Date: October 2023
Background
In January 2019, four options were shortlisted by Norfolk County Council (NCC) to link the end of the current Norwich Northern Distributor Road (NDR) now called Broadland Northway, on the A1067 with the A47 near to Easton – the proposed ‘Norwich Western Link’ (NWL). Norfolk Wildlife Trust considered the four options in detail, looking at the direct impacts on wildlife and habitats, as well as indirect impacts such as pollution, noise and light disturbance and habitat severance that isolates wildlife populations and therefore undermines species ability to survive. All four options were found to be unacceptable as they will cause significant damage to multiple County Wildlife Sites (CWS), irreplaceable habitats such as ancient woodlands and rare species.
In July 2019, NCC selected route option ‘C’. The new 3.8 mile dual carriageway road would link from the roundabout at the western end of Broadland Northway and extend for around 350 metres along the A1067 Fakenham Road before turning in a south-westerly direction via a new junction.
NWT further considered evidence of the wildlife impacts of this particular route, and continues to hold grave concerns about its impact on wildlife and habitats. NWT continues to oppose the development.
What is NWT’s primary reason for opposing the development of the Norwich Western Link?
Independent surveys have recently identified the presence of what is likely to be the largest breeding population of one of the UK’s rarest bat species, the barbastelle. Several old woodlands on and close to the route have been confirmed as “maternity woodlands” and hold breeding colonies which, together, make up a super colony with a population higher than any other recorded in the UK.
The importance of the area nationally for barbastelle bats, which are fully protected under wildlife law, cannot be underestimated. The colonies are highly dependent on the high-quality network of woodland, wetland and river habitats in the surrounding area.
The NWL would destroy some of the breeding woodlands and sever the connectivity between the remainder of the woodland breeding sites, isolating the colonies from each other, as well as placing the bats at risk of collision with the traffic on the NWL as they attempt to move across the landscape for feeding. This risks the long-term complete loss of the super-colony, which could be catastrophic for the future of the species in the UK.
What other concerns does NWT have about the impact of the proposed road on wildlife?
The landscape between the A47 and A1067 is a well-connected network of vital wildlife habitats including ancient woodlands, grasslands, chalk streams and floodplain. It supports ancient oak trees and species including bats, badgers and farmland birds such as yellowhammer and linnet.
The proposed development will fragment this wildlife-rich area, damage the River Wensum Site of Special of Scientific Interest (SSSI) and Special Area of Conservation (SAC) and destroy parts of three County Wildlife Sites: River Wensum Pastures; Primrose Grove; and Land adjoining Foxburrow Plantation.
Old woodlands and ancient trees are a rare and irreplaceable wildlife habitat. Several such woodlands are found adjacent to the proposed route. The River Wensum and River Tud, both affected by the proposed route, are wildlife-rich chalk rivers, one of the rarest habitats in the world, with fewer than 200 found across the globe.
Norfolk County Council have admitted that the area of impact of the development will extend much further than the width of the carriageways. The land around the road will also become fragmented and degraded for wildlife through noise, lights and pollution. Impacts will include:
-
Noise from the road can affect the communication between birds across the landscape, including linnet, yellowhammer and skylark, all of which are on the red-list of conservation concern. This is very likely to lead to losses in local populations, leaving them more vulnerable in the future.
-
Species including owls, bats and badgers will be at risk of collisions with vehicles.
What are NWT’s concerns with the information Norfolk County Council have shared on how they plan to mitigate against the impacts on wildlife?
NWT is a member of the Ecology Liaison Group, set up by the Council to discuss progress with the ecological surveys and road design as they work towards the planning application. Discussion in the group has included potential mitigation options that the Council are considering. The Council has suggested during discussions mitigation including bat boxes to replace lost roost sites in trees, new tree planting to compensate for loss of foraging habitat and green bridges and tunnels created in places where the road will sever routes for wildlife across the landscape.
Whilst no formal designs have been provided to date, we believe that it is not possible to mitigate for the scale of impacts on wildlife with the measures proposed. As such, significant permanent losses to a number of important habitats and a large number of protected species are inevitable.
In July 2022 NCC changed the route of the road and claimed that impacts of the new route on wildlife are acceptable. Why is NWT still opposing the development?
Fundamentally NWT don’t believe there is any route for the NWL that won’t have unacceptable impacts on wildlife.
In July 2022, Norfolk County Council shared data from new ecological surveys on the location of bat roosts and feeding areas within a mature woodland found on the proposed route, and published a new route map that they believe will avoid significant impacts to the bats. The route change would avoid a roost tree found by Council surveyors, but this makes very little difference to the wider impacts of the route and is not evidence that the route is now acceptable.
Conservation Scientist and bat expert, Dr Charlotte Packman, has been leading a research collaboration studying barbastelle bat colonies in the area for the past five years. She has confirmed that Norfolk County Council’s reports only show a very limited snapshot of what is known about the nationally important barbastelle super-colony that is located here – with colony counts, home ranges, foraging areas and roosts substantially underrepresented in their reports.
For example, at one colony the peak count recorded by the Council’s surveys is reported as 27 barbastelles, where her research team have recorded 105. Dr Packman’s data have been verified by the University of East Anglia, making this currently the largest known barbastelle roost in the country.
It is very concerning that the true scale and importance of the barbastelle super-colony has not been presented in the Council’s reports and therefore the proposed impact of the road on barbastelles will be significantly underestimated.
How has NWT shared its concerns?
NWT has written to Norfolk County Council to share its concerns about the protected habitats and species at all stages of consultation on the proposed development. We have highlighted that the proposed bat boxes and new tree planting — regardless of scale — cannot replicate the mature woodland roosting habitats used by a significant colony of endangered bats on the route.
We also wrote several times to the Department for Transport to urge that the NWL is removed from further consideration for funding, for the same reasons.
In recognition of their importance for barbastelle bats, NWT has also written to Natural England to urge them to designate a group of woodlands on the proposed route as a Site of Special Scientific Interest (SSSI) and Special Area of Conservation (SAC). This area clearly meets the criteria for SSSI and SAC status and deserves the full protection under wildlife law that this designation provides. As the area is highly likely to support the UK’s largest barbastelle bat population, safeguarding the important mosaic of habitats that the bats are dependent on in this area through SSSI and SAC designation is a vital step in safeguarding the species’ future in the UK. NWT was pleased to learn that, following our request and sharing of data in 2022, Natural England has added the Wensum Woodlands to a list of sites being considered for designation as SSSIs.
Why should a whole woodland be considered the roost for barbastelle bats, rather than an individual tree?
Different bat species have different roosting requirements. Barbastelle bat breeding colonies are measured collectively at the woodland scale due to the species’ dependency on many different roost trees within the same woodland, which they regularly switch between due to their changing requirements and social interactions throughout the breeding season. Barbastelle colonies are highly faithful to their breeding woodlands, with the same colonies occupying the same woodlands every year.
Evidence demonstrates that their success is dependent on the whole woodland rather than individual roost trees on their own and that breeding colonies can only be safeguarded if the whole woodland is protected.
Won’t the bats just move somewhere else if the road is built?
Barbastelles have very specific requirements, needing mature woodlands with a range of suitable roost trees (they favour loose bark features on old and dead trees) in high quality landscapes with access to extensive and well-connected foraging grounds. They are very strongly site-faithful, returning each year to the same woodland to breed and are known to be mostly sedentary and unable to easily colonise new areas. There are a limited number of suitable woodlands within the landscape (and the few nearby suitable woodlands are occupied by other barbastelle colonies within the super-colony) and habitats are already under significant pressure and have become fragmented by other developments (including the NDR). Therefore, it is very unlikely that the bats would simply be able to move to alternative suitable habitat in the area and overcome the range of major impacts from the road to survive and reproduce in the long-term.
How effective have measures to protect bats on the existing NDR route proved?
There is a lack of evidence to support the effectiveness of bat mitigation measures for roads (particularly for barbastelles) and growing evidence that existing approaches are failing to protect bat populations. Norfolk County Council’s own monitoring data on mitigation measures intended to protect bats on the existing NDR route have unfortunately shown a similar picture, with only a very small proportion of resident bats using the bridges and gantries that were put in place with the aim of helping them move across the landscape separated by the road. Their data also indicate that barbastelle colonies present within 2.5km of the NDR pre-construction, are no longer likely to be present post-construction.
This suggests that, even with mitigation measures in place, the presence of the road has destroyed a previously well-used feeding, breeding and roosting area for bats.
Has NWT shared their bat data with Norfolk County Council?
Independent bat research on this barbastelle population has been ongoing for the past decade, pre-dating any serious intentions to progress plans for a Western Link for the NDR. The research has been undertaken by a range of different groups working together over this period, including Wild Wings Ecology, the University of East Anglia and the Norfolk Barbastelle Study Group (now part of the Norfolk & Norwich Bat Group).
Since 2022 the lead researcher, Dr Packman, has been employed by NWT to support this vital research for barbastelle conservation and to enable the specific risks associated with the proposed NWL to be further investigated and evidence gathered, data analysed and reports and peer-reviewed scientific papers produced so that it will be available to everyone to read.
We are still in the data collection, analysis and write-up phase of this work and sharing detailed data publicly at this stage could jeopardise the academic publication process.
However, we have met with Norfolk County Council to make them aware of the deficiencies in their data. This included presenting our results and findings and sharing interim reports with them. We have advised the Council that the impacts of the road on barbastelles cannot be adequately mitigated and that submitting a planning application for the development in its current form will not meet their legal obligations to wildlife.
Why are NWT concerned about the carbon emissions associated with the proposed road?
Moving forward with the road now also risks the UK not meeting its carbon reduction targets. Recently the Government’s own climate advisors, the Climate Change Committee, advised that the Government should conduct a systematic review of current and future road-building projects to assess their consistency with the Government's environmental goals. This is because the committee found that the Government does not have good enough policies to reduce emissions from road transport.
Once again, Council leaders have closed their eyes to the climate and nature emergency. The two are inextricably linked, and the fate of Norfolk’s wildlife and people relies on meeting the legally binding UK climate change targets, which require steep reductions in carbon emissions in the next decade which this road is just not consistent with.
In addition to building a 700m viaduct that has a heavy carbon burden from embedded emissions from steel and cement production, construction would also destroy carbon rich woodlands and landscapes releasing carbon stored in natural assets such as soil, trees and plants.
The Council’s own traffic modelling shows that carbon emissions in the study area from use of the road will not reduce in line with Government projections in the Net Zero Strategy and local projections in the Local Transport Plan.
Can NWT suggest another solution to the issues the Western Link is proposed to solve?
Whilst we can’t support the Western Link Road due to its unacceptable impacts on wildlife, we recognise that members of the local community are experiencing issues with rat running on narrow roads in residential areas and support the exploration of alternative solutions.
A key part of any major planning application is the consideration of alternatives, and being able to demonstrate that less environmentally damaging options for solving the problem are not possible. Based on the information publicly available at present, we do not believe that sufficient study of alternative ways to solving local traffic congestion had been carried out by the Council before they decided to focus on a multi-million-pound road that threatens to destroy Norfolk’s precious countryside as their preferred option.
Whilst we are not experts on traffic solutions, we understand from other commentators that a range of measures to alleviate rat-running successfully used in other parts of the country have not yet been tried here. When the application is made, we will be reviewing the Council’s consideration of alternatives in detail.
What is the next stage in the planning process?
We understand that Norfolk County Council will be submitting a planning application for the road in 2023, although we are aware the timings are subject to change.
This will be directly followed by a period of public consultation (we expect this to last at least 6 weeks), during which local residents and organisations will be invited to share their views on the proposed development with the Council.
During the public consultation, it is NWT’s intention to highlight our grave concerns to Norfolk County Council and formally object to the final planning application.
Why is this a national issue?
The development of the Norwich Western Link may feel like a very local issue, but the consequences of building the road would be felt on a national scale – both in terms of impacts on a nationally important population of barbastelle bats and due to the dangerous precedent, such a decision would set for further developments across the UK that could harm wildlife.
In the middle of a climate and nature emergency, this development is directly at odds with the UK government’s commitments through the Environment Act and the Climate Change Act, in which the UK is legally bound to halt the decline in species abundance by 2030 and to achieve net zero carbon emissions by 2050.
Read more here.
What can I do to help?
We urge you to speak up for Norfolk’s wildlife, and against the Norwich Western Link.
NWT has joined with other conservation and environmental organisations in launching a petition against the road. Please sign our joint petition, found here.
During the public consultation, NWT is planning on providing an e-action that will support you to respond to the consultation in support of wildlife. Please visit www.norfolkwildlifetrust.org.uk/ndr for more information and to take action when the time comes.
Who else is NWT working alongside to combat the proposed road development?
Norfolk Wildlife Trust is part of a growing collective of regional and national environmental organisations including Stop the Wensum Link, CPRE Norfolk, Friends of the Earth, the Woodland Trust, Norfolk and Norwich Naturalists’ Society, Buglife, Norfolk and Norwich Bat Group and British Dragonfly Society, all of whom oppose the development on the grounds of the unacceptable impact it will have on wildlife and the wider natural landscape.