A36 Corridor Alliance response on Stonehenge

Last updated: 22 March 2006

The A36 Corridor Alliance campaigns for better transport links in and around the A36 corridor in the West Country. This letter is their response to the 2006 public consultation on Stonehenge.

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The Stonehenge Project
Highways Agency Zone 2/26 – H
Temple Quay House
2 The Square
Temple Quay
BRISTOL BS1 6HA

22nd March 2006

Dear Mr. Chapman

A303 Stonehenge Review

The previous A303 scheme, taken to public inquiry in 2004, was described, somewhat unctuously, as an ‘exceptional’ scheme, on the basis, presumably, that the Stonehenge site was too important to be treated irresponsibly by any government that proclaims a civilised respect for its nation’s heritage, landscape and environment.

The scheme before the Inquiry in 2004 did not, however, meet up with the standards one ought to expect from a civilised government. It was hugely damaging of a World Heritage Site, a damage that ought not to have been even contemplated. Now we are presented with worse. Four routes through the World Heritage Site, all with large surface damage, the northern and southern scheme being worse from this point of view, whilst the crassly conceived cut-and-cover monstrosity (aptly described as equivalent to routing a cabling duct through the Sistine Chapel ceiling and making good with Polyfilla and a few dabs of Airfix enamels) is revived as a cheap alternative. The 2.1km bored tunnel returns, only, since this was unaffordable before, it will presumably now be a cheaper, nastier construction the HA has in mind.

The fifth option, perhaps the most dishonest, is to do nothing except build more road capacity at either end of the WHS and wait until that capacity generates enough traffic to force through further demands for a Stonehenge scheme. This is the Twyford Down principle – build your less controversial motorway from both sides up to the edges of the really important area, so that the pressure to fill the gap becomes irresistible.

What is the Problem?

The Government has its priorities back to front in all this – the problem in this landscape is not Stonehenge, the problem is the road. The Government has it in its mind that there is a reconciliation to be had of an irresistible force and an immovable object. But such a metaphor is to compare things of equivalent importance. Does the Government seriously believe that the importance of the A303 compares with the importance of Stonehenge?

What is this road in the scheme of things? It is just another road of 300,000 miles of road in this country. For a period of 30 years or so, maybe 50, this road is being built to carry mostly superfluous, subsidised traffic from one place to another, which could be carried by much more efficient means or not carried at all. Beyond the end of oil, beyond the possible cataclysm of climate change, who can say that the A303 has any importance at all? For a period of 5000 years Stonehenge and its landscape have endured to the world’s wonder. They would endure for the wonder and amaze of a less greedy and culpable future, beyond the end of oil and maybe beyond all but the worst ice age consequences of climate change.

So, what should give way here? There is no reconciliation to be had. There is no grubby compromise to be had, we cannot talk the political talk about ‘balance’ - there is no scale in which the importance of Stonehenge can be weighed against the supposed ‘needs’ of road transport.

The problem of the existing road is traffic, which compromises the site, in its landscape setting and in the noise intrusion. But to put it in those terms is to speak the dead language of the planner, who talks in terms of decibels and viewpoints, believing that formula or quantification can somehow describe the problem in a way that permits quantified amelioration. This is profoundly to miss the point. The planners, if they are unable to understand this themselves, must be made to at least acknowledge that there are people for whom Stonehenge is ineffable, transcendent, a place of mystery and poetry, to be felt, not observed or analysed.

The problems of the proposed options are many - the damage done to archæology, landscape and habitat; the traffic generated by such schemes damaging the site and many other places outside the site. We argue in the section below on ‘Inner Sense’ that out-of-sight is not out-of-mind and that tunnel schemes create a fundamental problem of their own for those who most care about the sense of immanence in the place.

Crucially, however, the proposed options do nothing useful in addressing the existing problem of traffic. We argue below, on the noise problem in particular, that the activity of roads is super-insistent – minor changes in decibel levels are of negligible importance in dragging our thoughts away from the unreasonableness and intrusiveness of the noise itself.

Taking the traffic away from Stonehenge – the wrong way

Firstly, the ridiculously named ‘Partial Solution’ does nothing for Stonehenge except make everything worse through traffic generation. How is that in any way a ‘solution’?

If we take at face value the assertion that the purpose of this consultation is to find the best way of taking traffic away from the Stonehenge monument, then the options put before us need to be measured against a number of important aspects:

Archaeology: We do not think we have any special qualification to comment on archæological matters though we know that there are many who are so qualified and have concerns about the schemes on offer here. We cannot, however, see how the destruction of a substantial area of land deemed to be of world-class heritage quality, can be contemplated. The level of destruction in terms of surface area is greatest for the northern and southern routes but in all options (apart from the ‘Partial Solution’) the land affected is not peripheral to the designated area but through the middle of it.

We note from issues of the Stonehenge Vision, the magazine of the Stonehenge Project, that significant, unexpected archæological finds are still being made within the WHS. This surely means that we ought to expect significant things to be found within the footprint of any of the road options within the WHS. Of course the promoters will say that rescue archæology will reveal that, but as established at the last Inquiry, if anything of huge importance were to be discovered, there would be no contingency commitment by the Highways Agency to abandon the scheme in order to preserve such finds in situ.

Landscape: The removal of the road from the immediate visual field of the stones is of no great benefit (considering its cost elsewhere), since the presence of the road remains insistent in other ways. We know that the tunnel options result in substantial remodelling of the landscape at the portal ends (especially at Stonehenge Bottom) with lighting from the tunnel and in the approach cuttings. We know that the greater part of the road in the WHS would be a surface road much wider and much more intrusive than the current road.

The northern route enormously affects the landscape of Woodhenge, the Cursus and the Old King Barrows all of which are represented in the Stonehenge Project as being important parts of the pedestrian access from the proposed Visitor Centre. The Southern route impinges on the Normanton Down area, also represented by the Stonehenge Project as being an important visual area.

Habitat: Again we have no particular expertise in this area, but we note the concern of others, particularly the very forcefully expressed concern by the RSPB over the threat to the stone curlew and 25 other species of the two all-surface routes in particular. We note again that the newsletters of the Stonehenge Project have themselves drawn attention to the importance of the habitat, including special reference (Update Autumn 2004) to the importance of the WHS for the future of the stone curlew.

Noise: The importunity of the noise intrusion applies to all the options proposed. One only has to go to any of the big new roads that have been built in recent times to know that nothing of peace and quiet is to be had within three or four miles of them. Take, for example, the M3 at Winchester. Here was a road that the DfT promised would bring reduced noise to many areas of Winchester’s valley and downland landscape and yet which, together with the A34, has completely blighted the whole of these areas. What Cobbett described as the finest landscape in England can only be enjoyed by the deaf.

In addition to its manifest failure to physically predict noise levels correctly (as at Winchester), the DfT has notoriously always failed to understand the effect of noise in the landscape. Noise can be physically intrusive, of course, to the point of aural damage and such effects are clearly physically measurable and relatable to physical measures of the sound (dB). But its psychological intrusion is much more complex - the degree of psychological annoyance that noise brings is actually not measurable in terms of dB.

Reasonableness and appropriateness are factors – if my neighbour’s TV is too loud I prefer it turned down (i.e. dB counts), but if my neighbour is known to me to be hard of hearing, the degree of annoyance is lessened. If I live in a town, one level of noise is appropriate; if I live in the countryside a different level of sound seems reasonable. In an important landscape the sole meaningful noise criterion is that the only noise should be that of Nature – it is a fatuous analysis to compare the decibel level of a road to that of a skylark. Unless one is physically incapable of distinguishing the noise of a road from the sounds of Nature, the noise of traffic is importunate in Nature at all dB levels – it demands attention and instils dismay.

The northern and southern options for Stonehenge both come within a mile of the stones. The traffic from such roads would dominate the experience of the stones, not so very differently from the present road, particularly given the increase in traffic and traffic speed that such a new road would generate. So, cutting a whole new swathe of land elsewhere in the WHS offers no real advantage and only further damage.

The tunnel scheme and the cut-and-cover scheme leave portals less than 1km away from the stones. One DfT argument against a tunnel scheme at Twyford Down was that noise emissions from the portals would be too great. In any case the noise evidence at the Stonehenge Inquiry (even if it is to be trusted more than the evidence for the Winchester M3) suggested that at best the noise levels at the stones would be equivalent to those pertaining at about ¾mile side-on to an unprotected road of the same traffic levels. There is no sense in which such noise levels could be construed as anything other than monstrously intrusive into the atmosphere of such an important site.

Inner sense: The essence of Stonehenge is not simply in its visual appearance within a landscape. If it were, the simplest, cheapest option for the DfT would be to move the stones to some theme park which recreated the landscape. It is very hard to analyse why it should be so, but most people we believe would regard this as ridiculous. Even though such things have been done before (such as the move of the Abu Simbel temple) no civilised nation would contemplate doing it now.

Crucial to the place is the sense of place, atavistic longings, the wonder about people who wrought wonders here. There is the desire to know, through archæology, but also the desire for the hidden and mysterious – the ground beneath one’s feet feels as though it hides the unknowable. For this reason a road beneath the ground ought to be anathema to anyone of sensibility. It would be as present to the imagination as the surface road is to the physical senses.

Once done, a tunnelled road is done forever – the mystery of the ancient ground is gone forever. The present road, however, only does its damage to Stonehenge for the brief Age of Oil, after which it would drift into minor use or, in disuse, would be absorbed slowly back into the landscape.

Beyond the WHS: The Government claims that the A303 scheme is part of the wider Stonehenge Project and highlights very nicely, in its ‘consultation’ brochure, a lot of good aims for the project. None of them includes increasing traffic on the A303 or any transport purpose at all. This highlights the essentially fraudulent nature of the Government’s position on Stonehenge. If the Government were really putting these proposals forward as aimed at meeting the objectives of the Stonehenge Project, it would surely have proposed schemes that did the least damage to the WHS. If the Government were proposing a tunnel under the whole WHS, we might very well argue about the rights and wrongs of that in other terms (indeed, as a modern transport campaigning group, we certainly would), but we could not gainsay the government’s intention to meet the aims of the Stonehenge Project.

But the government does not propose this. The government proposes only schemes which increase the capacity of the A303 and, therefore, its traffic generation effect. This then is the overriding objective of the schemes proposed. Yet nowhere in the consultation brochure, however, is this objective declared. Nothing in the brochure whatsoever explains why the A303 needs to have increased capacity. This is profoundly hypocritical.

The effects of increasing the capacity of the road within the WHS are clear. Traffic generation will make all surface roads noisier, more polluting and more visually unattractive. Outside the WHS it will make all sections (including existing ‘improved’ sections) of the A303, noisier, more polluting and more visually unattractive. In particular it puts pressures on communities elsewhere in the corridor – indeed we suspect it is intended to, in order that such communities may be persuaded more readily to accept further schemes.

As with all road-building the knock-on effect of the capacity increase does not apply just to on-corridor communities. Our group’s particular concern is for the pressures put on the north-south roads in Wiltshire and Dorset. The M4-South Coast attraction appears to be highly influential with local authorities, who, for whatever reason, see the opportunity to develop road freight routes from southern ports (e.g. Poole and Weymouth) northwards. A closer east-west major road with its M5,A34, M3 connections is clearly a big interim attractor, likely to encourage these north-south movements, which threaten much of rural Dorset in particular.

Taking the traffic away from Stonehenge – the right way

The Hippocratic Oath is popularly supposed to say ‘first do no harm’. This would not be a bad principle of government. There is no doubt in our minds that everything so far proposed by the Government at Stonehenge would do much more harm than good. We are sure that the Government has been trying to get something acceptable to those people who care about Stonehenge. But even the National Trust, whose association with the Highways Agency in the Stonehenge Project, has been a cause of much distress amongst environmental groups, has been profoundly upset by what has been on offer from Government.

We believe that it is time for the Government, therefore, to acknowledge that there is no longer a possibility of a road scheme in the WHS. The importance of Stonehenge is the immovable object; there is no justification for making an irresistible force out of a transport policy of relatively insignificant importance. We note that government has come to such a rational conclusion elsewhere in the past – the Avon valley east of Bath and the twin environments of the New Forest and the Blackwater Valley at Wellow in Hampshire were seen precisely as immovable objects, so much so that the A36 has become virtually detrunked.

Presumably the stated aims of the Stonehenge Project remain. With the exception of the Visitor Centre, about which there could be a wide range of opinion (even within our own group), the objectives seem such that no reasonable or caring person could object to. Some of the objectives could be achieved simply by the better management of land as the Stonehenge Project anticipates and indeed as the National Trust and DEFRA are already engaged in. Those objectives, however, that relate to the traffic on the road can only now be addressed in two ways:

1. The government does nothing. This option essentially means building no new capacity along the A303 corridor. Traffic will grow according to so-called ‘natural growth’ (as distinct from the induced traffic from A303 improvements elsewhere) until such time as:

   1. The road physically clogs up.

   2. Or the oil price brings its own limits

   3. Or until wiser government policy prevails.

2. The government takes positive action to reduce traffic on the A303. This option can include measures from strategic re-designation, through specific corridor alternative transport measures to wider regional or national traffic reduction policies.

Do nothing: Stonehenge will be the worse for extra traffic at least for the short term, but we would contend not significantly worse. The Stonehenge experience is already close to a limit of nastiness. Extra moving traffic means some more noise, but as the congestion limit approaches and the average speed drops, tyre noise, which is now the worst aspect of modern roads, will drop, though at the limit air pollution will be greater. The congestion limit has the advantage of deterring traffic from this corridor, whereas any of the road building options simply increases it and the noise effects attendant upon it.

None of this is pleasant for the present generation of those who care, but in the longer term, resource limitation and the possibility of wiser government will take us past congestion-limited traffic restraint. And the longer term is what is important to Stonehenge – 50 years of insane transport policy is nothing in the timescale of this place.

Obviously with Do-nothing, the capacity increases at Winterbourne Stoke and Countess Roundabout are absurd, as indeed are any further road building or junction improvements anywhere along the A303 corridor, or any part of the network likely to affect traffic on this road. The A344 from Stonehenge Bottom to Airman’s Corner we believe is a special case for consideration. An examination of the road network would suggest that the effect of removal of this link would be entirely borne by the A303/A360 sides of the triangle. The effect of blocking off or removal of the A344, therefore, would be to increase traffic on the A303 west of the stones, comparable to the effects of a fairly short period of natural corridor growth (and probably much less than would occur from induced traffic as a result of the road-building options). It merely brings forward somewhat the congestion limit of this road, in the case that oil price or better government policy do not act soon enough.

Removal of the A344, therefore, would seem to offer significant value to the surroundings of the monument without much cost. It would also gain the supposed accident benefit from this junction at no real cost.

We note, incidentally, that the South West Regional Assembly has not called for funding of schemes at the western end of the A303, so clearly does not see this corridor as a priority for road development.

Traffic reduction: Strategically the inter-regional function of the A303 acts as a parallel corridor to the M4/M5. We are, of course, tempted to assert that for these two motorway corridors the environmental damage has already been done; that for much of the A303 corridor much has so far been spared; that Stonehenge is so important that it justifies attempted diversion of traffic to the parallel corridor by re-designation (e.g. de-trunking of the A303). The principle of diversion of traffic, however, is not one which we favour. Such a principle, beloved of the Highways Agency, sets community against community – encouraging classic NIMBY. Of course by seeking traffic restraint on a particular corridor we might be thought of as passively favouring the natural diversion to other corridors that would result. Our response to that is that we favour restraint on the A303 corridor as an early transport objective, a precursor to achieving restraint elsewhere.

But traffic reduction is not simply about deterrence or diversion. We would favour, in the medium term (there is no ‘long-term’ in these matters) an overall reduction in travel (i.e. in trips by whatever mode) as the only sensible response to the imperatives of dwindling energy resources and growing climate danger. But in the short term we believe that there is much more that could be done by government towards alternative modes of transport.

The SWARMMS study was as fraudulent as all the other supposed multi-modal studies. Essentially it promoted uni-modalism by promoting road schemes it thought the Highways Agency would fund and paid lip-service to alternatives, effectively clothing the road wolf in a ragged fleece of unfundable public transport alternatives. In the most amazing circular logic SWARMMS based itself on the assumption that the A303 through Stonehenge would be ‘improved’ and, therefore, other sections of the A303 would have to be improved; then the Stonehenge Inquiry used the expected SWARMMS improvements of the A303 elsewhere to justify the Stonehenge scheme.

Now that a road scheme at Stonehenge is unconscionable, it is time for Government to commission a real multi-modal study for this corridor. This should investigate (for the first time) where all the traffic is coming from and how the trip desires can be met by alternative means. This should include not just the long distance (London-Exeter) traffic and the potential (in our view very considerable) for railway infrastructure and service improvements, but also the potential of local bus services to take the shorter corridor trips.

Stonehenge is itself a trip attractor and the Government should be seeking much better public transport access for the site. The current maximum 8 buses per day from Salisbury station, for example, could be much improved. It may be objected that the current service is not fully used and that therefore, there is no demand to be met. But the proposed visitor centre anticipates very significant car parking – indeed an objection to having the re-sited visitors’ centre off Countess Roundabout without building the road in the WHS, was stated to be that the traffic movement at Countess Roundabout would demand grade-separation there. Too much private road traffic should be met by demand management – e.g. through increased parking charges – these could cross-subsidise public transport access – i.e. trip access can be maintained or increased, only its mode would be changed.

For tourist traffic, Salisbury is not as well-served by train from London as, say, Winchester, in terms of frequency or speed. More importantly, however, the tourist journey from Salisbury to Bath could be much improved. The woefully neglected railway service from Bath to Salisbury could be enormously improved for a fraction of the cost that the Highways Agency plans to spend in the A303 corridor, an improvement which would do much to alleviate problems along the A36 corridor that have led to the many foolish road proposals we have been struggling against for years.

We understand that the Salisbury Transport 2000 group, which has been at the forefront of developing green travel plans for that City, has also made a recent submission on Stonehenge, in which it proposes a number of alternative transport measures. We fully endorse that approach and continue to wonder why the Department for Transport, with all its resources, is incapable of thinking of such alternatives for itself.

The government is supposedly contemplating the use of road pricing to restrain traffic growth in the ‘longer term’ (though why it should be so delayed we do not know, since the essence of the technology is already there – in any case interim nation-wide traffic reduction can be achieved by stepping back on the fuel price escalator). The discriminatory power of location-based road pricing enables special consideration to be given to locations where the externalised cost of road transport is even greater than usual. In such a sensitive environmental area as Stonehenge, the externalisation of costs is enormous. While we dislike the notion that we may be putting a price on the environment, it is eminently reasonable that traffic imposing such an environmental cost as it does at Stonehenge should pay over the odds. Road pricing is a powerful mechanism for deterring externalisation here.

Conclusion

The Government’s position on Stonehenge is now simply ludicrous. It had a scheme which it was pursuing against huge opposition, a scheme which was unacceptable even to its partner in the Stonehenge Project, the National Trust. It considers this deeply unsatisfactory scheme to be unaffordable so comes up with a consultation exercise in which it proposes only things which are much worse. It is clear that Government no longer has a clue what to do here.

The truth is that Stonehenge has revealed the essential rotten heart of Government transport policy. You cannot have the Environment ‘at the heart of Government policy’, as is claimed and continue with a transport policy which is profligate of resources, ruinous of the environment and quality of life and essentially unsustainable. It is time for the Government to acknowledge that it is not possible, with honour or integrity, to build roads through a World Heritage Site.

If no road is to be built here, then there is no logic to further road-building anywhere on this corridor, not least because of the stated aims of the Government in the Stonehenge Project, to aim for the removal of traffic from the vicinity of the monument. Indeed, if the Government was the least bit serious in its avowal of those aims it needs now to develop a strategy for reducing the traffic on this corridor. It should start with a proper multi-modal study.

Yours sincerely

Christopher Gillham