NDR Western Link

Help us protect vital wildlife habitats


Norfolk Wildlife Trust will strongly object to the planning application for the Western Link. Based on the evidence available, we consider that the proposal would result in the loss of significant and irreplaceable ecological features of national importance for which mitigation and compensation are not feasible. We cannot envisage how it would be possible to proceed with the road and comply with wildlife laws and planning policies, nor provide a net gain for biodiversity as stated by Norfolk County Council.

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A Western Link for the Northern Distributor Road (NDR) now called Broadland Northway, is being considered, which will link the end of the current NDR on the A1067 with the A47 near to Easton.

The landscape between the A47 and A1067 is a well-connected network of habitats that are important for wildlife, including ancient woodlands, grasslands and floodplains. These are not only along the River Wensum but also along the corridor of the River Tud and towards Easton.

The landscape contains many significant areas of importance for wildlife. The River Wensum is a site of international importance for wildlife. Several of the areas are designated as County Wildlife Sites, which are the best semi-natural habitats in Norfolk after nature reserves and SSSIs. Further areas are also in the process of being designated as County Wildlife Sites. The connection between the habitats is of particular importance in this area, for wildlife including bats, such as the barbastelle bat, one of our rarest bat species. The majority of the road design will not be available until after a contractor has been chosen.

We are very concerned about the potential damage by the Western Link to these important habitats and their connectivity and have been raising our significant concerns throughout the process at all levels. We will continue to do so with councillors, technical staff and the press.

Unacceptable wildlife impacts of the proposed Western Link

All UK bat species are protected under the Wildlife & Countryside Act and the Habitats Regulations. The negative impacts of new road schemes on bats are well documented, with a high likelihood that the habitat loss, severance of remaining habitat, reduction in habitat quality nearby and increased collision risks will lead to long term declines that can result in the extinction of local bat colonies. There is a very real risk that the road would lead to the local extinction of multiple bat colonies, which would be a clear breach of the Habitats Regulations and the Wildlife & Countryside Act. This includes the endangered barbastelle colony at Weston, which is likely to be of international significance due to its current size. The barbastelle bat is listed as Near Threatened on the red list. We would not consider any assessment of the impacts on a narrow 75 metre corridor around the road, as indicated in the interim survey reports, to provide sufficient information to inform the full scale of the impact on the colony and its core sustenance zone. 

Several of the woodlands in the surrounding landscape are included in the Ancient Woodland Inventory and there is therefore a risk that there are further areas of ancient woodland directly on the route or its zone of influence.

Much of the woodland in this area is not listed in the inventory, but still contains ancient trees. These provide havens for wildlife as they are full of cracks and crevices and flaking bark that make wonderful microhabitats. Newly planted trees will not create this kind of varied habitat for many years.

Ancient woodland is a rare and irreplaceable habitat and the full extent of ancient woodland habitat on the route and its zone of influence should be identified through detailed Phase 2 botanical surveys in order to properly assess the risk to this irreplaceable priority habitat. 
The UK holds a significant proportion of the world’s chalk rivers, and so holds a key responsibility for their conservation. The road would require crossing the River Wensum SAC, and would also result in the loss of County Wildlife Site floodplain habitats which are functionally linked to the health of the SAC. Whilst the focus appears to be on ensuring that adverse effects on the SAC are avoided, it is not clear from the information provided if the habitat loss, hydrological and pollution impacts on the supporting floodplain habitats adjacent to the SAC have been considered in assessing the long term impacts on the SAC.  We also consider the River Tud on the southern edge of the proposal to be of equal ecological value to the River Wensum. The Western Link would need to cross a tributary of the Tud below Foxburrow Plantation, with likely hydrological impacts on the flow and water quality of the Tud. Whilst it is not designated as an SAC, and only partially designated as a CWS, we believe it is of equal ecological value, and potentially of SSSI quality. It is also likely to suffer from in-combination effects from the A47 upgrades necessary to join to the Western Link, with cumulative impacts on habitat quality and its hydrology.
At present, the Council have included a target to deliver Biodiversity Net Gain as part of the proposal. This refers to a specific government policy in the 2021 Environment Act which, from late 2023, will require all development to deliver a mandatory net gain in the area of habitats that would otherwise be lost to development. However, net gain targets only cover the area of habitats involved, and are not meant to cover any legal responsibilities where protected species are present. Regardless of the area of new tree planting offered to meet net gain targets, it cannot replace the old woodland with trees hundreds of years old that legally protected species like the barbastelle depend on.

We have written to Norfolk County Council to highlight that proposed new tree planting — regardless of scale — cannot replicate the mature woodland roosting habitats used by a significant colony of endangered bats on the route. NWT therefore strongly disagrees with the Council’s claim that a net gain for biodiversity can be delivered in this context.

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