Object

Representation ID: 20595

Received: 10/03/2020

Respondent: Climate Friendly Policy and Planning (CFPP)

Policy 4: Transport
23 CONS, page 61, Policy 2, bullet 6. This is a very weak, bland statement and contains no
reference to modal shift and targets for modal shift.
We note that the Director of Place, Norwich City Council, has commented that Policy 4
is “insufficiently ambitious in supporting the transition to a low carbon future by
achieving significant modal shift” 6.
We would agree and suggest a modal shift hierarchy needs to be developed and made
central to Policy 4, Transport section. Road building, known to increase traffic, lock-in
car dependence, congestion and carbon emissions, should be the option of last resort.
Currently Policy 4 places various road building projects as options of high priority; these
should be removed as below.
24 CONS, page 76, Policy 4, bullet on A47 dualling, and other, projects being promoted by
Highways England. Following the February 27th 2020 judgement in the appeal court7,
the Airports National Policy Statement (ANPS) has been prevented from having any
legal effect "unless and until the Secretary of State has undertaken a review of it in
accordance with the relevant statutory provisions". This is because the Secretary of
State failed to consider the Paris Agreement (signed 22 April 2016) in the ANPS. This
is a landmark judgement that will have repercussions for any infrastructure projects that
increases emissions going forward in the Climate emergency.
We submit that the A47 dualling projects, on Highway's England own analysis increases
carbon emissions in construction and use. Highways England has also failed to consider
the Paris Agreement as the Paris Agreement is not mentioned in any of the scheme documents. We expect to see a legal challenge is being mounted against the National
Network National Policy Statement (NN NPS) which would cover proposals for
developments such as the A47 under the NSIP regime. We await the outcome of legal
challenges to the National Network NPS that will provide further clarity on this issue. In
the meantime, we do not believe that the plan can rely on including the A47 proposals
under “strategic infrastructure”, and the A47 proposals should be removed.
25 CONS, page 76, Policy 4, bullet on “delivery of the Norwich Western Link road”.
(A) The NWL on Norfolk County Council’s own analysis increases carbon emissions
in construction and use. The issue above (for A47) applies here too. The Paris
Agreement has not been considered in the NWL business case. Given the legal
uncertainty, we do not believe that the plan can rely on including the NWL
proposal under “strategic infrastructure”, and it should be removed.
(B)We also note that the HRA assessment of Policy 4 at HRA 8.2.2 considers the
impact of the NWL on the River Wensum SAC and recommends the additional
text underlined ‘Delivery of the Norwich Western Link Road provided that it can
be achieved without causing an adverse affect on the integrity of the River
Wensum SAC.’ The wording of Policy 4 does not include this recommendation
from the HRA.
(C) Given the recent, and emerging scientific evidence for impacts to the Weston
super-colony of rare and protected species of barbastelle bats, we recommend
that if the NWL remains in the plan (at (A) above we give reason for its complete
removal), then the additional text should be “…provided that it can be achieved
without causing an adverse affect on the integrity of the River Wensum SAC,
and to the Weston super-colony of rare and protected species of barbastelle bats.”