Object
Publication
Representation ID: 23877
Received: 22/03/2021
Respondent: Norfolk Wildlife Trust
Legally compliant? No
Sound? No
Duty to co-operate? Yes
We have significant concerns regarding the impacts of the Western Link road proposal on wildlife. Recent independent surveys have also identified a previously unknown ‘super-colony’ of barbastelle bats directly on the proposed route which is likely to be the country’s largest breeding colony. Given the significance of this colony and the strict legal protection afforded to bats and their roost sites under the Wildlife & Countryside Act and the Habitats Regulations, we do not believe that the NWL is deliverable. Therefore, if there are elements of the GNLP that are dependent on the NWL, these will also be undeliverable.
The plan makes reference to the NWL as key infrastructure but it is not clear which allocations or other plan objectives are reliant on delivery of the NWL. We seek clarification from the GNLP team which housing and employment allocations (if any) are dependent on the delivery of the NWL to meet their own delivery. If any allocations are dependent on delivery of the NWL then we recommend they are reviewed to evaluate if their delivery would be compromised by the NWL failing to the delivered.
The inclusion of reference to the Norwich Western Link in the plan text indicates that the growth promoted through allocations is in part dependent on the delivery of the NWL within the plan period.
We have significant concerns regarding the impacts of the Western Link road proposal on wildlife, including the loss of multiple County Wildlife Sites, and impacts to the River Wensum SAC. However, recent independent surveys has also identified a previously unknown ‘super-colony’ of barbastelle bats directly on the proposed route which is likely to be the country’s largest breeding colony. A recent position statement issued by the Bat Conservation Trust summarises the key concerns regarding this proposal - https://www.bats.org.uk/our-work/biodiversity-policy-advocacy/position-statements-1/bcts-position-statement-on-the-proposed-norwich-distributor-road-western-link
Given the significance of the size of the colony and the strict legal protection afforded to bats and their roost sites under the Wildlife & Countryside Act and the Habitats Regulations, we do not believe that the NWL is deliverable. Therefore, if there are elements of the GNLP that are dependent on the NWL, these will also be undeliverable.