Rt. Hon. Norman Baker, MP,
Parliamentary Under-Secretary of State for Transport,
Department for Transport
Great Minster House
76 Marsham Street
Dear Mr Baker,
Re: DEVELOPMENT POOL FUNDING FOR THE NORWICH NDR
I am the founding Chair of Stop Norwich Urbanisation (SNUB) a community campaign group that has been campaigning since 2007 against the proposed growth plans for the city of Norwich as presented by the Joint Core Strategy (JCS) delivered by the Greater Norwich Development Partnership (GNDP; made up of Norfolk County Council, Norwich City, Broadland and South Norfolk District Councils).
In particular our campaign is against the plans for the North East growth triangle of Norwich that incorporates the proposed NDR in addition to the so-called Eco town of 4,000 houses at Rackheath as an integral element of the 10,000 proposed houses in this area which forms part of the overall plans for 37,000 new homes.
Our 3,000+ supporters and followers believe that the alternatives for growth and the associated traffic infrastructure have not been fully explored. We are all of the view that there is a need for some growth and new houses albeit at a reduced level than planned, based on evidence from Shelter and CPRE, and that the number of houses needed over the next 15 to 20 years is a lot less than planned in the JCS.
We are supported by organisations such as CPRE and the majority of Parish Councils in the affected area and in particular Wroxham, Hoveton, Rackheath, Great and Little Plumstead Parish Councils and the Residents Association at Thorpe End.
Our local support is reaffirmed on regular basis through SNUB core members attending summer fetes etc and holding public meetings where affirmation of our stance is sought from the attendees. The latest of the former was the Rackheath Summer Fete on 10th July 2011 and the latest of the latter was held as recently as Thursday 29th September 2011 where over 120 local residents from a number of Parishes in and around the North East growth area were unanimous in asking SNUB to continue with the campaign and in particular the protest against the “road to nowhere” as the proposed NDR has been dubbed locally. The former saw our display at the fete visited by over 300 local residents who urged us to continue with our campaign and generously donated towards our legal fighting fund.
It is perhaps telling that at our latest public meeting campaigners from Norwich and Norfolk Transport Action Group (NNTAG) an umbrella organisation for transport groups in Norfolk, local councillors from the Conservatives, Greens and Liberal Democrats joined us along with campaigners from the Kings Lynn Without InciNeration (KLWIN) group. The latter group were there to demonstrate some commonality and solidarity with our campaign here in Norwich and the breathtaking lack of democracy being demonstrated by Norfolk County Council as they have steadfastly ignored their own consultations and petitions from both SNUB and KLWIN as local residents demonstrate their opposition to proposals from this so called elected body. Not so much Big Society but more like Big Brother!
Our campaign was also recognised by the Sheila McKechnie Foundation (SMK) last year, as SNUB was short-listed in their Campaign of the Year competition; the SMK awards were supported by your central government colleagues in the Department for Communities and Local Government!
WHY SNUB OPPOSES A NDR
Our view, and one that is shared with over 3,000 local residents who signed a petition to this effect in 2009, is that the NDR is merely an access road for the proposed development in the growth triangle and that the GNDP took advantage of the fact that Norwich, without any consultation or mandate, became a regional growth point under the previous administration in 2005, to resurrect the previous discredited plans for this road.
We were told at one of our many public meetings in 2009 by the then leader of Broadland District Council, Councillor Simon Woodbridge, that if the NDR was not built then there would be no large scale development of houses in the North East growth triangle. This proved to us and the hundreds of local residents present at the meeting that the real reason for the NDR was to provide infrastructure for the 10,000+ houses to be built in the growth triangle and nothing to do with easing congestion
Norfolk’s growing industry is based largely on agriculture and tourism and the completion of the NDR and associated inevitable “ribbon development” along its shoulders is hardly supportive of these two very important UK plc industries.
An integral part of the NDR plans are the proposed closure of local feeder roads in the East such as Smee lane, Low Road and Middle Road which will result in the funnelling of traffic on to the Plumstead Road, Salhouse Road, and Thorpe Road causing even more congestion and resulting in carcinogenic pollution through the heart of a conservation area.
Empirical evidence shows that the increase in traffic on the proposed NDR will increase the carbon footprint of Norwich and the surrounding area. Indeed Policy 1 of the JCS is:
‘Addressing climate change and protecting environmental assets’.
Without apparent embarrassment, the GNDP proclaim this Policy 1, despite the fact that the ‘most critical’ piece of infrastructure for the JCS is the proposed NDR. This is modelled by the GNDP themselves to produce 25,000 tonnes of CO2 per year in addition to current levels – equivalent to 6% of Norwich’s current transport emissions. There couldn’t be a clearer carbon disbenefit working against Policy 1.
LACK OF GENUINE PUBLIC CONSULTATION ON A NDR/POSTWICK HUB
Whilst the GNDP as agents for Norfolk County Council (NCC) may well point to the fact that the consultation in 2003 showed residents in favour of the NDR, NCC’s proposals have changed significantly since then as the 2003 NDR was a full length route from the A47 West of Norwich to the A47 East of Norwich, and did not involve the major ‘Postwick Hub’ gyratory at Postwick. The NDR proposed in the 2003 Norwich Area Traffic Study (NATS) consultation was a full Norwich northern by-pass from the A47 East anti-clockwise to the A47 West – this would have linked the proposed road to the A47 Southern by-pass in a full ring road. The ring road to the West was seen by many consultees to the far West of the City in villages, like Costessey and Hellesdon, as providing relief to their villages and local lanes. It therefore received considerable support on this basis and this basis alone.
The proposals before you now are for a half-length route that is linked too much greater growth as defined in the JCS that has both the NDR and the Growth Triangle as fixed elements in all of their consultations. If this proposed shorter NDR was to proceed the aforementioned villages would see considerable “rat running” as traffic would be forced onto minor roads at the termination point of the proposed shorter NDR in order to connect to the western side of Norwich to join the A47 en route to the Midlands and the North. These residents have not had the opportunity to be consulted on this scenario and we suspect that one of the reasons why NCC and others have not consulted is that the probable result would be a resounding NO to this proposal. Any plans for the rest of the NDR to be funded locally, as being promoted by the unelected GNDP in their closed to the public meetings, by local councils, commercial borrowing and the use of the Community Infrastructure Levy are short sighted and not practicable in this time of economic prudence.
In fact the only public opinion on this shorter version of the NDR was during a public poll held by the Eastern Daily Press (the country’s biggest selling regional morning newspaper) last month and the overwhelming result was a resounding NO vote by members of the public with 63% against the NDR.
Whilst we acknowledge that NCC have mentioned SNUB in their Best and Final Bid (para 5) they have completely ignored all of the other groups that opposed the NDR and never even responded to a detailed letter of opposition from Great and Little Plumstead Parish Council. They have dismissed our objections due to our reported link with the planned growth in the North East and assumed that local residents will merely see a new road with no associated growth on its shoulders! This demonstrates their sheer arrogance and scant regard for local residents views. Their statement indicating strong overall support for the NDR is both morally and technically incorrect as it is based on outdated plans and a flawed public consultation. We represent over 3,000 local residents who have stated that they do not wish to see this road being built and we have their names and addresses on a petition that was presented to Keith Simpson at Westminster in November 2010 as evidenced on our website. We would like to see the numbers from NCC on those that have supported the NDR, as they seem to be using excuses from the Data Protection Act to hide the true numbers.
SNUB’S LEGAL CHALLENGE OF JOINT CORE STRATEGY
In both the 2009 Norfolk Area Transport Strategy (NATS) consultation and the statutory Examination in Public (EiP) on the GNDP JCS, the NDR is presented a fixed element with no alternatives given. The EiP does not comprise a proper public consultation.
We are of the view that the JCS is ill conceived, outdated and probably unlawful with SNUB in the process of challenging the JCS in the High Court with a hearing scheduled for 6th December this year. An integral element of this challenge is the part that the proposed Northern Distributor Road (NDR) plays in the JCS.
One of the heads of our legal challenge is that the alternatives to the JCS and associated infrastructure were not subjected to a full Strategic Environmental Assessment as required by EU legislation that has been enacted in the UK. The second head is that there was a lack of assessment of Northern Distributor Road (NDR) in the JCS.
We are confident of winning our challenge particularly following the success of the legal challenge on the Postwick Hub application, which is seen as many as the commencement of the eastern start of the NDR.
A11 CORRIDOR MAKES MORE SENSE AS A GROWTH LOCATION
We also cannot understand the logic for growth in the North East and the need for a major trunk road in an area of productive agriculture land and little employment opportunities
The major employment opportunities, as defined by the JCS, are in the South West and South of the city based on the success of the Norwich Science Park, John Innes Centre, Hethel Engineering centre, UEA and the Norwich and Norfolk University Foundation Trust hospital. It therefore makes sense economically for any surplus funds to be allocated to the dualling of the A11 and bypassing the market town of Long Stratton on the A140 link south of Norwich to the A12 and A14 with the latter linking to the New Anglia Local Enterprise Partnership (LEP) geographical footprint and the burgeoning off shore Renewable Energy industries and employment hot spots along the East coast of Norfolk and Suffolk.
This new LEP aims to create up to 2,000 jobs and 80 businesses by 2015 and 13,500 jobs and 200 businesses over the 25-year lifetime of the zone. West Norfolk will also benefit from a similar LEP in Greater Cambridgeshire and Greater Peterborough. Indeed we also see the planned improvements of the A47, as an integral part of the European TEN-T network, providing the main east-west road connection and route to the Midlands and North of England and would support funding of improvements to the A47 Acle Straight in the East and further improvements towards Kings Lynn and onto Peterborough in the West linking both LEP areas.
We see no justification for a northern leg of this west – east – south axis and believe that any use of scarce public funds on a road to nowhere is foolhardy and bordering on maladministration.
We would urge you to use what funds are available on sensible and joined up plans to reinvigorate the regional economy in places were local residents and communities actually welcome the investment, as called for in local Parish Plans, and where central government plans from different departments are in agreement. Particularly as the present Government has defended it’s scrapping of strict house building targets in England as they “antagonised communities” and generated “thousands of objections”.
We concur and there are thousands of objections here in Norfolk to this level of development including the NDR. Norfolk County Council have not demonstrated wide public support for this scheme, and I and the thousands of SNUB supporters hope you will take account of this lack of consultation on the NDR when you consider which Development Pool schemes to fund.
Stephen Heard MBA MCIPS
Chair Stop Norwich Urbanisation
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