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NORWICH NORTHERN DISTRIBUTOR ROAD TRO10015

EXAMINATION OF NORFOLK COUNTY COUNCIL’S APPLICATION FOR DEVELOPMENT CONSENT ORDER

WRITTEN REPRESENTATION FROM Norwich and Norfolk Transport Action Group (NNTAG) PINS Registration No. 10026257 June 2014 Introduction

1. NNTAG is an umbrella body of local environment and transport groups with the aim of promoting sustainable transport. The group creates a forum for information exchange; it campaigns on issues (such as No to NDR); it participates in the planning process. Member groups include Campaign for Better Transport, Norfolk Buswatch, Norwich Cycling Campaign, Norwich & Norfolk Friends of the Earth, Norfolk Living Streets, Railfuture and Tramforward. NNTAG has a chairman, secretary and treasurer who are elected annually; each member group sends a representative to the committee.

Author

2. This statement has been prepared by Denise Carlo who coordinates the NNTAG 'No to NDR' campaign. My qualifications are: BA Hons in History and Landscape Archaeology; PG Dip AA in Conservation of Historic Landscapes, Parks and Gardens; PG Dip in Urban Planning. I have campaigned on local (Norwich) and regional (East of England) environmental transport matters since 1986.

NDR and the Norwich Inner Ring Road Phase 3

3. NNTAG was formed in 1988 to oppose the Norwich Inner Ring Road Phase 3 (IRR3) and lobby for a sustainable transport strategy. The Secretary of State called-in the application for inquiry in 1992. NNTAG commissioned MTRU to develop a non-road building alternative. MTRU proposed a paper based morning peak hour permit system. Modelling by Norfolk County Council (NCC) demonstrated the measure's effectiveness in removing city centre

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through traffic. The Inspector recommendation to reject the IRR3, describing the scheme as “a temporary and costly answer', was accepted by the Secretary of State. In his conclusions, the Inspector said that traffic restraint appeared “inevitable and desirable”. Dismissal of IRR3 prompted NCC to review NATS and to the adoption of a new strategy based on park and ride and no major increase in road capacity.

4. The NDR and IRR3 share much in common:

the claim by NCC that the NDR would remove 19,000 vpd from the city centre; exactly the number that the County said would be removed by IRR3.

the claim by NCC that the NDR is fundamental to the delivery of NATS; exactly the claim made for IRR3.

the claim by NCC that there are is no alternative to the NDR; exactly the line taken on IRR3. NNTAG's Involvement with the NDR

5. NNTAG has had a long involvement with the NDR, starting with the Norwich Northern Bypass proposed in the 1988 NATS review. The scheme was abandoned in 1996 on financial and environmental grounds, but revived as the NDR by a new County Council administration in 2000.

6. We have tried to make a constructive contribution at all stages of the various

planning processes surrounding the NDR. NNTAG represented environmental transport interests on EERA's Regional Transport Forum from 2000 to 2006; we participated in the EoE Plan EiP in 2005, the JCS EiP in 2010 and 2013; we commented on the MSBC and CIF bids in 2008 and 2009 and on the Development Pool bid in 2011; we appeared at Postwick Hub public inquiry in 2013. Over the years, we have commissioned several reports from independent consultants: Prof. Alan Wenban Smith, Dr Denvil Coombe, MTRU and at this Eamination, Prof. Phil Goodwin.

7. The history of the NDR, as we have seen it evolve over many years, is outlined in 'How Norfolk County Council Changed the NDR from a Local Road Scheme to a 'Nationally Significant' Project to the Detriment of Local People (1988-present)', in 'Public Consultation and Engagement' submitted by CPRE et al.

NDR is a Predict and Provide Scheme

8. In essence, the NDR is a traditional predict and provide road scheme for

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harnessing economic development and fostering traffic growth but dressed up as the agent for delivering sustainable transport. The 2008 MSBC was put forward in a sustainable transport plan vacuum. Environmental transport groups were instrumental in re-shaping the draft East of England Plan transport strategy and the Norwich Policy Area policy away from road building-led strategies to those based on modal shift, but NCC took few steps to reorientate transport in line with the published Plan (2008). With the help of MTRU, NNTAG and CPRE criticised this failure which led to the County developing a NATS Implementation Plan in 2009, albeit one which hinges on the NDR and to DfT making NDR Programme Entry conditional upon funding and delivery of sustainable transport measures.

9. Political ambitions for the NDR have spiralled out of control. In the DCO

application, the NDR is presented, unrealistically, as the solution to a wide range of problems and issues: unemployment; deprivation; falling incomes in north Norwich, Great Yarmouth and east Norfolk; low house prices in north Norwich; improving conditions for sustainable transport; removal of city centre traffic; reduction in congestion and rat running in north Norwich and surrounding villages; protection of environmental amenity; opening up land for major development to include at least 10,000 dwellings in north-east Norwich; speeding up journeys to key employment locations, notably the Airport, Rackheath, Broadland business parks area, the City Deal area (covering the whole city) and Great Yarmouth Enterprise Zone; bringing more tourists to north Norfolk and Norwich and more shoppers to the city centre; regenerating the city centre and its northern quadrant; improving access to the former RAF Coltishall; improving access to the strategic road network; doubling the size of Aylsham and expanding North Walsham.

10. And at the same time as all the above, we are told that the NDR would

reduce people's exposure to traffic, air pollution and noise, improve road safety, enhance access to facilities, speed up bus journeys, create more wildlife habitats, mitigate climate change and generally add to the quality and comfort of life in Norwich.

A47 Norwich Southern Bypass

11. It is ironical that the A47 Norwich Southern Bypass was predicted to bring benefits of a similar order; yet eight years after the bypass opened in 1993, the NDR came back onto the political agenda as a vital scheme for reducing congestion. Traffic was allowed to grow back again in the short time the bypass was open. The Post Opening Evaluation of the A47 Norwich Southern

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Bypass Study (1998,TecnEcon) (which has not been submitted by NCC) estimated that 3% to 3.3% of trips were induced. A comparison of traffic flows reported in the 1998 study with current flows in NDR 2012 Base Year reveals significant traffic growth in 15 years.

12. This is unsurprising as only modest sustainable transport measures have been implemented outside of city centre. Large numbers of HGVs continue to rattle along the ORR, on Colman Road past people's homes in south Norwich for example, which the bypass was supposed to remove. Also, large scale traffic- generating development has been permitted at key junctions along the Southern Bypass on the periphery of Norwich, generating short distance car trips: retail at Longwater; a new district hospital at Colney (with the largest car park in Norfolk) and business park development at Thorpe St Andrew/Postwick.

13. It is a further irony that the same failed predict and provide transport policies which built the southern bypass have resulted in calls for more road building to solve the problems.

NDR as a Nationally Significant Infrastructure Project

14. However the promoter/supporters' ambitions for the NDR go much further than their declared aims of tackling local traffic and environmental conditions. In 2001, NCC endorsed Shaping the Future's Economic Strategy for Norfolk 2001- 2010 which listed the NDR as one of their five transport infrastructure priorities, along with A11 and A47 dualling, expansion of Norwich Airport and Great Yarmouth outer harbour.

15. Their vision for a transport/economic development corridor stretching from the Midlands to Norwich and a third orbital road and onto Great Yarmouth (with proposals for extending the A47 to Lowestoft) and the Continent has come full circle, in the treatment of the NDR as 'nationally significant' on grounds it would connect Norwich Airport with the A47-TEN-T and Great Yarmouth Enterprise Zone.

16. The NCC promotional brochure for business, Northern Distributor Route: Unlocking potential for Greater Norwich (Autumn 2013), shows how the NDR fits into the County's larger transport ambitions.

http://www.norfolk.gov.uk/Travel_and_transport/Major_projects_and_improvement_plans/Norwich/Northern_Distributor_Road/index.htm

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We see from NCC's letter of application (25 July 2013) for NSIP status to the Secretary of State that the ambitions for the NDR were far reaching:

“The NDR will drive growth in East Anglia”. (p2)

“The NDR supports national growth potential” (p6)

17. Despite nearly two decades of transport wisdom and policy on breaking the link between traffic and economic growth, we have a scheme that seeks to-re-engineer that link. The NDR is a scheme working to two different agendas. Firstly, a scheme for supporting strategic (long distance) traffic and transport-led economic growth. Secondly, a scheme we are told is a pre-requisite for dealing with local traffic and local conditions.

18. Reading through the numerous documents since 2001, what is apparent are the nuances of presentation and language that emphasis different aspects of need for the NDR depending on the audience: official bid documents to the Department for Transport and Department for Communities and Local Government; local business leaders; the public; residents living close to the route.

19. The Sec of State's decision (letter dated 9 Aug 2013 but not released to the public until 19 Aug) to treat the NDR as a NNSIP came as a shock to local people. Not only did the announcement come out of the blue halfway through the pre-application consultation, the implications for local residents as a result of the impacts of a scheme designed to attract strategic traffic and economic growth were far reaching in their implications.

20. It was the first occasion of reference to connecting the NDR to A47-TEN-T and Great Yarmouth Enterprise Zone. The Statement of Community Consultation had made no reference to the A47 TEN-T and connection to Great Yarmouth Enterprise Zone as a justification for constructing the NDR.

21. Neither had the Preliminary Environmental Information Report (June 2013) cited the connection to A47 TEN-T and Gt Yarmouth Enterprise Zone or set out the case for the scheme's 'national significance as a reason for the scheme. Consequently, the PEI did not assess the potential environmental impacts on sensitive habitats along the A47 Acle Straight, nor the socio-economic impacts on the Great Yarmouth economy.

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22. It appears that the new objective for the NDR was added in at a late stage, unsupported by evidence.

Non Compliance with Habitat Regulations

23. The Traffic Flows map (Traffic Forecasting Report, Vol 3 Fig 1.4) shows an increase in traffic on the Acle Straight with the NDR in 2017 (1,100 vpd) and 2032 (2,500 vpd).

2-way AADT traffic flows for the Acle Straight: 2012 - 23,100 2017 25300 (without NDR) 26400 (with NDR 2032 30400 (without NDR) 32900 (with NDR)

24. Even small changes in traffic can potentially impact on fragile habitats. Despite the significant traffic increase, there has been no Appropriate Assessment of the indirect effects of additional traffic on air and noise pollution on nationally and internationally designated habitats at Breydon Water, Halvergate Marshes and Damgate Marshes along the Acle Straight, otherwise the Examining Authority and Secretary of State will not be in compliance with the Habitats Directive.

25. More detail on this matter is in NNTAG's Appendix 1 on National Policy Context.

26. Norfolk County Council, as the driving force behind the A47 Alliance, has persuaded the Government to carry out an A47 Feasibility Study, with the intention of securing end to end dualling. It is quite likely that NCC sold to Government the 'national significance' line on the NDR connecting the Airport to A47 TEN-T and Great Yarmouth Enterprise Zone, in order to achieve its goal of dualling of the A47 Acle Straight.

River Wensum SAC and EIA

27. The Secretary of State's NSIP Direction has emboldened NDR proponents.

28. In a meeting of the Full Council on13 September 2013, elected members resolved to commission a scoping/feasibility report on providing a link across

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the Wensum valley from the A1067 to the A47 Southern Bypass which the County had dropped in 2005.

29. The County Councillor for Costessey who put forward the motion sees it as a formality in a short step to completing the NDR. In an email (9/3/14) to a constituent he wrote:

“It has been already agreed to extend the NDR to fill in the missing link over the Wensum; that’s why I proposed the motion which had the support of the full council in September. It will now happen.”

30. NNTAG is concerned that NCC will try to take the NDR across the Wensum valley as soon as possible. Firstly to deal with traffic problems. It's interesting to note that the DCO Scheme has deleted the traffic calming proposals in the northern suburbs which featured in the 2008 Major Scheme Business Case as a means of mitigating any traffic effects of a three quarters NDR. Secondly, the NCC will want to build further major road infrastructure to attract further economic growth.

31. The EIA does not address the likelihood of River Wensum crossing in its chapter on Cummulative Impacts.

NDR Extension West of A140

32. The DfT did not accept the extension in the Programme Entry. The dual carriageway extension serves little purpose and has been dubbed 'Road to Nowhere'. The Traffic Forecasting Report shows that traffic would reassign from the A47(T) west of the city to the A1067 (7.1.5 of Doc 5.6). Even with the road extension in place, traffic would increase on the radial roads in north Norwich to the detriment of sustainable transport. The fig leaf that the NDR would facilitate traffic management in the northern suburbs is implausible given that NCC has withdrawn proposals for traffic calming measures here. There are no development and growth areas planned (as yet) for the area west of the A140. Its main purpose appears to be little more than signposting the NDR to the Wensum in an effort to ensure that a approval for a three quarters route would lead to a complete NDR.

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Why NNTAG Objects to the NDR

33. NNTAG opposes the Norwich NDR for reasons which include:

Traffic, Transport and Land Use Planning

34. We are concerned that the NDR would:

simply re-distribute traffic. Some roads would see a reduction, but other roads would see an increase, eg villages to the west, radial roads in NE Norwich

(Traffic flows maps figs 1.1 to 1.4 in the Traffic Forecasting Report, Vol 3).

result in an overall increase in traffic. Unless road space reallocation takes place between now and shortly after opening, newly released road space would quickly be taken up by new trips attracted to the network (as suggested by TecnEcon's 1998 Norwich Southern Bypass study). If traffic continues to grow beyond 2032 (in line with the National Road Traffic Forecast of 46% more traffic on the strategic road network by 2040), the implications are serious for the local road network and also the strategic road network such as Postwick signalised junction and communities.

lead to rat running through residential areas to access the A47 Southern Bypass adding to pressures for a Wensum crossing.

create more motorised orbital journeys which would be difficult to shift to modal transport. In particular, connecting strategic housing/employment allocations in NE Norwich to those SW of the City, would generate short distance trips. Overall, the NDR would increase reliance on car use.

add to pressure for car based development on the periphery of Norwich, with more urban sprawl and traffic. We are very concerned that a NDR could create a third ring of development around Norwich from the north-west round to A47 East and also put development pressures on the first ring of villages outside the NDR not unlike the Growth Triangle. The report, 'Trunk Roads and the Generation of Traffic' (SACTRA, 1994) looked at Norwich and the NDR as a case study. It concluded that the level of induced traffic would be 'very significant' if sites along the NDR were to be developed to 100% of their assumed potential. (Land-Use/Transport Interaction Modelling in Norwich p157- 161).

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create pressures for further road building. Already, in response to the three quarters NDR adopted, Norfolk CC has resolved to proceed with a 7.2 km single carriageway link road (£6.7 million) between A47 near Hockering and A1067 near Lenwade to deal with anticipated traffic problems. Even though the link is regarded as essential for mitigating traffic, it has not been included in the NDR costs We could see future upgrades to the A47 Southern Bypass junctions are a result of the NDR, for example additional traffic is shown between A146 and Postwick Interchange with the NDR.

Environment and Communities

35. NNTAG is concerned that the NDR would result in unacceptable harm to the environment and to communities. It would:

run close to the ring of villages around north Norwich and the city's urban fringe.

result in more traffic overall with impacts on noise, air and light pollution, severance and road danger and quality of life.

the additional motorised traffic and vehicle mileage would increase greenhouse gas emissions and undermine efforts to tackle climate change.

obliterate an area of countryside to north of Norwich, bisect two historic parks at Rackheath and Beeston St Andrew, sacrifice high grade farmland needed for food security and undermine the City's rural setting. Whilst the setting of the southern bypass is protected by landscape policies in the Local Plan, the countryside to the north of Norwich has little protection.

create intense development pressures for further development along the NDR. Land severed by the road west of the A140 would no longer be viable for agriculture and would instead become vulnerable to development pressures.

threaten important wildlife habitats and landscapes. It would put pressure to extend the NDR across the River Wensum Special Area of Conservation. Traffic growth on the A47 Acle Straight with the NDR would increase pressure for dualling through the environmentally sensitive Broads area. Increased access by car to areas north of Norwich would lead to increased impacts on fragile natural habitats of the coast and Broads.

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promote car-dependent travel patterns, with implications for public health.

Economic

36. NNTAG is concerned that the NDR would:

encourage even more growth on the periphery of Norwich at the expense of more sustainable locations, notably the city centre. Our concern has been underlined by a study commissioned by NCC, “The Economic Impact of the NDR” (Roger Tym and Partners, 2005) which concluded that main positive effects would be felt on the periphery of Norwich near the NDR route. Overall, the study presented a mixed picture on whether a NDR would deliver employment growth. It concluded that:

A NDR would have only limited effects on: - retail sector or office employment in Norwich city centre - labour market - unemployment - economic activity rates - tourism - suppliers - social exclusion - uncertain impact on the property market and inward investment.

The report was quietly shelved by the County Council.

undermine towns with fragile economies such as Great Yarmouth and North Walsham and the coastal towns. A paper for NNTAG for the draft consultation East of England Plan (Prof. Alan Wenban Smith, 2004) concluded that:

“The extent to which NNDR is likely to facilitate access to other towns and villages has been over-stated. To the extent that it does it could lead to diversion of customers for local services from smaller settlements to Norwich. This could well be accompanied by further extension of housing demand from Norwich into such areas, raising house prices and increasing traffic impacts. Norwich might gain to the extent that its labour market is extended, but any such benefit would diminish over time as people commute from further away and congestion increases.”

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undermine some existing small enterprises along the NDR, for example, the road potentially threatens one agricultural farm and one free range eggs farm at Drayton.

Cumulative social, environmental and economic impacts

37. The EIA fails to adequately assess the cummulative effects:

the impacts of completing the NDR and creating a third orbital route around Norwich on the River Wensum SAC, landscape, traffic and land use.

the negative socio-economic impacts of building a large road on smaller towns, in particular, Great Yarmouth and market towns in north and East Norfolk. The additional 2,500 traffic movements per day in 2032 on the Acle Straight might mean that residents of the coastal town are commuting out to work in Norwich and what impact would that have for Great Yarmouth?

the impact of likely further development along the NDR and its implications for traffic, communities and the environment.

Examination of NDR and Need

38. As a voluntary group, we have limited resources to analyse the DCO documentation. Therefore, we have decided to focus on whether the NDR is justified and whether it will perform in the way the promoter says it will do.

The Transport Assessment (Doc Ref. 5.5) states the NDR objectives as: i) reduce traffic levels and congestion and speed up journey times

ii) provide access to planned and potential areas of growth

iii) provide transport connections to new housing and employment development, Norwich International Airport, North and North East Norfolk and to the strategic road network

iv) release road space for public transport and other sustainable forms of transport and improve traffic management within the City Centre

v) improve the environment in the northern suburbs of Norwich and outlying villages, whilst minimising the adverse environmental impacts of the NDR.

39. NNTAG has examined the DCO documentation on traffic and economics, in

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particular the reports on Traffic Forecasting and Land Use and Economic Development. The findings are contained in:

traffic and wider economics (paper by Prof. Phil Goodwin)

whether the NDR would facilitate sustainable transport (NNTAG Appendix 2)

whether the NDR can accommodate planned growth (NNTAG Appendix 3)

40. On the basis of comparing do-something with current conditions using figures provided from modelling and analysis, Professor Goodwin's overall conclusion is that the NDR does not lead to an improvement in network performance. Instead conditions grow worse but more slowly than would otherwise be the case:

2017 forecast traffic is 9% higher and 2032 forecast traffic is 39% higher than in 2012.

Congestion will be worse than now. With the NDR, queues in the morning peak in 2017 are 4% longer than in 2012 and 38% longer in 2032 than in 2012.

More people would live close to excessive traffic. With the NDR, the number of dwellings near roads with excessive traffic increases by 39% from 2012 to 2017 and by 74% from 2012 to 2032.

By 2032 with the NDR, every public transport route into the city centre in the morning peak period has a longer journey time than in 2012.

See Summary on p 2- 3 and Table 1 on p6 in P. Goodwin Statement.

41. Professor Goodwin advises that in sensitivity tests, the higher the growth rate assumed, the higher the Benefit Cost Ratio but the worse the progressive deterioration of network performance even with the NDR. He continues, “It seems likely that lower growth would put substantial pressure on the BCR and the higher growth would cause a substantial deterioration in network performance; either needing careful consideration of the viability of the scheme”. He recommends the testing of a wider range of different assumptions about growth.

42. He also requests information, not made available, on a number of matters that include the overall traffic growth rates used and the split between

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strategic and local traffic estimates. Finally, he asks for further information relating to the proposal for travel planning measures to reduce trip rates by 11% as without the promised traffic reduction, future traffic levels would be even higher and network performance would be worse.

43. With regard to wider economic benefits and costs, Professor Goodwin found difficulty in testing the arguments on the basis of the reports presented. He has tabled a number of questions on p28 of his statement relating to: the general approach taken in the literature review; the conditions under which wider economic effects are extra benefits or extra costs; the treatment of the well-known problem usually called the 'two-way road'; and treatment of the wider economic effects of the forecast progressive worsening of network performance seen between 2017 and 2032, and subsequently.

44. With regard to catering for planned and future growth, NNTAG considers that

the NDR is not necessary. With the exception of Rackheath eco-town (the development of which has barely progressed since 2010),

45. There is no reason why the design of the inner links could not be coordinated as a wide single carriageway orbital road for carrying more traffic. Also, a Plan B sustainable transport package would encompass more than the inner road link.

Therefore, in conclusion, the NDR fails to meet its objectives.

46. In relation to National and Local Policy Context (Appendix 1), we conclude that the NDR is contrary to national policy with regard to the need to facilitate growth through the use of sustainable transport in order to cut carbon emissions from transport. The NDR is contrary to this purpose in seeking to facilitate existing and forecast traffic growth. It may also conflict with policy to protect European and Ramsar sites of nature conservation importance following a significant rise in traffic movements along the A47 Acle Straight with the NDR. The NDR is also contrary to local policy in relation to the need to minimise the need to travel (JCS Policy 1 and Objective 7) and minimise contributors to climate change (JCS Objective 1).

Plan B

47. If the NDR fails to meet the objectives set up, it follows that a Plan B would necessary to tackle the problems identified.

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48. Prof. Goodwin has outlined an approach to developing a Plan B. NNTAG has listed (at Apendix 4) some of the main elements which could be combined to form an alternative sustainable transport package.

49. Conclusions

1 The NDR would make traffic, network performance and conditions for economic growth worse in 2032 than those currently experienced. It would be a 'temporary and costly answer'.

2 With higher levels of motorised traffic with the scheme, traffic-related impacts on the environment and communities (air pollution, carbon, noise, severance, disturbance, safety etc) would all be worse. High costs would be imposed on the environment and communities for a negative return. The damage would be even greater if the NDR is taken across the River Wensum valley.

3 The NDR is heavily framed in terms of supporting NATS to help deliver development and growth but there is no justification for the NDR on this basis.

4 Delivery of development and growth are not dependent on the NDR. Many of the sites with planning permission lie along the axis of the inner link roads away from the NDR. The two main airport development sites can be accessed from the A140.

5 The 2010 JCS Panel Report proposed further consideration of housing capacity through an Area Action Plan for the Growth Triangle in the event of the NDR not going ahead and this has been carried forward into the Amended JCS (Policy 22 para 7.17). There is no reason why the design of the inner links could not be coordinated as a wide single carriageway orbital road for carrying more traffic. Also, a Plan B sustainable transport package would encompass more than the inner road link.

6. The case for treating the NDR as 'nationally significant' was on the basis the scheme would connect the Airport to A47-TEN-T and Great Yarmouth Enterprise Zone. Traffic growth along the A47 east of Norwich with the NDR suggests outward commuting from the coastal area to Norwich, which could have a negative economic impact on Great Yarmouth. An Appropriate Assessment of the environmental impact on nationally and internationally important habitats along the A47 Acle Straight has not been carried out.

7. There is no traffic and economic case for extending the NDR west of the A140. Its

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main purpose appears to be signposting of the NDR across the Wensum valley at a future date.

8. For the above reasons, we recommend to the Examining Authority that they dismiss the NDR on grounds it would fail to improve conditions and in fact would make them worse.

9. If the EA is minded to recommend approval of the NDR between A47 Postwick and A140, we recommend that the Panel rejects the NDR extension to the west of A140 on grounds that it brings little benefit and would spell disaster for the future of the River Wensum SAC and its valley and also for future land use planning for Norwich.

10. We would like the EA to recommend that Norfolk County Council should set about developing a Plan B Sustainable Transport Alternative, although that, hopefully would be the inevitable outcome if the NDR is not approved.

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Appendix 1: NDR – National and Local Policy Context NORWICH NORTHERN DISTRIBUTOR ROAD TRO10015

EXAMINATION OF NORFOLK COUNTY COUNCIL’S APPLICATION FOR DEVELOPMENT CONSENT ORDER

WRITTEN REPRESENTATION FROM Norwich and Norfolk Transport Action Group (NNTAG) PINS Registration No. 10026257 June 2014

National Policy Context

White Paper

1. The 2011 Transport White Paper Creating Growth, Cutting Carbon: Making Sustainable Local Transport Happen provides a clear focus on enabling sustainable transport choices to be made at a local level and finding ways to facilitate growth through the use of sustainable transport, whilst reducing carbon dioxide emissions from transport. Given that the scope of the NDR scheme to facilitate existing and forecast motorised transport movements, it clearly has been developed contrary to the White Paper. The forecast growth in transport movements will certainly give rise to growth in carbon dioxide emission, also contrary to the White Paper.

National Networks National Planning Statement (NN NPS)

2. Although only at the draft consultation stage, the NN NPS remains a good guidance document through which to consider national network development projects, such as the NDR.

3. In particular, there may be a conflict between the NN NPS and the proposed NDR

scheme in terms of the effect of the scheme on internationally and nationally designated nature conservation sites.Significant increases in traffic movements on the A47 Acle Straight are shown to result directly from the delivery of an NDR, which is immediately adjacent to the Breydon Water SPA/Ramsar/SSSI site. The potential impacts on these sites have not been assessed in accordance with Habitats Directive and therefore the impact of the NDR on these nature conservation sites are unknown. Appropriate Assessment scoping in 2006 determined that these sites were outside the zone of influence of the scheme. However, the scope of the NDR significantly changed when it became a Nationally Significant Infrastructure Project, linking Norwich Airport with Great Yarmouth.

4. The NN NPS requires that where a proposed development on land within or outside

a SSSI (such as Breydon Water) is likely to have an adverse effect on an SSSI (either individually or in combination with other developments), development consent should not normally be granted. Where an adverse effect on the site’s notified special interest features is likely, an exception should only be made where

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the benefits of the development at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of SSSIs. As no assessment of the NDR’s potential impact on the Breydon Water SPA/Ramsar/SSSI site has been undertaken, it is not possible to know whether the benefits of the development would outweigh both the impacts of the site and any broader impacts across the wider national network of sites. It therefore seems unlikely, in the absence of this information, that neither the Examining Authority nor the Secretary of State would be able to ensure compliance with the NN NPS and the Habitats Directive if the scheme were to be approved.

National Planning Policy Framework (NNPF) 5. Section 4 of the NPPF outlines an intention to promote and delivery sustainable

transport through the planning system, by balancing the transport system in favour of sustainable development. The NDR focuses entirely on accommodating road based transport movements, contrary to Section 4, thus ensuring that much of the forecast growth continues to travel by and, thus increasing greenhouse gas emissions.

6. Paragraph 32 looks to ensure that opportunities for sustainable transport modes are

taken up to reduce the need for major transport infrastructure. In Greater Norwich, the bulk of the planned growth has been directed into locations that facilitate the need for an NDR, rather than promote sustainable modes of transport.

7. Paragraph 34 looks for plans and decision to ensure that developments that

generate significant movement are located where the need to travel is minimised and the use of sustainable transport is maximised. In the case of the NDR, as its need is predicated by growth and development, it is clear that the developments it will facilitate have not been located to minimise the need to travel and maximise sustainable transport.

8. The development the NDR will facilitate have not been located and designed to give

priority to pedestrian and cycle movements, and have access to high quality transport services as required in Paragraph 35.

9. The Greater Norwich Development Partnership should have planned for

development in locations and way which reduce greenhouse gas emissions, in accordance with Paragraph 95, but given the forecast growth in traffic from growth and the NDR, this is clearly not the case.

10. There are likely to be signification impacts from the NDR on nationally and

internationally designated biodiversity sites,

Local Policy Context

Joint Core Strategy

11. The Joint Core Strategy for Norwich, Broadland and South Norfolk contains objectives against which the plan is intended to deliver. Although the plan has

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certainly been developed, to some extent, around the idea of and commitment to the NDR, the scheme appears to conflict with several objectives and policies as outlined below.

12. Contrary to Objective 1, the NDR will not minimise contributors to climate change,

as it will increase motorised traffic movements, thus increasing greenhouse gas emissions from transport. Policy 1 specifies that this objective will be met by ensuring that development minimises the need to travel and gives priority to low impact modes of travel. Given that the function of the NDR is to enable growth in Greater Norwich to come forward, particularly in the north-east growth triangle and Broadland Business Park, the assumption can be made that the growth in this area has therefore does not comply with Policy 1.

13. Policy 1 also states that all new developments will ensure that there will be no

adverse impacts on European and Ramsar designated sites and no adverse impacts on European protected species in the area and beyond. However, significant increases in traffic movements on the A47 Acle Straight are shown to result from the delivery of an NDR, which is immediately adjacent to the Breydon Water SPA/Ramsar site. The potential impacts on these sites have not been assessed in accordance with Habitats Directive. The proposed NDR scheme is therefore contrary to the Habitats Directive, Policy 1 of the JCS and also Objective 9 of the JCS, which seeks to protect, manage and enhance the natural, built and historic environment, including key landscapes, natural resources and areas of natural habitat or nature conservation value and that biodiversity will be protected and enhanced.

14. Objective 7 of the JCS states that the location and design of development will

reduce the need to travel especially by private car. However, given that the NDR is deemed necessary to facilitate development at the Airport, north-east growth triangle and Broadland Business Park, is raises the question as to how these developments (and the development of the NDR itself) meets this objective. It appears that little to no effort has been made to realise this objective – as the major development locations are unable to facilitate greater is of sustainable modes of transport; the NDR certainly will not provide better public transport in itself; and it seems clear that housing, services and jobs have not been co-location, as stated in Objective 7. Policy 6 (Access and Transportation), through which Objective 7 would in theory most easily be met, strangely makes little mention of any sustainable transport, and focuses almost entirely on significant road based transport improvements for motorised transport users.

15. Finally, Objective 11 of the JCS looks to encourage the development of healthy and

active lifestyles and that people will also be offered the best opportunities to make healthy travel choices as part of their daily lives. However, the proposed NDR scheme in itself only really enhances access between major developments by car.

16. In summary, the proposed NDR scheme appears to be contrary to the relevant

objectives and policies within the JCS and therefore is not consistent when considered within the local planning policy context.

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Appendix 2: Is the NDR Necessary for Creating 'Elbow Room' for Sustainable Transport? NORWICH NORTHERN DISTRIBUTOR ROAD TRO10015

EXAMINATION OF NORFOLK COUNTY COUNCIL’S APPLICATION FOR DEVELOPMENT CONSENT ORDER

WRITTEN REPRESENTATION FROM Norwich and Norfolk Transport Action Group (NNTAG) PINS Registration No. 10026257 June 2014

This statement considers the DCO Objective: “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.”

Traffic Conditions

1. The A47 Norwich Southern Bypass which opened in 1993 was intended to remove through traffic from the Norwich road network and improve conditions for users.

2. Whilst the Southern Bypass released some road space at the time of opening,

traffic has been allowed to grow back to much higher levels than before.

3. Outside the city centre, NCC has reallocated a limited amount of road space to 'lock in' traffic reductions from the Southern Bypass: a bus lane along the length of A11 Newmarket Road and short bus lane sections along B1108 Earlham Road, A1151 Wroxham Road and A1074 Dereham Road/Grapes Hill.

4. The Norfolk Transport Monitoring Report 2008 observed that traffic crossing

the Outer Ring Road cordon had fallen by minus 0.8% since 2002 with a 0.5% fall in 2008. Traffic entering the city centre had fallen by almost 25% over ten years.

5. The reasons given for the decline were the availability of car parking spaces in

the city centre, the introduction of on street controlled parking, other traffic restraint measures in the city centre and increasing use of park and ride.

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6. The Norfolk Transport Monitoring Report 2010 noted that results in 2008/09

had shown only a 0.1% reduction in traffic flows crossing the Inner Ring Road cordon and a 0.5% increase in the amount of traffic crossing the Outer Ring Road cordon, hence the need for further intervention ie the NDR.

7. In recent years traffic management has eased off. NCC has reduced its financial

support for bus park and ride and passenger numbers have fallen ( See Table 1, Norfolk Park and Ride Passenger Data 2009 – 10 to 2014 – 15). The local planning authorities have allowed major traffic generating developments. For example, Chapelfield Shopping Centre with 1,000 car parking spaces opened in late 2008, with vehicular access off the Inner Ring Road at Chapelfield Road.

NDR and NATS

8. The NDR Major Scheme Business Case (2008) lacked complementary sustainable transport measures.

9. MTRU noted that:

“There does not appear to be any overall plan for sustainable transport in Norwich. Although the County's NATS is intended to provide this, it fails to do so in a meaningful way as borne out by the evidence that NATS non-road based options are underdeveloped.”

(Interim Note (Feb 2009) for NNTAG and CPRE on the Assessment of the NDR Major Scheme Business Case).

10. The NCC was prompted by the DfT to prepare a NATS Implementation Plan for public consultation in October 2009 containing a more worked up strategy for sustainable transport measures including a detailed set of proposals for the city centre. Programme Entry for a short NDR from the A47 Postwick Junction to the A140 in December 2009 and two years later was made conditional upon funding and delivering sustainable transport measures.

11. With the emergence of NATS IP, the NCC adopted a new narrative that the

NDR would provide "elbow room" for measures to support public transport, walking and cycling

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Progress on Delivering Sustainable Transport Without a NDR

12. Norfolk CC has made progress in implementing sustainable transport: phase one of BRT along Dereham Road; commencement of work on a southbound bus lane along Grapes Hill, two-way bus movements along Chapelfield North and removal of general traffic from St Stephens, Rampant House Street and Theatre Street; progress on developing a cross-city network of cycle routes.

13. The projects demonstrate that delivery is not dependent on building a NDR.

14. The fall in traffic on the Norwich road network, evident in the lower traffic

flows in the NDR transport model in 2012 Base Year compared with 2006, offers the opportunity to reallocate road space to sustainable transport. There are simple immediate which NCC could take to 'lock in' the fall in traffic:

- Improve use of Park and Ride to reduce the amount of traffic entering

Norwich.

- Extend Controlled Parking Zones (CPZs) between the inner and outer rings roads to encourage commuters to use park and ride. Residents regularly request permit parking for their street, but NCC regularly turns them down citing lack of resources.

- Remove on-street car parking on the radial roads using Traffic Regulation

Orders in order to release road space for bus priority lanes. An ideal place to start is A1151 Wroxham Road in north-east Norwich serving Sprowston Park and Ride.

- Adopt a programme and funding plan for travel planning measures to achieve

the 11% reduction in vehicle trips. Such measures would help stabilise traffic levels and support modal shift. The NDR Will Do Little To Assist Sustainable Transport

15. The Traffic Forecasting Report Vol 1 examines journey times on five public transport routes in north and east Norwich. With the NDR, they are mostly worse in 2017 for bus journeys leaving the city centre in the morning and evening peaks than in 2012. Bus journeys are forecast to be longer for nearly all journeys into the city centre in the morning peak in 2032 compared with 2012.

16. Without significant measures to lock in the benefits of road space

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released by the NDR, traffic will grow especially if the NDR is built ahead (2016 to 2021) of BRT, the timetable and funding arrangements for which are uncertain.

17. Traffic flows on radial routes to the north-east sector vary between the

different traffic flow maps presented at different stages.

18. In the transport model updated to 2012, traffic appears to have been diverted from Plumstead Road to Salhouse Road.

Salhouse Road inside NDR (site 62) AADT 2006 Base Year 2017 DM 2017 DS 2032 DM 2032 DS 6300 9400 6900 13200 11800 2012 Base Year 2017 DM 2017 DS 2032 DM 2032 DS 5400 6900 12000 8500 17800 Plumstead Road inside the NDR (Thorpe End) (site 84) 2006 Base Year 2017 DM 2017 DS 2032 DM 2032 DS 8500 9200 11100 13500 17900 2012 Base Year 2017 DM 2017 DS 2032 DM 2032 DS 11400 9200 10600 7600 7900 Source for 2006 Base Year figures: Provisional Daily Traffic Flows Map based on Development Pool funding bid in 2011 and updated to take account of NCC's plans for a dual carriageway standard between A140 and A1067 (shown at Public Exhibitions in Spring 2012). Source for 2012 Base Year figures: AADT Traffic Flows Fig 1.2 in DCO Traffic Forecasting Report Vol 3 Appendices H to K.

19. We assume that the switch is in response to the concerns raised by Thorpe End residents. The large increase in DS vehicle flows along

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Salhouse Road casts doubt on the claim that the NDR is necessary for releasing road space on radial roads to support public transport.

20. In any case, Gurney Road/Salhouse Road corridor does not provide an

optimum route for BRT. It is not the most direct route to Beyond Green development. The area through which the roads pass is low density along most of its route. Gurney Road crosses Mousehold Heath, an important local nature reserve raising issues about environmental impact. Salhouse Road is single carriageway and may need widening to accommodate BRT if NCC diverts traffic from Plumstead Road to Salhouse Road.

City Centre Traffic

21. Work has begun on plans to remove general traffic from St Stephens Street and Theatre Street which will also improve capacity and reliability for buses. The Norwich Highways Agency Committee (NHAC) has agreed to the principle of camera enforcement to deter motorists from entering St Stephens. In July, the Committee will consider a report on introducing a 20mph zone across the city centre.

22. Some additional city centre network improvements (5.6 in 4.4.6) are

proposed in DS. There is no indication that they are dependent on the NDR for reducing traffic flows on the IRR. The changes in traffic flows between DS and DM at various locations along the IRR and radial roads (5.5 Transport Assessment Table 9.3) are negligible in 2017. The inner ring road can accommodate traffic displaced from the city centre without a NDR by reducing traffic using a range of demand management measures, starting with encouraging use of park and ride.

23. The implementation of city centre traffic management measures is not

dependent on the NDR. On the other hand, the NDR 'package' modelled is dependent on the delivery of complementary city centre traffic management measures.

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Appendix 3: Is the NDR Necessary to Cater for Development?

NORWICH NORTHERN DISTRIBUTOR ROAD TRO10015 EXAMINATION OF NORFOLK COUNTY COUNCIL’S APPLICATION FOR DEVELOPMENT CONSENT ORDER WRITTEN REPRESENTATION FROM Norwich and Norfolk Transport Action Group (NNTAG) PINS Registration No. 10026257 June 2014

1. This statement considers the DCO Objective: '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'.

"If the NDR does not get built, major housing and employment development in the area will still go ahead"

The above is a quote taken from NCC's webpage headed 'About the NDR'

This statement follows the question posed:

“Is the NDR being built purely to serve new housing in and around Sprowston, Rackheath, Old Catton and Thorpe St Andrew? (As proposed in the Greater Norwich Development Partnership’s Joint Core Strategy)

No. The NDR was originally conceived to tackle existing problems that were, and still are, affecting the area. It was adopted as a key element in Norwich Area Transport Strategy well before the ‘growth triangle’ north-east of Norwich was identified in the emerging Joint Core Strategy for Greater Norwich. The NDR will reduce the impact of this growth on the existing road network while allowing major improvements in public transport, walking and cycling, and for measures to enhance the city centre.

"If the NDR does not get built, major housing and employment development in the area will still go ahead"

http://www.norfolk.gov.uk/Travel_and_transport/Major_projects_and_improvement_plans/Norwich/Northern_Distributor_Road/About_the_NDR/index.htm

2. NNTAG agrees with the NCC's assessment that major development planned for

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the area will still go ahead (depending on the economic recovery) if the NDR is not built. This is because planned and potential growth is not dependent on the NDR, although the Greater Norwich Development Partnership has created a dependency in the adopted Joint Core Strategy Implementation policies. We do not accept the argument that growth is dependent on the NDR delivering NATS and significant public transport. As Prof Goodwin demonstrates in his statement, public transport journey times into the city centre in the morning rush hour would be slower with the NDR than currently.

Growth can take place without a NDR.

3. The north-east Growth Triangle in the JCS at least 7,000 dwellings to 2026 rising to at least 10,000 thereafter. Table 5.1 in Land Use and Economic Development Report (10.3) lists 13 sites dependent on the NDR. Of these:

4. Five sites already have planning permission for development and access

arrangements: Broadland Gate (site 1): the business park development would occupy land enclosed by the £19 million A47 Postwick Hub, the capacity and layout of which is much larger than is necessary for proving access. Outline planning permission was granted in 2012, with 10 years given for submission of a detailed application. There is considerable scope for improving the Travel Plan to reduce car commuting. Brook Farm (site 2): planning consent for 600 dwellings was made conditional upon Postwick Hub. A link road to Plumstead Road East formed part of the application. Laurel Farm (site 3) :14 ha of land for employment was allocated in the adopted Broadland Local Plan 2006, together with the link road to Plumstead Road East. Blue Boar Lane (site 4): planning consent given for 1,200 dwellings at White House Farm and link road from Salhouse Road to Wroxham Road. Land for both was allocated in the adopted Broadand Local Plan 2006. Norwich Airport (site 8): a new aviation related business park (Norwich Aeropark) has been approved for the north-east corner of Norwich Airport close to the NDR. The site will be accessed by a new spur road off the A140. The Transport Assessment states that the project can operate without the NDR. “An access road from the A140 roundabout will be constructed to serve the development.Should the Norwich Northern Distributor Road (NDR) (subject to

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planning approval) be constructed then provision has been made to serve the development site from a proposed roundabout on the new NDR road. The application does not rely on the provision of the NDR, but is designed so as to take advantage of the improved connectivity should it be constructed.” Section 1.3 in Norwich Aeropark ES Addendum Updated Transport Assessment, June 2013 prepared by Iceni Projects Ltd on behalf of Wrenbridge Norwich Airport LLP

5. The Aeropark reflects moves by Norwich Airport to diversify activities in the light of falling passenger numbers from 773,000 ppa in 2007 to 463,000 in 2013. A draft Master Plan (2002), but never published, forecast growth to 900,000 passengers in 2015 which has not materialised.

6. With improved NDR access, the Councils has wanted to expand the airport to

2.4 million passengers per annum. Norwich Airport: Economic and Environmental Impact Study, (Arup,2003) for Norwich City Council and Norfolk County Council.

7. A report for NCC, The Economic Impacts of the NDR, (Roger Tym, 2005)

concluded that the NDR would have only a limited effect on widening the airport catchment area because of its proximity to Stansted.

8. One major site with outline planning permission has been made partly dependent on the NDR, but NNTAG believes development can proceed without the NDR.

Beyond Green (Old Catton and North Sprowston) (site 7)

The development of 3,520 dwellings has outline planning consent. Planning permission permits 900 dwellings pre-NDR, with 2,600 dwellings made dependent on the NDR being built.

9. The project is based upon reducing reliance on the car with an overall aim of

'traffic neutrality'. A 30% reduction rate has been applied to vehicular trip generation. Development design includes an east-west High Street between Wroxham Road and North Walsham Road as the primary route for movement, with the option of a transport link to the Airport industrial estate.

10. In response to discussions about uncertainty over the NDR and north-east

growth sector at the JCS examination in 2010, the Beyond Green project team assessed the effects of their development on the transport network with and

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without a NDR. Their preliminary analysis were that the NDR didn't 'do anything that the new E-W link can't do'; that 'there was nothing about the level of traffic on the NDR which can't be accommodated by E-W link passing through the High Street which is 'flexible enough to accommodate through traffic' (BG Design workshops, 5 Oct 2011, Sustainable Transport Presentation, Bruce McVean).

11. Beyond Green's modelling at that preliminary stage showed traffic levels on

key routes such as North Walsham Road and the new High Street would be lower with the NDR than without it. The assessment of their transport consultants, Buchanan and Partners, was that peak time traffic with the NDR would be comparable with peak-hour traffic on Unthank Road, Norwich. Without the NDR, the High Street would potentially need to accommodate east-west movements on levels comparable with parts of the B1108 Earlham Road, Norwich.

12. “We don't think such a level of traffic is incompatible with high quality

development but it would mean that street typologies on primary routes would need to be carefully designed so as to preserve a high quality pedestrian environment and public transport priority whilst accommodating the necessary extra capacity”. Q8 of Beyond Green in Broadland QandAs 13 Oct 2011

http://www.beyondgreen.co.uk/wordpress/wp-content/uploads/2011/10/Beyond-Green-Developments-in-Broadland-QAs-13th-October-2011.pdf

13. Further jobs would be created at three existing employment sites: Rackheath Industrial Estate (6): The Industrial Estate can continue to be served by the existing transport network. Table A.1 Economic Impact Calculations in 10.3 with regard to the NDR and Development Sites estimates just 20 jobs gross. Salhouse Road (site 11) A new link road connecting Salhouse Road and Plumstead Road East which in tun would connect to the A47 Postwick Hub is mooted in a scoping opinion report for potential new residential development off Salhouse Road, north of Thorpe End. The new link road would serve employment along Salhouse Road. Norwich Airport Industrial Estate (site 10) The Industrial Estate can continue to be served by the existing transport network. Table A.1 Economic Impact Calculations in 10.3 with regard to the NDR and Development Sites estimates a modest 50 jobs gross.

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Planned/Potential Development Sites – but no planning application Rackheath Eco-Town (site 5): Very little progress made on this proposal. The promoters' website most recent reference to public consultations is 2008. At the JCS examination in 2010, Building Partnerships, one of the promoters of the eco-town, stated that its development was not dependent on the NDR. A 30% reduction rate has been applied to vehicular trip generation for this site which, if implemented, would constrain car trips. Norwich Airport (site 9): Aviation Academy A proposal for an aviation education and skills training centre was announced in September 2013 on land close to the airport, A140 and NDR route. It is highly unlikely that a training centre would be dependent on the NDR. Housing in North East Growth Triangle (site 4) Land within the Growth Triangle currently not identified for specific development proposals is confined to areas inside the NDR. Here, the inner link road would give more direct access to potential development sites than the NDR. Land with potential for development potential for at least another 1,000 houses on top of the 600 dwellings lies north of Brook Farm. The site would be accessed by the link road agreed in planning permission for Brook Farm and Laurel Farm, which would connect Broadland Way to Plumstead Road East. Housing in Broadland Part of NPA (site 13) This relates to 2,000 dwellings which are not site specific in the JCS. There isn't a case for building the NDR in order to serve 2,000 dwellings which are likely to be distributed around a number of sites. Discussion

14. With the exception of Rackheath eco-town, many of the sites lie along the axis of the inner link roads and would be directly served by the links than they would by the NDR. Airport sites nos 8 and 9 can be accessed from the A140 and planning permission has already been granted for the Aeropark on this basis.

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15. The 2010 JCS Panel Report proposed further consideration of housing capacity through an Area Action Plan for the Growth Triangle in the event of the NDR not going ahead and this has been carried forward into the Amended JCS (Policy 22 para 7.17). There is no reason why the design of the inner links could not be coordinated as a wide single carriageway orbital road for carrying more traffic. Also, a Plan B sustainable transport package would encompass more than the inner road link.

16. The table in Policy 22 of the Implementation and Monitoring Chapter of the

Joint Core Strategy Amendments (adopted Jan 2014) showing the level of growth that can come forward following improvements to Postwick Junction and in advance of confirmation of delivery of the NDR. It shows a figure of at least 3,240 dwellings. However, this is an estimate and not one based on detailed testing.

17. A further uncertainty is the shortfall in delivering the JCS housing targets. The Inspector into the part JCS examination last year directed that should monitoring show a continuing shortfall in housing delivery over the next two years, (defined as meeting less than 90% of the required deliverable housing land), notably in the north-east sector, the local planning authorities should investigate allocating further sites elsewhere in addition to the 37,000 dwellings already planned.

18. Our concern is that if the NDR is built, the road would generate significant

orbital journeys by car, van and lorry and create reliance on vehicular trips which would be difficult to transfer to sustainable modes. A single carriageway inner link road could support development without generating significant traffic growth.

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Appendix 4: Plan B: A Sustainable Transport Package for Norwich as an Alternative

Option to the NDR NORWICH NORTHERN DISTRIBUTOR ROAD TRO10015

EXAMINATION OF NORFOLK COUNTY COUNCIL’S APPLICATION FOR DEVELOPMENT CONSENT ORDER

WRITTEN REPRESENTATION FROM Norwich and Norfolk Transport Action Group (NNTAG) PINS Registration No. 10026257 June 2014

1. Community groups and developers alike urged NCC to develop a 'Plan B' for

facilitating growth as an alternative to the NDR at the 2010 examination into the Joint Core Strategy, but the GNDP rejected the Panel's invitation. At various discussion forums held, for example a Postwick Developer Forum recommended by the JCS Panel and design workshops on Old Catton and North Sprowston, NCC made clear its intention to pursue the NDR whilst the scheme was in the running.

2. Norfolk CC equates a 'Plan B' with the disjointed 'developer link roads' which would

zig zag their way from Broadland Way to North Walsham Road. However, these piecemeal sections of infrastructure do not equate with the alternatives package which NNTAG and others advocate. Therefore, NNTAG will not comment on the Sensitivity Test findings for the Developer Link Roads and very poor BCR.

3. Options assessed by NCC at earlier stages such as public transport were largely

considered in isolation. NNTAG recommends the development of a combined package of solutions, building on NATS IP but without the NDR.

Alternative Package

4. In his examination statement for NNTAG, Professor Phil Goodwin recommends as a starting point the central need to bring down traffic growth sufficiently for enabling other investments in infrastructure and operations to make travel conditions better than the current situation, using measures which themselves have some benefit.

5. The next stage is to consider the package of policies required for delivery using a

combination of measures such as travel planning, pricing, re-allocation of road capacity, land use planning and so on. Professor Goodwin advises that if the underlying trend in traffic growth is not as great as forecast (as he judges to be the case), it would be easier to put together such a package, but if it is as great as forecast, it is more essential to do so.

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6. These steps creates a new trend line, against which different combinations of infrastructure, operations and management can be tested, all with a chance of delivering improvements. The planning task involves searching for the best combination.

7. NNTAG recommends testing an Alternatives Package, using a combination of

elements to include: 1. Modest new road building for supporting new development

8. A well designed properly coordinated developer funded wide single carriageway inner link road would give more direct access to planned development in North-East Norwich than would a NDR. It could also relieve traffic on the Outer Ring Road and northern suburbs to some extent. Traffic modelling undertaken by Colin Buchanan and Partners, transport consultants for Beyond Green has demonstrated this possibility.

9. A new 'inner link road' will be built to serve north-east Norwich as part of

developer agreements.

10. The route runs from Broadland Business park in the south to the Airport, close to the NDR route. It follows the 2004 NDR consultation 'Eastern Pink Route Option'. Broadland DC formally objected to the option on grounds it would restrict the potential for development inside the NDR. Since then, the GNDP has allocated land for development both in and outside the NDR. A petition of 1,000 signatures from residents of Rackheath, the Plumsteads, Salhouse and other communities supported the Pink eastern route.

11. The Panel modified JCS Policy 20 to require investigation of any potential for

existing growth without a NDR and testing whether interim schemes and/or alternatives to a NDR as part of the preparation of an Area Action Plan for the Growth Area. Broadland DC has failed to design the scheme properly allowing each developer to design their part of the route. No technical appraisal has been undertaken that NNTAG is aware of as to how much movement the Inner Link could carry and whether it could supplant the NDR.

12. It is wasteful of public money to spend £148 million (on the NDR), when a Inner Link Road will be being provided at zero cost to the public purse. Because developers are being asked to contribute to not one but two roads that are both , allegedly critical to opening up development, they cannot then be asked to generously meet the costs of affordable housing and neighbourhood infrastructure.

2. Demand management to include:

13. Road space reallocation for public transport walking, cycling and traffic management.

14. Bus Rapid Transit (BRT): a cross city network is vital but its delivery needs speeding

up and a funding package put in place to bring forward delivery. One immediate effective way of releasing road space for bus lanes would be to remove on-street parking along radial roads where possible.

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15. An obvious example is radial road serving north-east Norwich (Wroxham

Road/Sprowston Road). Between Denmark Road , close to the IRR and Blue Boar Lane, both roads are wide single carriageway lined by houses, mostly with off street parking. Vehicles are permitted to park at all times of the day on both sides of Wroxham Road and Sprowston Road. An in-bound bus lane runs along part of Wroxham Road towards the ORR. It operates Mon – Sat from 7.30am to 9.30am but there is no bus lane enforcement. Removal of the on-street parking would provide dedicated road space for public transport.

16. More creative traffic management would be required on the radial road closer to the

IRR where Sprowston Road narrows down from four lane width to two lanes between Denmark Road and Magdalen Road and passes through a stretch of terrace housing with on-street parking. One possible solution might be to retain the on-street parking but create a one-way gyratory system using Denmark Road/Magdalen Road/Sprowston Road with bus priority at signalised junctions which currently delay buses. This would be similar in concept to the St Augustines Street gyratory system..

17. We consider that a better route for BRT serving north-east Norwich would be via

Sprowston Road/Wroxham Road rather than Gurney Road/Salhouse Road. Sprowston Road/ Wroxham Road gives a more direct route to the Beyond Green development which has outline planning consent. The corridor is built up along its length unlike Gurney Road/Salhouse Road which passes run through areas of low density including Mousehold Heath, a large area of open heathland and woodland inside the city. More buses travelling across Mousehold Heath would undermine its amenity and wildlife value.

Demand management to include Pricing

18. Norwich politicians, businesses and residents did not respond favourably to a proposal for local road pricing some years earlier. However, car parking charges are an important means of managing demand for transport. A better balance between charges for bus park and ride and city centre parking are required to encourage greater use of park and ride, coupled with the extension of Controlled Park Zones in residential eras between the ORR and IRR.

19. Travel planning: NATS IP proposes working with large employers on travel plans

but many more possibilities exist which if consistently applied in a well funded long term programme, could have a significant impact on reducing traffic and encouraging modal shift. Currently, we have doubts about NCC's commitment to travel planning, having disbanded its travel planners team in 2010.

20. City centre traffic management: progress is being made but further measures should be identified. Some County Council members have consistently opposed important measures such as closing Westlegate to traffic.

21. Traffic management/calming measures: a funded programme should be

identified for the built up area. There is a large unsatisfied demand from local residents eg 20 mph limits. The NCC diverted funding from the Integrated Transport Budget into preparing major roads schemes (NDR, Postwick Hub, Great Yarmouth river crossing)

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22. New public transport and rail hubs: an example is the proposed rail halt at

Postwick, for which land has been allocated but no progress made in delivering the project. Given the plans to use Postwick business parks as an outpost for firms from Great Yarmouth, this scheme is a no brainer, as it would serve passengers on Norwich to Great Yarmouth line.

23. Active travel: the Pink Pedalways is a welcome start, but a comprehensive cycling

network is needed along with one for walking .

24. Limit further improvements to the strategic road networks around the city to those which support public transport travelling in and out of the city. NCC and partners want to upgrade several junctions along the Norwich southern bypass to provide additional capacity to include a tunnel under Thickthorn junction for creating a fast route from A11 to the Airport via the NDR. New road capacity for vehicular traffic will only generate new trips.

25. Land use planning: the over-reliance on car based out of town development

around Norwich has contributed to urban sprawl and congestion. Development must be sustainably based, starting with the strict application of a sequential test (recent planning consent for a superstore at Taverham close to the NDR does not bode well); developing sites near high quality public transport hubs; re-use of land currently used for car parks; application of maximum parking standards, car free development, widespread use of car clubs; applying a traffic neutral to green field urban extensions and putting in place high quality public transport before the residents move in.

26. The alternative package builds on the NATS IP but without the NDR. Rather than a car dominated noisy polluted city hemmed in by major highways, a sustainable transport package would provide a high quality living and working environment which is attractive for residents, visitors and the types of businesses that the Councils want to attract. Such a package would bring a large number of related benefits which include improved road safety and public health, less severance, lower carbon emissions and protection of natural resources including land.

27. The issue is not so much whether a strategy along the above lines can be

developed and delivered but whether there is the political will to do so. The choice doesn't have to be between a 'bad present and a slightly less worse future”. It can be a 'better future.'