Norwich Western Link
By email attachment to firstname.lastname@example.org
18th January 2019
Response of CPRE Norfolk to the Norwich Western Link road consultation
CPRE Norfolk is highly concerned about the substantial harmful impacts to countryside, environment, wildlife and ecology which are likely to be caused by any of the proposed options for the Norwich Western Link road (NWL.) CPRE Norfolk opposed the construction of the Northern Distributor Road (NDR) for Norwich, on the basis that there were other less damaging options, and noted that the extension beyond the A140 was not justified, warning that it would lead to ‘rat-running’ in the Wensum valley.
It should also be noted that when planning permissions were being granted for the NDR, Norfolk County Council (NCC) did not promote any construction of the NWL “because of the environmental impact on the Wensum valley” (NCC website accessed on 03.01.18.) It is therefore with dismay that CPRE Norfolk observes that NCC has seemingly put these concerns to one side as the NWL has now perhaps unsurprisingly become part of its road infrastructure priorities, as they try to deal with the expected emerging issues. It should be noted that recent research (‘the end of the road? Challenging the road-building consensus’, CPRE, 2017) shows that building new roads only generates a long-term increase in traffic, leading to more congestion, along with other negative environmental impacts. Moreover, it is very disappointing to see the apparent re-allocation of priorities towards building the NWL rather than following the transport policies within the adopted Joint Core Strategy, in particular the commitment to significant improvement to the bus, cycling and walking network, including Bus Rapid Transit on key routes in the Norwich area (Policy 06: Access and transportation, JCS.) These six Bus Rapid Transit Corridors are shown on the Key Diagram of the JCS area. CPRE Norfolk feels strongly that this element of the JCS should be enacted before thought and spending is given to the construction of an un-planned NWL. It is hoped that this commitment to Bus Rapid Transit corridors and other forms of public transport, and walking and cycling routes are maintained in the new Greater Norwich Local Plan.
Whichever option for the NWL is chosen as the favoured route, serious environmental damage and loss of countryside will result. If this link road goes ahead, major remedial/mitigation measures are required both for the environment and directly-affected communities. It therefore makes sense for the route selected to be the one which causes least overall environmental and community damage. Unfortunately, the detailed evidence for such mitigation measures is not given within the consultation materials, although assurances are given that “we are committed to minimising any impact on the environment. We intend to hold ourselves to high standards on this – it’s what is expected of modern infrastructure projects but it’s also the right thing to do. We have been liaising with Natural England and the Environment Agency about the possibility of creating a Norwich Western Link for some time and what potential mitigation would be needed. We will also seek opportunities to enhance the local environment, so that we can make a positive impact where possible” (NWL website, ‘your questions answered’.) However, the information provided in the consultation materials makes it difficult to evaluate potential harm to landscape, environment, wildlife and ecology. For example, the artist’s impression of a viaduct along with less than detailed comments about “higher bridge crossings” make it impossible to be clear about what is proposed for the various options, and therefore difficult to form precise opinions. What CPRE Norfolk has gleaned from the consultation process and materials is that more detail needs to be provided on what is going to be done to protect vital habitats, create new habitat areas and make mitigation measures on existing ones. We are concerned about the apparent proposals for a viaduct supported by many pillars rather than having a longer span bridge (although the latter could present more negative visual impacts), as the pillars are likely to cause harm by the diversion of subterranean flow patterns, which are relevant across the river valleys, not just within the relatively narrow SSSI designated landscape of the Wensum. The run-off from the new roads and viaduct, and/or from increased traffic on the existing A1067 and river crossing at Attlebridge is a major concern, along with the effects on existing habitats of the large roadside lagoons which would be installed to cope with this.
Visual, light and noise impacts would also be substantial and harmful. The current tranquillity of this area of landscape would be lost through the new roads and associated structures, as well as through the increase in traffic. Any tree-screening would be poor mitigation, as this would contribute further to the loss of the current open character of the Wensum valley in particular. At night, even if the road is not lit, the current dark sky would be lost due to car headlights.
CPRE Norfolk is concerned that if a new NWL is constructed it will come to be seen as the outer limit for the development of Norwich and its suburbs in the long term, and is therefore disappointed to see options closer to Norwich have not been included for public consideration within the consultation. The justification for this is noted: that recent development and housing growth closer to Norwich means that a new road would impact on “many more homes and businesses”. It is hoped that this reason will be used not to allow new houses and businesses to be permitted to be developed out towards any new NWL.
In its research on road building entitled ‘the End of the Road? Challenging the Road-building Consensus’ mentioned above, CPRE’s National Office commissioned research by Transport for Quality of Life (TfQL). This report reinforced the long-held view that road building simply generates more traffic, leads to permanent and significant environmental damage, and shows little evidence of economic benefits to local economies. CPRE Norfolk strongly endorses these findings and believes that other transport solutions should be considered which could achieve more beneficial long-term outcomes for the locality and the county. The serious concerns which have been raised above should, we feel, have been resolved before asking for responses through a consultation process, and as a result CPRE Norfolk is currently unable to support any of the suggested options for a NWL.
Submitted on behalf of CPRE Norfolk by
Planning Campaigns Consultant, CPRE Norfolk