The Norfolk County Council (Norwich Northern Distributor Road (A1067 to A47(T))) Order

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Applicant’s comment on Relevant Representations Volume 1 - Introduction

Planning Act 2008

Infrastructure Planning

The Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009

PINS Reference Number: TR010015

Document Reference: NCC/EX/4

Author: Norfolk County Council

Version Date Status of Version 0 11th July 2014 Final

Norwich Northern Distributor Road Document Reference: NCC/EX/4

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Norwich Northern Distributor Road Document Reference: NCC/EX/4

1. Introduction

1.1. This document contains Norfolk County Council’s (NCC’s) comment on a number of Relevant Representations (RRs) received.

1.2. The RRs raised many issues, but analysis of them indicated that there were 9 key topics which were repeated in many of them. Comment have been prepare on these 9 topics, and are presented in this document. This approach has been taken in an attempt to minimise repetition while providing a reasonable overview of the issues raised. The topics are as follows, listed in approximate order of the number of representations which raised them:-

. Environment

. Traffic

. Cost

. Associated Development

. Link to A47

. Alternatives

. Need

. Consultation and Planning

. Economic Benefits

1.3. In addition to the above, NCC have also provided comment on selected RRs as follows:

. All from Districts & Parish Councils & Meetings - Councillors - Political groups

. All from Statutory Organisations

. All from Landowners (and Agents on their behalf)

. All from Non-Statutory Organisations & selected other interested parties

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1.4. NCC appreciates that the selection of RRs on which comments are provided will result in not providing a comment on every individual issue raised in RRs. However, the intention has been to provide comment in this document on the key issues raised. Comment on other issues will be made during the examination process.

1.5. As parties who have submitted RR’s may subsequently submit Written Representations (WR’s) NCC will provide additional comment on these if the issues raised have not been covered in this document. However, as it is not currently known which parties will submit WR’s, NCC has compiled these comment on the selected RR’s.

1.6. This document is presented in 6 Volumes as follows:-

Volume 1 – this introduction, and lists of contents for Volumes 2 to 6

Volume 2 – comment on RR’s grouped in 9 key topics

Volume 3 – comment on RR’s from Districts & Parish Councils & Meetings - Councillors - Political groups

Volume 4 – comment on RR’s from Statutory Organisations

Volume 5 – comment on RR’s from Landowners (and Agents on their behalf)

Volume 6 – comment on RR’s from Non-Statutory Organisations and selected RR’s from Other Interested Parties

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Volume 2. 9 Key Topics

Ref Topic / Summary RR Page

2.1 Environment Various 5

2.2 Traffic Various 7

2.3 Cost Various 7

2.4 Development Associated with the NDR Various 9

2.5 Link to A47 Various 10

2.6 Alternatives Various 13

2.7 Need Various 15

2.8 Consultation and Planning Various 18

2.9 Economic Benefits Various 22

Volume 3. Districts & Parish Councils & Meetings - Councillors - Political groups

Ref Name RR Page

Alfred N Townly on behalf of G & L Plumstead Parish 3.1 20 5 Council

Swannington with Alderford and Little Witchingham 3.2 77 11 Parish Council

3.3 Attlebridge Parish Meeting 467 13

3.4 Cllr Lesley Grahame 519 15

3.5 Weston Longville Parish Council 535 17

3.6 Felthorpe Parish Council 536 22

3.7 Spixworth Parish Council 600 23

3.8 Eastern Region Green Party 617 24

3.9 Norwich Green Party 645 25

3.10 Cllr Boswell 646 34

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3.11 Great Yarmouth Borough Council 658 38

3.12 Hockering Parish Council 747 38

3.13 North Norfolk District Council 755 40

3.14 Salhouse Parish Council 844 40

3.15 Cromer Town Council 916 45

3.16 Colney Parish Meeting 932 46

3.17 Wroxham Parish Council 983 50

3.18 Morton on the Hill Parish Council 1133 52

Volume 4. Statutory Organisations

Ref Name RR Page

4.1 Norwich Airport Limited 700 5

4.2 Network Rail Infrastructure Ltd 777 5

4.3 National Grid Plc 779 8

4.4 English Heritage 849 8

4.5 Environment Agency 858 8

4.6 Public Health England 862 9

4.7 Natural England 894 9

Volume 5. Landowners

Ref Name RR Page

5.1 Glen Taylor 26 6

5.2 L E Thomson on behalf of Mr & Mrs Arnold 38 6

5.3 L E Thomson on behalf of Blanmar 1 39 7

5.4 L E Thomson on behalf of Blanmar 2 41 8

5.5 Charles Birch on behalf of C Bunn 89 8 6

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5.6 Charles Birch on behalf of Mr & Mrs G Black 294 9

Charles Birch on behalf of Trustees of Gurloque 5.7 295 10 Settlement

Charles Birch on behalf of Mrs S Bransom on behalf 5.8 296 10 of Mrs Barrett

Charles Birch on behalf of The Trustees of the 5.9 297 11 Thorpe and Felthorpe Trust

5.10 Charles Birch on behalf of Mrs S Bransom 298 11

5.11 Charles Birch on behalf of Mr Bransom 303 12

5.12 Charles Birch on behalf of Rachel Foley 305 12

5.13 Charles Birch on behalf of Nicholas Waller-Barrett 306 13

5.14 Charles Birch on behalf of Mr M & Miss J Keeler 307 14

Charles Birch on behalf of Mr & Mrs L Howe and Mr 5.15 308 14 N Howe

Charles Birch on behalf of Mr A Medler c/o Mrs S 5.16 309 15 Alston

Charles Birch on behalf of Mr M A Dewing on behalf 5.17 310 16 of the E M and E J Dewing Settlement

Charles Birch on behalf of Hilary Barratt and Mr 5.18 Michael Dewing on behalf of the Trustees of the 312 16 Beeston Estate

5.19 Charles Birch on behalf of June Brooks 313 17

Charles Birch on behalf of Mr A J Papworth on behalf 5.20 314 18 of Mr M F Trafford

5.21 Charles Birch on behalf of Mr Karl Basey 315 18

5.22 Mr Duncan 316 19

5.23 Charles Birch on behalf of P Basey 317 19

5.24 Clive Scott 442 20

5.25 Jim Papworth on behalf of Michael Trafford 472 20

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5.26 Lawson Howe 584 22

5.27 Drayton Farms Ltd 648 23

5.28 Jason Cantrill on behalf of David and Sally Jacobs 652 24

5.29 Ifield Estates 725 24

5.30 Tracey Burton 781 25

5.31 Mr T Shaw 792 25

5.32 Sidney Cowell on behalf of Scrone Ltd 802 26

5.33 Tim Place – M.D Frontbench Ltd 809 26

5.34 Roly Beazley on behalf of RG Carter Will Trust 817 27

Christopher Fairlie Bond on behalf of The Howe 5.35 850 27 Family

5.36 Mrs V A Smith (t/a S J Smith) 852 27

Charles Birch on behalf of R E T Gurney and S E 5.37 856 28 Gurney & Partners

5.38 David Hooper on behalf of Russell Nicholls 859 29

5.39 Rachel Foley on behalf of Horsford Estate 883 29

5.40 Alan Irvine on behalf of W R & P J Tann 951 30

5.41 Alan Irvine on behalf of P Key Esq 957 31

5.42 Alan Irvine on behalf of Mr & Mrs D Jacobs 959 32

5.43 Alan Irvine on behalf of J Blake Esq 960 32

5.44 R & J M Place Ltd / Frontbench Ltd 1161 33

5.45 Nigel Handley R G Carter Farms Ltd 1165 33

5.46 Michael Dewing 1197 34

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Volume 6. Non-Statutory Organisations & Other Interested Parties

Ref Name RR Page

6.1 Victor Brown 8 5

6.2 The Open Spaces Society 14 6

Anthony Clarke on behalf of Cyclists’ Touring Club 6.3 129 14 (CTC)

6.4 Katy Jones on behalf of Ian Shepherd CPRE 189 20

Peter Wilkinson on behalf of Lothbury Investment 6.5 249 33 Management Ltd

6.6 Building Partnerships Ltd 275 35

6.7 Norfolk Dinosaur Park Ltd 347 36

6.8 Go West Travel t/a Norfolk green 374 37

6.9 Mr Gray on behalf of Drayton Local Community 502 38

6.10 Norfolk Wildlife Trust 533 40

6.11 Patrick Barkham 689 43

6.12 Stop Norwich Urbanisation (SNUB) 691 46

6.13 Campaign for Better Transport 763 55

6.14 Drayton Hall Park Residents 778 68

Campaign for the Protection of Rural England 6.15 836 70 (CPRE)

6.16 Broads Society 864 73

6.17 Visit Norwich Ltd 887 73

Michael Innes on behalf of Norfolk Association of 6.18 895 74 Architects

Eric Kirk on behalf of Wensum Valley Hotel and Golf 6.19 990 75 Club

6.20 Norfolk Living Streets 995 77

6.21 John Elbro on behalf of Norwich Cycling Campaign 1004 80 9

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6.22 Campaign for Better Transport - East Sussex 1060 80

6.23 Gordon A Denton 1065 81

Norwich and Norfolk Transport Action Group 6.24 1084 82 (NNTAG)

Appendices

Appendix A Review into missing submissions to NDR consultation process

Appendix B Planning Inspectorate Report Postwick Junction Oct 2013

Appendix C NCC Cabinet Report 19 Sept 2005

Appendix D NCC Cabinet Report 4 Nov 2013

Appendix E Planning Inspectorate Report JCS Nov 2013

Addendum to the NDR Environmental Statement Lighting Appendix F Assessment (July 2014)

Norwich Northern Distributor Road Document Reference: NCC/EX/4

The Norfolk County Council (Norwich Northern Distributor Road (A1067 to A47(T))) Order

Applicant’s comment on Relevant Representations Volume 2 - Key Topics

Planning Act 2008

Infrastructure Planning

The Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009

PINS Reference Number: TR010015

Document Reference: NCC/EX/4

Author: Norfolk County Council

Version Date Status of Version 0 11th July 2014 Final

Norwich Northern Distributor Road Document Reference: NCC/EX/4

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Norwich Northern Distributor Road Document Reference: NCC/EX/4

Contents

Ref Topic / Summary RR Page

2.1 Environment Various 5

2.2 Traffic Various 7

2.3 Cost Various 7

2.4 Development Associated with the NDR Various 9

2.5 Link to A47 Various 10

2.6 Alternatives Various 13

2.7 Need Various 15

2.8 Consultation and Planning Various 18

2.9 Economic Benefits Various 22

Brief Introduction (for a full introduction see Volume 1)

Norfolk County Council (NCC) has provided comment on selected Relevant Representations (RRs) as follows:-

. Comment on 9 key topics repeated in many RRS (this approach has been taken in an attempt to minimise repetition while providing a reasonable overview of the issues raised) . Comment on all RRs from Districts and Parish Councils & Meetings - Councillors - Political groups . Comment on all RRs from Statutory Organisations . Comment on all RRs from Landowners (and Agents on their behalf) . Comment on all RRs from Non-Statutory Organisations and selected RRs from other interested parties

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The comments are provided in 6 volumes as follows:-

Volume 1 - Introduction, and lists of contents for Volumes 2 to 6 Volume 2 - Comment on RRs grouped in 9 key topics Volume 3 - Comment on RRs from Districts & Parish Councils & Meetings - Councillors - Political groups Volume 4 - Comment on RRs from Statutory Organisations Volume 5 - Comment on RR’s from Landowners (and Agents on their behalf) Volume 6 - Comment on RRs from Non-Statutory Organisations and selected RRs from other interested parties

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Applicant’s comment on Relevant Representations

2.1. Environment

2.1.1. The NDR would cause extensive environmental damage including large destruction of countryside, farmland and wildlife habitats; indirect effects on nationally designated landscapes; an increase in noise, air and light pollution; an increase in carbon emissions; severance of country lanes used for walking and cycling.

Applicant’s comment

2.1.2. The effects on Landscape, Air Quality, Noise, Water and Drainage, Ecology, Agricultural Land, Carbon and the Community are presented within the Environmental Statement (ES) (Document Ref. 6.1). The ES presents the findings of the Environmental Impact Assessment (EIA) and details the effects of the Scheme, both adverse and beneficial.

2.1.3. An overall view of the results of the EIA is presented in the Non- Technical Summary (Document 6.3) Section 16 provides a Summary of Effects. The detailed analyses and assessments are presented within Volume 1 of the ES (Document 6.1) the technical reports that support these assessments can be found in Volume 2 of the ES (Document 6.2).

2.1.4. The proposed Scheme incorporates measures to prevent, reduce and where possible offset environmental impacts from the earliest stage of the project. Specific details of the proposed mitigation measures are included in the individual topic sections of the ES. The proposed measures were designed according to statutory and non-statutory guidance and the Design Manual for Roads and Bridges (DMRB) to provide proposals that are proportionate to the significance of the relevant effect. Such mitigation measures are set out in the requirements in the draft Development Consent Order (DCO) and NCC is committed to delivering them as an integral part of the proposed Scheme.

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2.1.5. In addition the Habitats Regulations Assessment (HRA) has considered any potential effects on protected sites and species. This has been undertaken in consultation with Natural England (NE) and the Environment Agency (EA) who have the responsibility for the protection of the Wensum Special Area of Conservation (SAC). This can be found in Volume 11: Chapter 17 of the ES (Document Ref 6.2). After consultation NE and the EA required clarification and further details on the mitigation required to prevent silt entering the Wensum via the existing road network at the western extent of the Scheme. An addendum is still in draft form and is being reviewed by NE and the EA and this will be made public as soon as the Statutory Bodies have finished the review of the data submitted. It is anticipated this document will be finalised by mid July 2014.

2.1.6. The impact of light pollution is discussed in Volume 1: Chapter 7 of the ES (Document Ref 6.2). The only part of the scheme to include street lighting is Postwick junction. Paragraph 7.7.62 says ‘Night time effects arising from vehicle headlights and the lighting of the Postwick junction are regarded as ‘slight adverse’ for both year 1 and year 15, since the additional lighting will be seen within the context of an already lit and well trafficked junction.’ In further reviewing the DCO application material in considering its response to Relevant Representations, NCC has identified that the Scheme did not include all the street lighting required at Postwick, and in particular on 200 metres of the NDR approach to the Business Park Roundabout. In order to ensure this can be considered by the Examining Authority and interested parties, NCC has therefore produced an Addendum to the NDR Environmental Statement Lighting Assessment (July 2014), see Appendix F. This concludes that there are no significant adverse effects arising from the additional lighting, and no change to the conclusions of the Environmental Statement (Vol 1, Doc. Ref. 6.1).

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2.2. Traffic

2.2.1. NDR would make traffic problems worse, particularly on radial roads leading to the new road.

Applicant’s comment

2.2.2. The traffic flows forecast with the Northern Distributor Road (NDR) are compared to those without the Scheme in the Traffic Forecasting Report (Document Ref. 5.6) in Volume 3 Figures I.1 to I.4. These show that there are increases on some radial routes in the vicinity of where they connect with the NDR. However the Transport Assessment (Document Ref. 5.5) shows in section 8.5 that the NDR junctions are considered to operate acceptably well.

2.2.3. Furthermore the Traffic Forecasting Report in Vol 1 Section 7 describes the reductions in traffic in other parts of the network with NDR. In particular traffic would be reduced in the suburban area, including on radial routes and on inappropriate routes that are currently used by orbital traffic movements.

2.3. Cost

2.3.1. Do not believe the proposals represent good value for money and object to NCC spending £60 million and possibly more on the road.

Applicant’s comment

2.3.2. Sections 5.4 and 5.5 of the Economic Appraisal Report (Document Ref 5.7) provides a detailed economic analysis of the transport benefits and the value for money (VfM) using the Department for Transports (DfT’s) criteria.

2.3.3. The scheme delivers a Benefit to Cost Ratio (BCR) of 4.17 inclusive of accident benefits and a BCR of 5.33 when wider economic benefits and journey time reliability are included. Both of these figures represent ‘very 7

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high’ value for money (i.e. for BCR’s above 4) according to DfT’s VfM criteria.

2.3.4. In addition to the transport benefits the Scheme would bring substantial land use and economic development benefits that are set out in The Land Use and Economic Development Report (Document Ref. 10.3.) These benefits include:

. 4,358 net additional direct jobs arising from the development sites listed in the;

. When multiplier effects are included the figure (of 4,358) rises to 5,230 net additional jobs that would not otherwise arise in Greater Norwich;

. £1.099bn of additional Gross Value Added (GVA) is forecast to be generated by those 5,230 jobs over some 30 years;

. £966m of net additional physical investment in roads, infrastructure and housing; and

. An average of 426 construction jobs (rising to 511 when multiplier effects are included) in each of the years until development is complete (estimated at 2034).

2.3.5. Reflecting the very high VFM and value to the local economy funding for the NDR project has been agreed by NCC’s Cabinet Nov 2013. This includes details of the funding sources and the value underwritten by the County Council, which is supported by an in principle agreement that up to £40m Community Infrastructure Levy (CIL) income can be used towards the project.

2.3.6. This reflects the importance of the NDR as essential highway infrastructure supporting growth in employment and housing as set out in the adopted Joint Core Strategy (JCS), as well as providing much needed benefits in transport terms by resolving existing traffic problems

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and providing direct access from the strategic road network to Norwich International Airport.

2.4. Development Associated with the NDR

2.4.1. The NDR will facilitate new large scale development across countryside to the north east of Norwich

Applicant’s comment

2.4.2. The level of housing and employment provision in the JCS is required to meet the objectively assessed need to support economic, household and population growth. This has been determined by the local plan process which is the appropriate mechanism. The JCS legitimately and appropriately take account of the plans of the transport authority and the highway authority (i.e. NCC) including the proposals for NATS and the NDR. The JCS proposals for growth to the north east of Norwich were subject to examination as recently as 2013 and found sound.

2.4.3. In view of the importance of the NDR within NATS, the local authorities and the Planning Inspectors, who found the JCS sound, have taken the view that if there is no NDR, the JCS would have to be reviewed to determine a different growth strategy for the Norwich area. However, it is not appropriate to use the DCO examination of the NDR as an opportunity to re-run arguments about whether the JCS planned growth in housing and employment is the appropriate spatial strategy for Greater Norwich. That was a matter that was fully investigated, tested, and settled by the JCS process which had the responsibility of setting the spatial strategy for Greater Norwich.

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2.5. Link to A47

2.5.1. The three quarters NDR would terminate at A1067 Reepham Road and dump traffic on communities at Taverham and Drayton, leading to rat running.

Applicant’s comment

2.5.2. Vol 1 Section 7 Paragraph 7.1.8 to 7.1.14 of the Traffic Forecasting Report (Document Ref. 5.6) analyses the traffic impacts at the western end of the NDR in the vicinity of Taverham and Drayton and especially the impact on traffic crossing the Wensum Valley.

2.5.3. This shows that the NDR leads to a decrease in daily traffic on the routes that connect the A1067 with the A47(T) to the west of Norwich of 6% in 2017 and 4% in 2032 as shown in Table 7.1, although there is an increase in traffic on the western part of the corridor (between Lenwade / Weston Longville and Hockering) which has, separately to the NDR project, already received highway and traffic management improvements.

2.5.4. In Figure I.3 in Vol3 of the Traffic Forecasting Report site A54 shows there would be a forecast reduction with the NDR on the A1067 Fakenham Road.

2.5.5. These model outputs do not support the assertion that the Scheme would ‘dump’ traffic on communities in Taverham and Drayton. It is shown that these communities see a significant reduction in traffic using the existing A1067.

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2.5.6. A three quarters NDR would lead to pressure for a link from A1067 – A47 Norwich Southern Bypass across the River Wensum, a Special Area of Conservation (European Importance) and River Tud, which if built would cause huge environmental damage.

Applicant’s comment

2.5.7. It is considered that the NDR Scheme is unlikely to result in significant adverse environmental impacts on the Wensum SAC. This is detailed within the HRA and in the subsequent Addendum. This has been undertaken in consultation with NE and the EA who have the responsibility for the protection of the Wensum SAC. This can be found in Volume 11: Chapter 17. ES (Document Ref 6.2) HRA, the addendum is still in draft form and is being reviewed by NE this will be made public as soon as NE has finished the review of the data submitted.

2.5.8. At its meeting of 7 October 2013 the applicant’s Cabinet resolved that a “scoping report on the feasibility of providing a link across the Wensum Valley from the A1067 – A47 be written once consultation work was completed” This work is in its early stages of development. Any future scheme would in due course be subject to Environmental Impact Assessment (EIA) and Habitats regulations Assessment (HRA). The NDR is in no way dependent on a link from the A1067 to the A47(w) and can be assessed (and has been assessed) as a stand-alone scheme on its own merits. Any proposals for a link to the A47(w) would be a matter for separate assessment on their own merits if and when any such proposals were put forward. Refer also to section 2.5.10 below which set out more details.

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2.5.9. No provision is made to connect the road directly to the southern bypass which is considered essential.

Applicant’s comment

2.5.10. A road linking the A1067 and the A47(w) would have to cross the Wensum Valley, which is designated a SAC under the European Directive on the Conservation of Natural Habitats and of Wild Fauna and Flora - often referred to as the Habitats Directive. An assessment of options across the Wensum Valley concluded, in 2005, that significant impacts on the SAC would be likely, and there was doubt as to whether, under the terms of the Habitats Directive, it would be possible to design an acceptable scheme. This in turn raised the prospect that consent for a wider scheme including such a link might not be granted. On 19 September 2005, the applicant’s Cabinet resolved to have no NDR link between the A47(w) and the A1067. It therefore did not form part of the adopted route. At its meeting of 16 September 2013 the meeting of the Norfolk County Council resolved to recommend to Cabinet that they submit an application for a DCO in respect of the NDR as proposed (i.e. between the A47 at Postwick and the A1067 near Attlebridge) and to also commission a report on a feasibility study of providing a link across the Wensum Valley from the A1067 to the A47(w).

2.5.11. Whilst at its meeting of 7 October 2013 the applicant’s Cabinet resolved that a “scoping report on the feasibility of providing a link across the Wensum Valley from the A1067 – A47 be written once consultation work was completed”, this study has not been carried out and there is therefore currently no proposal establishing the form any link between the A1067 and A47(w) would take, or indeed whether any such link is feasible. The Transport Assessment for the NDR (Document Ref 5.5.) shows that the NDR can provide substantial benefits without a further link between the A1067 and A47(w) and that the NDR will reduce daily traffic on existing routes between the A1067 and the A47(w) between

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Drayton/Taverham and Costessey. The NDR is therefore in no way dependent on the provision of such a link. The feasibility and environmental acceptability of a link to the A47(w) have not been established and the previous assessment in 2005 discarded this option. Accordingly, it is the position of the applicant that the NDR can and should be considered on its own merits without such a link.

2.6. Alternatives

2.6.1. An alternative transport package has not been tested. It includes a series of inner orbital link roads between Postwick and Hurricane Way at Norwich Airport which developers have offered to fund. An inner link would serve growth in NE Norwich and release capacity on the Outer Ring Road. Traffic calming in north Norwich would reduce rat running.

Applicant’s comment

2.6.2. Chapter 3 of Volume 1 of the ES (Document Ref 6.1) explains the consideration given to potential alternatives. Section 3.15 discusses Alternative 5 which comprises developer link roads between radials (within the growth areas).

2.6.3. Further analysis using the DCO transport model for alternatives is provided in The Traffic and Economic Appraisal of NDR Alternatives (Document Ref 5.12). Section 8 of the report provides an analysis for Alternative 5 and conclusions are summarised in Section 9.

2.6.4. Alternative 5 (developer link roads) singularly fails to reduce traffic on inappropriate routes and relieve the existing network. Whilst the Alternative includes the city centre traffic management measures the reductions of cross city centre traffic are much smaller compared with the DCO Scheme, especially for trips crossing the Outer Ring Road Cordon. The junction analyses show that North Walsham Road and Wroxham

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Road junctions would operate substantially over their theoretical capacity with long queues and delays, with delays of over 10 minutes at North Walsham Road Junction in the 2032 AM peak, and 5 minutes in the 2032 PM peak. On these grounds the developer link roads would not operate satisfactorily and they would cause particularly severe difficulties in implementing the proposed shared use high street-type design envisaged in the development proposals.

2.6.5. For the Beyond Green planning permission for North Sprowston, Old Catton the development is proposed to provide an internal east west street which will ultimately span four radial routes from St Faiths Road to Wroxham Road. All the roads within this development, including the east west route, will have a 20mph speed limit to make it easier for pedestrians to cross streets at any point. Speeds will be kept low through design rather than enforcement, using features such as short lengths of street between junctions, narrow carriageways, on street parking, limiting forward visibility and the use of shared space on some tertiary streets.

2.6.6. The Norwich Area Transportation Strategy sets out to reduce rat running in north Norwich. This is explained in 3.5.4 (policies 5 and 6) of the ES (Document Ref 6.1) and it would not be possible to achieve this without an alternative to serve these movements given the constraints in the network which are explained in section 3.4.

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2.7. Need

2.7.1. The NDR is not necessary for implementing NATS, as underlined by sustainable transport schemes progressed to date and by the fall in traffic since 2006.

Applicant’s comment

2.7.2. The overall transportation strategy for the Norwich area, NATS, is a package of transport improvements, interventions and measures. Together these will deliver a reliable, efficient and long-term sustainable transport network which will improve accessibility and connectivity and which will support the continued economic and physical growth of the Norwich area.

2.7.3. The NDR is an integral part of NATS and required to address existing problems and issues which include an Outer Ring Road operating at near capacity or overcapacity around the northern part of the city.

2.7.4. Whilst some bus related improvements have been progressed through the NATS, improvements to the public transport corridors to the north and east of the City have been constrained by the amount of traffic and related congestion on key radial routes and the ring road routes. With the reduction in traffic flows and congestion on these routes forecast to result from the NDR, further improvements in these areas can be made and benefits realised.

2.7.5. Traffic levels have fallen in the central area of Norwich since 2006 largely attributable to measures that have been implemented in the city centre, which form part of NATS. However, the issue of rat running in the northern suburbs has not diminished over that period.

2.7.6. Chapter 3, the Needs and Alternatives section of the ES (Document Ref. 6.1) describes the work carried out in devising NATS. This work determined that the preferred option for NATS included an NDR.

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2.7.7. The report on Traffic and Economic Appraisal of NDR Alternatives (Document 5.12) includes in Section 10.2 Appendix B the results of appraisal of an option comprising significant improvements to public transport provision. This option could be considered as a proxy for NATS without an NDR. The results indicate that such an option would not meet the Scheme objectives or deliver good value for money.

2.7.8. The Traffic Forecasting Report (Document 5.6, see Section 1.1.7) sets out the substantial reductions in traffic on existing orbital routes as a result of the reassignment of strategic traffic to the NDR. There would also be substantial reductions on the proposed developer link roads which would not be appropriate routes for carrying strategic traffic. Traffic levels would be reduced on routes in the Thorpe St Andrew, Old Catton and Hellesdon suburbs, including on the Outer Ring Road. Traffic flows in the city centre would also be reduced substantially as a result of the city centre measures that could be implemented with the introduction of the NDR, though there is some displacement to the Inner Ring Road. The traffic reductions will facilitate the implementation of NATS.

2.7.9. No proven local or national need for the scheme. Contrary to National and Local Planning Policy.

Applicant’s comment

2.7.10. Within a number of the relevant representations received, general comment have been made that the NDR scheme is not needed, although specific concerns have generally not been identified.

2.7.11. Chapter 3 of Volume 1 of the NDR ES (Document Ref 6.1) sets out (in sub sections 3.2 to 3.6) the need for the NDR.

2.7.12. In summary, the ES explains that the NDR is needed to improve connectivity and accessibility across both the northern part of the Norwich urban area and areas of the county in an arc from the north west

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to the east of the main urban area. It further demonstrates that such improvement will ease the relative disadvantage of the peripheral location of these areas and provide the basis of the transport infrastructure required to both address existing and future problems and achieve the growth objectives which have been identified for Norwich and its surrounding area.

2.7.13. The need information provided also explains that the specific objectives for the NDR are to:

. Reduce traffic levels and congestion on the existing road network both within the urban area and beyond to the north;

. Facilitate journeys that are currently difficult and require traffic to use roads that are unsuitable for the type and volume of traffic that is currently accommodated;

. Provide access to and help to deliver planned and potential areas of growth, and enable those areas to be free of the need to incorporate provision for extraneous traffic;

. Provide improved transport connectivity, including with the national strategic road network, for existing and future areas of residential and employment development, Norwich International Airport and the wider area of North and North East Norfolk;

. Increase the opportunities for improving provision for public transport and other sustainable forms of transport and for improving traffic management within the city centre, thereby encouraging modal shift,

. Improve traffic related environmental conditions for residents in the northern suburbs of Norwich and outlying villages, whilst minimising the adverse environmental impacts of the NDR.

2.7.14. The key local planning policy relevant to the NDR is contained within the JCS for the Greater Norwich area. This recently adopted development

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plan document – found to be sound and therefore consistent with National policy following independent examinations – makes clear that the NDR scheme is infrastructure which is fundamental to the achievement of the strategy set out in the JCS (see Volume 2.11.2 to 2.11.9 of Volume 1 of the ES (Document Ref 6.1). As paragraphs 3.3.35 to 3.3.46 of Volume 1 of the ES (Document Ref 6.1) explains, the objectives identified in the JCS at the local level benefit from support at the national level.

2.8. Consultation and Planning

2.8.1. Making the NDR ‘nationally significant’ would attract more long distance and local traffic, with adverse effects on local communities.

Applicant’s comment

2.8.2. The Secretary of State has directed that the NDR, together with any matters associated with it, is to be treated as development for which development consent is required. This Direction means that the Scheme is being progressed under the Planning Act 2008. See Section 1 Paragraph 1.1.3 of the Introduction to the Application (Document Ref. 1.1)

2.8.3. However, the Direction does not alter the data or methodology used for traffic forecasts for the Scheme. Therefore traffic forecasts either without or with the Direction would be identical and the Direction with regards to how it is dealt with in the planning approval process will not result in the NDR attracting more long distance traffic.

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2.8.4. Public consultation in summer 2013 showed that 80% of respondents who expressed an opinion were opposed to the County Council’s NDR scheme.

Applicant’s comment

2.8.5. The volume of respondents objecting to scheme is considered small when compared to the overall number of people consulted. It is approximately 2% of the 57,000 residential and business addresses sent consultation letters. The proportion of respondents opposed to the scheme is considered a reflection of the area of consultation. i.e. that the consultation focused on the areas most directly affected rather than areas further afield, which are likely to benefit from the NDR and future NATS measures that depend on the NDR. NCC’s own analysis of the Section 47 and 48 consultation responses is contain in Chapter 5 of the Pre-application Consultation Report (Document Ref 5.1), with the key issues identified highlighted in Section 5.4

2.8.6. At the only previous consultation in 2003, the public were consulted on a full NDR and not the current scheme. Last summer’s pre- application consultation was legally flawed, as the legal status of the road (as an NSIP) changed and additional rationales for the road were added mid-consultation. The promoters “lost” three key consultation responses from objector groups: a matter that is now being investigated at a high-level within Norfolk County Council.

Applicant’s comment

2.8.7. Section 2.7.4 to 2.7.8 of the Pre-application Consultation Report (Document Ref 5.1) outlines NCC’s reasoning for its view that the NDR is a development for which development consent is required. This includes a chronology of events prior to the application for a DCO being made, which states that in December 2012, the applicant decided to promote 19

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the NDR as a Nationally Significant Infrastructure Project (NSIP). At that time the NDR fell within the definition of a NSIP set out in Section 22(2) of the Planning Act 2008 (as it then was) because it included works to the Postwick junction of the A47(T) and was to be constructed for a purpose connected with the A47(T).

2.8.8. Publication of the notice stating where and when the SOCC could be inspected took place on 21 June 2013 and on 28 June 2013, with the first publication exhibition held on 8 July 2013. The Section 48 Notices were published on 12 July 2013 and 19 July 2013. The programme of public exhibitions ran until 12 August 2013. Section 42 consultation letters were issued on 30 July 2013 and representations under all three strands of consultation were invited until 20 September 2013. Further information on the consultation is set out in the rest of the Consultation Report.

2.8.9. On 24 July 2013 the Highway and Railway (Nationally Significant Infrastructure Project) Order 2013 (S.I. 2013/1883) (the Highways Order) was made and the Order came into force on 25 July 2013. This was some weeks after the start of the statutory consultation process referred to above. The Order amended Section 22 of the Planning Act 2008 so that a project such as the NDR would not (from 25 July 2013 onwards) fall within the definition of a NSIP. The Secretary of State made the Direction on 9 August 2013. The effect of the Direction on the validity of the pre-application consultation is set out at sections 2.7.1 to 2.7.3 and 2.7.10 to 2.7.17 of Document Ref 5.1.

2.8.10. On 25 July 2013, the applicant submitted a qualifying request to the Secretary of State for a direction under Section 35(1) of the Planning Act 2008 that the NDR was a project of national significance and so should be treated as development for which development consent was required.

2.8.11. NCC received over 1400 responses to its consultations under Section 47 of the Planning Act, which commented on a wide range of issues associated with the NDR proposals. NCC is aware that three submissions made by Norwich Green Party, CPRE and SNUB were on 20

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the balance of probabilities received but unfortunately were not logged. In respect of these submissions, the Planning Inspectorate has concluded that the points raised in them had been raised by other consultees and therefore are covered in the Consultation Report. A legal point raised about the changes to the legislation during the consultation process was addressed in any event in the Consultation Report (as referred to in section 2.8.10 above) In addition there will be further opportunity for these comment to be considered during the examination process.

2.8.12. NCC’s consultations, as described in Section 3.2 of the Pre-Application Consultation Report (Document Ref. 5.1), undertaken on the NDR sought comment on route options for the NDR between the A47 near Postwick and the A47 to the west of Norwich. These consultations and further consultation work undertaken in 2004 and 2005 helped to inform the decision made by its Cabinet in September 2005 to agree an adopted route for the NDR. This route was between the A47 at Postwick and the A1067 near Attlebridge (i.e. no link between the A1067 and A47) and it has not significantly changed up to the statutory pre-application consultations undertaken in accordance with Planning Act 2008. The statutory pre-application consultation included consultation on the principle of and need for the NDR and on alternative ways of meeting the need and on the route of the NDR (as set out in the Statement of Community Consultation in Appendix J of Document Ref 5.1).

2.8.13. All consultations undertaken since 2005 have shown the route of the NDR as being from the A47 at Postwick and the A1067 near Attlebridge. More recently these have included the statutory pre-application consultations and the consultations also undertaken in April/May/June 2012 and February/March 2013 (as described in 3.3 and 3.4 of the Pre- application Consultation Report (Document Ref 5.1)). During these consultations there was the opportunity to comment on the route as well as on alternative ways of meeting the need.

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2.9. Economic Benefits

2.9.1. The £1.3 billion of claimed economic benefits are overstated.

Applicant’s comment

2.9.2. The assessment of the economic benefits has followed a recognised methodology. Within Sections 5.4 and 5.5 of the Economic Appraisal Report (Document Ref 5.7) it is explained that the scheme delivers a BCR of 4.17 (inclusive of accident benefits) and a BCR of 5.33 when wider economic impacts and journey time reliability are included. Both of these represent ‘very high’ value for money (i.e. for BCR’s above 4) according to DfT’s VfM criteria. This analysis is in accordance with the standard DfT WebTAG methodology.

2.9.3. An analysis of the potential land use and development benefits has also been undertaken. The Scheme has the potential to bring over £1bn of investment in employment, housing and transport infrastructure into Norfolk. This investment is forecast to produce £1.1bn of Gross Value Added (GVA) benefits this is explained and justified in Section 5 of the Land Use and Economic Development Report (Document Ref 10.3).

2.9.4. Norfolk County Council claims the NDR would create thousands of jobs. However, net job growth doesn’t depend on road building and simply opening up land for development but on a wide range of factors, including the national economy. Also, it doesn’t consider the negative effects and likelihood that some businesses in Norwich city centre, Great Yarmouth and small market towns would relocate to the NDR corridor, leading to job losses.

Applicant’s comment

2.9.5. The economic development impact of NDR is set out in Document Ref. 10.3. The economic impact assessment of the proposed NDR is

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provided within the context of the JCS stated growth targets which are in place to guide the future of the Greater Norwich economy. The NDR is a key strategic piece of infrastructure and will play a key role in supporting the delivery of growth in housing and jobs over the next two decades.

2.9.6. The amount of development and the general location of development for the Greater Norwich area are detailed in the adopted JCS, the key adopted element of the development plan for Norwich and its surrounding area. This has been found to be sound following independent examinations of that strategy; most recently in 2013. As explained in paragraphs 2.11.2 to 2.11.9 of Volume 1 of the ES (Document Ref 6.1) the NDR scheme is identified as infrastructure which is fundamental to the achievement of the strategy in the JCS.

2.9.7. The level of employment provision in the JCS is required to meet the objectively assessed need to support economic, household and population growth. This has been determined by the local plan process which is the appropriate mechanism.

2.9.8. The JCS is the adopted strategy for the area and sets out the broad distribution type and scale of growth. It emphasises the need for the NDR as Priority 1 infrastructure as well as providing the spatial strategy for the area encompassing the city centre, the rest of the urban area and surrounding areas including market towns in Broadland and South Norfolk. The views of surrounding areas such as North Norfolk and Great Yarmouth were taken into account through the consultation process and more recently through the duty to co-operate. The JCS is evidenced based and subject to sustainability appraisal which includes economic considerations.

2.9.9. Norwich is a dominant regional city located within a largely rural county. As explained in Chapters 2 and 3 of Volume 1 of the ES (Document Ref 6.1) a number of objectives which centre on substantial population growth and economic development have been identified for the City of Norwich and its surrounding area. As explained in paragraphs 3.3.20 to 23

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3.3.34 of Volume 1 of the ES (Document Reference 6.1), at the local level these objectives have been largely identified within the adopted JCS. As paragraphs 3.3.35 to 3.3.46 of Volume 1 of the ES further explain, these objectives benefit from support at the national level.

2.9.10. The purpose of the Land Use and Economic Development Report (Document Ref 10.3) is to provide an explanation of the relationship between the proposed NDR and sites earmarked for development and to assess the economic development impact of the NDR in terms of jobs and dwellings which are assessed on a site-by-site basis with respect to the influence of the NDR on bringing development forward. The report quantifies the economic benefits of the development sites located on or close to the line of the NDR and provides a qualitative assessment of wider economic effects, including within Norwich City Centre and at Great Yarmouth and the market towns of Aylsham and North Walsham. Positive (but unquantified) effects are identified for these areas in Table 5.2 of the report.

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The Norfolk County Council (Norwich Northern Distributor Road (A1067 to A47(T))) Order

Applicant’s comment on Relevant Representations Volume 3 - District & Parish Councils & Meetings - Councillors - Political Groups

Planning Act 2008

Infrastructure Planning

The Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009

PINS Reference Number: TR010015

Document Reference: NCC/EX/4

Author: Norfolk County Council

Version Date Status of Version 0 11th July 2014 Final

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Contents

Ref Name RR Page

Alfred N Townly on behalf of G & L Plumstead Parish 3.1 20 5 Council

Swannington with Alderford and Little Witchingham 3.2 77 11 Parish Council

3.3 Attlebridge Parish Meeting 467 13

3.4 Cllr Lesley Grahame 519 15

3.5 Weston Longville Parish Council 535 17

3.6 Felthorpe Parish Council 536 22

3.7 Spixworth Parish Council 600 23

3.8 Eastern Region Green Party 617 24

3.9 Norwich Green Party 645 25

3.10 Cllr Boswell 646 34

3.11 Great Yarmouth Borough Council 658 38

3.12 Hockering Parish Council 747 38

3.13 North Norfolk District Council 755 40

3.14 Salhouse Parish Council 844 40

3.15 Cromer Town Council 916 45

3.16 Colney Parish Meeting 932 46

3.17 Wroxham Parish Council 983 50

3.18 Morton on the Hill Parish Council 1133 52

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Brief Introduction (for a full introduction see Volume 1)

Norfolk County Council (NCC) has provided comment on selected Relevant Representations (RRs) as follows:-

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Applicants comment on Relevant Representations

3.1. Alfred N Townly on behalf of Great & Little Plumstead Parish Council (RR 20)

Representation

The substance of the proposed NDR was changed midway through the latest consultation. A large proportion the area affected by these proposals were not consulted in the last consultation.

Applicant’s comment

3.1.1. The applicant is currently developing a Statement of Common Ground (SOCG) with Great and Little Plumstead Parish Council.

3.1.2. Section 2.7 of the Pre-application Consultation Report (Document Ref 5.1) explains why the Norwich Northern Distributor Road (NDR) is an infrastructure project for which a Development Consent Order (DCO) is required.

3.1.3. On 9 August 2013, the Secretary of State for Transport made a Direction (the Direction) pursuant to the powers in Section 35 of the Planning Act 2008, which directed that the NDR is "to be treated as development for which development consent is required.” This Direction was made during the formal pre-application consultation under the Planning Act 2008, and Appendix D of the Pre-application Consultation Report (Document Ref 5.1) contained a Legal Opinion from the Norfolk County Council's (NCC) Counsel, explaining why there are no issues in relation to the validity of the pre-application consultation that has been undertaken by the applicant simply because some of it preceded the making of the Direction.

3.1.4. Section 2.7.4 to 2.7.8 of the Pre-application Consultation Report (Document Ref 5.1) outlines NCC’s reasoning for its view that the NDR is a development for which development consent is required. This includes

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a chronology of events prior to the application for a DCO being made, which states that in December 2012, the applicant decided to promote the NDR as a Nationally Significant Infrastructure Project (NSIP). At that time the NDR fell within the definition of a NSIP set out in Section 22(2) of the Planning Act 2008 (as it then was) because it included works to the Postwick junction of the A47(T) and was to be constructed for a purpose connected with the A47(T).

3.1.5. Publication of the notice stating where and when the Statement of Community Consultation (SOCC) could be inspected took place on 21 June 2013 and on 28 June 2013, with the first publication exhibition held on 8 July 2013. The Section 48 Notices were published on 12 July 2013 and 19 July 2013. The programme of public exhibitions ran until 12 August 2013. Section 42 consultation letters were issued on 30 July 2013 and representations under all three strands of consultation were invited until 20 September 2013. Further information on the consultation is set out in the rest of the Consultation Report (Document Ref 5.1).

3.1.6. On 24 July 2013 the Highway and Railway (Nationally Significant Infrastructure Project) Order 2013 (S.I. 2013/1883) (the Highways Order) was made and the Order came into force on 25 July 2013. This was some weeks after the start of the statutory consultation process referred to above. The Order amended Section 22 of the Planning Act 2008 so that a project such as the NDR would not (from 25 July 2013 onwards) fall within the definition of a NSIP. The Secretary of State made the Direction on 9 August 2013. The effect of the Direction on the validity of the pre-application consultation is set out at sections 2.7.1 to 2.7.3 and 2.7.10 to 2.7.17 of Document Ref 5.1.

3.1.7. On 25 July 2013, the applicant submitted a qualifying request to the Secretary of State for a direction under Section 35(1) of the Planning Act 2008 that the NDR was a project of national significance and so should be treated as development for which development consent was required.” 6

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Representation

A large proportion of objectors were not considered at the applicant’s submission to the planning inspectorate.

Applicant’s comment

3.1.8. NCC received over 1400 responses to its consultations under Section 47 of the Planning Act, which commented on a wide range of issues associated with the NDR proposals. NCC is aware that three submissions made by Norwich Green Party, CPRE and SNUB were on the balance of probabilities received but unfortunately were not logged. In respect of these submissions, the Planning Inspectorate has concluded that the points raised in them had been raised by other consultees and therefore are covered in the Consultation Report. A legal point raised about the changes to the legislation during the consultation process was addressed in any event in the Consultation Report. In addition there will be further opportunity for these comments to be considered during the examination process.

3.1.9. The County Council’s Head of Procurement carried out an extremely thorough investigation, and although he was unable to arrive at a definitive view as to what happened, NCC have apologised to the Green Party, SNUB and CPRE. The full report, Review into missing submissions to Norwich Northern Distributor Road consultation process, is included in Appendix A.

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Representation

The Proposed NDR does not compare with the one and only route option consultation carried out in 2003. Applicant’s comment

Applicant’s comment

3.1.10. NCC’s consultations, as described in Section 3.2 of the Pre-Application Consultation Report (Document Ref. 5.1), undertaken on the NDR sought comment on route options for the NDR between the A47 near Postwick and the A47 to the west of Norwich. These consultations and further consultation work undertaken in 2004 and 2005 helped to inform the decision made by its Cabinet in September 2005 to agree an adopted route for the NDR. This route was between the A47 at Postwick and the A1067 near Attlebridge (i.e. no link between the A1067 and A47) and it has not significantly changed up to the statutory pre-application consultations undertaken in accordance with Planning Act 2008. The statutory pre-application consultation included consultation on the principle of and need for the NDR and on alternative ways of meeting the need and on the route of the NDR (as set out in the Statement of Community Consultation in Appendix J of Document Ref 5.1).

3.1.11. All consultations undertaken since 2005 have shown the route of the NDR as being from the A47 at Postwick and the A1067 near Attlebridge. More recently these have included the statutory pre-application consultations and the consultations also undertaken in April/May/June 2012 and February/March 2013 (as described in 3.3 and 3.4 of the Pre- application Consultation Report (Document Ref 5.1)). During these consultations there was the opportunity to comment on the route as well as on alternative ways of meeting the need.

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Representation

The consultation was opposed by 80% of respondents

Applicant’s comment

3.1.12. The volume of respondents objecting to scheme is considered small when compared to the overall number of people consulted. It is approximately 2% of the 57,000 residential and business addresses sent consultation letters. The proportion of respondents opposed to the scheme is considered a reflection of the area of consultation i.e. that the consultation focused on the areas most directly affected rather than areas further afield, which are likely to benefit from the NDR and future Norwich Area Transportation Strategy (NATS) measures that depend on the NDR. NCC’s own analysis of the Section 47 and 48 consultation responses is contain in Chapter 5 of the Pre-application Consultation Report (Document Ref 5.1), with the key issues identified highlighted in Section 5.4

Representation

No consideration for alternative start point for the NDR was considered at the Postwick Hub inquiry.

Applicant’s comment

3.1.13. In giving notice of the intention to hold a Public Inquiry for Postwick Hub, the Secretary of State for Transport directed that any person intending to submit alternative proposals to the Inquiry should provide details of those alternatives by a specified date.

3.1.14. In total, 13 Alternative Routes were proposed prior to the start of the Inquiry. These were all publicised by the Highways Agency (HA) and some representations of support and in opposition were received. Two further alternatives were put forward whilst the Inquiry was sitting. Some of these routes included an alternative junction location on the A47. 9

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3.1.15. The Inspector’s Report (Appendix B) into the Postwick Hub Public Inquiry (Report to the Secretaries of State for Transport and for Communities and Local Government by David Wildsmith BSc(Hons) MSc CEng MICE FCIHT MRTPI; 29 October 2013) included the following:-

 (Para 8.152) “AR9 and AR11 both propose major new grade- separated junctions well to the east of the existing junction, in the vicinity of Church Road, rather than seeking to improve the existing Postwick junction, which would remain largely unaltered in both alternatives. AR9 appears to be very much geared towards providing an element of a future NDR, whilst key parts of AR11 are forecast to carry very low traffic flows, such that the new construction would be hard to justify...”

 (Para 8.153) “Both alternatives are estimated to cost considerably more that the published Scheme (£44 million and £33 million respectively), and both would require the diversion of the high pressure gas main, would need Compulsory Purchase powers to be invoked to acquire the necessary land, and would be likely to have more significant environmental impacts than the published Scheme. Most importantly, both are predicted to give rise to significant operational problems and would fail to achieve the Scheme objectives. There is nothing before me to persuade me that either of these alternatives would offer any advantages over the published Scheme, and they therefore cannot be supported.”

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3.2. Swannington with Alderford and Little Witchingham Parish Council (RR 77)

Representation

NDR ceases at A1067 Fakenham Road. Local opinion is that this will cause road blockages there. These are likely to result in alternative 'rat runs' through minor roads within the Parish.

Applicant’s comment

3.2.1. The applicant is currently developing a SOCG with Swannington with Alderford Parish Council.

3.2.2. Vol 1 Section 7 Paragraph 7.1.8 to 7.1.14 of the Traffic Forecasting Report (Document Ref. 5.6) analyses the traffic impacts at the western end of the NDR in the vicinity of Taverham and Drayton and especially the impact on traffic crossing the Wensum Valley.

3.2.3. This shows that the NDR leads to a decrease in daily traffic on the routes that connect the A1067 with the A47(T) to the west of Norwich of 6% in 2017 and 4% in 2032 as shown in Table 7.1, although there is an increase in traffic on the western part of the corridor (between Lenwade / Weston Longville and Hockering) which is subject to improvements and traffic management.

3.2.4. In Figure I.3 in Vol3 of the Traffic Forecasting Report site A54 shows there would be a forecast reduction with the NDR on the A1067 Fakenham Road.

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Representation

NDR development is inextricably linked with housing expansion on periphery of Norwich, cutting into rural neighbourhoods.

Applicant’s comment

3.2.5. The level of housing and employment provision in the Joint Core Strategy (JCS) is required to meet the objectively assessed need to support economic, household and population growth. This has been determined by the local plan process which is the appropriate mechanism.

3.2.6. The existing problems on the transportation network in the Norwich area have been assessed and future problems and issues predicted. The overall transport strategy for the Norwich area, NATS which includes an NDR, has been devised to address the current and future problems and issues. This is described in detail in Section 3 of the Environmental (ES) Statement (Document Ref 6.1).

3.2.7. In view of the importance of the NDR within NATS, the local authorities and the Planning Inspectors, who found the JCS sound, have taken the view that if there is no NDR, the JCS would have to be reviewed to determine a different growth strategy for the Norwich area. However, it is not appropriate to use the DCO examination of the NDR as an opportunity to re-run arguments about whether the JCS planned growth in housing and employment is the appropriate spatial strategy for Greater Norwich. That was a matter that was fully investigated, tested, and settled by the JCS process which had the responsibility of setting the spatial strategy for Greater Norwich.

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Representation

Concern that gravel sand extraction will take place from Upgate/Felthorpe area abutting SSSI Upgate Common, resulting in damage to fragile eco-systems

Applicant’s comment

3.2.8. Although Swannington Bottom Plantation (Min48 DPD number) (500m from Upgate Common) has been deemed acceptable for potential future mineral extraction in the Local Development Plan Documents, there are no plans to use sand and gravels from this location in the construction on the NDR.

3.2.9. Therefore Environmental Impact Assessment (EIA) has identified no adverse environmental impacts upon Upgate Common Site of Special Scientific Interest (SSSI) that lies more than 2000m from the proposed scheme.

3.3. Attlebridge Parish Council (RR 467)

Representation

As a small village we are concerned of a possible increase in traffic on the A1067 at the point of the junction when leaving the village to turn right towards Fakenham.

Applicant’s comment

3.3.1. The applicant is currently developing a SOCG with Attlebridge Parish Council.

3.3.2. Vol 1 Section 7 of the Traffic Forecasting Report (Document Ref. 5.6) describes the changes in traffic and network performance that would occur with the implementation of the NDR. To the west of Norwich the NDR results in an increase in traffic using A1067 Fakenham Road, with some trips reassigning on this route from the direction of Kings Lynn. The reassignment onto Fakenham Road amounts to an increase of 1900 AADT in 2017 and 2900 in 2032 (18% and 22%) (site 9). However the 13

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model shows that the forecast traffic flows are very low on Old Fakenham Road which is used to access Attlebridge, less than 100 in the peak hour, and therefore there is not expected to be any capacity issues at the junction, even with the increase in traffic on the A1067 Fakenham Road.

Representation

A 'no right turn' is required, directing traffic up to the new proposed roundabout at the junction of the NDR with the A1067. At the turn off to Attlebridge on the A1067 from Norwich/NDR a widening of the road and a central turning lane would be needed.

Applicant’s comment

3.3.3. The perceived problem of traffic waiting on the A1067 if correct would be reflected in an elevated level of related injury accidents occurring at the junction. NCC has looked at the accident record and this junction is not identified as an accident cluster site. NCC defines this as 5 injury accidents occurring in a 3 year period within a 100m radius Only one accident at this junction within the last 5 years can be attributed to turning vehicles waiting on the A1067. This involved a westbound tail end collision on A1067 occurring in August 2009.

3.3.4. NCC acknowledges the concerns regarding traffic flows on the A1067 with the NDR but given the low minor road flows anticipated and the current accident record there is no evidence at present to suggest there will be a problem in the future as a result of the NDR. Addressing such issues is outside of the scope of the NDR scheme and the County Council would treat this junction similar to others across the county. If an adverse situation were to arise in the future at any junction on the highway network it would implement remedial works to address the problem, although these would need to be prioritised against other schemes across the county.

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3.4. Councillor Lesley Grahame (RR 519)

Representation

The Northern Distributor Road is not needed for East -West traffic as there is already a southern bypass.

Applicant’s comment

3.4.1. The NDR is not intended to replicate the A47 Norwich Southern Bypass. It is a distributor road designed to address existing overcapacity issues in the north of Norwich and enable the implementation of the full range of sustainable transport measures that comprise NATS.

3.4.2. The strategic modelling work shows that the NDR achieves these objectives of resolving existing overcapacity issues and enabling NATS.

3.4.3. The problems are set out in section 3.4 the ES (Document Ref 6.1.) Section 3.5 then shows how the NDR addresses these problems. The remaining parts of section 3 describe the derivation of the overall NATS strategy including looking at different options for an NDR.

Representation

Indeed it would not take traffic on a through route, as the ring is incomplete, and so would dump traffic on the western side of the city.

Applicant’s comment

3.4.4. Refer to Para 3.2.2 to 3.2.4 above.

3.4.5. These model outputs do not support the assertion that the Scheme would ‘dump’ traffic on communities in Taverham and Drayton. It is shown that these communities see a significant reduction in traffic using the existing A1067.

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Representation

Little evidence for the stated economic benefits, and that costs are understated - both financially, but also in opportunity costs of money not being better spent.

Applicant’s comment

3.4.6. Within Sections 5.4 and 5.5 of the Economic Appraisal Report (Document Ref 5.7) it is explained that the scheme delivers a transport Benefit Cost Ratio (BCR) of 4.17 (inclusive of accident benefits) and a BCR of 5.33 when wider economic impacts and journey time reliability are included. Both of these represent very high value for money (BCR above 4) according to Department for Transport’s (DfT) Value for Money criteria. This analysis is in accordance with the standard DfT WebTAG methodology.

3.4.7. An analysis of the potential land use and development benefits has also been undertaken. The Scheme has the potential to bring over £1bn of investment in employment, housing and transport infrastructure into Norfolk. This investment is forecast to produce £1.1bn of Gross Value Added (GVA) benefits. This is explained and justified in Section 5 of Land Use and Economic Development Report (Document Ref 10.3).

Representation

The need is to reduce our carbon footprint, and this road undermines any efforts climate commitments.

Applicant’s comment

3.4.8. The ES - Volume 1, Chapter 5 (Document Ref 6.1) examines the emissions of carbon arising from the NDR. The construction phase of the Scheme will lead to a one-off carbon emission from the use of construction materials, plant and transport. Mitigation measures have been included in the Scheme design, which reduce overall emissions from construction by 13.8kt CO2 . Carbon emissions during the 16

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operational phase of the Scheme will occur as a result of an increase in vehicle kilometres. Changes in absolute emissions will represent around 1% of the total emissions from all sources within the relevant Local Authorities in the assessment years. Carbon sequestration will increase as the habitat creation and landscaping matures.

3.5. Weston Longville Parish Council (RR 535)

Representation

Whereas it is possible to demonstrate the value of the section of the NDR from Postwick to Norwich airport, the economic case for this third section which would affect Weston Longville has to be demonstrated.

Applicant’s comment

3.5.1. Section 1.1.6 of Economic Appraisal Report (Document Ref 5.7) states that the DCO scheme has a BCR of 4.17 inclusive of accident benefits and a BCR of 5.33 when wider impacts and journey time reliability benefits are included. On the other hand Section 1.1.8 of Traffic and Economic Appraisal of NDR Alternatives (Document Ref 5.12) states that Alternative 2 (i.e. dual carriageway NDR between Postwick Junction and A140) has a BCR of 3.81 inclusive of accidents and a BCR of 4.11 when wider impacts and journey time reliability benefits are included. These results therefore illustrate the economic case for the section between A140 and A1067 as the additional costs of the western section produce benefits that are sufficiently high to increase the overall BCR for the Scheme.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Representation

The capacity of the A1067 to cope with traffic from the NDR must be clearly demonstrated

Applicant’s comment

3.5.2. According to the COBA 11 part 5 (June 2006) manual the calculated maximum capacity for a rural single carriageway such as A1067 Fakenham Road just to the west of where the NDR will terminate is 1290 vehicles per hour per direction.

3.5.3. This location on the A1067 just to the west of where the NDR terminates is not shown in the traffic forecasts displayed in the Traffic Forecasting Report (Document Ref. 5.6) in Appendix I, therefore the traffic forecasts have been extracted from the traffic model for this location and are shown in the tables below.

DM (without NDR) 2017 flows (veh/hr) 2032 Flows (veh/hr) AM PM AM PM Eastbound 520 440 660 520 Westbound 430 500 470 580

DS (with NDR) 2017 flows (veh/hr) 2032 Flows (veh/hr) AM PM AM PM Eastbound 840 780 960 990 Westbound 720 770 960 990

Note: All numbers are rounded to the nearest 10

3.5.4. It is evident that the capacity of A1067 with and without the NDR is below the maximum link capacity of 1290 veh/hr/direction.

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Representation

The impact on villages close to the end of the section may be to exacerbate existing problems in terms of high volumes of traffic on narrow and unsuitable roads. To what extent will this section create new 'rat runs' through adjacent villages?

Applicant’s comment

3.5.5. The forecasts of traffic to the west of Norwich crossing the Wensum valley are set out in the Traffic Forecasting Report (Document Ref. 5.6) in paragraphs 7.1.8-7.1.14 and in Table 7.1. Whilst traffic flows across an imaginary screen line along the Wensum Valley are forecast to reduce with the NDR by 6% in 2017 and 4% in 2032, it does show that there would be an increase in the western corridor on the C167 through Weston Longville and C173 between Lenwade and Hockering. However this issue will be addressed as described below to avoid impacts on the local settlements.

3.5.6. Norfolk County Council’s Cabinet resolved on 19 September 2005, to have no NDR link between the A1067 and A47 and to also pursue a separate scheme to address existing local issues between Hockering and Lenwade. On the 9 November 2009 Norfolk County Council’s Cabinet agreed to undertake works to progress a route improvement scheme that also included the introduction of HGV restrictions in Hockering, reclassification of the route to a B road and in the longer term to consider improvements to the junctions with the A47 and A1067 and the northern section of the route when funding permits.

3.5.7. The improved route between the A1067 and the A47 addresses previous HGV problems by diverting HGVs away from the villages of Weston Longville and Hockering. The route improvement works have been completed, with reclassification of the road to a B road and an accompanying HGV ban to be implemented in Hockering in 2014.

3.5.8. Marl Hill Road leads onto Church Street, which has a 6’ 6’’ width restriction (restriction runs from Morton Lane/Ringland Lane through 19

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Weston Longville to Rectory Road) and a 7.5T Gross Vehicle Weight restriction (restriction runs from Morton Lane/Ringland Lane through Weston Longville to just north of Wood Lane/Walnut Tree Lane). This means HGVs should already use Weston Hall Road. The aim is to deter other vehicles and light goods vehicles from using Marl Hill Road and traffic will be signed to use the new B road from the A1067.

Representation

What will the relationship of this section of the NDR be to the A1067- A47 HGV route? Will this become by default and without improvement the 4th section of the NDR?

Applicant’s comment

3.5.9. The recent improvements to the route between the A1067 and the A47 have been made in response to an existing issue relating to HGV’s. They are not intended to comprise a section of the NDR between these two roads. Cabinet Report 19 Sept 2005 (Appendix C)

Representation

What do traffic models say about expected volumes of traffic and directional flows?

Applicant’s comment

3.5.10. Locations between the A47 and A1074 are not shown in the traffic forecasts displayed in the Traffic Forecasting Report (Document Ref. 5.6) in Appendix I, therefore the traffic forecasts have been extracted from the traffic model and are shown in the table below.

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Annual Average Daily Traffic 2012 2017 2017 2032 2032 (AADT) Base DM DS DM DS

A1074 Dereham Rd between 14600 16700 15800 19900 19100 Stafford Avenue and Richmond Rd

Old Watton Rd 5400 5900 5800 6000 6000

B1108 Watton Rd between Colney 20200 22600 22000 28700 28100 Lane and Old Watton Rd

Representation

How much funding will be made available to deal with problems created in adjacent villages by this section of the NDR?

Applicant’s comment

3.5.11. Funding will be directed towards schemes that are necessary for the safe and efficient working of the highway network according to existing assessment criteria used by NCC. The allocation of future budgets for scheme development and implementation will need to be considered as part of NCC’s budget planning process.

3.5.12. NCC has also agreed to review the existing traffic calming on West End Costessey and to consider improved signing for and enforcement of HGV restrictions between Costessey and Taverham Drayton and funding has been allocated for this work to proceed.

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Representation

Any examination should focus on the wider issues created by this section of the NDR. For example building the Southern Bypass created a rat run in Weston Longville to the extent of more than 20,000 vehicles a week passing through a 6'6"width restriction.

Applicant’s comment

3.5.13. Refer to Para 3.5.5 to 3.5.7 above.

3.6. Felthorpe Parish Council (RR 536)

Representation

The Parish Council are broadly supportive of the NDR, but have concerns regarding increased traffic through the village caused by cars cutting through to reach the bypass the NDR will not fully circle Norwich and link with the southern bypass.

Applicant’s comment

3.6.1. The applicant is currently developing a SOCG with Felthorpe Parish Council.

3.6.2. Volume 3 Figure I.1 Traffic Forecasting Report (Document Ref. 5.6) shows that AADT traffic flows through Felthorpe are forecast to reduce with the NDR. These are shown at location A28.

3.6.3. Refer to Para 3.5.5 to 3.5.7 above.

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3.7. Spixworth Parish Council (RR 600)

Representation

Parish Council wishes to contest the County Council’s projected level of traffic flow through the village following construction of the NDR.

Applicant’s comment 3.7.1. The applicant is currently developing a SOCG with Spixworth Parish Council.

3.7.2. Traffic forecasts have been made in accordance with DfT guidance set out in WebTAG.

3.7.3. Volume 3 Figure I.2 of the Traffic Forecasting Report (Document Ref. 5.6) shows the impact of the NDR on traffic flows in Spixworth. This shows reductions in forecast traffic on Crostwick Lane (site A24) and on Buxton Road (site A52) but an increase on the North Walsham Road approaching the NDR junction (site A57). NDR will provide relief to existing orbital routes such as Crostwick Lane which is demonstrated by the traffic model results.

Representation

The Parish Council is further concerned about the proposed treatment of the Crostwick Lane/B1150/Rackheath Lane junction, namely to block off the latter at the junction.

Applicant’s comment 3.7.4. Following comment received from the April/May/June 2012 consultations NCC agreed to examine the operation of this junction. Assessment of the existing junction layout showed that it would operate within its desirable capacity in 2017 and 2032 with the NDR in place. Operational assessment of this junction is contained in Chapter 8.7 on pages 107 to 109 of the Transport Assessment (Document Ref 5.5).

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3.7.5. As part of the statutory pre application consultation the Parish Council commented that by a narrow majority it supported the proposal for the Crostwick Lane/Rackheath Lane/B1150 junction (Refer to PC033 on page 45 of Appendix T of the Pre-application Consultation Report (Document Ref 5.1). The reason for the closure is primarily to improve highway safety at the junction as closure of Rackheath Lane will simplify turning movements allowing drivers waiting at the Crostwick Lane arm to concentrate on the vehicle movements on the main road.

3.8. Rupert Read (MEP candidate) Eastern Region Green Party (RR 617)

Representation

There are many reasons to oppose the NDR. Eastern Region GP will focus here on just one: the argument from air pollution:

Applicant’s comment

3.8.1. Volume 1, Chapter 4 of the ES (Document Ref 6.1) examines the air quality impacts arising from the NDR. A qualitative assessment of potential construction phase effects has been undertaken for the Scheme. Mitigation measures have been identified for incorporation within the Construction Environmental Management Plan commensurate with the risk of dust effects identified and in line with best practice. Potential impacts are concluded to be Negligible to Slight Adverse, at worst and therefore not significant.

3.8.2. Operation phase effects have been assessed using an advanced dispersion model. Concentrations of key traffic related pollutants have been predicted at sensitive human health and ecological receptors and the change as a result of the Scheme has been quantified. Existing concentrations of nitrogen dioxide (NO2) are of concern in Norwich, particularly in the city where an ‘Air Quality Management Area’ (AQMA) 24

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has been declared, The Scheme is predicted to cause a Slight Beneficial effect on NO2 concentrations, including within the AQMA, and Negligible effects on fine particulate concentrations. Overall, operational phase air quality effects are concluded to be not significant.

3.9. Norwich Green Party (RR 645)

Representation

The road’s funding deficit requires generating a large local component (c. £60m). Such massive expenditure on a single project will impact the ability of the Councils to deliver other desperately needed infrastructure.

Applicant’s comment

3.9.1. Cabinet Report 4 Nov 2013 (Appendix D) sets out that the total cost of the scheme is £148.55m and that the county council will underwrite £60.34m of this, with £40m committed in principle from the GNDP. The adopted Joint Core Strategy identifies in Appendix 7 a range of infrastructure to support planned growth. Through the Greater Norwich City Deal Agreement that has been reached between the local authorities in the area, to pool Community Infrastructure Levy (CIL) and put this towards a programme of strategic infrastructure. The strategic infrastructure programme includes NDR, Green Infrastructure, sustainable transport, education and other important infrastructure required for the development of the area. The NDR is an important element of infrastructure to support the growth plans and allows the full range of sustainable transport interventions to be put in place. Having an agreed programme of strategic infrastructure allows decisions to be made so that the full programme can be delivered in a timely fashion, all of which is important to support planned growth.

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3.9.2. The County Council cannot spend government funding allocated to the NDR on other projects including training schemes, affordable housing projects, improving the A47 and reducing councils’ budget cuts. In any case, the A47 is a trunk road and so the Council is not responsible for the funding of it, and the county council would not be responsible for the budgets of other councils.

Representation

The claims for its economic benefits and job creation potential are based more in wishful thinking than solid evidence: they require thorough scrutiny against the realities of the local economy.

Applicant’s comment

3.9.3. Refer to Para 3.4.5 to 3.4.6 above.

Representation

The economic modelling is falsely based on traffic projections of up to a 40% increase nationally. This does not fit recent historical trends, and evidence that per capita private car miles has peaked (“Peak Car”).

Applicant’s comment

3.9.4. Traffic forecasts have been made in accordance with DfT guidance set out in WebTAG. This process derives future year trip matrices for different types of trip purpose and separately for home-based trips and non-home-based trips. This is discussed in Vol. 1 section 5.10 of the Traffic Forecasting Report (Document Ref. 5.6). These trips include all the generated traffic from the development sites in Norwich, South Norfolk and Broadland. The trip purposes consist of home-based trips which are forecast for a 24 hour time period and non-home-based trips which are forecast separately for each of the modelled time periods, the

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AM peak, Interpeak and the PM peak. Tables 5.19 to 5.22 of the forecasting report show this reference forecast demands.

3.9.5. For home-based trips, the total number of trips increase from 208,731 in 2012 to 223,207 in 2017 (an increase of 7%) and to 262,090 in 2032 (an increase of 26%). The growth in non-home based trips from 2012 base year to the future year of 2017 is estimated to be around 6% to 7%, while 2032 is forecast to be around 16% to 23% (the figures vary for each time period). In terms of freight, HGVs are forecast to grow at 2% up to 2017, and 19% up to 2032. LGV trips are forecast to increase by 10% from base year to 2017 and by 55% from base year to 2032.

3.9.6. It is acknowledged that there is uncertainty in forecasting the future traffic growth, although in this case the implementation of JCS is bound to account for a significant increase in road traffic. However to address the issue of uncertainty sensitivity tests were undertaken which are reported in Summary Results of Sensitivity Tests (Document Ref 5.11) This includes a test on a low growth forecast and the results are reported in section 6. The results show that even with low growth traffic would increase substantially on inappropriate routes without the Scheme, but these routes would be relieved substantially with the Scheme. Accident savings would be similar with low growth and the value for money for the scheme would be High with transport user and accident benefits, rising to Very High with the inclusion of wider impacts and journey time reliability benefits.

3.9.7. The economic appraisal has been based on forecasts that take account of the JCS proposals and produce reasonably sensible increases in traffic on that basis. Uncertainty has been addressed through sensitivity testing. Therefore it is considered that the economic modelling is not ‘falsely based’.

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Representation

The economic dis-benefits to other areas such as Norwich City Centre, Norfolk market towns, and Great Yarmouth has not been considered.

Applicant’s comment

3.9.8. The level of housing and employment provision in the JCS is required to meet the objectively assessed need to support economic, household and population growth. This has been determined by the local plan process which is the appropriate mechanism. The JCS legitimately and appropriately take account of the plans of the transport authority and the highway authority (i.e. NCC) including the proposals for NATS and the NDR. The JCS proposals for growth to the north east of Norwich were subject to examination as recently as 2013 and found sound.

3.9.9. The JCS is the adopted strategy for the area and sets out the broad distribution type and scale of growth. It emphasises the need for the NDR as Priority 1 infrastructure as well as providing the spatial strategy for the area encompassing the city centre, the rest of the urban area and surrounding areas including market towns in Broadland and South Norfolk. The views of surrounding areas such as North Norfolk and Great Yarmouth were taken into account through the consultation process and more recently through the duty to co-operate. The JCS is evidenced based and subject to sustainability appraisal which includes economic considerations.

Representation

At the only previous consultation in 2003, the public were consulted on a full NDR and not the current scheme. Last summer’s pre-application consultation was legally flawed, as the legal status of the road (as an NSIP) changed.

Applicant’s comment

3.9.10. Refer to Para 3.1.1 to 3.1.7 above. 28

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Representation

The promoters “lost” three key consultation responses from objector groups: a matter that is now being investigated at a high-level within Norfolk County Council.

Applicant’s comment

3.9.11. Refer to Para 3.1.8 and 3.1.9 above.

Representation

Alternatives to the scheme have never been properly designed, appraised or consulted upon.

Applicant’s comment

3.9.12. The NDR is part of the overall transport strategy for the Norwich area, NATS, which has been devised to address the current and future problems and issues. NATS has been in existence for many years and has evolved over time to reflect changing national and local policies and current challenges. It was at a review carried out by consultants in 1992 that the concept of a northern distributor road for Norwich was first introduced. A further review of NATS over the period 2002 to 2005 considered various schemes and measures to resolve the transport problems, protect the historic city and reduce the impact of traffic in urban and rural areas where rat running is prevalent and detrimental to those communities.

3.9.13. These measures were then assembled into a number of packages which were evaluated. The preferred package comprised measures to improve public transport and encourage modal shift and an NDR to address existing problems that were hindering the former objectives. Alongside this work to develop NATS, environmental studies and consultation work was carried out to understand the nature and best routeing for an NDR to minimise environmental impact and best meet the needs of the overall

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NATS package. This work is described in detail in the ES (Document Ref 6.1) in Section 3.

Representation

A three-quarter NDR will ‘dump’ traffic into the Drayton/Taverham area. There will be an increase of rat-running to the A47 afflicting Costessey and the Wensum valley.

Applicant’s comment

3.9.14. Refer to Para 3.2.1 to 3.2.4 above.

Representation

NDR increases carbon emissions at a time when the socio-economic responsibility to reduce carbon is enshrined in national legislation

Applicant’s comment

3.9.15. Volume 1, Chapter 5 of The ES (Document Ref 6.1) examines the emissions of carbon arising from the NDR. The construction phase of the Scheme will lead to a one-off carbon emission from the use of construction materials, plant and transport. Mitigation measures have been included in the Scheme design, which reduce overall emissions

from construction by 13.8ktCO2 . Carbon emissions during the operational phase of the Scheme will occur as a result of an increase in vehicle kilometres. Changes in absolute emissions will represent around 1% of the total emissions from all sources within the relevant Local Authorities in the assessment years. Carbon sequestration will increase as the habitat creation and landscaping matures.

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Representation

It will increase levels of NO2, PM2.5, PM10s are other air pollutants. It will contribute to the UK being unable to meet its future commitments under the UN Gothenburg protocol to reduce these air pollutants.

Applicant’s comment

3.9.16. Refer to Para 3.8.1 to 3.8.2 above.

Representation

It will cause significant health impacts, both by promoting car dependency leading to unhealthy “obesogenic” lifestyles at the root of chronic illnesses and from air pollution (eg asthma)

Applicant’s comment

3.9.17. With regards to lack of exercise and human health, Chapter 12 of the ES concludes that the Scheme would have a Moderate Beneficial and therefore significant effect for All Travellers. This is as a result of reduced traffic and congestion on the majority of radial routes, improved amenity for Non-Motorised Users and relief from existing severance within and between communities caused by existing high traffic levels thus providing better facilities for walking and cycling.

Representation

It will bring increased traffic levels and congestion on other roads, especially the radial routes in/out of Norwich.

Applicant’s comment

3.9.18. The traffic flows forecast with the NDR are compared to those without the Scheme in Volume 3 Figures I.1 to I.4 of the Traffic Forecasting Report (Document Ref. 5.6) These show that there are increases on

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some radial routes in the vicinity of where they connect with the NDR. However the Transport Assessment (Document Ref. 5.5) shows in section 8.5 that the NDR junctions are considered to operate acceptably well. Furthermore the Traffic Forecasting Report in Vol 1 Section 7 describes the reductions in traffic in other parts of the network with NDR. In particular traffic would be reduced in the suburban area, including on radial routes and on inappropriate routes that are currently used by orbital traffic movements.

Representation

It breaks existing pedestrian/cycle links and lanes, create longer journeys (including by car). This reduces accessibility to vital services including health centres, and to green spaces and the countryside.

Applicant’s comment

3.9.19. The strategy published as part of the February/March 2013 public consultations identified a network of routes to link areas that generate NMU’s (such as villages, employment areas, future development) with each other, the Norwich Cycle Network and the Marriott’s Way. Part of these routes utilised narrow country lanes, roads closed to motor vehicles and existing public rights of way. NCC has prioritised NMU improvements on this network, and these improvements have included new NMU facilities as part of the proposals. Approximately 25 kilometres of new links suitable for use by pedestrians, cyclists and equestrians where permitted would be provided alongside, over, and connecting with, in places, the NDR route, together with improved surfacing provided on some existing rights of way. The scheme includes eight grade separated crossings of the NDR and two grade separated crossings of the A47. Various NMU at grade crossings of NDR and side roads are also proposed. The NMU proposals are shown on the General Arrangement Plans (Document Ref 2.6). 32

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3.9.20. Volume 1, Chapter 13 of The ES (Document Ref 6.1) Overall, the assessment presented within the ES concludes that a Slight Adverse but not significant impact is anticipated for All Travellers during construction for a temporary period, as a result of construction delays, route diversions and the presence of construction plant. However, once the Scheme is operational, it is considered that there would be a Moderate Beneficial and therefore significant impact for All Travellers. This is as a result of reduced traffic and congestion on the majority of radial routes, improved amenity for Non Motorised Users (NMUs) and relief from existing severance within and between communities and facilities caused by existing high traffic levels.

Representation

It destroys good agricultural land and woodland, at a time when UK food security is important.

Applicant’s comment

3.9.21. Volume 1, Chapter 13 of The ES (Document Ref 6.1) The only temporary effects that were identified for individual farm businesses was that of temporary land-take during construction and severance of fields and irrigation systems. This land will be fully restored to agricultural use once construction is completed and the mitigation put in place for construction is similar to mitigation for the operational phase of the Scheme.

3.9.22. When the criteria for assessment are applied there is a significant effect resulting from the loss agricultural land as a local resource. However, this assessment should be considered in relation to current farming practices and the benefits arising from a potential increase in biodiversity from intensively farmed land lost to habitat creation.

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3.10. Councillor Andrew Boswell (RR 646)

Representation

Levels of NO2, PM2.5, PM10s will increase.

Applicant’s comment 3.10.1. Refer to Para 3.8.1 to 3.8.2 above.

Representation

We should be developing much greater public transport. Evidence shows that per capita private car miles have peaked (“Peak Car”) so why invest so much in an old concept of transport.

Applicant’s comment 3.10.2. Improved public transport, cycle and pedestrian facilities are important parts of NATS that will encourage mode shift from private car use. Some improvements have been made already but others are dependent upon the relief that the NDR will provide to key radial routes in the built up area and on the outer ring road.

3.10.3. Section 3.4 of the ES (Document Ref. 6.1) identifies the existing problems and issues and illustrates the conditions on the highway network including traffic flows. Section 3.5 then identifies how the NDR as part of NATS addresses these problems and issues taking account of the planned JCS growth. Sections 3.7 and 3.8 explain how the preferred NATS strategy which includes and NDR was devised. During this process strategies that didn’t include an NDR were assessed but were not selected due to their inability to offer solutions to the full range of problems and issues.

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Representation

If built, the vitality of Norwich City Centre, Norfolk market towns, and Great Yarmouth will be depleted as economic activity becomes focussed around the road in North and East Norwich.

Applicant’s comment 3.10.4. Refer to Para 3.9.8 to 3.9.9 above.

Representation

Applicant’s comment

3.10.5. Refer to Para 3.9.1 to 3.9.2 above.

Representation

The claims for its economic benefits and job creation potential are wishful thinking.

Applicant’s comment

3.10.6. Refer to Para 3.4.5 to 3.4.6 above.

Representation

Norfolk people do not want this model of economic growth thrust down from on high, and feel that their views are being ignored.

Applicant’s comment

3.10.7. The amount of development and the general location of development for the Greater Norwich area are detailed in the adopted JCS, the key adopted element of the development plan for Norwich and its

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surrounding area. This has been found to be sound following independent examinations of that strategy; most recently in 2013. As explained in paragraphs 2.11.2 to 2.11.9 of Volume 1 of the ES (Document Ref 6.1) the NDR scheme is identified as infrastructure which is fundamental to the achievement of the strategy in the JCS.

Representation

Indeed, the public have not been properly consulted. Last summer’s pre-application consultation was legally flawed, with the road going from a local scheme to a national scheme mid-consultation.

Applicant’s comment

3.10.8. Refer to Para 3.1.1 to 3.1.7 above.

Representation

The promoters “lost” three key consultation responses from objector groups, including one written by myself.

Applicant’s comment

3.10.9. Refer to Para 3.1.8 and 3.1.9 above.

Representation

A three-quarter NDR will ‘dump’ traffic into the Drayton/Taverham area. There will be an increase of rat-running to the A47 afflicting Costessey and the Wensum valley. This will create demand for a further unaffordable extension of the road across the Wensum valley.

Applicant’s comment

3.10.10. Refer to Para 3.2.2 to 3.2.4 above.

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Representation

The plan goes against planning for healthier lifestyles through active travel as it embeds car travel as the primary transport method.

Applicant’s comment

3.10.11. The NDR forms a key part of NATS and the NATS Implementation Plan (NATSIP), which was updated in November 2013 (Cabinet 4 Nov 2013). NATSIP sets out the relationship between the NDR and NATS and identifies those elements of NATSIP that cannot be delivered without the NDR. The NDR therefore allows the full range of NATSIP measures to be delivered. NATSIP has been developed to deliver the required step- change in transport provision to realise the full potential of, and cater for, the transport needs of a vibrant and growing regional centre including Bus Rapid Transit (BRT) Cycle Network and Public Realm Improvements. The NDR, with its associated NATS measures underpins the opportunity to deliver a high quality living environment in sustainable developments based around walking, cycling and public transport.

Representation

Elderly and less able people are disadvantages by reduced access to vital services including health centres, and to green spaces and the countryside, particularly where the road would cuts off existing pedestrian/cycle links and lanes.

Applicant’s comment

3.10.12. Volume 1 Chapter 13 of the ES (Document Ref 6.1) Overall, the assessment presented within the ES concludes that a Slight Adverse but not significant impact is anticipated for All Travellers during construction for a temporary period, as a result of construction delays, route diversions and the presence of construction plant. However, once the Scheme is operational, it is considered that there would be a Moderate Beneficial and therefore significant impact for All Travellers. This is as a 37

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result of reduced traffic and congestion on the majority of radial routes, improved amenity for NMUs and relief from existing severance within and between communities and facilities caused by existing high traffic levels.

3.11. Great Yarmouth Borough Council (RR 658)

Representation

Great Yarmouth Borough Council has been a consistent supporter of the Norwich Northern Distributor Road because of the economic and access benefits it will bring.

Applicant’s comment 3.11.1. The Applicant has noted this representation

3.12. Richard Hawker – Hockering Parish Council (RR 747)

Representation

Hockering village has suffered major HGV traffic problems for over 30 years. Also, large numbers of cars and light industrial traffic use the road through the village to gain access from the north of Norwich and the A1067 to the A47. NCC's own figures show that all this traffic this will increase massively if the NDR is built.

Applicant’s comment 3.12.1. Refer to Para 3.5.5 to 3.5.7 above.

Representation

It is clear that alternatives to this very expensive road have not been properly investigated

Applicant’s comment 3.12.2. Refer to Para 3.9.12 to 2.9.13 above.

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Representation

It is difficult to believe that this country is still considering big new roads, given its commitment to reduction in CO2 emissions and the need to tackle climate change.

Applicant’s comment 3.12.3. Refer to Para 2.9.15 above.

Representation

We are particularly annoyed that our council was not advised by NCC about this examination, as we have been actively involved in past representations and participated in exhibitions about this road.

Applicant’s comment 3.12.4. Section 56 of the Planning Act 2008 outlines how and who NCC is required to notify regarding the acceptance of the DCO application and that it will be moving forward to examination. In accordance with this section of the Planning Act 2008 NCC placed a Section 56 Notice in both local (on 14 and 21 February 2014) and national newspapers (on 14 February 2014) and sent a copy of this notice to: • local authorities, the Planning Act 2008 states that the local authorities (both at County and District level) to be notified are those through which the NDR passes together with their neighbouring authorities, • prescribed consultees, the list of these being identified by The Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009, • those with a interest in land affected by the NDR.

3.12.5. With regard to parish councils, although the relevant legislation only requires NCC to consult parish council's in whose area the scheme is located, it decided to adopt similar principles as for the local authorities and also notified neighbouring parish councils.

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3.13. North Norfolk District Council (RR 755)

Representation

The Council strongly supports the provision of the NDR and considers that it will deliver significant benefits.

Applicant’s comment

3.13.1. The Applicant has noted this representation.

3.14. Salhouse Parish Council (RR 844)

Representation

Salhouse Parish Council believes that it is wrong that the proposed NDR has become inextricably linked to the planned development of the North East Growth Triangle as designated in the Joint Core Strategy.

Applicant’s comment

3.14.1. The applicant is currently developing a SOCG with Salhouse Parish Council.

3.14.2. Refer to Para 3.2.5 to 3.2.7 above.

Representation

We believe local environmental criteria should hold more weight. Issues that concern us include the peace and tranquillity of historic Rackheath Park, the wetland habitat of Dobb's Beck and The Springs, to NW of A1151 which drains into River Bure the peace and beauty of the area around Beeston St. Andrew.

Applicant’s comment

3.14.3. Volume 1 and 2 Chapter 14 Drainage and Water of the ES (Document Ref 6.1) Chapter 8 Nature Conservation and Chapter 7 Landscape All water prior to discharge from the Scheme will be treated by a three step 40

Norwich Northern Distributor Road Document Reference: NCC/EX/4

cleaning process. It is anticipated that water discharging to The Springs will be of equal or better quality than already there.

3.14.4. An ecological survey has been conducted around and within The Springs. Aquatic invertebrates at The Springs County Wildlife Site were first surveyed in 2005, and repeated in 2006/7. Further surveys were undertaken in 2013, as the previous dataset required updating. At the same time, surveys for Desmoulin’s whorl snail (Vertigo moulinsiana) were repeated, to allow an accurate assessment of the impacts on this sensitive species to be made.

3.14.5. Landscaped embankments would be provided to screen views of the NDR from the rear of Beeston Hall, which would be gently graded to blend into the existing contours so as to be as unobtrusive as possible. The mitigation provided as the scheme crosses Beeston Park will reduce the effects on this landscape of moderate sensitivity to slight adverse for both year 1 and year 15, although beyond Beeston Park the impact will be moderate adverse in year 1, reducing to ‘slight adverse ‘ by year 15 as the dense mitigation planting matures.

Representation

A further environmental concern is that the new road will cause increased surface drainage runoff into local (Broadland) water courses and that it will contain pollutants from the road.

Applicant’s comment

3.14.6. Volume 1 and 2 Chapter 14 Drainage and Water of the ES (Document Ref 6.1) Chapter 8 Nature Conservation and Chapter 7 Landscape. There is only one location where there will be a discharge to surface water and all water prior to discharge from the Scheme will be treated by a three step cleaning process. It is anticipated that water discharging to The Springs will be of equal or better quality than already there.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Representation

We are concerned by the predicted increase in traffic along the A1151 and B1140 between NDR and the new housing developments around Wroxham and Hoveton.

Applicant’s comment

3.14.7. The amount of development and the general location of development for the Greater Norwich area are detailed in the adopted JCS, the key adopted element of the development plan for Norwich and its surrounding area. This has been found to be sound following independent examinations of that strategy; most recently in 2013. As explained in paragraphs 2.11.2 to 2.11.9 of Volume 1 of the ES (Document Ref 6.1) the NDR scheme is identified as infrastructure which is fundamental to the achievement of the strategy in the JCS. This included the proposed level of growth at Wroxham and evidence provided in relation to the JCS took account of the growth in Hoveton.

3.14.8. The Traffic Forecasting Report (Document Ref 5.6) explains that the NDR results in orbital traffic reducing on the existing routes to the east of Norwich (see paragraph 7.1.4). Whilst traffic is forecast to increase on Wroxham Road as shown in Figure I.2 in Volume 3 of the Traffic Forecasting Report, there is a large forecast reduction in traffic on the B1140. This location is not shown in the report plan so the forecast AADTs have been extracted from the traffic model and are set out in the Table below. This shows that NDR would substantially reduce traffic on the B1140.

Annual Average Without NDR With NDR Daily Traffic 2017 8900 4200 2032 11200 4800

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Representation

The Postwick Hub is a poorly designed, over-specified and, in our view, unnecessary white elephant which due to its complication and extra mileage will actually deter traffic from using the NDR.

Applicant’s comment

3.14.9. The Postwick Hub proposal has already been examined in detail at the Public Inquiry in 2013 and has subsequently been approved by Government. It has been designed to be able to accommodate the NDR traffic and the traffic impact is set out in the Transport Appraisal (Document Ref 5.5).

3.14.10. Paragraph 7.8.1 of the Transport Assessment explains that the existing junction configuration at Postwick presently leads to substantial delays and queuing, with queues reaching the A47(T) westbound diverge slip road. Traffic growth would exacerbate this situation and there will be a high risk of queues conflicting with high speed traffic on the A47(T). In addition it explains that existing orbital routes already carry significant amounts of traffic due to the lack of a strategic provision. This traffic is predicted to increase in future years. A number of these roads are inappropriate for the amount of traffic they carry presently or in the future.

3.14.11. The results for the assessment of the Scheme junctions are presented in section 8 of the Transport Assessment, and proposed Postwick junctions are assessed in section 8.6. The junction layouts are considered to be the best possible balance between relieving the existing network whilst ensuring acceptable conditions on this new part of the network.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Representation

The money should be spent improving elsewhere on A47.

Applicant’s comment

3.14.12. The County Council cannot spend government funding allocated to the NDR on the A47. In any case, the A47 is a trunk road and so the Council is not responsible for the funding of improvements to it.

Representation

Local heavy goods vehicles will continue to use the B1140 through Salhouse, particularly during the “beet season”.

Applicant’s comment

3.14.13. NCC has a Route Hierarchy network which classifies roads according to their function and level of use. This was developed following assessments of roads and public consultations during the 1990s and early 2000s. This had designated the route between Wroxham Road and Salhouse Road through Salhouse as a Main Distributor Route and classified as a B road. Roads with this designation are generally identified as being a distributor of local through traffic. However, the Route Hierarchy will need to be reviewed post NDR implementation and this would include the designation of the B1140 through Salhouse.

Representation

We have concerns regarding the safe and easy ability for crossing the NDR by cyclists, mobility vehicles, animals and pedestrians.

Applicant’s comment

3.14.14. During the April/May/June 2012 public consultations NCC had various requests for improved walking and cycling facilities as part of the

Norwich Northern Distributor Road Document Reference: NCC/EX/4

proposals for the NDR. As a result a strategy was developed to consider and prioritise these consultation requests. The strategy published as part of the February/March 2013 public consultations identified a network of routes to link areas that generate NMU’s (such as villages, employment areas, future development) with each other, the Norwich Cycle Network and the Marriott’s Way. Part of these routes utilised narrow country lanes, roads closed to motor vehicles and existing public rights of way. NCC has prioritised NMU improvements on this network, and these improvements have included new NMU facilities as part of the proposals. Approximately 25 kilometres of new links suitable for use by pedestrians, cyclists and equestrians where permitted would be provided alongside, over, and connecting with, in places, the NDR route, together with improved surfacing provided on some existing rights of way. The scheme includes eight grade separated crossings of the NDR and two grade separated crossings of the A47. Various NMU at grade crossings of NDR and side roads are also proposed. The NMU proposals are shown on the General Arrangement Plans (Document Ref 2.6). NCC has considered requests for cycle improvements and developed a strategy to prioritise these. This included identifying routes that linked communities with Norwich via its agreed Norwich Cycle Network.

3.15. Cromer Town Council (RR 916)

Representation

The Town Council is generally in favour of the road. As the main Norwich to Cromer Road will cross the NNDR the Town Council will want to express views on this junction.

Applicant’s comment

3.15.1. The Applicant has noted this representation.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

3.16. Colney Parish Council (RR 932)

Representation

The large housing developments proposed are hugely unpopular. Recent government population growth statistics indicate that the number of proposed housing schemes could be dropped altogether and others significantly reduced.

Applicant’s comment

3.16.1. This issue was most recently considered at the JCS examination in 2013. Inspector Vickery concluded “The GNDP figures indicate that the adopted JCS total still lies comfortably within the range of various projections based on completion extrapolations, affordable housing requirements, and population and economic figures [Table 1 of SDJCS 14 and TP 13]”. [Report to Broadland District Council, Norwich City Council and South Norfolk District Council, November 2013 paragraph 40]. (Appendix E) He concluded that “overall the housing totals and modified Housing Trajectory represent a realistic, balanced, deliverable, justified and soundly based set of figures which would meet the objectively assessed housing needs over the plan period” [ibid. paragraph 80].

Representation

Far from reducing traffic, traffic associated with the NDR will increase traffic on all radial roads, including knock-on effects on communities in the south and west of Norwich.

Applicant’s comment

3.16.2. Refer to Para 3.9.18 above.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Representation

Most of the route for the NDR and related housing developments is proposed on green-field land. Thousands of acres of productive agricultural land will be permanently lost.

Applicant’s comment

3.16.3. Refer to Para 3.9.20 to 3.9.21 above.

Representation

The Government has interfered in the local consultation on the NDR by proposing to fast-track the planning process by making the NDR a NSIP.

Applicant’s comment

3.16.4. Parliament has legislated to provide the DCO regime in the Planning Act 2008 and this empowers the Secretary of State to make Directions under section 35 requiring projects to be deal with via that regime. The Secretary of State has made such a Direction in the exercise of his statutory powers. The DCO regime builds in opportunities for public participation by local communities and others.

3.16.5. The NDR has always been regarded as part of a package of measures to improve transport in the Norwich area. The requirement for an NDR was first formally identified in 1992 following a review of transportation strategies for the greater Norwich area (NATS). A subsequent review of NATS carried out between 2002 and 2005 centred around a further comparative analysis of possible interventions to resolve the area’s transport problems, conserve the historic core of the City, reduce the effect of traffic on the urban area and rural settlements used as rat-runs and facilitate the continued growth of the City in accordance with the policies of the statutory development plan.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Representation

Any east-west traffic round Norwich already on the A47 is unlikely to choose even a complete NDR in preference to the Southern Bypass. Smaller developments than those proposed would allow much cheaper alternatives to be considered to serve the transport needs North and East of Norwich.

Applicant’s comment

3.16.6. The NDR is not intended to replicate the A47 Norwich Southern Bypass. It is a distributor road designed to address existing overcapacity issues in the north of Norwich and enable the implementation of the full range of sustainable transport measures that comprise NATS.

3.16.7. Another potentially smaller and cheaper alternative to the NDR is Alternative 5 which has been assessed in the Traffic and Economic Appraisal of NDR Alternatives (Document Ref 5.12). Specifically Section 8 contains an assessment of Alternative 5 which comprises developer link roads extended to enable a route through to the Airport.

3.16.8. Alternative 5 fails to reduce traffic on inappropriate routes and relieve the existing network. The developer link roads would not operate satisfactorily and they would cause particularly severe difficulties in implementing the proposed shared use high street-type design envisaged in the development proposals. (For example, the Beyond Green planning permission for North Sprowston, Old Catton is providing an internal east west street which will ultimately span four radial routes from St Faiths Road to Wroxham Road. All the roads within this development, including the east west route, will have a 20mph speed limit to make it easier for pedestrians to cross streets at any point. Speeds will be kept low through design rather than enforcement, using features such as short lengths of street between junctions, narrow carriageways, on street parking, limiting forward visibility and the use of shared space on some tertiary streets).

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Representation

Passenger numbers for Norwich airport have fallen by over 40% since 2007 and in 2013 some aviation experts stated that there are too many small regional airports and Norwich was identified as amongst those.

Applicant’s comment

3.16.9. Although the NDR provides improved connectivity to Norwich International Airport (NIA) and its adjacent industrial areas, this is not its only function. It is required to enable the implementation of the full range of sustainable transport measures that comprise NATS. Any reduction in passenger numbers is a reflection of the global economy.

3.16.10. NIA provides an important regional facility serving both business and leisure markets and providing international connections. It is the base for a number of helicopter charter companies that serve the offshore energy industry. There here are businesses in the north of Norwich that form part of the supply chain for the offshore and emerging industries in Great Yarmouth including the Enterprise Zones. Improved connectivity between these areas will help these industries prosper and encourage economic growth which could create more jobs in Norfolk.

Representation

The NDR is a hugely expensive road scheme with inflated and unproven economic benefits.

Applicant’s comment

3.16.11. Refer to Para 3.4.5 to 3.4.6 above.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Representation

Government projects are notorious for underestimating costs. Similarly, local councils, who already face a shortfall in their budgets for years ahead, will have to fund such additional costs.

Applicant’s comment

3.16.12. The County Council has completed significant work with the already appointed contractor (Birse Civils Ltd) and has high confidence regarding scheme costs. The County Council has agreed the funding arrangements for the difference in funding between the government contribution and the cost of the scheme (Cabinet Report Nov 2013 Item 14 Appendix C sets out that the total cost of the scheme is £148.55m; government grant is £86.5m; growth point funding £1.71m; and that the county council will underwrite £60.34m, with £40m of this committed in principle from the GNDP).

3.17. Wroxham Parish Council (RR 983)

Representation

It seems to be a general view amongst a large number of our residents that there is little justification for building the NDR, unless to facilitate the creation of new housing development.

Applicant’s comment

3.17.1. The applicant is currently developing a SOCG with Wroxham Parish Council.

3.17.2. Refer to Para 3.2.5 to 3.2.7 above.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Representation

We are very concerned at the number of roundabouts proposed over the length of the route. In particular we are concerned at the close proximity of roundabouts at the B1150 North Walsham Road; the A1151 Wroxham Road; the B1140 Salhouse Road and the Plumstead Road.

Applicant’s comment

3.17.3. The NDR is a distributor road designed to address existing overcapacity issues in the north of Norwich and enable the implementation of the full range of sustainable transport measures that comprise NATS. To function as such it requires junctions with all the main radial routes to provide the connectivity to distribute traffic movements. The junction designs are the best possible balance between environmental impact and relieving the existing network whilst ensuring acceptable conditions on the highway network. Operational assessments of these junctions are contained in Chapter 8.3 and 8.4 of the Transport Assessment (Document Ref 5.5).

Representation

It is well known to your Department at County HQ of the serious traffic problems that already exist in Wroxham and Hoveton consequent on the decision to not build a by pass in 1995.

Applicant’s comment

3.17.4. Traffic levels are predicted to increase in Wroxham and Hoveton over time due to general growth in trips and population increase, as they have done since 1995. However, the predicted traffic levels at the bridge over the river are likely to be very similar with or without an NDR. That is to say Wroxham is beyond the influence of the NDR.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Representation

With new houses being built, or planned, in Hoveton and Wroxham, together with those planned in Rackheath, the A1151 will be seriously overburdened during busy periods. We strongly believe that the proposed A1151 roundabout should be replaced with a bridging arrangement either under or over the NDR.

Applicant’s comment

3.17.5. NCC considers that the adopted JCS, which outlines the level of housing development in the Greater Norwich Area, and the process for its development has been properly tested through the local plan process. Most recently, the proposals for growth in the Broadland part of the Norwich Policy Area were the subject of examination in public in 2013.

3.17.6. NCC’s assessment of the Wroxham Roundabout junction shows that the junction would operate within its desirable capacity in 2017 and below its theoretical capacity in 2032. Whilst it exceeds its desirable capacity in 2032 NCC considers that the delay is reasonable and the queues can be accommodated safely. Chapter 8 of the Transport Assessment (Document Ref 5.5) contains the assessment of this junction.

3.18. Morton on the Hill Parish Council (RR 1133)

Representation

No provision is made to connect the road directly to the southern bypass which we consider essential. The road should include crossing the Wensum Valley at the outset.

Applicant’s comment

3.18.1. The applicant is currently developing a SOCG with Morton on the Hill Parish Council.

3.18.2. The NDR is in no way dependent on a link from the A1067 to the A47(w) and can be assessed (and has been assessed) as a stand-alone scheme 52

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on its own merits. Any proposals for a link to the A47(w) would be a matter for separate assessment on their own merits if and when any such proposals were put forward.

3.18.3. An assessment of options across the Wensum Valley concluded, in 2005, that significant impacts on the SAC would be likely, and there was doubt as to whether, under the terms of the Habitats Directive, it would be possible to design an acceptable scheme. This in turn raised the prospect that consent for a wider scheme including such a link might not be granted. On 19 September 2005, the applicant’s Cabinet resolved to have no NDR link between the A47(w) and the A1067. It therefore did not form part of the adopted route.

3.18.4. At its meeting of 16 September 2013 the meeting of the NCC resolved to recommend to Cabinet that they submit an application for a DCO in respect of the NDR as proposed (i.e. between the A47 at Postwick and the A1067 near Attlebridge) and to also commission a report on a feasibility study of providing a link across the Wensum Valley from the A1067 to the A47(w). Whilst at its meeting of 7 October 2013 the applicant’s Cabinet resolved that a “scoping report on the feasibility of providing a link across the Wensum Valley from the A1067 – A47 be written once consultation work was completed”, this study has not been carried out and there is therefore currently no proposal establishing the form any link between the A1067 and A47(w) would take, or indeed whether any such link is feasible. The NDR is in no way dependent on a link from the A1067 to the A47(w) and can be assessed (and has been assessed) as a stand-alone scheme on its own merits. Any proposals for a link to the A47(w) would be a matter for separate assessment on their own merits if and when any such proposals were put forward. The Transport Assessment for the NDR (Document Ref 5.5.) shows that the NDR can provide substantial benefits without a further link between the A1067 and A47(w) and that the NDR will reduce daily traffic on existing routes between the A1067 and the A47(w) between Drayton/Taverham 53

Norwich Northern Distributor Road Document Reference: NCC/EX/4 and Costessey. The NDR is therefore in no way dependent on the provision of such a link. The feasibility and environmental acceptability of a link to the A47(w) have not been established and the previous assessment in 2005 discarded this option. Accordingly, it is the position of the applicant that the NDR can and should be considered on its own merits without such a link.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

The Norfolk County Council (Norwich Northern Distributor Road (A1067 to A47(T))) Order

Applicant’s Comment on Relevant Representations Volume 4 - Statutory Bodies

Planning Act 2008

Infrastructure Planning

The Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009

PINS Reference Number: TR010015

Document Reference: NCC/EX/4

Author: Norfolk County Council

Version Date Status of Version 0 11th July 2014 Final

Norwich Northern Distributor Road Document Reference: NCC/EX/4

This page has been left intentionally blank

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Contents

Ref Name RR Page

4.1 Norwich Airport Limited 700 5

4.2 Network Rail Infrastructure Ltd 777 5

4.3 National Grid Plc 779 8

4.4 English Heritage 849 8

4.5 Environment Agency 858 8

4.6 Public Health England 862 9

4.7 Natural England 894 9

Brief Introduction (for a full introduction see Volume 1)

Norfolk County Council has provided comment on selected Relevant Representations (RRs) as follows:-

The comment are provided in 6 volumes as follows:-

Volume 1 – Introduction, and lists of contents for Volumes 2 to 6 Volume 2 – Comment on RRs grouped in 9 key topics Volume 3 – Comment on RRs from Districts & Parish Councils & Meetings - Councillors - Political groups 3

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Volume 4 – Comment on RRs from Statutory Organisations Volume 5 – Comment on RR’s from Landowners (and Agents on their behalf) Volume 6 – Comment on RRs from Non-Statutory Organisations and selected RRs from other interested parties

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Applicant’s comment on Relevant Representations

4.1. Norwich Airport Limited (RR 700)

Representation

NIA and Norfolk County Council have been using and will continue to use all reasonable endeavours to resolve a number of significant adverse impacts of the NDR upon essential airport operations in order to safeguard the continued safe provision of Air Navigation Services and the operation of its landholdings.

Applicant’s comment

4.1.1. The applicant is currently developing a Statement of Common Ground (SOCG) with Norwich Airport Limited.

4.2. Network Rail Infrastructure Limited (RR 777)

Representation

A detailed representation was received from Network Rail Infrastructure Limited which has not been fully reproduced here.

Applicant’s comment

4.2.1. The applicant is currently developing a SOCG with Network Rail.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Representation

All of Network Rail’s operational land is owned by Network Rail Infrastructure Limited. To the extent that the draft DCO purports to affect Network Rail Limited, this representation is also to be treated as an objection by Network Rail Limited.

Applicant’s comment

4.2.2. Norfolk County Council (NCC) notes the comment about the relationship between Network Rail Limited and Network Rail Infrastructure Limited. NCC acknowledges that protective provisions will be required for Network Rail.

4.2.3. The draft Development Consent Order (DCO) will be updated through the examination process and the issues raised will be considered and incorporated where appropriate.

Representation

Network Rail will press, both in representations and in submissions at hearings, the absolute need for protective provisions to be included in a DCO where Network Rail’s operational infrastructure is affected by the proposal.

Applicant’s comment

4.2.4. Discussions are proceeding with Network Rail, as to the appropriate protective provision clauses to include within the DCO. An “in principle” agreement has been reached and a draft set of the clauses is shortly to be sent to Network Rail for it to consider.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Representation

Turning to the specifics of the proposals, we have previously submitted proposals to the County about alternative means of addressing level crossing closures and locations of bridges.

Applicant’s comment

4.2.5. At a meeting on 2 July 2012, Network Rail expressed a desire to close the level crossing at Green Lane East / Broad Lane. It was explained that total closure of the crossing would result in severance of the properties to the south-east of the railway from the rest of the village. Network Rail’s view is that closing the crossing to motorised traffic but leaving it open to pedestrians would not be acceptable and agreed a footbridge would be a better solution. NCC explained that providing a footbridge at the current level crossing location would prove difficult, as there is limited space for access ramps and also that the elevated deck would affect the privacy of adjacent properties. Network Rail suggested that locating a footbridge in the field to the south may be an option to avoid blight to the adjacent properties. This could link up with the proposed footway/ cycleway that passes in front of the west abutment to the proposed railway bridge. This was considered by NCC but it was felt that due to safety issues the closure of Broad Lane at the junction with the Plumstead Road would be the preferred option. . Although this is not the best option for Network Rail, the preferred option will result on there being a significant reduction in the volume of traffic using the level crossing.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

4.3. National Grid Gas Plc (RR 779)

Representation

A detailed representation was received from National Grid which has not been reproduced here.

Applicant’s comment

4.3.1. The applicant is currently developing a SOCG with National Grid Gas.

4.4. English Heritage (RR 849)

Representation

We have considered the application documents and have no objections to the proposed scheme. We hope that where the Environmental Statement has identified impacts on heritage assets these will be properly addressed and where necessary mitigated.

Applicant’s comment

4.4.1. The Applicant has noted this representation.

4.5. Environment Agency (RR 858)

Representation

A detailed representation was received from the Environment Agency which has not been reproduced here.

Applicant’s comment

4.5.1. The applicant is currently developing a SOCG with the Environment Agency.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

4.6. Public Health England (RR 862)

Representation

The current documentation does not appear to address the possible EMF impacts which may arise from the proximity, installation or relocation of any high voltage electricity supplies, substations or similar.

Applicant’s comment

4.6.1. No high voltage installations are being installed or relocated as part of the Scheme. Therefore, there are no Electric & Magnetic Field (EMF) effects identified as a result of the scheme.

4.7. Natural England (RR 894)

Representation

A detailed representation was received from Natural England which has not been reproduced here.

Applicant’s comment

4.7.1. The applicant is currently developing a SOCG with Natural England.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

The Norfolk County Council (Norwich Northern Distributor Road (A1067 to A47(T))) Order

Applicant’s comment on Relevant Representations Volume 5 - Landowners

Planning Act 2008

Infrastructure Planning

The Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009

PINS Reference Number: TR010015

Document Reference: NCC/EX/4

Author: Norfolk County Council

Version Date Status of Version 0 11th July 2014 Final

Norwich Northern Distributor Road Document Reference: NCC/EX/4

This page has been left intentionally blank

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Contents

Ref Name RR Page

5.1 Glen Taylor 26 6

5.2 L E Thomson on behalf of Mr & Mrs Arnold 38 6

5.3 L E Thomson on behalf of Blanmar 1 39 7

5.4 L E Thomson on behalf of Blanmar 2 41 8

5.5 Charles Birch on behalf of C Bunn 89 8

5.6 Charles Birch on behalf of Mr & Mrs G Black 294 9

Charles Birch on behalf of Trustees of Gurloque 5.7 295 10 Settlement

Charles Birch on behalf of Mrs S Bransom on behalf 5.8 296 10 of Mrs Barrett

Charles Birch on behalf of The Trustees of the 5.9 297 11 Thorpe and Felthorpe Trust

5.10 Charles Birch on behalf of Mrs S Bransom 298 11

5.11 Charles Birch on behalf of Mr Bransom 303 12

5.12 Charles Birch on behalf of Rachel Foley 305 12

5.13 Charles Birch on behalf of Nicholas Waller-Barrett 306 13

5.14 Charles Birch on behalf of Mr M & Miss J Keeler 307 14

Charles Birch on behalf of Mr & Mrs L Howe and Mr 5.15 308 14 N Howe

Charles Birch on behalf of Mr A Medler c/o Mrs S 5.16 309 15 Alston

Charles Birch on behalf of Mr M A Dewing on behalf 5.17 310 16 of the E M and E J Dewing Settlement

Charles Birch on behalf of Hilary Barratt and Mr 5.18 Michael Dewing on behalf of the Trustees of the 312 16 Beeston Estate

5.19 Charles Birch on behalf of June Brooks 313 17

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Charles Birch on behalf of Mr A J Papworth on behalf 5.20 314 18 of Mr M F Trafford

5.21 Charles Birch on behalf of Mr Karl Basey 315 18

5.22 Mr Duncan 316 19

5.23 Charles Birch on behalf of P Basey 317 19

5.24 Clive Scott 442 20

5.25 Jim Papworth on behalf of Michael Trafford 472 20

5.26 Lawson Howe 584 22

5.27 Drayton Farms Ltd 648 23

5.28 Jason Cantrill on behalf of David and Sally Jacobs 652 24

5.29 Ifield Estates 725 24

5.30 Tracey Burton 781 25

5.31 Mr T Shaw 792 25

5.32 Sidney Cowell on behalf of Scrone Ltd 802 26

5.33 Tim Place – M.D Frontbench Ltd 809 26

5.34 Roly Beazley on behalf of RG Carter Will Trust 817 27

Christopher Fairlie Bond on behalf of The Howe 5.35 850 27 Family

5.36 Mrs V A Smith (t/a S J Smith) 852 27

Charles Birch on behalf of R E T Gurney and S E 5.37 856 28 Gurney & Partners

5.38 David Hooper on behalf of Russell Nicholls 859 29

5.39 Rachel Foley on behalf of Horsford Estate 883 29

5.40 Alan Irvine on behalf of W R & P J Tann 951 30

5.41 Alan Irvine on behalf of P Key Esq 957 31

5.42 Alan Irvine on behalf of Mr & Mrs D Jacobs 959 32

Norwich Northern Distributor Road Document Reference: NCC/EX/4

5.43 Alan Irvine on behalf of J Blake Esq 960 32

5.44 R & J M Place Ltd / Frontbench Ltd 1161 33

5.45 Nigel Handley R G Carter Farms Ltd 1165 33

5.46 Michael Dewing 1197 34

Brief Introduction (for a full introduction see Volume 1)

Norfolk County Council (NCC) has provided comment on selected Relevant Representations (RRs) as follows:-

The comment are provided in 6 volumes as follows:-

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Applicant’s comment on Relevant Representations

5.1. Glen Taylor (RR 26)

Representation

Due to the position of my land, I would like to know if access would be compromised by the exits leading from the new roundabout on the A1151 Wroxham Road.

Applicant’s comment

5.1.1. See entries for Book of Reference Plot No 9/15 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

5.2. L Thomson on behalf of Mr & Mrs Arnold (RR 38)

Representation

On behalf of a landowner client affected by the scheme it is my intention to make a representation with respect to how the detailed provisions of the scheme cater for my client's continued use of its land holding.

Applicant’s comment

5.2.1. Detailed representations are awaited although Norfolk County Council (NCC) is in contact with the landowner’s representative to try and agree any necessary accommodation works. See entries for Book of Reference Plot No’s 2/5 and 2/6 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

Norwich Northern Distributor Road Document Reference: NCC/EX/4

5.3. L Thomson on behalf of Blanmar 1 (RR 39)

Representation

A full representation will be made on behalf of my landowning client once the details submitted by the developer for a development consent order have been analysed, and a request is made for a written representation to be considered by the examination public.

Applicant’s comment

5.3.1. Detailed representations are awaited although NCC is in contact with the landowner’s representative to agree any necessary accommodation works. See entry for Book of Reference Plot No 9/34 in the F Compulsory Purchase Report (Document Ref NCC/Ex/1).

Representation

However my client's primary concern is that revised access arrangements to the land continue to provide a right of way usable “for all purposes” and to a width as currently enjoyed; also it cannot be good public policy for the footpath, bridleway and access road to co-incide

Applicant’s comment

5.3.2. NCC is satisfied that given anticipated types and levels of traffic movements along Newman Road its design proposals for a shared use facility are appropriate in this location.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

5.4. L Thomson on behalf of Blanmar 2 (RR 41)

Representation

Identical points to those raised in RR39.

Applicant’s comment

5.4.1. Refer to Para 5.3.1 and 5.3.2 above.

5.5. Charles Birch on behalf of C Bunn (RR 89)

Representation

The Norwich Distributor road cuts across the interested party's land. Rather than acquire only the property required for the road, the proposals allow to acquire nearly all of the enclosure to the north and to the south of the highway corridor for drainage attenuation and landscaping.

Applicant’s comment

5.5.1. The Norwich Northern Distributor Road (NDR) is more than just the carriageway itself and the provision of lagoons and landscaping are integral parts of the scheme. It is acknowledged that the landowner’s holding comprises a single field extending to approximately 7.43 hectares (18.35 acres) and that the proposed permanent acquisition extends to 7.12 hectares (17.59 acres). In addition there is a temporary use of a further 0.06 hectares (0.15 acres).

5.5.2. If the land acquisition were approved as submitted it would leave the landowner with only 0.31 hectares (0.76 acres) or some 4% of their original landholding. NCC has offered to acquire the entire field.

5.5.3. See entries for Book of Reference Plot No 1/7 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Representation

The drainage attenuation could be located elsewhere but the authority refuses to engage in discussions to realign or to relocate it.

Applicant’s comment

5.5.4. The majority of this land parcel is proposed to be used for infrastructure in the form of a roundabout and two drainage lagoons. The landscaping on the remainder of the land parcel forms part of an integrated landscape and ecological mitigation strategy for the scheme and is considered essential in this location for both habitat creation and visual amenity purposes.

5.6. Charles Birch on behalf of Mr & Mrs Black (RR 294)

Representation

The two access points on the north side of the NDR should remain passable during and after construction. It will be necessary to replace the current fence with an appropriate alternative and to fence the eastern boundary at the time of the realignment. It will be necessary to replace the current hedge with an appropriate alternative at the time of the realignment. The boundary on the eastern side of the land taken should also be planted with a hedge as a long term screen.

Applicant’s comment

5.6.1. See entries for Book of Reference Plot No 1/3 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

5.6.2. Negotiations with the landowner’s representative have progressed such that it is proposed that the access points will remain during and after construction and the line of acquisition will be fenced and a hedge planted.

5.6.3. With regard to the remaining eastern boundary of the affected field this is not directly affected by the scheme but the Applicant is willing to consider 9

Norwich Northern Distributor Road Document Reference: NCC/EX/4

filling in any gaps along the boundary with hedging as part of the land acquisition and compensation negotiations.

5.7. Charles Birch on behalf of Trustees of Gurloque Settlement (RR 295)

Representation

Summary - A detailed representation with respect to access arrangement/provision and boundary treatment was received on behalf of Trustees of Gurloque Settlement.

Applicant’s comment

5.7.1. See entries for Book of Reference Plot No’s 2/19 and 2/20 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

5.7.2. Responses to the issues raised are given in Appendix X (Ref DC012) of the Pre-application Consultation Report (Document Ref 5.1).

5.8. Charles Birch on behalf of Mrs S Bransom on behalf of Mrs Barrett

(RR 296)

Representation

Summary - A detailed representation with respect to access arrangement/provision and boundary treatment was received on behalf of Mrs Barrett.

Applicant’s comment

5.8.1. See entries for Book of Reference Plot No 3/8 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

5.8.2. Negotiations with the landowner’s representative have progressed such that it is proposed that the line of acquisition will be fenced and a hedge planted.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

5.8.3. Response to the roundabout access issue is covered in Appendix U (Ref IT022) of the Pre-application Consultation Report (Document Ref 5.1).

5.9. Charles Birch on behalf of The Trustees of the Thorpe and Felthorpe Trust (RR 297)

Representation

Summary - A representation with respect to boundary treatment and plantation woodland was received on behalf of The Trustees of the Thorpe and Felthorpe Trust which has not been reproduced here.

Applicant’s comment

5.9.1. See entries for Book of Reference Plot No 3/11 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

5.9.2. Responses to these issues are covered in Appendix U (Ref DC022) of the Pre-application Consultation Report (Document Ref 5.1).

5.10. Charles Birch on behalf of Mrs Bransom (RR 298)

Representation

Summary - A detailed representation with respect to access arrangement/provision, land ownership, quantity of land take and boundary treatment was received on behalf of Mrs S Bransom.

Applicant’s comment

5.10.1. See entries for Book of Reference Plot No’s 3/19 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

5.10.2. Responses to the issues raised are given in Appendix U (Ref IT028) and Appendix X (Ref DC018) of the Pre-application Consultation Report (Document Ref 5.1).

Norwich Northern Distributor Road Document Reference: NCC/EX/4

5.11. Charles Birch on behalf of Mr Bransom (RR 303)

Representation

Summary - A detailed representation with respect to access arrangement/provision and boundary treatment was received on behalf of Mr B Bransom

Applicant’s comment

5.11.1. See entries for Book of Reference Plot Nos 3/24 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

5.11.2. Responses to the issues raised are given in Appendix U (Ref IT027) and Appendix X (Ref DC016) of the Pre-application Consultation Report (Document Ref 5.1).

5.12. Charles Birch on behalf of Rachel Foley (RR 305)

Representation

Summary - A detailed representation with respect to boundary treatment, access arrangement/provision, landscaping, embankment height, farming operation travel times, irrigation and proposed lagoon 6 was received on behalf of Mrs R Foley

Applicant’s comment

5.12.1. See entries for Book of Reference Plot Nos 4/23 and 4/26 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

5.12.2. Responses to the issues raised are given in Appendix U (Ref IT033) and Appendix X (Ref DC027) of the Pre-application Consultation Report (Document Ref 5.1).

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Representation

The embanked area north-west of the Holt Road roundabout should be raised in level as high as possible to reduce the impact from the roundabout in noise and visual terms.

Applicant’s comment

5.12.3. The embanked area north-west of the Holt Road will be raised to provide maximum benefits to resident both in terms of landscape and noise effects allowing for structural integrity. Please see Document Ref 3.1 Draft Development Consent Order for the details and Chapter 7 Landscape and Chapter 11 Noise of the Environmental Statement (Document Ref 6.1) for the associated assessments.

Representation

Drainage attenuation lagoon 6 must be relocated on the basis that it fits in to the scheme layout better on the west of the junction than the east.

Applicant’s comment

5.12.4. The lagoon is located in the optimum position. The landscape areas and lagoons have been designed with regular shaped boundaries to maximise the amount of retained land that can be farmed once the scheme has been constructed. The request to review the shape of the lagoon is currently being investigated.

5.13. Charles Birch behalf of Mr Waller-Barrett (RR 306)

Representation

Identical points to those raised in RR305.

Applicant’s comment

5.13.1. Refer to Para 5.12.1 to 5.12.4 above.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

5.14. Charles Birch on behalf of Mr & Mrs Keeler (RR 307)

Representation

Summary - A detailed representation with respect to access arrangement/provision, boundary treatment and works compound was received on behalf of Mr M and Miss J Keeler.

Applicant’s comment

5.14.1. See entries for Book of Reference Plot Nos 5/40 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

5.14.2. Responses to the issues raised are given in Appendix U (Ref IT021) and Appendix X (Ref DC014) of the Pre-application Consultation Report (Document Ref 5.1).

5.15. Charles Birch on behalf of the Mr & Mrs L Howe and Mr N Howe

(RR 308)

Representation

Summary - A detailed representation with respect to effect on property and interested parties, embankment height, works compound location, access arrangement/provision, severance and land drainage was received on behalf of Mr and Mrs L Howe and Mr N Howe.

Applicant’s comment

5.15.1. See entries for Book of Reference Plot Nos 6/5 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

5.15.2. Responses to the issues raised are given in Appendix U (Ref IT025) and Appendix X (Ref DC013) of the Pre-application Consultation Report (Document Ref 5.1).

Norwich Northern Distributor Road Document Reference: NCC/EX/4

5.15.3. The landscaping provided is to give maximum benefits to residents both in terms of landscape and noise effects allowing for structural integrity. Please see Document Ref 3.1 Draft Development Consent Order for the details and Chapter 7 Landscape and Chapter 11 Noise of the Environmental Statement (Document Ref 6.1) for the associated assessments.

5.16. Charles Birch on behalf of Mr A Medler c/o Mrs S Alston (RR 309)

Representation

Summary - A detailed representation with respect to effect on farming operations access arrangement/provision, boundary treatment and drainage lagoon was received on behalf of Mr A Medler c/o Mrs S Alston

Applicant’s comment

5.16.1. See entries for Book of Reference Plot Nos 6/10 and 6/11 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

5.16.2. Responses to the issues raised are given in Appendix U (Ref IT024) and Appendix X (Ref DC010) of the Pre-application Consultation Report (Document Ref 5.1).

Representation

Realign the drainage lagoon to leave a sensible portion and shape of retained land. We presume this will be situated alongside the NDR towards the roundabout with the bridleway located between the NDR and the drainage lagoons.

Applicant’s comment

5.16.3. The request to review the shape of the lagoon is currently being investigated.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

5.17. Charles Birch on behalf of Mr M A Dewing on behalf of the E M and E J Dewing Settlement (RR 310)

Representation

Summary - A detailed representation with respect to access arrangement/provision, boundary treatment and land impact during works was received on behalf of E M and E J Dewing Settlement

Applicant’s comment

5.17.1. See entries for Book of Reference Plot No 7/16 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

5.17.2. Responses to the issues raised are given in Appendix U (Ref IT031) and Appendix X (Ref DC011) of the Pre-application Consultation Report (Document Ref 5.1).

5.18. Charles Birch on behalf on behalf of Hilary Barratt and Mr Michael Dewing on behalf of the Trustees of the Beeston Estate (RR 312)

Representation

Summary - A detailed representation with respect to access arrangement/provision, boundary treatment, quantity of land take, severance, landscaping drainage and noise was received on behalf of the Trustees of the Beeston Estate.

Applicant’s comment

5.18.1. See entries for Book of Reference Plot Nos 7/30 and 7/32 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

5.18.2. Responses to the issues raised are given in Appendix U (Ref IT052) and Appendix X (Ref DC024) of the Pre-application Consultation Report (Document Ref 5.1).

Norwich Northern Distributor Road Document Reference: NCC/EX/4

5.18.3. The applicant will fence landscaping areas including lagoons. Future ownership and maintenance of landscaping areas can be discussed as part of the land acquisition negotiations.

5.18.4. All landscaping is part of an overall plan for the Scheme, as detailed in the Environmental Statement Volume 1. Chapter 7 (Document Ref 6.1). The landscaping plan has been undertaken with specific sensitive receptors in mind, both ecological and human therefore any reduction must be considered in relation to the required mitigation for the Scheme.

5.19. Charles Birch on behalf of June Brooks (RR 313)

Representation

Summary - A detailed representation with respect to boundary treatment, landscaping, access arrangement/provision and embankment height was received on behalf of Mrs J Brooks.

Applicant’s comment

5.19.1. See entries for Book of Reference Plot Nos 9/4 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

5.19.2. Responses to the issues raised are given in Appendix U (Ref IT023) and Appendix X (Ref DC020) of the Pre-application Consultation Report (Document Ref 5.1).

Norwich Northern Distributor Road Document Reference: NCC/EX/4

5.20. Charles Birch on behalf Mr A J Papworth on behalf of Mr M F Trafford

(RR 314)

Representation

Summary - A detailed representation with respect to embankment height, landscaping, access arrangement/provision, noise and farming operations was received on behalf of Mr M F Trafford.

Applicant’s comment

5.20.1. See entries for Book of Reference Plot No 9/10 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

5.20.2. Responses to the issues raised are given in Appendix U (Ref IT030) and Appendix X (Ref DC023) of the Pre-application Consultation Report (Document Ref 5.1).

5.21. Charles Birch on behalf of Karl Basey (RR 315)

Representation

Summary - A detailed representation with respect to access arrangement/provision, boundary treatment, landscaping and noise was received on behalf of Mr K Basey

Applicant’s comment

5.21.1. See entries for Book of Reference Plot No 9/24 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

5.21.2. The response to the issue raised concerning a new access is given in Appendix X (Ref DC003) of the Pre-application Consultation Report (Document Ref 5.1). The review of this alternative access is now being investigated.

5.21.3. Boundary fencing and associated planting will be considered as part of the accommodation work discussions with the land owner.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

5.22. Mr Duncan (RR 316)

Representation

We are the owners of land and buildings at Newman Road Rackheath The issues we need to register with you about our property are :-how our land will be effected and it's access during and after construction. Also the effects on our tenant and their ability to continue trading during and after the scheme.

Applicant’s comment

5.22.1. See entries for Book of Reference Plot No 10/14 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

5.23. Charles Birch on behalf of P Basey (RR 317)

Representation

Access will be affected by combining it with a much used bridleway and highway crossing, so a new private access from the Wroxham Road is required. The current access will then need to be closed off with suitable fencing.

Applicant’s comment

5.23.1. Responses to the issues raised are given in Appendix X (Ref DC003) of the Pre-application Consultation Report (Document Ref 5.1).

5.23.2. NCC does not consider that the existing access off Wroxham Road needs to be closed and can remain operational with the proposed equestrian crossing.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

5.24. Clive Scott (RR 442)

Representation

I have been contacted to tell me that my house is going to be impacted and uninhabitable doing the building work. My only real wish here is that this is all completed ASAP as this whole process has been hanging over our heads for several years now. We just want to move and start life again elsewhere.

Applicant’s comment

5.24.1. See entries for Book of Reference Plot No 10/53 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

5.24.2. Mr and Mrs Scott have served a Blight Notice which was received by the County Council on 27 May 2014. The Notice was accepted by the Council on 6 June 2014. Negotiations are underway to agree the purchase price and the Council will work with the Scotts and their professional advisors to finalise the acquisition of the property at the earliest opportunity.

5.25. Jim Papworth on behalf of Michael Trafford (RR 472)

Representation

We are very concerned that insufficient attention has been given to reducing the impact of the noise resulting from the proposed development.

Applicant’s comment

5.25.1. The effects on Landscape, Air Quality, Noise, Water and Drainage, Ecology, Agricultural Land, Carbon and the Community are presented within the Environmental Statement (Document Ref. 6.1). The ES presents the findings of the Environmental Impact Assessment (EIA) and details the effects of the Scheme, both adverse and beneficial.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

5.25.2. An overall view of the results of the EIA is presented in the Non- Technical Summary (Document Ref 6.3) Section 16 provides a Summary of Effects. The detailed analysis and assessments are presented within Volume 1 of the ES (Document Ref 6.1) the technical reports that support these assessments can be found in Volume 2 of the ES (Document Ref 6.2).

5.25.3. The proposed Scheme incorporates measures to prevent, reduce and where possible offset environmental impacts from the earliest stage of the project. Specific details of the proposed mitigation measures are included in the individual topic sections of the ES. The proposed measures were designed according to statutory and non-statutory guidance and the DMRB to provide proposals that are proportionate to the significance of the relevant effect. Such mitigation measures are set out in the requirements in the applied for Development Consent Order and NCC is committed to delivering them as an integral part of the proposed Scheme.

Representation

We are extremely concerned that the mitigation measures proposed provide sufficient safety measures to protect the water entering into a head of the Broads area from polluting the whole eco-system.

Applicant’s comment

5.25.4. The proposed Scheme incorporates measures to prevent, reduce and where possible offset environmental impacts from the earliest stage of the project.

5.25.5. Specific details of the proposed mitigation measures for the protection of surface water are included in Volume 1 Chapter 14 of the NDR ES. The proposed measures were designed according to statutory and non- statutory guidance and the DMRB to provide proposals that are proportionate to the significance of the relevant effect. Such mitigation 21

Norwich Northern Distributor Road Document Reference: NCC/EX/4

measures are set out in the requirements in the applied for Development Consent Order and NCC is committed to delivering them as an integral part of the proposed Scheme.

5.25.6. In addition the Habitats Regulations Assessment has considered any potential effects on protected sites and species. This has been undertaken in consultation with Natural England and the Environment Agency who have the responsibility for the protection of the Wensum SAC and surface and groundwater.

Representation

We are aghast at the proposal to close Crostwick Lane and fail to see how we can farm the Trafford Estate with this closure in place.

Applicant’s comment

5.25.7. It is accepted that access may in some cases be less convenient but it will be possible via the public highway. The reason for the closure is primarily to improve highway safety at the junction as closure of Rackheath Lane will simplify turning movements allowing drivers waiting at the Crostwick Lane arm to concentrate on the vehicle movements on the main road.

5.26. Lawson Howe (RR 584)

Representation

Similar points to those raised by agent in RR308.

Applicant’s comment

5.26.1. Refer to Para 5.15.1 to 5.15.2 above.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

5.27. Drayton Farm Limited (RR 648)

Representation

The proposed road should take a different route along the Reepham Road to the north of Holly Lane, Horsford to the junction with Fir Covet Road, Taverham. The proposed road closures are flawed. Holly Lane, Horsford should not be closed off together with others. The road will bisect our land holding.

Applicant’s comment

5.27.1. The Environmental Statement (Document Ref. 6.1) explains in Section 3.8 (paragraphs 3.8.23 to 3.8.26) that prior to the County Council adopting a preferred route for the NDR in September 2005 consultation on alternative routes was carried out in 2003, 2004 and 2005.

5.27.2. These consultations are summarised in Appendix B of the Pre- application Consultation Report (Document Ref. 5.1). Design development is explained in section 2.2 of the Design and Departures Report (Document Ref 10.2). Paragraph 2.2.6 explains that environmental assessment was undertaken in parallel with all stages of scheme development.

5.27.3. This assessment work involved a comprehensive desk study assessment of a wide variety of possible options and was reported in a Stage 1 Environmental Assessment, dated January 2003. This work informed development of route options for public consultation. The use of Reepham Road as part of a potential route for the NDR was identified in the January 2003 report but was not taken forward for further assessment. A key factor would have been the proximity of the route to Thorpe Marriott.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

5.28. Jason Cantrill on behalf of David and Sally Jacobs (RR 652)

Representation

Access to retained property to the west of the NDR. Stopping up of Low Road, Little Plumstead.

Applicant’s comment

5.28.1. Responses to the issues raised are given in Appendix U (Ref IT043) of the Pre-application Consultation Report (Document Ref 5.1).

5.28.2. The justification for the acquisition of all land required for the NDR is given in the Statement of Reasons (Document Ref 4.1).

5.29. Ifield Estates (RR 725)

Representation

This application deals with the compulsory acquisition of land where there already exists a specific agreement between the authorities and the Land owner. This specific agreement needs to be recognised as taking precedence.

Applicant’s comment

5.29.1. NCC acknowledges that there is a legal agreement in place which gives NCC access to areas of land but does not agree that it can take precedence over the DCO. At the time the application was submitted the parcels of land affected remained in the freehold title of the current landowner, not NCC. This remains the case even though works on the Postwick Hub have now commenced since the land transfer to NCC will not occur until the construction works are completed. Until such time as the legal transfer is completed the powers to acquire the plots must remain within the DCO.

5.29.2. The justification for the acquisition of all land for the NDR is given in the Statement of Reasons (Document 4.1). 24

Norwich Northern Distributor Road Document Reference: NCC/EX/4

5.29.3. The DCO application had to assume the scenario of the legal agreement between NCC and landowner/option holder would not be completed. Appropriate rights of acquisition were therefore sought. If, through the completion of the Postwick Hub scheme and land transfers under the legal agreement applicable to that scheme, land is no longer required then it will not be acquired under the DCO.

5.30. Tracey Burton (RR 781)

Representation

The proposed ‘Scheme’ directly affects land held by Legislator 1657 Ltd, a company co-owned by Norfolk County Council and Norwich City Council.

Applicant’s comment

5.30.1. See entries for Book of Reference Plot No 5/41 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

5.31. Mr T Shaw (RR 792)

Representation

The issues we need to register with you about our property are how the land will be effected and it's access during and after construction. The effects on our tenant and their ability to continue trading during and after the scheme.

Applicant’s comment

Refer to Para 5.22.1 above

Norwich Northern Distributor Road Document Reference: NCC/EX/4

5.32. Sidney Cowell on behalf of Scrone Limited (RR 802)

Representation

Our concern, is that the line of the NDR blocks off the right of way access to Gazebo Covert and potentially leaves it land locked. We have had several meetings and have forwarded our suggestions to the NCC but to date, this issue has not been resolved.

Applicant’s comment

5.32.1. NCC disagree that the land will be land locked as alternative access will be provided via plot X47h as shown on Street Plan Sheet 10 (Document Ref 2.4). Extending the PMA as suggested by Mr Cowell would impact on land in third party ownership. Extending the access was discussed with the third party landowner who was not supportive of this proposal.

5.33. Tim Place – M.D Frontbench Ltd (RR 809)

Representation

We are directly effected landowners and wish to continue discussions to make sure that our issues are resolved.

Applicant’s comment

5.33.1. See entries for Book of Reference Plot No 10/27 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

Norwich Northern Distributor Road Document Reference: NCC/EX/4

5.34. Roly Beazley on behalf of RG Carter Will Trust (RR 817)

Representation

We continue to negotiate with NPS on various aspects of the scheme.

Applicant’s comment

5.34.1. See entries for Book of Reference Plot No 4/3 in the Compulsory Purchase Report (Document Ref NCC/Ex/1.

5.35. Christopher Fairlie Bond on behalf of The Howe Family (RR 850)

Representation

This is the minimum price payable for the land irrespective of the area actually purchased. Should the area purchased exceed 0.537 acres the price will be increased pro rata to take into account the additional land. 90% of the price to be paid prior to entry being taken to the land.

Applicant’s comment

5.35.1. No land is proposed to be acquired from this party.

5.36. Mrs V A Smith (t/a S J Smith) (RR 852)

Representation

I am the tenant of land situated off the Plumstead Road. I need clarification of access to the field both during and after construction of NDR so that I can plan my farming activities.

Applicant’s comment

5.36.1. See occupier entry for Book of Reference Plot No 10/49 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

Norwich Northern Distributor Road Document Reference: NCC/EX/4

5.37. Charles Birch on behalf of R E T Gurney and S E Gurney & Partners (RR 856)

Representation

The closure of the road junction at Crostwick Lane with the North Walsham Road at Spixworth is very damaging to properties owned nearby and businesses that access the road network through the junction.

Applicant’s comment

5.37.1. It is accepted that access to properties and businesses may in some cases be less convenient but access will be maintained to all properties and businesses via the public highway.

5.37.2. With the NDR providing an appropriate alternative route it is not considered that the minor roads referred to would be utilised by significant through traffic. However, this situation would be monitored post NDR implementation. This point was responded to at IT030 on page 38 of Appendix U of the Pre-application Consultation Report (Document Ref 5.1).

5.37.3. The reason for the closure is primarily to improve highway safety at the junction as closure of Rackheath Lane will simplify turning movements allowing drivers waiting at the Crostwick Lane arm to concentrate on the vehicle movements on the main road.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

5.38. David Hooper on behalf of Russell Nicholls (RR 859)

Representation

The land take involves land with obvious residential development potential and the opportunity to minimise loss of such land has not been fully taken. At Rackheath the land take reduces one field to useless proportions and no account was taken of suggestions to alleviate this problem without prejudice to the scheme.

Applicant’s comment

5.38.1. Responses to the issue raised concerning land at Rackheath are given in Appendix U (Ref IT042 (BoR Plot ref 10/36)) of the Pre-application Consultation Report (Document Ref 5.1).

5.39. Rachel Foley on behalf of Horsford Estate (RR 883)

Representation

Similar points to those raised by agent in RR305.

Applicant’s comment

5.39.1. Refer to Para 5.12.1 to 5.12.4 above.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

5.40. Alan Irvine on behalf of W R & P J Tann (RR 951)

Representation

The application includes land that is the subject of an existing planning application for a Business Park and road scheme that is subject to existing legal agreements. The application takes land from the agricultural holding that is not necessary for the scheme. The application also includes land that has not been the subject of discussions to date and the inclusion of which is not necessary for the application scheme to proceed.

Applicant’s comment

5.40.1. NCC acknowledges that there is a legal agreement in place which gives NCC access to areas of land but does not agree that it can take precedence over the DCO. At the time the application was submitted the parcels of land affected remained in the freehold title of the current landowner, not NCC. This remains the case even though works on the Postwick Hub have now commenced since the land transfer to NCC will not occur until the construction works are completed.

5.40.2. Until such time as the legal transfer is completed the powers to acquire the plots must remain within the DCO.

5.40.3. There is additional land requirements over and above that covered in the separate legal agreement. The justification for the acquisition is given in the Statement of Reasons (Document 4.1).

Norwich Northern Distributor Road Document Reference: NCC/EX/4

5.41. Alan Irvine on behalf of P Key Esq (RR 957)

Representation

The application process should not be used for such unrelated issues.

The proposal to open Middle Road and not provide an agricultural link on Low Road will significantly impact on the viability and efficiency of the farming business.

Applicant’s comment

5.41.1. Proposals at Green Lane West / Wroxham Road junction were identified as a result of comment received during the April/May/June 2012 consultations as detailed in Section 3.3.5 of the Pre Application Consultation Report (Doc 5.1). The scheme proposals and land take implications have arisen from this.

5.41.2. The justification behind provision of the Middle Road bridge is provided in Appendix U (Ref IT032).

Representation

Agricultural traffic will have to use busy parts of the highway network that will impact on the safety of the network and its smooth operation.

Applicant’s comment

5.41.3. It is acknowledged that agricultural traffic would use the network but it is not accepted that this would impact on the safety of the network and its smooth operation. The modern design standards adopted for the NDR and its junctions together with the resultant traffic reduction on other routes would mitigate any congestion caused by agricultural traffic.

Representation

The application proposes to take land that has the benefit of planning permission for business use and housing and the proposed land take will significantly impact on the already approved development potentially making it undeliverable. The application takes more land out of agricultural production than is necessary.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Applicant’s comment

5.41.4. The applicant is currently working with the developer and its consultants to ensure there is an acceptable solution for all parties.

5.41.5. The justification for the acquisition is given in the Statement of Reasons (Document 4.1).

5.42. Alan Irvine on behalf of Mr and Mrs D Jacobs (RR 959)

Representation

The application proposal to open Middle Road and not provide an agricultural link on Low Road will significantly impact on the efficiency and viability of the farming operation. The application includes land that is not necessary for the scheme to proceed, appears unrelated and is not justified.

Applicant’s comment

5.42.1. Refer to Para 5.28.1 to 5.28.2 above

5.43. Alan Ivine on behalf of J Blake Esq (RR 960)

Representation

The application proposal will have an unacceptable impact on the farming operation and does not make best use of the land that it is proposed to take. An alternative use of part of the land in the application proposal would offer wider benefits to the community.

Applicant’s comment

5.43.1. See entries for Book of Reference Plot Nos 2/34 and 2/35 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

5.43.2. Responses to the issues raised are given in Appendix U (Ref IT046) of the Pre-application Consultation Report (Document Ref 5.1). 32

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5.44. R & J M Place Ltd / Frontbench Ltd (RR 1161)

Representation

We continue to negotiate with NPS on various aspects of the scheme.

Applicant’s comment

5.44.1. See entries for Book of Reference Plot Nos 5/33 and 10/27 in the Compulsory Purchase Report (Document Ref NCC/Ex/1).

5.45. Nigel Handley R G Carter Farms Ltd (RR 1165)

Representation

In brief, the NDR should use the Reepham Road from its junction wit Holly Lane, Horsford to its junction with Fir Covet Road, Taverham in an improved capacity rather than construct a new road.

Applicant’s comment

5.45.1. The Environmental Statement (Document Ref. 6.1) explains in Section 3.8 (paragraphs 3.8.23 to 3.8.26) that prior to the County Council adopting a preferred route for the NDR in September 2005 consultation on alternative routes was carried out in 2003, 2004 and 2005.

5.45.2. These consultations are summarised in Appendix B of the Pre- application Consultation Report (Document Ref. 5.1).

5.45.3. Design development is explained in section 2.2 of the Design and Departures Report (Document Ref 10.2). Paragraph 2.2.6 explains that environmental assessment was undertaken in parallel with all stages of scheme development.

5.45.4. This assessment work involved a comprehensive desk study assessment of a wide variety of possible options and was reported in a Stage 1 Environmental Assessment, dated January 2003. This work informed development of route options for public consultation. The use of 33

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Reepham Road as part of a potential route for the NDR was identified in the January 2003 report but was not taken forward for further assessment. A key factor would have been the proximity of the route to Thorpe Marriott.

5.46. Michael Dewing (RR 1197)

Representation

As owners of the xxxx through which the NDR will pass, there are issues of land area required, and injurious affection to the properties situated on the Estate, still to be resolved. In addition, there are matters of provision of roadways to access areas cut off by the road and access during construction, and boundary fencing.

Applicant’s comment

5.46.1. Refer to Para 5.18.1 to 5.18.4 above.

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The Norfolk County Council (Norwich Northern Distributor Road (A1067 to A47(T))) Order

Applicant’s Comment on Relevant Representations Volume 6 - Non-Statutory Organisations & Other Interested Parties

Planning Act 2008

Infrastructure Planning

The Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009

PINS Reference Number: TR010015

Document Reference: NCC/EX/4

Author: Norfolk County Council

Version Date Status of Version 0 11th July 2014 Final

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This page has been left intentionally blank

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Contents

Ref Name RR Page

6.1 Victor Brown 8 5

6.2 The Open Spaces Society 14 6

Anthony Clarke on behalf of Cyclists’ Touring Club 6.3 129 14 (CTC)

6.4 Katy Jones on behalf of Ian Shepherd CPRE 189 20

Peter Wilkinson on behalf of Lothbury Investment 6.5 249 33 Management Ltd

6.6 Building Partnerships Ltd 275 35

6.7 Norfolk Dinosaur Park Ltd 347 36

6.8 Go West Travel t/a Norfolk green 374 37

6.9 Mr Gray on behalf of Drayton Local Community 502 38

6.10 Norfolk Wildlife Trust 533 40

6.11 Patrick Barkham 689 43

6.12 Stop Norwich Urbanisation (SNUB) 691 46

6.13 Campaign for Better Transport 763 55

6.14 Drayton Hall Park Residents 778 68

Campaign for the Protection of Rural England 6.15 836 70 (CPRE)

6.16 Broads Society 864 73

6.17 Visit Norwich Ltd 887 73

Michael Innes on behalf of Norfolk Association of 6.18 895 74 Architects

Eric Kirk on behalf of Wensum Valley Hotel and Golf 6.19 990 75 Club

6.20 Norfolk Living Streets 995 77

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6.21 John Elbro on behalf of Norwich Cycling Campaign 1004 80

6.22 Campaign for Better Transport - East Sussex 1060 80

6.23 Gordon A Denton 1065 81

Norwich and Norfolk Transport Action Group 6.24 1084 82 (NNTAG)

Brief Introduction (for a full introduction see Volume 1)

Norfolk County Council (NCC) has provided comment on selected Relevant Representations (RRs) as follows:-

The comments are provided in 6 volumes as follows:-

Volume 1 - Introduction, and lists of contents for Volumes 2 to 6 Volume 2 - Comment on RRs grouped in 9 key topics Volume 3 - Comment on RRs from Districts & Parish Councils & Meetings - Councillors - Political Groups Volume 4 - Comment on RRs from Statutory Organisations Volume 5 - Comment on RR’s from Landowners (and Agents on their behalf) Volume 6 - Comment on RRs from Non-Statutory Organisations and selected RRs from other interested parties

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Applicant’s comment on Relevant Representations

6.1. Victor Brown (RR 8)

Representation

I am objecting to the proposal to build a bridge over the proposed NDR at Middle Road, Great Plumstead as this will allow rat-run traffic to continue passing through Great Plumstead and deny the residents of Great Plumstead any benefit from the proposed NDR.

Applicant’s comment

6.1.1. During consultations undertaken in April/ May/ June 2012 the scheme proposals included closures of Smee Lane and Middle Road where they meet the NDR, and a Non-Motorised User (NMU) and agricultural vehicle bridge over the Norwich Northern Distributer Road (NDR) at Low Road.

6.1.2. As a result of the consultations, which highlighted concerns that the scheme reduced the number of access options to Great Plumstead, the proposals were amended to provide closures to Smee Lane and Low Road, with an all user bridge being provided over the NDR at Middle Road. Middle Road was identified as the most appropriate road out of these three roads for an all user bridge because it was a better standard than Low Road or Smee Lane.

6.1.3. The revised proposals where presented during the February/ March 2013 consultations and the statutory pre-application consultation undertaken in accordance with the Planning Act 2008. Norfolk County Council (NCC) has given regard to the responses received during both of these consultations and acknowledges the concerns of residents of Middle Road. However, it also needed to consider the wider view of the highway network (including the alternative routes to Middle Road) and on this basis the Middle Road Bridge has been retained as part of the proposal. 5

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6.2. The Open Spaces Society (RR 14)

Representation

The proposed NDR development would create significant, permanent environmental damage. It would have an extremely large, permanent, and gravely adverse impact on the Norfolk countryside. Landscape impacts would be considerable, and severe.

Applicant’s comment

6.2.1. The effects on; Landscape, Air Quality, Noise, Light, Water and Drainage, Ecology, Agricultural Land, Carbon and the Community are presented within the Environmental Statement (ES) (Document Ref. 6.1). The ES presents the findings of the Environmental Impact Assessment (EIA) and details the effects of the Scheme, both adverse and beneficial. An overall view of the results of the EIA is presented in the Non- Technical Summary (Document Ref. 6.3) in which Section 16 provides a Summary of Effects. The detailed analysis and assessments are presented within Volume 1 of the ES (Document Ref. 6.1). The technical reports that support these assessments can be found in Volume 2 of the ES (Document Ref. 6.2).

6.2.2. The proposed Scheme incorporates measures to prevent, reduce and where possible offset environmental impacts from the earliest stage of the project. Specific details of the proposed mitigation measures are included in the individual topic sections of the ES. The proposed measures were designed according to statutory and non-statutory guidance and the Design Manual for Roads and Bridges (DMRB) to provide proposals that are proportionate to the significance of the relevant effect. Such mitigation measures are set out in the requirements in the draft Development Consent Order (DCO) and NCC is committed to delivering them as an integral part of the proposed Scheme.

6.2.3. In addition the Habitats Regulations Assessment (HRA) has considered any potential effects on protected sites and species. This has been undertaken in consultation with Natural England (NE) and the 6

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Environment Agency (EA) who have the responsibility for the protection of the Wensum Special Area of Conservation (SAC). This can be found in Volume 11: Chapter 17 of the ES (Document Ref 6.2). After consultation NE and the EA required clarification and further details on the mitigation required to prevent silt entering the Wensum via the existing road network at the western extent of the Scheme. An addendum is still in draft form and is being reviewed by NE and the EA and this will be made public as soon as the Statutory Bodies have finished the review of the data submitted. It is anticipated this document will be finalised by mid July 2014.

6.2.4. The impact of light pollution is discussed in Volume 1: Chapter 7 of the ES (Document Ref 6.2). The only part of the scheme to include street lighting is Postwick junction. Paragraph 7.7.62 says ‘Night time effects arising from vehicle headlights and the lighting of the Postwick junction are regarded as ‘slight adverse’ for both year 1 and year 15, since the additional lighting will be seen within the context of an already lit and well trafficked junction.’ In further reviewing the DCO application material in considering its response to Relevant Representations, NCC has identified that the Scheme did not include all the street lighting required at Postwick, and in particular on 200 metres of the NDR approach to the Business Park Roundabout. In order to ensure this can be considered by the Examining Authority and interested parties, NCC has therefore produced an Addendum to the NDR Environmental Statement Lighting Assessment (July 2014), see Appendix F. This concludes that there are no significant adverse effects arising from the additional lighting, and no change to the conclusions of the Environmental Statement (Vol 1, Doc. Ref. 6.1).

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Representation

We are concerned that the proposed development would interfere with a large number of rural public rights of way, and other quiet highways, which currently have a high amenity value, necessitating their permanent closures or diversions.

Applicant’s comment

6.2.5. In the majority of instances where a public right of way has been severed an alternative diverted route has been provided. For example alternatives have been provided where the NDR severs the following routes, as shown on the General Arrangement (GA) Plans (Document Ref. 2.6):

. Attlebridge Restricted Byway No 3 (GA Plan Sheet 1 of 12) . Drayton Restricted Byway No 6 (GA Plan Sheet 3 of 12) . Horsford Restricted Byway No 7 (GA Plan Sheet 4 of 12) . Postwick Footpath No 2 (GA Plan Sheet 12 of 12).

6.2.6. There are two public rights of way, as detailed below, that are substantially removed by the proposals but similarly new alternative bridleways have been provided in their place:

. Spixworth Bridleway No 1 (GA Plan Sheet 7 of 12), . Gt/ Lt Plumstead Footpath No 5 (GA Plan Sheet 11 of 12).

6.2.7. In addition where the NDR severs Marriott’s Way and Horsford Restricted Byway No 5 a bridge over the NDR has been provided.

6.2.8. Volume 1, Chapter 13 of The ES (Document Ref. 6.1), overall, the assessment presented within this ES concludes that a Slight Adverse but not significant impact is anticipated for All Travellers during construction for a temporary period, as a result of construction delays, route diversions and the presence of construction plant. However, once the Scheme is operational, it is considered that there would be a Moderate Beneficial and therefore significant impact for All Travellers. This is as a result of reduced traffic and congestion on the majority of radial routes, improved amenity for Non Motorised Users (NMUs) and relief from

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existing severance within and between communities and facilities caused by existing high traffic levels.

Representation

We would oppose the NDR, and the proposed complex revision to the Postwick junction. We feel that there are alternatives that are, not only viable, but would be more effective, less costly, and which would not impact upon the countryside to anything like the same degree as the NDR that is currently being proposed.

Applicant’s comment

6.2.9. The NDR is part of the overall transport strategy for the Norwich area, the Norwich Area Transport Strategy (NATS) which has been devised to address the current and future problems and issues. This is described in detail in the ES (Document Ref. 6.1) which identifies the existing problems and issues and illustrates the conditions on the highway network including traffic flows. Section 3.5 then identifies how the NDR as part of NATS addresses these problems and issues taking account of the planned JCS growth. Sections 3.7 and 3.8 explain how the preferred NATS strategy which includes and NDR was devised. During this process strategies that didn’t include an NDR were assessed but were not selected due to their inability to offer solutions to the full range of problems and issues.

6.2.10. More recently, prior to the DCO submission to the Planning Inspectorate, we have reviewed the previous analysis of options in light of new traffic surveys undertaken in 2012, the final results of the environmental studies, feedback from stakeholders and public consultation and the progress of the JCS to adoption. This included an option that only improved public transport without an NDR and an option making improvements to the existing road network instead.

6.2.11. The conclusion for public transport initiatives was that they are an essential complement to the NDR and key to the implementation of a 9

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sustainable transport policy but, even in combination, they do not constitute an alternative to it. By relieving the radials of traffic, the NDR would help to facilitate the introduction of bus priority measures and an orbital bus service. By freeing the internal road networks of new development areas of the need to cater for extraneous through traffic, better residential environments could be created, which would be more easily penetrated by local bus services and walking and cycling routes.

6.2.12. The conclusion for improving the existing highway network in the urban area was that it would only partly replicate the functions of an NDR and would not resolve many cross city connectivity issues or serve new development. It would unavoidably have a very significant direct and/or indirect physical and environmental impact on many residential and commercial properties, and would require property acquisition and demolition in order to provide the necessary additional highway capacity. It would be likely to face considerable objection, especially from affected occupiers.

6.2.13. Another potentially cost effective alternative to the NDR is Alternative 5 which has been assessed in the Traffic and Economic Appraisal of NDR Alternatives (Document Ref. 5.12). Specifically Section 8 contains an assessment of Alternative 5 which comprises developer link roads extended to enable a route through to the Airport.

6.2.14. Alternative 5 fails to reduce traffic on inappropriate routes and relieve the existing network. The developer link roads would not operate satisfactorily and they would cause particularly severe difficulties in implementing the proposed shared use high street-type design envisaged in the development proposals the delays would also mean that Alternative 5 would fail to meet the improved transport connectivity objective for the Scheme.

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Representation

We are also concerned at the extent to which it would appear to be proposed that the NDR would facilitate new large-scale development of areas of countryside lying to the north of Norwich.

Applicant’s comment

6.2.15. The level of housing and employment provision in the JCS is required to meet the objectively assessed need to support economic, household and population growth. This has been determined by the local plan process which is the appropriate mechanism. The JCS legitimately and appropriately take account of the plans of the transport authority and the highway authority (i.e. NCC) including the proposals for NATS and the NDR. The JCS proposals for growth to the NE of Norwich were subject to examination as recently as 2013 and found sound.

6.2.16. The NDR scheme is identified in the JCS as infrastructure which is fundamental to the strategy set out within the JCS. It is not appropriate to use the DCO examination of the NDR as an opportunity to re-run arguments about whether the JCS planned growth in housing and employment is the appropriate spatial strategy for Greater Norwich. That was a matter that was fully investigated, tested, and settled by the JCS process which had the responsibility of setting the spatial strategy for Greater Norwich.

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Representation

It is understood that the project would cost huge sums of public money – some £89 million from central government and up to £78 million, on top of that, from the people of Norfolk. This money could be spent in significantly more sustainable and less damaging ways, such as long-term investment in rural public transport networks.

Applicant’s comment

6.2.17. The NDR is an essential element of NATS which is a balanced package of measures designed to address existing and future transport problems and issues in the Norwich area. These problems and the development of NATS are set out in Section 3 of the ES (Document Ref. 6.1).

6.2.18. The NDR has a ‘very high’ Benefit to Cost Ratio (BCR), as set out in Document 5.7. Economic Appraisal Report, demonstrating that it is a good use of public funds. Sustainable transport is at the heart of NATS and only so much can be implemented due to existing issues and constraints that the NDR addresses.

Representation

We understand that there is considerable opposition to this damaging scheme, and would urge permission to proceed with the development to be withheld.

Applicant’s comment

6.2.19. The volume of respondents objecting to scheme is considered small when compared to the overall number of people consulted. It is approximately 2% of the 57,000 residential and business addresses sent consultation letters. The proportion of respondents opposed to the scheme is considered a reflection of the area of consultation. i.e. that the consultation focused on the areas most directly affected rather than areas further afield, which are likely to benefit from the NDR and future NATS measures that depend on the NDR. NCC’s own analysis of the Section 47 and 48 consultation responses is contained in Chapter 5 of 12

Norwich Northern Distributor Road Document Reference: NCC/EX/4 the Pre-application Consultation Report (Document Ref. 5.1), with the key issues identified highlighted in Section 5.4.

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6.3. Anthony Clarke on behalf of Cyclists’ Touring Club (CTC) (RR129)

Representation

The scheme does not meet the requirements of national and local government policy to encourage cycling as it will make commuting by cycle to Norwich more dangerous. It will also make leisure cycling to the Broads and the coast more dangerous. This is also contrary to local plans for tourism development.

Applicant’s comment

6.3.1. The needs of cyclists including those addressed as part of the scheme have been developed through consultation with interested parties. During the April/ May/ June 2012 public consultations NCC had various requests for improved walking and cycling facilities as part of the proposals for the NDR. As a result a strategy was developed to consider and prioritise these consultation requests. The strategy published as part of the February/ March 2013 public consultations identified a network of routes to link areas that generate NMU’s (such as villages, employment areas, future development) with each other, the Norwich Cycle Network and the Marriott’s Way. Part of these routes utilised narrow country lanes, roads closed to motor vehicles and existing public rights of way. NCC has prioritised NMU improvements on this network, and these improvements have included new NMU facilities as part of the proposals. Approximately 25 kilometres of new links suitable for use by pedestrians, cyclists and equestrians where permitted would be provided alongside, over, and connecting with, in places, the NDR route, together with improved surfacing provided on some existing rights of way. The scheme includes eight grade separated crossings of the NDR and two grade separated crossings of the A47. Various NMU at grade crossings of NDR and side roads are also proposed. The NMU proposals are shown on the General Arrangement Plans (Document Ref. 2.6).

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6.3.2. NCC has considered requests for cycle improvements and developed a strategy to prioritise these. This included identifying routes that linked communities with Norwich via its agreed Norwich Cycle Network. With specific regard to providing links to the Broads areas, NCC, as part of its Norfolk Trails initiative, has a longer term aspiration to provide a NMU route from Wroxham (as a key tourist destination in the Broads area) and Norwich (by linking into the already agreed Norwich Cycle Network). The exact route for this has not yet been determined but initial examination has identified that it is likely to be located in the corridor between the A1151 Wroxham Road and C283 Salhouse Road. The NDR scheme proposals have provided two grade-separated crossing points of the NDR in this corridor that could be utilised by this route. These are:

(1) Newman Road Bridge, which provides a combined private means of access and bridleway over the NDR,

(2) A bridleway adjacent to the Norwich to Sheringham railway line, between Green Lane East and Plumstead Road, which passes under the NDR Bridge (Over Railway Line).

Representation

The traffic information does not take into account Department for Transport guidelines and Local Transport plans to study and report on non-motorised transport.

Applicant’s comment

6.3.3. The DCO submission includes a Transport Assessment (Document Ref. 5.5). This document details the existing NMU provision in section 6.5 of the report and the proposed mitigation measures are explained in sections 6.12 and 6.13.

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Representation

The scheme does not meet the requirement for sustainability demanded for funding from central government, the plans for buses are vague and not guaranteed and are subject to whims and cuts by Norfolk County Council at any time.

Applicant’s comment

6.3.4. NCC has approval from government to fund the scheme appropriate to the stage which the project is at (see funding approval letter from DFT 15 December 2011)

6.3.5. A considerable amount of NATS measures including bus improvements have already been implemented across Norwich as a result of the NATS strategy, having such a well developed strategy and implementation plan has enabled Norfolk County Council to be successful in bidding for central government funding. For example most recently Better Bus Access (BBA) which has seen bus improvements delivered across the Norwich network and specifically on the Dereham Road BRT corridor. NCC has been successful in a £5.5m bid for implementation of the Norwich Pink Pedal way of its cycle network (published in July 2012, and forming part of the NATS Implementation Plan adopted in April 2010).

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Representation

The traffic forecast for the NDR and roads to Norwich is inadequate as it does not properly take into account the full extent of the traffic growth from the 30000+ houses planned for the area which could generate 100,000 car journeys per day. The promoters of this scheme seek to persuade the public that people will drive east west along the NDR when everybody knows that the major traffic flow is and will be in the future North South to Norwich which is the centre for work, shopping, education, entertainment, health and other services. This will overload the roads into Norwich and put cyclists at risk.

Applicant’s comment

6.3.6. Traffic forecasts have been made in accordance with DfT guidance set out in WebTAG and has taken account of the full implementation of the JCS. The forecast traffic includes all the generated traffic from the development sites in Norwich, South Norfolk and Broadland. This is set out in section 5 of the Traffic Forecasting Report (Document Ref. 5.6).

6.3.7. The traffic modelling takes account of the full range of existing and forecast travel across Norwich, both radial and orbital movements. NDR results in reductions in traffic on inappropriate routes and reductions in traffic on the radial routes into the city centre. These impacts are explained in Section 7 of the Traffic Forecasting Report (Document Ref. 5.6).

Representation

The costs of the scheme, and it's associated works, are vague and should be subject to an independent audit.

Applicant’s comment

6.3.8. The assessment of the economic benefits has followed a recognised methodology. Sections 5.4 and 5.5 of the Economic Appraisal Report

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(Document Ref 5.7) provides a detailed economic analysis of the transport benefits and the Value for Money (VfM) using DfT’s criteria.

6.3.9. The scheme delivers a BCR of 4.17 inclusive of accident benefits and a BCR of 5.33 when wider economic benefits and journey time reliability are included. Both of these figures represent very high value for money (i.e. for a BCR above 4) according to DfT’s VfM criteria.

6.3.10. Funding for the NDR project has been agreed by NCC Cabinet. This includes details of the funding sources and the value underwritten by the County Council, which is supported by an in principle agreement that up to £40m Community Infrastructure Levy (CIL) income can be used towards the project.

Representation

The Government has responded to the "Get Britain Cycling" report by All Party Parliamentary Cycling Group by stating that all future developments will be "Cycle Proofed". While we wait to hear what exactly this will mean in practical terms I have no doubt that the current NDR plans will not meet this requirement.

Applicant’s comment

6.3.11. The All Party Parliamentary Cycling Group (APPCG) conducted an Inquiry in Spring 2013 looking at the state of cycling in Britain. A summary report “Get Britain Cycling” was published in April 2013, which outlined 18 recommendations. These recommendations included:

. A statutory requirement that cyclists’ and pedestrians’ needs are considered at an early stage of all new development schemes,

. Local authorities should seek to deliver cycle-friendly improvements across their existing roads, including small improvements, segregated routes, and road reallocation.

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6.3.12. A cross-departmental 'Cycle Delivery Plan', promised in the Government's response to the Get Britain Cycling report, is due out later in 2014.

6.3.13. Refer to para 6.3.1 above.

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6.4. Katy Jones on behalf of Ian Shepherd Campaign to Protect Rural England (CPRE) (RR 189)

Representation

The NDR is primarily a facilitator of excessive housing development.

Applicant’s comment

6.4.1. Refer to Para 6.2.15 and 6.2.16 above.

Representation

The Greater Norwich Development Partnership’s JCS states that there will be an increase in the population in the Norwich Policy Area by at least 50,000 people. Yet a large percentage of the houses that this road purports to facilitate are not needed. CPRE Norfolk demonstrated at the re-hearing of the GNDP in July 2013 that given latest household projection statistics, there is a projected over-supply of 11,000 homes in the GNDP area; a figure which was accepted by the GNDP.

Applicant’s comment

6.4.2. It is incorrect to suggest that the Greater Norwich Development Partnership (GNDP) local authorities accepted at the 2013 examination that the JCS housing provision represents an over-supply. The authorities provided evidence to the JCS examination to demonstrate that housing provision in the adopted JCS remained appropriate to meet locally assessed need. Inspector Vickery concluded “The GNDP figures indicate that the adopted JCS total still lies comfortably within the range of various projections based on completion extrapolations, affordable housing requirements, and population and economic figures [Table 1 of SDJCS 14 and TP 13]”. [Report to Broadland District Council, Norwich City Council and South Norfolk District Council, November 2013 paragraph 40]. (Appendix E) He concluded that “overall the housing totals and modified Housing Trajectory represent a realistic, balanced, deliverable, justified and soundly based set of figures which would meet 20

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the objectively assessed housing needs over the plan period” (ibid. paragraph 80).

Representation

The NDR will increase traffic movements in and around the city of Norwich and as such, the Norwich Policy Area developments will generate hundreds of thousands of new traffic movements a day in and round Norwich, much of this associated with the NDR. Far from reducing traffic, the NDR would increase traffic on all radial roads and most parishes will experience higher flows mainly due to the massive development plans and recent proposals for specific site allocations.

Applicant’s comment

6.4.3. Traffic forecasts have been made in accordance with DfT guidance set out in WebTAG. This process derives future year trip matrices for different types of trip purpose and separately for home-based trips and non-home-based trips. This is discussed in Vol 1 section 5.10 of the Traffic Forecasting Report (Document Ref. 5.6). These trips include all the generated traffic from the development sites in Norwich, South Norfolk and Broadland. The trip purposes consist of home-based trips which are forecast for a 24 hour time period and non-home-based trips which are forecast separately for each of the modelled time periods, the AM peak, Interpeak and the PM peak. Tables 5.19 to 5.22 of the forecasting report show these references forecast demands.

6.4.4. For home-based trips, the total number of trips increase from 208,731 in 2012 to 223,207 in 2017 (an increase of 7%) and to 262,090 in 2032 (an increase of 26%). The growth in non-home based trips from 2012 base year to the future year of 2017 is estimated to be around 6% to 7%, while 2032 is forecast to be around 16% to 23% (the figures vary for each time period). In terms of freight, HGVs are forecast to grow at 2% up to 2017,

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and 19% up to 2032. LGV trips are forecast to increase by 10% from base year to 2017 and by 55% from base year to 2032.

6.4.5. Analysis of the forecast traffic has indicated that the total number of trips made is expected to be largely unchanged as a result of the NDR. This is documented in paragraph 6.5.3 in the Traffic Forecasting Report (Document Ref. 5.6), which forecasts the increase in vehicle trips subject to the variable demand modelling to be around 0.2% with the NDR, or around 100 trips in each of the one hour model periods. It should be noted that this assumes the same JCS reference development in both the scenarios with and without the scheme and it therefore identifies the impact of the NDR in this context.

6.4.6. The traffic flows forecast with the NDR are compared to those without the Scheme in the Traffic Forecasting Report (Document Ref. 5.6) in Vol. 3 Figures I.1 to I.4. These show that there are increases on some radial routes in the vicinity of where they connect with the NDR. However the Transport Assessment (Document Ref. 5.5) shows in section 8.5 that the NDR junctions are considered to operate acceptably well. Furthermore the Traffic Forecasting Report in Vol. 1 Section 7 describes the reductions in traffic in other parts of the network with NDR. In particular traffic would be reduced in the suburban area, including on radial routes, and on inappropriate routes that are currently used by orbital traffic movements.

6.4.7. Thus the forecasts show that there is expected to be significant increases in traffic, especially in connection with the development proposals, but that the NDR alone will result in a small increase in trips.

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Representation

Environmental Impact: Most of the route for the NDR and related housing developments would be on greenfield land. Hundreds of acres of productive agricultural land will be permanently lost.

Applicant’s comment

6.4.8. The effects on Landscape and Agricultural Land are presented within the ES (Document Ref. 6.1). The ES presents the findings of the EIA and details the effects of the Scheme, both adverse and beneficial.

6.4.9. An overall view of the results of the EIA is presented in the Non- Technical Summary (Document Ref. 6.3) Section 16 provides a Summary of Effects. The detailed analysis and assessments are presented within Volume 1 of the ES (Document Ref. 6.1). The technical reports that support these assessments can be found in Volume 2 of the ES (Document Ref. 6.2).

6.4.10. Temporary effects that were identified for individual farm businesses were temporary land-take during construction and severance of fields and irrigation systems. This land will be fully restored to agricultural use once construction is completed and the mitigation put in place for construction is similar to mitigation for the operational phase of the Scheme.

6.4.11. When the criteria for assessment are applied there is a significant effect resulting from the loss agricultural land as a local resource. However, this assessment should be considered in relation to current farming practices and the benefits arising from a potential increase in biodiversity from intensively farmed land lost to habitat creation.

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Representation

A Road of National Importance?: The NDR has been consistently presented as a distributor road to promote housing developments North East of Norwich, and reduce traffic on the radial roads and through the villages. However a Ministerial statement made in July 2013 indicated separate agenda between Norfolk County Council and the Government which envisaged a wider role for the NDR. This should be clarified by the Inquiry and discussed.

Applicant’s comment

6.4.12. Section 2.7.4 to 2.7.8 of the Pre-application Consultation Report (Document Ref. 5.1) outlines NCC’s reasoning for its view that the NDR is a development for which development consent is required. This includes a chronology of events prior to the application for a DCO being made, which states that in December 2012, the applicant decided to promote the NDR as a Nationally Significant Infrastructure Project (NSIP). At that time the NDR fell within the definition of a NSIP set out in Section 22(2) of the Planning Act 2008 (as it then was) because it included works to the Postwick junction of the A47(T) and was to be constructed for a purpose connected with the A47(T).

6.4.13. Publication of the notice stating where and when the SOCC could be inspected took place on 21 June 2013 and on 28 June 2013, with the first publication exhibition held on 8 July 2013. The Section 48 Notices were published on 12 July 2013 and 19 July 2013. The programme of public exhibitions ran until 12 August 2013. Section 42 consultation letters were issued on 30 July 2013 and representations under all three strands of consultation were invited until 20 September 2013. Further information on the consultation is set out in the rest of the Consultation Report.

6.4.14. On 24 July 2013 the Highway and Railway (Nationally Significant Infrastructure Project) Order 2013 (S.I. 2013/1883) (the Highways Order) was made and the Order came into force on 25 July 2013. This was

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some weeks after the start of the statutory consultation process referred to above. The Order amended Section 22 of the Planning Act 2008 so that a project such as the NDR would not (from 25 July 2013 onwards) fall within the definition of a NSIP. The Secretary of State made the Direction on 9 August 2013. The effect of the Direction on the validity of the pre-application consultation is set out at sections 2.7.1 to 2.7.3 and 2.7.10 to 2.7.17 of Document Ref. 5.1.

6.4.15. On 25 July 2013, the applicant submitted a qualifying request to the Secretary of State for a direction under Section 35(1) of the Planning Act 2008 that the NDR was a project of national significance and so should be treated as development for which development consent was required.

Representation

A waste of taxpayers’ money: The NDR from Postwick to Attlebridge will cost nearly £142 million; any extension will cost tens of millions of pounds more. At a time when central and local government is cutting public services, this level of spending in one unwelcome and unnecessary road shows poor financial acuity.

Applicant’s comment

6.4.16. Refer to Para 6.3.8 and 6.3.10 above.

6.4.17. The County Council cannot switch funding from one budget to another and cannot spend government funding allocated to the NDR on other projects or services.

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Representation

NCC has denied receiving responses to the consultation from CPRE Norfolk and other objectors, despite unequivocal evidence that they were received.

Applicant’s comment

6.4.18. NCC received over 1400 responses to its consultations under Section 47 of the Planning Act, which commented on a wide range of issues associated with the NDR proposals. NCC is aware that three submissions made by Norwich Green Party, CPRE and SNUB were on the balance of probabilities received but unfortunately were not logged. In respect of these submissions, the Planning Inspectorate has concluded that the points raised in them had been raised by other consultees and therefore are covered in the Consultation Report. A legal point raised about the changes to the legislation during the consultation process was addressed in any event in the Consultation Report (Document Ref. 5.1) sections 2.7.1 to 2.7.3 and 2.7.10 to 2.7.17. In addition there will be further opportunity for these comments to be considered during the examination process.

6.4.19. The County Council’s Head of Procurement carried out an extremely thorough investigation, and although he was unable to arrive at a definitive view as to what happened, NCC have apologised to the Green Party, SNUB and CPRE. The full report, Review into missing submissions to Norwich Northern Distributor Road consultation process, is included in Appendix A.

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Representation

They have failed to clearly identify support/opposition to the scheme in their application to PINS (January 2013). Independent analysis of the consultation responses shows that the Council has under-played the level of opposition to the scheme by manipulating/incorrectly coding the data.

Applicant’s comment

6.4.20. Refer to Para 6.2.19 above.

Representation

The evidence base on which the NDR is proposed is flawed insofar that it fails to fully interrogate either the role of local/light rail in facilitating local movement needs or the role of the Inner Link Road in serving to open up development in this area.

Applicant’s comment

6.4.21. The consideration given to the potential role of local heavy rail and light rail during the 2002-2005 NATS Review and subsequently is documented in Section 3.8 of Chapter 3 of Volume 1 of the ES (Document Ref. 6.1).

6.4.22. Heavy Rail - The potential of local heavy rail services to play a role in facilitating local movement needs is limited by the geography of the rail network within the Norwich Policy Area (NPA).

6.4.23. The only rail stations, other than Norwich, within the NPA are:

. Brundall and Brundall Gardens on the Wherry Lines to Great Yarmouth and Lowestoft;

. Salhouse on the Bittern Line to Sheringham; and

. Wymondham on the line to Ely.

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6.4.24. Additional rail stations within the NPA to the east of Norwich have been considered as potential NATS interventions and this is documented in the 2005 NATS Options Assessment Report, which makes the following comment:

“An additional rail station provides an additional travel choice and can contribute to improving accessibility into the city centre and delivering modal shift. Depending on the exact site of the station, this intervention could contribute to economic vitality (Broadland Business Park) or assist growth in the north east sector (Dussindale), although both these areas have good bus links to the city centre. A station at Postwick is likely to provide few benefits for the NATS area that are not provided by the present Park and Ride service, although it would create potential for Park and Rail for travel to Great Yarmouth and Lowestoft.”

6.4.25. Even allowing for the possibility of new stations, a very small percentage of the population of the NPA would have access to a heavy rail service for local travel. A heavy rail option thus could not make a significant contribution to the objectives set for the NDR scheme or represent an alternative to building an NDR.

6.4.26. Light Rail - In 2003 a study was undertaken on Light Rapid Transit Study for Norwich as part of the evidence base to inform the review of NATS which led to the adoption of a revised NATS including the NDR. Modes considered included guided bus, ultra light rail and tram. The study considered conceptual route options, with appraisal undertaken to examine outline economic feasibility of preferred route and mode options.

6.4.27. The 2003 study informed the work on strategy options documented in the 2005 NATS Options Assessment Report and is referenced within this report in Section 4.3.1. These included light rail as a strategy option, which was recommended for rejection on affordability and financial sustainability grounds.

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6.4.28. Further consideration was given to light rail in 2007 - 2008 during the development of public transport options for the NDR Major Scheme Business Case MSBC). Four options were assessed against the NATS and NDR objectives, including:

6.4.29. Option 2A - A Bus Rapid Transit (BRT) system linking key housing and employment growth locations and the city centre, complemented by road user charging or workplace parking charging within the Inner Ring Road, implementation of physical measures to remove through traffic from the city centre and improvements to junctions on the Inner and Outer Ring Roads.

6.4.30. Commentary on this option - “This option is proposed as a more affordable alternative to the light rapid transit option considered and appraised during the 2002-2004 NATS Review. If a light rail option is likely to be discarded on affordability and financial sustainability grounds, it would be appropriate to consider BRT as an intermediate mode between conventional bus and light rail. “

6.4.31. Option 2B - A Light Rail Transit (LRT) system linking key housing and employment growth locations and the city centre, complemented by road user charging or workplace parking charging within the Inner Ring Road, implementation of physical measures to remove through traffic from the city centre and improvements to junctions on the Inner and Outer Ring Roads.

6.4.32. Commentary on this option - “There is a case to be made that sufficient work has already been done on this option to justify discarding it on affordability and financial sustainability grounds, but it has been retained at this stage of the process to enable a comparative assessment of Bus Rapid Transit and Light Rail Transit.”

6.4.33. The assessment concluded that Options 2A and 2B performed similarly against both the NATS and NDR objectives and thus Option 2A (Bus Rapid Transit) should be preferred over Option 2B (Light Rail) on

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grounds of practicality and affordability, as it was considered that BRT was more likely than LRT to be economically viable to serve a city of the scale of Norwich.

6.4.34. It is thus possible to demonstrate that the potential for light rail was considered at a strategy level during the period 2003-2005 and prior to the adoption of a revised NATS including the NDR. Light rail was also considered at a plan level as a potential alternative to the NDR during the preparation of the MSBC. The outcome of this process was the inclusion of proposals for Bus Rapid Transit within the NATS Implementation Plan in preference to Light Rail Transit, with BRT being identified as complementary to the NDR rather than an alternative to it.

6.4.35. Inner Link Road / Alternatives - Chapter 3 of Volume 1 of the ES (Document Ref 6.1) explains the consideration given to potential alternatives. Section 3.15 discusses Alternative 5 which comprises developer link roads between radials (within the growth areas).

6.4.36. Further analysis using the DCO transport model for alternatives is provided in The Traffic and Economic Appraisal of NDR Alternatives (Document Ref 5.12). Section 8 of the report provides an analysis for Alternative 5 and conclusions are summarised in Section 9.

6.4.37. Alternative 5 (developer link roads) singularly fails to reduce traffic on inappropriate routes and relieve the existing network. Whilst the Alternative includes the city centre traffic management measures the reductions of cross city centre traffic are much smaller compared with the DCO Scheme, especially for trips crossing the Outer Ring Road Cordon. The junction analyses show that North Walsham Road and Wroxham Road junctions would operate substantially over their theoretical capacity with long queues and delays, with delays of over 10 minutes at North Walsham Road Junction in the 2032 AM peak, and 5 minutes in the 2032 PM peak. On these grounds the developer link roads would not operate satisfactorily and they would cause particularly severe difficulties in

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implementing the proposed shared use high street-type design envisaged in the development proposals.

6.4.38. For the Beyond Green planning permission for North Sprowston, Old Catton the development is proposed to provide an internal east west street which will ultimately span four radial routes from St Faiths Road to Wroxham Road. All the roads within this development, including the east west route, will have a 20mph speed limit to make it easier for pedestrians to cross streets at any point. Speeds will be kept low through design rather than enforcement, using features such as short lengths of street between junctions, narrow carriageways, on street parking, limiting forward visibility and the use of shared space on some tertiary streets.

6.4.39. The Norwich Area Transportation Strategy sets out to reduce rat running in north Norwich. This is explained in 3.5.4 (policies 5 and 6) of the ES (Document Ref 6.1) and it would not be possible to achieve this without an alternative to serve these movements given the constraints in the network which are explained in section 3.4.

Representation

NCC’s consultation document fails to give information about the size and location of developments that the NDR purports to serve and also omits to include data on present or projected traffic volumes.

Applicant’s comment

6.4.40. The level of housing and employment provision in the JCS is required to meet the objectively assessed need to support economic, household and population growth. This has been determined by the local plan process which is the appropriate mechanism.

6.4.41. The precise locations of the JCS growth in the northeast of Norwich will be set out in an Area Action Plan to be produced by Broadland District Council.

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6.4.42. The existing problems on the transportation network in the Norwich area have been assessed and future problems and issues predicted. The overall transport strategy for the Norwich area, NATS which includes an NDR, has been devised to address the current and future problems and issues. This is described in detail in Section 3 of the Environmental Statement (ES) (Document Ref 6.1).

6.4.43. During the public consultations on the NDR, present and projected traffic flows were presented for two scenarios. One reflected the best estimate as to where the JCS growth might occur (details of this can be seen in the Document Ref 5.6 Traffic Forecasting Report: Volume 2 – Appendices C to F) and another presented data for a dispersed growth scenario reflecting a more conservative set of traffic volumes.

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6.5. Peter Wilkinson on behalf of Lothbury Investment Management Ltd (RR 249)

Representation

The development of the road will compromise access to the existing Broadland Business Park, owned by my client.

Applicant’s comment

6.5.1. Whilst there will be some temporary disruption to traffic movements during the actual construction of the Scheme, access will be maintained to the Broadland Business Park at all times and after completion of the Scheme access and capacity will be enhanced.

Representation

The development will compromise the potential to develop part of the land upon which my client has a legal interest.

Applicant’s comment

6.5.2. Although Lothbury Investment Management Ltd has a subsoil interest in Plot 12/31, it is in fact already part of the public highway. This section of the highway will be improved and will continue to form part of the public highway. The County Council has included other sections of highway land within the Book of Reference to ensure that all interested parties are informed of the scheme proposals and for consistency would not wish to remove this particular plot from the Book of Reference. However, should the DCO be confirmed by the Secretary of State the County Council would not seek to exercise its powers to compulsorily acquire Lothbury Investment Management Ltd’s interest in this plot of land.

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Representation

The development could also compromise the ability of my client to develop a valid planning permission no 20090886 as the critical road access could be compromised.

Applicant’s comment

6.5.3. This is covered in the response given in Appendix U (Ref IT045) of the Pre Consultation Report (Document Ref. 5.1).

6.5.4. The applicant is currently working with the developer and its highway consultants to find an acceptable solution for all parties.

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6.6. Building Partnerships Limited (RR 275)

Representation

The NDR scheme in this area does not provide a suitable access from the proposed northern roundabout into the site to accord with the JCS and likely BDC allocation.

Applicant’s comment

6.6.1. The JCS does not specifically allocate this site or a location adjacent to the junction for employment use. The JCS identifies the need for a new business park of around 30ha associated with the Airport and focussed on uses benefitting from an airport location. The role of the NDR is to provide strategic access and sufficient capacity for planned growth; local site access is the responsibility of the developer.

6.6.2. As part of the NDR scheme an additional arm is proposed from the northern roundabout to maintain access to fields affected by the scheme but this unlikely to be sufficient for large scale development. If a developer wishes this to be upgraded to suit a development proposal, NCC would consider this but the cost of any enhancement will need to be met by the developer.

6.6.3. In addition to the above the applicant is also currently developing a Statement of Common Ground (SOCG) with Building Partnerships Limited.

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6.7. Norfolk Dinosaur Park Ltd (RR 347)

Representation

We have serious concerns about the implications that this proposal has in relation to the lack of a link to the A47 resulting in the minor roads between the NNDR where it joins the A1067 and the A47. A public consultation was held in 2007 identified that this route is already a 'rat run' where some improvements have been made however the NDR will compound this further for traffic going to and from North Norfolk from the west of Norwich.

Applicant’s comment

6.7.1. Vol 1 Section 7 Paragraph 7.1.8 to 7.1.14 of the Traffic Forecasting Report (Document Ref. 5.6) analyses the traffic impacts at the western end of the NDR in the vicinity of Taverham and Drayton and especially the impact on traffic crossing the Wensum Valley.

6.7.2. This shows that the NDR leads to a decrease in daily traffic on the routes that connect the A1067 with the A47(T) to the west of Norwich of 6% in 2017 and 4% in 2032 as shown in Table 7.1. Highway and traffic management improvements will be in place where there is a predicted increase in traffic on the western part of the corridor (between Lenwade / Weston Longville and Hockering).

6.7.3. In Figure I.3 in Vol 3 of the Traffic Forecasting Report (Document Ref. 5.6) site A54 shows there would be a forecast reduction with the NDR on the A1067 Fakenham Road.

6.7.4. These model outputs do not support the assertion that the Scheme would ‘dump’ traffic on communities in Taverham and Drayton.

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6.8. Go West Travel t/a Norfolk Green (RR 374)

Representation

Will there be funds supplied to allow for the provision of bus services that will incur additional mileages making current routes impractical or will there be funding for new routes to accommodate the villages.

Applicant’s comment

6.8.1. There will be no specific funds made available for the provision of bus services that may incur additional mileage as a result of potential route changes following completion of the NDR. Reviews are carried out regularly in terms of looking at the provision of bus services to towns and villages and this process will continue. Any additional mileage that may be incurred will be counteracted by congestion benefits from reduced running time in the greater Norwich area and improvements to journey time reliability.

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6.9. Mr Gray on behalf of Drayton Local Community (RR502)

Representation

We strongly object to closure of C282 Drayton Lane, south of its junction with Reepham Road. This means the main link between Drayton and the NDR would be via a dangerous route along C261 Reepham Road, U57141 Hall Lane (north) and their junction, all with recorded and unrecorded accidents and serious hazards to road users.

Applicant’s comment

6.9.1. An amendment to the DCO Scheme has been promoted to address this issue by keeping Drayton Lane South open. Refer to the report 'Proposed Minor Change to the Application for Development Consent: Drayton Lane (south)' (Document Ref. 5.13).

Representation

We have also determined that no proper Safety Audits have been carried out on any of the roads and junctions away from the NDR footprint that will be affected by the new road. Both the flawed modelling and lack of safety audits could well affect the whole NDR and surrounding areas.

Applicant’s comment

6.9.2. The Scheme has been the subject of a number of road safety audits carried out by independent audit teams in accordance with NCC procedures and the DMRB HD 19/03 Road Safety Audit. The audits are scheduled on pages 3 and 4 of Road Safety Audits and Briefs (Document Ref 10.1).

6.9.3. The audits comprise an evaluation of all works that involve construction of new highways or permanent change to the existing highway layout or features in accordance with the guidance in paragraph 1.15 and 1.17 of HD19/03 and this includes the junctions of radial routes with the Scheme

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and any off-line improvements proposed on these radial routes. Road safety audit is an ongoing process and further audits will be carried out as the scheme progresses through detailed design, completion of construction and post construction monitoring.

6.9.4. In addition to the formal road safety audit process Chapter 10 of the Transport Assessment (Document Ref 5.5) includes a high level Personal Injury Collision (PIC) data analysis carried out as part of a wider road safety review of the Scheme. This analysis considers all the principal routes in the study area, and identifies accident cluster sites. It then identifies the changes in traffic flow on the approaches to a cluster site junction and then provides a commentary on the likely implications for each site as a result of the Scheme. The conclusions of this analysis can be found in paragraphs 10.6.1 to 10.6.5 of the Transport Assessment (Document Ref. 5.5). Where cluster sites are subject to forecast increases in traffic with the Scheme NCC will monitor these sites on a quarterly basis. This regular investigation of the detailed accident records will determine whether the road environment was a factor and what, if any, measures could be implemented to improve road safety.

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6.10. Norfolk Wildlife Trust (RR 533)

Representation

In our view the NDR should only proceed if it can be clearly shown that all impacts on biodiversity can be completely mitigated for and that there is enhancement of biodiversity, as set out in the NERC Act 2006.

Applicant’s comment

6.10.1. The proposed Scheme incorporates measures to prevent, reduce and where possible offset environmental impacts from the earliest stage of the project. Specific details of the proposed mitigation measures are included in the individual topic sections of the ES (Document Ref. 6.1). The proposed measures were designed according to statutory and non- statutory guidance and the DMRB to provide proposals that are proportionate to the significance of the relevant effect. Such mitigation measures are set out in the requirements in the applied for DCO and NCC is committed to delivering them as an integral part of the proposed Scheme.

6.10.2. Refer to Para 6.2.4 above.

Representation

We are particularly concerned that completion of the currently proposed NDR will lead to moves to complete the link to the A47, across the Wensum Valley. Current decisions by Norfolk County Council to commission a new study on the Wensum Crossing route make it clear that there is a real threat that a new proposal will come forward.

Applicant’s comment

6.10.3. A road linking the A1067 and the A47(w) would have to cross the Wensum Valley, which is designated a SAC under the European Directive on the Conservation of Natural Habitats and of Wild Fauna and

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Flora - often referred to as the Habitats Directive. An assessment of options across the Wensum Valley concluded, in 2005, that significant impacts on the SAC would be likely, and there was doubt as to whether, under the terms of the Habitats Directive, it would be possible to design an acceptable scheme. This in turn raised the prospect that consent for a wider scheme including such a link might not be granted. On 19 September 2005, the applicant’s Cabinet resolved to have no NDR link between the A47(w) and the A1067. It therefore did not form part of the adopted route. At its meeting of 16 September 2013 the meeting of the NCC resolved to recommend to Cabinet that they submit an application for a DCO in respect of the NDR as proposed (i.e. between the A47 at Postwick and the A1067 near Attlebridge) and to also commission a report on a feasibility study of providing a link across the Wensum Valley from the A1067 to the A47(w).

6.10.4. Whilst at its meeting of 7 October 2013 the applicant’s Cabinet resolved that a “scoping report on the feasibility of providing a link across the Wensum Valley from the A1067 – A47 be written once consultation work was completed”, this study has not been carried out and there is therefore currently no proposal establishing the form any link between the A1067 and A47(w) would take, or indeed whether any such link is feasible. The NDR is in no way dependent on a link from the A1067 to the A47(w) and can be assessed (and has been assessed) as a stand- alone scheme on its own merits. Any proposals for a link to the A47(w) would be a matter for separate assessment on their own merits if and when any such proposals were put forward. The Transport Assessment for the NDR (Document Ref 5.5.) shows that the NDR can provide substantial benefits without a further link between the A1067 and A47(w) and that the NDR will reduce daily traffic on existing routes between the A1067 and the A47(w) between Drayton/Taverham and Costessey. The NDR is therefore in no way dependent on the provision of such a link. The feasibility and environmental acceptability of a link to the A47(w)

Norwich Northern Distributor Road Document Reference: NCC/EX/4 have not been established and the previous assessment in 2005 discarded this option. Accordingly, it is the position of the applicant that the NDR can and should be considered on its own merits without such a link.

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6.11. Patrick Barkham (RR 689)

Representation

I do not believe adequate Environmental Impact studies have been undertaken to properly assess the disastrous environmental consequences of this road. In particular, as the author of The Butterfly Isles and an authority on butterflies, I am concerned at the road's impact on butterflies living and breeding on land and trees which will be lost to the road, in particular White-letter Hairstreaks and White Admirals on land to the north of Norwich.

Applicant’s comment

6.11.1. Butterfly species have been addressed under assessment of impacts and overall effects on terrestrial invertebrates, within Chapter 8 of the ES (Document Ref 6.1). Assessment of terrestrial invertebrate populations were carried out by focusing on assessing the value of the habitats along the route of the NDR. This was carried out with a view to assessing the likely impacts and informing appropriate compensation measures, including habitat creation. The focus was to consider the wider importance of the landscape for terrestrial invertebrates, and not individual species.

6.11.2. This was proposed in the Scoping Report; refer to Vol. 1 Appendix 4. of the ES (Document Ref. 6.1) No objections to this approach were received from NE. The comment below from NE is taken from the Scoping Opinion:

6.11.3. “We are satisfied that all necessary protected species surveys have been listed in the scoping report, and note the extensive ecological surveys that have been undertaken to date, particularly in relation to bats. We are satisfied with the further surveys proposed in the report.”

6.11.4. This proposed survey methodology was informed by more detailed invertebrate surveys that took place in 2007 and were updated in 2010. These surveys did not identify any notable populations of invertebrate

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species within the Zone of Influence. However, it was still felt important to identify those habitats with the potential to support terrestrial invertebrate assemblages of conservation importance so that they can be mitigated for appropriately. The survey comprised a habitat suitability assessment of the area within the Zone of Influence, considering the potential to support both particularly diverse assemblages (relative to the surrounding habitat) and assemblages that may contain specialised and potentially rare species. The habitats present along the route were surveyed in the field during a walkover of the whole length of the proposed Scheme route by an ecologist using knowledge and experience to identify features of particular importance to terrestrial invertebrates.

6.11.5. Addressing the issue of the species mentioned in the Representation, high level, brief research shows that the White-Letter Hairstreak (Satyrium w-album) primarily uses Elms of various species as this is the primary larval food source, and ruderal habitats with bramble, hogweed, ragwort etc., as the primary adult food source. The route of the proposed Scheme does not affect particularly large areas of these habitats, so the direct impacts are minimal. White Admiral (Limenitis Camilla) is a woodland species, with larvae and adults using honeysuckle, with adults also feeding on bramble, umbellifers and thistles. Whilst these latter, ruderal species are not uncommon, honeysuckle is not particularly abundant within the footprint of the proposed scheme. As with the above, the direct impacts should be minimal.

6.11.6. Impact on both of these species are therefore minimised by the careful routing of the proposed Scheme, with the majority of the footprint taking in arable land of low ecological value, and with sections through other habitats positioned and oriented to minimise land take as far as is practically possible.

6.11.7. A detailed assessment on the effects of butterflies can be found in the Volume 1, Chapter 8, Sections 8.3 (Methodology) and 8.6 (Impact 44

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Assessment) and Volume 2, Chapter 8, Section K Terrestrial Invertebrate Survey Report of the ES (Document Ref. 6.1)

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6.12. Stop Norwich Urbanisation (SNUB) (RR 691)

Representation

The NDR is linked to the discredited Joint Core Strategy (JCS) as it provides the infrastructure to access the proposed 10,000 new homes in the North East Growth Triangle (NEGT).

Applicant’s comment

6.12.1. The JCS is an adopted plan that underwent the proper statutory local plan processes, including a thorough examination process and consultation, and was found sound by independent government inspectors. This is the appropriate mechanism for such development strategies. The JCS legitimately and appropriately takes account of the plans of the transport authority including the proposals for NATS and the NDR. The JCS proposals for 10,000 dwellings in the growth triangle were subject to examination as recently as 2013 and found sound.

Representation

The Community Infrastructure Levy (CIL) generated from the planned construction of these homes is meant to be allocated towards the funding of the NDR to close the £60m gap between government funding and the ESTIMATED COST. Norfolk County Council (NCC) have needed to make cuts of circa £150m which have been provided from cutting front line services to vulnerable local residents.

Applicant’s comment

6.12.2. The County Council has agreed the funding arrangements for the difference in funding between the government contribution and the cost of the scheme (Cabinet Report Nov 2013) Appendix D sets out that the total cost of the scheme is £148.55m; government grant is £86.5m; growth point funding £1.71m; and that the county council will underwrite £60.34m, with £40m of this committed in principle from the GNDP.

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6.12.3. The adopted Joint Core Strategy identifies in Appendix 7 a range of infrastructure to support planned growth. Through the Greater Norwich City Deal Agreement that has been reached between the local authorities in the area, to pool CIL and put this towards a programme of strategic infrastructure. The strategic infrastructure programme includes NDR, Green Infrastructure, sustainable transport, education and other important infrastructure required for the development of the area. The NDR is an important element of infrastructure to support the growth plans and allows the full range of sustainable transport interventions to be put in place. Having an agreed programme of strategic infrastructure allows decisions to be made so that the full programme can be delivered in a timely fashion, all of which is important to support planned growth.

6.12.4. The County Council cannot spend government funding allocated to the NDR on other projects including training schemes, affordable housing projects, improving the A47 and reducing councils’ budget cuts. In any case, the A47 is a trunk road and so the Council is not responsible for the funding of it, and the county council would not be responsible for the budgets of other councils.

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Representation

The JCS is flawed as the latest report from the Planning Inspectorate stated in their summation that the remitted elements of the JCS i.e. the NEGT was only legally sound if major modifications were made. Two of these were significant modifications concerning the lack of a five year land supply and the ability of the Average Build Rate to be increased to meet the JCS targets. If, as we believe, these modifications are not achieved, and there is no sign that they will be achieved, then the JCS remains unsound and will never achieve the desired objectives and therefore negating the need for the NDR.

Applicant’s comment

6.12.5. The JCS is adopted and is a sound plan. As a result of discussions at the examination two policies were added to the plan. Policy 21 is based on the Planning Inspectorate’s model policy reflecting the NPPF and is required in an appropriate form in all local plans. Policy 22 relates to the monitoring of land supply and future actions in relation to maintaining a 5 year supply of housing land. As stated in JCS supporting text Paragraph 7.20 this largely reflects the delay in delivering key infrastructure serving the Broadland part of the NPA since the original adoption of the JCS in 2011. The NDR and the Postwick junction improvement are identified as the key infrastructure that impacts on delivery in the previous section (Paragraphs 7.11-7.18). Policy 22 will not apply until 2 full years of monitoring after adoption i.e. later in 2016 and after the conclusion of this NSIP process. If there is a future shortfall in housing supply, Policy 22 requires the identification of additional land, not the review of the “NEGT”. The potential need to identify additional housing land has no significant impact on the need for the NDR.

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Representation

This is not a distributor road in the sense that is does not distribute traffic but allows access.

Applicant’s comment

6.12.6. The NDR is a distributor road and designed to address existing overcapacity issues in the north of Norwich and enable the implementation of the full range of sustainable transport measures that comprise the Norwich Area NATS. The strategic modelling work shows that the NDR achieves these objectives of resolving existing overcapacity issues and enabling NATS.

6.12.7. The Scheme would provide a main distributor road function. In doing so it will facilitate access to new areas of housing and employment development whilst keeping those areas free of extraneous traffic. In this way the Scheme meets key objectives.

Representation

The environmental damage has not been assessed correctly as the construction removes hectares of food producing agricultural land from the UK food chain

Applicant’s comment

6.12.8. Refer to Para 6.2.1 to 6.2.4 above.

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Representation

The viability of Norwich International Airport and its so called justification for making the NDR nationally significant. The owners of the airport are in serious financial difficulties and the local management of the airport have openly admitted that passenger numbers are falling as is revenue.

Applicant’s comment

6.12.9. Although the NDR provides improved connectivity to Norwich International Airport and its adjacent industrial areas, this is not its only function. It is required to enable the implementation of the full range of sustainable transport measures that comprise NATS.

Representation

The lack of statutory and current safety audits on all of the arterial link roads and roads that access the proposed NDR.

Applicant’s comment

6.12.10. Refer to Para 6.9.2 to 6.9.4 above.

Representation

The pollution (noise, light and exhaust gas) on local residents as the additional 50,000 daily car journeys are completed.

Applicant’s comment

6.12.11. Refer to Para 6.2.1 to 6.2.3 above.

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Representation

The visual impairment particularly at proposed flyovers.

Applicant’s comment

6.12.12. Volume 1 Chapter 7 of the ES (Document Ref 6.1): There are two grade separated junctions on the Scheme at the junction with the Cromer Road (A140) and over the A47(T) Southern Bypass at Postwick.

6.12.13. The landscape and visual impact of the Cromer Road (A140) junction will be reduced by its location and the fact that it is sited largely on the line of the existing A140, which already carries a significant amount of traffic, and the landscape is therefore regarded as being of low sensitivity to the addition of the NDR (see photomontage location 4).

6.12.14. However, the addition of further infrastructure into this road dominated location will result in as having a moderate magnitude of change due to the increased scale and height of the new junction, with the A140 being carried over the NDR. Combining the low sensitivity with the moderate magnitude of change the impact would result in Slight Adverse landscape effects at this location in the opening year of the Scheme. This would remain at year 15 on account of the scale of the new junction. Night time impacts will be ‘neutral’, due to the large numbers of vehicles which already use the existing junction at this location.

6.12.15. A grade separated junction already exists over the A47(T) at Postwick, therefore any additional landscape and visual impacts of the revised grade separated junction will be negligible.

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Representation

The division of parishes and communities and the negative impact the NDR will have on the social value of local communities.

Applicant’s comment

6.12.16. As stated in Vol. 1 Chapter 13 of the ES (Document Ref 6.1) when the Scheme is operational, it is considered that there would be a Moderate Beneficial and therefore significant impact for All Travellers. This is as a result of reduced traffic and congestion on the majority of radial routes, improved amenity for NMUs and relief from existing severance within and between communities caused by existing high traffic levels.

Representation

The lack of a proper study of the developer funded alternatives e.g. the inner orbital link and the use of light railways alternative.

Applicant’s comment

6.12.17. The NDR is part of the overall transport strategy for the Norwich area, NATS, which has been devised to address the current and future problems and issues. NATS has been in existence for many years and has evolved over time to reflect changing national and local policies and current challenges. It was at a review carried out by consultants in 1992 that the concept of a northern distributor road for Norwich was first introduced. A further review of NATS over the period 2002 to 2005 considered various schemes and measures to resolve the transport problems, protect the historic city and reduce the impact of traffic in urban and rural areas where rat running is prevalent and detrimental to those communities. These measures were then assembled into a number of packages which were evaluated. The preferred package comprised measures to improve public transport and encourage modal shift and an NDR to address existing problems that were hindering the

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former objectives. Alongside this work to develop NATS, environmental studies and consultation work was carried out to understand the nature and best routeing for an NDR to minimise environmental impact and best meet the needs of the overall NATS package. This work is described in detail in the ES (Document Ref. 6.1) in Section 3.

6.12.18. Refer to Para 6.4.21 to 6.4.36 above.

Representation

The over supply of commercial properties (at least 7 years worth) therefore negating the need for any additional business and commercial parks, including the Postwick Hub, along the proposed route of the NDR.

Applicant’s comment

6.12.19. The adopted JCS has identified the need for additional employment areas to be allocated. The allocation process is currently under way by Broadland District Council in the preparation of their Site Specifics document and Growth Triangle Area Action Plan (AAP) for the north eastern part of the Norwich Policy Area. The Broadland gate development at Postwick Hub has planning permission already and therefore is not a material consideration for the NDR.

Representation

The absence of any "anchor commercial tenants" to provide the necessary employment opportunities to justify the JCS and in turn the NDR.

Applicant’s comment

6.12.20. The take up of individual employment sites is the business of the developers and unrelated to the identified need over the longer term as set out in the JCS

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Representation

The absence of any link up with the identified investment hot spots identified by the Anglia Local Enterprise Partnership for employment growth.

Applicant’s comment

6.12.21. The JCS has identified need for employment growth which will attract investment. The New Anglia Strategic Economic Plan considers that “The Norwich Northern Distributor Road is fundamental to the delivery of the overall scale of growth, the remainder of the transport package that supports growth, and key elements of the City Deal” (paragraph 6.12) The SEP makes numerous references to the significance of the Norwich area economy. Specific references include recognition of the civil aviation cluster at the airport (at paragraph 2.5) Paragraphs 6.20 and 6.21 specifically refer to the northeast quadrant of Norwich including the airport and surrounding development opportunities, Rackheath and Broadland Business Park.

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6.13. Campaign for Better Transport (CfBT) (RR 763)

Representation

CfBT believes that there is no proven local or national need for this road

Applicant’s comment

6.13.1. Chapter 3 of Volume 1 of the NDR ES (Document Ref. 6.1) sets out (in sub sections 3.2 to 3.6) the need for the NDR.

6.13.2. In summary, the ES explains that the NDR is needed to improve connectivity and accessibility across both the northern part of the Norwich urban area and areas of the county in an arc from the north west to the east of the main urban area. It further demonstrates that such improvement will ease the relative disadvantage of the peripheral location of these areas and provide the basis of the transport infrastructure required to both address existing and future problems and achieve the growth objectives which have been identified for Norwich and its surrounding area.

6.13.3. The need information provided also explains that the specific objectives for the NDR are to:

. Reduce traffic levels and congestion on the existing road network both within the urban area and beyond to the north;

. Facilitate journeys that are currently difficult and require traffic to use roads that are unsuitable for the type and volume of traffic that is currently accommodated;

. Provide access to and help to deliver planned and potential areas of growth, and enable those areas to be free of the need to incorporate provision for extraneous traffic;

. Provide improved transport connectivity, including with the national strategic road network, for existing and future areas of residential and employment development, Norwich

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International Airport and the wider area of North and North East Norfolk;

. Improve traffic related environmental conditions for residents in the northern suburbs of Norwich and outlying villages, whilst minimising the adverse environmental impacts of the NDR.

6.13.4. The key local planning policy relevant to the NDR is contained within the JCS for the Greater Norwich area. This recently adopted development plan document – found to be sound and therefore consistent with National policy following independent examinations – makes clear that the NDR scheme is infrastructure which is fundamental to the achievement of the strategy set out in the JCS (see Volume 2.11.2 to 2.11.9 of Volume 1 of the ES (Document Ref. 6.1). As paragraphs 3.3.35 to 3.3.46 of Volume 1 of the ES (Document Ref. 6.1) explains, the objectives identified in the JCS at the local level benefit from support at the national level.

6.13.5. The purpose of the Land Use and Economic Development Report (Document Ref. 10.3) is to provide an explanation of the relationship between the proposed NDR and sites earmarked for development and to assess the economic development impact of the NDR in terms of jobs and dwellings which are assessed on a site-by-site basis with respect to the influence of the NDR on bringing development forward. The report quantifies the economic benefits of the development sites located on or close to the line of the NDR and provides a qualitative assessment of wider economic effects, including within Norwich City Centre and at Great Yarmouth and the market towns of Aylsham and North Walsham. Positive (but unquantified) effects are identified for these areas in Table 5.2 of the report. 56

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Representation

CfBT believes that the NNDR will increase carbon emissions

Applicant’s comment

6.13.6. Volume 1, Chapter 5 of the ES (Document Ref. 6.1) examines the emissions of carbon arising from the NDR.

6.13.7. The construction phase of the Scheme will lead to a one-off carbon emission from the use of construction materials, plant and transport. Mitigation measures have been included in the Scheme design, which reduce overall emissions from construction by 13.8kt CO2. Carbon emissions during the operational phase of the Scheme will occur as a result of an increase in vehicle kilometres. Changes in absolute emissions will represent around 1% of the total emissions from all sources within the relevant Local Authorities in the assessment years. Carbon sequestration will increase as the habitat creation and landscaping matures.

Representation

CfBT believes that the NNDR will not deliver the stated economic benefits or the number of new jobs claimed

Applicant’s Response

6.13.8. The economic development impact of NDR is set out in Document Ref. 10.3. The Economic Impact Assessment of the proposed NDR is provided within the context of the JCS stated growth targets which are in place to guide the future of the Greater Norwich economy. The NDR is a key strategic piece of infrastructure and will play a key role in supporting the delivery of growth in housing and jobs over the next two decades.

6.13.9. The amount of development and the general location of development for the Greater Norwich area are detailed in the adopted JCS, the key adopted element of the development plan for Norwich and its 57

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surrounding area. This has been found to be sound following independent examinations of that strategy; most recently in 2013. As explained in paragraphs 2.11.2 to 2.11.9 of Volume 1 of the ES (Document Ref. 6.1) the NDR scheme is identified as infrastructure which is fundamental to the achievement of the strategy in the JCS.

6.13.10. The level of employment provision in the JCS is required to meet the objectively assessed need to support economic, household and population growth. This has been determined by the local plan process which is the appropriate mechanism.

6.13.11. The JCS is the adopted strategy for the area and sets out the broad distribution type and scale of growth. It emphasises the need for the NDR as Priority 1 infrastructure as well as providing the spatial strategy for the area encompassing the city centre, the rest of the urban area and surrounding areas including market towns in Broadland and South Norfolk. The views of surrounding areas such as North Norfolk and Great Yarmouth were taken into account through the consultation process and more recently through the duty to co-operate. The JCS is evidenced based and subject to sustainability appraisal which includes economic considerations.

6.13.12. Norwich is a dominant regional city located within a largely rural county. As explained in Chapters 2 and 3 of Volume 1 of the ES (Document Ref. 6.1) a number of objectives which centre on substantial population growth and economic development have been identified for the City of Norwich and its surrounding area. As explained in paragraphs 3.3.20 to 3.3.34 of Volume 1 of the ES (Document Ref. 6.1), at the local level these objectives have been largely identified within the adopted JCS. As paragraphs 3.3.35 to 3.3.46 of Volume 1 of the ES further explain, these objectives benefit from support at the national level.

6.13.13. The purpose of the Land Use and Economic Development Report (Document Ref. 10.3) is to provide an explanation of the relationship between the proposed NDR and sites earmarked for development and to 58

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assess the economic development impact of the NDR in terms of jobs and dwellings which are assessed on a site-by-site basis with respect to the influence of the NDR on bringing development forward. The report quantifies the economic benefits of the development sites located on or close to the line of the NDR and provides a qualitative assessment of wider economic effects, including within Norwich City Centre and at Great Yarmouth and the market towns of Aylsham and North Walsham. Positive (but unquantified) effects are identified for these areas in Table 5.2 of the report.

6.13.14. A wider area study on the A47 Wider Economic Benefits suggested that improvements to the A47 are likely to lead to increases in employment and economic activity that are widely spread across Norfolk.

Representation

CfBT believes that the NNDR will reduce air quality in many areas

Applicant’s comment

6.13.15. Volume 1, Chapter 5 of the ES (Document Ref. 6.1) examines the air quality impacts arising from the NDR.

6.13.16. A qualitative assessment of potential construction phase effects has been undertaken for the Scheme. Mitigation measures have been identified for incorporation within the Construction Environmental Management Plan commensurate with the risk of dust effects identified and in line with best practice. Potential impacts are concluded to be Negligible to Slight Adverse, at worst and therefore not significant.

6.13.17. Operation phase effects have been assessed using an advanced dispersion model. Concentrations of key traffic related pollutants have been predicted at sensitive human health and ecological receptors and the change as a result of the Scheme has been quantified. Existing

concentrations of nitrogen dioxide (NO2) are of concern in Norwich,

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particularly in the city where an ‘Air Quality Management Area’ (AQMA) has been declared, The Scheme is predicted to cause a Slight Beneficial

effect on NO2 concentrations, including within the AQMA, and Negligible effects on fine particulate concentrations. Overall, operational phase air quality effects are concluded to be not significant.

Representation

CfBT believes that the NNDR will increase traffic along the A47 and through The Broads, a nationally important landscape and part of the National Park family

Applicant’s comment

6.13.18. Figure I.4 Vol 3 of the NDR Traffic Forecasting Report (Document Ref. 5.6) and paragraph 7.1.3 in Vol 1 explains the strategic traffic movements in 2012 and in forecasting years of 2017 and 2032 with and without the NDR.

6.13.19. With the NDR, the increase in traffic using the A47(T) between Great Yarmouth and Acle (the switching of 1100 AADT in 2017 and 2500 AADT in 2032) represents an increase of 4% in 2017 and 8% in 2032 (site 1).

6.13.20. Traffic along the Acle straight is currently very heavy at peak times. The Damgate Marshes Site of Special Scientific Interest (SSSI) is an important site because the summer grazed marshland and the hydrological features that cross the area. The dykes support a range of plants and associated invertebrates. Increased traffic will not impact on the hydrological regime of the area and therefore will not impact on the flora and fauna present. The species present will not be affected by changes to noise, air quality and drainage.

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Representation

CfBT believes that the NNDR will increase traffic, congestion and pollution on other parts of the road network and particularly the radial routes to it, adversely affecting local communities in these areas

Applicant’s comment

6.13.21. The traffic flows forecast with the NDR are compared to those without the Scheme in the Traffic Forecasting Report (Document Ref. 5.6) in Vol. 3 Figures I.1 to I.4. These show that there increases on some radial routes in the vicinity of where they connect with the NDR. However the Transport Assessment (Document Ref. 5.5) shows in section 8.5 that the NDR junctions are considered to operate acceptably well. Furthermore the Traffic Forecasting Report in Vol. 1 Section 7 describes the reductions in traffic in other parts of the network with NDR. In particular traffic would be reduced in the suburban area, including on radial routes, and on inappropriate routes that are currently used by orbital traffic movements.

6.13.22. Thus the forecasts show that there is expected to be significant increases in traffic, especially in connection with the development proposals, but that the NDR alone will result in a small increase in trips.

Representation

CfBT believes that the NNDR will sever pedestrian and cycle links, particularly in the countryside, and reduce people’s access to green space and local services

Applicant’s comment

6.13.23. Refer to 6.2.5 to 6.2.8 above.

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Representation

CfBT believes that the NNDR will lead to loss of productive farmland

Applicant’s comment

6.13.24. Refer to 6.4.8 to 6.4.11 above.

Representation

CfBT believes that the NNDR will increase light and noise pollution

Applicant’s comment

6.13.25. Refer to Para 6.2.1 to 6.2.3 above.

Representation

CfBT believes that the NNDR will increase car dependency encouraging a sedentary lifestyle leading to greater obesity and other health issues which cost the NHS billions of pounds every year

Applicant’s comment

6.13.26. With regards to lack of exercise and human health, Chapter 12 of the ES (Document Ref 6.1) concludes that the Scheme would have Moderate Beneficial and therefore significant effect for All Travellers. This is as a result of reduced traffic and congestion on the majority of radial routes, improved amenity for Non-Motorised Users and relief from existing severance within and between communities caused by existing high traffic levels thus providing better facilities for walking and cycling.

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Representation

By taking the NNDR as far as the A1067, there is a real risk that rat-running will increase across the Wensum Valley, blighting local communities and potentially impacting upon the River Wensum Site of Special Scientific Interest (SSSI) and Special Area of Conservation (SAC). This could create pressure for further road building across the valley to connect the A1067 around to the A47. This risks damaging the SAC and would lead to further traffic using this route.

Applicant’s comment

6.13.27. Vol 1 Section 7 Paragraph 7.1.8 to 7.1.14 of the Traffic Forecasting Report (Document Ref. 5.6) analyses the traffic impacts at the western end of the NDR in the vicinity of Taverham and Drayton and especially the impact on traffic crossing the Wensum Valley.

6.13.28. This shows that the NDR leads to a decrease in daily traffic on the routes that connect the A1067 with the A47(T) to the west of Norwich of 6% in 2017 and 4% in 2032 as shown in Table 7.1, Highway and traffic management improvements will be in place where there is a predicted increase in traffic on the western part of the corridor (between Lenwade / Weston Longville and Hockering).

6.13.29. It is considered that the NDR Scheme is unlikely to result in significant adverse environmental impacts on the SAC.

6.13.30. Refer to Para 6.2.4 above

6.13.31. Any subsequent studies associated with proposed crossings of the Wensum Valley will be subject to EIA and HRA.

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Representation

The current economic case for the scheme is based on flawed traffic projections which predict a large increase in traffic nationally. However, historically, these figures have never been accurate and have consistently grossly overestimated future traffic levels. This inaccuracy is likely to lead to an overestimate of the economic benefits, not least because the problem with the WebTAG method of calculating costs and benefits is that it relies too heavily for benefits on small time savings for drivers. At the same time it does not take into account very real costs, including health, environmental and social costs.

Applicant’s comment

6.13.32. The development of the NDR transport models and the forecasting of future traffic demand used the guidance and best practice set out in WebTAG (Web-based Transport Analysis Guidance). This is the DfT appraisal guidance and toolkit and is the requirement for all interventions that require Government approval.

6.13.33. Traffic forecasts have been made in accordance with Department for Transport guidance set out in WebTAG. This process derives future year trip matrices for different types of trip purpose and separately for home-based trips and non-home-based trips. This is discussed in Vol 1 section 5.10 of the Traffic Forecasting Report (Document Ref. 5.6). These trips include all the generated traffic from the development sites in Norwich, South Norfolk and Broadland. The trip purposes consist of; home-based trips which are forecast for a 24 hour time period and non- home-based trips which are forecast separately for each of the modelled time periods, the AM peak, Interpeak and the PM peak. Tables 5.19 to 5.22 of the forecasting report show these reference forecast demands.

6.13.34. For home-based trips, the total number of trips increase from 208,731 in 2012 to 223,207 in 2017 (an increase of 7%) and to 262,090 in 2032 (an increase of 26%). The growth in non-home based trips from 2012 base year to the future year of 2017 is estimated to be around 6% to 7%, while

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2032 is forecast to be around 16% to 23% (the figures vary for each time period). In terms of freight, HGVs are forecast to grow at 2% up to 2017, and 19% up to 2032. LGV trips are forecast to increase by 10% from base year to 2017 and by 55% from base year to 2032.

6.13.35. It is acknowledged that there is uncertainty in forecasting the future traffic growth, although in this case the implementation of JCS is bound to account for a significant increase in road traffic. However to address the issue of uncertainty sensitivity tests were undertaken which are reported in Document Ref. 5.11, Summary Results of Sensitivity Tests. This includes a test on a low growth forecast and the results are reported in section 6. The results show that even with low growth traffic would increase substantially on inappropriate routes without the Scheme, but these routes would be relieved substantially with the Scheme. Accident savings would be similar with low growth and the value for money for the scheme would be high with transport user and accident benefits, rising to Very High with the inclusion of wider impacts and journey time reliability benefits.

6.13.36. The economic appraisal has been based on forecasts that take account of the JCS proposals and produce reasonably sensible increases in traffic on that basis. Uncertainty has been addressed through sensitivity testing. Therefore it is considered that the economic modelling is not based on ‘flawed traffic projections’.

6.13.37. The Economic Appraisal Report (Document Ref. 5.7) contains the economic case for the DCO Scheme. This is based on central traffic forecasts produced by the Department for Transport and Section 5 of the Traffic Forecasting Report (Document Ref. 5.6) contains more details. Summary results of Sensitivity test report (Document Ref. 5.11) contains low and high growth economic appraisal results in Section 6.3. These assess the uncertainty in growth and are a WebTAG requirement. According to Section 6.3.2 and 6.3.4 even the low growth scenario provides a BCR of 3.77 including accidents and 4.75 also including wider 65

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economic and journey time reliability benefits. These represent high / very high value for money categories respectively.

6.13.38. Table 6.3 of (Document Ref. 5.7) contain net user benefits by time saving bands. The results indicate that concentrations of benefits are of significant magnitude and savings are sensibly distributed over time. Section 6.3.2 indicates that 73% benefits are due to time savings of more than 2 minutes hence the scheme doesn’t rely too heavily on small time savings.

6.13.39. WebTAG worksheets for the environmental aspects of the Scheme provide monetary values for noise, air quality, carbon and landscape, other aspect give a qualitative assessment. However the ES looks at the impacts on the environment and the local communities in addition WebTAG requires a Social and Distributional Impact Assessment to ensure disadvantaged groups are not adversely affected.

Representation

CfBT does not believe the proposals represent good value for money, especially as Norfolk County Council has not looked sufficiently at other options for improving conditions in the area and alternative transport package has not been tested which might be able to deliver the same or better outcomes at far less cost to the public purse. CfBT believes that without such an assessment, promoting cheaper, cleaner and less damaging alternatives, the true value for money of the scheme cannot be properly tested.

Applicant’s comment

6.13.40. Refer to Para 6.3.8 above

6.13.41. Section 3.10.13 Volume 1 of the ES, (Document Ref. 6.1) looked at the alternatives to the DCO scheme. Traffic and economic assessments for a number of Alternatives have been assessed in the Traffic and Economic Appraisal of NDR Alternatives (Document Ref. 5.12) using the

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latest version of the transport model. As mentioned in Section 1.1.5 of Document Ref 5.12. These assessments provide comparative quantitative information on the same basis as that provided for the Scheme. Therefore it is not true to say that other options remain unexamined.

6.13.42. The comparison of economic appraisal results of the DCO scheme and the alternatives (see table below Section 1.1.11 of Document Ref. 5.12) indicate that the DCO scheme provides best value for money compared to others. Section 1.1.12 of Document Ref. 5.12 also indicate that an option comprising significant improvements to public transport provision would not meet the Scheme objectives or deliver good value for money.

Representation

Clearly, though, the requirements of the Treasury Green Book and the Department for Transport’s WebTAG process have not been met while other options remain unexamined

Applicant’s comment

6.13.43. Refer to Para 6.13.41 above.

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6.14. Drayton Hall Park Residents (RR 778)

Representation

We strongly oppose the closure of Drayton Lane (South of its junction with Reepham Road); this will create additional traffic along Hall Lane (East of its junction with Drayton Lane).

Applicant’s comment

6.14.1. An amendment to the DCO Scheme has been promoted to address this issue by keeping Drayton Lane South open. Refer to the report 'Proposed Minor Change to the Application for Development Consent: Drayton Lane (south)' (Document Ref. 5.13).

6.14.2. The applicant is currently developing a SOCG with affected parties.

Representation

Many vehicles travelling along Hall Lane go at speeds well in excess of the 40 mile speed limit, so I would hope that we can have some traffic-calming measures put in place as they have in Costessey and some other nearby villages, especially if traffic is going to increase.

Applicant’s comment

6.14.3. NCC is proposing to implement traffic calming measures on Hall Lane and to introduce a speed limit on Drayton Lane (south). These measures are not part of the NDR scheme and are proposed to be implemented irrespective of whether the NDR goes ahead. They are currently planned to address existing local concerns about traffic flows, HGV use, speed, safety and accidents in this location.

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Representation

The residents of Drayton Hall Park were not made aware of the NDR and any road closures and the impact they would have on our community.

Applicant’s comment

6.14.4. Residents of Drayton Hall Park were identified as Section 47 consultees under the Planning Act 2008 and Section 4.2 to 4.9 of the Pre-application Consultation Report (Document Ref. 5.1) detail the consultations undertaken. As a result of these consultations residents of Drayton Hall Park were sent the consultation documents contained in Appendix K-2 of the Pre-application Consultation Report (Document Ref. 5.1).

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6.15. Campaign for the Protection of Rural England (CPRE) (RR 836)

Representation

The NNDR is contrary to national and local planning policy

Applicant’s comment

6.15.1. Refer to Para 6.13.1 to 6.13.4 above.

Representation

Entrench car dependence rather than secure the fullest possible use of public transport, walking and cycling

Applicant’s comment

6.15.2. The NDR forms a key part of the Norwich Area Transportation Strategy NATS and the NATS Implementation Plan (NATSIP), which was updated in November 2013 (Cabinet Report 4 Nov 2013) Appendix D. NATSIP sets out the relationship between the NDR and NATS and identifies those elements of NATSIP that cannot be delivered without the NDR. The NDR therefore allows the full range of NATSIP measures to be delivered. NATSIP has been developed to deliver the required step- change in transport provision to realise the full potential of, and cater for, the transport needs of a vibrant and growing regional centre including Bus Rapid Transit (BRT) Cycle Network and Public Realm Improvements. The NDR, with its associated NATS measures underpins the opportunity to deliver a high quality living environment in sustainable developments based around walking, cycling and public transport.

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Representation

Reduce air quality in a number of places

Applicant’s comment

6.15.3. Refer to Para 6.13.15 to 6.13.17 above.

Representation

Increase noise and light pollution

Applicant’s comment

6.15.4. Refer to Para 6.2.1 to 6.2.3 above.

Representation

Result in loss of agricultural land Applicant’s comment

6.15.5. Refer to Para 6.4.8 to 6.4.11 above.

Representation

Could lead to indirect effects on nationally designated landscapes and habitats by increasing traffic and pressure for additional road-building.

Applicant’s comment

6.15.6. See Para 6.2.1 to 6.2.4 above.

Representation

Reasonable alternatives have not been properly considered.

Applicant’s comment

6.15.7. See Para 6.2.9 to 6.2.14 above

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6.15.8. See Para 6.4.21 to 6.4.36 above.

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6.16. Broads Society (RR 864)

Representation

The Broads Society would like to have the opportunity to make representation, particularly concerning our aims over concerns of the environmental affect that the development of the NDR may bring to the surrounding Broadland region.

Applicant’s comment

6.16.1. The applicant has noted this representation with regard to concerns about the environmental effect that the development of the NDR may bring to the surrounding Broadland region.

6.17. Visit Norwich Ltd (RR 887)

Representation

In summary, NDR will protect the present vitally important visitor economies of Norwich and Norfolk and facilitate their further growth. Conversely, failure to invest in this key infrastructure project opens up the risk of a progressive reduction in the destination's competitiveness, with the inevitable consequences in terms of economic activity and employment.

Applicant’s comment

6.17.1. The applicant has noted this representation with regard to the proposed NDR as being essential to the future health and growth of tourism in Norwich and Norfolk.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

6.18. Michael Innes on behalf of Norfolk Association of Architects (RR 895)

Representation

Finds it difficult to understand the NDR as Nationally Significant Infrastructure: a categorisation that has received very little local explanation, debate, or justification.

Applicant’s comment

6.18.1. Refer to 6.4.12 to 6.4.15 above.

Representation

The NDR will consume a great deal of national and local money to solve local problems that can be better dealt with in more economic ways.

Applicant’s comment

6.18.2. The NDR is an essential element of NATS which is a balanced package of measures designed to address existing and future transport problems and issues in the Norwich area. These problems and the development of NATS are set out in Section 3 of the ES (Document Ref. 6.1).

6.18.3. The NDR has a high BCR, set out Document 5.7. Economic Appraisal Report, demonstrating that it is a good use of public funds.

6.18.4. Sustainable transport is at the heart of NATS and only so much can be implemented due to existing issues and constraints that the NDR addresses.

Representation

The NDR will blight a great deal of open countryside and wooded landscape,

6.18.5. Refer to Para 6.2.1 to 6.2.4 above.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

6.19. Eric Kirk on behalf of Wensum Valley Hotel and Golf Club (RR 990)

Representation

We would wish to support the Western Purple and Brown variation proposals. We would also question why the proposed route could not include more of the Reepham Road to allow further use of open land without any material increase on the overall length of this section of the NDR.

Applicant’s comment

6.19.1. The ES (Document Ref. 6.1) explains in Section 3.8 (paragraphs 3.8.23 to 3.8.26) that prior to the County Council adopting a preferred route for the NDR in September 2005 consultation on alternative routes was carried out in 2003, 2004 and 2005.

6.19.2. These consultations are summarised in Appendix B of the Pre- application Consultation Report (Document Ref. 5.1).

6.19.3. Both the western purple and brown variations were included in the consultation carried out in 2004. Further assessment and a further limited local public consultation in 2005 was also undertaken to consider the purple and brown routes as single carriageway standard between the A1067 and A47. The results of the consultations and further assessment work were reported to and considered by the NCC’s Cabinet prior to adopting the preferred route.

6.19.4. Design development is explained in section 2.2 of the Design and Departures Report (Document Ref 10.2). Paragraph 2.2.6 explains that environmental assessment was undertaken in parallel with all stages of scheme development. This assessment work involved a comprehensive desk study assessment of a wide variety of possible options and was reported in a Stage 1 Environmental Assessment, dated January 2003. This work informed development of route options for public consultation. The use of Reepham Road as part of a potential route for the NDR was identified in the January 2003 report but was not taken forward for further

Norwich Northern Distributor Road Document Reference: NCC/EX/4 assessment. A key factor would have been the proximity of the route to Thorpe Marriott.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

6.20. John Peacock – Norfolk Living Streets (RR995)

Representation

Overall the NDR would not improve conditions for pedestrians. Whilst it would reduce traffic on some roads it would increase them on others including on some residential roads such as Beech Avenue in Taverham where there is now a High School.

Applicant’s comment

6.20.1. Section 7 of the Traffic Forecasting Report (Document Ref. 5.6) sets out the traffic impact that would occur with the implementation of the proposed transport interventions. It shows that there would be substantial reductions in traffic on existing orbital routes as a result of the reassignment of strategic traffic to the NDR. There would also be substantial reductions on the proposed developer link roads which would not be appropriate routes for carrying strategic traffic. Traffic levels would be reduced on the Outer Ring Road. Traffic flows in the city centre would also be reduced substantially as a result of the city centre measures that could be implemented with the introduction of the NDR. These reductions in traffic would benefit pedestrian movement.

6.20.2. Paragraph 4.4.6 of the Forecasting Report (Document Ref. 5.6) shows a list of complementary traffic management measures that are proposed for Norwich city centre in conjunction with the NDR, with the aim of discouraging through car trips and reducing the dominance of traffic in certain areas. These measures will improve pedestrian movements in the city centre, an area of high pedestrian density.

6.20.3. Figure I.3 in the Forecasting Report Vol. 3 (Document Ref. 5.6) shows the AADT traffic flows crossing the Wensum Valley. According to this Figure, on Beech Avenue (site A55) the daily traffic flows would increase in the forecast years, but are forecast to reduce with the NDR.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Representation

The NDR would allow traffic to grow overall by a predicted 40% over the next 25 years. The NDR would also attract traffic generating development along its corridor. Together with planned and future new development along the NDR traffic would grow on the local road network to the detriment of people on foot.

Applicant’s comment

6.20.4. Refer to Para 6.13.32. to 6.13.33 above.

6.20.5. Section 7 of the Traffic Forecasting Report (Document Ref no. 5.6) sets out the traffic impact that would occur with the implementation of the proposed transport interventions. It shows that there would be substantial reductions in traffic on existing orbital routes as a result of the reassignment of strategic traffic to the NDR. There would also be substantial reductions on the proposed developer link roads which would not be appropriate routes for carrying strategic traffic. Traffic levels would be reduced on the Outer Ring Road. Traffic flows in the city centre would also be reduced substantially as a result of the city centre measures that could be implemented with the introduction of the NDR. These reductions in traffic would benefit pedestrian movement.

6.20.6. Paragraph 4.4.6 of the Forecasting Report (Document Ref. 5.6) shows a list of complementary traffic management measures that are proposed for Norwich city centre in conjunction with the NDR, with the aim of discouraging through car trips and reducing the dominance of traffic in certain areas. These measures will improve pedestrian movements in the city centre, an area of high pedestrian density.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Representation

The NDR would sever a number of lanes to the north of Norwich which are used to access facilities on foot (such as Holly Lane in Drayton). It would also sever a number of lanes used for recreational walking such as Quaker Lane. The alternative arrangements would increase journey times for people on foot in several instances and discourage walking. Many people currently with easy access by foot to the countryside on their doorstep would lose an important amenity.

Applicant’s comment

6.20.7. Refer to Para 6.2.5 to 6.2.8 above.

Representation

The NDR would destroy countryside in the north of Norwich.

Applicant’s comment

6.20.8. Refer to Para 6.2.1 to 6.2.4 above.

Representation

Norfolk County Council says that one of the reasons for building the NDR is to remove traffic from the City centre and improve conditions for pedestrians. However, conditions for pedestrians, cyclists, bus users and people with mobility problems can be better addressed through a variety of alternative sustainable measures without the need to build a Northern Distributor Road.

Applicant’s comment

6.20.9. Refer to Para 6.2.9 to 6.2.14 above.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

6.21. John Elbro on behalf of Norwich Cycling Campaign (RR 1004)

Applicant’s comment

6.21.1. The applicant has noted this representation. The applicant is currently developing an SOCG with Norwich Cycling Campaign

6.22. Campaign for Better Transport - East Sussex (RR 1060)

Representation

We do not consider that alternatives to the scheme proposed have been fully appraised.

Applicant’s comment

6.22.1. Refer to Para 6.2.9 to 6.2.14 above.

Representation

We consider that the benefits of the scheme have been exaggerated and that the disbenefits have been greatly downplayed or overlooked altogether.

Applicant’s comment

6.22.2. Refer to Para 6.13.37 to 6.13.39 above.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

6.23. Gordon A Denton (RR 1065)

Representation

We live and own almost the nearest property to the proposed raised roadway over the railway line at Thorpe End, with the expectation of an unknown level of noise and light contamination. There will also certainly be a very large increase in the level of commuter traffic through this relatively unspoilt rural 'garden village' which will spoil its unique character for ever. Property values for many houses at least on the fringes of the village will undoubtedly suffer; we anticipate we, or our heirs, will lose when our property is sold several tens of thousand pounds if the NDR is constructed as planned.

Applicant’s comment

6.23.1. Mr Denton is included within Part 2 of the Book of Reference (Document Ref. 4.3) as a person identified by the applicant as someone that, if the order sought by the application were to be made and fully implemented, the person would or might be entitled as a result of use of the land once the order has been implemented to make a “relevant claim”. In this particular case the “relevant claim” envisaged is a claim under Part 1 of the Land Compensation Act 1973.

6.23.2. It is not possible to give any definitive response on the suggested quantum of the property depreciation. The effect of the road on property prices along the route is ultimately something that the property market itself will determine over time taking into account all national factors, such as the economy and interest rates, as well as local factors, one of which will be the NDR.

6.23.3. These issues will be taken into account in the consideration of any Part 1 compensation claims received under the scheme.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

6.24. Norwich and Norfolk Transport Action Group (NNTAG) (RR 1084)

Response

The local/national need for the NDR is not justified in terms of the stated objectives. We will present written evidence to show that: The NDR would not reduce congestion and rat running. It would redistribute traffic, with reductions on some roads but increases on others.

Applicant’s comment

6.24.1. The need for the NDR is set out in Chapter 3 of Volume 1 of the NDR ES (Document Ref. 6.1) and in particular sub sections 3.2 to 3.6. In summary, the ES explains that the NDR is needed to improve connectivity and accessibility across both the northern part of the Norwich urban area and areas of the county in an arc from the north west to the east of the main urban area. NCC notes that the author of the representation proposes to present written evidence to provide further detail on the objections raised. Such further specific written evidence detailing the points will be responded to as necessary by NCC.

Representation

The three quarters NDR would terminate at A1067 Reepham Road and dump traffic on communities at Taverham and Drayton, leading to rat running.

6.24.2. Refer to Para 6.7.1 to 6.7.4 above.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Representation

Contrary to national policy, the NDR would generate new journeys and increase the need to travel.

Applicant’s comment

6.24.3. The author of this relevant representation does not identify which specific aspect of national policy they allege the NDR proposal is contrary to. It is noted that they propose to present further written evidence to demonstrate this point. NCC will respond as necessary when further evidence is provided. However, the key local planning policy relevant to the NDR is that contained within the JCS for the Greater Norwich area. This recently adopted development plan document – found to be sound and therefore consistent with national policy following independent examinations – makes clear that the NDR scheme is infrastructure which is fundamental to the achievement of the strategy set out in the JCS (see Volume 2.11.2 to 2.11.9 of Volume 1 of the ES (Document Ref. 6.1). As paragraphs 3.3.35 to 3.3.46 of Volume 1 of the ES (Document Ref. 6.1) explains, the objectives identified in the JCS at the local level benefit from support at the national level.

6.24.4. Analysis of the forecast traffic has indicated that with the total number of trips made is expected to be largely unchanged as a result of the NDR. This is documented in paragraph 6.5.3 in the Traffic Forecasting Report (Document Ref. 5.6), which forecasts the increase in vehicle trips to be around 0.2% with the NDR, or around 100 trips in each of the one hour model periods. It should be noted that this does not account for a different growth/ development scenario in the without Scheme compared to the With Scheme, but does identify the impact of the NDR with the same reference growth in both scenarios.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Representation

It would undermine sustainable urban planning in a number of ways which would result in more traffic and new congestion: encourage orbital movements, especially in conjunction with the A47 Norwich Southern Bypass; stimulate further development along its corridor, not least to help pay for its cost; and contribute to further decentralisation of activities.

Applicant’s comment

6.24.5. The NDR is an essential element of NATS which is a balanced package of measures designed to address existing and future transport problems and issues in the Norwich area. These problems and the development of NATS are set out in Section 3 of the ES (Document Ref. 6.1).

6.24.6. In summary there is evidence of an unmet demand for orbital travel in the north of Norwich and beyond causing the use of unsuitable urban and rural routes giving rise to congestion, delay and amenity and safety issues. If left unaddressed, these problems and issues would compromise the aspirations for sustainable urban planning in the northeast of Norwich as routes through the growth areas would need to additionally accommodate long distance traffic attempting to get around Norwich.

6.24.7. The level of housing and employment provision in the JCS is required to meet the objectively assessed need to support economic, household and population growth. This has been determined by the local plan process which is the appropriate mechanism.

6.24.8. The precise locations of the JCS growth in the northeast of Norwich will be set out in an Area Action Plan to be produced by Broadland District Council which should include consideration of the most sustainable locations.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Representation

In listing the NDR as a key infrastructure priority to help cater for a predicted 43% increase in traffic by 2040, the traffic and others impacts have not been considered.

Applicant’s comment

6.24.9. The traffic and other impacts have been comprehensively considered in the DCO submission documents. As well as the wider traffic impacts described in the Traffic Forecasting Report, a full Transport Assessment has been carried out and is reported in Document Ref. 5.5. An economic appraisal is reported in Document Ref. 5.7 and the Land Use and Economic Development report is contained in Document Ref. 10.3. In addition the impact on the environment is contained in the ES for which there is a non-technical summary in Document Ref. 6.3.

Representation

The NDR is not necessary for implementing NATS, as underlined by sustainable transport schemes progressed to date and by the fall in traffic since 2006.

Applicant’s comment

6.24.10. Refer to Para 6.24.5 to 6.24.8 above.

6.24.11. Traffic levels have fallen in the central area of Norwich since 2006 largely attributable to measures that have been implemented in the city centre. However, the issue of rat running in the northern suburbs has not diminished over that period.

6.24.12. Chapter 3, the Needs and Alternatives section of the ES (Document Ref. 6.1) describes the work carried out in devising NATS. This work determined that the preferred option for NATS included an NDR.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Representation

The NDR is not necessary for delivering growth and jobs.

Applicant’s comment

6.24.13. Refer to Para 6.13.8 to 6.13.14 above.

Representation

A lower impact, well-planned inner orbital link road as part of sustainable transport package would be more effective.

Applicant’s comment

6.24.14. Refer to Para 6.2.9 to 6.2.14 above.

6.24.15. Refer to Para 6.4.35 to 6.4.36 above.

Representation

The NDR would not deliver the stated economic benefits and job numbers claimed.

Applicant’s comment

6.24.16. Refer to Para 6.13.8 to 6.13.14 above.

Representation

Construction of a large distributor road through open countryside would bring unacceptable harm to the environment and to communities. Impacts include increased carbon emissions, noise, air and light pollution, severance, road danger, loss of farmland; loss of habitats and wildlife and loss of Norwich's rural setting.

Applicant’s comment

6.24.17. Refer to Para 6.2.1 to 6.2.4 above.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Representation

The NDR would promote car-dependent travel patterns, with implications for public health. It would damage efforts to tackle climate change.

Applicant’s comment

6.24.18. Refer to Para 6.13.26 above

6.24.19. Refer to Para 6.13.6 to 6.13.7 above.

Representation

Traffic growth on the A47 Acle Straight arising from the NDR would increase pressure for dualling through the environmentally sensitive Broads area.

Applicant’s comment

6.24.20. At present there are no plans to dual the A47 Truck Road known as the ‘Acle Straight’, therefore this was not considered within the Cumulative Impacts Chapter of the Environmental Statement. Should there be dualling of the Acle Straight it would be subject to an Environmental Impact Assessment in its own right.

Representation

The applicant aspires to extend the NDR across the River Wensum Special Area of Conservation, previously abandoned on environmental grounds

Applicants comment

6.24.21. Refer to Para 6.10.3 and 6.10.4 above.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Representation

Reasonable alternatives have not been adequately assessed. The applicant has failed to test a lower-impact road option proposed by community groups, together with additional sustainable transport measures and traffic management for improving conditions.

Applicant’s comment

6.24.22. See Para 6.2.9 to 6.2.14 above.

Representation

The cumulative social, environmental and economic impacts of the NDR scheme have not been assessed.

Applicant’s comment

6.24.23. Refer to Para 6.2.1 to 6.2.4 above.

Representation

In promoting the 'three quarters NDR', the applicant has relied on the 2003 public consultation which focused on the principle of a full route; whereas the public was first consulted on the principle of building a 'three quarters NDR' only in 2013.

Applicant’s comment

6.24.24. NCC’s consultations, as described in Section 3.2 of the Pre-Application Consultation Report (Document Ref. 5.1), undertaken on the NDR sought comment on route options for the NDR between the A47 near Postwick and the A47 to the west of Norwich. These consultations and further consultation work undertaken in 2004 and 2005 helped to inform the decision made by its Cabinet in September 2005 to agree an adopted route for the NDR. This route was between the A47 at Postwick and the A1067 near Attlebridge (i.e. no link between the A1067 and A47) and it has not significantly changed up to the statutory pre-application 88

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consultations undertaken in accordance with Planning Act 2008. The statutory pre-application consultation included consultation on the principle of and need for the NDR and on alternative ways of meeting the need and on the route of the NDR (as set out in the Statement of Community Consultation in Appendix J of Document Ref. 5.1).

6.24.25. All consultations undertaken since 2005 have shown the route of the NDR as being from the A47 at Postwick and the A1067 near Attlebridge. More recently these have included the statutory pre-application consultations and the consultations also undertaken in April/May/June 2012 and February/March 2013 (as described in 3.3 and 3.4 of the Pre- application Consultation Report (Document Ref. 5.1). During these consultations there was the opportunity to comment on the route as well as on alternative ways of meeting the need.

Representation

Moreover, the latter consultation was flawed and the applicant ‘lost’ several key objections.

Applicant’s comment

6.24.26. Refer to Para 6.4.18 to 6.4.19 above.

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Appendix A

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Norwich Northern Distributor Road Document Reference: NCC/EX/4

Appendix B

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Appendix C

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Item No Cabinet 19 September 2005

Norwich Northern Distributor Road

Report by the Director of Planning and Transportation

Summary This report advises Cabinet of the further work carried out on the alternative route options for a Norwich Northern Distributor Road (NDR) and puts forward proposals for moving the scheme forward.

1. Introduction

1.1. At its meeting on 7 March 2005, Cabinet received a detailed report setting out the results of the public consultation into the route options for the Northern Distributor Road (NDR). The report recommended that it would be premature to make a decision on a preferred route in view, principally, of the strong adverse comments expressed by English Nature (EN) and Environment Agency (EA).

1.2. It is not intended to repeat the previous report here as a copy has been given to all Members who have attended the political group briefings. A copy of (Appendix 1) of the March Cabinet Report, which summarises the consultation responses is, however, attached to this report as Appendix 1, as is a copy of the plan showing the consultation routes - Appendix 2.

1.3. Cabinet resolved to defer a decision on a preferred route to allow further work to be carried out as set out below:

x Develop mitigation measures for all eastern and western route options and the latter's impacts on the Wensum Special Area of Conservation (SAC) in consultation with EN and EA.

x Assessment of the Purple and Brown routes to single carriageway standard, including limited local public consultation.

x Report back on progress in order that the Council may determine its input to the East of England Plan (EEP) Examination in Public (EIP).

1.4. The EIP begins on the 1 November having recently been deferred from 14 September and if Cabinet agrees a preferred route, that decision will be recommended to full Council on 26 September and reported to the Examination Panel accordingly.

2. Further Work Carried Out

If you need this report in large print, audio, Braille, alternative format or in a different language please contact David Pearson on 01603 223223 minicom 01603 223833 and we will do our best to help.

File name: c:\documents and settings\caxlm\desktop\liz\current papers\cabinet190905\6 ndr report.doc Date created: 08/09/2005 15:31 Page 1 of 22 Date and time last amended: 08/09/2005 15:31 time to canvass the views of their Executive, but it was understood a view of the City Council would be available after its meeting on 21st September.

The Cabinet Member for Planning and Transportation took members through each recommendation in turn to given Cabinet the benefit of his considered views as to a preferred route option.

The Cabinet Member drew attention to the fact that the Blue route to the east, being closer to Green Lane, would give more traffic relief to properties fronting the existing road than either the Yellow or Pink routes and this would result in a net benefit to those properties in terms of noise levels and safety on the existing road. The modelling showed the potential for increased traffic flows on Green Lane with the Yellow route compared with the Blue route. In addition, over the last few months, adjustments to the Blue route had been looked at which placed more of the existing development over 300 metres from the NDR. The Yellow route, on the other hand, would be 170 metres at its closest point to houses in Thorpe End.

With regard to the brown route, suggested as a single carriageway between A1067 Fakenham Road and A47 at Easton, he considered that the benefits were minimal when taking into account the degree of modelling and effort needed to achieve such a road, the overriding and unresolved issue of how to achieve a sensitive and acceptable crossing of the River Tud and the fact that the proposed route was far enough away to not serve adequately as part of an NDR. Traffic would still cause difficulties in the western area even if this route were adopted. He added that he had never supported the proposed brown or purple routes, nor had he given any public views at all on the NDR proposals. For these reasons above and more he considered that it was not reasonable to pursue a complete NDR route, especially given that there was a high risk of failure if such a course was taken.

The Cabinet Member indicated that he preferred the proposed recommendation to have no NDR link between the A47 and A1067 but to pursue a separate scheme to address the existing local problems between Hockering and Lenwade. He saw this proposal as serving an important local purpose, supporting local communities and alleviating rat running. .

Finally, he recommended that the Director of Planning and Transportation develop the agreed preferred route in consultation with local communities and the District Councils and report back on the proposed layout as the basis of a submission for planning permission. He reassured members that there would be the consideration and development of mitigations measures once a decision was taken on the preferred route for the NDR, to ensure that communities such as Costessey, Taverham, Ringland and parts of West Norwich were supported against the potential for rat running from additional traffic generation. In addition, it was noted that, prior to the development of the three-quarters NDR route, if agreed, highway and other works would be undertaken to alleviate the problems faced now by Norwich and the western suburbs.

The Cabinet Member for Human Resources, Finance, Property and Corporate Affairs advised that, as local member for Wroxham Division including Rackheath, he intended to abstain from voting in favour of the Blue route as he had consistently opposed this route and its adverse impact on Green Lane. He did however comment that he strongly supported the need for an NDR and welcomed the commitment given that officers would work with local communities in developing the preferred route, once approved.

Decision (Key Decision)

RESOLVED TO RECOMMEND TO COUNTY COUNCIL –

(i.) To adopt the Eastern Blue route as part of the NDR between the A47 at Postwick and the A140 Cromer Road.

(ii.) To adopt the Red route as part of the NDR between the A140 Cromer Road and A1067 Fakenham Road.

All as shown on plan number R1C093-R1-600 at Appendix 12 of the report.

(iii.) To have no NDR link between the A47 and A1067 but to pursue a separate scheme to address the existing local problems between Hockering and Lenwade.

(iv.) To authorise the Director of Planning and Transportation to develop the agreed preferred route in consultation with local communities and the District Councils and to report back on the proposed layout as the basis of a submission for planning permission.

Reasons for Decision

The NDR remains a fundamental element of NATS. It is critical to the delivery implementation of other elements of the strategy, particularly removal of traffic from the City centre, relieving congestion on the ring roads and radial routes, to facilitate improvements to public transport and relieving congestion in the northern suburbs. The NDR will also facilitate a wide range of regional and local objectives.

Alternative Options Considered

Alternative strategies that would not include a Northern Distributor Road were considered before the County Council adopted its present Norwich Area Transportation Strategy.

A large number of variations to the routes discussed in this report were examined through a Stage 1 Environmental Assessment and rejected as less suitable, before the public consultation.

The Cabinet agreed to consider items 25, 9 and 15 respectively next.

The Chairman, Mrs A L King returned and took the Chair for the remainder of the meeting.

7. OTHER ITEM OF URGENT BUSINESS: HOLT: PROPOSED CAR PARK AND ACCESS WORKS B1110 THORNAGE ROAD, HOLT

The report (25) tabled by the Director of Planning and Transportation was received. The Chairman agreed to accept this business as a matter of urgency for the following reason:

The County Council is being pressed by the District Council., Holt Town Council, MP and Local Members for urgent resolution of a planning condition relating to the car park proposal.

Mr J H Perry-Warnes addressed Cabinet to explain that, noting compliance and enforcement concerns, he would prefer a 30 mph speed limit to the recommended 50 mph but if this was not possible he suggested a compromise of 40 mph.

Norwich Northern Distributor Road Document Reference: NCC/EX/4

Appendix D

Norwich Northern Distributor Road Document Reference: NCC/EX/4

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Cabinet 4 November 2013 Item No 14 .

Norwich Area Transportation Strategy (NATS) Implementation Plan and Norwich Northern Distributor Route (NDR) Update

Report by the Director of Environment, Transport and Development

Summary

The implementation plan for the Norwich Area Transportation Strategy (NATSIP) was agreed by Cabinet in April 2010. The plan sets out the range of transport measures, together with their general intended phasing, for delivery over the short to medium term. Good progress has been made delivering the plan. It has now been updated to take account of what has been delivered since 2010, and to reflect the latest position on future scheme delivery, given progress with implementation, and now that the growth plans for the area are more clear. The update is not a new plan. Rather, it takes account of progress with scheme delivery, outlines the relationship between NATS schemes and the wider growth and development agenda, and takes account of the implications of emerging funding opportunities including the Community Infrastructure Levy. The major difference between the NATSIP adopted in 2010 and the update is in the phasing of delivery of the schemes. For example, the recent government awards of funding for better Bus Area and Cycle City Ambition has allowed significant acceleration of delivery on schemes. The key features of the Implementation Plan are also unchanged and include city centre improvements; a bus rapid transit (BRT) network; a core bus network, integrated ticketing and information; a package of cycling and walking improvements; specific rail service improvements; ”Smarter Choices” initiatives, like travel planning; major road network; the Northern Distributor Road.

The Implementation Plan is included as Appendix A. It sets out the overall basis for scheme delivery across the Norwich Policy Area over the next 10-15 years. A detailed, two-year programme of schemes for delivery will be rolled-forward each year, which Members will be asked to agree annually as part of the annual Local Transport Plan capital programme. The NDR update at section 3 includes details following completion of the Nationally Significant Infrastructure Project (NSIP) consultation (see Appendix B). It sets out some minor changes to the NDR project as a result of the consultation. It is proposed that the finalised NDR project will be submitted to the Planning Inspectorate in late November/early December 2013. Having also completed the consultation and finalised the details of the NDR, an updated cost profile for the project is included (see Appendix C). This now incorporates the additional costs of the roundabout at Fir Covert Road and the airport radar replacement, which were reported and agreed at Cabinet in September, which combined have added £2m to the overall project costs. Recommendation / Action Required i) Cabinet is asked to adopt the updated NATS Implementation Plan. ii) Cabinet is asked to agree the revised NDR cost profile. iii) Cabinet is asked to confirm it is content for the Development Consent Order for the finalised NDR scheme to be submitted.

89 delivery model and the proposed senior management arrangements align with the Administration’s vision and aspirations.

14 Norwich Area Transportation Strategy (NATS) Implementation Plan and Norwich Northern Distributor Route (NDR) Update

The Cabinet received a report (item 14), which gave an update on the Norwich Area Transportation Strategy (NATS) Implementation Plan and the Norwich Northern Distributor Route (NDR).

Officers advised that the implementation plan was agreed in 2010, and since that time good progress had been made with delivery. Members were being asked to agree an updated implementation plan. It is not a new plan, but takes account of the delivery to date. The main changes relate to the phasing of delivery, although the key elements of the plan remained the same. Members were advised of the recent consultation on the NDR, and of the minor changes to this scheme. An updated cost profile was also included and included all recent changes previously agreed by Cabinet.

The Cabinet Member for Schools noted that the NDR was a priority in terms of what was needed in Norfolk and that he was pleased to see progress was being made.

The Chairman agreed that the NDR was essential for Norfolk and that businesses would agree with this.

The Cabinet Member for Adult Social Services noted that there were many positives within the plan affecting the whole of the greater Norwich area and that she was pleased that regular updates were reported to Cabinet on this subject.

Decision

RESOLVED that:-

x The updated NATS Implementation Plan be adopted.

x The revised NDR cost profile be agreed.

x The Development Consent Order for the finalised NDR scheme be submitted.

Alternative Options: Refer to the Cabinet report.

Reason for Decision

The Norwich Area Transport Strategy Implementation Plan (NATSIP) had been adopted by the County Council in April 2010. It was important to keep the plan up to date to reflect the progress made on delivery and to ensure it continues to provide a guide to future delivery reflecting the growth plans for the area. The NDR was an essential element of the NATSIP and forms a key part of the Joint Core Strategy for the Norwich Policy Area. The decision to continue the development consent order application for the project was essential to be able to realise the full benefits of the Implementation Plan, to provide the transport infrastructure for Norwich to enable its prosperity into the future, taking account of existing transport problems and accommodating future growth in housing and

9 employment, which were essential to economic growth in Norfolk and vital to achieving LTP targets.

15 Carbon and Energy Reduction Programme Report 2012/13

The Cabinet received a report (item 15), which provided a progress update on the Council's carbon and energy reduction programme.

The Cabinet Member for Adult Social Services noted that she was disappointed that the County Council had seen an increase in expenditure on energy within 2012/13, though understood that this was due to the harsh winter and rise in energy costs. The expenditure was still less than it had been in 2008-09. A large part of the costs were caused by school estates, which the County Council had no control over. The Cabinet Member asked officers if they thought the target would be hard to meet.

The Climate Change Manager responded that the automated meter readings for Council properties currently showed that the County Council was actually one month head of schedule to meet the targets. This allows for the fact that schools had been closed over the summer and recognised the potential for a harsh winter ahead. Though still challenging, he believed that the target could be met.

Further to Mr Bearman’s supplementary question earlier the Chairman asked whether it would be possible to install solar PV panels onto the roof of County Hall. Officers responded that this was part of the overall planning for the site.

Decision

RESOLVED that:-

x The reductions in non-schools building, and Traffic and Street Lighting energy use and the continued delivery of the Carbon & Energy Reduction Programme be supported, to meet obligations and address ongoing energy costs .

x The marketing to schools of other options to finance energy improvements, including considering the package developed by Norse Energy Ltd as an alternative approach to carbon reduction, be agreed.

x Further delivery improvements, in the areas indentified in Section 6 of the Cabinet report, be agreed.

Alternative Options: Refer to the Cabinet report.

Reason for Decision

The Cabinet report updated Members on the progress of the Carbon and Energy Reduction Programme and highlighted the need to take further actions to ensure that the Council achieved its 25% emissions reduction target, achieved financial savings and minimised its liabilities under the CRC Scheme

16 Energy and Carbon Management Programme 2014-2020

10 Norwich Northern Distributor Road Document Reference: NCC/EX/4

Appendix E

Norwich Northern Distributor Road Document Reference: NCC/EX/4

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Report to Broadland District Council, Norwich City Council and South Norfolk District Council

by David Vickery DipT&CP MRTPI an Inspector appointed by the Secretary of State for Communities and Local Government

Date : 13th November 2013

PLANNING AND COMPULSORY PURCHASE ACT 2004 (AS AMENDED)

SECTION 20

REPORT ON THE EXAMINATION INTO THE JOINT CORE STRATEGY FOR BROADLAND, NORWICH AND SOUTH NORFOLK, THE BROADLAND PART OF THE NORWICH POLICY AREA LOCAL PLAN

Document submitted for examination on 4 February 2013

Examination hearings held between 21 to 23 May, and on 24 & 25 July 2013

File Ref: PINS/G2625/429/7 Joint Core Strategy for Broadland, Norwich and South Norfolk, the Broadland Part of the Norwich Policy Area Local Plan: Inspector’s Report November 2013

[TP 13]. This concluded that local evidence (including an update to the Strategic Housing Market Assessment calculations) showed that the adopted JCS housing provision still sat well within the latest regional and national population projections and a range of estimates of housing requirements. The GNDP also provided the latest (July 2013) update to the East of England Forecasting Model, an economic forecasting tool [DV 36] which produced figures at the lower end of the range.

40. This conclusion on housing numbers was challenged by various parties, some arguing for lower and some for higher numbers. However, I am not convinced that the adopted JCS figure is so wrong that the amounts of housing proposed in this Plan need to be reduced or increased. This is not an exact science, and population projections are just that – projections. The GNDP figures indicate that the adopted JCS total still lies comfortably within the range of various projections based on completion extrapolations, affordable housing requirements, and population and economic figures [Table 1 of SDJCS 14 and TP 13].

41. Windfall housing development is not included within the adopted JCS 37,000 homes total, and it cannot be included because no evidence was submitted to show that it will continue to be a reliable source of supply as required by paragraph 48 of the Framework. I accept that windfall development would make the housing total higher if it continues at current rates (Table 1 of SDJCS 14 estimated that it would result in 42,000 homes). I also accept that the adopted JCS housing total does not lie at the bottom end of the range of projections. However, housing targets are not a maximum number, and the Government’s policy in the Framework is to boost significantly the supply of housing (paragraph 47). Moreover, there is no evidence to indicate that there are good planning reasons to restrict the proposed housing numbers in the Plan area, even if windfall development is included.

42. It was alleged that there was a backlog or shortfall in the provision of housing numbers in the adopted JCS that had to be made up in this Plan. I have already referred above to the possibility of an increase in total numbers due to the fact that windfall development is not included - this introduces an important element of flexibility. In addition, the housing numbers in the adopted JCS are based upon, and slightly exceed, the now revoked May 2008 Regional Strategy totals which, with the previous Regional Planning Guidance for East Anglia of 2000, had taken account of housing backlogs during those plan periods. And the Strategic Housing Market Assessment (and its updates) included an allowance to meet the affordable housing backlog (although there are practical difficulties in achieving it) in the adopted JCS. I have seen no convincing evidence that there is any significant housing backlog or shortfall either now or in the adopted JCS that cannot be accommodated by this Plan.

43. The GNDP has had regard to a range of population projections, some of which are higher and some lower than the adopted JCS target. I do not consider that the submitted evidence shows that the housing numbers in this Plan, which is for only a part of the adopted JCS total, need to be decreased or increased. In any event, as the GNDP said in evidence, the

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Appendix F

Norwich Northern Distributor Road Document Reference: NCC/EX/4

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Addendum to the NDR Environmental Statement

Lighting Assessment

July 2014

Norfolk County Council

Addendum to the NDR Environmental Statement

339156 BSE NOR 003 0

07 July 2014 Lighting Assessment Addendum to the NDR Environmental Statement Lighting Assessment July 2014

Norfolk County Council

County Hall, Martineau Lane, Norwich, Norfolk

Mott MacDonald, East Wing, 69-75 Thorpe Road, Norwich NR1 1UA, United Kingdom

T +44 (0)1603 226780 F +44 (0)1603 619365 W www.mottmac.com

Addendum to the NDR Environmental Statement Lighting Assessment

Issue and revision record

Revision Date Originator Checker Approver Description Standard P1 July 2014 Jackie Fookes Simon Allen / First Draft Mark Kemp

0 July 2014 Jackie Fookes Simon Allen / Mark Frith First Issue Mark Kemp

This document is issued for the party which commissioned it and We accept no responsibility for the consequences of this for specific purposes connected with the above-captioned project document being relied upon by any other party, or being used only. It should not be relied upon by any other party or used for for any other purpose, or containing any error or omission any other purpose. which is due to an error or omission in data supplied to us by other parties.

This document contains confidential information and proprietary intellectual property. It should not be shown to other parties without consent from us and from the party which commissioned it..

339156/BSE/NOR/003/0 07 July 2014

Addendum to the NDR Environmental Statement Lighting Assessment

Contents

Chapter Title Page

1 Introduction 1 1.1 Purpose of this Report ______1 1.2 Description of Development ______1 1.3 Methodology ______2

2 Conclusion 3

Appendices 4 A. Postwick Junction Lighting Assessment ______5

339156/BSE/NOR/003/0 07 July 2014

Addendum to the NDR Environmental Statement Lighting Assessment

1 Introduction

1.1 Purpose of this Report

1.1.1 This addendum to the Environmental Statement (ES) for the Norwich Northern Distributor Road (NDR) has been prepared by Mott MacDonald on behalf of Norfolk County Council (NCC), in support of an application, by NCC, for a Development Consent Order (DCO) in accordance with the Planning Act 2008 as amended.

1.1.2 The NDR is a dual carriageway all-purpose strategic distributor road, which would link the A1067 Fakenham Road, near Attlebridge to the A47 Trunk Road (T) at Postwick. This would be over a length of approximately 20.4 kilometres.

1.1.3 This addendum has been produced as a small section of lighting at the Postwick section of the Scheme was omitted from the original ES. It seeks to address this by undertaking a Lighting Assessment (LA) for this section of the NDR (Appendix A: Postwick Junction Lighting Assessment). This section of lighting is required to provide for driver safety. There are also some relocated columns associated with the Business Park Roundabout as explained in paragraph 1.2.3 below, and in the Postwick Junction Lighting Assessment in Appendix A.

1.1.4 This assessment will determine whether there are any significant impacts arising as a result of the additional lighting.

1.2 Description of Development

1.2.1 The NDR is subject to an application on behalf of Norfolk County Council, for a Development Consent Order in accordance with the Planning Act 2008 as amended. As such it also includes the Postwick Junction, a new bridge over the A47, new slip roads on to the A47, three new roundabouts, a traffic light-controlled junction south of the A47, 1.5km of new dual carriageway and three drainage lagoons.

1.2.2 The Postwick Hub, which includes improvements to Postwick Junction, has planning permission and is currently under construction.

1.2.3 The arrangements of Postwick Junction as included in the DCO application are slightly different to the existing planning permission. The NDR DCO will facilitate changes to Postwick Junction that will accommodate the linking of the NDR to Postwick Junction. This involves some changes to the position of, and inclusion of, lighting columns at the Business Park Roundabout and the approaches to this roundabout.

1.2.4 As such it is intended to provide highway lighting to the proposed Postwick Junction and a maximum of 200m of the northern NDR approach to the proposed Business Park Roundabout as shown on drawing R1C093-R1-4950 within the Lighting Assessment in Appendix A.

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Addendum to the NDR Environmental Statement Lighting Assessment

1.3 Methodology

1.3.1 The detailed methodology for the LA is explained in Appendix A.

1.3.2 Using the results from the LA, a qualitative assessment of any effects on other topics in the ES was undertaken and the results presented in Table 1.1.

Table 1.1: Qualitative Assessment ES Topic Evaluation Assessment Air Quality There are no anticipated impacts on Negligible and therefore not significant Air Quality from the additional lighting columns Carbon There is a small amount of Carbon Negligible and therefore not significant embedded in the additional infrastructure and an additional small energy usage Cultural heritage There are no heritage sites affected by Negligible and therefore not significant the additional lighting Landscape As the extant planning permission Negligible and therefore not significant includes lighting of the Postwick Junction, and the existing adjacent business park is currently brightly lit there are no anticipated effects from the additional lighting and columns Nature Conservation The effects on the proposed bat bridge Negligible and therefore not significant are assessed within the LA in Appendix A; The baseline consists of existing lighting already in place and the permitted lighting from the Postwick Junction improvements. Geology and Soils There are no effects on Geology and Negligible and therefore not significant Soils Materials The quantities of materials required for Negligible and therefore not significant the additional lighting columns is small Noise There is no noise effects associated Negligible and therefore not significant with the additional lighting Effects on All Travellers The lighting is required for safety when Moderate beneficial effects approaching the roundabout Community and Private Assets There are no effects on private land or Negligible and therefore not significant community land over and above those already proposed to be acquired for the NDR Road Drainage and Water The lighting and columns will not affect Negligible and therefore not significant water quality or road drainage

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Addendum to the NDR Environmental Statement Lighting Assessment

2 Conclusion

2.1.1 There are no anticipated adverse impacts arising from the additional lighting and columns. There are therefore no changes necessary to the conclusions reached in the Environmental Assessment (Document Ref 6.1) in relation to the absence of any significant environmental effects as a consequence of the lighting proposed for the NDR.

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Appendices

A. Postwick Junction Lighting Assessment ______5

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A. Postwick Junction Lighting Assessment

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Norwich Northern Distributor Road

Postwick Junction Lighting Assessment

July 2014

Norfolk County Council

Norwich Northern Distributor Road

339156 BSE NOR 002 0

09 July 2014 Postwick Junction Lighting Assessment Norwich Northern Distributor Road Postwick Junction Lighting Assessment July 2014

Norfolk County Council

County Hall, Martineau Lane, Norwich, Norfolk, NR1 2DG

Mott MacDonald, East Wing, 69-75 Thorpe Road, Norwich NR1 1UA, United Kingdom

T +44 (0)1603 226780 F +44 (0)1603 619365 W www.mottmac.com

Norwich Northern Distributor Road Postwick Junction Lighting Assessment

Issue and revision record

Revision Date Originator Checker Approver Description Standard P1 June 2014 Dean Hawkins Jamie Mark Frith First Draft McKay/Jacqueline Fookes

P2 July 2014 Dean Hawkins / Jamie McKay / Mark Frith Second Draft Simon Allen Jacqueline Fookes

0 July 2014 Dean Hawkins / Jamie McKay / Mark Frith First Issue, following legal review Simon Allen Jacqueline Fookes

This document contains confidential information and proprietary intellectual property. It should not be shown to other parties without consent from us and from the party which commissioned it.

339156/BSE/NOR/002/0 09 July 2014

Norwich Northern Distributor Road Postwick Junction Lighting Assessment

Contents

Chapter Title Page

Executive Summary i

1 Introduction 1 1.1 Overview ______1

2 Site Description 2 2.1 Description of the Proposed Works ______2 2.1.1 Site Location ______2

3 Method of Assessment 3 3.1 Scope of Assessment ______3 3.2 Methodology of Assessment ______3 3.2.1 Obtrusive Light ______4 3.2.2 Environmental Zone Classification for the NDR Postwick Junction ______4 3.2.3 Obtrusive Light Limitations ______5 3.3 Summary of Sensitive Receptor Locations ______5 3.4 Assessment of Effects and Determining of Significance ______6

4 Proposed Development 8 4.1 Proposed Lighting Design ______8

5 Predicted Impacts - Obtrusive Light Assessment 9 5.1 Maintenance Factor for Obtrusive Light calculations ______9 5.2 Obtrusive Light Assessment ______9 5.2.1 Sky Glow - Upward Light Ratio (ULR) ______9 5.2.2 Light Intrusion (onto windows) ______14 5.2.3 Luminous Intensity ______15

6 Calculation and Methodology 17 6.1 Calculation Notes and Methodology ______17 6.2 Assumptions ______17

Appendices 18 Appendix A. Guidance Notes for the Reduction of Obtrusive Light ______19 A.1 Guidance Notes for the Reduction of Obtrusive Light GN01:2011 ______19 Appendix B. NCC Street Lighting Plan ______20 B.1 NCC Street Lighting Plan, drawing number R1C093-R1-4950 ______20 Appendix C. MM Lighting Impact Assessment – Receptor and Contour Plan ______21 C.1 Mott MacDonald Lighting Impact Assessment – Receptor and Contour Plan, drawing number MMD- 339156-DT-0075 ______21 Appendix D. Lighting Calculations ______22

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D.1 Consistency Checked Lighting Calculations ______22

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Norwich Northern Distributor Road Postwick Junction Lighting Assessment

Executive Summary

This report provides a lighting assessment for part of the proposed Postwick Junction forming part of the Norwich Northern Distributor Road. The assessment includes Sky Glow, Light Intrusion onto Windows and Luminaire Intensity for the fourteen identified sensitive receptor locations on Smee Lane including the bat gantry crossing the NDR at the Smee Lane location.

This assessment has been based on the lighting design supplied by Norfolk County Council, as indicated on drawing number R1C093-R1-4950, for further details refer to Appendix B.

The results from the Design provided were compared against the Institute of Lighting Professionals (ILP) Guidance for Reduction of Obtrusive Light (GN01:2011), as summarised below:

Table 1.1: ILP Guidance for Reduction of Obtrusive Light

Environmental Sky Glow ULR Light Intrusion (into Luminaire Intensity Zone (Max %) Windows) Ev (Lux) (Candelas (cd)) Pre- Post-curfew Pre-curfew Post-curfew curfew E2 2.5 5 1 7,500 500

Source: ILP

Table 1.2: Summary of Findings Calculated Performance ILP Guidance Guidance Criteria Worst Case Comment Pre Curfew Post Pre Curfew Post Curfew Curfew Light Intrusion 5 Lux 1 Lux 0 Lux 0 Lux Design Considered Satisfactory onto windows Sky Glow 2.5% Max 0% Design Considered Satisfactory Luminaire 7,500cd 500cd N/A Design Considered Satisfactory Intensity

Source: ILP / Mott MacDonald

It must be noted that the luminaire in conjunction with the light source specified has a low Ultra Violet (UV) output. Lower levels of UV are known to limit the amount of insects attracted to the light source. This should therefore cause less disruption to the natural foraging routes of bats which would otherwise be attracted to the insects.

339156/BSE/NOR/002/0 09 July 2014 i Norwich Northern Distributor Road Postwick Junction Lighting Assessment

The revised lighting levels from the proposed lighting are calculated to be sufficiently low that no changes are envisaged to the stated impacts on the significant bat flight route along Smee Lane, as detailed in the Nature Conservation chapter of the Environmental Statement. Further, calculated levels are sufficiently low that the bat gantry, proposed to mitigate the bisection of the flight route by the NDR, would function as originally proposed.

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1 Introduction

1.1 Overview

This Lighting Assessment (LA) has been prepared by Mott MacDonald on behalf of Norfolk County Council (NCC), in support of an application, by NCC, for a Development Consent Order (DCO) in accordance with the Planning Act 2008 as amended.

The proposed Scheme (the Norwich Northern Distributor Road, known as the NDR) is a dual carriageway all-purpose strategic distributor road, which would link the A1067 Fakenham Road, near Attlebridge to the A47 Trunk Road (T) at Postwick. This would be over a length of approximately 20.4 kilometres.

The Postwick junction will be lit as explained in Section 2.7 of Volume 1 of the Environmental Statement (Document Ref 6.1), with the additions described below.

 Road lighting at the Postwick junction will also require a maximum of 200 metres of the NDR approach to the Business Park Roundabout to be lit. Due to an oversight, lighting of this approach road was not considered as part of the assessment work for the Environmental Statement. There are also some relocated lighting columns associated with the Business Park Roundabout to accommodate the marginal changes to the roundabout that are required once the NDR is in place.

It is standard practice to provide approach lighting to roundabouts where the roundabout itself is lit. Lighting has also been provided in accordance with the Design Manual for Roads and Bridges (DMRB) TD 51/03 as it is a requirement of TD 51/03 to light segregated left hand lanes (as proposed on the NDR approach to the Business Park Roundabout).

Due to the omission of this 200m of lighting from the Environmental Statement, this report is provided as a lighting impact assessment to form part of an addendum to the Environmental Statement (ES). It should be noted that the lighting for the Postwick Junction has already been approved (Broadland District Council Planning permission 2008 1773.) and therefore has only been assessed as part of the assessment of the cumulative effects of the omitted lighting with the baseline lighting (see Section 3.2 Method of Assessment).

In line with NCC’s requirements, this lighting assessment provides details of proposed highway lighting including a layout plan with a lux contour diagram showing calculated illuminance levels in the immediate vicinity of the site.

The purpose of this report is to assess the lighting conditions of the area associated with the NDR Postwick Junction in relation to identified sensitive receptors, including the proposed bat gantry at Smee Lane.

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2 Site Description

2.1 Description of the Proposed Works

The Postwick Junction consists of a new bridge over the A47, new slip roads on to the A47, three new roundabouts, a traffic light-controlled junction south of the A47, 1.5km of new dual carriageway and three drainage lagoons.

It is intended to provide highway lighting to the proposed Postwick Junction and a maximum of 200m of the northern NDR approach to the proposed Business Park Roundabout as shown on drawing R1C093-R1- 4950 provided in Appendix B.

2.1.1 Site Location

The location of the site is shown in Figure 2.1 below.

The location of the proposed Postwick Junction incorporates an area currently used for agricultural purposes and as such has no existing highway lighting, the existing Postwick Junction which has highway lighting, and immediately adjacent to the west of the site is an existing industrial estate and link road with extensive highway lighting.

Figure 2.1: Site Location Plan

Source: Mott MacDonald

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3 Method of Assessment

3.1 Scope of Assessment

Due to the requirement for highway lighting for the proposed NDR approach road to the Postwick Junction it was considered necessary to ensure that the DCO Submission was supported by a Lighting Impact Assessment Report.

This report is based on the lighting designs provided by Norfolk County Council; refer to drawing number R1C093-R1-4950 within Appendix B, Lighting Reality modelling has been based on this drawing and relied upon to form the basis of the assessment, refer to Appendix D for lighting model information. A desktop assessment has been carried out to identify sensitive receptors in the area which could be affected by the proposed NDR lighting. These sensitive receptors include, but are not limited to, dwellings, listed buildings, footpaths / bridleway, conservation areas and heritage sites.

Mott MacDonald has identified fourteen potential sensitive receptor locations, including a proposed bat gantry, all situated along Smee Lane which have been summarised in Table 3.3. This report provides a review of the light spill and luminaire intensity and assess the impact on these local sensitive receptors. It also considers the level of sky glow resulting from the proposed lighting installation.

The Institution of Lighting Professionals (ILP) has provided a guidance note on the reduction of obtrusive light, GN01:2011 which is provided in Appendix A. This document forms the basis for the lighting analysis carried out within this report.

Having regard to the ecological information contained in the ES Volume 1 Chapter 8 Nature Conservation (Document Ref 6.1), the assessment of potentially significant lighting effects on ecological species has been limited to an assessment of the potential effects on the bat gantry which is proposed to cross the NDR at Smee Lane.

3.2 Methodology of Assessment

The proposed lighting has been be modelled using the ‘Lighting Reality Area’ program (an industry standard lighting design package) to provide light spill information associated with the proposed roundabout and approach road lighting in lux.

Although the lighting proposed for the Postwick Junction has already been approved, the proposed lighting in the vicinity of the Business Park Roundabout was included within the model in addition to the newly proposed lighting and relocated columns, to take account of the cumulative effect of the proposed lighting in the area. This was to provide an accurate model to allow for a robust assessment of the impacts of the lighting. Drawing MMD-339156-DT-0075 provided in Appendix C shows the visual distinction between the Postwick Junction lighting and the lighting being assessed as part of the NDR.

The information required to model the proposed lighting levels has been obtained from NCC drawing R1C093-R1-4950 provided in Appendix B.

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An assessment of direct upward light for each of the proposed luminaires has been carried out using ‘Lighting Reality Roadway’ program (an industry standard lighting design package).

An assessment of luminaire intensity was carried out. An assessment of surveyed contour plans has ascertained that the landscape between the NDR lighting and the sensitive receptors is relatively flat in nature, with only a slight fall in elevation from the northeast to southwest of the site.

3.2.1 Obtrusive Light

Obtrusive Light Limitation Design Guidance

Light intensity and distribution needs to be carefully considered during the design process to ensure that direct upward light is minimised, and light distribution cut-offs from luminaries do not result in severe lighting contrast on light receiving surfaces such as floors and walls. Luminaries, lamps, optics and equipment should be specified and located to minimise any direct upward light component in order to reduce light pollution. In addition light trespass and spill light will need to be minimised through design.

Figure 3.1: Types of Obtrusive Light

Source: ILP Guidance Notes for the Reduction of Obtrusive Light (2011)

3.2.2 Environmental Zone Classification for the NDR Postwick Junction

To assess the levels of obtrusive light an appraisal was carried out to classify the site in terms of its ‘Environmental Zone’ which equates to the district brightness of the surroundings, see Table 3.1 below for environment zone information.

In the case of a site being between two possible environmental zones, ILP guidance recommends that the most difficult environmental zone of the two options to achieve is assigned for assessment purposes. In

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this case it could be argued that the site lies between an E2 and E3 zone. Therefore in line with ILP guidance, we have applied E2.

Table 3.1: Environmental Zones Lighting Zone Surrounding Environment Examples E0 Protected Dark UNESCO Starlight Reserves, IDA Dark Sky Parks E1 Natural Intrinsically dark National Parks, Areas of Outstanding Natural Beauty etc. areas E2 Rural Low District Village or relatively dark outer suburban locations Brightness E3 Suburban Medium district Small town centres or suburban locations brightness E4 Urban High district Town/city centres with high levels of night time activity brightness

Source: ILP guidance notes for the reduction of obtrusive light – 2011

3.2.3 Obtrusive Light Limitations

It can be seen from Table 3.2 below that a lighting installation located in an area deemed to be more sensitive will understandably equate to greater constraints with regards to obtrusive light. Based on our appraisal, see below for maximum levels of obtrusive light associated with an E2 Zone.

Table 3.2: Obtrusive Light Limitations (ILP guidance notes for the reduction of obtrusive light 2011) Building Sky Glow Light Intrusion (into Luminaire Intensity Luminance Pre- Environmental Zone ULR (Max %) Windows) Ev (Lux) I (Candelas) curfew Pre- Post-curfew Pre-curfew Post-curfew Average, L curfew (cd/m2) E0 0 0 0 0 0 0 E1 0 2 0 2,500 0 0 E2 2.5 5 1 7,500 500 5 E3 5.0 6 2 10,000 1,000 10 E4 15 25 5 25,000 2,5000 25

Source: ILP guidance notes for the reduction of obtrusive light - 2011

Curfew: The time after which more stringent requirements (for control of obtrusive light) will apply; often a condition of use of lighting by the local planning authority. If not otherwise stated – 23:00 hours is suggested by the ILP.

3.3 Summary of Sensitive Receptor Locations

A desktop study was executed using the existing infrastructure information. The viewpoints in Table 3.3 below span the area to be most likely affected by the proposed highway lighting and encompass the listed

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buildings in the area identified as sensitive receptors R8, R10, R12, R13 and R14. The key sensitive receptor locations have been illustrated in Appendix C and are listed in Table 3.3 below.

Table 3.3: Sensitive Receptor Locations Survey Viewpoint Location No Drawing Reference No Description of Location R1 MMD-339156-DT-0075 Fairview House, Smee Lane R2 MMD-339156-DT-0075 The Nurseries (rear property), Smee Lane, R3 MMD-339156-DT-0075 The Nurseries (front property), Smee Lane, R4 MMD-339156-DT-0075 Apple Tree Farm (west property), Smee Lane, R5 MMD-339156-DT-0075 Apple Tree Farm (east property), Smee Lane, R6 MMD-339156-DT-0075 Smee Farm Cottage, Smee Lane R7 MMD-339156-DT-0075 Smee Bungalow, Smee Lane R8 MMD-339156-DT-0075 Smee Farm, Smee Lane R9 MMD-339156-DT-0075 Smee Farm, Smee Lane R10 MMD-339156-DT-0075 Smee Barn, Smee Lane R11 MMD-339156-DT-0075 Bat gantry, Smee Lane R12 MMD-339156-DT-0075 Grove Farm, Smee Lane R13 MMD-339156-DT-0075 Grove Farm, Smee Lane R14 MMD-339156-DT-0075 Grove Farm, Smee Lane

Source: Mott MacDonald

The desktop study included an assessment of local conservation areas with the nearest identified conservation area being Thorpe End Garden Village. The village is some 1.5 kilometres from the lighting installation with no apparent direct views; it is therefore considered that no further assessment of the village will be required.

There is an existing footpath running to the east of the Business Park Roundabout and NDR which is being closed off and relocated to run along the new sections of highway. Lighting to the new path adjacent to a vehicular highway is not considered to have a detrimental effect on people using the path and therefore no further assessment will be required.

No heritage sites have been identified within the area and therefore no further assessment will be required.

The topography of the study area is gently undulating, with elevations between 26 m Above Ordnance Datum (AOD) at the north east falling to 16 m AOD at the south east and south west, a distance of approximately 600 metres.

3.4 Assessment of Effects and Determining of Significance

The proposed development will have varying levels of significance and these have been assessed based on the scale of change experienced by each identified sensitive receptor. The level of change is assessed

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on a scale of minor, moderate or major in terms of whether the changes have a positive, neutral or negative effect.

To determine the scale of the change in lighting levels at each key receptor, the following criteria have been utilised:  The obtrusive light limitations detailed in Table 3.2;  Type of lighting that will be in use during the operational phase;  The anticipated duration of artificial lighting during the hours of darkness;  The distance between the proposed lighting installation and the key sensitive receptor;  Existing and proposed screening from the proposed development.

The level of change evaluated from the criteria above is assessed using the matrix outlined in Table 3.4 below. Levels that are either moderate or above are considered to be a significant effect. Note that significant effects can be either beneficial or adverse.

Table 3.4: Evaluation Table Nature Ref Level Description Remedial Needs Positive 1 Major/substantial Significant improvement in night environment No remedial / beneficial effects and/or reductions in glare, spill light and sky glow. mitigation measures required 2 Moderate Noticeable improvements in night environment beneficial effects and/or reductions in glare, spill light and sky glow etc. 3 Minor beneficial Slight improvement in night environment and/or effects reductions in glare, spill light and sky glow etc. Neutral 4 None/negligible No significant effect or overall effects balancing out. Negative 5 Minor adverse Slight increase in visibility of site, glare, and sky Develop appropriate effects glow etc. levels and type of mitigation 6 Moderate Noticeable increase in visibility of site, glare and adverse effects sky glow etc. 7 Major adverse Significant problems with increase in visibility of effects site, glare, and sky glow etc.

Source: ILP Professional Lighting Guide 04

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4 Proposed Development

4.1 Proposed Lighting Design

The proposed lighting design has been carried out by Amey PLC on behalf of NCC.

The design of the proposed lighting has been based on providing lighting levels in accordance with British Standard BS5489-1:2003+A2:2008, Code of Practice for the design of road lighting.

The lighting across the Postwick Junction consists of lighting columns either 10 metres or 12 metres in height, which is in keeping with the required lighting levels for the roads. The lighting columns located on the NDR approach road are 10 metres in height.

The luminaires are flat glass and mounted at 0° tilt which should act to limit the amount of light spill, luminaire intensity and direct upward light.

The luminaires have an LED light source which emits a very low level of Ultra Violet (UV). The Philips WRTL Luma LED ranges are exempt from UV classification as the level of UV is under the low risk group as defined by BS EN 62471:2008. Lower levels of UV are known to limit the amount of insects attracted to the light source. This should therefore cause less disruption to the natural foraging routes of bats.

The bat gantry at Smee Lane is the nearest of all the sensitive receptors to the proposed lighting installation with this distance being approximately 280 metres.

Each of the properties has varying levels of hedgerow and tree cover providing an element of shielding from the proposed development.

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5 Predicted Impacts - Obtrusive Light Assessment

This section of the report highlights three specific forms of obtrusive light that have been assessed in detail.

The three forms of light pollution that are within the scope of this assessment are as follows:  Sky Glow – (in terms of the Upward Light Ratio) the upward spill of light into the sky which can cause a glowing effect and is often seen above cities when viewed from a dark area;  Light Intrusion – the spilling of light beyond the boundary of the area being lit. The unwanted spillage of light onto adjacent areas that may affect sensitive receptors, particularly residential properties; and  Luminaire Intensity – the amount of light that a source radiates in a given direction.

The obtrusive light limitations for an exterior lighting installation are dependent on the location of the site in terms of its environmental zone; the definitions of these zones are given within Appendix A – Guidance notes for the reduction of obtrusive light GN01:2011. For the purposes of this report the environmental zone has been assessed and assigned as E2, for further details of the environmental zone and the restriction that apply to that zone please refer to Section 2.

5.1 Maintenance Factor for Obtrusive Light calculations

To ensure that Obtrusive Light calculations cover the worst case scenario the maintenance factor has been set at 1.0, as required by ILP guidance notes.

5.2 Obtrusive Light Assessment

5.2.1 Sky Glow - Upward Light Ratio (ULR)

Upward Light Ratio or ULR is the maximum permitted percentage of the luminaires flux that goes directly into the sky, the general term for ULR over a large area such as a city or town is referred to as Sky Glow. Please note that Upward Light Ratio is not subject to differing limits dependant on time and hence there are no pre and post curfew readings, as they are not required.

Table 5.1: ULR – ILP Guidance Source of requirement Maximum permissible ULR ILP Guidance – Sky Glow (ULR) E2 Zone ULR <= 2.5%

Source: ILP

Sky Glow – Proposed NDR Postwick Junction Lighting

The lighting for the different sections of the Postwick Junction layout utilises five different variations of the Philips WRTL Luma LED luminaire. The different options are listed below with the polar diagram for each variation obtained from Lighting Reality Roadway. The polar diagrams provide information on the level of light emitted from the luminaire at different angles with light emitted from the luminaire above 90° considered as direct upward light.

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As can be seen in Figures 5.1 to 5.5, none of the five variations of luminaire when mounted at 0° tilt emit light above the 90° angle and can therefore be considered as having a 0% ratio of direct upward light.

This analysis shows that the proposed luminaires are all within the ILP limits for direct upward light and therefore the level of effect has been classified as None/Negligible.

Figure 5.1: Polar Diagram Philips WRTL Luma 3 R5 32klm

Source: Mott MacDonald – Lighting Reality Roadway

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Figure 5.2: Polar Diagram Philips WRTL LUMA 3 R5 48klm

Source: Mott MacDonald – Lighting Reality Roadway

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Figure 5.3: Polar Diagram Philips WRTL LUMA 2 R5 27klm

Source: Mott MacDonald – Lighting Reality Roadway

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Figure 5.4: Polar Diagram Philips WRTL Luma 2 R5 30klm

Source: Mott MacDonald – Lighting Reality Roadway

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Figure 5.5: Polar Diagram Philips WRTL Luma 2 R5 22klm

Source: Mott MacDonald – Lighting Reality Roadway

5.2.2 Light Intrusion (onto windows)

This section of the report assesses the Light Intrusion onto windows of properties in the affected areas. The spilling of light beyond the boundary of the area being lit onto adjacent areas may affect sensitive receptors, particularly residential properties. The two dimensional model has been constructed with all proposed luminaires in the design positions provided to ensure that the results provided are realistic and accurate. All maintenance factors have been set at 1.0 to allow for the worst case scenario of the initial first day installation.

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Table 5.2: Summary of Light Intrusion (onto windows) Pre Curfew Maximum Permissible Post Curfew Maximum Source of requirement Lux Permissible Lux ILP Guidance – Light Intrusion E2 Zone 5 1

Source: ILP

At this stage the curfew time has not been confirmed with the local planning authority and has been assumed as 23:00hrs, after which the more stringent requirements for control of obtrusive light, highlighted in table 5.2, will apply.

Please refer to the Spill Light Contour Plan, drawing number MMD-339156-DT-0075 within Appendix C, this plan provides a general overview of the spill light contours associated with this proposed development.

From reviewing the lux contour lines provided on the plan it can be seen that none of the identified sensitive receptor locations experience either of the pre-curfew or post curfew limits of 5 Lux and 1 Lux respectively. Furthermore an additional contour line of 0.01 Lux has been included on the plan which represents a near moonless sky at night. To put this into perspective a fully moonlit sky will provide approximately 0.4 Lux. This 0.01 Lux line is a significant distance from all of the identified sensitive receptor locations.

A level of 0.01 lux means that the lighting would have no impact on bats. The viability of the bat gantry would therefore remain as required; the lighting would not reduce the effectiveness of the gantry.

Two dimensional lighting model analysis shows that all identified sensitive receptors including the bat gantry at Smee Lane are all within the ILP limits for a pre and post curfew light intrusion by a significant margin therefore the level of effect has been classified as None/Negligible.

5.2.3 Luminous Intensity

This section of the report considers the luminous intensity of the proposed luminaires and the effect that this may have on the affected areas.

Luminous intensity is a direct calculation, measured in Candelas, from an observer location at a given height looking at the luminaire. It is standard practice for an observer height to be 1.5m above ground level.

Table 5.3: Luminous Intensity Requirements – ILP Guidance Maximum permissible Maximum permissible Source of requirement Pre Curfew Post Curfew ILP Guidance – Luminous Intensity E2 7,500 cd 500 cd Zone Source: ILP

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Whilst specific calculations have not been carried out due to the relatively flat nature of the landscape, an assessment, based on the equipment specification and experience, of the lighting design has been carried out in terms of luminous intensity and the following can be concluded:  The nearest sensitive receptor is at least 280 metres from the lighting installation;  The luminaires are mounted at 0° tilt;  The luminaires are flat glass;  The luminous intensity class of the luminaires, as shown in figures 5.1 to 5.5 defines the luminaires as having a rating of G4. Luminous intensity classes are used to restrict the level of disability glare and/or the control of obtrusive light as defined in BS EN 13201-2:2003 British Standard for Road Lighting Part 2: Performance Requirements. G1, G2 and G3 rated luminaires are considered to achieve “semi cut-off” and “cut-off” characteristics with G4, G5 and G6 rated luminaires being considered to achieve “full cut-off” characteristics.

For the reasons stated above the effects on the identified sensitive receptors caused by the luminous intensity of the proposed luminaires are considered as None/Negligible.

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6 Calculation and Methodology

6.1 Calculation Notes and Methodology

Numerical modelling and calculations have been carried out using the lighting analysis software Lighting Reality Pro version 1.7, Area and Roadway.

6.2 Assumptions

The following assumptions have been made:  Obtrusive light is considered for the properties and bat gantry at Smee Lane identified on drawing MMD-339156-DT-0075.  Topographical levels of the area between the NDR and identified sensitive receptors are considered as relatively flat.  Existing lighting has not been included in the proposed lighting calculations, only the lighting indicated on drawing MMD-339156-DT-0075 has been considered.  Trees and all other vegetation have not been considered for the purpose of light spill calculation to provide a ‘worst case’ assessment, i.e. in winter when vegetation is minimal, or to allow for vegetation to be removed in the future.  Luminaire photometry from the relevant lighting manufacturers has been utilised.  Upward Light Ratio and Light Spill calculations utilise an overall maintenance factor of 1.0, as this is the worst case scenario. This maintenance factor would be equivalent to the initial installation rather than the deteriorated light output from the luminaires which would occur over months and years of use.

Spill Light calculations performed are direct calculations only; no account of the reflective properties of the various surfaces has been incorporated into the model.

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Appendices

Appendix A. Guidance Notes for the Reduction of Obtrusive Light ______19 Appendix B. NCC Street Lighting Plan ______20 Appendix C. MM Lighting Impact Assessment – Receptor and Contour Plan ______21 Appendix D. Lighting Calculations ______22

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Appendix A. Guidance Notes for the Reduction of Obtrusive Light

A.1 Guidance Notes for the Reduction of Obtrusive Light GN01:2011

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Guidance Notes for the Reduction of Obtrusive Light GN01:2011

GUIDANCE NOTES FOR THE REDUCTION OF OBTRUSIVE LIGHT

“Think before you light - The right amount of light, where wanted, when wanted.”

Man's invention of artificial light has done much to safeguard and enhance our night-time environment but, if not properly controlled, obtrusive light (sometimes referred to as light pollution) can present serious physiological and ecological problems.

Obtrusive Light, whether it keeps you awake through a bedroom window or impedes your view of the night sky, is a form of pollution, which may also be a nuisance in law and which can be substantially reduced without detriment to the lighting task.

Sky glow, the brightening of the night sky, Glare the uncomfortable brightness of a light source when viewed against a darker background, and Light Intrusion (“Trespass”), the spilling of light beyond the boundary of the property or area being lit, are all forms of obtrusive light which may cause nuisance to others and waste money and energy. Think before you light. Is it necessary? What effect will it have on others? Will it cause a nuisance? How can you minimise the problem?

Figure 1 – Types of obtrusive light

Do not "over" light. This is a major cause of obtrusive light and is a waste of energy. There are published standards for most lighting tasks, adherence to which will help minimise upward reflected light. Organisations from which full details of these standards can be obtained are given on the last page of this leaflet.

1 Guidance Notes for the Reduction of Obtrusive Light GN01:2011

Dim or switch off lights when the task is finished. Generally a lower level of lighting will suffice to enhance the night time scene than that required for safety and security.

“Good Design equals Good Lighting”

Any lighting scheme will consist of three basic elements: a light source, a luminaire and a method of installation.

Light sources (Lamps)

Remember that the light source output in LUMENS is not the same as the wattage and that it is the former that is important in combating the problems of obtrusive light.

Most nightime visual tasks are only dependant on light radiated within the visual spectrum. It is therefore NOT necessary for light sources to emit either ultra-violet or infra-red radiation unless specifically designed to do so. It is also understood that light from the shorter wavelengths of the spectrum has important effects on both flora and fauna that should be considered.

Research indicates that light from the blue end of the spectrum has important non-visual effects on the health of the human body, in particular in our sleep/wake patterns. It is therefore important to appreciate that while in obtrusive light terms the use of blue light should be minimised, there are many night-time tasks such as driving and sports where to be fully awake is an important aid to safety.

Luminaires

Care should always be taken when selecting luminaires to ensure that appropriate products are chosen and that their location will reduce spill light and glare to a minimum.

Use specifically designed lighting equipment that minimises the upward spread of light near to and above the horizontal. The most sensitive/critical zones for minimising sky glow are those between 90o and 100o as shown in Figure 2 and referred to as the lower, upward light output zone (UL).

Figure 2 – Critical luminaire angles For minimising sky glow

2 Guidance Notes for the Reduction of Obtrusive Light GN01:2011

For most sports and area lighting installations the use of luminaires with double- asymmetric beams designed so that the front glazing is kept at or near parallel to the surface being lit should, if correctly aimed, ensures minimum obtrusive light.

Appendices 1 and 2 to these notes gives more details of how to choose and if necessary modify luminaires.

Installation

In most cases it will be beneficial to use as high a mounting height as possible, giving due regard to the daytime appearance of the installation. The requirements to control glare for the safety of road users are given in Table 3.

Keep glare to a minimum by ensuring that the main beam angle of all lights directed towards any potential observer is not more than 70o. Higher mounting heights allow lower main beam angles, which can assist in reducing glare. In areas with low ambient lighting levels, glare can be very obtrusive and extra care should be taken when positioning and aiming lighting equipment. With regard to domestic security lighting the ILP produces an information leaflet GN02:2009 that is freely available from its website.

Figure 3 – Luminare aiming angles

Poor Okay Good

When lighting vertical structures such as advertising signs, direct light downwards wherever possible. If there is no alternative to up-lighting, as with much decorative lighting of buildings, then the use of shields, baffles and louvres will help reduce spill light around and over the structure to a minimum.

For road and amenity lighting installations, (see also design standards listed on Page 5) light near to and above the horizontal should normally be minimised to reduce glare and sky glow (Note ULR’s in Table 2). In rural areas the use of full horizontal cut off luminaires installed at 0o uplift will, in addition to reducing sky glow, also help to minimise visual intrusion within the open landscape. However in some urban locations, luminaires fitted with a more decorative bowl and good optical control of light should be acceptable and may be more appropriate.

3 Guidance Notes for the Reduction of Obtrusive Light GN01:2011

Figure 4 – Façade Illumination

Poor Good Good

Since 2006 “Artificial Light” has been added to the list of possible Statutory Nuisances in England, Wales and Scotland. The monitoring of such nuisances will be the responsibility of Environmental Health Officers (EHOs) for which separate guidance is being produced.

With regard to the planning aspect, many Local Planning Authorities (LPAs) have already produced, or are producing, policies that within the planning system will become part of their local development framework. For new developments there is an opportunity for LPAs to impose planning conditions related to external lighting, including curfew hours.

The Scottish Executive has published a design methodology document (March 2007) entitled “Controlling Light Pollution and Reducing Energy Consumption” to further assist in mitigating obtrusive light elements at the design stage.

ENVIRONMENTAL ZONES

It is recommended that Local Planning Authorities specify the following environmental zones for exterior lighting control within their Development Plans.

Table 1 – Environmental Zones

Zone Surrounding Lighting Examples Environment E0 Protected Dark UNESCO Starlight Reserves, IDA Dark Sky Parks E1 Natural Intrinsically dark National Parks, Areas of Outstanding Natural Beauty etc E2 Rural Low district brightness Village or relatively dark outer suburban locations E3 Suburban Medium district Small town centres or suburban locations brightness E4 Urban High district Town/city centres with high levels of night- brightness time activity

4 Guidance Notes for the Reduction of Obtrusive Light GN01:2011

Where an area to be lit lies on the boundary of two zones the obtrusive light limitation values used should be those applicable to the most rigorous zone.

NB: Zone E0 must always be surrounded by an E1 Zone.

DESIGN GUIDANCE

The following limitations may be supplemented or replaced by a LPA’s own planning guidance for exterior lighting installations. As lighting design is not as simple as it may seem, you are advised to consult and/or work with a professional lighting designer before installing any exterior lighting.

Table 2 – Obtrusive Light Limitations for Exterior Lighting Installations – General Observers Environment Sky Glow Light Intrusion Luminaire Intensity Building al Zone ULR (into Windows) I [candelas] (3) Luminance (2) [Max Ev [lux] Pre-curfew %](1) (4) Pre- Post- Pre- Post- Average, curfew curfew curfew curfew L [cd/m2] E0 0 0 0 0 0 0 E1 0 2 0 ( 1*) 2,500 0 0 E2 2.5 5 1 7,500 500 5 E3 5.0 10 2 10,000 1,000 10 E4 15 25 5 25,000 2,500 25

ULR = Upward Light Ratio of the Installation is the maximum permitted percentage of luminaire flux that goes directly into the sky.

Ev = Vertical Illuminance in Lux - measured flat on the glazing at the centre of the window.

I = Light Intensity in Candelas (cd)

L = Luminance in Candelas per Square Metre (cd/m2)

Curfew = the time after which stricter requirements (for the control of obtrusive light) will apply; often a condition of use of lighting applied by the local planning authority. If not otherwise stated - 23.00hrs is suggested.

* = Permitted only from Public road lighting installations

(1) Upward Light Ratio – Some lighting schemes will require the deliberate and careful use of upward light, e.g. ground recessed luminaires, ground mounted floodlights, festive lighting, to which these limits cannot apply. However, care should always be taken to minimise any upward waste light by the proper application of suitably directional luminaires and light controlling attachments.

5 Guidance Notes for the Reduction of Obtrusive Light GN01:2011

(2) Light Intrusion (into Windows) – These values are suggested maxima and need to take account of existing light intrusion at the point of measurement. In the case of road lighting on public highways where building facades are adjacent to the lit highway, these levels may not be obtainable. In such cases where a specific complaint has been received, the Highway Authority should endeavour to reduce the light intrusion into the window down to the post curfew value by fitting a shield, replacing the luminaire, or by varying the lighting level.

(3) Luminaire Intensity – This applies to each luminaire in the potentially obtrusive direction, outside of the area being lit. The figures given are for general guidance only and for some sports lighting applications with limited mounting heights, may be difficult to achieve.

(4) Building Luminance – This should be limited to avoid over lighting, and related to the general district brightness. In this reference building luminance is applicable to buildings directly illuminated as a night-time feature as against the illumination of a building caused by spill light from adjacent luminaires or luminaires fixed to the building but used to light an adjacent area.

Table 3 – Obtrusive Light Limitations for Exterior Lighting

Installations – Road Users

Road Threshold Increment (TI) Veiling (1) Classification Luminance (Lv)

No road lighting 15% based on adaptation 0.04 2 luminance of 0.1cd/m ME6/ ME5 15% based on adaptation 0.25 2 luminance of 1cd/m ME4/ ME3 15% based on adaptation 0.40 luminance of 2cd/m ME2 / ME1 15% based on adaptation 0.84 2 luminance of 5cd/m

TI = Threshold Increment is a measure of the loss of visibility caused by the disability glare from the obtrusive light installation

Lv = Veiling Luminance is a measure of the adaptation luminance caused by the disability glare from the obtrusive light installation

(1) = Road Classifications as given in BS EN 13201 - 2: 2003 Road lighting Performance requirements. Limits apply where users of transport systems are subject to a reduction in the ability to see essential information. Values given are for relevant positions and for viewing directions in path of travel. For a more detailed description and methods for determining, calculating and measuring the above parameters see CIE Publication 150:2003.

6 Guidance Notes for the Reduction of Obtrusive Light GN01:2011

RELEVANT PUBLICATIONS AND STANDARDS:

British Standards: BS 5489-1: 2003 Code of practice for the design of road lighting – Part 1: Lighting www.bsi.org.uk of roads and public amenity areas BS EN 13201-2:2003 Road lighting – Part 2: Performance requirements BS EN 13201-3:2003 Road lighting – Part 3: Calculation of performance BS EN 13201-4:2003 Road lighting – Part 4: Methods of measuring lighting performance. BS EN 12193: 1999 Light and lighting – Sports lighting BS EN 12464-2: 2007 Lighting of work places – Outdoor work places

Countryside Commission/ Lighting in the Countryside: Towards good practice (1997) (Out of Print but DOE available on www.communities.gov.uk/index.asp?id=1144823)

UK Government / Defra Statutory Nuisance from Insects and Artificial Light – Guidance on Sections 101 to www.defra.gov.uk 103 of the Clean Neighbourhoods and Environment Act 2005

Road Lighting and the Environment (1993) (Out of Print)

CIBSE/SLL Publications: CoL Code for Lighting (2002) www.cibse.org LG1 The Industrial Environment (1989) LG4 Sports (1990+Addendum 2000) LG6 The Exterior Environment (1992) FF7 Environmental Considerations for Exterior Lighting (2003)

CIE Publications: 01 Guidelines for minimizing Urban Sky Glow near Astronomical Observatories (1980) www.cie.co.at 83 Guide for the lighting of sports events for colour television and film systems (1989) 92 Guide for floodlighting (1992) 115 Recommendations for the lighting of roads for motor and pedestrian traffic – Second Edition (2010) 126 Guidelines for minimizing Sky glow (1997) 129 Guide for lighting exterior work areas (1998) 136 Guide to the lighting of urban areas (2000) 150 Guide on the limitations of the effect of obtrusive light from outdoor lighting installations (2003) 154 The Maintenance of outdoor lighting systems (2003)

ILP Publications: TR 5 Brightness of Illuminated Advertisements (2001) www.theilp.org.uk TR24 A Practical Guide to the Development of a Public Lighting Policy for Local Authorities (1999) GN02 Domestic Security Lighting, Friend or Foe

ILP/CIBSE Joint Lighting the Environment - A guide to good urban lighting (1995) Publications

ILP/CSS Joint Code of Practice for the installation, maintenance and removal of seasonal Publications decorations. (2005)

ILP/CfDS Joint Publication Towards Understanding Sky glow. 2007 www.dark-skies.org

IESNA www.iesna.org TM-15-07 (R) Luminaire Classification System for Outdoor luminaires

NB: These notes are intended as guidance only and the application of the values given in Tables 2 & 3 should be given due consideration along with all other factors in the lighting design. Lighting is a complex subject with both objective and subjective criteria to be considered. The notes are therefore no substitute for professionally assessed and designed lighting, where the various and maybe conflicting visual requirements need to be balanced.

© 2011 The Institution of Lighting Professionals. Permission is granted to reproduce and distribute this document, subject to the restriction that the complete document must be copied, without alteration, addition or deletion.

7 Guidance Notes for the Reduction of Obtrusive Light GN01:2011

APPENDIX 1 - PROPOSED OUTDOOR LUMINAIRE CLASSIFICATION SYSTEM

Variable Aim Luminaires – General Classifications:

Proposed labelling System:

Fixed Position luminaires Variable Aim Luminaires (Shown here for a 45o Double-Asymmetric luminaire aimed at 70o – with and without a cowl).

8 Guidance Notes for the Reduction of Obtrusive Light GN01:2011

APPENDIX 2 - ILLUSTRATIONS OF LUMINAIRE ACCESSORIES FOR LIMITING OBTRUSIVE LIGHT (images provided by Philips and Thorn)

Cowl (or Hood) External Louvre

SHIELD SHEILD “Barn Doors”

Double Asymmetric Luminaire Simple Hood

9 Guidance Notes for the Reduction of Obtrusive Light GN01:2011

Circular Louvre Cowl & Louvre

Internal Louvre (horizontal) Internal Louvre (vertical)

10 Norwich Northern Distributor Road Postwick Junction Lighting Assessment

Appendix B. NCC Street Lighting Plan

B.1 NCC Street Lighting Plan, drawing number R1C093-R1-4950

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Norwich Northern Distributor Road Postwick Junction Lighting Assessment

Appendix C. MM Lighting Impact Assessment – Receptor and Contour Plan

C.1 Mott MacDonald Lighting Impact Assessment – Receptor and Contour Plan, drawing number MMD-339156-DT-0075

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Norwich Northern Distributor Road Postwick Junction Lighting Assessment

Appendix D. Lighting Calculations

D.1 Consistency Checked Lighting Calculations

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