trustees of The CM Watt Residual Trust (The Trustees) believe improvements to the Thickthorn Junction should be welcomed but whilst Highways England’s current design addresses a number of the Trustee’s concerns, there are still outstanding issues which the Planning Inspectorate should give due regard to within their assessment of the application. 1. Highways England are aware of the existence of planning obligations in respect of a previously approved development proposal, which were required to mitigate the impact of traffic upon the Thickthorn Junction. These obligations can be summarised as the securing of land to expand the existing Park & Ride site and for construction of a new slip road from the A11 to the Park & Ride to reduce the impact of Park & Ride traffic on the Thickthorn Junction. Highways England’s proposals do not include any provision for the envisaged Park & Ride slip road to be delivered and the physical constraints imposed by the proposed works mean the future delivery of a differently designed Park & Ride slip road is rendered impossible. The improvement proposals make it impossible to implement the terms of the legally binding planning obligations, thus Highways England should be responsible for the costs and liabilities associated with varying the terms of the planning obligations in relation to the Park & Ride slip road and unpicking the land agreements related to that now undeliverable obligation. 2. An extension to the Park & Ride remains a key objective of Norfolk County Council. Highways England have assured NCC the proposed improvements will free up the requisite capacity at the Thickthorn Junction and connected network for the Park & Ride extension to go ahead with access via the existing Park & Ride access route. The Trustees believe the Planning Inspectorate should be similarly assured. 3. In the expectation that further mitigation measures will be required by Highways England to reduce the impact of the anticipated increase in carbon emissions during the construction and operational phases of the junction improvement scheme, the Trustees believe the first place where Highways England should aim to deliver this mitigation is on the Trustee’s retained property, in partnership with them, and suggest such measures should include features to encourage travel by alternative modes and to create access to outdoor spaces for recreation and leisure. 4. In the expectation that further mitigation measures will be required to reduce the anticipated impacts of the proposed improvement scheme on the local community, the Trustees believe the first place where Highways England should aim to deliver this mitigation is on the Trustee’s retained property, in partnership with them, and suggest that improvements to the landowner’s historic parkland, that will otherwise be blighted by this scheme, is the correct place to start. 5. The proposed land take should be minimised. Where Highways England will require future access across the Trustee’s property to reach their infrastructure this should be provided by the granting of the appropriate rights rather than the acquisition of freehold title. 6. For the primary reasons of improving safety and controlling noise pollution, the road speed on the Cantley Lane link road should be a maximum of 30mph instead of the 40mph proposed. 7. Noise will be a major issue when the improvements are constructed and there will be a detrimental impact on the Trustees property as a result. The surface of any new roads to be constructed should be low noise tarmac or similar, concrete should not be used and Highways England should engage with the Trustees over a scheme for planting/bunding and acoustic fencing to minimise the negative impacts of their improvements. 8. The Trustees request the light pollution associated with the improvement scheme is reduced through the rejection of any new street lighting. Where new lighting is unavoidable, it should be the minimum required and designed with the appropriate screening in place to ensure the lowest possible impact upon the surrounding property and local environment. This could be managed through a Lighting Environmental Impact Assessment to be agreed with the Trustees. 9. To address the loss of mature trees, the impact of the proposed scheme on the character of the landscape and ensure an environmental net gain, a planting scheme should be agreed with the Trustees by Highways England. 10. The Trustees await additional detail regarding the construction phase of the improvement scheme. 11. The Trustees await additional detail regarding the rerouting of Cantley Stream, specifically the works which will be undertaken to reprofile what will then be the old course of this stream prior to it being handed back. 12. The Trustees note the Land Take plans include sections of public highway which Highways England propose to acquire permanently. It is the Trustees understanding these areas are included on the plans because the land was previously in their ownership and the subsoil remains so. The Trustees do not believe it should be necessary for Highways England’s proposed works to forever change the existing structure of ownership in relation to these areas."
Members of the Public/Businesses
Bidwells LLP on behalf of The Trustees of The Mackintosh Trust
"As the key highway junction, providing access to and around the City of Norwich, investment to improve the Thickthorn Junction’s efficiency is important to the City and wider County. The Trustees of The Mackintosh Trust (The Trustees) believe improvements to the Thickthorn Junction should be welcomed but whilst Highways England’s current design addresses a number of the Trustee’s concerns, there are still outstanding issues which the Planning Inspectorate should give due regard to within their assessment of the application. 1. Highways England are aware of the existence of planning obligations in respect of a previously approved development proposal, which were required to mitigate the impact of traffic upon the Thickthorn Junction. These obligations can be summarised as the securing of land to expand the existing Park & Ride site and for construction of a new slip road from the A11 to the Park & Ride to reduce the impact of Park & Ride traffic on the Thickthorn Junction. Highways England’s proposals do not include any provision for the envisaged Park & Ride slip road to be delivered and the physical constraints imposed by the proposed works mean the future delivery of a differently designed Park & Ride slip road is rendered impossible. The improvement proposals make it impossible to implement the terms of the legally binding planning obligations, thus Highways England should be responsible for the costs and liabilities associated with varying the terms of the planning obligations in relation to the Park & Ride slip road and unpicking the land agreements related to that now undeliverable obligation. 2. An extension to the Park & Ride remains a key objective of Norfolk County Council. Highways England have assured NCC the proposed improvements will free up the requisite capacity at the Thickthorn Junction and connected network for the Park & Ride extension to go ahead with access via the existing Park & Ride access route. The Trustees believe the Planning Inspectorate should be similarly assured. 3. Highways England’s design provides two points of agricultural access to the Trustees property on either side of the proposed Cantley Lane link road, north of the A11. The Trustees need to be consulted regarding the detailed design for these accesses and, following advice from transport consultants, request the precise location of the access points is amended to better meet the Trustee’s requirement for easy access to their farmland. 4. Highways England’s design provides additional new points of access to the Trustee’s property about which the Trustees need to be consulted. 5. Due to the volume of traffic on the Norwich Road B1172 during peak periods, it will be too difficult for vehicles to gain access onto this road from the proposed Cantley Lane link road if this junction takes the form of the proposed T junction. To guarantee this junction works safely for its users and ensure congestion (i.e. traffic backing up) on the proposed Cantley Lane link road does not impede the Trustee’s ability to travel across it, the Trustees again request that a roundabout is used at this junction. 6. For security, the boundaries of the proposed Cantley Lane link road with the Trustee’s retained land should be defined with timber post and rail fencing with gated accesses. Highways England need to engage with the Trustees on the design and specification of the fencing to be employed. 7. In the expectation that further mitigation measures will be required by Highways England to reduce the impact of the anticipated increase in carbon emissions during the construction and operational phases of the junction improvement scheme, the Trustees believe the first place where Highways England should aim to deliver this mitigation is on the Trustee’s retained property, in partnership with them, and suggest such measures should include features to encourage travel by alternative modes and to create access to outdoor spaces for recreation and leisure. 8. In the expectation that further mitigation measures will be required to reduce the anticipated impacts of the proposed improvement scheme on the local community, the Trustees believe the first place where Highways England should aim to deliver this mitigation is on the Trustee’s retained property, in partnership with them, and suggest that improvements to the landowner’s historic parkland, that will otherwise be blighted by this scheme, is the correct place to start. 9. The proposed land take should be minimised. Where Highways England will require future access across the Trustee’s property to reach their infrastructure this should be provided by the granting of the appropriate rights rather than the acquisition of freehold title. The Trustee’s particularly request that they should retain the freehold title of: the low meadows to the east of the existing A11 and south of Cantley Stream; the current track and verge that runs from Cantley Lane South to the north of Cantley Stream and provides access to The Sycamores; and the land under the underpass for the new northern free flow link road. All of these areas are currently being shown on Highways England’s plans as land to be acquired permanently and the Trustees are not content with Highways England’s assurances that these areas should be changed to being temporarily acquired as the DCO application and design process progresses. Highways England will not manage these areas to the same standard as the Trustees are capable and the Trustees can see no reason why these areas should be lost. 10. With regards to the land adjoining the Sycamores, referenced above, the Trustees insist the existing hedge to the front of this property should be retained for the benefit of that property. 11. For the primary reasons of improving safety; controlling noise pollution; and minimising the difficulty of moving agricultural vehicles between the Trustee’s retained property, the road speed on the Cantley Lane link road should be a maximum of 30mph instead of the 40mph proposed. 12. Noise will be a major issue when the improvements are constructed and there will be a detrimental impact on the Trustees property as a result. The surface of any new roads to be constructed should be low noise tarmac or similar, concrete should not be used and Highways England should engage with the Trustees over a scheme for planting/bunding and acoustic fencing to minimise the negative impacts of their improvements. 13. The Trustees request the light pollution associated with the improvement scheme is reduced through the rejection of any new street lighting. Where new lighting is unavoidable, it should be the minimum required and designed with the appropriate screening in place to ensure the lowest possible impact upon the surrounding property and local environment. This could be managed through a Lighting Environmental Impact Assessment to be agreed with the Trustees. 14. To address the loss of mature trees, the impact of the proposed scheme on the character of the landscape and ensure an environmental net gain, a planting scheme should be agreed with the Trustees by Highways England. 15. The Trustees await additional detail regarding the construction phase of the improvement scheme. 16. The Trustees await additional detail regarding the rerouting of Cantley Stream, specifically the works which will be undertaken to reprofile what will then be the old course of this stream prior to it being handed back. 17. The Trustees note the Land Take plans include sections of public highway which Highways England propose to acquire permanently. It is the Trustees understanding these areas are included on the plans because the land was previously in their ownership and the subsoil remains so. The Trustees do not believe it should be necessary for Highways England’s proposed works to forever change the existing structure of ownership in relation to these areas. 18. As a consequence of the positioning of the Cantley Lane link road, the Trustees will lose the use of their current farm track which is well secured and provides access to their field located south of the A11 and north of Cantley Stream and Wood. The track being lost is in good order and sufficiently short and wide for two vehicles to pass side by side along it. Highways England’s design shows a new access track to be provided which will turn off Cantley Lane where it runs parallel with the A47. The Trustees should be provided with the freehold title to this new track just as they have the freehold title of the track which Highways England are rendering unusable. Furthermore, whilst the Trustees accept Highways England’s proposal may be the only feasible design for the track, its greater length and the fact they will be required to share the use of it with Highways England, means it must have two lanes. Finally, the new track should be secured and surfaced to a high standard and the Trustees should be consulted with on the detail thereof."
Members of the Public/Businesses
Adrian Holmes
"Along with the Norwich Western link (NWL) road, two other RIS2 schemes (A47 North Tuddenham to Easton (A47NTE) and the A47 Blofield to North Burlingham), the scheme would increase capacity and traffic growth contrary to national policies for climate change, air quality and modal shift towards walking, cycling and public transport. Norfolk County Council has admitted the opening of the Northern Distributor Road (Broadland Northway) has led to a significant traffic increase on the North Walsham B1150. The cumulative impact of this scheme on biodiversity, ecology, and air quality have not been assessed with at least six other road infrastructure schemes near to Norwich and East Norfolk. The recent judgement of Pearce v Secretary of State BEIS [2021] demonstrates that the Courts accept the importance of a cumulative environmental impact assessment."
Members of the Public/Businesses
Alyson Lee
"I would like to register as an interested party for the A47/A11 Thickthorn Junction scheme for the following reasons – • The cumulative effect of this road scheme, along with the many other proposed road schemes in the Norwich area, has not been assessed. This is the case for carbon emissions, biodiversity and air pollution. • Carbon emissions have not been cumulatively assessed along with the other RIS2 national road schemes. • This road scheme has not been assessed against the new emission reduction targets set by the government earlier this year. • This road scheme, along with the other proposed road schemes in the area (Norwich Western link road and the other two A47 RIS2 schemes) will cause significant induced traffic which goes against the current policies to reduce carbon emissions and air pollution and to promote a shift towards active travel. • Assessments are based on out-of-date data – particularly in the light of the Covid pandemic. All traffic assessments should be re-assessed with post Covid data. • I am very concerned with the adverse effects on biodiversity with the loss of woodland (including veteran trees) and other vegetation. We are in an ecological emergency – the last thing we need is to destroy more natural habitat. • The effect of this road scheme on the local population of Barbastelle bats (a European protected species) also needs to be properly assessed – this also needs to be assessed on a cumulative basis with the other proposed schemes in the area."
Members of the Public/Businesses
Anglian Water
"Anglian Water Services Limited (Anglian Water) has been in active discussion with Highways England regarding the form of modified protective provisions within the DCO. We note that Book of Reference identifies some 56 plots of land where Anglian Water assets will need to be moved or protected during construction of the project. Anglian Water is submitting this Relevant Representation in agreement with Highways England to ensure clarity on our position as a utility provider and occupier affected by the proposed scheme and so to assist the Examining Authority. Anglian Water has no in principle objection to the scheme and seeks to ensure that through the agreement of protective provisions we continue to provide customers with uninterrupted water and waste water services during construction and then the operation of the scheme. The issues on which we are in discussion with Highways England on this and other Highways England applications include: 1. Definitions, in particular “apparatus”. 2. The application of NRSWA and specifically were it applies, notification(s) to Anglian Water. 3. Anglian Water's facilities and rights when alternative apparatus has been constructed and is in operation to our reasonable satisfaction. 4. Step in rights for approved works and notification. 5. Clarity regarding the undertakers works near to or which affect Anglian Water apparatus in part to assist the undertaker in flagging and so minimise the risk of damage by Highways England's contractors. 6. Time limits being able to be altered by written agreement between the undertaker and Anglian Water. 7. Safeguards to ensure emergency works on our apparatus by the undertaker are carried using best endeavours to keep the impact of those emergency works on Anglian Water’s apparatus and network on end-users/Anglian Water customers to a minimum. 8. Tightening up references so that paragraphs are self contained were possible including when we incur expense on the undertaker’s behalf. 9. Costs as a result on the undertaker's scheme which necessitate the provision of new Anglian Water infrastructure. 10. Ensuring definitions provide for adequate compensation following damage to Anglian Water's network by the undertaker. 11. The processes for exchange of documentation and requests by Anglian Water. 12. Pre - construction surveys and a Memorandum of Understanding on stage payments to Anglian Water with reconciliation at the end or works. With reference to the project timescales set out in Environmental Management Plan, Anglian Water would welcome these steps - to assist scheme collaboration and to reduce potential abortive costs - being included with the scheme Implementation Plan developed during the NSIP determination process. Anglian Water notes that there is no intention in the scheme to construct or require new waste water recycling infrastructure or connections. Anglian Water welcomes the inclusion of SuDS as part of the drainage design and which have also been sought by the Environment Agency and Norfolk County Council (NCC). Anglian Water also support the request by NCC that the scheme delivers Biodiversity Net Gain including improvements in blue infrastructure links and habitats."
Members of the Public/Businesses
response has attachments
Cadent Gas Limited
"Please refer to Cadent's Relevant Representation and associated attachments submitted 7th June 2021 via email to [email protected] ------- Please see attached"
Members of the Public/Businesses
Environment Agency
"APPLICATION BY HIGHWAYS ENGLAND FOR AN ORDER GRANTING DEVELOPMENT CONSENT FOR THE A47/A11 THICKTHORN JUNCTION PROJECT Please find below our relevant representation for the A47/A11 Thickthorn Junction project. The Role of the Environment Agency The Environment Agency is a statutory consultee on all applications for development consent orders. We have a responsibility for protecting and improving the environment, as well as contributing to sustainable development. We have three main roles: (i) We are an environmental regulator – we take a risk-based approach and target our effort to maintain and improve environmental standards and to minimise unnecessary burdens on business. We issue a range of permits and consents. (ii) We are an environmental operator – we are a national organisation that operates locally. We work with people and communities across England to protect and improve the environment in and integrated way. We provide a vital incident response capability. (iii) We are an environmental advisor – we compile and assess the best available evidence and use this to report on the state of the environment. We use our own monitoring information and that of others to inform this activity. We provide technical information and advice to national and local governments to support their roles in policy and decision-making. One of our specific functions is as a Flood Risk Management Authority. We have a general supervisory duty relating to specific flood risk management matters in respect of flood risk arising from Main Rivers or the sea. Overview and issues of concern Our relevant representation outlines where we consider further work, clarification or mitigation is required to ensure that the proposal has no detrimental impact on the environment. We have highlighted that we are generally satisfied with the assessment of, and proposed approach to managing fluvial flood risk across the scheme. Some additional detailed survey and modelling work is being undertaken by the Applicant, which we will need to review and approve. There are also some outstanding actions for the Applicant to address in respect of the flood model which supports the flood risk assessment. Our position is therefore subject to a satisfactory review of this further work. We are broadly satisfied with the proposed Cantley Stream realignment, subject to some points of clarification and a future review of the detailed design. In general we are also satisfied with the overall approach taken to date and the mitigation proposed in respect of protecting surface water quality and groundwater resources. We have made a number of observations in respect of these issues and have highlighted that we will need to review further assessments and the detailed proposals prior to development commencing. We have requested an amendment to Requirement 6, and that we are added as a named consultee to Requirements 4 and 8. Please do not hesitate to contact me if you require any further information. We look forward to continuing to work with the applicant to resolve the matters outlined within our relevant representation to ensure the best environmental outcome for the project. Yours faithfully Martin Barrell Planning Specialist Environment Agency 1.0 Document 3.1 Draft Development Consent Order (DCO) 1.1 Requirement 4 requires the preparation of an Environmental Management Plan (EMP) and associated documents. The EMP is a mechanism to ensure the delivery of mitigation measures during the construction phase, as outlined in the Environmental Statement, including those in Chapter 13 Road drainage and the water environment. Although we are generally satisfied with the approach taken in identifying the potential adverse effects of the proposed scheme on surface water quality and groundwater resources, and with the mitigation outlined to date, the Environment Agency should have the opportunity to review and comment on the detailed proposals prior to construction. 1.2 The Environment Agency should be included as a named consultee in respect of Requirement 4, for matters relevant to our remit. 1.3 We support the inclusion of Requirement 6 Contaminated land and groundwater, and we welcome the inclusion of the Environment Agency as a named consultee. However, the proposed wording should be amended. The determination of the need for remediation in part (2) should be based on a consideration of the risk assessment by all parties, rather than determined solely by the undertaker. Additionally, and also in respect of part (2), remedial measures should be taken to render the land fit for its intended purpose and to prevent any impacts on controlled waters. 1.4 Requirement 8 is concerned with Surface and foul water drainage. As detailed below, we are generally satisfied with the approach proposed to date. However, work on the detailed drainage design is ongoing. It will be important for us to review and confirm that the detailed proposals are acceptable. 1.5 The Environment Agency should therefore be a named consultee in respect of Requirement 8 Surface and foul water drainage system. 1.6 Regarding the procedure for discharge, we note that Requirement 17 Details of consultation, states that parties will be given not less than 10 business days to respond to any consultation. We would request that this be amended to 21 days, to allow us sufficient time to consult internally and provide a comprehensive response. 2.0 Document 3.3 Consents and Licences Position Statement 2.1 We note the inclusion of Appendix A - Table of Consents and Agreements as required from consenting authorities, including the Environment Agency. We welcome early discussions on these authorisations and note that progress is to be reported in a Statement of Common Ground. 2.2 With reference to the section concerning ‘Diversion of watercourses’, we would highlight that works to realign Cantley Stream may require a transfer licence from the Environment Agency. An impoundment licence may also be necessary if a structure is required that restricts flow. 2.3 On the issue of ‘Waste and Materials’, it should be noted that an Environmental Permit will be required for the importation and treatment of waste material falling outside the scope or limits detailed in either a Regulatory Position Statement or a waste exemption. In respect of ‘Waste Materials’, the consenting authority for certain mobile plant permits such as concrete crushers is the relevant local authority, and therefore they should be listed along with the Environment Agency. 3.0 Document 6.1 Environmental Statement Chapter 8 - Biodiversity 3.1 We are satisfied, for matters within our remit, that the ecological surveys are complete and correct in terms of their timings, and that an adequate number of surveys were completed during the survey season by a suitably qualified and experienced ecologist. 3.2 This chapter highlights that ecological enhancements are to be incorporated as part of the realignment of Cantley Stream, including the provision of additional habitat suitable for water voles. We note that all mitigation will be detailed and implemented as part of the Record of Environmental Actions and Commitments (REAC) within the Environmental Management Plan (EMP). The EMP falls under Requirement 4, and as highlighted in 1.2 (above) we would wish to be consulted on the relevant sections of the EMP. 3.3 Further comments on the proposed realignment of the Cantley Stream are included below in section 7 in response to the first iteration EMP. 4.0 Document 6.1 Environmental Statement Chapter 9 – Geology and Soils 4.1 We recognise the rationale for the classifications regarding the sensitivity of receptors and magnitude of impacts presented in Table 9-4 and 9-5 (and repeated in Table 13.1 & 13.2 of Chapter 13 Road drainage and the water environment). However, it will be essential for the project to apply the principle that no private drinking water supplies can be derogated, even temporarily, without the prior consent of the owner and the provision of mitigation measures. 4.2 With reference to paragraph 9.4.27, we would highlight that locating a drainage pond over an infilled gravel pit would not be appropriate unless the fill can be proved to be inert. We therefore welcome the commitment to a full investigation of the landfill and infilled pit, to better inform Tables 9-10 (Determination of magnitude of potential impact), 9-12 (Determination of residual effects significance) and the Materials Management Plan. 4.3 We also welcome and support the undertaking of further assessments of linkages and mitigation for potential on-site and off-site contaminated land sources proposed in Section 6.11 of ES Appendix 9.3 – Preliminary Sources Study Report Part 1 of 2. 4.4 As highlighted above, we support the inclusion within the draft DCO of Requirement 6 Contaminated land and groundwater, but have suggested two amendments to the proposed wording. We welcome the inclusion of the Environment Agency as a named consultee in respect of that Requirement. 5.0 Documents under 6.3 Environmental Statement Appendices relating to ES Chapter 10 – Material Assets and Waste 5.1 6.3 ES Appendix 10.2 – Waste disposal assessment. In respect of Table 1: Preliminary waste assessment summary, we would highlight the following in relation to the Cantley Lane landfill and the classification included under Domestic household waste: Reference has been made to LoW codes 17 05 03* and 17 05 04 for excavated waste soil. Based on the description provided from TP11, TP27 and TP29, once assessed in accordance with Technical Guidance WM3, some excavated waste may be more appropriately classified under additional Chapter 17 codes, such as, but not limited to the following examples: o 17 01 06* mixtures of, or separate fractions of concrete, bricks, tiles and ceramics containing hazardous substances o 17 01 07 mixtures of concrete, bricks, tiles and ceramics other than those mentioned in 17 01 06 o 17 09 03* other construction and demolition waste (including mixed waste) containing hazardous substances o 17 09 04 mixed construction and demolition wastes other than those mentioned in 17 0 9 01, 17 09 02 and 17 09 03 We would highlight that, along with the LoW code, the Duty of Care paperwork is to provide an accurate description of any waste removed from the site. 5.2 6.3 ES Appendix 10.3 – Outline site waste management plan (SWMP). With reference to paragraph 10.1.29 (anticipated waste types), we would recommend that the final SWMP includes a section on managing excavated waste from the Cantley Lane landfilled waste area and the infilled gravel pit east of Cantley Lane South. We would expect this section to reference the further waste assessments required on the landfilled/infilled waste identified in Table 1 of Appendix 10.2 Waste Disposal Assessment, and how this activity will be managed to protect the environment and prevent harm to human health. Factors such as, but not limited to, those listed below should be considered: o Preventing the creation of pathways from any contaminated land to sensitive environmental receptors, o managing to minimise impact on amenity and o ensuring that the remaining waste is left in a manner that prevents and minimises pollution. 5.3 Regarding paragraph 10.1.39 of the outline SWMP, we recommend that the final SWMP refers to an accurate description of the waste when referring to Duty of care documentation, such as transfer or consignment notes rather than the type of waste. 5.4 We note that the SWMP will be included as part of the Second Iteration of the EMP. We would wish to be consulted on the SWMP, and therefore, as highlighted above we should be included as a named consultee in respect of Requirement 4. 6.0 Document 6.1 Environmental Statement Chapter 13 – Road Drainage and Water Environment and Appendices 6.1 In respect of surface water quality, we are satisfied with the consideration of potential issues to date and with the general principles of the proposed mitigation measures for both the construction and operational phases. As previously highlighted, we would want to review the detailed proposals. 6.2 With regards to water quality and the water framework directive (WFD), we agree with the waterbodies considered and support the mitigation measures referenced in section 13.9 to protect water quality. The WFD considerations included in this section and elsewhere in Chapter 13 are fairly comprehensive. However there is often mention of effects on the ‘overall WFD status of the waterbodies’. This is the case, for example, in Table 13.2 Estimating the magnitude of an impact on an attribute. A key WFD requirement is for no deterioration in any of the individual elements that make up the waterbody classification, as well as no deterioration in the overall classification. It should therefore be ensured that the individual elements are also assessed and considered during the detailed design process. 6.3 We note that paragraph 13.9.44 states that for the Cantley Stream realignment, the detailed design including water vole enhancements will be agreed in consultation with the Environment Agency, Norfolk County Council and other stakeholders. We welcome this, although the mechanism for this consultation should be confirmed. As highlighted above, the realignment works may also require water resources licences from the Environment Agency. 6.4 In respect of groundwater resources and quality, and Table 13.1 & 13.2 (importance of an attribute and magnitude of impact), we would repeat our comment under 4.1 above. No private water supply can be derogated as a result of the works or operation of the scheme, even temporarily, without the prior written consent of the owner and the provision of mitigation measures. 6.5 Regarding section 13.8 and potential impacts during construction, we have specific requirements for any proposed horizontal directional drilling (HDD). A detailed prior assessment of the strata to be encountered should be undertaken. Inert drilling muds (as approved by the Environment Agency), should be used and drilling mud monitoring put in place and breakout plans prepared. HDD works must be undertaken in a way that precludes any alteration to the existing degree of hydraulic continuity between strata or surface water features. We would want to review the HDD method statements. 6.6 With reference to paragraph 13.8.26, we note that the A11 – A47 connector road may intercept and expose the top of the chalk bedrock. We welcome the undertaking in paragraph 13.9.19 to avoid infiltration to ground in this area and the commitment to complete construction method statements and consult on HDD works (paragraph 13.9.21). We also welcome the commitment to prepare piling risk assessments (13.9.24), and the undertaking to monitor at water features at risk (13.9.26). 6.7 We welcome the use of carrier drains in sensitive areas, as outlined in paragraphs 13.9.28 & 29. We would like the opportunity to review the areas where both carrier drains and filter drains are proposed after further ground investigation works have been completed. We would like further information on the risk to groundwater from hydrocarbon spills, in terms of both free product and dissolved phases. We would also like the opportunity to review further details on the operational subsurface drainage when available, as referred to in paragraph 13.9.49. 6.8 With reference to paragraph 13.9.50, the minimum thickness of unsaturated zone for areas where infiltration is shown to be acceptable will be 1.2 metres, not 1m as stated. A thickness of 2 – 5 m is preferable. 6.9 With reference to paragraph 13.9.51, we are pleased to note that baseline groundwater quality monitoring will continue. 6.10 We also welcome the proposals to undertake a water features survey along with hydrogeological risk assessments (HRA) for any abstractions and groundwater dependent terrestrial ecosystems down gradient of dewatering, HDD or other intrusive works. 6.11 Overall, we are generally satisfied with the proposals and information outlined in the Drainage Strategy Report (Document 6.3, ES Appendix 13.2). But as indicated, we will need to review and confirm that further assessments and the detailed proposals for both the construction and operational stages are acceptable. As highlighted above with regards to the draft DCO, the Environment Agency should therefore be a named consultee in respect of Requirement 8 (Surface and foul water drainage system), and, for matters relevant to our remit, Requirement 4 (Environmental Management Plan). 6.12 In respect of the Groundwater Assessment (Document 6.3, ES Appendix 13.2), we welcome the full assessment of potential impacts in Table 3.1. 6.13 The drainage in catchment B is of concern given the thin unsaturated zone and the presence of proximal abstractions, as noted in the Table 4.2. We welcome the proposed ground investigations (GI) to fully assess potential impacts. 6.14 As highlighted within the Groundwater assessment document, further consultation with the Environment Agency on the potential impacts on groundwater will be required. 6.15 Regarding the Water Quality Assessment (Document 6.3, ES Appendix 13.4), we are satisfied with the assessment for surface water and details of the measures to mitigate risks. We look forward to reviewing the detail. 6.16 In respect of fluvial flood risk, we note that paragraph 13.9.40 of the ES states that current assessments have shown that there is an increase in flood risk to a residential property of up to 15mm, and that property level protection is proposed as mitigation. It is highlighted that further survey work and flood modelling is being carried out to confirm the flood risk impacts and inform the required mitigation. This further work should form part of an updated Flood Risk Assessment, which we should be given the opportunity to review and approve. 6.17 Paragraph 13.9.42 states that “changes in the floodplain level ranged from a reduction of up to 250mm and an increase of up to 100mm” and “The magnitude of impact ranges from major adverse to major beneficial”. This point then goes on to state that other than the residential property discussed in the point above, the receptors impacted are “classified as ‘less vulnerable’ (agricultural land) and ‘water compatible’ (amenity) under the NPPF”. In concluding this point it is stated that “Overall, given the majority of areas are of moderate magnitude it is considered the significance of effect is classed as moderate rather than major under DMRB LA104”. 6.18 We also note that point 13.10.6 of chapter 13 of the Environmental Statement also states “The effects range from moderate beneficial to moderate adverse significance depending on the location within the floodplain”. Table 13.1 provides the criteria for estimating the importance of water environment attributes and Table 13.2 provides the criteria for Estimating the magnitude of an impact on an attribute. These tables have been used in assessing the impact of the changes to flood risk. 6.19 The standalone Flood Risk Assessment (FRA) is included as document 6.3 Appendix 13.1. We are generally satisfied with the FRA and with the proposed approach to managing fluvial flood risk across the scheme. However, this position is subject to a satisfactory review of the further information due to be provided, as outlined below. 6.20 Section 4.4.2 of the FRA states “Agreement that the proposed new larger culvert beneath Cantley Lane removes the throttling effect on flows / levels and, due to the negligible changes in downstream flood risk, removes the requirement to provide any compensatory flood storage”. We agree that no compensatory storage will be required, providing that any further assessments continue to show that the project has no significant adverse impacts on flood risk. 6.21 As highlighted above, the FRA indicates that there may be increased flood risk to a dwelling (classified as ‘more vulnerable’) as a result of the proposed scheme. We note that various options to mitigate the increase in flood risk have been considered, including whether compensatory flood storage could be provided. Our understanding is that the assessment concluded that compensatory flood storage did not appear to be an appropriate solution, but that property level protection may be proposed if required. 6.22 Sections 8.2.6 & 8.2.11 of the FRA state that “Confirmation of the impact and, therefore the mitigation, is subject to additional survey and modelling to better predict the impacts in this location”. As mentioned above, the outcome of this additional work will should form an update to this FRA, which should be reviewed and approved by us. 6.23 Section 8.2.12 of the FRA states “Due to the proposed removal of the existing Cantley Lane South culvert and the realigned stream there are changes in the patterns of flood risk within the floodplain affecting agricultural land and amenity areas (classed as ‘less vulnerable’ and ‘water compatible’ under the NPPF). Following the initial impact assessment of removing the existing Cantley Lane South culvert throttle, it was agreed with Norfolk County Council and the Environment Agency in August 2020 that there is no requirement to provide compensatory flood storage upstream of Cantley Lane South culvert.” As above, agreement is based on further assessments continuing show no significant adverse effects on flood risk. 6.24 The Environment Agency has previously reviewed the flood modelling work completed by the Applicant to inform this FRA. At the time of submission, there remained some outstanding model review actions needing to be resolved before the suitability of the assessment could be confirmed. A demonstration that these required actions have been addressed should be submitted along with the details and conclusions of the additional survey and modelling work currently being undertaken. 6.25 Following the further survey and flood modelling work, if any increases in flood risk as a result of the scheme are identified, it should be clearly documented as to why the increase cannot be prevented and how any impacts will be managed. Where decisions on the significance of any flood risk impacts on receptors have been made, it should be clear how the assessment was undertaken and why the conclusion on significance was reached. 7.0 Document 7.4 Environmental Management Plan (First Iteration) 7.1 With reference to paragraphs 1.1.5 and 1.1.6, we note that there is no reference to a Temporary surface water drainage plan being prepared as part of the EMP. However, it is listed as a plan to be prepared in the draft DCO under Requirement 4, and is referred to elsewhere within the EMP. 7.2 As highlighted above, the Environment Agency should be included as a named consultee in respect of Requirement 4, to enable us to review and comment on relevant documents. 7.3 Plans and strategies forming part of the EMP that we would wish to review include: the Landscape and ecology management plan, Temporary surface water drainage plan, Water monitoring and management plan, Site waste management plan, Soil management plan and Materials management plan. 7.4 We have reviewed Section 3 and Table 3.1: Record of Environmental Actions and Commitments (REAC). We have the following comments at this time: 7.5 B15 – we support the approach proposed to protect fish caught up in the de-watering of the old channel of the Cantley stream, which include netting and electrofishing to remove fish. We note that full details will be included in the Second Iteration EMP and we would wish to review those details. As highlighted above, consents may be required from the Environment Agency for works associated with the diversion of Cantley Stream. 7.6 Currently, we would highlight that additional checks will be required as water levels are lowered, with individual fish removed and transported upstream. We would like to see the use of a silt curtain or coffer dam at the downstream extent of the old channel to prevent fish kills further downstream as a result of the silt released during fish removal, and in particular as the channel is de-watered. Use of a dissolved oxygen monitor would also be recommended to monitor changes in levels during this activity. 7.7 When the water is diverted into the new channel for the first time, there is likely to be some release of loose surface sediment in to the channel immediately downstream. We would like to see that there are measures in place to prevent silt and sediment from being flushed downstream from the new channel. This could include constructing the new stream bed from locally sourced gravels, cobbles, or any gravels that can be retrieved from the original stream bed. We would wish to review this detail in further consultations. 7.8 RD1, RD2 & B3 – we note the measures outlined in relation to pollution prevention and sediment management. As highlighted above, the Environment Agency should be consulted on the water monitoring plans and temporary surface water drainage strategy. 7.9 RD2 – in respect of flood risk, the potential need for property level protection is highlighted. It is not currently clear how the EMP would secure the implementation of such measures. This should be confirmed. 7.10 RD4 – we note the inclusion of the statement that the design of the realigned Cantley Stream will be undertaken in consultation with the Environment Agency, Norfolk County Council and other stakeholders. The mechanism for that consultation should be clarified. 7.11 The full distance of the existing channel being re-aligned and subject to water vole displacement should be compared with the new length of enhanced/restored habitat. It must be ensured that there is adequate provision of alternative habitat for the displaced individuals, especially if there is a delay between displacement activities and establishment of vegetation in the new re-aligned channel. 7.12 The construction period for the proposed scheme seems to offer a relatively short time period in which to establish suitable alternative habitat for displaced water vole, if required. The detailed design must take this into account. 7.13 How the new re-aligned section of channel will be colonised with aquatic and marginal plants has not yet been clarified. The Applicant may be intending to divert some of the flow from the original channel, or bring water in from elsewhere, to wet the new section prior to the final diversion. In that scenario water resource licences may be required from the Environment Agency as highlighted above. Alternatively, the Applicant may be intending to demonstrate that there will be sufficient alternative water vole habitat available to displace/ trap and release into while the new channel re-vegetates. The chosen approach will need to be fully assessed and approved at the detailed design stage. 7.14 RD4 – we also note that the Environment Agency and Norfolk County Council are to agree monitoring requirements for the realigned Cantley Stream as part of the EMP Water monitoring and management plan. We welcome this and look forward to reviewing the plan. Currently, we would highlight that during the process of planning and construction, the water quality of the Cantley Stream should be monitored for changes to pH, turbidity and dissolved oxygen as a minimum. 7.15 RD5 – we note that required WFD mitigation is to be agreed with the Environment Agency. Will this be through consultation on aspects of the EMP, or via other means? 7.16 RD7 to RD10, and RD14 are concerned with the protection of groundwater resources during construction. We are satisfied with the measures proposed, subject to the review of further assessments and details, as outlined. The mechanism for further consultation with the Environment Agency should be clarified. 7.17 We would highlight that the dewatering exemptions noted here; in Table 4-1; and elsewhere in the ES, are only applicable if the works will take less than 6 months. For works over a longer time period, an abstraction licence will be required for any dewatering at rates over 20 m3/d. 7.18 We welcome the proposals to undertake a water features survey along with hydrogeological risk assessments (HRA) for any abstractions and groundwater dependent terrestrial ecosystems down gradient of dewatering, HDD or other intrusive works. 7.19 RD11 – while we are generally supportive of the measures outlined to protect groundwater during operation, we would highlight that the minimum thickness of unsaturated zone for areas where infiltration is shown to be acceptable will be 1.2 metres, not 1m as stated. A thickness of 2 – 5 m is preferable. 7.20 RD15 – we note that this section states that: “Drainage Strategy and Flood Risk Assessment including hydraulic modelling to be approved by the Environment Agency, Lead Local Flood Authority (Norfolk County Council) and Norfolk Rivers Internal Drainage Board”. We welcome this but would highlight that consultation should be progressed and approval obtained as part of the DCO process and not through permit and consent requirements. Cantley Stream is an ordinary watercourse, not a designated main river, and as such the LLFA is the consenting authority for works affecting flows. However, the Environment Agency has reviewed and commented on the FRA due to the presence of fluvial flood risk associated with the Cantley Stream. We should review and approve the FRA to ensure that fluvial flood risk is appropriately managed, and review and approve the drainage strategy to ensure the protection of controlled waters. 7.21 RD17 – as highlighted above, the Environment Agency should review and approve the detailed drainage design. We should be a named consultee in respect of Requirement 8 (Surface and foul water drainage system), and, for matters relevant to our remit, Requirement 4 (Environmental Management Plan). 7.22 Regarding Table 4-1, it should also be noted that the consenting authority in the case of certain mobile plant permits such as concrete crushers is the local authority, and therefore they should be listed along with the Environment Agency. 7.23 With reference to Annex C, we would highlight that we would want to review the Construction method statement for water."
Members of the Public/Businesses
Gil Murray
"1. The UK has legislated to be carbon neutral by 2050. Expanding our road capacity is not compatible with this legally binding commitment. 2. According to the National Academy of Sciences of the USA in 50 years 12% to 30% of the world will be uninhabitable. Two of the countries most affected, India and Pakistan, are nuclear powers. At the upper figure our fair share of refugees would be 43% of our population. (theGuardian.com/environment/2020/may/05 3. The recent extreme heatwave in British Columbia and the record drought in southwest USA indicate that climate models may have underestimated the effects of climate change."
Members of the Public/Businesses
Historic England
"The Historic Buildings and Monuments Commission for England (HBMCE) is better known as Historic England, and we are the Government’s adviser on all aspects of the historic environment in England - including historic buildings and areas, archaeology and historic landscape. We have a duty to promote conservation, public understanding and enjoyment of the historic environment. We are an executive Non-Departmental public body and we answer to Parliament through the Secretary of State for Digital Culture, Media and Sport. We summarise our representation regarding this proposed project as follows. Please note we do not intend to attend the preliminary hearing. However, we will be submitting full written representation at a later date. Representation: 1. Introduction Historic England’s written representation will comment more fully on the key historic environment issues in due course, however for the purposes of this representation they are summarised below. 2. Designated Heritage Assets Historic England’s advice on designated heritage assets will be limited to the scheduled monument of ‘Two tumuli in Big Wood’ (1003977) which lies immediately adjacent to the DCO boundary. Advice on grade II listed structures will be provided by South Norfolk District Council’s Conservation Team. We note from Section 6.7.16 of the Chapter 6.1 of the ES that the trial trenching proposed adjacent to the scheduled monument was not carried out. Historic England would welcome the opportunity to hold further discussions about the proposed trial trenching adjacent to the scheduled monument with the applicant’s heritage consultant and Norfolk County Council. Section 6.10.7 of the ES identifies that the proposed scheme would have a ‘significant residual adverse effect’ on the scheduled monument. This would arise through a permanent change to the setting of the monument and the severance of the barrows from their landscape context overlooking a small valley to their south. We consider that the change to the setting of the ‘Two tumuli in Big Wood’ scheduled monument would result in harm to the significance of this designated heritage asset. The level of harm will need to be weighed against the public benefit of the proposed scheme. 3. Non-Designated Heritage Assets Chapter 6 of the ES identifies a wide range of non-designated heritage assets within the DCO application boundary and wider study area. The archaeological surveys already undertaken have identified previously unrecorded buried archaeological remains and a high potential for further such heritage assets to be present within the application site boundary. We note that further field survey would be necessary to fully establish the archaeological potential of the proposed development area. A ‘Compound/Material Storage Area’ is shown southeast of the existing A11 on Figure 2.1. This area was not included in the archaeological surveys and we are concerned that it could impact on as yet unidentified heritage assets. We request clarification regarding the potential impact in this area, and whether archaeological surveys are proposed for this. 4. Summary We intend to expand on these matters more fully in our written representation. We are broadly satisfied with the baseline data and overall assessment methodology used in the Cultural Heritage chapter of the submitted Environmental Statement. In the event that the development is consented, we would be concerned to ensure that the historic environment is adequately and appropriately considered, and that the DCO is appropriately worded to ensure appropriate mitigation would be delivered."
Members of the Public/Businesses
Jan Davis
"It is a well-established fact that traffic expands to fill the road space available and that with the climate crisis we should not be building more roads. The Department for Transport and Highways England are ignoring the government’s promises and policies on climate. In particular, it is acknowledged the scheme will have a “large adverse effect” with an accumulation of impacts on biodiversity including veteran trees, deciduous woodland, hedgerows, bats, and barn owls. This scheme cannot be considered in isolation from other road schemes planned for Norfolk and planned nationally. Cumulative carbon emissions and adverse impact on biodiversity are required to be taken into account and this application fails to do so. My objections to the A47/A11 Thickthorn Junction scheme include: • The scheme would increase capacity and traffic growth contrary to national policies for climate change, air quality, and modal shift towards walking, cycling, and public transport. This is particularly so when taken in combination with the Norwich Western link road, and the A47 North Tuddenham to Easton, and the A47 Blofield to North Burlingham schemes. Carbon emissions need to be cumulatively assessed within the Norwich area and Norfolk as a whole, not as single, isolated, road projects. • The A47 capacity requirement needs to be re-assessed as it is based on the 2015 baseline year which has been superseded by the 2019 modelling. This is crucial because there are major traffic reductions observed between the 2015 and 2019 Norfolk County Council traffic model baseline years. In addition, the impacts of Covid have not been taken into account and it is well known that this has impacted traffic flows. • As with carbon emissions, the cumulative impacts on biodiversity of the various road projects in and around Norwich need to be assessed collectively. They cannot be simply viewed in isolation. It is acknowledged there will be large adverse effects on nature and wildlife which need to be assessed along with other major infrastructure projects locally and nationally since each project contributes to the fragmentation of wildlife corridors and a greater adverse impact on biodiversity generally."
Members of the Public/Businesses
Brown & Co on behalf of Janet Grint
"We wish to make representations on behalf of Mrs Janet Grint with regard to the design and impact of this scheme on the amenity of her dwelling. The scheme will strip the dwelling of screening that provides privacy and protection from light, noise and airborne pollutants. The removal of the screening on the north and west boundary combined with the signficiant increase in traffic flow around the property, notably because of the link road running north to south situation to the rear/south west of the dwelling. Highways England need to take greater account for this level of disruption and provide a greater level of accomodation works."
Members of the Public/Businesses
John Elbro
"I support • A speed limit of 40mph or less on the new link road connecting Cantley Lane South with the B1172 Norwich Road to the north. It is a necessary safeguard if walkers and cyclists on the segregated pathway are not to be intimidated by traffic travelling at excessive speeds. It will also slow traffic travelling towards Cantley Lane in preparation for the lower speed limit on Cantley Lane and its more difficult driving conditions – narrow and winding with cyclists and pedestrians in the road. • The 40mph speed limit on the B1172 Norwich Road. The limit should help to improve safety at the new junction connecting to Cantley Lane Link Road. • Access to the Park and Ride from the Cantley Lane link road for walkers and cyclists. Its provision should help encourage cycling and walking and use of public transport. • The new footbridge over the A47 for walkers, cyclists and horse riders, provided it is carefully graded and has smooth bends to ensure easy passage for mounted cyclists. • The paths for walking and cycling proposed along the new Cantley Lane link road. These give access to local amenities and provide a link to other recreational routes. They are essential if local cycling and walking is to be encouraged. I object to • A 30mph speed limit on Cantley Lane South. 30mph is too high. It is also not clear where it is supposed to begin and end. Cantley Lane is a popular route for cyclists. There is a danger that, with the improved access provided by the Cantley Lane South to Cantley Lane link road, there will be a significant increase in vehicular traffic on Cantley Lane, south of the junction with the link road. This is a winding road in part sunken where it descends to pass under a railway, in other parts there is insufficient space for vehicles to pass one another, or pass a cyclist or walker. A safe speed on any of these sections is certainly less than 30 mph. If this road is to remain in use by safety conscious cyclists and walkers the speed limit will need to be reduced to 20 mph. • The lack of green landscaping plans. In particular there should be substantial green screen planting to shield the proposed recreational open space (in the Cringleford development adjacent to the A47) from the noise, pollution and visual intrusion of traffic on the A47 and the new free flow link road emerging from the underpass."
Members of the Public/Businesses
New Anglia LEP
"Dear Inspector New Anglia Local Enterprise Partnership fully supports the delivery of the Thickthorn junction improvement as part of Highways England’s Roads Investment Strategy. The improvement will help deliver the Economic Strategy for Norfolk and Suffolk, which sets out ambitious targets to grow our economy by £17.5 billion, creating 88,000 new jobs and 140,000 new homes and increasing GVA by £39 per hour by 2036. The junction is one of the most important in the region and suffers consistently from congestion, impacting on productivity and increasing pollution. The scheme will support the ambitions of the Norfolk and Suffolk Economic Strategy and our emerging Economic Renewal Plan by improving connectivity and journey reliability to economic opportunities in the County. It will also encourage further investment in Norwich and Greater Norwich, a Priority Place in the Norfolk and Suffolk Economic Strategy, covering Broadland District Council, Norwich City Council and South Norfolk Council areas. The city has a long tradition of creative, radical thinking, and has a fast growing digital and creative hub as well as an established cultural scene. The city also has a successful financial and insurance cluster, home to Aviva, Marsh and Virgin Money and a growing number start-ups and fin-tech companies. The Thickthorn improvement presents the opportunity to add to the benefits that will be realised by the other A47 improvements, connecting to the centres of global excellence in food and health at Norwich Research Park, the Food Enterprise Zone at Easton and the Cambridge Norwich Tech Corridor. Finally, the Thickthorn improvement is also identified by Transport East in their Investment and Delivery Plan as a measure within one of six strategic corridors where investment is necessary to delivering an ambitious and cohesive transport strategy. In summary, we can confirm that we fully support the proposal being put forward and look forward to continuing working closely with partners to see the improvement scheme delivered. Yours, Ellen Goodwin (on behalf of Chris Starkie - CEO, New Anglia LEP)"
Members of the Public/Businesses
Norwich & Norfolk Friends of the Earth
"I object to the A47/A11 Thickthorn (A47/THI) scheme: Norfolk County Council: NCC 1. The scheme, in conjunction with the Norwich Western Link and two other RIS2 schemes A47 North Tuddenham to Easton & A47 Blofield to North Burlingham, would increase capacity, traffic growth and air pollution, all contrary to national policies for climate change. Also detracts from encouragement for walking, cycling and public transport. 2. Data, out of date due to lack of change to travel patterns and road capacity need post pandemic 3. Environmental assessment requires rework with an EIA baseline that expresses the 'current' environmental situation which is NO_NWL and none of the RIS2 schemes. 4. Do-Minimum (DM) traffic model should codify the 'current' situation - NO-NWL + no RIS2 schemes. Sensitivity testing should then look at all possible options in mathematical orthogonal sense. 5. Major traffic reductions are observed between NCC NATS traffic models run 2015 and 2019 baseline years. A47THI capacity requirements needs greater assessment as it is based on 2015 baseline year. 6. The scheme disrupts and destroys wildlife habitats and severely damages habitat of nationally significant breeding colony of barbastelle bats a European protected species which would qualify for SSSI or SAC status. Immense loss of veteran woodland and hedgerows The combined impact of NWL and other RIS2 schemes has not been assessed. 7. Combined impact on biodiversity, ecology and air quality have not been assessed with other road infrastructure schemes near to Norwich and East Norfolk. The recent judgement of Pearce v Secretary of State BEIS 2021 demonstrates that the Courts accept the importance of cumulative environmental impact assessment 8. Carbon emissions need to be cumulatively assessed within the Norwich area in combination with other schemes as above (7) and nationally with 100 other schemes planned by Government, including other RIS2 9. Carbon emissions should be tested against the dUK obligations under the Paris Agreement including the UK's Natioinally Determined Contribution (NDC), the legally binding target under the Climate Change Act 2008 to meet net-zero carbon emissions by 2050, the UKSixth Carbon Budget (6CB), science-based carbon budgets from the UK Tyndall Centre, the NPPF 148 planning requirement to 'radical reductions of greenhouse gas emissions', the statutory duty on Highways England under the Infrastructure Act 2015 secion 5 (2) to have regard for the environment, and the NCC Environmental Policy. 10. The NPS requires that the scheme is assessed against national carbon reduction targets and the UK's international commitments in place at the time when a DCO application is determined"
Members of the Public/Businesses
Norwich Green Party Group of City and County Councillors
"Norwich City Council and Norfolk County Council Green Party Groups (12 councillors) object: Scheme is over-engineered at considerable loss to the local and global environment. There is for example, no justification for new link roads, junctions and bridges between Cantley Lane and Cantley Lane South and between Cantley Lane South and B1172 and the significant environmental impacts that would result. Opening up Cantley Lane South to vehicular traffic would turn a quiet, attractive rural road for safe cycling between Norwich and Wymondham into a fast route for drivers. Trip length distribution analysis conducted on all approaches of the Thickthorn interchange in 2040 DS show 30% of journeys are between 10 -20 km in the AM Peak whilst 6% are less than 10km. This high number of short trips indicates the potential for modal shift. Current trip length distribution analysis is requested. Government policy seeks to make public transport and active travel the natural first choice for daily activities. Traffic surveys pre-date covid-19 and the traffic model and traffic growth forecasts do not factor in pandemic impacts on future travel demand and other uncertainties such as the impact of digital technology on travel and the economy and new policy levers to cut carbon. It is likely that the scheme has over-estimated future traffic growth, time savings and economic benefits. The scheme would increase greenhouse gas emissions. Highways England estimate is an underestimate as it excludes several associated sources of emissions such as vegetation removal, induced traffic and traffic from consequential development. Norfolk’s transport carbon emissions are substantial and growing. This scheme would increase emissions still further and make it harder to achieve legally-binding targets and Norfolk County Council’s ambition of carbon neutrality by 2030. The scheme would concrete over and fragment ancient countryside around Norwich. It would strip away complex wildlife habitats and protected species would be displaced or suffer mortality as acknowledged by the Large Adverse impact assessment for biodiversity. This road scheme is one of four planned for construction around Norwich within the next five years. The synergistic effect of building a large amount of new road capacity on induced traffic and consequential development and the cumulative impact on greenhouse gas emissions and biodiversity loss has not been considered. This scheme as part of road expansion around Norwich would make the city region more hostile for biodiversity and a hotter place to live and make worse the climate and biodiversity emergencies. The alternatives considered all involve road building. Prior to 2010, as part of Joint Core Strategy preparations, Highways England proposed a bus priority scheme for Thickthorn junction to assist bus rapid transit, with the aim of serving housing growth along the A11 corridor. However, Norfolk County Council demanded a major traffic upgrade of the junction whilst failing to deliver public transport improvements along the A11. Non-road building alternatives must be explored in place of this major scheme, particularly in view of the high number of vehicles making short local trips that pass through the junction."
Members of the Public/Businesses
Orsted Hornsea Project Three (UK) (Orsted Hornsea Project Three (UK))
"This relevant representation is made by Ørsted Hornsea Project Three (UK) Limited (“Hornsea Three”) and sets out the potential interaction and issues to be resolved between Hornsea Three and the Highways England A47/ A11 Thickthorn Junction (the ‘A47 Thickthorn DCO’) development. The A47 Thickthorn DCO will interact with Hornsea Three in the following main ways: 1. Potential impacts on access for Hornsea Three’s construction vehicles during construction and operation phases along the B1172 (Norwich Road), and along the A11; 2. Overlap of works along the B1172 (Norwich Road), and along and adjacent to the A11 which has the potential for impacting the construction and operation of Hornsea Three. Hornsea Three considers that the two schemes can co-exist and therefore does not have an in-principle objection to the A47 Thickthorn DCO. However, as Hornsea Three is a consented nationally significant infrastructure project, it is crucial that the A47 Thickthorn DCO does not prohibit or delay the construction and/or operation of Hornsea Three or result in Hornsea Three being in breach of the Hornsea Three Order. Hornsea Three has identified a number of issues that need to be resolved to ensure that no serious detriment is caused to Hornsea Three. A summary of the issues, and the measures that Hornsea Three requires to resolve them, is set out below. Technical issues: • Access for Construction - Hornsea Three requires unfettered access along the B1172 (Norwich Road), A11 Hethersett Bypass, A47, Cantley Lane South (including links onto A47 & access from A11 Hethersett Bypass), and Station Lane for the full duration that Hornsea Three is in construction in order to facilitate the construction activities associated with the development. • Access for Operations – Hornsea Three requires operational access off the B1172 (Norwich Road), and adjacent to the A11 (off Station Cottages Service Road). • Overlap between the A47 Thickthorn DCO and the Hornsea Three Order Limits at B1172 (Norwich Road), and along the A11 (Hethersett Bypass) – It is not clear what this land might be used for, and therefore Hornsea Three would like to engage further to understand potential impacts and subsequent requirements that might be required for Hornsea Three. Legal issues: • Highways England to provide confirmation that it will procure (either by agreement or compulsory acquisition) adequate permanent access rights for Hornsea Three to the Hornsea Three cable corridor for operational purposes if these are fettered by the A47 Thickthorn DCO. • Any other issues which may arise due to the overlap between the A47 Thickthorn DCO and the Hornsea Three Order Limits at B1172 (Norwich Road), and along the A11 (Hethersett Bypass). Hornsea Three will continue to work with Highways England to facilitate agreement between the parties so that both projects can co-exist. Hornsea Three looks forward to further engagement with Highways England on these and any other matters that may arise. Sincerely, Karma Leyland Consents Project Manager, Hornsea Three"
Members of the Public/Businesses
Public Health England
"Thank you for your consultation regarding the above development. Public Health England (PHE) welcomes the opportunity to comment on your proposals at this stage of the project. PHE notes that we have replied to earlier consultations as listed below and this response should be read in conjunction with that earlier correspondence: Request for Scoping Opinion 8 February 2018 Section 42 11 July 2019 We can confirm that we have assessed the submitted documentation and wish to make the following recommendations with respect to the areas that were addressed at the Section 42 stage. Overall, better characterisation and assessment of impacts on human health both before and after mitigation is required across the Environmental Statement (ES), in the Population and Human Health chapter for the general population and vulnerable groups; with particular reference to the air quality assessments. In the assessment scenarios, further justifications are required regarding the choice of the baseline, construction and operational opening and design years; (for example, the construction year 2019 is no longer applicable) and whether these capture the worst-case/peak scenarios. Topic specific comments are as follows: Air Quality • The air quality assessment only considers long-term impacts through changes in annual means. It is recommended that short-term impacts on air quality are considered for both construction and operational activities for all potential pollutants (PM10, PM2.5 and NOx), as there are no safe limits of exposure in relation to health risk. Reducing public exposures to non-threshold pollutants (such as particulate matter and nitrogen dioxide) below air quality standards has potential public health benefits. We support approaches which minimise or mitigate public exposure to non-threshold air pollutants, address inequalities (in exposure), and maximise co-benefits (such as physical exercise) and encourage their consideration during development design, environmental and health impact assessment, and development consent. • Clarity and justifications are required regarding the choice of study area and the zone of influence for the air quality assessment of the construction and operational phases; and the choice of Cringleford, Hethersett, Mulbarton and Stoke Holy Cross only, for the assessment of health impacts. Residential areas are also noted within 2km to the north east, for example Eaton, it is unclear why these have not been included. Further details regarding these points and the assessment of cumulative impacts should be provided. • It is recommended that the assessment of receptors include those within 25m of a junction. Construction Phase • Limited details have been provided regarding overall air emissions that would be expected from the construction phase, including the presence of any non-road mobile machinery and cumulative impacts from these. It is recommended that further details are provided, including those regarding monitoring and worst-case assessments. • Consideration should be given within the air quality assessment to the impact of any proposed road closures, traffic management, or further restrictions that may be encountered during the construction phase, both on the roads to be developed as part of the scheme and roads in the surrounding area, including the Affected Road Networks. It is noted that Construction and Traffic Management Options 1 and 2 both lead to an increase in the zone of influence up to 4km. It is recommended that this be taken into account in the cumulative and population health assessments and further detailed assessment regarding the impact on the AQMA located approximately 3km to the northeast. • It is unclear why construction impacts have been screened out on the basis of the construction phases lasting less than two years; whilst potential air quality impacts on human health from this phase are acknowledged in Chapter 12 (section 12.8.9). Operational Phase • It is recommended that short term and long-term modelling be undertaken for PM10 and PM2.5 for the Do-minimum and Do-something scenarios to define areas of deterioration of air quality where further mitigation could be required. • PM10 concentrations have been used to demonstrate the Proposed Scheme does not impact on the PM2.5 air quality objectives. Where scoping out is recommended by the applicant, the public health impact assessment should be supported with reliable data, including modelling and predictions. • There are several areas where clearer justifications are required: o The choice of baseline year (2015) and the need to back cast when more recent data could be available. o The choice of opening year (2025) for worst-case assessment. It has not been demonstrated that this is the worst-case year when compared to other years, for example during the construction phase where there is the potential for a number of cumulative impacts. o Whether the choice of locations for the scheme specific monitoring is representative of worst-case scenario for sensitive receptors (for example, taking into account weather conditions). o The location of colocation sites 1-3 relative to the scheme monitoring, how findings (which show close to or an exceedance in AQS) inform the risk assessment and whether there is an impact on these locations from the proposed works (see comment regarding the zone of influence). • The modelling for NO2 showed that 50 of the 155 receptors are expected to show a deterioration in air quality, which is of concern. o It is noted that for each triggered road link only one receptor representing the closest receptor was chosen, which may preclude the identification of a greater number of receptors with a deterioration in air quality. It is recommended that details of results for individual receptors be be included. o It is recommended that further details are provided regarding additional mitigation measures to be incorporated into the development to prevent this deterioration. This deterioration and the corresponding health impacts should also be acknowledged and assessed in Chapter 12 (Population and Human Health) for the general population and vulnerable groups, i.e. the impacts on respiratory diseases, hospital admissions and other chosen health indicators. Justification for the methodology should be provided and where necessary, monitoring should be recommended. Health and Wellbeing • Chapter 5 (Air Quality) identifies the local road network screened into the affected road network (ARN), however, Chapter 12 does not identify the impacts of effects from these on population and human health more widely. Further information is required in relation to the screening process and subsequent effects. • There is little assessment in the Health Chapter regarding impacts from water pollution and flooding on health outcomes on the population and any vulnerable groups. Water, Geology and Soils • In view of areas of potential contamination and the presence of a number of sensitive groundwater abstraction points, it is recommended that further details are included regarding the potential impacts of piled foundations within the conceptual model to ensure any risks to human health are minimised. Electric and Magnetic Fields The current documentation makes no reference to EMF emissions from the development. We recommend that the proposer: 1. Identify if the proposed development has electricity generation and/or distribution infrastructure that may result in the emission of electric and/or magnetic fields such that there is the potential for an adverse impact on public health. Where electricity generation and/or distribution equipment is identified an assessment of potential EMF exposures should be included; 2. Should the proposer believe that EMF can be scoped out of the assessments they should clearly state their assumptions and rationale in the application for DCO submission. We can confirm that we have registered an interest on the Planning Inspectorate Website. Please do not hesitate to contact us if you have any questions or concerns."
Members of the Public/Businesses
BNP Paribas Real Estate on behalf of Royal Mail Group
"Royal Mail does not have an in principle objection to this proposed road scheme but is seeking to secure mitigations to protect its road based operations during the construction phase. Under section 35 of the Postal Services Act 2011 (the “Act”), Royal Mail has been designated by Ofcom as a provider of the Universal Postal Service. Royal Mail is the only such provider in the United Kingdom. The Act provides that Ofcom’s primary regulatory duty is to secure the provision of the Universal Postal Service. Ofcom discharges this duty by imposing regulatory conditions on Royal Mail, requiring it to provide the Universal Postal Service. The Act includes a set of minimum standards for Universal Service Providers, which Ofcom must secure. The conditions imposed by Ofcom reflect those standards. Royal Mail is under some of the highest specification performance obligations for quality of service in Europe. Its performance of the Universal Service Provider obligations is in the public interest and should not be affected detrimentally by any statutorily authorised project. Royal Mail’s postal sorting and delivery operations rely heavily on road communications. Royal Mail’s ability to provide efficient mail collection, sorting and delivery to the public is sensitive to changes in the capacity of the highway network. Royal Mail is a major road user nationally. Disruption to the highway network and traffic delays can have direct consequences on Royal Mail’s operations, its ability to meet the Universal Service Obligation and comply with the regulatory regime for postal services thereby presenting a significant risk to Royal Mail’s business. Royal Mail has five operational facilities within 6 miles of this junction, which is heavily used every day by both mail / parcel processing and delivery vehicles and is critical to its operations. In exercising its statutory duties, Royal Mail vehicles use all main roads that may be impacted by any additional traffic arising / delays during construction of this scheme. Any periods of road disruption / closure, night or day, have the potential to impact operations. Therefore, the scheme presents risk of construction phase impact / delays to Royal Mail’s operations. Royal Mail does not wish to stop or delay this scheme from being constructed. However, Royal Mail does wish to ensure the protection of its future ability to provide an efficient mail sorting and delivering service. In order to do this, Royal Mail requests that: 1. the DCO includes specific requirements that during the construction phase Royal Mail is consulted by Highways England or its contractors at least one month in advance on any proposed road closures / diversions / alternative access arrangements, hours of working, and on the content of the final CTMP, and 2. the final CTMP includes a mechanism to inform major road users (including Royal Mail) about works affecting the local highways network (with particular regard to Royal Mail’s distribution facilities near the DCO application boundary as identified above). Royal Mail reserves its position to object to the DCO application if the above requests are not adequately addressed."
Members of the Public/Businesses
The Woodland Trust
"The Woodland Trust welcomes the opportunity to register a representation to the following project. We hold significant concerns with regards to the removal of T13 and T14, two oak trees recognised as veteran specimens within the applicant’s Arboricultural Impact Assessment (AIA) Report [APP-085], alongside likely detrimental impact to a number of other veteran trees adjacent to the scheme boundary. The Trust asks that all trees displaying veteran characteristics are retained, and adequately protected during construction in line with Natural England’s Standing Advice which states: “A buffer zone around an ancient or veteran tree should be at least 15 times larger than the diameter of the tree. The buffer zone should be 5m from the edge of the tree’s canopy if that area is larger than 15 times the tree’s diameter.” We also note that Cantley Wood (grid reference: TG18290488) is referred to as potentially unmapped ancient woodland within the Botanical Survey Report [APP-087]. Natural England’s opinion on the antiquity of this site should be sought, to ensure ancient woodland is appropriately considered as part of the Examination Process. In summary, the Woodland Trust objects to the proposed development on the grounds of direct loss of veteran trees. We hope our comments are of use to you."
Members of the Public/Businesses
Transport Action Network
"Transport Action Network wishes to register our objection to the Development Consent Order for this proposed scheme. We object on the grounds of: 1. Climate change The proposed scheme would increase carbon emissions at a time of climate emergency this will make meeting the UK’s target of a 78% reduction in emissions by 2035 even more challenging than it already is. We are also concerned that not all carbon emissions have been included in this calculation, including loss of land, trees and other carbon sinks. 2. Cumulative impacts. There is significant roadbuilding planned in this area, including two other A47 schemes that are at the Examination stage (A47 North Tuddenham to Easton and the A47 Blofield to North Burlingham), and the Norwich Western link road (promoted by Norfolk County Council). The cumulative impacts of these schemes needs to be assessed thoroughly as all these schemes will increase road capacity which will increase traffic growth. This is counter to national policies to tackle climate change and air pollution, and to promote switching car journeys to public transport and active travel. 3. Air and noise pollution. As the proposed scheme will increase traffic, there will be an increase in air and noise pollution. 4. Biodiversity and Landscape The proposed scheme has a “large adverse” impact on biodiversity including veteran trees, water voles, bats and barn owls. The scheme will also significantly impact on the water environment due to the culverting of the natural alignment of the Cantley Stream, and the habitat of water voles. 5. Cultural Heritage The scheme introduces a new road into a landscape with a Scheduled Ancient Monument - two barrows at Big Wood. 6. Severance to Non-Motorised Users (NMUs) The scheme will make active travel (walking and cycling) less likely, and will cause severance to the local population."
Members of the Public/Businesses
Vattenfall Wind Power Ltd
"Vattenfall Wind Power Limited (VWPL) welcomes the chance to respond to Highways England’s (HE) A47/A11 Thickthorn Junction Improvement Scheme application. VWPL is currently developing the Norfolk Vanguard and Norfolk Boreas offshore windfarm projects. Each project has been subject to a separate DCO examination and both are currently awaiting the outcome of separate determination processes, expected toward the end of 2021. This response reflects the position of both projects (collectively referred to as the Norfolk Projects). The Norfolk Projects rely on the A47 corridor for the transport of materials and personnel to the landfall, onshore cable route, onshore substations and National Grid extension works. Construction is anticipated to commence in 2022 for Norfolk Vanguard. The most intense construction activity is forecast to occur between 2022 and the end of 2023, during this period, the project’s A47 traffic demand would peak at 693 daily movements of which 312 would be HGVs. Construction is anticipated to commence in 2023 for Norfolk Boreas (Scenario 2 - should Norfolk Vanguard not proceed) or 2027 (Scenario 1 – should Norfolk Vanguard proceed). The most intense construction activity is forecast to occur between 2023 (or 2026 for Scenario 1) and the end of 2024 (or 2027 for Scenario 1), during this period, the project’s A47 traffic demand would peak at 691 (or 181 for Scenario 1) daily movements, of which 291 (or 70 for Scenario 1) would be HGVs The A47/A11 Thickthorn Junction Improvement Scheme has a construction duration of 23 months, which (noting construction commencement early 2023) has the potential for cumulative impacts with the Norfolk Projects associated with HE’s proposed temporary traffic management proposals and construction traffic demand. VWPL has regularly engaged with HE during the development of the Norfolk Projects culminating with agreement on the approach to managing cumulative impacts as follows: “To manage potential cumulative traffic impacts, it has been agreed with HE that the management of the potential cumulative impacts can be addressed in the final submitted Traffic Management Plan (post consent) when there is greater certainty with regard to RIS scheme construction traffic data. VWPL commits to engage with HE to establish opportunities to co-ordinate activities and avoid significant impacts resulting from cumulative peak traffic is captured in the OCoCP (document reference 8.1) through the development of a Communication Plan.” VWPL would expect this regular engagement to continue with HE throughout the development and implementation lifecycle of the A47/A11 Thickthorn Junction Improvement Scheme, and be secured within the respective parties’ communication plans. VWPL has reviewed the application documents and draw attention to the following specific matters: 6.1 Environmental Statement Chapter 15 – Cumulative Effects Assessment (APP- 052) Section 15.5 identifies The Norfolk Projects and contains an assessment of cumulative effects. With regard to traffic and transport and the assessment concludes that the cumulative effects of the A47/ A11 Thickthorn Junction Scheme construction traffic in combination with the Norfolk Projects’ construction traffic would be neutral. VWPL agree with this statement in principle but would expect the implementation of a communication plan that maximises opportunities to co-ordinate roadworks and manage peak construction traffic. 7.5 Outline Traffic Management Plan (APP – 129) The Outline Traffic Management Plan identifies options for traffic management during the construction phase of the A47/A11 Thickthorn Junction Scheme, including contraflow working, lane closures and full overnight closures. These measures could potentially lead to significant delays to the A47 corridor, which could be exacerbated by the Norfolk Projects’ construction traffic. It is unclear from the construction phasing (APP-039, Table 2-3) the likely timing of these measures and therefore, it is difficult to determine the potential for disruption to construction traffic associated with the Norfolk Projects. For example, the diversion outlined could potentially induce delays of over an hour in journey time. There is also the need to consider additional management processes to ensure diverted traffic does not utilise inappropriate alternative local routes (a matter which was raised by Parish Councils during the Norfolk Projects’ examinations). However, VWPL consider that any potential cumulative impacts between the A47/A11 Thickthorn Junction Scheme and the Norfolk Projects would be mitigated by regular engagement and alignment of the respective traffic management plans. VWPL seek formal engagement with HE to gain a better understanding of the A47/A11 Thickthorn Junction Improvement Scheme roadworks proposals and to jointly formulate traffic management plans to minimise disruption to the travelling public, local communities and the respective project’s construction programmes. VWPL would seek to capture an agreed position on these items through a Statement of Common Ground."