A47 North Tuddenham to Easton

Representations received regarding A47 North Tuddenham to Easton

The list below includes all those who registered to put their case on A47 North Tuddenham to Easton and their relevant representations.

SourceRepresentation - click on an item to see more details
Members of the Public/Businesses
Graham Everett
"I am very supportive of this scheme as it will bring benefit to the areas to the west of Norwich."
Members of the Public/Businesses
Adrian Rutterford
"I have concerns regarding the access of properties in Lower Easton onto the new road. This will involve a long detour through narrow lanes."
Members of the Public/Businesses
Heather Brennecke
"As Berry's Lane, Honingham, is intended to be closed, the traffic from Barnham Broom and beyond wishing to join the A47 would cut through via Colton Road as the next available junction and would not travel to the Honingham roundabout as you propose. Colton Road is a very narrow single width residential country lane with high banks and NO passing places at all. Any increase in the present volume of through traffic would be dangerous for residents exiting their property and also for pedestrians as there is no footpath. I would ask that the junction of Colton Road with Mattishall Road be sealed off, thereby preventing all through traffic. Access for local residents to Colton Road would be via the lower junction with Norwich Road."
Members of the Public/Businesses
Weston Longville Parish Council
"The final proposal has not adequately considered a coherent side road strategy, that keeps an equal distribution of traffic moving north – south across all the routes available across the Wensum Valley but has caused a displacement of traffic onto a small number of routes which are inadequate to the task. The Wood Lane junction strategy is flawed in that it does not provide a seamless, uninterrupted traffic flow onto and off the proposed Norwich Western Link."
Members of the Public/Businesses
Catharine Hooker
"We have been assured on several occasions over the years that there was no intention to compulsory purchase any of the land surrounding [redacted] and suddenly we find that there is every intention of part of the garden being subject to compulsory purchase for absolutely no reason at all that anyone can understand. The whole family is obviously devastated to lose our garden which four generations have loved over the last fifty years."
Members of the Public/Businesses
David Hooker
"Recommendation that the Planning Inspectorate requires Highways England 1. To publish the detailed results of the Statutory Consultation. 2. To reassess and minimise the area of agricultural land needed to meet their proposals. 3. To justify the lack of a continuing direct connection for two way traffic between St Andrew’s Church, Honingham and the village. 4. To justify the removal of a direct connection between the Honingham roundabout and the existing A47. 5. To justify the necessity, size and location of their proposals for a Taverham/Norwich Road junction."
Members of the Public/Businesses
Alexander Barrett
"I have concerns about the traffic volumes on Taverham Road that will be generated by this scheme. I still have concerns over how well the main carriageway of the A47 will be shielded by trees from my eyeline at [redacted] I still have reservations whether a roundabout is really necessary at Taverham Road I would like more information on how the drainage at Taverham road will operate as we currently have severe new flooding issues both on the road and also into our garden."
Members of the Public/Businesses
Ben Hooker
"We have been assured on several occasions over the years that there was no intention to compulsory purchase any of the land surrounding [redacted] and the [redacted] Barn complex and suddenly we find that there is every intention of part of the garden being subject to compulsory purchase for absolutely no reason at all that anyone can understand. My family is obviously devastated to see my elderly parents lose their garden which four generations we have loved over the last fifty years."
Members of the Public/Businesses
Mr Joshua Hooker
"I am somewhat perplexed as to why there suddenly seems to be a compulsory land purchase order for [redacted] gardens and how this has mysteriously been added with no warning whatsoever. I am now questioning the transparency of this process."
Members of the Public/Businesses
D G M Kenney
"HE's proposal to close the Ringland Road connection to the A47 at Easton will result in the present rat-run traffic from the north (Taverham etc) being redirected westwards, down Weston Road (single width) and onto the southern mile of Taverham Road (another single lane country lane with blind bends and brows and few passing places) in order to access the A47 via the proposed new Norwich Road roundabout. HE has completely failed to address this in its strategy, repeatedly passing the issue on to NCC. The 'receptor' feedback comments have not had an adequate response - just a statement acknowledging that Taverham Road is the next access lane to the A47 from the north side once the Easton roundabout access is removed. NCC Highways has expressed concern about the implications for traffic quantities but no mitigation has been suggested. Residents have repeatedly highlighted concerns about safety (for walkers and cyclists). The potential linking of the expanding Food Hub on the southern roundabout at the new junction will draw even more traffic up and down Taverham Road. The traffic forecast figures circulated have changed constantly and there is no plan for addressing the exacerbated levels of rat-run traffic should NCC's Western Link Road not be built (and that still looks to be a strong possibility). Taverham Road is currently a beautiful, tranquil and narrow country lane, popular with cyclists. It will be destroyed by the predicted rat-running and become even more dangerous to users than it is at present. With the present proposals, Taverham Road should not have a connection onto the A47."
Members of the Public/Businesses
Peter Milliken
"I would like to make representation in support of this application. At present there is no safe way to get to a part of our village on foot or by cycle which limited the travel options of this part of our community to only being able to travel by motor vehicle and even then may Easton residents prefer not to cross the roundabout on the A47 near St Peters Church because of the actual and preceded dangers due to the high speed of traffic on the A47 not slowing down as they approach the roundabout. At present, Church Lane sees at least 4800 on average daily motor vehicle journeys along Church Lane and Ringland Road. This is an unclassified county track. The scheme devised stops the rat-running traffic and provides a safe and secure means for residents to move around the whole village on foot, by cycle, wheelchair or mobility scooter. With the proposed plan the dispersed traffic will use more suitable C and B class roads in the local area. This plan even protects the residents of Ringland against rat-running which NCC Highways has to date not been prepared to do. Highways England engaged, you listened, you developed a locally agreed proposal and now it is time to implement without any further delay."
Members of the Public/Businesses
Wensum Valley Alliance
"The WVA (Wensum Valley Alliance) is concerned about the Road Building proposals for the County generally, but particularly for the impact upon the Chalk streams and river environments on the grounds of (a) cumulative effect upon eco systems and the environment generally e.g. this proposal takes down existing woodland and damages areas adjacent to the River Tud, but this also applies to the Thickthorn roundabout proposals and the Cant stream, and to the North Burlingham proposals. How many mature trees will be lost in combination ? How much farmland is taken ?. How many Country Wildlife and special interest Sites ? (b) the failure to acknowledge that "mitigation" in current forms is not a solution to the disruption to eco-systems during the years of survey, construction and after for years."
Members of the Public/Businesses
Bryan Robinson
"HE comments to Norfolk County Council on the NWL Scoping application stated that until such time as the A47 DCO is approved and delivery confirmed, the impact of and mitigation for the NWL should be considered with and without the A47 dualling. TR010038 should reciprocate with a base assessment without the NWL to establish environmental and climate changes from the existing situation as the core design with an alternative scenario reflecting the NWL. At present the environmental and climate figures are the extra over implications with the NWL but miss the impact of increased traffic due to the NWL above present traffic and emission levels. The submission does include a brief comparison without the NWL (DS1 map - fig 4.27 Doc 7.1) on which the numbers suggest that the Wood Lane junction is overdesigned, solely to accommodate the NWL and the creation of a dominant Norwich outer ring road. The design of all junctions is questionable, ranging from the known inadequacy of the existing Fox Lane, which HE deems acceptable, to the overdesign of both the Wood Lane and Norwich Road junctions when compared to design proposed in the concurrent TR010040 scheme. Reference is made to the controversial Food Enterprise Park near Easton. Its LDO approval in 2017 was largely dependent upon a future access from an upgraded A47. The existing Blind Lane is required to be closed, whatever happens to the A47. The TR010038 documents are ambiguous, stating that the site can be connected to the new side road (Dereham Road) but stating that there is no requirement for it to be accessed directly from the A47, given the approved alternative route along Church Lane, Easton. If the latter is true, there is no necessity for the dumbbell roundabout near Blind Lane/Taverham Road, and this should be initiated and paid-for, if made necessary, by others. Local traffic could access the new A47 via the Wood Lane or Longwater junctions. The requirement of access to Honingham church and the minor traffic using Taverham Road can be catered for with a small spur underpass off Dereham Road, and no need at all for a junction at Blind Lane/Norwich Road, with a much lower cost and land requirement. Other issues, amongst many more which I will raise at the earliest opportunity, are that the BCR calculations appear to contain errors; the agglomeration benefits specific to TR010038 lack evidence; and the climate change/carbon emissions calculation figures which do not establish changes from existing levels and are distorted by the predetermination of the NWL and do not include all the categories in the Carbon tool workbook 2.3 nor is there an inclusion for change of land use/biomass removal. There is an unrealistic assumption that the NWL calculations by others will include the impact of emissions for that scheme for A47 traffic which is excluded from this submission. Therefore, under the cumulative process this submission should reflect these impacts or they will disappear into the ether."
Members of the Public/Businesses
Transport Planning Associates on behalf of Clarion Housing Group
"We wish to make additional representations to those already made in relation to the A47 road improvements consultation, on behalf of our clients, Clarion Housing Group. In making these further comments we reaffirm our support of the grade separated junction in this position as part of the A47 highway improvements We note the indicative location for the potential future FEP access , that is being proposed by yourselves, facilitates the possibility to provide a satisfactory vehicular link to the Food Enterprise Park(FEP) which is required to connect to the A47 once the dualling has taken place. The level and type of vehicular traffic that will be seeking access and egress from the FEP will require a road connection that is substantially better than the current configuration of Blind Lane however. In addition, there are existing employment at Honingham Thorpe Farm Business park (300 staff) as well as the farming activities that would need to be accommodated at this junction. The proposed scheme will enable growth in and around Norwich, specifically the FEP and the Honingham Thorpe Settlement which would deliver c5,000 new homes."
Members of the Public/Businesses
David Lewis
"Subject: Closure of Church Lane, Lower Easton Dear James and the Highways team, I wish to express my gratitude to you for producing the planned changes to the road system in Lower Easton, as well as the new footbridge across the A47. For the first time in 30 years I will soon be able to walk along Ringland Road without the danger of speeding traffic, HGVs etc and access the rest of my village safely across the new footbridge. For 30 years it has been impossible to leave my house on foot and have a walk up the road towards Easton for fear of becoming a statistic. I look forward to the start of roadworks to dual the A47 and remove the rat running traffic that plagues Lower Easton at present. I will no longer have to put up with HGVs passing within half a metre of the front wall of my house and damaging my property. My near neighbours are also pleased with your plans as their properties are also being damaged by the heavy traffic that we are currently experiencing along Ringland Road. Thank you for all your hard work. Kind Regards, David Lewis"
Members of the Public/Businesses
response has attachments
Childhood First
"We wish to make a representation to confirm the arrangements we made with Highways England who have altered their plans to prevent disruption to one of our children's homes which is adjacent to the a47 development. We want the inspectorate to ensure that the new arrangements are honoured. The representation will consist of a brief letter and minutes of the meeting with HE. This will be submitted as an email and attachments."
Members of the Public/Businesses
CPRE Norfolk
"CPRE Norfolk does not agree with the need for an optional arm at the proposed Wood Lane Junction Northern Dumbbell roundabout and therefore that part of the junction needs to be redesigned. This is due to the supposed unlawfulness of the proposed Norwich Western Link road and therefore no junction of that proposed road with the A47 will be required. Volume 6. 6.3 Environmental Statement appendices. Appendix 7.7 Lighting Assessment. CPRE Norfolk's understanding is that artificial lighting for the proposed junctions, slip roads and associated roundabouts is not a legal requirement. There are plenty of local examples where roundabouts on major routes maintained by the County Council are not artificially lit e.g. the Pulham roundabout on the A140 and roundabouts along the Broadland Northway. We wish to see clear evidence why lighting such as that which is proposed is a necessity, given the intrusion this would cause to sensitive and currently dark landscapes, particularly given much of the new infrastructure would be visible from the River Tud and its valley. Section 2.2 of the Lighting Assessment (Local Policy) does not refer to Norfolk County Council's Environmental Lighting Zones Policy: this is something which needs to be addressed, as all the areas being proposed for artificial lighting are within the area designated as "rural dark landscape" within this policy. If, despite these concerns, artificial lighting is approved, CPRE Norfolk requests that it should incorporate dimming technology and should involve the use of white LED lamps mounted in full cut off flat glass shields."
Members of the Public/Businesses
Edward Bown
"- concern about the NMU link between Hockering and Mattishall - concern about the lack of noise barrier between Hockering and the new road. speeds on the new road will be higher, there will be a lot more traffic therefore noise from the road is likely to increase. there is already some level of A47 noise in Hockering, this should decrease rather than increase when this project opens. - concern about the NMU link between Hockering east and west (there would be a clear benefit of an NMU route between Dereham and Norwich to reduce the reliance on private motor vehicles."
Members of the Public/Businesses
Howard James Rees
"This scheme is not consistent with the UK's commitments under the Paris Agreement. It also falls foul of many areas of Government commitments, policy and legislation regarding limits on greenhouse gas emissions and the protection of biodiversity, particularly in relation to the Ecological damage it will cause to the River Tudd and the habitats of many protected species including bat roosts."
Members of the Public/Businesses
John Cummings
"The Supreme Court has ruled that developments must accord with government commitments under the Paris Accord (which will include current G7 and CoP26 commitments. This means that Road traffic must be greatly reduced, biodiversity enhanced and air pollution reduced. Since the whole world is being affected by climate change and species loss, which will get worse for generations to come, everyone is an interested party."
Members of the Public/Businesses
Easton Parish Council
"On behalf of Easton Parish Council as chairman representing the unanimous support of the Parish Council members at a meeting of the council on the 27th May 2021, I make representation in support of this application. At present, there is no safe way to get to a part of our village on foot or by cycle which limited the travel options of this part of our community. The only safe way to travel is by motor vehicle and even then many Easton residents prefer not to cross the roundabout on the A47 near St Peters Church because of the actual and preceded dangers due to the high speed of traffic on the A47 not slowing down as they approach the roundabout. At present, Church Lane sees at least 4800 on average daily motor vehicle journeys along Church Lane and Ringland Road. This is an unclassified county track. The scheme devised stops the rat-running traffic and provides a safe and secure means for residents to move around the whole village on foot, by cycle, wheelchair or mobility scooter as well as a motor vehicle. This design is supported by the majority of residents as it will help improve the lives of the residents of Easton as a whole. With the proposed plan the dispersed traffic will use more suitable C and B class roads in the local area. This plan even protects the residents of Ringland against rat-running which NCC Highways has to date not been prepared to do. The current plan will improve the economic benefits of the area while improving road safety on this stretch of the A47. It will remove flooding from a stretch of the A47 which has seen major delays and accidents over the years and with climate change has been increasing in recent years. The removal of direct access to many side roads will reduce collisions in the area that have lead to serious injury and in some cases death. The only area of concern as a community we have is concerning the current lack of designed direct access from the FEP onto the A47. We fully accept it is not the responsibility of HE to use public money to build a stretch of road for a private business. However, we feel given that this site and the designated area forms part of the FEZ for this region it is of strategic importance as part of the food supply chain for the region it is vital to ensure everything is done to support a direct link to the A47 even if HE was to provide the connection point and suitable grading to enable access to be created. Highways England engaged, you listened, you developed a locally agreed proposal and now it is time to implement without any further delays."
Members of the Public/Businesses
Brown & Co on behalf of A L Alston & Sons Ltd
"We wish to make representations on behalf of A L Alston & Sons Ltd concerning the configuration of the proposed grade separate junction at Wood Lane. We have been engaged with Highways England at all the consultation stages that form part of the preparation of the highway improvements for the A47 in Norfolk. We have generally been supportive in developing a junction for Wood Lane which involves a proportion of our clients land. Our concern relates to a section of land bounded by the improved A47, and a side road leading from the Wood Lane junction westwards towards Hockering. It has been the intention of the landowner to promote the land (approximately 9 acres) for roadside services including a petrol filling / EV station. We have indicated our intentions over a lengthy period via letters and e-mails with the relevant Councils and Highways England. We can provide if necessary copies of representations, e-mails and letters to date. The subsequent road scheme that has been submitted shows the area concerned now the subject of landscaping/biodiversity net gain initiatives. This is illustrated on sheets 6 & 7 of the Environmental Masterplan (6.8). We believe that these biodiversity net gains can be achieved on an alternative section of our clients land to the south of the improved A47 where half of the land is proposed in part for an attenuation pond. We believe that the alternative position of for these measures, on an area of land already being used to deal with drainage matters, would be more appropriate and link to existing woodland to the south. Our client also has additional land to the north if it is needed. We have not been able to submit proposals as a planning application for our roadside services as the design of the Wood Lane junction was not fixed until a late stage. We don’t believe that the landscaping proposals formed part of any consultation undertaken by Highways England so we haven’t had the opportunity to discuss potential alternatives. By the time any discussion occurred the application had already been submitted. In summary, we object to the use of this area of land being used for landscape purposes and that there are reasonable alternatives to where the landscaping/biodiversity net gain solutions can be sited. This will allow appropriate roadside services to be sited at this junction."
Members of the Public/Businesses
Brown & Co on behalf of Honingham Aktieselskab
"We have received limited feedback on requests although 12 months or so ago, there were numerous meetings to discuss the scheme. The Farm is large and private and the owners would like it to remain so. If the scheme is to proceed, they accept the broad alignment, but would have preferred the route to be further to the edge of the farm as it introduces noise and visual and land use intrusion further into the farm than is ideal. We have made it clear that we are keen to work with HE to agree how to mitigate the impact, but with less success than we might have expected. We are advised that there is an embankment between Wood Lane and [redacted] but not between Taverham Road and Easton roundabout, at Lower Easton. We have not been able to discuss proactively whether the embankment design is suitable and would have liked to ensure that the mitigation is as good as possible. We are advised the bank is 2m in height and HE provided some drawings, but which few people have been able to interpret. To assist, we have employed consultants to prepare visualisations to assess whether 2m height is sufficient or more or less than is required. In most places the height is too low and increasing the bank to 3m or in some places to 4m would make a significant improvement in the future reduction in noise and increase in privacy and limit the reduction in value. Some places benefit from more height to a greater extent. We have requested discussions about the design of the embankment and will still be pleased to discuss it. There are two principle areas along the route where there will be no visual screening, so we have requested 3m high fences at carriageway level to minimise the impact of high sided vehicles. We would benefit from screening with fencing between Taverham Road and Easton Roundabout to enable the tree planting to become established. There are gaps in the embankment at the [redacted] entrance and south east of [redacted] where we suggest the banks should be extended. There is a local roads closure order proposed, which will impact upon the farm traffic gaining access to owned land north of the river as the farm access is along Honingham Lane. The farm needs a private right or for the road to remain open to enable access, but this has not been discussed. The [redacted] entrance was discussed around 12 months ago or more. We advised that the underpass needs to be a minimum of 5m in height and wide enough to provide a public right of way separate from farm traffic. We have not had confirmation that this is agreed, although we have provided evidence that 5m is necessary for articulated lorries. We have had no discussion about the specification for the modified farm access but it should be no less good than the existing roadway. Other accesses are not available for articulated lorries without building a new road across the farm, at vast expense. We have requested discussions about gates, hedges and fences but not agreement. The water supply to [redacted] will be cut off and we have not received confirmation that the meter will be moved to the north of the scheme works. Access to the fields north of the Lower Easton stretch of road needs to be provided, but is not yet allowed for as far as we are aware. We remain keen to deal with as many of these issues as we can outside of the Inquiry, but do need more co-operation."
Members of the Public/Businesses
Lesley Grahame
"A. Increasing road capacity increases traffic, and fails to support the aspiration to shift travel mode from car to active travel B. Committing to new roads without knowing how our post-covid travel patterns will change is hasty, ignores up to date evidence and is likely to waste vast amounts of money and irreplacebale open land C. It is at best spurious to ignore up to date evidence about travel patterns while at the same using modelling based on the completion of other road schemes, which do not have current planning permission. D The relationship between road schemes, and their cumulative impact on land use and biodiversity loss needs to be examined E. Traffic modelling based on 2015 is clearly out of date F. The loss of trees, bats and wildlife habitat is simply not justified G. The cumulative impacts on biodiversity & habitat loss, carbon emissions and climate require full assessment The recent judgement of Pearce v Secretary of State BEIS [2021] demonstrates that the Courts accept the importance of cumulative environmental impact assessment. H. Increasing carbon emissions go against the letter and spirit of the Paris agreement, the legally binding target under the Climate Change Act 2008 and the need to stay within the 6th carbon budget I. The nationally significan babastel bat colonies merit protection"
Members of the Public/Businesses
Nick Bishop-Clark
"I object to the proposed scheme for these reasons: A. The case for the scheme (at 3.5.1) says that it will increase capacity which means that it will increase traffic growth in Norwich area. This does not comply with national policies for climate change and modal shift towards walking, cycling and public transport. B. The traffic and economic modelling uses data, assumptions and projections from before the Covid 19 pandemic. Recent and future levels of home-working, the shift towards Internet-based meetings, and strong reductions of traffic on the roads due to COVID impacts need to be assessed against the supposed need for “increased capacity”. C. The application and traffic modelling assume that the Norwich Western link is already built. To comply with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017, the environmental statement should start from the current situation now as the environmental baseline. D. The A47 dualling links with the Norwich Western link. The application does not fully explore the relationships between the two road proposals, and needs to be fully examined at the examination. E. The traffic modelling is based on the NATS 2015 (baseline year 2015) model. Recent modelling by Norfolk County Council based on the newer NATS 2019 (baseline year 2019) model reports substantially lower (c. -30%) vehicle kilometres within the scheme area. The discrepancies need to be examined, and the models fully reconciled. F. The scheme involves fragmentation, loss or displacement of diminishing wildlife habitats such as wet grazing meadows and protected species, notably bats and the urbanisation of mature countryside. G. In-combination, and cumulative impacts, for biodiversity, ecology, air quality and carbon emissions have not been assessed with at least six other road infrastructure schemes near to Norwich and East Norfolk. Carbon emissions need to be cumulatively assessed both locally within this area, and nationally with up to 100 other schemes planned. The recent judgement of Pearce v Secretary of State BEIS [2021] demonstrates that the Courts accept the importance of cumulative environmental impact assessment. H. Carbon emissions should be tested against inter/national legislation and guidance including the Paris agreement, the legally binding target under the Climate Change Act 2008 to meet net-zero carbon emissions by 2050, the UK Sixth Carbon Budget (6CB), science-based carbon budgets from the Tyndall Centre, NPPF 148 which requires the planning system contribute to “radical reductions of greenhouse gas emissions”. I. Norfolk County Council has identified that the area north of the scheme has a nationally significant breeding barbastelle colony of bats, recently found, which although not yet afforded SSSI or SAC status would otherwise qualify as such (see: page 85 in NCC submission to PINS on the A47/A11 Thickthorn Junction, June 3rd, at [redacted]). The in-combination, and cumulative impacts, of the A47 dualling with the Norwich Western link road on this European protected species should be assessed under Part 3, Section 40 of the Natural Environment and Rural Communities Act 2006."
Members of the Public/Businesses
Olivia Hanks
"I am concerned that this scheme is being considered in isolation and that the application does not consider the relationship with other road infrastructure projects, in particular the proposed Norwich Western Link. The cumulative impact on carbon emissions and ecology from this and at least six other road expansion projects currently proposed in the Greater Norwich and East Norfolk area would be very significant, yet there has been no assessment of these cumulative impacts. Norfolk County Council has identified that the area north of the scheme has a nationally significant breeding barbastelle colony of bats. The cumulative impacts of this scheme with the Norwich Western Link on this protected species should be assessed under Part 3, Section 40 of the Natural Environment and Rural Communities Act 2006. The UK has committed to achieve ‘net zero’ carbon emissions by 2050. This requires very rapid emissions reductions across all sectors; major new projects should be able to demonstrate how they are compatible with this target and with the UK’s legally binding carbon budgets under the Climate Change Act 2008. The case for this scheme says that it will increase capacity, i.e. it will contribute to additional traffic. This is not in line with either the UK’s ‘net zero’ commitment or the need for modal shift away from car use towards walking, cycling and public transport."
Members of the Public/Businesses
Roc Sandford
"This project is inconsistent with national planning policies and the Paris agreement calling for a shift to low carbon transport modes."
Members of the Public/Businesses
Anne Robinson
"I object to the proposed scheme for the following reasons: 1. The case for the scheme (at 3.5.1) says that it will increase capacity. 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 traffic and economic modelling uses data, assumptions and projections from before the Covid 19 pandemic and Brexit. Recent and future levels of home-working, the shift towards Internet-based meetings, and strong reductions of traffic on the roads due to COVID impacts and changed patterns of journeys due to Brexit all need to be assessed against the supposed need for “increased capacity”. 3. The Infrastructure Planning (Environmental Impact Assessment) Regulations 2017 require the environmental statement to start from the existing environmental baseline but the application and traffic modelling assume that the Norwich Western link is already built. 4. The A47 dualling links with the Norwich Western link. The relationships between the two road proposals has not been fully explored but needs to be through the examination. 5. The traffic modelling is based on the NATS 2015 (baseline year 2015) model. Recent modelling by Norfolk County Council based on the newer NATS 2019 (baseline year 2019) model reports substantially lower (c. -30%) vehicle kilometres within the scheme area. The discrepancies need to be examined, and the models fully reconciled. 6. The scheme would fragment and destroy important wildlife habitats such as wet grazing meadows and lead to displacement of protected species, particularly bats. 7. The cumulative impacts on biodiversity, ecology, air quality and carbon emissions have not been assessed for the scheme with the (at least six) other road infrastructure schemes near to Norwich and East Norfolk. Carbon emissions must be cumulatively assessed both locally, and nationally with up to 100 other schemes planned. The Courts accept the importance of cumulative environmental impact assessment (Pearce v Secretary of State BEIS 2021). 8. 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. 9. The area north of the scheme has a nationally significant breeding colony of barbastelle bats which would qualify for, but is not yet protected by, SSSI or SAC status (page 85 in NCC submission to PINS on the A47/A11 Thickthorn Junction, June 3rd, at http://bit.ly/NCC_PlanDeleg_June2021). The cumulative impacts of the A47 dualling with the Norwich Western link road on this European protected species should be assessed under Part 3, Section 40 of the Natural Environment and Rural Communities Act 2006."
Members of the Public/Businesses
Deepak Rughani
"I object to the proposed scheme for these reasons: A. The case for the scheme (at 3.5.1) says that it will increase capacity which means that it will increase traffic growth in Norwich area. This does not comply with national policies for climate change and modal shift towards walking, cycling and public transport. B. The traffic and economic modelling uses data, assumptions and projections from before the Covid 19 pandemic. Recent and future levels of home-working, the shift towards Internet-based meetings, and strong reductions of traffic on the roads due to COVID impacts need to be assessed against the supposed need for “increased capacity”. C. The application and traffic modelling assume that the Norwich Western link is already built. To comply with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017, the environmental statement should start from the current situation now as the environmental baseline. D. The A47 dualling links with the Norwich Western link. The application does not fully explore the relationships between the two road proposals, and needs to be fully examined at the examination. E. The traffic modelling is based on the NATS 2015 (baseline year 2015) model. Recent modelling by Norfolk County Council based on the newer NATS 2019 (baseline year 2019) model reports substantially lower (c. -30%) vehicle kilometres within the scheme area. The discrepancies need to be examined, and the models fully reconciled. F. The scheme involves fragmentation, loss or displacement of diminishing wildlife habitats such as wet grazing meadows and protected species, notably bats and the urbanisation of mature countryside. G. In-combination, and cumulative impacts, for biodiversity, ecology, air quality and carbon emissions have not been assessed with at least six other road infrastructure schemes near to Norwich and East Norfolk. Carbon emissions need to be cumulatively assessed both locally within this area, and nationally with up to 100 other schemes planned. The recent judgement of Pearce v Secretary of State BEIS [2021] demonstrates that the Courts accept the importance of cumulative environmental impact assessment. H. Carbon emissions should be tested against inter/national legislation and guidance including the Paris agreement, the legally binding target under the Climate Change Act 2008 to meet net-zero carbon emissions by 2050, the UK Sixth Carbon Budget (6CB), science-based carbon budgets from the Tyndall Centre, NPPF 148 which requires the planning system contribute to “radical reductions of greenhouse gas emissions”. I. Norfolk County Council has identified that the area north of the scheme has a nationally significant breeding barbastelle colony of bats, recently found, which although not yet afforded SSSI or SAC status would otherwise qualify as such (see: page 85 in NCC submission to PINS on the A47/A11 Thickthorn Junction, June 3rd, at [redacted]). The in-combination, and cumulative impacts, of the A47 dualling with the Norwich Western link road on this European protected species should be assessed under Part 3, Section 40 of the Natural Environment and Rural Communities Act 2006."
Members of the Public/Businesses
Dr Larch Maxey
"I object to this proposed road scheme for these reasons: A. As someone who has researched, practiced and taught transport policy and planning since 1993 it is clear that this scheme will lead to more traffic, accelerating the risk of climate induced societal collapse and increasing premature deaths from air pollution. Indeed, the case for the scheme (at 3.5.1) says that it will increase capacity ie allow m ore traffic. This scheme therefore breaches national policies for climate change and modal shift towards walking, cycling and public transport. B. The scheme employs modelling data, assumptions and projections from before the Covid 19 pandemic, e.g. for traffic and economic projections. Recent and future levels of home-working, the shift towards Internet-based meetings, and strong reductions of traffic on the roads due to COVID impacts need to be assessed against the supposed need for “increased capacity”. This is particularly true when considered against the overriding policy imperatives to reduce emissions and pollution and thus enhance not undermine these traffic reducing trends. C. The environmental statement should start from the current situation, not, as this application currently does, from an assumption that the Norwich Western link is already built. The application and traffic modelling thus fail to comply with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017, by failing to take the current environmental and infrastructure context as the starting point. As is clear throughout the planning system we must avoid planning by stealth and anything that smacks of corruption and failure to uphold the highest standards of probity and process. D. My above point re the need to avoid planning by stealth also relates to the A47 dualling's links with the Norwich Western link. The application fails to adequately explore the relationship between the two road proposals, and such relationships and, why they have thus far been largely ignored, needs to be fully examined. E. The traffic modelling is based on the NATS 2015 (baseline year 2015) model. Recent modelling by Norfolk County Council based on the newer NATS 2019 (baseline year 2019) model reports substantially lower (c. -30%) vehicle kilometres within the scheme area. The discrepancies need to be examined, and the models fully reconciled. F. Given that we are in a nature, or ecological emergency as well as a climate emergency, as noted by parliament in 2019 and the loss of nature alone threatens human extinction, the scheme's destruction and fragmentation of rare habitats such as wet grazing meadows and those home to protected species, notably bats, needs careful examination. As has been well established in the literature and practice associated developments risk exacerbating this scheme's tendency to detrimentally urbanise mature, rare and biodiverse countryside. G. I urge that this inspection exercise take the larger view and avoid piecemeal landing be stealth. In-combination, and cumulative impacts, for biodiversity, ecology, air quality and carbon emissions have not been assessed with at least six other road infrastructure schemes near to Norwich and East Norfolk. Carbon emissions need to be cumulatively assessed both locally within this area, and nationally with up to 100 other schemes planned. The recent judgement of Pearce v Secretary of State BEIS [2021] demonstrates that the Courts accept the importance of cumulative environmental impact assessment. H. Carbon emissions should be tested against inter/national legislation and guidance including the Paris agreement, the legally binding target under the Climate Change Act 2008 to meet net-zero carbon emissions by 2050, the UK Sixth Carbon Budget (6CB), science-based carbon budgets from the Tyndall Centre, NPPF 148 which requires the planning system contribute to “radical reductions of greenhouse gas emissions”. I. Norfolk County Council has identified that the area north of the scheme has a nationally significant breeding barbastelle colony of bats, recently found, which although not yet afforded SSSI or SAC status would otherwise qualify as such (see: page 85 in NCC submission to PINS on the A47/A11 Thickthorn Junction, June 3rd, at http://bit.ly/NCC_PlanDeleg_June2021). The in-combination, and cumulative impacts, of the A47 dualling with the Norwich Western link road on this European protected species should be assessed under Part 3, Section 40 of the Natural Environment and Rural Communities Act 2006."
Members of the Public/Businesses
Dr Matt Tomlinson
"I wish to raise environmental points related to climate change and increasing road capacity. The impact this dual carriageway has on the local wildlife and on the wider impact via co2 driven climate change."
Members of the Public/Businesses
Edward Kevin OHara
"I am concerned that most (if not all) examinations as to where we go with transport in the immediate future do not take account of the imminent full self-driving technologies expected to break over our heads within the next few years. These changes which with transform our societies will bring unknown changes to the way we organise transport - but most experts agree that the result will be far fewer vehicles, especially those owned by individuals (and so less "road use") and possibly different patterns of road use. These ideas don't seem to figure in the thinking of those who plan the expansion of our road system. It is essential that they do if we are to minimise misplaced capital spending."
Members of the Public/Businesses
Emma Tristram
"I object to the proposed scheme for these reasons: A. The case for the scheme (at 3.5.1) says that it will increase capacity which means that it will increase traffic growth. ''If road capacity increases, peak-period trips also increase until congestion again limits further traffic growth. The additional travel is called “generated traffic.”' (Todd Littman, Victoria Transport Policy Institute) This is incompatible with the Government's goals on climate change and modal shift. B. The traffic and economic modelling uses data, assumptions and projections from before the Covid 19 pandemic. Recent and future levels of home-working, and the shift towards Internet-based meetings, mean that traffic figures for the scheme (which are based on a 2015 baseline) are out of date. C. The scheme involves fragmentation, loss or displacement of diminishing wildlife habitats such as wet grazing meadows and protected species, notably bats and the urbanisation of mature countryside. Today's news shows that George Eustice has stated in response to the Dasgupta Report that all new infrastructure projects must have a positive effect on nature. D. Carbon emissions need to be cumulatively assessed both locally within this area, and nationally with up to 100 other schemes planned. Phil Goodwin, emeritus professor of transport policy at UCL, said in a deposition for the Transport Action Network legal case against the roads programme that “the total emissions of carbon from RIS2 schemes reported by Highways England in its separate scheme appraisals give a number which is roundly 100 times greater than that suggested by DfT witnesses.' E. Norfolk County Council has identified that the area north of the scheme has a nationally significant breeding barbastelle colony of bats, recently found. The in-combination, and cumulative impacts, of the A47 dualling with the Norwich Western link road on this European protected species should be assessed under Part 3, Section 40 of the Natural Environment and Rural Communities Act 2006."
Members of the Public/Businesses
Joe McCarney
"I object to the proposed scheme for these reasons: A. The case for the scheme (at 3.5.1) says that it will increase capacity which means that it will increase traffic growth in Norwich area. This does not comply with national policies for climate change and modal shift towards walking, cycling and public transport. B. The traffic and economic modelling uses data, assumptions and projections from before the Covid 19 pandemic. Recent and future levels of home-working, the shift towards Internet-based meetings, and strong reductions of traffic on the roads due to COVID impacts need to be assessed against the supposed need for “increased capacity”. C. The application and traffic modelling assume that the Norwich Western link is already built. To comply with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017, the environmental statement should start from the current situation now as the environmental baseline. D. The A47 dualling links with the Norwich Western link. The application does not fully explore the relationships between the two road proposals, and needs to be fully examined at the examination. E. The traffic modelling is based on the NATS 2015 (baseline year 2015) model. Recent modelling by Norfolk County Council based on the newer NATS 2019 (baseline year 2019) model reports substantially lower (c. -30%) vehicle kilometres within the scheme area. The discrepancies need to be examined, and the models fully reconciled. F. The scheme involves fragmentation, loss or displacement of diminishing wildlife habitats such as wet grazing meadows and protected species, notably bats and the urbanisation of mature countryside. G. In-combination, and cumulative impacts, for biodiversity, ecology, air quality and carbon emissions have not been assessed with at least six other road infrastructure schemes near to Norwich and East Norfolk. Carbon emissions need to be cumulatively assessed both locally within this area, and nationally with up to 100 other schemes planned. The recent judgement of Pearce v Secretary of State BEIS [2021] demonstrates that the Courts accept the importance of cumulative environmental impact assessment. H. Carbon emissions should be tested against inter/national legislation and guidance including the Paris agreement, the legally binding target under the Climate Change Act 2008 to meet net-zero carbon emissions by 2050, the UK Sixth Carbon Budget (6CB), science-based carbon budgets from the Tyndall Centre, NPPF 148 which requires the planning system contribute to “radical reductions of greenhouse gas emissions”. I. Norfolk County Council has identified that the area north of the scheme has a nationally significant breeding barbastelle colony of bats, recently found, which although not yet afforded SSSI or SAC status would otherwise qualify as such (see: page 85 in NCC submission to PINS on the A47/A11 Thickthorn Junction, June 3rd, at http://bit.ly/NCC_PlanDeleg_June2021). The in-combination, and cumulative impacts, of the A47 dualling with the Norwich Western link road on this European protected species should be assessed under Part 3, Section 40 of the Natural Environment and Rural Communities Act 2006."
Members of the Public/Businesses
John Greenaway
"The long-term effects of Covid -19 on such things as home working will reduce the need for more road capacity and this needs to be taken into account at the inquiry. The proposed road scheme seems to run counter to the government policy of encouraging a modal shift away from car use to public transport, cycling and walking and to the overriding desire to reduce carbon emissions. How does the scheme meet the legally-binding target under the Climate Change Act 2008 to meet zero climate emissions by 2050? The scheme will have a most undesirable impact upon the environment by diminishing wildlife habitats and adversely affecting protecting species such as bats. The cumulative affect of the A47 dualling, the Western Link Road, Thickthorn roundabout remodelling and their combined impact needs to be considered by the enquiry."
Members of the Public/Businesses
Mireille Heald
"I object to the proposed scheme for these reasons: A. The case for the scheme (at 3.5.1) says that it will increase capacity which means that it will increase traffic growth in Norwich area. This does not comply with national policies for climate change and modal shift towards walking, cycling and public transport. B. The traffic and economic modelling uses data, assumptions and projections from before the Covid 19 pandemic. Recent and future levels of home-working, the shift towards Internet-based meetings, and strong reductions of traffic on the roads due to COVID impacts need to be assessed against the supposed need for “increased capacity”. C. The application and traffic modelling assume that the Norwich Western link is already built. To comply with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017, the environmental statement should start from the current situation now as the environmental baseline. D. The A47 dualling links with the Norwich Western link. The application does not fully explore the relationships between the two road proposal, and needs to be fully examined at the examination. E. The traffic modelling is based on the NATS 2015 (baseline year 2015) model. Recent modelling by Norfolk County Council based on the newer NATS 2019 (baseline year 2019) model reports substantially lower (c. -30%) vehicle kilometres within the scheme area. The discrepancies need to be examined, and the models fully reconciled. F. The scheme involves fragmentation, loss or displacement of diminishing wildlife habitats such as wet grazing meadows and protected species, notably bats and the urbanisation of mature countryside. G. In-combination, and cumulative impacts, for biodiversity, ecology, air quality and carbon emissions have not been assessed with at least six other road infrastructure schemes near to Norwich and East Norfolk. Carbon emissions need to be cumulatively assessed both locally within this area, and nationally with up to 100 other schemes planned. The recent judgement of Pearce v Secretary of State BEIS [2021] demonstrates that the Courts accept the importance of cumulative environmental impact assessment. H. Carbon emissions should be tested against inter/national legislation and guidance including the Paris agreement, the legally binding target under the Climate Change Act 2008 to meet net-zero carbon emissions by 2050, the UK Sixth Carbon Budget (6CB), science-based carbon budgets from the Tyndall Centre, NPPF 148 which requires the planning system contribute to “radical reductions of greenhouse gas emissions”."
Members of the Public/Businesses
response has attachments
Norfolk County Council
"While the County Council has long supported the principle of full dualling of the A47 – and this proposal is consistent with that objective – 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 items of concern relate to resolving issues related to: • How to deal with traffic issues rising on the local road network should the Norwich Western Link (NWL) not come forward, or not come forward within a reasonable time period after the dualling scheme • Connections to the Food Enterprise Park • The County Council taking on responsibilities for parts of the existing A47 trunk road that will be de-trunked following the scheme. In summary the County Council supports the principle of dualling the A47 between North Tuddenham to Easton 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."
Members of the Public/Businesses
Norwich Green Party Group of City and County Councillors
"Norwich and Norfolk Green Party councillors (twelve councillors) object: Scheme is over-engineered at considerable loss to the local and global environment. AADT flows in base scenario are modest compared to many parts of SRN. Highway is currently operating just below available capacity during AM and PM peaks eastbound. We request travel analysis data to show scope for influencing travel behaviour along corridor. Highways England A47 studies found travel along corridor is predominantly local. The scheme is intended to increase road capacity and facilitate traffic growth. Traffic surveys, traffic model and traffic forecast use inputs that pre-date the Covid-19 pandemic. The latter has most likely resulted in permanent flexible working and a change in travel patterns, with fewer car commuting trips at peak times. It is likely that future traffic growth, time savings and economic benefits have been over-estimated and a larger scheme designed than is necessary. The DM and DS models are unreliable and sensitivity tests do not take sufficient account of and uncertainties. We request new surveys, updated traffic model and revised forecast. The large increase in greenhouse gas emissions is incompatible with 2015 Paris Agreement and new legally-binding target of 78% cut in emissions over 1990 levels by 2035. Even so, the estimated increase excludes emissions from several sources, for example, vegetation removal and traffic from developments facilitated by scheme. Moreover, this is one of three A47 schemes close to Norwich undergoing examination simultaneously (North Tuddenham, Thickthorn, Blofield). In total, seven road schemes are planned for construction in Greater Norwich/ East Norfolk by 2025. The synergistic effect of significant new road capacity on induced traffic and their cumulative impacts on climate change would be considerable, but the NWL is the sole road scheme referenced in Cumulative Effects Assessment (6.1). HE must assess cumulatively impacts of full set of schemes on GHG emissions. A ‘Large Adverse’ impact on biodiversity would reinforce UK’s position as one of the most nature depleted countries. The scheme involves fragmentation or loss of diminishing wildlife habitats and unquantifiable adverse impacts on protected species. Eg bats and water voles would suffer direct mortality. It would see further urbanisation of ancient countryside around Norwich. The three A47 schemes and NWL would have a deleterious cumulative impact on biodiversity and landscape. This has not been recognised and should be assessed. We object to Wood Lane junction for connecting NWL with A47. Surveys record a nationally significant barbastelle bat colony in NWL area. Responding to A47/A11 Thickthorn upgrade, NCC acknowledges that the colony size would qualify for pSAC status. Planning approval of NWL is by no means certain. HE should assess ‘Without NWL’ in core design and consider ‘With NWL’ as an alternative scenario. A smaller junction without NWL would reduce land-take, biodiversity loss and GHGs. HE acknowledges lower environmental impact of on-line dualling but has opted for off-line dualling to reduce driver inconvenience during construction, at greater cost to the local environment. HE has not tested lower cost measures for addressing road safety and encouraging modal shift."
Members of the Public/Businesses
Ringland Parish Council
"The A47 project involves the removal of the existing roundabout at Easton and as a consequence effectively closes one of the three current routes for light traffic to cross the Wensum valley. Traffic flow across the valley is already highly congested and is a major problem for local residents and businesses. This situation will only be resolved if the proposed Norwich Western Link Road is built, but this is a separate project administered by Norfolk County Council rather than Highways England. If the NWL is not built or is significantly delayed as seems highly likely then the impact on the local and wider community and business will be disastrous. Both projects should be reviewed as one entity and neither should proceed without the other being approved at the same time."
Members of the Public/Businesses
Adrian Holmes
"I object to the proposed scheme for these reasons: The case for the scheme (at 3.5.1) says that it will increase capacity which means that it will increase traffic growth in Norwich area. This does not comply with national policies for climate change and modal shift towards walking, cycling and public transport. The traffic and economic modelling uses data, assumptions and projections from before the Covid 19 pandemic. Recent and future levels of home-working, the shift towards Internet-based meetings, and strong reductions of traffic on the roads due to COVID impacts need to be assessed against the supposed need for “increased capacity”. The application and traffic modelling assume that the Norwich Western link is already built. To comply with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017, the environmental statement should start from the current situation now as the environmental baseline. The A47 dualling links with the Norwich Western link. The application does not fully explore the relationships between the two road proposal, and needs to be fully examined at the examination. The traffic modelling is based on the NATS 2015 (baseline year 2015) model. Recent modelling by Norfolk County Council based on the newer NATS 2019 (baseline year 2019) model reports substantially lower (c. -30%) vehicle kilometres within the scheme area. The discrepancies need to be examined, and the models fully reconciled. The scheme involves fragmentation, loss or displacement of diminishing wildlife habitats such as wet grazing meadows and protected species, notably bats and the urbanisation of mature countryside. In-combination, and cumulative impacts, for biodiversity, ecology, air quality and carbon emissions have not been assessed with at least six other road infrastructure schemes near to Norwich and East Norfolk. Carbon emissions need to be cumulatively assessed both locally within this area, and nationally with up to 100 other schemes planned. The recent judgement of Pearce v Secretary of State BEIS [2021] demonstrates that the Courts accept the importance of cumulative environmental impact assessment. Carbon emissions should be tested against inter/national legislation and guidance including the Paris agreement, the legally binding target under the Climate Change Act 2008 to meet net-zero carbon emissions by 2050, the UK Sixth Carbon Budget (6CB), science-based carbon budgets from the Tyndall Centre, NPPF 148 which requires the planning system contribute to “radical reductions of greenhouse gas emissions”. Norfolk County Council has identified that the area north of the scheme has a nationally significant breeding barbastelle colony of bats, recently found, which although not yet afforded SSSI or SAC status would otherwise qualify as such (see: page 85 in NCC submission to PINS on the A47/A11 Thickthorn Junction, June 3rd, at [redacted]). The in-combination, and cumulative impacts, of the A47 dualling with the Norwich Western link road on this European protected species should be assessed under Part 3, Section 40 of the Natural Environment and Rural Communities Act 2006."
Members of the Public/Businesses
Broadland District Council
"This letter sets out Broadland District Council’s Relevant Representation in respect of the application made by Highways England for a Development Consent Order for alterations to a section of the A47 between North Tuddenham and Easton (the Scheme). The adopted Joint Core Strategy for Broadland, Norwich and South Norfolk seeks to enhance the transport system in order to develop the role of Norwich as a Regional Transport Node. This is to be achieved by, amongst other things, promoting improvements to the A47. This strategic aim is echoed in the emerging Greater Norwich Local Plan (GNLP), which supports strategic infrastructure improvements that support the growth needs of the area. The emerging GNLP specifically refers to improvements to the A47 between North Tuddenham and Easton as one of the schemes that will help the plan achieve its aims. The Regulation 19 Publication of the GNLP was undertaken between 1 February 2021 and 22 March 2021 and is anticipated to be examined between November and December 2021 and adopted in September 2022. As such, the North Tuddenham to Easton dualling scheme is given in principle support by the existing and emerging development plan. The potential for the scheme to deliver economic growth is strongly supported by the District Council. These benefits, in combination with the wider programme of A47 improvements being proposed by Highways England, include: • help to boost the economic prosperity of a large part of the East of England and contribute to national economic growth. • Shorter and more reliable journey times along the road and onwards to the Midlands. • Reduce delay, congestion and inefficiency. • Attracting more customers for businesses and attracting new businesses. • supporting existing businesses to grow and become more productive and profitable. • allowing businesses to invest with confidence. • encouraging more visitors to the region. • creating more jobs. However, whilst the District Council is supportive of the scheme in principle, there is the potential for impacts that will require detailed consideration through the examination process ahead of any final decision on the Development Consent Order. Matters of particular interest to the District Council through the examination stage are considered to be: • Access to the Food Enterprise Park • Landscape and visual impact • Impacts arising from noise, air quality and vibration. • Impacts on designated heritage assets Access to Food Enterprise Park The Food Enterprise Park (FEP) (referred to as the Food Enterprise Zone (FEZ) in the application documents) is a 100 acre development site, the first 46 acres of which benefits from a Local Development Order to encourage and support food production, processing and agriculture through the co-location of commercial enterprises. The FEP is considered to be a strategically important employment site which has the potential to support significant economic growth in Greater Norwich and Norfolk more generally. Earlier iterations of the Scheme proposed by Highways England included provision of a spur off the southern most roundabout at the proposed Norwich Road junction. This spur would have allowed direct access to be provided from the FEP onto the strategic road network. In previous responses to the scheme the Council has made clear that direct access to the strategic road network is an integral element of delivering the FEP vision in its entirety and would be extremely supportive of this. Direct access into the FEP as previously proposed would avoid the need for vehicles associated with the FEP (including heavy goods vehicles) to use local roads and would make the FEP a more attractive prospect for future occupants thereby accelerating the delivery of the site and its associated economic benefits. If an access to the FEP is not provided at this point there is likely to be an unacceptable increase in heavy goods movements through the village of Easton. The scheme, as submitted, does not facilitate direct access from the strategic road network into the FEP and Highways England have adopted the position that they are not responsible for its provision, nor is its provision necessary to deliver the FEP. The Council would continue to request that the Scheme includes this important access. Landscape and Visual Impact The key landscape issues are considered to be: • Impacts of scheme on existing vegetation; hedgerows and trees • Effect of the engineering and landform on the landscape character, in particular the relatively gentle landform. • Whether there are significant adverse visual effects for sensitive receptors, e.g. users of PROWs, that cannot be sufficiently mitigated • Appropriateness of proposed Environmental Masterplan Hedgerows and Arboricultural implications: The Council welcome that the submission has identified where ‘important’ (and other) hedgerows will be lost as a result of the scheme. Where it is necessary to remove sections of ‘important’ hedgerows for construction working margins – and the ‘importance’ was due to an historical line, it would be preferable to have the line re-instated after construction by replanting (if the original form of the land is unchanged). There is inevitable tree loss as a result of this scheme which is impossible to avoid in such a landscape. The Council are pleased to see that whilst some category ‘A’ trees are scheduled for removal, no Veteran trees appear to be implicated. The Council are concerned about potential construction compounds being within root protection areas of retained trees (including category As); would like to see this avoided if at all possible. Landscape Character: Significant adverse effect on landscape character is anticipated within the Broadland section of the scheme, but the mitigation is expected to reduce this within 15 years to not be significant. Visual Effects: Significant adverse visual effects are anticipated within the Broadland section of the scheme, but the mitigation is expected to reduce these within 15 years to not be significant. Environmental Masterplan: The sensitive design and integration of hard landscape features, such as barriers requires careful consideration. Notwithstanding the highway maintenance requirements, it would be preferable for fencing in more visible locations to be set with planting that will soften the built elements. Impacts arising from Noise, Air Quality and Vibration Whilst the project is in a predominantly rural area, the scheme has the potential to impact on the amenity of local residents during the construction and operational phases as a result of noise, emissions and vibration. Although the Council raises no specific issues on these matters at this stage, we may wish to make representations on these issues through the examination process and ensure that these issues are adequately addressed in the Development Consent Order. Impact on Heritage Assets The Council notes that the Scheme would have a large adverse impact on St Andrew’s Church, a Grade II* listed building, identified by the applicant as having a high level of heritage value. The Council does not disagree with this assessment. However, the Council notes that the existing pedestrian access into the church yard is currently from a footpath through a lychgate. The proposed landscaping (Environmental Masterplan Sheet 11 of 14 TR010038/APP/6.8) does not appear to be designed for retaining pedestrian access through lychgate. The Council consider this an important issue when considering consequential changes around the church as a result of the roads construction and further design consideration in relation to access to the church is therefore required. In the Cultural and Heritage section of the ES, the applicants have not included a C19 lodge to Honingham Hall (to the east of St Andrew’s Church) which the Council considers to have sufficient heritage and architectural interest to be a non-designated heritage asset (due to its historic connection to the hall and typical example of a C19 lodge). However, the Council considers that the diversion of the road will be beneficial to the setting of this building so is not a cause of concern. The Council supports the protection of milestones during the construction of the Scheme as is proposed by the applicant. The decision maker should, as required by Section 66 (1) of the Planning (Listed Buildings & Conservation Areas) Act 1990, have special regard to the desirability of preserving the setting of the building or any features of special architectural or historic interest which it possesses. Conclusion The Council is strongly supportive of the scheme in principle subject to further consideration of the issues identified above. The Council wishes to continue to work pro-actively with the applicants as the application is progressed through to Examination to try to resolve any issues in respect of the above."
Members of the Public/Businesses
Glebe House
"I believe a review of the road development needs to take place given the change in road use as a result of the Covid 19 pandemic. The development is based on our of date information. My strong view is that the expansion of road building will increase traffic at a time when the climate crisis means the County should be investing in public transport, cycle lanes and improved rail networks for freight. Increased emissions will effect the air quality of the region and have an adverse effect on the air that local residents breathe, destroying the rural landscape and what makes Norfolk such such a wonderful place to live. Roads can be conduits for pollutants into the wider environment. Our rural cultural heritage and our landscape will be adversely and irreversibly affected by further road expansion. There also needs to be a robust impact assessment of the impact on biodiversity and wildlife at a time when wildlife is in crisis globally as precious habitats are irredeemably lost. My particular concern is that the very nature of our county and what makes it stand out head and shoulders above the rest will be irredeemably effected by unnecessary road building, and is out of step with the critical need to address climate change."
Members of the Public/Businesses
Hannah Hoechner
"I object to the proposed scheme for the following reasons: A. The case for the scheme (at 3.5.1) says that it will increase capacity which means that it will increase traffic growth in Norwich area. This does not comply with national policies for climate change and modal shift towards walking, cycling and public transport. B. The traffic and economic modelling uses data, assumptions and projections from before the Covid 19 pandemic. Recent and future levels of home-working, the shift towards Internet-based meetings, and strong reductions of traffic on the roads due to COVID impacts need to be assessed against the supposed need for “increased capacity”. C. The application and traffic modelling assume that the Norwich Western link is already built. To comply with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017, the environmental statement should start from the current situation now as the environmental baseline. D. The A47 dualling links with the Norwich Western link. The application does not fully explore the relationships between the two road proposals, and needs to be fully examined at the examination. E. The traffic modelling is based on the NATS 2015 (baseline year 2015) model. Recent modelling by Norfolk County Council based on the newer NATS 2019 (baseline year 2019) model reports substantially lower (c. -30%) vehicle kilometres within the scheme area. The discrepancies need to be examined, and the models fully reconciled. F. The scheme involves fragmentation, loss or displacement of diminishing wildlife habitats such as wet grazing meadows and protected species, notably bats and the urbanisation of mature countryside. G. In-combination, and cumulative impacts, for biodiversity, ecology, air quality and carbon emissions have not been assessed with at least six other road infrastructure schemes near to Norwich and East Norfolk. Carbon emissions need to be cumulatively assessed both locally within this area, and nationally with up to 100 other schemes planned. The recent judgement of Pearce v Secretary of State BEIS [2021] demonstrates that the Courts accept the importance of cumulative environmental impact assessment. H. Carbon emissions should be tested against inter/national legislation and guidance including the Paris agreement, the legally binding target under the Climate Change Act 2008 to meet net-zero carbon emissions by 2050, the UK Sixth Carbon Budget (6CB), science-based carbon budgets from the Tyndall Centre, NPPF 148 which requires the planning system contribute to “radical reductions of greenhouse gas emissions”. I. Norfolk County Council has identified that the area north of the scheme has a nationally significant breeding barbastelle colony of bats, recently found, which although not yet afforded SSSI or SAC status would otherwise qualify as such (see: page 85 in NCC submission to PINS on the A47/A11 Thickthorn Junction, June 3rd, at http://bit.ly/NCC_PlanDeleg_June2021). The in-combination, and cumulative impacts, of the A47 dualling with the Norwich Western link road on this European protected species should be assessed under Part 3, Section 40 of the Natural Environment and Rural Communities Act 2006."
Members of the Public/Businesses
Hanne Lene Schierff
"I object to the proposed scheme for these reasons: The case for the scheme (at 3.5.1) says that it will increase capacity which means that it will increase traffic growth in Norwich area. This does not comply with national policies for climate change and modal shift towards walking, cycling and public transport. The traffic and economic modelling uses data, assumptions and projections from before the Covid 19 pandemic. Recent and future levels of home-working, the shift towards Internet-based meetings, and strong reductions of traffic on the roads due to COVID impacts need to be assessed against the supposed need for “increased capacity”. The application and traffic modelling assume that the Norwich Western link is already built. To comply with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017, the environmental statement should start from the current situation now as the environmental baseline. The A47 dualling links with the Norwich Western link. The application does not fully explore the relationships between the two road proposal, and needs to be fully examined at the examination. The traffic modelling is based on the NATS 2015 (baseline year 2015) model. Recent modelling by Norfolk County Council based on the newer NATS 2019 (baseline year 2019) model reports substantially lower (c. -30%) vehicle kilometres within the scheme area. The discrepancies need to be examined, and the models fully reconciled. The scheme involves fragmentation, loss or displacement of diminishing wildlife habitats such as wet grazing meadows and protected species, notably bats and the urbanisation of mature countryside. In-combination, and cumulative impacts, for biodiversity, ecology, air quality and carbon emissions have not been assessed with at least six other road infrastructure schemes near to Norwich and East Norfolk. Carbon emissions need to be cumulatively assessed both locally within this area, and nationally with up to 100 other schemes planned. The recent judgement of Pearce v Secretary of State BEIS [2021] demonstrates that the Courts accept the importance of cumulative environmental impact assessment. Carbon emissions should be tested against inter/national legislation and guidance including the Paris agreement, the legally binding target under the Climate Change Act 2008 to meet net-zero carbon emissions by 2050, the UK Sixth Carbon Budget (6CB), science-based carbon budgets from the Tyndall Centre, NPPF 148 which requires the planning system contribute to “radical reductions of greenhouse gas emissions”. Norfolk County Council has identified that the area north of the scheme has a nationally significant breeding barbastelle colony of bats, recently found, which although not yet afforded SSSI or SAC status would otherwise qualify as such (see: page 85 in NCC submission to PINS on the A47/A11 Thickthorn Junction, June 3rd, at [redacted]). The in-combination, and cumulative impacts, of the A47 dualling with the Norwich Western link road on this European protected species should be assessed under Part 3, Section 40 of the Natural Environment and Rural Communities Act 2006."
Members of the Public/Businesses
Historic England
"Historic England (retaining the formal title of the Historic Buildings and Monuments Commission for England) is the government service championing England’s heritage and giving expert, constructive advice. We summarise our representation regarding this proposed project as follows: 1. The development would include alteration of a section of the A47 in Norfolk including 9km of new carriageway with four new bridges, two new junctions with local roads, the removal of an existing roundabout, a new access road and lay-bys and associated changes to existing roads along the route. 2. The applicant has carried out an assessment of the historic environment within a defined study area. Assets within this area which could be affected by the proposed development include three grade I, three grade II* and 19 grade II listed buildings along with 244 undesignated heritage assets. We will comment on the assessment of and impact on the grade I and II* listed buildings where there is potential for impact on their setting. We will defer advice on grade II listed buildings and undesignated heritage assets to the local planning authorities. 3. The development has the potential to harm archaeological deposits of interest, both directly and indirectly. A mitigation strategy has been presented by the applicant, which includes a programme of archaeological works that will inform preservation strategies, either preserving remains in situ or by record. We will not comment on this strategy and associated documents and are content for Norfolk County Council’s Historic Environment Service to comment on this."
Members of the Public/Businesses
Honingham Parish Council
"The Parish of Honingham sits directly on the route of the proposed dualled A47. The Council has had significant involvement during the initial stages, consulting regularly with Highways England about the design and details of the dualled A47. The Council has fed back on many issues regarding the evolving designs but continues to have significant concerns about the final design and the impact it will have on the parish of Honingham and its residents. Many key aspects of the design of the A47 hinge on the construction of the Norwich Western Link. This road, proposed by Norfolk County Council, has currently neither the funding nor the approval to build it, yet the implications of the two roads combined will create a traffic nightmare for those living in the area. The Council continue to be extremely concerned about the impact of additional traffic through the village of Honingham which will be seeking to gain access to roads to the South, such as the A11, from the Wood Lane roundabout to the west of the village. After consultation with local parish councils Highways England have agreed to close Berrys Lane, cutting off the obvious route to travel South. However, it has not provided enough detail on how they will prevent traffic from cutting through Dereham Road and the village centre. The proposed Norwich Road roundabout to the east of Honingham village has been placed in an unsuitable location, connecting to a narrow single track country lane on one side (Taverham Road) and another narrow lane which is due to be closed under a Local Development Order on the other (Blind Lane). There seems no justifiable reason for this junctions location or the impact the noise, lighting, construction and increase in traffic will have on this rural area. The issue of increased traffic on Taverham Road both during and after the completion of the A47 remains an area of deep concern for the Parish Council. Highways England have continued to reiterate that this problem is not one they are responsible for solving, passing responsibility to Norfolk County Council, yet it is a problem of their creation. The current proposal by Highways England is for a Temporary Traffic Order which proposes the closure of Honingham Lane just north of what is locally known as the Merryhill crossroads. The outcome of this will be to redirect all the local (and new) traffic across the Ringland Hills via Taverham Road. Traffic modelling by Norfolk County Council has indicated that traffic flow on this road will vastly increase during this time but there has yet to be any significant or conclusive decisions as to how to mitigate this, and the impact it will have on those living on that road. There are significant details for this application which remain unresolved and the Council seek to ensure they continue to contribute to this application."
Members of the Public/Businesses
Jonathan Maynard
"I strongly object to the proposed A47 Tuddenham to Easton scheme. This is contrary to a move towards greener transport and we should be looking at ways to reduce our car usage."
Members of the Public/Businesses
Laura Blake
"I have concerns over the impact of this project if it goes ahead. I do not believe that it would comply with the Government's legal committments to Carbon Net Zero by 2050. The traffic modelling is assuming that the Norwich Western Link is already in place which is unacceptable. I have concerns that it seems when it suits the scheme the traffic and other roads are considered, yet when it comes to the cumulative negative impacts or considerations that should be taken into account they are not considered. It also doesn't seem to be compliant with taking NMU into account. Nor have the changes pre and post COVID been taken into account and considering the changes that have and are occuring this is something that really should be considered. I have serious concerns about the negative impact to the environment and wildlife, how the scheme would fragment the habitats, and also the impact to creatures like the nationally significant breeding barbastelle colony of bats. This would be a hugely destructive scheme and I don't believe that adequate consideration has been given to those impacts and they need to be addressed and taken seriously."
Members of the Public/Businesses
Mattishall Parish Council
"The following represent the concerns of Mattishall Parish Council. A concern that the spill over of traffic issues resulting from the proposed junctions on the new A47 dual carriageway. In particular the Wood Lane junction. We understand the limitations of the HE remit on the ancillary roads network resulting from that work, but stress that the impact locally of it can not be allowed to fall into a void between HE and Norfolk County Council. It is therefore essential that those two organisations work together with us to mitigate and resolve emerging issues. In this context, there is a concern from several other Parishes as well as ours regarding the proposed Wood Lane complex. Where HE's remit ends on Berry’s Lane, the road is currently unsuitable for any volume of traffic likely to arise from the new Wood Lane Junction complex. It will require significant investment and improvements from NCC to deal with it, and even more should the final link of the NW Link completes at that same new A47 Wood Lane junction. The whole North South route will then be opened up on both the Northern side and the Southern side of the A47 bringing substantial increases in traffic for adjacent villages on either side and as far south as the A11. Other minor local North/South roads such as Church Lane, Fox Lane/Mattishall Lane, and Stone Road west of Mattishall are even less suitable for any increase in traffic being already heavily used as links from the Mattishall Road and Dereham Road which runs East West in parallel with, and to the south of the A47. Easy local access North South, to and past, the new A47 is vital for local services such as farmers, schools, doctors surgeries and emergency services. The Mattishall surgery has a large catchment area on both sides of the A47 with significant numbers of patient journeys. Finally, there are some issues that may arise from Norfolk County’s decision on how much of the old existing road is retained for local use such as farm transport, bus services, cyclists etc given that several existing access points to the A47 will be severed."
Members of the Public/Businesses
David Hooker on behalf of Mrs Anne Gowing
"My family's house and land are on the route of the proposed dualled A47. We have had numerous meetings with Highways England to discuss their proposals and suggestions. We have made every effort to keep up to date with Highways England's plans though 1) they have have been poorly communicated 2) they have frequently changed 3) they often ignore the points raised by others and ourselves 4) they take no account of the substantial acreages involved 5) they appear to reverse earlier points agreed Of particular concern are 1) the proposed closure of the existing A47 between Easton and Honingham 2) the lack of an overpass or underpass for the new A47 where it crosses the old A47 3) the safety implications for Taverham Road and its use as a rat run 4) the need for and location of the proposed Norwich Road roundabout 5) the effects of additional noise, drainage and lighting on the Tud river valley"
Members of the Public/Businesses
Norfolk Barbastelle Study Group
"We are concerned that the Ecological Assessment of the proposed scheme does not adequately consider the short and long-term impacts on the nationally important colony of Western Barbastelle Barbastella barbastellus, a rare Annex II bat species which is located in the Lenwade/Ringland Hills/Weston Longville area. The cumulative impacts of this scheme and the Norwich Western Link are not addressed, despite the fact that both schemes fall within the Core Sustenance Zone of the barbastelle colony. On-going comprehensive research on this colony by Wildwings Ecology, in collaboration with the University of East Anglia and the Norfolk Barbastelle Study Group, has shown that barbastelles from the colony cross the A47. To our knowledge, there has been no attempt to consider this information in the impact assessment. The dualled road corridor road will considerably increase the risk of road kills and habitat severance which, together with the adverse impacts from the Norwich Western Link, will have a major adverse impact on the long-term viability of the colony. There is no existing evidence to give confidence that green bridges, gantries or underpasses will successfully mitigate for these impacts. Although not designated, the barbastelle colony exceeds the criteria for Special Area of Conservation (SAC) designation. The national importance of the colony should not be ignored in the impact assessment."
Members of the Public/Businesses
North Tuddenham Parish Council
"Generally, the route met with approval of North Tuddenham PC as it will meet the key objectives of providing a safer and faster route into Norwich and beyond. The complex road interchanges at Wood Lane and Blind Lane (Norwich Road) did raise a few eyebrows. Concern was expressed about increased traffic along narrow minor roads especially Taverham Road to Ringland and Berry’s Lane towards Barnham Broom. We are not convinced that the impacts of the proposed FEP in Colton or the future housing development plans west of Norwich have been considered deeply enough. Locally, we wanted assurances about maintaining a road into Hockering whilst slowly down and limiting the traffic coming from Lyng - mainly HGVs from the Industrial Zone and the A1067. This has been accepted with T-Junction to Lyng and use of existing road to Hockering village. The possibility of encouraging a local bus service to Norwich from Dereham via North Tuddenham and Hockering has been suggested but nothing has developed to date. The issues of HGVs continuing to use Stone Road to access the A47 at North Tuddenham despite the proposed NWL road or more worryingly if the NWL does not happen, must be addressed. With both Low Road East and Mattishall Lane in Hockering due to be closed off, concern was expressed as to how Hockering villagers would access the surgery in Mattishall and potential traffic congestion, if diverted around Fox Lane. Fortunately, Mattishall Lane will remain open as an underpass, so this is positive news for North Tuddenham. 4 other main points were raised in discussions with both HE and Norfolk County Council about the route and the effect on minor roads. At the time of writing no answers have been given. 1. Blind exit from Fox Lane overpass towards old Main Road especially turning right to Lyng or Hockering. Several ‘near misses’ have been reported as traffic coming from these directions is far too fast. 2. Exits from existing A47 are very sharp and roads signs are continually being knocked over as cars negotiate the very demanding curvatures. 3. Residents have also expressed concern about the proximity of the River Tud south of Hockering to the new dual carriageway. 4. Will there be any noise reduction on the new stretch of dual carriageway between North Tuddenham and Hockering? Thank you."
Members of the Public/Businesses
Norwich & Norfolk Friends of the Earth
"I am extremely concerned about the environmental impact of building new roads in general and the A47 North Tuddenham-Easton in particular This is because the dualling of this road is very much part of plans to build the Norwich Western Link, yet is not adequately addressed in the Application This area, The Wensum Valley, has two chalk rivers, the Wensum and the Tud, which are extremely rare and will be affected by construction and run off, etc of dualling the A47. The area is wildlife-rich, inc rare barbastelle bat colonies which habitats will be destroyed Carbon emissions are inadequately and confusingly calculated and expressed Traffic movement data is out of date"
Members of the Public/Businesses
Patricia Day
"I am very concerned by the impact on local wildlife and their unique and specific habitats as yet another new structure encroaches on mature countryside. The increase of capacity anticipated by the proposal contradicts local and national policies for climate change and modal shift towards walking, cycling and public transport. The change in work and travel patterns post covid has not been considered and therefore the need for increased road capacity is not current. The Norwich Western link has not been built. How can we make decisions about the environmental impact using this non-existent construction as a starting point?"
Members of the Public/Businesses
Richard Hawker
"Please can the following topics be explored in the examination. 1) Procedural - initial consultation was late and poor. Early offer to co-operate was declined. Only four options for the route. Difficulty of finding out information from Highways England. Not told of SoCC. Very little notice was given of statutory consultation. No time to publicise and obtain local opinion. Plans are difficulty to see on screen, and almost no chance of getting full-sized paper copies, especially during lockdown, yet project timetable hardly extended. Arrangement of hundreds of DCO documents difficult to understand. No time to read and digest properly before registration. 2) Cumulative effects. 4 large road schemes, very close together (an even more just a little further away), launched over almost the same period, prevents adequate consideration and scrutiny, particularly over cumulative effects. 3) Accuracy of information given. Preferred route announcement was headlined as Option 2, yet the actual route decided-upon was nearer the River Tud than the actual Option 2. This is misleading. 4) Need for the scheme. This has not been fully addressed in the DCO, especially bearing in mind government policy on modal shift and the need for carbon emissions. 5) Alternatives, both in routes and lower-cost road schemes, some offered by the public were not adequately assessed. 6) Access and PROW. Several are to be severed or massively diverted. Certain roads providing local contact are to be severed. Cycling routes very badly compromised 7) Landscape. Local tranquil areas devastated. Tud Valley landscape altered massively. 8) Environment. Huge threat to River Tud from run-off, and disturbance of habitat and earth during construction. 9) Public transport. So many roundabouts puts buses on potential routes through villages at a serious disadvantage compared with private car. 10) Impact on local road system not properly addressed; temporary traffic orders should not be relied upon to alleviate what could be a permanent problem. Nor can other, separate planned road schemes, whether or not considered ’near certain’ be relied upon to alleviate problem caused by the design of this road. 11) Lighting. Very little information. A serious issue for people in country areas who value the night sky. 12) Noise. Very little information, especially regarding impact on Hockering village residents, to show HOW their noise type may be affected (even if absolute values may be lower )– we are not told. 13) Costs. These have risen considerably since the start of the project. Some attempt should be made to assess realistically what a maximum final cost could be."
Members of the Public/Businesses
Robert Palgrave
"I object to the proposed scheme for these reasons: A. The case for the scheme (at 3.5.1) says that it will increase capacity which means that it will increase traffic growth in Norwich area. This does not comply with national policies for climate change and modal shift towards walking, cycling and public transport. B. The traffic and economic modelling uses data, assumptions and projections from before the Covid 19 pandemic. Recent and future levels of home-working, the shift towards Internet-based meetings, and strong reductions of traffic on the roads due to COVID impacts need to be assessed against the supposed need for “increased capacity”. C. The application and traffic modelling assume that the Norwich Western link is already built. To comply with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017, the environmental statement should start from the current situation now as the environmental baseline. D. The A47 dualling links with the Norwich Western link. The application does not fully explore the relationships between the two road proposals, and needs to be fully examined at the examination. E. The traffic modelling is based on the NATS 2015 (baseline year 2015) model. Recent modelling by Norfolk County Council based on the newer NATS 2019 (baseline year 2019) model reports substantially lower (c. -30%) vehicle kilometres within the scheme area. The discrepancies need to be examined, and the models fully reconciled. F. The scheme involves fragmentation, loss or displacement of diminishing wildlife habitats such as wet grazing meadows and protected species, notably bats and the urbanisation of mature countryside. G. In-combination, and cumulative impacts, for biodiversity, ecology, air quality and carbon emissions have not been assessed with at least six other road infrastructure schemes near to Norwich and East Norfolk. Carbon emissions need to be cumulatively assessed both locally within this area, and nationally with up to 100 other schemes planned. The recent judgement of Pearce v Secretary of State BEIS [2021] demonstrates that the Courts accept the importance of cumulative environmental impact assessment. H. Carbon emissions should be tested against inter/national legislation and guidance including the Paris agreement, the legally binding target under the Climate Change Act 2008 to meet net-zero carbon emissions by 2050, the UK Sixth Carbon Budget (6CB), science-based carbon budgets from the Tyndall Centre, NPPF 148 which requires the planning system contribute to “radical reductions of greenhouse gas emissions”. I. Norfolk County Council has identified that the area north of the scheme has a nationally significant breeding barbastelle colony of bats, recently found, which although not yet afforded SSSI or SAC status would otherwise qualify as such (see: page 85 in NCC submission to PINS on the A47/A11 Thickthorn Junction, June 3rd, at [redacted]). The in-combination, and cumulative impacts, of the A47 dualling with the Norwich Western link road on this European protected species should be assessed under Part 3, Section 40 of the Natural Environment and Rural Communities Act 2006."
Members of the Public/Businesses
South Norfolk Council
"This letter sets out South Norfolk Council’s Relevant Representation in respect of the application made by Highways England for a Development Consent Order for alterations to a section of the A47 between North Tuddenham and Easton (the Scheme). The adopted Joint Core Strategy for Broadland, Norwich and South Norfolk seeks to enhance the transport system in order to develop the role of Norwich as a Regional Transport Node. This is to be achieved by, amongst other things, promoting improvements to the A47. This strategic aim is echoed in the emerging Greater Norwich Local Plan (GNLP), which supports strategic infrastructure improvements that support the growth needs of the area. The emerging GNLP specifically refers to improvements to the A47 between North Tuddenham and Easton as one of the schemes that will help the plan achieve its aims. The Regulation 19 Publication of the GNLP was undertaken between 1 February 2021 and 22 March 2021 and is anticipated to be examined between November and December 2021 and adopted in September 2022. As such, the North Tuddenham to Easton dualling scheme is given in principle support by the existing and emerging development plan. The potential for the scheme to deliver economic growth is strongly supported by the District Council. These benefits, in combination with the wider programme of A47 improvements being proposed by Highways England, include: • help to boost the economic prosperity of a large part of the East of England and contribute to national economic growth. • Shorter and more reliable journey times along the road and onwards to the Midlands. • Reduce delay, congestion and inefficiency. • Attracting more customers for businesses and attracting new businesses. • supporting existing businesses to grow and become more productive and profitable. • allowing businesses to invest with confidence. • encouraging more visitors to the region. • creating more jobs. However, whilst the District Council is supportive of the scheme in principle, there is the potential for impacts that will require detailed consideration through the examination process ahead of any final decision on the Development Consent Order. Matters of particular interest to the District Council through the examination stage are considered to be: • Access to the Food Enterprise Park • Landscape and visual impact • Impacts arising from noise, air quality and vibration. • Impacts on designated heritage assets Access to Food Enterprise Park The Food Enterprise Park (FEP) (referred to as the Food Enterprise Zone (FEZ) in the application documents) is a 100 acre development site, the first 46 acres of which benefits from a Local Development Order to encourage and support food production, processing and agriculture through the co-location of commercial enterprises. The FEP is considered to be a strategically important employment site which has the potential to support significant economic growth in Greater Norwich and Norfolk more generally. Earlier iterations of the Scheme proposed by Highways England included provision of a spur off the southern most roundabout at the proposed Norwich Road junction. This spur would have allowed direct access to be provided from the FEP onto the strategic road network. In previous responses to the scheme the Council has made clear that direct access to the strategic road network is an integral element of delivering the FEP vision in its entirety and would be extremely supportive of this. Direct access into the FEP as previously proposed would avoid the need for vehicles associated with the FEP (including heavy goods vehicles) to use local roads and would make the FEP a more attractive prospect for future occupants thereby accelerating the delivery of the site and its associated economic benefits. If an access to the FEP is not provided at this point there is likely to be an unacceptable increase in heavy goods movements through the village of Easton. The scheme, as submitted, does not facilitate direct access from the strategic road network into the FEP and Highways England have adopted the position that they are not responsible for its provision, nor is its provision necessary to deliver the FEP. The Council would continue to request that the Scheme includes this important access. Landscape and Visual Impact The key landscape issues are considered to be: • Impacts of scheme on existing vegetation; hedgerows and trees • Effect of the engineering and landform on the landscape character, in particular the relatively gentle landform. • Whether there are significant adverse visual effects for sensitive receptors, e.g. users of PROWs, that cannot be sufficiently mitigated • Appropriateness of proposed Environmental Masterplan Hedgerows and Arboricultural implications: The Council welcome that the submission has identified where ‘important’ (and other) hedgerows will be lost as a result of the scheme. Policy DM4.8 of the South Norfolk Development Management Polices Document presumes in favour of ‘important’ hedgerows except in cases where there is an overriding justification; in this instance it is agreed that the proposed improvements to the A47 constitute an overriding justification. Where it is necessary to remove sections of ‘important’ hedgerows for construction working margins – and the ‘importance’ was due to an historical line, it would be preferable to have the line re-instated after construction by replanting (if the original form of the land is unchanged). There is inevitable tree loss as a result of this scheme which is impossible to avoid in such a landscape. Pleased to see that whilst some category A trees are scheduled for removal, no Veteran trees appear to be implicated. Concern about potential construction compounds being within root protection areas of retained trees (including category As); would like to see this avoided if at all possible. Landscape Character There are no significant adverse landscape effects anticipated within the South Norfolk section of the scheme. Visual Effects There are no significant adverse visual effects anticipated within the South Norfolk section of the scheme. Environmental Masterplan The sensitive design and integration of hard landscape features, such as barriers requires careful consideration. Notwithstanding the highway maintenance requirements, it would be preferable for fencing in more visible locations to be set with planting that will soften the built elements. The Council has reservations about the proposed formal approach to planting around the Easton pedestrian/cycle bridge; this is not an urban area as the annotation suggests. Will it be possible to view St Peter’s Church Easton from the pedestrian/cycle crossing and/or its approach(es)? If not, is this desirable/possible? What is the function of the spur of former Church Lane to the north of the proposed Easton pedestrian/cycle bridge? Is this necessary? Impacts arising from Noise, Air Quality and Vibration Whilst the project is in a predominantly rural area, the scheme has the potential to impact on the amenity of local residents during the construction and operational phases as a result of noise, emissions and vibration. Although the Council raises no specific issues on these matters at this stage, we may wish to make representations on these issues through the examination process and ensure that these issues are adequately addressed in the Development Consent Order. Impact on Heritage Assets The Council supports the protection of milestones during the construction of the Scheme as is proposed by the applicant. The decision maker should, as required by Section 66 (1) of the Planning (Listed Buildings & Conservation Areas) Act 1990, have special regard to the desirability of preserving the setting of the building or any features of special architectural or historic interest which it possesses. Conclusion The Council is strongly supportive of the scheme in principle subject to further consideration of the issues identified above. The Council wishes to continue to work pro-actively with the applicants as the application is progressed through to Examination to try to resolve any issues in respect of the above."
Members of the Public/Businesses
Wild Wings Ecology
"The proposed scheme is located within the 6km radius Core Sustenance Zone of a nationally important 'super-colony' of a very rare Annex II bat species, the western barbastelle (Barbastella barbastellus). This super-colony is located in the Ringland/Attlebridge/Weston Longville/Lenwade area and includes a known 77 confirmed barbastelle roosts (to date - located from radio-tracking), one of which is the largest known extant barbastelle roost in the country. The area exceeds criteria for Special Area of Conservation (SAC) designation and as such should be treated in the same manner. We have been carrying out research on this barbastelle super-colony for a number of years, in collaboration with the University of East Anglia and the Norfolk Barbastelle Study Group. This has included radio-tracking of 40 adult female barbastelles. Night-tracking of individuals which travel south to cross the A47 has identified a single, specific crossing point over the A47, within the scheme's boundary/proposed dualling area. Very careful consideration is therefore needed as to how safe crossing of barbastelles over the road at this location will be maintained by the scheme, noting that standard mitigation approaches (green bridges, gantries, underpass) on the Norwich Northern Distributor Road (NDR) have failed. The cumulative impacts on the barbastelle super-colony of the proposed A47 dualling, Norwich Western Link road and the off-shore windfarm cable route are likely to be substantial and will need very careful consideration to avoid damaging the Favourable Conservation Status of this nationally important population. We have not been consulted about this scheme and therefore our research findings on the barbastelle population here have not been considered by the proposal. We do not consider that a full and informed assessment of impacts on the barbastelle population has been made; the road is likely to negatively impact this nationally important population and no suitable, effective mitigation measures have been proposed."
Members of the Public/Businesses
Brown & Co on behalf of Alston Farms Ltd
"Respondant: James Alston Submission is made on behalf of James Alston as shareholder and director of Alston Farms Ltd, parent company of Ebony Holdings Ltd as owner of the property known as [redacted] (Hereafter referred to as the Estate) and partner in Honingham Thorpe Farms. The Estate extends to circa 421 ha (1040 acres) of what is primarily high quality agricultural land used to grow a wide variety of cereals and high value root crops. The farming business is carried on by Honingham Thorpe Farms (HTF) which is a farming partnership owned and operated by the Alston family. The shareholders of Alston Farms Ltd are partners in HTF, thus creating a synergy of interest and representation. HTF farming operations are based at Colton, some 5.7km by road to the south of the Estate. Access is simple being via Blind Lane, crossing the A47 and north up Taverham Road into the heart of Ringland. It is acknowledged that these roads are narrow, as is typical of most rural highways, but they have been suitable for use in the past and should remain so in the future. There is no record of an RTA involving HTF arm machinery using this route. An additional benefit of this route is that it does not pass through any residential areas and Ringland village itself can be circumnavigated used Estate tracks. The greatest weight of traffic is during harvest time, which for the Estate can span across a large period of the year as the different crops grown will come to harvest at different points through the year. The pressure is not just concentrated around the usual cereal harvest period of July and August. Field scale potatoes have an average yield of 48t/ha (varying year or year) and some main crop varieties can push towards 60t/ha. With a 1 in 5 rotation there will be an average area of 80ha of potatoes on the Estate. This gives a potential crop of 3840t to move back to HTF base and stores at Colton. An average trailer will hold 16t of produce, meaning 240 round trips (480 vehicle movements) per year between the Estate and HTF. This is in addition to any other root crops that might be grown on the Estate and the cereal crops. The proposed road layout will push this traffic onto Church lane, where it will interact with the FEP traffic, through to Easton Church junction, back along the spur road to the grade separated junction to pick up Taverham Road. A journey that will be 2.7kn longer, create conflict with traffic on Church Lane, increase large vehicle traffic through Easton, increase pressure at the Easton Church junction, cause added disturbance to the use of Easton Church and clash with the proposed residential development on the southwest side of Easton. It is inefficient, disruptive, and illogical. Consideration should be given to the working hours of a farm and how this will interact with the residential areas. The respondent believes that Blind Lane should remain available as a private means of access to join the southern Honingham spur off the grade separated junction, near where the potential future FEP access might be. The southern access to Blind Lane could be close to public traffic, a link created from the HTF roadway at Red Barn onto Blind Lane to preclude public access and then the Honingham spur could be joined at the most suitable point. There is potential interaction with the FEP and the potential access point and it is considered possible for the two uses to be combined. Nobody could rat run through the FEP and down Blind Lane as they would only end up in HTF yard, they could not join Church Lane. The farm access at the northern end, where it interacts with the FEP, could be separately gated and fob controlled to add further security. Highways England have stated that this is not possible, and that Blind Lane should be closed as it is not fit for purpose. They consider it is agreeable to push all the traffic onto Church Lane, through Easton and past the Church and on to joint the other local traffic at the grade separated junction. The respondent contests this and requests that their proposal is given consideration for the benefit of the respondent and the inhabitants of Easton"
Members of the Public/Businesses
Alyson Lee
"I would like to register as an interested party for the following reasons:- 1. All new roads mean increased traffic and therefore increased air pollution and carbon emissions. We are in a climate emergency – tackling this means reducing the number of cars on the roads as well as converting to EVs. 2. Congestion needs to be solved through investment in active travel and public transport and a general reduction in freight volumes through a national policy of degrowth as opposed to the suicidal policy of perpetual growth in a finite world. 3. We are also in an ecological crisis – this scheme threatens many wildlife habitats such as wet grazing meadows. Many species will be harmed by the scheme. Britain is one of the most nature depleted countries in the world and we need to stop destroying our natural habitats for the sake of growth. 4. The environmental assessments do not look at cumulative effects – this scheme is not an isolated scheme – there are several other road schemes near to Norwich and East Norfolk. The effects on biodiversity, pollution and carbon emissions should be assessed in combination with these other schemes. 5. There are also many other major road schemes within the government’s RIS2 programme - the cumulative effect of this scheme, along with all other road schemes nationally, should be seriously considered in terms of the national carbon budgets – road transport is the only sector where carbon emissions are still increasing – this is probably because the cumulative carbon emissions of individual schemes are ignored. This can’t go on! 6. All road schemes should be re-evaluated in the light of the Covid pandemic – much has changed that will affect future traffic volumes such as home-working – the government should be taking steps to make this a permanent change by investing in improved broadband and local work hubs rather than continuing with outdated policies of ever expanding roads."
Members of the Public/Businesses
Savills UK Ltd on behalf of Anthony Meynell
"INTRODUCTION 1. This relevant representation is made on behalf of Mr Anthony Meynell (‘the Owner’), in respect of the application made by Highways England (‘the Applicant’) for development consent for the dualling of the A47 North Tuddenham to Easton (‘the DCO’). 2. The Owner is the registered freehold owner of land known as [redacted], Honingham, Norfolk (‘the Estate’). The Estate has been in the Owner’s family since 1948. 3. The Estate comprises some 125 acres/50.5 ha of land in use as a small agricultural and forestry estate. It is situated to the west of the village of Honingham and approximately 8 miles west of Norwich. The northern boundary of the greater part of the Estate is the existing A47, to which the Estate benefits from a private right of way (to be stopped up without substitute); at its eastern end the Estate abuts a section of the former A47 known as Dereham Road. 4. The whole of the Estate is designated by the Treasury as being of outstanding scenic or historic or scientific interest, pursuant to s.31(1)(b) of the Inheritance Tax Act 1984 (‘ITA 1984’). The designation confers upon the Estate conditional exemption from certain taxes e.g. inheritance tax and capital gains tax, on death or in the event of certain authorised disposals (eg to a member of the family or to a heritage body such as the National Trust). The purpose of the designation, however, is to ensure the continued management and maintenance of qualifying property in private hands, and continuing public access to the assets, so that they may be secured and conserved for the benefit of the public as part of the nation’s cultural heritage. Consequently, although a private benefit accrues as a result of the existence of the designation, the designation is made for public interest reasons, in the public interest. 5. There are fewer than 350 such designated national heritage properties or estates in the whole of the UK. Other well-known examples include Blenheim Palace, Chatsworth House, Bamburgh Castle, the Holkham and Houghton Estates in Norfolk, and the Syon Park Estate in west London (the last being the only designated asset in London). These examples will give the Examining Authority an indication as to the quality required of qualifying property. As a condition of this statutory designation as a national heritage asset, which was made in 2003, the Estate was at the same time made subject to a bespoke Heritage Management Plan (‘HMP’), which has been funded by the Owner placing cash and assets into an irrevocable settlement (the ‘Maintenance Settlement’) approved by the Treasury and designed to secure the Estate’s improvement and preservation. The Owner’s stewardship of the Estate since its designation, and the management of the Maintenance Settlement, each in fulfilment of and compliance with the HMP, is subject to periodic monitoring by Natural England (‘NE’). As noted above, as well as complying with the HMP, the Owner is required to provide opportunities for public access to the Estate, and disposals are subject to restriction to ensure the continued maintenance of the Estate in its designated condition. 6. The principal residence on the Estate, [redacted], is, additionally, Grade II Listed (List entry No. 1306730). A further structure on the estate, a C18 icehouse, is the subject of another, independent Grade II listing (List entry No. 1077350) (This is a separate listing and not part of a group with Berry Hall, as appears to be suggested in Doc 6.1 Environmental Statement – Chapter 6 Cultural Heritage at [6.7.24].). Other properties within the Estate boundary are used as tenanted dwellings and one for holiday letting, and the income from these supports the maintenance of the Estate. 7. Within the Estate is [redacted], built in the 1950s as the Estate’s second residence. This property is now let to a charity, Childhood First, as a residential children’s home which cares for severely traumatised children. Its freehold ownership (subject to the tenancy to Childood First) has been transferred by the Owner to the Maintenance Settlement. The property now forms the principal asset of that settlement and the income derived from the letting to the charity is devoted to the maintenance of the Estate. It is understood that the Charity Trustees and Childhood First’s Managers are in separate discussions with the Applicant concerning the effect of the proposals on Merrywood House and the children living there. 8. The Estate falls within the Order Limits of the DCO. It principally comprises Plots 9/1a, 9/1b, 9/1c, 9/1d, 9/1f, 9/1g, 9/1h, 9/1i, 9/1j, 9/1l, 9/1m, and 9/2a. Some of these plots are required permanently, whilst others are required only temporarily, or temporarily subject to the later acquisition of permanent rights. 9. The Owner has participated in two prior rounds of consultation: the non-statutory consultation undertaken by the Applicant in April 2020, and statutory consultation undertaken in January 2021. The Applicant’s response to the points raised in the statutory consultation are addressed at pp.27-30 of Annex O to the Consultation Report (‘Annex O’), to which further reference is made below. SUMMARY OF THE OWNER’S CASE 10. Although the Owner is supportive of the principle of the DCO, and the aims it seeks to achieve, he objects to the application in its current form. 11. The application fails to take into account the heritage significance of the Estate, consistent with its designation by the Treasury as described above. There is no acknowledgement in any of the application materials of the status the Estate enjoys, and/or any consideration of the implications of the DCO for that status, and the features that have led to its designation. The effect of this potential loss is not principally complained of because of the impact upon a private beneficial tax arrangement (though that disbenefit does fall to be taken into account), but because the public interest in preserving and maintaining the Estate in its outstanding present form and in the condition envisaged by the HMP, as reflected by the designation, would be compromised. 12. The failure to have regard to this matter is in direct conflict with the requirements of the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017, the National Networks NPS (particularly Section 5) and the NPPF (particularly Section 16), as well as the freestanding requirement to take into account (Figure 2.1 (Doc 6.2 Environmental Statement Figures] identifies the Grade II listed buildings as environmental constraints, but is silent as to the designation of the wider Estate under the ITA 1984) all relevant material considerations. It further represents an environmental constraint not taken into account in the consideration of alternatives (to which we return below), and a matter not assessed in the Applicant’s consideration of the compelling case for temporary and permanent acquisition of the affected land. 13. This failure has arisen notwithstanding the matter having been raised with the Applicant in the previous rounds of consultation referred to above. The Applicant’s response to the issue of designation as set out in Annex O refers only to their having taken into account the separate Grade II listings of Berry Hall itself, and the Icehouse, suggesting a fundamental failure either to understand or grapple with the point raised. 14. The DCO will see the temporary loss within the Estate of 12ha of land (c.27%) and a permanent loss of 3 ha (c.7%) (Both figures taken from Doc 6.1 Environmental Statement – Chapter 12 Population and human health (where the Estate is identified as Holding 10), and have not yet been verified by the Owner.), with the works resulting in the loss of or substantial harm to its arboricultural and landscape interest and historic integrity – features for which it was designated. It seriously risks compromising the ability of the Owner to comply with the HMP. These unacceptable impacts expose the Estate to the loss of its designated status, and consequently conflict with the public interest in securing its preservation and enhancement for the benefit of the nation. 15. The Owner considers that an alternative option could see the route alignment in proximity to the Estate sited on less sensitive land, to the north of the existing A47, which would either avoid or reduce the impact upon the Estate, and consequently the adverse effects of the DCO generally, including as-yet unassessed heritage-related harm. 16. This option would also have the benefit of avoiding or reducing the unacceptable effects on the agricultural holding (identified as number 10 in the ES Chapter Population and Human Health), which even on the Applicant’s assessment are identified as being “large adverse” during the construction phase and “slight adverse” during operation – effects which the Owner considers are likely to underplay the significance of the impact upon the present agricultural tenants and the future viability of the working agricultural unit, which forms a vital part of the Estate and is integral to its character. The Applicant’s assessment will be challenged on that basis. 17. The need to accommodate a junction in the location of the Wood Lane/Berry’s Lane junction, and the impacts it might have, was not a matter that can have informed the selection of ‘Option 2’ as the preferred route alignment, no junction being proposed at the location at the time that the option selection was undertaken. 18. The prospect of the alternative option referred to above has previously been raised with the Applicant who has so far declined to consider it on the basis that it would require an alteration to the red-line boundary, which had been selected prior to the identification of the need for the Wood Lane junction as just described, and would therefore result in programme delay. This is not an acceptable response, and is evidence of an inadequate consultation procedure, with the Owner being denied an opportunity to influence the scheme design at a sufficiently formative stage. 19. The availability of an alternative which would have fewer adverse impacts is particularly significant in the context of the Applicant’s case for compulsory acquisition. In short, no compelling case can be made out where (as here) such a reasonable alternative exists. 20. Other material inadequacies in the Applicant’s claimed compelling case can be identified – most notably the failure to acknowledge, seek to mitigate and otherwise take into account the substantial public and private disbenefits flowing from the impact upon the designated Estate, and also the total absence of any attempt to acquire the land or rights required for the DCO by agreement, even by way of option (as is commonplace on other major linear schemes) or conditional sale. 21. The Owner will consequently contend that, in view of the above matters, no compelling case for acquisition of his land has been made out. 22. In light of and in a manner consistent with the above, the Owner intends to participate in the Examination and make representations in relation to the following topics: a. Cultural heritage; b. Ecology;. c. Population and human health; d. Alternatives;. e. Adequacy of environmental information; f. Adequacy of consultation; and g. The case for compulsory acquisition. 23. The above is based on the best information presently known to the Owner. In the short time available since the commencement of the consultation, it has not been possible for him to obtain all the professional input he may wish to secure. The Owner therefore reserves the right to amend or supplement these representations as appropriate during the course of the Examination. NEXT STEPS 24. In light of the above, the Owner considers that it is necessary for the Applicant to revisit its chosen route alignment. 25. The Owner would wish to be able to withdraw his objection to the DCO. This will however necessitate meaningful engagement by the Applicant so that changes to the scheme can be made that will enable the impacts upon the Estate to be avoided or, at the very least, reduced to an acceptable level, in view of its statutory designation. 26. The Owner and his representatives are willing to meet with the Applicant in order to discuss both the alternative proposals and/or what further mitigation/compensation may be possible. Appropriate fee undertakings will be sought for the professionals involved."
Members of the Public/Businesses
Breckland Council
"Breckland Council, as the host authority for the proposals, has been in discussions with Highways England for some time in relation to the proposed scheme. It welcomes the chance to be an active part of the Examination Process and considers that the following matters are relevant to the scheme and would ask that they are addressed by the Examining Inspector(s). • The impact of the development on the economy of the area including the improvements in connectivity between Dereham and Norwich • The impact of the development on the amenity of local residents • The impact of the development on the character and appearance of the landscape and the area in which it located • The impact of the development on local areas of designated open space with particular reference to Poppys Wood. This is designated as an area of open space within the Breckland Local Plan and therefore Policy ENV01 applies. The impact of the proposals upon this area clearly needs to be considered. The need for any mitigation, and the form of any mitigation, will need to be considered if there is found to be an unacceptable impact on this area off Public Open Space. • The impact of the development on designated heritage assets, including a veteran woodland area. This is with specific reference to a Grade II listed building (Berry Hall) and an area of veteran woodland at Berry’s Lane as being situated in close proximity to the location of the proposed junction. It also relates to the Grade II Listed building (Icehouse - listing 1077350) on Berry’s Lane. The impacts of the proposal upon these will clearly need to be considered carefully. • Drainage and flooding – in particular the impact of the proposal upon the area of surface water flood risk that exists to the south of Hockering. • The improvement of connectivity of existing villages through improvements to walking and cycling routes in the vicinity of the proposed schemes. • The impact of the development upon through traffic, in particular the proposal to stop up Berry’s Lane. The Council would seek to have Berry’s Lane and Wood Lane connected by way of an underpass under the A47 but separate from the proposed A47/Norwich Western Link Road junction. • Ensuring that there is connectivity to the Norwich Western Link Road. • Assessment of the proposal against the policies of the Breckland Local Plan (November 2019)."
Members of the Public/Businesses
Christine Way
"I object to the proposed scheme for these reasons: A. Increasing capacity means an increase in traffic growth in the Norwich area which is contrary to the national policies for climate change and a shift towards walking, cycling and public transport. B. Since the pandemic levels of home-working and internet based meetings has increased resulting in a significant reduction in traffic which may well continue. Therefore the data, assumptions and projections used for traffic and economic modelling are outdated and a reassessment is needed. C. The Environmental Impact Assessment should be made using the current situation as the baseline and not assume that the Norwich Western link is already built. D. The A47 dualling links with the Norwich Western link. The application does not fully explore the relationships between the two road proposals, and needs to be fully examined at the examination. E. There are discrepancies in vehicle kilometres between the NATS 2015 model used and recent modelling by Norfolk County Council based on the newer NATS 2019 model which should be examined and reconciled. F. The scheme involves fragmentation, loss or displacement of diminishing wildlife habitats such as wet grazing meadows and protected species, notably bats and the urbanisation of mature countryside. G. In-combination, and cumulative impacts, for biodiversity, ecology, air quality and carbon emissions have not been assessed with at least six other road infrastructure schemes near to Norwich and East Norfolk. Carbon emissions need to be cumulatively assessed both locally within this area, and nationally with up to 100 other schemes planned. The recent judgement of Pearce v Secretary of State BEIS [2021] demonstrates that the Courts accept the importance of cumulative environmental impact assessment. H. Carbon emissions should be tested against inter/national legislation and guidance including the Paris agreement, the legally binding target under the Climate Change Act 2008 to meet net-zero carbon emissions by 2050, the UK Sixth Carbon Budget (6CB), science-based carbon budgets from the Tyndall Centre, NPPF 148 which requires the planning system contribute to “radical reductions of greenhouse gas emissions”. I. Norfolk County Council has identified that the area north of the scheme has a nationally significant breeding barbastelle colony of bats, recently found, which although not yet afforded SSSI or SAC status would otherwise qualify as such (see: page 85 in NCC submission to PINS on the A47/A11 Thickthorn Junction, June 3rd, at [redacted]). The in-combination, and cumulative impacts, of the A47 dualling with the Norwich Western link road on this European protected species should be assessed under Part 3, Section 40 of the Natural Environment and Rural Communities Act 2006."
Members of the Public/Businesses
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 A47NTE scheme for these reasons: A. In combination with the Norwich Western link (NWL) road, the scheme would increase capacity and traffic growth (APP-140, s3.5.1; AADT data at APP-140, s4.5 & s4.9) contrary to national policies for climate change, air quality and modal shift towards walking, cycling and public transport. B. Data, assumptions and projections in the traffic and economic modelling do not take account of the impact of the Covid 19 pandemic on travel patterns and road capacity need. C. The application, EIA, and traffic modelling *baselines* assume the NWL is already built. D. EIA baseline should express the *current* environmental situation which is NO_NWL and NO_A47NTE. E. Do-Minimum (DM) traffic model should codify the *current* situation (ie: NO_NWL + NO_A47NTE). Sensitivity testing requires *THREE* Do-Something models: (NO_NWL + A47NTE), (NWL + NO_A47NTE), (NWL + A47NTE). F. Major discrepancies are observed between Norfolk County Council (NCC) NATS traffic models run 2015 and 2019 baseline years for the NWL study area. At 2019-baseline, there is substantially lower (c. -30%) vehicle kilometres ([redacted]) over the 2015-baseline ([redacted]). G. The substantive traffic reduction at the 2019 baseline indicates that A47NTE capacity requirement (APP-140, s3.5.1 and based on 2015-baseline) needs greater assessment. H. Notwithstanding C, D, E, F & G above, the relationship between the scheme and a possible NWL is confused (especially at APP-142, s9.2). I. The scheme fragments and displaces nature and wildlife habitats, wet grazing meadows, protected species (notably bats). J. NCC identifies near-by a nationally significant breeding colony of barbastelle bats, which would qualify for SSSI or SAC status [redacted], PDF page 85). The in-combination impacts of A47NTE and NWL on this European protected species have not been assessed. K. In-combination, and cumulative impacts, for biodiversity, ecology, and air quality have not been assessed with at least six other road infrastructure schemes near to Norwich and East Norfolk. (Note Natural England on the EIA Scoping, APP-163, PDF page 163). The recent judgement of Pearce v Secretary of State BEIS [2021] demonstrates that the Courts accept the importance of cumulative environmental impact assessment. L. Carbon emissions need to be cumulatively assessed *both* locally within the Norwich area (in combination effects with the six other possible schemes identified above), and nationally with up to 100 other schemes planned by Government, including under RIS2. M. Carbon emissions should be tested against inter/national legislation and guidance including the Paris agreement, the legally binding target under the Climate Change Act 2008 to meet net-zero carbon emissions by 2050, the UK Sixth Carbon Budget (6CB), science-based carbon budgets from the UK Tyndall Centre, the NPPF 148 planning requirement to “radical reductions of greenhouse gas emissions”, and the NCC Environmental Policy. N. Note, the relevant NPS requires that the scheme be assessed against national carbon reduction targets and the UK's international commitments in place at the time when a DCO application is determined."
Members of the Public/Businesses
David Morton
"Dear Sirs, My representation is that I oppose this scheme, primarily because of the increase in greenhouse gases that would entail not only due to its construction, but the inevitable increase in road traffic. The climate and ecological emergency is upon us. Other considerations are the effect on local wildlife, air quality and the lack of provision for active travel which should be promoted instead. It may also have an impact on the availability of agricultural land that is going to be required in future years. Thank you for your consideration."
Members of the Public/Businesses
Environment Agency
"APPLICATION BY HIGHWAYS ENGLAND FOR AN ORDER GRANTING DEVELOPMENT CONSENT FOR THE A47 NORTH TUDDENHAM TO EASTON PROJECT Please find below our relevant representation for the A47 North Tuddenham to Easton 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 further information is required in respect of assessing and mitigating the potential impacts of shading on the ecology of the River Tud at the proposed crossing. We are broadly satisfied with the assessments and proposals in respect of managing fluvial flood risk, subject to a number of points of clarification and a review of the detailed design. In general we are also satisfied with the 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 We note that the applicant is not seeking to dis-apply environmental permits. We would like to remind the applicant that it will be necessary to apply for and have in place all necessary permits prior to any works commencing. 1.2 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. 1.3 The Environment Agency should be included as a named consultee in respect of Requirement 4, for matters relevant to our remit. 1.4 Given that construction activity will be required to take place in and around areas of fluvial Flood Zone 2 and 3 (medium and high probability), an Emergency Flood Plan should be prepared. It is currently not clear whether such a document will form part of the EMP, and this should be confirmed. 1.5 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. 1.6 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 on-going. It will be important for us to review and confirm that the detailed proposals are acceptable. 1.7 The Environment Agency should therefore be a named consultee in respect of Requirement 8 Surface and foul water drainage system. 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 It should be noted that the Environment Permitting (England and Wales) Regulations from 2007 onwards replaced the permitting system in the Pollution Prevention and Control Act. Guidance on this can be found in the DEFRA Environmental Permitting: Core Guidance document. 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 This chapter details the loss of some habitat types that fall within the footprint of the work, and acknowledges that compensatory habitat can take some time to re-establish (including floodplain grazing marsh and mixed deciduous woodland). We note that compensatory habitat is to be delivered, monitored and managed through the Landscape and Ecology Management Plan (LEMP), as part of 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 this. 3.2 The results of the white-clawed crayfish survey (Appendix 8.5), show that the invasive signal crayfish have become much more numerous in the past 3-4 years, and that numbers of white clawed crayfish have further declined. The remaining population of white clayed crayfish is extremely vulnerable to crayfish plague. It must be ensured that any work in or near the water will be preceded by strict biosecurity measures, in particular a thorough Check-Clean-Dry of machinery equipment and clothing must be undertaken. Such measures must be included in the EMP. 3.3 As laid out in section 5.2.3 of the Otter and water vole survey report (Appendix 8.14), measures must be in place to ensure that otters can move freely up and down the watercourse ensuring access during both construction and scheme operation. Excavations and trenches must be covered overnight to prevent entrapment, and permanent fencing should be in place to exclude otter from the carriageway. We note the proposed installation of otter ledges at new culverts and the River Tud crossing. 3.4 The Otter and water vole survey report (Appendix 8.14), also states that measures must be in place during construction to ensure that water vole are not impacted. A 5m buffer is to be retained from the top of the bank of the River Tud. Any displacement, if required, must be carried out within the displacement window 15 February – 15 April under Natural England licence. We note the reference to these measures in the EMP table 3.1 Record of Environmental Actions and Commitments (REAC). 4.0 Document 6.1 Environmental Statement Chapter 9 – Geology and Soils 4.1 In respect of Table 9-4: Sensitivity of receptor; we would suggest that any aquifer, principal or secondary, which supports potable supply should be accorded ‘very high’ values. However, we note that within Table 9-13: Determination of the significance of residual effects, ‘Groundwater’ as a feature (encompassing both principal and secondary aquifer) is identified as having ‘very high’ sensitivity. 4.2 Regarding Table 9-5: Magnitude of impact; any impacts on groundwater abstraction, whether those abstractions are used for public or private potable supply, should be deemed to be of major magnitude. It will be essential 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. 4.3 Table 9-6: Baseline data. We have a few corrections to make in respect of this table. We would highlight that both the chalk and the sand & gravel aquifers are used for private domestic (i.e. potable) supplies in the area of the scheme, not just for agricultural purposes as recorded in the table. The new Anglian Water Services Public Water Supply borehole is in East Tuddenham not North Tuddenham; the associated Source Protection Zone 1 (SPZ1) should be assumed to extend 250m to east, south and west in addition to 1 km to the north. For information, the site was licensed in September 2020, to take water from the chalk for public supply, all year round. 4.4 Regarding ‘Landfill records’ and baseline data, records of former landfills taking ‘inert’ waste should be substantiated. Prior to regulation, proper records of waste types deposited were not kept, and records that do exist have been found to be incorrect at other sites. 4.5 For table 9-8: Potential receptors; this should include East Tuddenham SPZ1 and private groundwater abstractors. 4.6 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 Document 6.1 Environmental Statement Chapter 10 – Material Assets and Waste 5.1 Appendix 10.2 Outline site waste management plan is comprehensive in its current form. But the references at 10.1.20 and 10.1.32 to the Environmental Permitting (England and Wales) Regulations 2010, should be updated to Environmental Permitting (England and Wales) Regulations 2016. 6.0 Document 6.1 Environmental Statement Chapter 13 – Road Drainage and Water Environment and Appendices 6.1 In respect of fluvial flood risk, a Flood Risk Assessment (FRA) has been prepared and is included as Appendix 13.1. We are generally satisfied with the FRA and with the proposed approach to managing fluvial flood risk across the scheme, subject to clarification on the points outlined below. 6.2 The FRA confirms that a compensatory flood storage scheme is required to compensate for the loss of floodplain storage at the proposed River Tud crossing. As highlighted at paragraph 13.4.13 of ES Chapter 13, the Applicant has previously provided information to us to demonstrate that the flood storage area indicated in drawing HE551489-GTY-ELS-000-DR-LX-30012 from document 6.8 Environmental Masterplan, has the potential to directly compensate on a volume-for-volume and level-for-level basis to prevent a loss of floodplain storage. 6.3 However, the submitted FRA does not currently include clear confirmation that appropriate flood storage compensation can be delivered. Further information, possibly as an addendum to the FRA, should be provided as part of the DCO application to demonstrate that the required volumes have been assessed and can be appropriately provided. 6.4 FRA paragraph 7.1.2, in respect of the River Tud compensatory storage scheme, states that: “The proposal will be further reviewed at detailed design, where it will be appropriately contoured and sensitively tied into the landscape following the provision of updated topographic survey”. The Environment Agency would wish to review and agree that detail. It is not currently clear which mechanism will be used to enable us to review and approve the detailed design. This should be confirmed. It would not be appropriate for this matter to be agreed as part of a Flood Risk Activity Permit. 6.5 The potential requirement for flood compensatory storage on the Oak Farm tributary is discussed at paragraph 7.2.3 of the FRA. This paragraph states: “it is proposed that no flood compensatory storage is provided. This has been agreed, in principle, with Norfolk County Council subject to the provision of more detail of the flood risk impacts within this assessment”. It is not clear whether the provision of more detail is already contained within this assessment or is to be added. As above, the mechanism for reaching the final agreement on this issue needs to be defined. If flood compensatory storage is not provided, flood risk to an area of arable land will increase. For that scenario, it should be confirmed that any landowner affected is accepting of the increased risk. 6.6 Regarding the possible need for compensatory flood storage on the Hockering watercourse, paragraph 7.3.2 of the FRA states that: “A detailed topographic survey is currently being undertaken, therefore the estimated volume of floodplain storage displaced will be reviewed at detailed design”. As above, the mechanism for reviewing and agreeing the final design needs to be defined. 6.7 Paragraph 7.3.1 of the FRA notes that there will be a small displacement of water on the Hockering watercourse, calculated to be 27m3. The paragraph states: “Due to the poor quality of LiDAR within this area and the fact that cross-sections are mainly based on interpolation, an uncertainty allowance of 20% has been included in the estimate”. As stated at ES paragraph 13.9.36, we agree that no compensatory storage would be required for a loss in floodplain storage of 27m3. However, the Applicant should confirm that the 20% uncertainty allowance is a sufficient worst case scenario, and that there is no risk that a detailed topographic survey would change the amount of water displaced sufficiently to result in a compensatory storage scheme becoming required. 6.8 In respect of surface water and ecology, paragraph 13.8.28 of the ES considers the potential impact of the River Tud crossing on the watercourse. Although shading is considered in respect of its potential effects on channel stability, structural damage and increasing sediment, the potential impact of the new 30m wide bridge deck on Water Framework Directive (WFD) Biological quality elements does not appear to have been assessed. 6.9 Shading of the River Tud at this location may have profound impacts on the aquatic, marginal and bankside vegetation assemblage and consequently create a ‘dead zone’ where shading is densest. If vegetation is shaded out there will be a permanent loss of habitat for invertebrate species, and subsequently fish and mammal species as well. For some fish species dense shade is a barrier to migration. It should be demonstrated that the impact of shading has been assessed both alone, and in combination with the existing crossing which will be retained and with other relevant projects. 6.10 Drawing HE551489-GTY-ELS-000-DR-LX-30012 (from document 6.8 Environmental Masterplan), identifies an area for potential enhancement measures in the vicinity of the River Tud crossing. There must be confidence that ecological enhancements, which are to be detailed at a later stage, will be capable of appropriately compensating and mitigating any adverse effects of the proposals, including those caused through shading. The River Tud is priority Chalk Stream Habitat, which are protected under the Natural Environment and Rural Communities Act 2006 (NERC). The proposed development must also ensure that there is no deterioration in the current WFD status of the River Tud, and must not prevent the waterbody from achieving ‘Good’ status in the future. Further information is required to demonstrate that measures will be provided to mitigate all impacts of the proposed crossing. 6.11 Paragraph 13.8.30 of the ES highlights the impacts of the new and extended culverts on the ecology of the Oak Farm and Hockering watercourses. Paragraph 13.9.11 outlines the proposed mitigation and enhancement measures. Further information will be required to fully demonstrate that the detailed measures proposed will provide adequate compensation for the impacts on the specific ecology of the affected watercourses from the permanent loss of riparian habitat. 6.12 In respect of groundwater resources and quality, we would comment that in Table 13-1 Criteria for Estimating the Importance of Water Environment Attributes, the ‘high’ category should include principal and secondary aquifers supporting all drinking water supplies (public and private). In Table 13-2 Estimating the Magnitude of an Impact on an Attribute, we note that the ‘major beneficial’ category includes ‘recharge of an aquifer. Artificial recharge to the chalk aquifer must be precluded. 6.13 Paragraph 13.5.2 considers groundwater levels. We would suggest that the February/March 2021 levels are likely to be representative of maxima. 6.14 With reference to paragraph 13.5.5, the temporary source protection zones for the new public water supply abstraction at East Tuddenham are available online. 6.15 Paragraph 13.8.15 refers to the use of directional drilling for utilities crossings. Where directional drilling is to be used, the Environment Agency must be consulted prior to any works to agree a method statement. Any such works must not alter the hydraulic continuity or otherwise between strata, must use inert drilling fluids, and should include monitoring and breakout mitigation plans. 6.16 With reference to paragraph 13.8.16; the Environment Agency would like to be consulted on the methodology for any groundworks with the potential to disrupt vertical hydraulic gradients. 6.17 The potential for impacts from spillages on shallow groundwater during construction should be included in Table 13.8. We note that this potential impact is included in Table 13.9 which considers potential effects during the operation of the proposed scheme. 6.18 In respect of the Drainage Strategy Report (Appendix 13.2), and paragraph 6.8.5, we would comment that no hazardous substances can be permitted to enter groundwater irrespective of the dilution potential. 6.19 We are pleased to note that filter drains will not be employed over areas where groundwater is within 1 m of the ground surface or within SPZ1. We request that drainage basins should also be excluded from these settings. 6.20 We look forward to being consulted on Piling Works Risk Assessment (and those for other below-ground structures) in terms of obstruction to groundwater flow, water quality and the preclusion of contaminant mobilisation. 6.21 We also look forward to seeing the Preliminary Risk Assessment for GWDTE (Groundwater Dependent Terrestrial Ecosystems) and groundwater abstractions, and any subsequent Hydrogeological Impact Assessments for sites in proximity to underground works, along with water features surveys for drainage at cuttings. 6.22 Overall, we are generally satisfied with the proposals and information outlined in the Drainage Strategy Report, 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). 6.23 In respect of surface water quality, we are satisfied with the consideration of potential issues and with the general principles of the proposed mitigation measures for construction and operation. As mentioned, we would want to review the detailed proposals. 6.24 With regards to water quality and WFD, chapter 13 includes reference to no impact on the ‘overall WFD status of the waterbodies’. There should be no deterioration in the status of any of the quality elements; it should be made clear that this has also been considered and is also the case. 6.25 We have reviewed the Water Quality Assessment (Appendix 13.3). We support the proposed approach to identify and put in place mitigation measures to ensure that sediment and other pollutants will not impact on the water quality of receiving watercourses. We look forward to reviewing the detail. 7.0 Document 7.4 Environmental Management Plan 7.1 With reference to paragraph 1.1.6, we note that the following documents are to be prepared to mitigate potential adverse effects upon surface waters and groundwater during construction: • a water monitoring and management plan • a temporary surface water drainage strategy 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 Other plans that we would also wish to review include the Landscape and ecology management plan, Soil management plan, Materials management plan, Site waste management plan, Biosecurity management plan and Invasive non-native species management plan (if prepared as a separate document). 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 BD4 & RD1 – we note the reference to the use of construction best practice in relation to pollution prevention and water management. As highlighted, the Environment Agency should be consulted on the water monitoring plans and temporary surface water drainage strategy. 7.6 RD2 & RD9 – In addition to the above, specifically in respect of the proposed compensatory flood storage area upstream of the River Tud Crossing, it should be noted that the Environment Agency should review and approve the detailed design. This should be progressed as part of the DCO process and not through an Environmental Permit. 7.7 RD3 – we note that the Environment Agency is to be consulted on construction method statements and risk assessments. We should also be consulted on piling design. 7.8 RD5 (and Table 4.1) – dewatering can only be undertaken without a licence at the rates quoted in the tables if the dewatering works for the whole scheme will last for a period of 6 consecutive months or less. If dewatering will occur over a longer time frame, the maximum rate at which dewatering can be undertaken without an abstraction licence is 20 m3/d. 7.9 RD10 – we would like to see the groundwater and surface water monitoring proposal and an assessment of the areas where groundwater is judged to be less than 1m below the drainage system. 7.10 The EMP does not currently appear to consider how catastrophic spills affecting the surface water drainage systems will be dealt with, or how any directional drilling activities will be managed. These issues should be addressed. 7.11 Regarding Table 4.1 – it should be noted that the Environment Permitting (England and Wales) Regulations from 2007 onwards replaced the permitting system in the Pollution Prevention and Control Act. 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."
Members of the Public/Businesses
Brown & Co on behalf of Food Enterprise Park Ltd
"Respondent: Food Enterprise Park (FEP) – James Alston as named partyif required FEP are owners and developers of land North of Church Lane, Easton where this an existing LDO for current and future development. FEP has significant concerns over the lack of access provision within the Scheme for the A47 dualling. The present arrangement is for traffic to exit the new route A47 at the grade separated junction (GSJ) and proceed along the side road to Easton before doubling back down Church Lane to the FEP access. From the GSJ to FEP is 2.3km and will involve bringing all traffic past Easton Church to then cross the flow of traffic at the Easton junction and then head west on Church Road. This will put the FEP traffic on the same route at the HTF farm traffic and the other 300+ users of the commercial space at Honingham Thorpe. It is inevitable that traffic from the East will try and bypass the double back and save circa 2.8km of journey by leaving the A47 at Longwater and taking the road through Easton, where they can turn left onto Church Lane and not have to cross the traffic. It is noted that under the terms of the LDO for the FEP phase 1, Blind Lane is required to be closed once certain thresholds relating to developed area and employed persons are reached. Blind Lane is currently easing some of the traffic flow in the area by taking traffic from the west approaching A47 traffic and Taverham Road. Its closure will exacerbate the problem detailed above. Discussions at an early stage of the A47 project inception included designs for a spur off the southern part of the GSJ direct into the FEP, then an access was shown off the Honingham spur and now nothing is provided. It is the opinion of the FEP that the design for the A47 scheme should allow for such an access as an integral part of the design, rather than allowing it to be a ‘bolt on’ later. Designing in an access at an early stage will ensure that it is fit for purpose and could mean that the potential problem with gradient change to the Honingham spur is avoided. The development of the FEP, along with the development of housing around Easton is part of the justification for the A47 project. The design, as submitted will result in those enabling factors becoming even greater hinderances on the local highways network. An access close to the southern part of the GSJ would remove traffic from Easton, reduce journey time, reduce traffic on Church Lane and take traffic away from Easton Church. Provision of an access point for the FEP could also enable the farm traffic for HTF serving Ringland Estate to be kept away from the highways network and Easton, without allowing Blind Lane to remain open to the public as a potential rat run. The respondent requests that the Inspection seeks further consideration on these proposals."
Members of the Public/Businesses
Gil Murray
"I object to the proposed scheme for these reasons: A.     The traffic and economic modelling uses data, assumptions and projections from before the Covid 19 pandemic.  Recent and future levels of home-working and the shift towards Internet-based meetings need to be assessed against the supposed need for “increased capacity”. B. When the Northern Distributor Road (NDR) was first proposed it was as a circular road around Norwich (with the Southern Bypass). Permission for this was refused because the Wensum valley is a wildlife site of European importance. The NDR was then redesigned as a distributor road and the traffic modelling claimed that the traffic would go from the NDR to the A47 via Postwick, not to the west of Norwich. Immediately the NDR was opened this proved to be wrong and the Norwich Western Link was proposed, despite this route having already been refused. We need a satisfactory explanation why the traffic modelling was wrong last time before we can believe it this time. C.      The application for this scheme and traffic modelling assume that the Norwich Western link is already built, when in fact that route has previously been refused. To comply with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017, the environmental statement should start from the current situation now as the environmental baseline.    D.     The A47 dualling links with the Norwich Western link.  The application does not fully explore the relationships between the two road proposals, and needs to be fully examined at the examination.    E.  When the NDR was proposed it was said that this would reduce traffic in the north of Norwich and free up space for more bus priority schemes. This has not been done. These should be done before more car schemes are proposed. F.      The traffic modelling is based on the NATS 2015 (baseline year 2015) model.  Recent modelling by Norfolk County Council based on the newer NATS 2019 (baseline year 2019) model reports substantially lower (c. -30%) vehicle kilometres within the scheme area.  The discrepancies need to be examined, and the models fully reconciled. G.     Carbon emissions should be tested against inter/national legislation and guidance including the Paris agreement, the legally binding target under the Climate Change Act 2008 to meet net-zero carbon emissions by 2050, the UK Sixth Carbon Budget (6CB), science-based carbon budgets from the Tyndall Centre, NPPF 148 which requires the planning system contribute to “radical reductions of greenhouse gas emissions”. H.       Norfolk County Council has identified that the area north of the scheme has a nationally significant breeding barbastelle colony of bats, recently found, which although not yet afforded SSSI or SAC status would otherwise qualify as such (see: page 85 in NCC submission to PINS on the A47/A11 Thickthorn Junction, June 3rd, at [redacted]).  The in-combination, and cumulative impacts, of the A47 dualling with the Norwich Western link road on this European protected species should be assessed under Part 3, Section 40 of the Natural Environment and Rural Communities Act 2006."
Members of the Public/Businesses
Hockering Parish Council
"1. TO CONGRATULATE HIGHWAYS ENGLAND UPON THEIR WORK TO DATE ESPECIALLY THEIR ATTENTION TO OUR PREVIOUS MATTISHALL LANE CONCERNS. 2. TO SEEK REASSURANCE ON POSSIBLE CONTAMINATION TO THE RIVER TUD. 3. TO SEEK FURTHER GUIDANCE ON IMPROVED LIGHTING PROPOSALS FOR THE DEVELOPMENT ONCE COMPLETE."
Members of the Public/Businesses
James Brown
"I am a resident of Hockering. I expect my representation to cover the following points. I intend to comment positively on the provision for cycle lanes although I will examine the proposal carefully to see how it joins up with provision for cyclists at the Norwich end. I will examine carefully the provisions for footpaths and will comment positively or negatively on provision. I am concerned about the potential loss of footpaths along a section of the River Tud. I am concerned about the impact on wildlife in woods and marshes along the River Tud and I hope to see that the final plan, including the layout of junctions, recognises the exceptional wildlife value of these habitats. I will comment very critically if there is any deviation from the stated intention to not to increase traffic in the village of Hockering. I hope to see that the scheme will include improvement of the junctions at North Tuddenham, which are currently dangerous and thus have the potential to adversely traffic flow on the new dualled section of the A47."
Members of the Public/Businesses
Jamie Osborn
"Councillor Jamie Osborn, Green Party I am a Norwich City councillor and Norfolk County councillor. This submission is made independently as my personal submission, and is separate to the Green Party submission, already made. I object to the scheme for the following reasons: A. In combination with the Norwich Western link (NWL) road, the scheme would increase capacity, traffic growth and emissions contrary to national policies for climate change, air quality and modal shift towards walking, cycling and public transport. B. The impact of the Covid 19 pandemic on travel patterns and road capacity need has not been assessed. C. The application, Environmental Impact Assessment, and traffic modelling baselines all assume the NWL is already built. To give an accurate assessment of the impact of the schemes, each of these should start from the current situation which is that no NWL, nor A47NTE exists. D. The traffic modelling needs to start from the current situation and sensitivity test all options that include either an NWL or an A47NTE. E. The NWL study area overlaps with the scheme area. The implications for the A47NTE from the loss of 30% of AADT vehicle kilometers, a proxy for traffic levels and carbon emissions, from the NWL models between the 2019 Option Selection Report ([redacted]) and the 2021 Outline Business Case ([redacted]) needs to be fully assessed. F. The scheme fragments and displaces nature and wildlife habitats, wet grazing meadows, protected species (notably bats). G. A nationally significant breeding colony of barbastelle bats, a European protected species, has been identified by NCC as potentially qualifying for SSSI or SAC status ([redacted], PDF page 85). Full assessment of the in-combination impacts of A47NTE and NWL on this colony is required. H. In-combination, and cumulative impacts, for biodiversity, ecology, and air quality with at least six other road infrastructure schemes near to Norwich and East Norfolk need full assessment. I. Carbon emissions need to be cumulatively assessed *both* locally within the Norwich area (in combination effects with the six other possible schemes identified above), and nationally with up to 100 other schemes planned by Government, including under RIS2. J. Carbon emissions should be tested against inter/national legislation and guidance including the Paris agreement, the legally binding target under the Climate Change Act 2008 to meet net-zero carbon emissions by 2050, the UK Sixth Carbon Budget (6CB), science-based carbon budgets from the UK Tyndall Centre, the NPPF 148 planning requirement to “radical reductions of greenhouse gas emissions”, and the NCC Environmental Policy."
Members of the Public/Businesses
Jean Bishop
"I am opposed to the proposed scheme as I feel it will have a disasterous impact on the very sensitive Wensum Valley, causing fragmentation, loss or displacement of dimminishing wildlife habitats. Also causing urbanization of precious mature countryside. It does not comply with current national policiy of reducing carbon emmisions at a time when it is vital to do so, the road will increase emmisions. This should be calculated in the light of COVID where many people have been working from home and with meetings online vastly reducing car journeys and consequently carbon emmisions. National policies require a modal shift towards more walking, cycling, and public transport."
Members of the Public/Businesses
Mair Bain
"I object to this scheme because... Road traffic numbers must reduce if the UK is to met legally binding carbon emissions targets. This scheme will increase capacity and increase emissions. Carbon emissions should be tested against inter/national legislation and guidance including the Paris agreement, the legally binding target under the Climate Change Act 2008 to meet net-zero carbon emissions by 2050, the UK Sixth Carbon Budget (6CB), science-based carbon budgets from the Tyndall Centre, NPPF 148 which requires the planning system contribute to “radical reductions of greenhouse gas emissions”. The impact of COVID-19 on travel demand has not been assessed and taken into account with this scheme. It is based on pre-pandemic and pre-climate emergency data and plans. The scheme involves fragmentation, loss or displacement of diminishing wildlife habitats such as wet grazing meadows and protected species, notably bats and the urbanisation of mature countryside. This will hinder the UK's nature recovery targets set to act on the biodiversity crisis. It is illogical to be using public money on increasing capacity for a form of transport that must be reduced if the UK is to meet climate targets. The electric vehicle revolution will not happen fast enough and the resources and energy required for EVs and highways are higher with greater carbon and ecological impact than mass transit and active travel transport."
Members of the Public/Businesses
Brown & Co on behalf of Mr Neil Alston
"Respondent: Mr Neil Alston Property: Land at East Tuddenham The total Property owned by the Respondent extends to approximately 518ha (1230 acres) of what is primarily productive arable land, interspersed with areas of woodland and lowland grass. Approximately 105 ha (260 acres), representing 20% of the holding, is located to the North of the existing A47. The single carriageway nature of the A47 at the dividing point and the availability of Berry Hall Lane and Church Lane ensure the Property retains a sense of connection. This is an important factor for the efficient operation of the agricultural enterprises carried out on the Property. The closure of Church Lane and Berry Hall Lane, without alternative provision for access, will result in the Property being severed. This will have a detrimental impact on the nature and cohesion of the Property and will significantly impact the efficacy of the farming operations carried out thereon. The Respondent accepts the need to close Church Lane, despite it being the closest link point between the two parts of the Property. It had been hoped, and understood to be the case from early designs, that Berry Hall Lane would remain open. This would have allowed agricultural traffic, which has always used this access route without challenge, to effectively passage between the north and south blocks. The Respondent has been informed that Berry Hall Lane must be closed to avoid ‘rat running’ from the Wood Lane junction south to Wymondham. This is apparently the belief of the local parish councils. To date, no empirical evidence has been provided to back up this assertion and in the absence of such data the closure of Berry Hall Lane appears to be without justification. The Respondent will suffer actual interference with the use and enjoyment of his Property. Proposals have been made by the Respondent to Highways England to retain Berry Hall Lane as a private means of access, with gates/bollards or some other form of traffic flow control. This would enable the issue of rat running to be addressed but allow the Respondent to operate the north and south blocks more efficiently and cohesively. In the absence of Berry Hall Lane as an access route, all farm traffic will need to follow one of two routes. Route 1 goes west through East Tuddenham to the Mattishall Lane link road and then back east along the old A47, taking 6km to do what used to take 1.6km and involving taking machinery through East Tuddenham. Route 2 heads east to the Honingham Church roundabout, doubles back along the old A47 to the Wood Lane Grade Separated Junction (GSJ), navigates that and then comes out on the north side of Wood Lane. Taking an extra 3km of journey compared to using Berry Hall Lane. The proposals sever the Property, significantly impact the efficacy of running a farming business on the Property, put a significant number of agricultural vehicles on the highways network rather than keeping them localised, and pushes traffic through East Tuddenham. It has been suggested that Berry Hall Lane is not fit for purpose because of its width, but it, like so many other Norfolk roads, has served the agricultural industry well over the years and should be allowed to continue to do so, for the benefit of the surrounding highways network as well as the Respondent. It is requested that the Inspector consider a proposal to maintain a private agricultural right of way along Berry Hall Lane with enhancement of the proposed footpath link to the Dereham road link, to that of a 4m wide hard surfaced roadway with gates/bollards."
Members of the Public/Businesses
National Grid Gas plc
"Dear Sir/Madam REPRESENTATION BY NATIONAL GRID GAS PLC (“NGG”) TO THE A47 NORTH TUDDENHAM TO EASTON (“THE PROJECT”) NGG wishes to make a relevant representation to the Project DCO in order to protect its position in relation to infrastructure and land which is within or near the proposed Order limits. NGG’s rights to retain its apparatus in situ and rights of access to inspect, maintain, renew and repair such apparatus located within or near the Order limits should always be maintained and access to inspect and maintain such apparatus must not be restricted. The documentation and plans submitted for the above proposed scheme are being reviewed in relation to impacts on NGG’s existing apparatus and land interests located within this area, and NGG may require protective provisions to be included within the DCO to ensure that its interests are adequately protected and to ensure compliance with relevant safety standards. The NGG project team are liaising with the Promoter in this regard and have been throughout the whole process thus far. NGG assets which have been identified as being within or within close proximity to the proposed Order limits are: HIGH PRESSURE GAS PIPELINE: Feeder 3 – Felthorpe to Hardingham NGG will continue to review the application documents in liaison with the applicant to adequately protect NGGs retained apparatus and to ensure that NGG will be able to deliver the infrastructure associated with the DCO if required. NGG will advise the Examining Authority of any issues in this regard as the examination progresses. I hope the above information is useful. If you require any further information, please do not hesitate to contact me. Yours sincerely Spencer Jefferies Town Planner, Land and Acquisitions."
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. This particular stretch of road has a poor safety record and 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
Pinsent Masons on behalf of Norfolk County Council as promoter of Norwich Western Link
"This representation is submitted for Norfolk County Council in its capacity as the local highway authority promoting the proposed Norwich Western Link (“NWL scheme”), which is intended to connect to Highways England’s (“HE”) A47 North Tuddenham to Easton scheme (“A47 scheme”) at the improved Wood Lane junction. A separate representation is submitted by Norfolk County Council in its wider capacity as a ‘host’ local authority under s.43 Planning Act 2008, commenting on the A47 scheme from its perspective as Highway Authority, Minerals and Waste Planning Authority, Lead Local Flood Authority and in having Public Health responsibilities. As promoter of the NWL scheme, Norfolk County Council (“NCC”) is fully supportive of the A47 scheme and welcomes HE’s inclusion in the DCO application documentation of provision linking the NWL scheme with the proposed A47 (“the NWL spur”). NCC seeks clarification of HE’s position on: 1. “Optional cycle track” – Work No.26a The A47 scheme includes provision for a cycle track between the realigned Wood Lane and Hall Farm Underpass, shown on the Rights of Way and Access (“RoWA”) Plans as looping around the NWL spur. In discussion with NCC, HE indicated this arrangement would not be provided if the NWL scheme starts construction in the same period as the A47 scheme. NCC seeks assurance from HE that a new permanent non-motorised user (“NMU”) facility is not required at this location as part of the NWL scheme. 2. Delivery of NWL spur NCC seeks clarification of HE’s intention to construct the NWL spur. HE’s Statement of Reasons (paragraph 4.16.4) anticipates delivery of the A47 scheme before the NWL scheme, and indicates that although the NWL spur is expressed (in the DCO) to be “optional”, HE would construct it in anticipation of the NWL scheme, to minimise future disruption to the highway network. However, the Scheme Design Report (paragraph 9.2.7) states that the NWL spur “would only be created if the NWL obtained planning consent prior to the [A47] Scheme commencing the main construction works." NCC seeks HE’s commitment to greater flexibility in collaborating to deliver both schemes. The NWL spur is not identified in the RoWA Plans as “new/improved/altered highway”, notwithstanding its identification as Work No.98 in the Works Plans, reflecting DCO Schedule 1 and the intention presented in the Classification of Roads Plans and DCO Schedule 3, Part 1A, where it is identified as an ‘A’ road. NCC suggests amendment of the RoWA Plans to resolve inconsistency and clarify HE’s intentions. 3. NMU provision on Dereham Road Noting HE’s proposed NMU provision on/around Dereham Road, NCC would welcome opportunities for collaboration with HE to ensure this element of the A47 scheme can be further developed to provide suitable NMU routes. 4. Delay to NWL delivery NCC has been working with HE to identify appropriate arrangements for local communities (in particular Weston Longville) should delivery of the NWL scheme be delayed. NCC would welcome the opportunity to settle the approach in agreement with HE, and to commit to a mutually acceptable solution."
Members of the Public/Businesses
Orsted Hornsea Project Three UK
"This relevant representation is made by Orsted Hornsea Project Three (UK) Limited (“Hornsea Three”) the named undertaker on the Development Consent Order (DCO) for the Hornsea Three Offshore Wind Farm Order 2020 (the “Hornsea Three Order”). The proposed Order limits and Order land for the A47 Tuddenham DCO overlap with the Order limits and Order land as defined in the Hornsea Three Order. Hornsea Three engaged with Highways England in relation to the possible interactions and impacts of the A47 Tuddenham DCO on Hornsea Three during the Examination of Hornsea Three and prior to the submission of the A47 Tuddenham DCO Application. Hornsea Three has subsequently reviewed the Highways England A47 Tuddenham DCO Application which has been accepted by PINS. This letter forms the initial representation to the proposal. The A47 North Tuddenham to Easton Dualling DCO (the “A47 Tuddenham DCO”) will interact with the Hornsea Three Order in two main ways: a. Overlap of works areas where Highways England had identified potential material storage areas and needs to create the new A47 mainline, utilities diversions and new route for walkers, cyclists and horse riders with the Hornsea Three Order onshore export cable corridor; and b. Loss of access for Hornsea Three for both construction and operation from Church Lane, north of the A47, when the Easton roundabout is removed. What has been provided by Highways England The A47 Tuddenham DCO includes development consent for works relating to the Hornsea Three Order. Works No. 94 grants consent for the Hornsea Three cables and Works No. 99 grants consent for the temporary haul road to construct the Hornsea Three cables. Requirement 13 of the A47 Tuddenham DCO requires Highways England to obtain Hornsea Three’s written approval prior to commencing Works No. 94 and all works must be carried out in accordance with Requirements 10, 17, 18 and 22 in Schedule 1 Part 3 of the Hornsea Three Order. The A47 Tuddenham DCO also includes compulsory acquisition powers to acquire new rights over land and impose restrictions relating to the installation of the Hornsea Three cables and rights to access to install and maintain the Hornsea Three cables. It is helpful that the powers in the A47 Tuddenham DCO can be transferred to Hornsea Three for the purposes of undertaking Works No. 94 and Works No 99. However, it is noted that there is currently no obligation upon Highways England to transfer the powers to Hornsea Three or any obligation on Highways England to cooperate and facilitate the installation of the Hornsea Three cables and the temporary haul road. Hornsea Three is the holder of a generation licence under the Electricity Act 1989 and a statutory undertaker for the purposes of s127 of the Planning Act 2008. Hornsea Three has the benefit of a number of Option Agreements over land within the proposed Order limits for the A47 Tuddenham DCO. Hornsea Three note that there are generic protective provisions for Electricity Act 1989 licence holders in the A47 Tuddenham DCO but as currently drafted these only apply to existing apparatus and would not therefore apply to the construction of the Hornsea Three cables. Issues to be resolved Hornsea Three considers that the two schemes can co-exist and therefore does not have an in-principle objection to the A47 Tuddenham DCO. However, as Hornsea Three is a consented nationally significant infrastructure project, it is crucial that the A47 Tuddenham 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 so as 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: • Highways England to provide confirmation that the replacement access track will be suitably designed to allow the maximum design of Hornsea Three’s construction vehicles to utilise the access. Specifically, Hornsea Three requires it’s abnormal load requirements to be facilitated, including any necessary approvals from the highways authority to be secured by Highways England on behalf of Hornsea Three. • Highways England to provide confirmation that the new dumbbell roundabout will be suitably designed and aligned to allow the maximum design of Hornsea Three’s construction vehicles to utilise the roundabout. • Highways England to provide confirmation of the construction activities that it is proposing to undertake and any permanent operational apparatus to be installed within the area of overlapping Order limits so it can be understood whether such activities will have an impact on the construction, operation or maintenance of Hornsea Three. • Highways England to provide sufficient information to Hornsea Three to establish whether the A47 Tuddenham DCO will prevent or restrict Hornsea Three from complying with Hornsea Three’s Taverham Highways Intervention Scheme (HIS) (as required pursuant to Requirement 18 (Construction Traffic Management Plan) of the Hornsea Three Order). Highways England to provide confirmation that it will work with Hornsea Three to agree any changes which might be required to the HIS with the local highways authority (Norfolk County Council). • Highways England to provide sufficient information to Hornsea Three to establish whether the A47 Tuddenham DCO will have any impacts on the Hornsea Three construction traffic routes.In particular, Hornsea Three would like to understand whether any of its vehicle movements may need to be re-routed and if this will align with previous commitments made to other relevant key stakeholders. 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. As mentioned above, whilst compulsory acquisition powers have been included in the A47 Tuddenham DCO there is no obligation on Highways England to exercise the powers or transfer the powers to Hornsea Three. • Highways England to provide confirmation that the replacement access provided by Highways England will remain in situ until the completion of the construction of Hornsea Three (which is likely to be after the opening of the new road). This includes ensuring that the temporary use powers are of a sufficient duration and including a positive obligation on Highways England to keep the access in place and maintained to a suitable standard. With regard to the A47 Tuddenham DCO Hornsea Three reserves the right to make further representations as the examination progresses but proposes the following additions/amendments to the A47 DCO on a preliminary basis: a. The rights and restrictions in Schedule 5 (Land in which only new rights etc. may be acquired) need to be amended so as to align with the rights in the Hornsea Three Order (including rights to “use” and rights for landscaping) and need to refer to the correct Works No. b. A provision is included to state that if compliance with the A47 DCO prevents the undertaker from complying with any article or requirement in the Hornsea Three Order then the undertaker shall not be in breach of the Hornsea Three Order and it shall be a defence to an offence under s161 of the Planning Act 2008 to prove that the undertaker was not able to comply as a result of the A47 DCO (and vice versa). c. Hornsea There require protective provisions to be included on the face of the A47 DCO. The parties propose to discuss and agree protective provisions and Hornsea Three will endeavour to submit draft protective provisions by the first deadline. Hornsea Three will continue to work with Highways England to facilitate agreement between the parties to ensure both projects can co-exist. Both parties are open to entering into a co-operation agreement to facilitate co-existence. This agreement will include the ongoing engagement with affected landowners. Hornsea Three looks forward to further engagement with Highways England on these and any other matters that may arise."
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. The modelling reported in the application documents predict a slight deterioration in air quality (in terms of nitrogen dioxide) at 25 of the 49 modelled human receptor locations, once the proposed scheme is operational. However, it is also predicted that concentrations will remain beneath relevant air quality objectives at all modelled human receptor locations with the remaining 24 showing a slight improvement. Nevertheless, 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. PHE have no additional comments to make at this stage and can confirm that we have chosen NOT to register an interest with the Planning Inspectorate on this occasion. Please do not hesitate to contact us if you have any questions or concerns."
Members of the Public/Businesses
Steve Hale
"I object to the proposed scheme for these reasons: A. The case for the scheme (at 3.5.1) says that it will increase capacity which means that it will increase traffic growth in Norwich area. This does not comply with national policies for climate change and modal shift towards walking, cycling and public transport. B. The traffic and economic modelling uses data, assumptions and projections from before the Covid 19 pandemic. Recent and future levels of home-working, the shift towards Internet-based meetings, and strong reductions of traffic on the roads due to COVID impacts need to be assessed against the supposed need for “increased capacity”. C. The application and traffic modelling assume that the Norwich Western link is already built. To comply with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017, the environmental statement should start from the current situation now as the environmental baseline. D. The A47 dualling links with the Norwich Western link. The application does not fully explore the relationships between the two road proposals, and needs to be fully examined at the examination. E. The traffic modelling is based on the NATS 2015 (baseline year 2015) model. Recent modelling by Norfolk County Council based on the newer NATS 2019 (baseline year 2019) model reports substantially lower (c. -30%) vehicle kilometres within the scheme area. The discrepancies need to be examined, and the models fully reconciled. F. The scheme involves fragmentation, loss or displacement of diminishing wildlife habitats such as wet grazing meadows and protected species, notably bats and the urbanisation of mature countryside. G. In-combination, and cumulative impacts, for biodiversity, ecology, air quality and carbon emissions have not been assessed with at least six other road infrastructure schemes near to Norwich and East Norfolk. Carbon emissions need to be cumulatively assessed both locally within this area, and nationally with up to 100 other schemes planned. The recent judgement of Pearce v Secretary of State BEIS [2021] demonstrates that the Courts accept the importance of cumulative environmental impact assessment. H. Carbon emissions should be tested against inter/national legislation and guidance including the Paris agreement, the legally binding target under the Climate Change Act 2008 to meet net-zero carbon emissions by 2050, the UK Sixth Carbon Budget (6CB), science-based carbon budgets from the Tyndall Centre, NPPF 148 which requires the planning system contribute to “radical reductions of greenhouse gas emissions”. I. Norfolk County Council has identified that the area north of the scheme has a nationally significant breeding barbastelle colony of bats, recently found, which although not yet afforded SSSI or SAC status would otherwise qualify as such (see: page 85 in NCC submission to PINS on the A47/A11 Thickthorn Junction, June 3rd, at [redacted]). The in-combination, and cumulative impacts, of the A47 dualling with the Norwich Western link road on this European protected species should be assessed under Part 3, Section 40 of the Natural Environment and Rural Communities Act 2006."
Members of the Public/Businesses
David Pett on behalf of Stop Wensum Link
"Submissions in relation to the proposed construction of A47 North Tuddenham to Easton (‘Proposed development’) I am a solicitor and a member of the steering committee of the Stop Wensum Link (’SWL’) action group. I make for and on behalf of SWL the following submissions. The Proposed Scheme, together with at least six other infrastructure schemes planned (1) /approved (2) within Norfolk, needs to be evaluated to measure the likely impact of cumulative CO2 emission levels in the context of relevant climate change commitments and obligations: these include the Norfolk County Council Environment Policy, and UK national (3) and international Climate Change obligations. The Norwich Western Link (NWL) is the only road scheme referenced in the Cumulative Effects Assessment (APP-054), and only for noise, vibration and air quality. The Infrastructure Planning (Environmental Impact Assessment) Regulations 2017 impose a general duty to consider cumulative impacts and climate change. Furthermore the carbon emission projections of Proposed Scheme need to be assessed as part of the large number of road schemes forming part of the RIS2 Scheme. The proposed Scheme will undoubtedly have an impact on the environment and biodiversity (4). In determining the level of impact as well as the design and implementation of appropriate mitigation and compensatory measures, it is our submission that baseline assessment should not be confined to this and the NWL schemes only, but should also encompasses the other major infrastructure projects that are proposed to take place within Norfolk. There is evidence currently before Norfolk County Council, for instance, which shows an interdependency of barbastelle bat colonies within the County that could if not adequately addressed lead to a population reduction of this highly protected species. There is also linked impacts in relation to the ecological condition of the River Wensum SAC given the works proposed in and around the River Tud. The traffic and economic modelling relied upon is based on data, assumptions and projections that pre date the Covid 19 pandemic. It our submission that the impact of the pandemic has lead to high levels of home-working, a shift towards Internet-based meetings, and strong reductions of traffic on the roads. It is likely that future traffic growth, time savings and economic benefits have been over-estimated and a larger scheme design than is necessary. It will be our wish to expand upon the following submissions and to interrogate within the context of these submissions the evidence adduced in support of the Proposed Scheme. Footnotes 1 A47 Blofield, A47 Tuddenham, A47 Thickthorn, Long Stratton By-Pass, Norwich Western Link, A47 Gt Yarmouth Junction Improvements at Vauxhall and Gapton 2 Gt Yarmouth third river crossing 3 Climate Change Act 2008 (2050 Target Amendment) Order 2019: the UK parliament passed legislation which replaced a previous target of an 80% reduction in GHG emissions by 2050 with a more ambitious target to reduce the UK’s net emissions to zero by 2050 – the so called “Net Zero” target 4 Graded as ‘Large Adverse’"
Members of the Public/Businesses
Transport Action Network
"Transport Action Network wishes to register an OBJECTION to the proposed scheme on the following grounds: 1. Climate change and increased traffic 2. Cumulative effect of this scheme with other proposed road schemes 3. Noise 4. Air quality 5. Biodiversity and habitats 6. Landscape"
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 North Tuddenham to Easton 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 North Tuddenham to Easton scheme has a construction duration of 23 months, which (assuming construction commencement 2022/23) 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 North Tuddenham to Easton 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- 054) Section 15.5 identifies The Norfolk Projects and contains an assessment of cumulative effects. With regard to traffic and transport and the assessment concludes: “Due to the temporary nature of the construction impacts and implementation of traffic management for both the Proposed Scheme and different projects, the potential cumulative effects identified on traffic and transport are not considered to be significant.” VWPL agrees with this statement in principle but would suggest that the implementation of communication plans that maximise opportunities to co-ordinate roadworks and manage peak construction traffic demand be committed to. No other potential cumulative impacts are identified, which aligns with VWPL’s assessments. 7.5 Outline Traffic Management Plan (APP – 144) The Outline Traffic Management Plan identifies that “Full carriageway closures will be used during the duration of the project from early works up to completion”. This could potentially lead to significant delays to the A47 corridor, which could be exacerbated by the Norfolk Projects’ construction traffic. In addition, the requirement for full overnight closures are identified (between 20:00 – 06:00) the majority of which would be carried out during the period from July 2024 to November 2024. Whilst it is noted that the majority of closures fall outside of the peak traffic demand for the Norfolk Projects, and the timings would only affect early arrivals to site, nevertheless, there is the potential for disruption to construction traffic associated with the Norfolk Projects being diverted off the A47, potentially inducing delays of over an hour in journey time. There is also the need to consider additional management processes to ensure diverted construction traffic does not utilise inappropriate alternative local routes. However, VWPL consider that any potential cumulative impacts between the A47 North Tuddenham to Easton 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 North Tuddenham to Easton 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."
Members of the Public/Businesses
Victoria Rance
"I object to the proposed scheme for these reasons: A. The case for the scheme (at 3.5.1) says that it will increase capacity which means that it will increase traffic growth in Norwich area. This does not comply with national policies for climate change and modal shift towards walking, cycling and public transport. B. The traffic and economic modelling uses data, assumptions and projections from before the Covid 19 pandemic. Recent and future levels of home-working, the shift towards Internet-based meetings, and strong reductions of traffic on the roads due to COVID impacts need to be assessed against the supposed need for “increased capacity”. C. The application and traffic modelling assume that the Norwich Western link is already built. To comply with the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017, the environmental statement should start from the current situation now as the environmental baseline. D. The A47 dualling links with the Norwich Western link. The application does not fully explore the relationships between the two road proposals, and needs to be fully examined at the examination. E. The traffic modelling is based on the NATS 2015 (baseline year 2015) model. Recent modelling by Norfolk County Council based on the newer NATS 2019 (baseline year 2019) model reports substantially lower (c. -30%) vehicle kilometres within the scheme area. The discrepancies need to be examined, and the models fully reconciled. F. The scheme involves fragmentation, loss or displacement of diminishing wildlife habitats such as wet grazing meadows and protected species, notably bats and the urbanisation of mature countryside. G. In-combination, and cumulative impacts, for biodiversity, ecology, air quality and carbon emissions have not been assessed with at least six other road infrastructure schemes near to Norwich and East Norfolk. Carbon emissions need to be cumulatively assessed both locally within this area, and nationally with up to 100 other schemes planned. The recent judgement of Pearce v Secretary of State BEIS [2021] demonstrates that the Courts accept the importance of cumulative environmental impact assessment. H. Carbon emissions should be tested against inter/national legislation and guidance including the Paris agreement, the legally binding target under the Climate Change Act 2008 to meet net-zero carbon emissions by 2050, the UK Sixth Carbon Budget (6CB), science-based carbon budgets from the Tyndall Centre, NPPF 148 which requires the planning system contribute to “radical reductions of greenhouse gas emissions”. I. Norfolk County Council has identified that the area north of the scheme has a nationally significant breeding barbastelle colony of bats, recently found, which although not yet afforded SSSI or SAC status would otherwise qualify as such (see: page 85 in NCC submission to PINS on the A47/A11 Thickthorn Junction, June 3rd, at [redacted]). The in-combination, and cumulative impacts, of the A47 dualling with the Norwich Western link road on this European protected species should be assessed under Part 3, Section 40 of the Natural Environment and Rural Communities Act 2006."