Stonehenge Alliance Closing Statement

Last updated: 25 May 2004

The Stonehenge Alliance presented two summaries of its case at the end of the public inquiry in May 2004.

Preliminary note

The Stonehenge Alliance’s Closing Statement is given in two parts. This part deals with evidence presented to the Inquiry on plans and policies, archaeology, landscape, hydrogeology, affordability and our final conclusions. The Alliance’s Closing Statement on transport matters is presented in a separate text to the Inspector. Both texts have been agreed for Stonehenge Alliance representative organisations at the Inquiry

1. Introduction

1.1. Having followed closely the evidence brought to the Inquiry, the Stonehenge Alliance’s view remains unchanged: the Published Scheme would inflict severe and permanent damage on the Stonehenge World Heritage Site and ought not to be allowed. This exceptional place has already been much damaged in the past. New ‘improvements’ at Stonehenge should not include a road scheme that English Heritage describes as no more than ‘the best we have on offer’ and falls far short of protection and conservation of the WHS.

1.2. On the contrary, we believe that the WHS is of such outstanding international importance that only the right thing should be done in terms of roads or anything else – even if that means we must wait until such as this may be achieved.

1.3. The Alliance’s case against the Published Scheme, in closing, can be summarised under the following considerations: plans and policies; archaeology; landscape; hydrogeology; transport; affordability; possible alternatives and suggested ways forward; and our final conclusions.

 

2. Plans and policies

2.1. The WHConvention demands that the whole WHS should be protected and conserved for future generations. The Nomination Document mentions the landscape as an integral part of the WHS. It is unacceptable for the Highways Agency (HA) to compartmentalise the landscape, and say that certain areas are more important and/or worthy of greater protection. The HA has placed too much emphasis on ‘enhancement’ of the central area of the WHS to the detriment of the remainder. The issues raised by the proposals affect the whole WHS, which was designated for its outstanding universal value.

2.2. We support ICOMOS-UK’s views on the qualities of the WHS, the need to protect it, and the framework that should ensure that protection, as expressed in Mrs Denyer’s summary Proof of Evidence (Day 11, pp.16ff.). We also agree with her summary of the inadequacy of the Environmental Statement and the reasons why the road scheme is unacceptable for the Stonehenge WHS (Day 11, pp. 19–22).

2.3. Protection of World Heritage Sites and their settings is given a high priority by the UK Government in PPG15. That advice, in respect of the Stonehenge WHS, is reflected in Regional Planning Guidance and in County and Local Plan policies which support the protection of the countryside of the WHS against development that would damage its archaeology and its setting. The strength of these policies is very relevant and the road proposals are obviously in conflict with them.

2.4. It has been questioned whether paragraph 2.22 of PPG15 is relevant to this Inquiry as it refers to the determination of planning and listed building applications. This Inquiry is not dealing with either type of application referred to in the paragraph. This is an Inquiry dealing with Orders under the provisions of the Highways Act 1980, the Road Traffic Regulation Act 1984 and the Acquisition of Land Act 1984. The normal statutory planning process does not form part of the consideration of Highways Orders in which case it could be argued that planning considerations have no place at this Inquiry. This would not be appropriate in respect of this Inquiry for the following reasons.

i) Evidence has been given to the Inquiry on behalf of the promoter and principal supporter of the scheme, the HA and the DCMS, in relation to the planning aspects of the proposals. Similarly, objectors to the scheme have raised relevant planning issues. The proposals in the Orders give rise to planning as well as highway issues and unless these planning matters are properly examined as a key material consideration it is submitted a proper assessment of them will not be possible. There has been no challenge to the submission of evidence relating to planning issues from any party to the Inquiry nor to their importance in relation to the WHS.

ii) An important part of the planning process has been built into the supporting material for the Orders in the form of an Environmental Statement which has been prepared by the HA.

iii) The proposed highway scheme is described as ‘an exceptional environmental scheme’ indicating that it is different from a normal highway scheme. The reasons for it being considered to be an exceptional scheme have been given to the Inquiry and these have indicated that as the proposal affects the WHS special considerations have needed to be addressed. Its relationship to the WHS has raised a number of issues which are clearly related to planning principles.

iv) Throughout the Inquiry reference has been made by all parties to various Government Planning Guidance, Regional Planning Guidance and the statutory development plan all of which make references of importance to the proposals contained within the Orders.

v) PPG15 deals with World Heritage Sites at paragraphs 2.22 and 2.23 and again at paragraphs 6.35, 6.36 and 6.37. Paragraph 2.22 highlights the outstanding international importance of a WHS as a key material consideration to the decision maker of an application for development permission. Whilst this reference is to planning and listed building consent applications notwithstanding the wording of the paragraph it must equally apply in the determination of proposals in Orders such as have been considered at this Inquiry. If any other interpretation were taken on this point it would mean the Secretary of State would not be required to follow the principle of considering any proposal within a WHS as a key material consideration relating to a proposal coming before him that was not a planning or listed building consent application. This cannot be right. Paragraph 2.22 recognises the outstanding international importance of a WHS is a key material consideration in the determining of development proposals. This should apply to any development falling within a WHS which comes before a decision maker.

vi) In these circumstances it is submitted that the decision makers in respect of the Orders before this Inquiry should follow the principle as set out in paragraph 2.22 of PPG15.

2.5. We note the Avebury Society’s reference, at the Inquiry, to planning decisions in the other half of the WHS that respected the principle of protection of the whole site, indicating that the long-term interests of this (Stonehenge and Avebury) WHS were to be taken into account. Copy correspondence (SA/2/18) produced by Dr Fielden on Day 16 in responding to the DCMS, showed that Mr Heron, for the then DNH in 1995, advised that PPG15:

‘urged planning authorities to formulate specific policies for protecting their World Heritage Sites (ie the whole site) [our emphasis] . . .’.

We also note the outcome of the Coal Contractors v. the Secretary of State and Northumberland County Council legal case, concerning proposals for opencast coal mining temporarily affecting the setting of Hadrian’s Wall WHS (SA/0/4/B). We consider that the judgement in this case has direct relevance in considering the road proposals for Stonehenge, where the temporary effects on setting (including the setting of the henge itself) would continue for up to four years, while other damaging effects both within and outside the WHS would be permanent.

Mr Lawson observed that para 3.2.60 of the WHS Management Plan (Day 18, p.54) indicates that a separate ‘buffer zone’ is not needed for the WHS; but the Plan also points to the commitment to ensure (via future statutory and non-statutory plans) that

‘. . . any proposals for new structures or activities outside the WHS would be particularly carefully considered as to their potential effect upon the approaches and setting of the WHS’. (Management Plan, para. 3.2.61)

2.6. The widely consulted and agreed Stonehenge WHS Management Plan has been accepted by the Government and English Heritage as providing objectives for management of the WHS landscape and the archaeological sites and monuments within it, so that the outstanding universal value of the place is conserved and improved (Management Plan, para.1.1.2). There has been no disagreement at the Inquiry that the WHS Management Plan, through its framework of clearly understandable objectives, signals the appropriate way forward for management in the WHS in the short, medium and long term. The Plan has been adopted by Salisbury District Council as Supplementary Planning Guidance and therefore has to be regarded as a material consideration.

2.7. The Published Scheme, however, ignores or only partially meets many of the Management Plan’s requirements (e.g. Objectives 3, 6, 9, 10, 11, 16, 20, 21 and 23); it would compromise a number of Objectives for the future management of the site and its enjoyment by visitors, e.g. restoration of the Avenue (Objectives 9, para. 4.4.6, and 16, para. 4.4.21) and restoration of the wider landscape of the WHS and the provision of access to it (Objectives 11, para. 4.4.8; 20; and 21, para 4.5.14, bullet point 2). In particular, the road scheme does not comply with Objectives 9 and 23 of the Management Plan, which deal with the treatment of roads and traffic within the WHS.

2.8. Management Plan Objectives 9 and 23 express the aim to remove roads and traffic from the clearly defined ‘Core’ and ‘Bowl’ areas of the WHS. The Highways Agency’s ‘MILS’, which extends over the proposed 2.1km tunnel area and is not mentioned in the Management Plan, does not correspond to either the Core or the Bowl. The 2.1km tunnel falls far short of what is required by the Management Plan and Dr Young admitted in cross-examination (Day 3, pp.32–34) that EH had not advised the relevant authorities, including the WHCommittee (via the DCMS), of the areas over which roads and traffic were to be removed under Objectives 9 and 23 of the Management Plan. EH’s advice to Ministers in October 2002 was that any of the longer bored tunnel options (2.1km or longer) would meet the requirements of the Management Plan for the WHS (letter from Simon Thurley, Chief Executive, English Heritage, to the DCMS: CD/INQ/3): it is now clear that that advice was incorrect. ICOMOS were (until recently) and the House of Lords still is under the impression that there would be no damage to archaeological sites resulting from implementation of the road scheme (e.g., DCMS/1/3/App.2, pp.14 and 16; and SA/2/16). We remain very concerned that all of these misunderstandings should have arisen and persist at such a high level.

2.9. Both EH (Dr Young; Day 2, pp.130–31) and the HA appeared to suggest at the Inquiry that the Master Plan, which does not have SPG status, is compatible with the Management Plan, pointing to para 1.5.11 of the Management Plan as evidence that the Master Plan is the means by which Management Plan objectives might be realised. Like other objectors, we do not read this meaning into para 1.5.11 of the Management Plan. Dr Fielden produced earlier drafts of this section of the Management Plan on Day 16 (SA/2/19), demonstrating that distancing of the Master Plan from the overarching Management Plan was intentional. Furthermore, it is obvious, from debate about the objectives of the Management Plan, that the Objectives relate to all aspects of management of the WHS and give particular emphasis to the protection, conservation and rehabilitation of the WHS as a whole. The assertion of EH (e.g. Dr Young, Day 2, p.149) and the HA (e.g. Mr Jones, Day 13, pp. 73–74) that the road scheme meets or substantially meets relevant Objectives of the Management Plan has been shown to be unsubstantiated.

 

3. Archaeology

3.1. The WHS was nominated for its archaeological monuments and sites (most of which were not named in the Nomination Document) and for the ‘landscape without parallel’ of which they form a part. We support ICOMOS-UK’s comments on the outstanding universal value (OUV) of the WHS and the definition of the significance of the Stonehenge WHS in the Management Plan (Day 10, p.101ff. and pp.106ff.).

3.2. Both EH and the HA have sought to undermine the importance of parts of the WHS at the Inquiry by questioning the validity of the assumption that the whole WHS is to be considered of OUV. Their argument was not soundly based. In cross-examination of Dr Young (Day 3, p.52), it was apparent that the WHCommittee has not altered the criteria for inclusion of Stonehenge on the WHList since nomination in 1986; while Article 1 of the WHConvention states that all sites in the WH List are of OUV. Even if present-day nominations for WHSs include criteria for identifying elements of OUV within a WHS, the Stonehenge WHS must continue to be of OUV unless or until precise definition of its value is altered by the WHCommittee.

3.3. Despite asserting that it is the Neolithic and EBA Scheduled monuments that are of OUV at Stonehenge, the HA has produced no maps to indicate the distribution of these monuments and their settings, or to show the visual and contextual interrelationships between them. The HA has not demonstrated that the road scheme would protect the OUV of the WHS.

3.4. Mr Lawson agreed in cross-examination (Day 17) that there would be direct damage to the WHS. The HA’s assessment of the direct impact of the scheme on the WHS appears, however, to have been largely based upon the impacts on individual sites, and these impacts were considered by Mr Lawson to be ‘relatively insignificant’ (Day 17, p.140). Sites inside and outside the WHS had been dealt with in the ES in exactly the same manner. Mr Lawson, despite acknowledging that WHSs are said in PPG15 to be of outstanding international importance, had not included the WHS designation alongside or above other designated areas for the purpose of evaluation of cultural heritage sites affected by the scheme (Day 17, pp.123–4).

3.5. We agree with ICOMOS-UK that the ES has failed to provide an overall assessment of the impact of the scheme on those cultural qualities that combine to give the site OUV, nor considered ‘ . . . the relationships between sites, nor their wider significance in relation to the finds from some of them.’ (Day 10, p.112–113)

3.6. We are convinced by the arguments put forward by objector-archaeologists concerning the setting of the WHS and its individual monuments, and the concept of a progressive setting, experienced as one moves between monuments within the WHS. We also share their concerns about the potential loss of important remains to road works, and about severance. Like them, we do not consider the methodology adopted by the HA to assess impacts on monuments and the site as a whole to be either adequate or appropriate for the WHS.

3.7. Mr Lawson’s method of assessing the impacts of the scheme on the WHS and its setting and the monuments within it and their settings was, in our view, confused and illogical and did not appear to relate to either planning policy or Management Plan objectives for protection of the WHS, its landscape, archaeology and setting. The setting of the WHS had not even been identified by the HA (Day 18, pp.51–5). (See also, our comments on the ‘buffer zone’ of the WHS, at the end of para. 2.5, above.)

3.8. Cross-examination of Mr Lawson by Mr Lindblom (Day 10, pp.23ff) made it plain that the HA’s methodology for assessing impact on the setting of monuments was flawed in that adverse visual effects could be neutralised by balancing them against other effects (noise and context) that were components in the HA’s interpretation of setting. Mr Batchelor (Day 4, p.27) said that the ES generally considered changes to the settings of monuments to be ‘indirect impacts’ (we believe they should be considered as direct impacts). Mr Batchelor agreed that neither the ES nor EH, in his evidence, had considered the impact of the scheme on the setting of the WHS Day 4, p.26).

3.9. Though no archaeological remains hitherto identified to be of major importance would be destroyed, there remain concerns about the possibility of such remains being found during road construction. Furthermore, there are serious concerns about the integrity of the important Saxon remains found at Countess East (Site 88), whose full extent has not yet been established, even though proposed Drainage Treatment Area 9 would lie close by (see Day 4, pp.58–60).

3.10. Dr Fielden (Day 16) drew particular attention to the substantial and visually damaging residual scarring of the landscape that the road scheme would cause.

3.11. We fully support the evidence given by ICOMOS-UK to the Inquiries and especially its reminder that we should be looking not only to the interests of present-day mankind in the Stonehenge WHS but also to the interests of future generations (Day 10, pp.93–94 and Closing Statement).

 

4. Landscape considerations

4.1. ICOMOS has pointed to the designed landscaping of the Stonehenge WHS (Day 10, p.100). Its major monuments have been deliberately located, and their inter-relationships with one another and with the topography of the landscape is not disputed. The road proposals should have been considered for their impact on the designated WHS as a whole, embracing all of its attributes, including its setting. The treatment of landscape matters in the ES is substantially inadequate in a number of respects.

4.2. Recommendations in relevant guidance such as the Design Manual for Roads and Bridges (DMRB), Guidance on the Methodology for Multi-Modal Studies (GOMMS) and Guidelines for Landscape Visual Impact Assessment (GLVIA) have not been followed in important instances, for example:

1. Ms Fox’s Proof of Evidence, para. 2.2.2.3 and Table 1, fails to acknowledge DETR and GVLIA guidance on classification of WHSs as being of ‘high importance, of particular quality, of great rarity and with no or limited potential for substitution’ (see: GOMMS Vol.2, para. 4.7.13; and also: GLVIA, p.144, ‘Determination of Value’).
2. Ms Fox admitted (Day 26, p.127) that the ES fails to assess the cumulative effects of the scheme on the WHS (see DMRB 11, Sect.2, pt.2: 1.15 and 1.16; also: GVLIA, pp. 86–87, Box 7.1).

 

4.3. Critical issues in the Management Plan have been overlooked in the ES, such as:

i) the Plan’s primary emphasis:

‘. . . to conserve the outstanding universal value of the cultural heritage assets of the Stonehenge WHS. ‘Conservation’ in the context of this Plan includes not only ensuring the physical survival of the archaeological sites and monuments, but also enhancing the visual character of their landscape setting . . .’ (Plan, para. 1.1.1; also Ob.1);

ii) the Plan’s concept of Stonehenge as

‘only a single component of a structured landscape in which inter-visibility with other monuments and spaces was likely to have been important’ (Plan, para. 2.2.18); and

‘the gradual change in the visual relationships or ‘ambience’ between Stonehenge and the other principal archaeological sites as the observer moves through the landscape’ Plan, para. 3.2.1);

iii) the Plan’s identification of the opportunities for enhancement

‘of key archaeological sites in the wider WHS landscape to improve visitor appreciation and understanding of the cultural landscape as a whole. For example, ‘earthwork enhancement’, through selective mowing and/or grazing could be used to emphasise the ceremonial route to the Stones of The Avenue.’ (Plan, para. 3.3.4 and Ob.16);

iv) the need for future woodland management and the possibility of

‘selective removal of trees [to] return barrows and earthworks to the landscape’ (Plan, para. 3.2.6; also Ob. 13, para. 4.4.16). and

v) the Plan’s recognition of the ‘fundamental importance’ of Stonehenge and its landscape as

‘a place that continues to offer sanctuary and spiritual sustenance’ (Plan, para. 2.2.32).

4.4. Ms Fox, for the HA, agreed that if the road scheme were implemented, the visual character of the landscape setting would, contrary to the demands of the Management Plan, not be improved for prominent sites such as long barrow Site 41 (Day 23, p.41); nor would it be improved for areas outside the WHS ‘core’– at the eastern and western sides of the WHS, where cuttings and tunnel portals would be located (Day 23, pp.41–2).

4.5. Ms Fox admitted that she had not shown graphically where zones of visual influence lay, indicating how monuments are related to one another (Day 19, p.130); nor had she explained how the ‘component parts’ of the landscape, notably the monuments and views to and from them, would be experienced by people moving through the landscape (Day 19, pp.131–33). She agreed that the relationship between monuments, such as the Winterbourne Stoke barrow group and Stonehenge, had not been considered (Day 19, pp.136–37).

4.6. Ms Fox admitted (Day 19, p.128–30) that long-term management of woodland within the WHS including, for example, the selective removal of trees at key archaeological sites so that barrows and earthworks might be returned to the landscape had not been taken into consideration. DMRB 11, Sect. 2, Pt.2, 1.2 says that:

‘Environmental assessment is to be undertaken to the extent that:

1. it is relevant to the specific characteristics of the project and of the environmental features likely to be affected by it, and
2. the information may reasonably be gathered having regard to current knowledge and assessment methods.’

4.7. Ms Fox agreed (Day 23, p.20) that there had been no Historic Landscape Character assessment, as required by the Management Plan (Plan, Ob. 11 and para. 4.4.8).

4.8. It appears to us that the HA has assessed the impact of the scheme according to its own prescribed limitations, devising a methodology that departs from normal practice in sensitive landscape areas and ignoring the need to take particular landscape characteristics of the WHS into account. The severe adverse effects of the road cuttings in the W and E parts of the WHS have been minimised in an inappropriate exercise that weighs benefits and disbenefits. No sensible attempt has been made to explain the HA’s concept of visual setting in terms of landscape; and the visual settings of individual monuments and of the WHS itself have not been clearly identified. There is no separate assessment of the impacts of the scheme on the landscape of the WHS.

4.9. The ‘Stonehenge Bowl’, which extends to Longbarrow Crossroads, has long been agreed as an area to be avoided by any route for the diverted A303 owing to its archaeological and visual sensitivity. Ms Fox agreed that the cutting and grade separated junction at the west side of the WHS would be modern and discordant features in the landscape and would be at considerable variance with the landscape (Day 19, p. 135; Day 23, pp.31–2). The DETR Guidance on the Methodology for Multi-Modal Studies (GOMMS; March 2000) set out as Table 2 in Ms Fox’s evidence and Table 6.2 in Chapter 6 of the ES advises that such features, at ‘considerable variance with the landscape’, would have a Major Adverse impact and we do not share the HA’s view that these new features would result in a Moderate Adverse impact. The resultant Major Adverse impact would be imposed upon a highly sensitive ‘gateway’area to the archaeological landscape of the WHS – both on the outstanding Winterbourne Stoke barrow group and on the setting of the WHS itself.

4.10. Visitors approaching the WHS from the west, either by road or by the newly created byway, would have a clear view of the proposed grade-separated double roundabout junction at Longbarrow Crossroads. Walkers would pass beside the new dual-carriageway cutting above and at ground levels and see a long barrow (Site 41) perched on top of the west tunnel portal. Traffic in the western cutting (which would be exposed at above ground level over some length) would be visible from barrows at Normanton Down and from walks on Stonehenge Down. Alterations to cutting design would leaves fences in full view.

4.11. Despite the clear departure of the road scheme from Objectives 9 and 23 of the Management Plan, and the implications its implementation would have on landscape character and setting in the WHS, no photomontages were produced by the HA to show the layman what the completed scheme would look like from critical viewpoints in the WHS.

4.12. We cannot agree with Mr Batchelor who said (Day 4, p.56) that the proposed extensive Longbarrow Crossroads junction would have only ‘a slight effect’ on people’s ability to comprehend the landscape in historic terms. And, like other objectors at the Inquiry, notably the archaeologists (e.g. Mr Lambrick, Day 12, pp.102–104), we see no reason to suppose that it would never be possible to restore the route of the ancient Avenue and mark it in some way to make it interesting and intelligible to visitors.

4.13. The ES fails to consider comprehensively the acknowledged spiritual and religious aspects of the WHS that are identified in the Management Plan and Mr Norfolk’s comments on its inadequacy on this important matter (SA/3/1, paras. 8.1 and 8.12–18) were not challenged by the HA. The Management Plan, para. 2.2.32, says:

‘The strong sense of history, the continuing intrigue and speculation, the astronomical and mystical significance of the Stones and its landscape setting for many people, all point to the universal spiritual value of the WHS in today’s society. Maintaining and improving Stonehenge and its landscape for future generations as a place that continues to offer sanctuary and spiritual sustenance is of fundamental importance.’

1. 
   
2. 5. Hydrogeology

5.1. In the Alliance’s view, the issues of lateral groundwater drainage and the concrete slab construction in Stonehenge Bottom have not been given sufficient prominence by the HA. Both present considerable cause for concern as to both short and long term environmental effects in Stonehenge Bottom.

5.2. Mr Reeves (Day 16) raised concern about the long term effects of the scheme on the chalk aquifer (and consequently on the surface water course to which the aquifer discharges), and highlighted the possibility that the tunnel could cause changes in groundwater flow patterns resulting from higher permeability in the excavation damage zone.

5.3. There could be serious drawbacks in the proposed barrier that would be created by the SCL tunnel in Stonehenge Bottom. The Alliance accepts Mr Reeves’ view that a tunnel constructed by the TBM method might prove less problematic, owing to its depth below the water table.

5.4. In Cross-examination of Mr Harries, for the HA, it became clear that works in Stonehenge Bottom would be both extensive and visually intrusive during construction. The proposals for horizontal drains to be constructed within the concrete slab over the tunnel area, to allow for lateral transfer of groundwater, are a novel method of groundwater control; they are unproven in both theory and practice, and in a chalk groundwater environment are very likely to clog up over time with both calcrete build-up and general accumulation of fines. Long term maintenance would be necessary and it would be difficult to carry this out effectively as acidisation of the system, for example, might well be involved. It appeared that certain issues in respect of these proposals remain to be resolved.

5.5. Contamination of the groundwater arising from a possible incident in the tunnel, however slight that possibility might be, cannot be ruled out. A serious incident in the tunnel could lead to pollution of the River Avon cSAC and this should not be lightly ignored. Mr Reeves referred to incidents that had occurred in tunnelling using the New Austrian (SCL) and other methods of tunnelling, and the disastrous effect that had resulted on tunnel linings. The 4.5km tunnel, lying largely below the water table at all times, would be less likely to lead to contamination of the groundwater following an incident in the tunnel. In a short tunnel, the sump is more likely to be affected/damaged and rendered ineffective following an incident.

5.6. There remain concerns that insufficient borehole testing has been done.

5.7. We note that the Appropriate Assessment required by English Nature, in respect of the cumulative impact of proposed developments affecting the Avon cSAC has still not been done (ref. our legal submission).

 
6. Affordability

6.1. During the course of the Inquiry, it has become clear that the A303 scheme was the brainchild of English Heritage in 1997. Despite the change in tunnel length, from 2km to 2.1km, and the use of a bored tunnelling technique instead of cut and cover, the scheme disregards earlier commitments to protection and rehabilitation of the whole WHS that were made in line with the Government’s duty under the WHC (e.g. HA 1995 Planning Conference Resolutions nos. 2, 3 and 9; CD/HA/95). The scheme is not it compliant with planning policy for the WHS or the WHS Management Plan.

6.2. EH and the DCMS assert that UNESCO’s World Heritage Committee is content with the scheme proposed and we may assume that its support is needed for the scheme to have credibility. We have raised concerns about the advice given to the Committee on the Stonehenge Project. In effect, the developer informs the Committee and, from the wording of Reports to the Committee presented to the Inquiry, it appears that inadequate advice has been given about the impacts of the scheme on the WHS.

6.3. The HA, in cross-examination and in their evidence, admits that the decision to opt for 2.1km tunnel was based on what could be afforded and this confirms statements made by Prime Minister Tony Blair and Transport Minister John Spellar, before Ministers decided to opt for a 2.1km bored tunnel (see correspondence produced by the Alliance at the Inquiry: SA/2/10a–b and SA/2/17).

6.4. There has been no explanation as to how the sum of £70m was arrived at as the amount required from the DCMS for protection of the heritage at Stonehenge. Clearly that sum is not enough for that purpose. Like the Council for British Archaeology, and other objectors at these Inquiries, the Alliance is not content that a judgement should be reached on what can be afforded for Stonehenge that is not based on any rational analysis of the value of the heritage, both for its own sake and in the interests of those who value and enjoy it now and those who will do so in the longer term.

6.4. The matter of measurement of the monetary value of the heritage at Stonehenge has also been raised in the Alliance’s Closing Statement on Transport matters, where it is considered in relation to the traffic and economic value assessments of the road scheme.

6.5. We were interested to hear the convincing evidence of Professor Maddison on Day 32 of the Inquiry and would like to endorse his recommendation that a new valuation is needed for the heritage at Stonehenge, using up-to-date techniques and a more wide-ranging survey, including evaluation of a long bored tunnel and responses from people outside the UK.

 

7. Alternatives

7.1. Dr Chippindale’s proof of evidence (Day 11) was convincing in drawing attention to the regrettable outcome of precipitate planning undertaken during the last century at Stonehenge. We, like other objectors, see no reason why the Government should be in any hurry to implement a road improvement scheme at Stonehenge, especially one that will severely and irremediably damage the site. There is no urgency for road widening on transport grounds.

7.2. The decision-making process leading to promotion of the Published Scheme was flawed from the start. An unconsulted ‘Master Plan’ road scheme has been advanced, despite its incompatibility with widely agreed objectives for roads and traffic in the WHS that appear in the more recent, overarching, Management Plan. The proposals are based on what the Government considers it can afford for the WHS, not on what is needed to protect and conserve it for future generations. This short sighted approach should be abandoned before further damage is done.

7.3.A breathing space is needed in which to find a better solution than that which is under scrutiny now. We should not be considering any road solution that inflicts further damage on the WHS, rather we should be working to a programme of protection, conservation and repair, in line with objectives of the Management Plan. It is agreed by most parties at the Inquiry, that a road solution that would remove the roads from as much as possible of the surface of the WHS would be better than the Published Scheme.

7.4. The Alliance is not advocating a Do Nothing situation. We would be glad to consider a scheme that would do no further damage to the WHS and would be aimed at protecting and rehabilitating the WHS as a whole. We would be prepared to consider serious proposals for a 4.5km tunnel or for alternative routes for the A303 outside the WHS.

7.5. The HA accepts that a long bored tunnel is technically feasible. Ministerial rejection of longer tunnel solutions was for purely financial reasons, on the basis of a subjective judgement that the marginal benefits of protecting the whole WHS were outweighed by the extra costs. Mr Jones, in cross-examination on Day 23, agreed that it would be possible to make visual improvements to the present road layout at Longbarrow Crossroads, should a 4.5km bored tunnel be implemented; this would be one of the considerable advantages of a more visionary scheme.


7.6. Mr Batchelor (Day 4, p.64) admitted in cross-examination that a fund-raising appeal for a longer tunnel had not been thought of and that perhaps there would be potential for raising money by appeal.

7.7.We would not agree to the NT’s proposal for a 2.9km tunnel since this, like the published scheme, would not be compliant with planning policy and would leave parts of the WHS severely damaged by road works and their long term impact on the site in terms of noise, and destruction of archaeological remains and setting, including the setting of the WHS.


8. In conclusion

8.1. The proposals are clearly a highways scheme with an attempt made to provide some environmental benefits. It fails miserably on this count. Without the DCMS’ (inadequate) financial contribution the scheme would not appear in the Roads Programme. The scheme does not involve closure of the A344 to traffic, which was the principal demand of the WHCommittee at the time of Inscription of the WHS; and, should there be any delay in constructing a new visitor-centre outside the WHS, the A344 would remain open to the present visitor-centre traffic indefinitely.

8.2. We remain deeply concerned about the blinkered approach of EH and the HA to the values and potential of the WHS as a place of significance and interest to visitors. Dr Young, of EH, said ‘I fear that . . . humanity will continue to go very largely to the Stones and the area around them since those are the things that are the iconic monument of which people are aware.’ (Day 2, p.133). Under cross-examination, it was admitted by Dr Young that part of the Management Plan’s vision is that visitors should be better informed about the WHS and encouraged to explore the wider landscape as well (loc. cit.). Mr Batchelor agreed, in cross-examination (Day 4, p.46) that the walker’s journey of expectation through the landscape towards Stonehenge could be damaged by road cuttings if the scheme were to be implemented.

8.3. This regrettably narrow-minded approach has allowed English Heritage and the DCMS to endorse road proposals that are oriented solely towards improving the environment of the henge, rather than of the WHS as a whole. The same under-valuation of the WHS can be seen in the NT’s proposals for an alternative that would damage an area that has been shown, by archaeologists at the Inquiries, to be of special significance, notably during the Neolithic period. The approach of these bodies to the road proposals has led us to be sceptical of their commitment to the WHS and its values and this naturally raises very worrying concerns in view of their responsibilities for the heritage, both at Stonehenge and in general.

8.4. It was shown that no examination of the environmental effects of the scheme was undertaken and considered by Wiltshire County Council, so that the Council’s support for the proposals should be given little weight.

8.5. It is the Alliance’s view that the road scheme would be so damaging to the WHS that it should be rejected. Like ICOMOS-UK, we do not feel that we should support the scheme for the benefits it would bring – for those benefits would be gained at too high a price: substantial and irreversible damage to the WHS and its setting. We would prefer to see nothing done rather than the damage the scheme would cause. We would, however, be glad to consider a scheme that would do no further damage to the WHS and aimed to protect and rehabilitate the WHS as a whole.

8.6. We have been strongly impressed by the revelations brought to the Inquiry by archaeologists Dr Parker-Pearson (Day 11), Professor Whittle (Days 12 and 13) and Dr Shell (Day 13) who object, for their organisations, to the road scheme. New work being undertaken in studying the relationships between monuments and landscape, changing concepts of setting (including the ideas of ‘mobile’ or ‘fluid’ setting, and the setting of unseen archaeological remains (e.g., Dr Parker-Pearson, Day 11, pp. 83 and 85; and Professor Whittle, Day 13, pp.13-16)) and the astonishing potential for future discoveries, has highlighted the exciting possibilities for interpretation of the whole WHS to visitors. Emphasis on new and currently developing investigations and techniques, and the evidence of ICOMOS-UK, has helped to bring home to us, if indeed that were needed, that the WHS is truly a place of outstanding international spiritual and historical importance, of which, as representatives of our nation, we are justly proud.

8.7. We do not need to be specialists in the field of British prehistory, to instinctively recognise the significance of the Stonehenge landscape and the need to respect and restore it. Some of us have taken part in the production of the Management Plan that endorses the outstanding universal value of the WHS. That is why we are here – to argue against the appalling threat that hangs over this WHS, all the more shocking because those who have responsibility for its protection are those who would damage the place and its setting for ever, apparently through lack of full understanding of the value that is to be placed upon it.

8.8. Our message to the Secretary of State is simple. We plead, logically because of the planning framework that should safeguard it, and with heartfelt enthusiasm because of its acknowledged significance to mankind, for the preservation of the Stonehenge WHS for future generations. We respectfully ask for a stay of execution until a better solution may be found and we would naturally be glad to assist in any effort to achieve such a solution.

The Stonehenge Alliance Closing Statement

Transport Considerations

 

1. Economic versus Heritage Justification

The Government has been at pains to present the A303 Stonehenge Improvement as a stand-alone project driven primarily by heritage as opposed to transport objectives, describing it as an "exceptional environmental scheme".

As raised on Days 4 and 17 and in the Supplementary Note by Denise Carlo, Government aspirations to increase the capacity of the A303 as a second strategic route between London/South West as an alternative to the M4/M5 to Exeter, are given strong prominence in transport policy documentation. It is clear beyond any doubt that the Government is seeking to upgrade the A303 to dual carriageway standard and provide a shadow to the M4/M5. The Published Scheme needs to be considered in this wider context. It contradicts the Agency’s refutation of this situation in HA/13/48 para 2.

The Published Scheme first entered the national roads programme as the A303 Berwick Down to Amesbury Improvement in 1989 when the White Paper, Roads for Prosperity (CD/HA/38) announced a major expansion of the inter-urban roads programme to meet revised traffic growth forecasts.

Plans were thwarted until English Heritage’s idea for a cut and cover tunnel enabled the Government to proceed. The route across the World Heritage Site and the A303 Winterborne Stoke bypass were combined to create the A303 Stonehenge Improvement.

The consultation paper, What role for trunk road in England (attached to SA/8/1) which set out the parameters for the trunk roads review in 1997, highlighted the importance of upgrading the A303 corridor:

"The A303 is an alternative to the M4/M5 between London and Exeter; whilst longer in distance, the motorway is normally quicker. However, increases in motorway congestion and improvements to the A30/A303 are likely to make this route increasingly more important" (p58 para 3)

A New Deal for Trunk Roads (CD/HA/18) shows the A303 as part of a core network map of nationally important routes, the aims of which include linking main centres of population and providing access to peripheral regions (p 22).

In the absence of a cut and cover tunnel initiative, Mr Jones surmised the scheme would not have re-entered the roads programme at the time of the roads review announcement in 1998. Instead, it would probably have been remitted to the London to South West and South Wales multi modal study (SWARMMS). (Day 17 p33 line 13)

SWARMMS assumed the A303 Stonehenge Improvement as a fixed input and did not assess the traffic impacts of whole corridor improvements on either the scheme or the World Heritage Site. The study recommended upgrading of the A303 partly as a way of reducing congestion on the M4/M5. (CD/HA/34 para 3.18.3)

Since 1997, the heritage and traffic elements have become inextricably linked, as Mr Jones phrased it. (Day 17 p33 line 13) Whereas the Stonehenge WHS was previously regarded as an impediment to Government aspirations for dualling the route section, the cut and cover tunnel solution promoted on heritage grounds created a convenient transport opportunity.

Does it matter whether a key driver behind the A303 Stonehenge Improvement owes more to economic than heritage factors? The answer is yes for several reasons.

In A New Deal for Trunk Roads in England, the Government promised,

"a strong presumption against new or expanded transport infrastructure which would adversely affect environmentally sensitive areas or sites such as Sites of Special Scientific Interest, National Parks, Areas of Outstanding Natural Beauty or National Nature Reserves. There will however be a few cases in which overriding public interest will allow development to proceed which will have an adverse impact on nationally or internationally designated sites." (CD/HA/18 3.4)

The Alliance considers that the Published Scheme fails the test of a "strong presumption against" as it would adversely affect an environmentally sensitive site.

Furthermore, the Government has not demonstrated the test of "overriding public interest". Firstly, the Alliance considers that the environmental disbenefits outweigh the benefits, with the Government prepared to sacrifice the setting of important parts of the WHS and its setting.

Secondly, there is no urgency for widening the A303 on transport grounds. On several occasions, Mr Jones acknowledged the scheme would not have been promoted for highway-related reasons alone if it were not for the perceived heritage benefits. (Cross-examination by Mr Lindblom on Day 8, p.104; Stephen Joseph on Day 17 p 32 line 27)

Traffic levels are low relative to other strategic routes. They range from 22,400 AADT within Winterborne Stoke (where the Congestion Reference Flow is 24,000), to 32,800 AADT east of the A344 (where the Congestion Reference Flow is 27,800). (NB The difference in flow between the western and eastern ends of the route section is accounted for by in the region of 10,000 vehicles turning off onto the A344 and A360. It would be interesting to model the effect of measures that encourage drivers who normally travel on the A344 to leave the A303 at Amesbury and use the A345 as an alternative route. Re-location of the Visitor Centre would also have an effect on A303 traffic).

Mr Jones agreed that the crash rate for the single carriageway sections is lower than the national average (Day 17 p 45). Safety is therefore not a major argument for dualling.

Thirdly, the Agency has not justified the Published Scheme in the context of Government plans to develop the A303 as second strategic route and an alternative to M4/M5.


Fourthly, the Highways Agency has not tested other transport options that would better protect the whole World Heritage Site, for example, a long bored tunnel funded by a toll.




1. Predict and Provide

As revealed by the Alliance cross-examination on Day 17, the inquiry is dealing with an old style "predict and provide" road scheme using a fixed trip matrix. The appropriateness of this in relation to this scheme was dealt with by Professor Goodwin and is summarised below; we do however have to put the scheme in context of the improvement of the A303 as a whole.

As a result of this upgrading of the whole route, types of traffic on the A303 Stonehenge Improvement include:

• Reassigned traffic from the M4/M5 using the A303 as a shorter route

• Induced traffic from the upgrading of this section and of the rest of the A303, for example through changes in origins and destinations of trips, or through changes in modes, or a combination of these

• General traffic growth – accounted for by national background traffic growth based on GDP growth and changes in general motoring costs

• Locally generated trips - although the Agency claims that only 16% of traffic on the A303 is local, the proportion of long distance to local traffic may alter in the future as a result of major housing and employment allocations located at Amesbury to take advantage of A303 improvements. Mr Jones confirmed that the Agency did not object to the Salisbury District Local Plan allocations for these developments, the effects of which would be to increase local traffic on the A303.

The fact that this scheme is just part of an upgraded full route leads to uncertainty as to how much of this traffic has been taken into account by the Agency. Whilst current traffic levels are relatively low, the Scheme has been designed, according to the Agency, to a high standard with grade separated junctions, "and so the issue of bottleneck-related problems is much less likely to occur". (Day 17 p49 line 23). "The Scheme …..would provide residual capacity in the Design Year of 2023, even assuming high growth." (HA/13/21 para 3.2). The Agency accepts the need to manage traffic along the route at some future point, otherwise it (the tunnel) "become a bottleneck in itself" (Day 17 p50). Mr Jones stated that the alternative proposition to constructing a dual [two-lane] carriageway would be a dual three-lane carriageway which the Agency "decided against promoting for various (heritage) reasons". (Day 17 p 50).

Nonetheless, as a result of providing for residual capacity in the Design Year assuming high growth, the Alliance argues that the road has been over-designed. Indeed, the Agency highlights the ability of the new road to carry flows of 70/80,000 vehicles per day and therefore to comfortably accommodate the amount of induced traffic calculated as a result of the Published Scheme itself and as a result of further improvements on the A303. (HA/13/48 para 3) Building in residual capacity for various types of traffic growth (reassigned, induced, background, locally generated) has adverse implications for the World Heritage Site, for example, the effect of the Grade Separated Junction at Longbarrow Crossroads on the setting of the Winterbourne Stoke Barrows.

The traffic and economic appraisal

This leads us to the discussion about the traffic and economic appraisal for the scheme. Our evidence, and the Highways Agency’s responses, have made some progress here, and we would like to make two main points – first, what may now be taken as agreed among all parties; secondly, bearing in mind the Inspector’s ruling on the ‘sensitivity tests’ we asked for (which we do not re-open), what follows in terms of caveats to the appraisal.

What is agreed?

On day 17, Professor Goodwin argued that the economics of the scheme were not ‘robust’, i.e. it was uncertain whether the traffic and economic benefits were sufficient to justify the costs, and on some assumptions even in the present appraisal, these benefits were less than the cost. The Highways Agency agreed with this: as Mr Jones said, taking the appraisal as it stands at present, if this were a conventional road improvement ‘with these sorts of economics, it would not be in the programme’. (Day 17 p55 line 18)

But that does not mean that the traffic appraisal may be ignored, because the worse or more uncertain these impacts are, the higher or more certain the environmental benefits have to be to justify going ahead. The potential for ‘induced traffic’ – the additional traffic that is encouraged by the existence of the improvement itself – is nowadays always one of the aspects that are looked at when considering economic appraisal, because induced traffic can erode part of the congestion relief that is offered, or shorten the period over which congestion may be ignored. This is especially the case if the provision of road capacity in a local area is part of a larger scale programme, as this is: A New Deal for Trunk Roads in England (CD/HA/18) includes the A303 in a Core Network of nationally important routes whose purposes include providing access to peripheral regions (2.2). If there is to be any impact on the wider economy of constructing a road then this would be incompatible with the assumption of a fixed trip matrix used in appraisal.

The Highways Agency considered this, and concluded (on the basis of the various assumptions and parameters they used) that induced traffic would be small, of little potential importance. So after this initial test they decided to proceed with the appraisal on the assumption that there would be no induced traffic, nor any changes in the patterns of origins and destinations chosen, or time of day of trips, or the method of transport used – what they call a ‘fixed trip matrix’. However, In cross-examination, Mr Jones agreed with a number of important points, namely

1. when traffic is operating in conditions of congestion a fairly small difference in traffic volume can make a more than proportionate difference to the level of congestion (Day 17 p51 line 14)
2. in turn, this fairly small difference in traffic can potentially make a bigger proportionate difference to the net present value, i.e. the overall economic balance of costs and benefits (Day 17 p51 line 19)
3. the fixed trip matrix model they used would not be suitable for allowing for induced traffic within the economic assessment, and they have in fact done no test to include induced traffic in the economic assessment - either the small amount of induced traffic they assumed, nor the larger amount of induced traffic that would result from different parameters, advice or assumptions. (Day 17 p57 line 2-9)

Thus Professor Goodwin thinks it is fair to say that the following points are agreed:

1. The scheme stands or falls on its claimed environmental benefits, the traffic and economic impacts not being strong enough to support it.
2. The amount of induced traffic that would exist can potentially have a disproportionate impact on the economic assessment.
3. We have in front of us no estimate of how big that potential is in quantitative terms.

 

(In the absence of such figures, what we have is judgement, unsupported by analysis, and on that we do not agree. The Agency thinks that the induced traffic they expect – but which they have not modelled – would not have a material effect. Professor Goodwin thinks that the induced traffic he expects – but which he also has not modelled – could have a material effect. The Alliance has suggested in supplementary note SA/8/1 that this might amount to as much as 20% on top of the Agency’s forecasts, depending on the treatment of induced traffic on the A303 as a whole. The Alliance is suggesting a 20% figure in the context of upgrading the whole A303 corridor. The Agency’s rebuttal of this figure in HA/13/48 para 4, on the other hand, is solely in the context of viewing the Published Scheme as a stand-along project.

The next question is what follows for the bounds, caveats or constraints within which any recommendation can be made in this Inquiry, and on this Professor Goodwin would like to argue that there is a genuine problem which is now ambiguous.

As the Inspector told us, his guidelines, based on the Bushell ruling made in the House of Lords in 1980, include the statement

'The merits and foundations of policies, methodologies, design standards, economic assumptions and forecasts of traffic growth adopted by Government are not matters for argument at inquiries. Any arguments about them must take place at national level'.

The fact that the ruling is a quarter of a century old is not of itself significant. The relevant point is that the last national road traffic forecasts, issued by Government in a format and timescale aimed at use for road schemes, was seven years ago, in 1997. Now when we inspect the text of the NRTF 1997 Report itself (paper CD/HA/90) there are a number of important explanations of how it might be used. In particular it cited its Advisory Group's conclusion that

'different policies will result in different forecasts' (para 52)

and it gave notice that

'...a new NRTF, identified by a new date, will be issued if major policy changes are introduced, or significant changes are made to the forecast inputs, or if further research leads to substantial changes to the present approach, or the formulation of a new forecasting method' (para 50)

That was in 1997. The report gave a list of parameters, assumptions and sensitivities, which were used to calculate forecasts through to 2031.

NRTF 1997 suggested that total traffic would grow, on its central forecast, by 17% in the decade 2001 to 2011.

Now the dilemma arises because it is clearly true that ‘a new NRTF, identified by a new date’ has not been issued by the DfT in the 7 years since 1997. (Hence the Inspector’s ruling). But it is also true that over that 7 year period since 1997 all the changes listed which would trigger such a revision have actually happened - major policy changes, significant changes to the forecast inputs, further research leading to substantial changes to the approach used then, and the formulation of a new forecasting method.

The demonstration of this is that the Department for Transport is not currently using the 1997 forecasts, or the model, assumptions, parameters and policy trends that had underpinned them. We can see this in published official DfT reports directed at its own most important forecasting exercises at national level, namely forecasting for the Government’s Ten Year Plan for Transport, 2000-2010. (I am not talking here of sensitivity tests, but the core central assumptions for the forecasts)

The scale of difference that has already been made by the Department for Transport may be seen in a comparison of two forecasts, made in 2000 and 2002.

Department for Transport Forecasts for the period 2000 to 2010

	Traffic Growth	Change in Congestion
Ten Year Plan, July 2000 (CD/HA/19)	+17%	-6%
Ten Year Plan Progress Report, December 2002 (SA/6/3)	+20% to +25%	+11% to +20%

It can be seen that in 2000 the Government expected traffic growth nationally to be 17% in the decade – entirely compatible with NRTF 1997. But by the end of 2002 this had already been very substantially revised. That the difference is material can be seen by the implied changes in the level of congestion, which are different not only in size, but even in direction.

That is the current Government view, whether it has re-issued NRTF or not.

If the change in assumptions and parameters can have such a big effect on the national figure in ten years, one simply cannot stop oneself from speculating how big an effect the equivalent changes would have at a local level, over thirty years.

We cannot argue, at this local inquiry, about whether the Government is right or not in its new national forecasts. But that doesn’t make the problem go away. This scheme has been assessed using assumptions that will be revised – as demonstrated by the published fact that they already have been revised, in part – before an inch of tunnel is dug.

So what follows? What Professor Goodwin submits is that – whatever the Inspector decides to recommend, the recommendation should be made with an explicit, and important, caveat. His suggested wording for that caveat is as follows:

"All the forecasts and appraisal underpinning the figures provided to the Inquiry are based on an approach to National Road Traffic Forecasting as outlined by the Government in 1997 which – it has been argued – is now in the middle of an uncompleted process of fundamental revision. These revisions may relate to any or all of those aspects which the Inquiry guidelines do not allow the Inspector to consider, namely

‘policies, methodologies, design standards, economic assumptions and forecasts of traffic growth adopted by Government’.

The recommendations therefore are based on – and hence confined to - the logic of the 1997 NRTF, as implemented by the Highways Agency in accordance with the instructions given to them by the Department for Transport. It has been agreed in the Inquiry that if any or all of these were to change, the appraisal results could in principle also change. In that case, Ministers would need to consider whether to re-appraise the scheme. The Inspector’s recommendations would not necessarily apply"

Professor Goodwin notes that Mr. Jones said

"I would disagree with very little, if anything, of what Professor Goodwin said; the point is that we are aware of the unfolding policy picture, we have been in close contact with the Department over this period of time and they are not asking the Agency to do anything more than we have done in accordance with prescribed procedures and methodology at the moment" (p25 2-8).

Professor Goodwin is concerned that the outcome of the Inquiry should be in accordance with the spirit, not only the letter, of the prescribed balance between national and local considerations: the special reason for considering it seriously at this Inquiry is not because of a general principle that ‘things might change’ which is of course always true, but because of the imminence and high likelihood of the changes which have already started to manifest themselves.

 

1. Alternatives

Alternatives to the Published Scheme are considered in the Alliance’s main closing statement. We make some reference to alternatives here, specifically in the transport context.

HA agrees that dualling on transport grounds is not a priority. Consequently, abandonment of the scheme would create a breathing space in which to find a better solution than that which is under current scrutiny. Although we have promoted no alternative scheme at the Inquiry, we would be prepared to consider serious proposals for a 4.5km tunnel or for alternative routes for the A303 outside the WHS. Looking into the future, transport developments will increasingly revolve around designing the vehicle and track to fit in with the environment and will be less intrusive in the landscape. HA implicitly acknowledge this likelihood in floating the idea of decommissioning the tunnel at some time in the future.

The HA Statement of Case claims to have studied all possible route options. However, under cross-examination, Mr Jones admitted the Agency had not investigated the option of a longer bored tunnel financed by a revenue toll (Day 17 p35 line 21-23). The Queen Elizabeth 11 Bridge at Dartford is an example of major infrastructure projects funded by the private sector in return for toll revenues.

A long bored tunnel would command wide support. The 1995 Planning Conference led by English Heritage gave its full backing to a long bored tunnel. A working paper, Summary of Tunnel Comparisons, submitted to Ministers in October 2002, shows a preferrance for a bored 4.53km tunnel on the part of the National Trust, ICOMOS and Stonehenge Alliance–type groups (the latter described by the report as "extreme opposition groups"). (CD/HA/33 Table 1.3 column 6 – Bored 4.53km tunnel – Comments box)

The Agency’s dismissal of the Alliance suggestion for a tolled tunnel on grounds that it would cause diversion onto less suitable routes such as the Packway, is inconsistent with its claimed intention to introduce demand management at some future date, as this could also in theory cause diversion. Diversion could be overcome by a national road user charging scheme, depending on its design. In the interim, diversion could be managed by adopting an area-wide approach to non-pricing demand-management measures to encourage diversion of long-distance traffic. Diversion of local traffic onto the local road network is entirely appropriate and any impacts on the network and on communities could be ameliorated by measures such as speed reduction. Until the Highways Agency models, using a variable trip matrix, a long bored tunnel with a toll set at varying levels, accompanied by solutions such as area-wide, non-pricing demand management measures, it is not in a position to rule out this option on diversion grounds.

In summary, the Alliance advocates an interim approach - Do-Minimum plus Do-Something Else, involving further small-scale safety measures such as speed reduction and small changes to junctions, Active Traffic Management, soft measures to reduce both local and long distance traffic and or experimental closure of the A3444.

In addition, the Alliance recommends the investigation of a wide package of measures as a long term solution that could include:

• a long bored tunnel funded by a toll or subject to national road user charging
• closure of A344
• small safety measures such as speed reduction
• improvement of sustainable transport alternatives.

A World Heritage Site deserves a truly "exceptional environmental" package of innovative solutions to provide better protection of the whole asset and not just the central part.

1. The Scope for Demand Management

The Agency’s rebuts the Alliance on this subject when it says, "pursuing other alternatives to road building would not secure the heritage objective. (HA/13/21 p2)

However, the Alliance is not suggesting that demand management measures alone, ranging from soft measures to pricing, would secure heritage benefits. We support the need to completely remove the A303 from the whole World Heritage Site, either by tunnelling or diversion. The Published Scheme would achieve only partial removal of the present road and protect just a limited area, confined to the setting of the Stones.

Demand management would form part of a package solution for the WHS in order to constrain traffic growth and reduce environmental effects such as noise. The Agency’s response that "In the future it can be anticipated that demand management measures of some form may well be in place, thereby maintaining the capacity of the Published Scheme", (HA/13/21 3.3) acknowledges the need for such measures to control traffic growth. However, the Agency hasn’t specified measures to accompany the scheme or the timescale.

Government findings on The Influence of Soft Factors (SA/6/1 p 11 footnote 1) demonstrate the measurable scope of soft measures for reducing traffic, irrespective of journey purpose or whether it is long distance or local, contrary to the Agency assertion at HA/13/21 para 6.4).

2. The Scope for Speed Management to Improve Safety and Manage Demand

The Agency has not commented on the section on speed management and safety in the Alliance proof (SA/6/1) and therefore we conclude they accept our case on these matters. Moreover, in cross-examination, Mr Jones agreed with the Alliance’s central argument that the crash rate for the single carriageway sections is lower than the national average and that this is a function of lower speeds (Day 17 p45-46).

Variable speed limits on this route section of the A303, coupled with

measures to control junction speeds would go a long way to addressing safety problems. The description of "exceptional environmental scheme" should be extended to treatment of the present route in which priority should be given to environmental protection of the WHS over transport and economic considerations. For this reason, the A303 past Stonehenge is a suitable candidate for the Highways Agency’s "toolkit" of small scale measures for making best use of existing roads.

Further SWARMMS work compares the performance of upgrading the A303 through Blackdown Hills AONB in Somerset, against the alternative of a longer diversion via A358. In the event of the Secretary of State opting for the A358 solution, his decision would give priority to environmental protection over longer journey times. A decision of this kind would act as a precedent for, introducing variable speed control on the A303 past Stonehenge.

 

3. Closure of the A344

The Agency is mistaken in interpreting the Alliance proposal for A344 closure as a stand-alone scheme. The Alliance is not arguing that closure of A344 by itself is sufficient, rather it should be undertaken in conjunction with a range of other measures, including small-scale safety works, speed reduction and other types of non-pricing demand management (in advance of any national pricing system). Soft measures such as travel plans for the new employment areas planned in and around Amesbury would help in tackling peak hour congestion.

The Highways Agency claims that closure of the A344/A303 junction at Stonehenge Bottom is dependent on dualling of the A303 to avoid congestion on the A303 and rat-running along local roads. However, the traffic figures are unreliable as they are based on a fixed trip matrix whereby closing the A344 transfers all traffic to the A303. Without modelling the effects using a variable trip matrix, the Agency is not in a position to make categorical claims about the effects of closure. Closure and even down-grading of the A344 could lead drivers to modify their journeys. Diversion of trips along the Packway could be discouraged by the installation of traffic management/ calming.

 

Long versus Short Tunnel

We would like to add some comments concerning the implications of the appraisal results for the case for considering a tunnel of a different design: this case (though affected by the forecasts in the same way as any other assessment) does not depend on the argument above.

The current HA position is expressed as follows

"The transport benefits that would be derived are substantial with high or low traffic growth, and the cost of the tunnel that starts to erode the net value of these transport benefits is being justified by the heritage benefits it would bring to Stonehenge and its immediately related sites and monuments. The Scheme is not therefore dependent on high traffic growth for its justification as suggested by the Alliance (Para 4.1.4.4), though the potential impacts of high growth have been assessed, as presented in the Environmental Statement (DD’s 9, 10 and 11)" (HA Rebuttal to Mr Joseph, 18.3.2004, para 2.2)

In quantitative terms, we can then identify two cases, corresponding with the range of economic outturn as estimated. At one end of the range of assumptions considered, the Published Scheme is predicted to have a negative net present value, -£35.1 m, but at the other end, the estimated net present value is positive, +£85.2 m. (6.3.3.2 p 58)

On this basis, the economic case for the published scheme would not be sufficient to justify its inclusion in the programme. No quantified estimate has been made of the economic value of the expected environmental benefits (because the NATA appraisal does not require this to be done, and because there is no well-established method for doing so): but a qualitative value judgement has been made that they are large enough to justify the scheme, informed by the environmental assessments that have been carried out.

Objectors have queried whether those environmental benefits would in fact be achieved, and suggested that there are other environmental dis-benefits which should be taken into account.

We make no comment on the content of those arguments about the environmental benefits themselves, but we do think that it is possible to extend the argument about their interaction with the economic benefits rather further than has been done.

At the moment, although the Highways Agency has not sought to give a monetary value to the environmental benefits it hopes will occur, it has made the judgement that they are sufficiently large that they outweigh the economic ‘loss’ even on the most unfavorable assumptions they looked at. This was the case where the scheme was estimated to have a negative net present value of -£35.1m.

So we can say that in proposing the scheme, the Highways Agency is committing itself to a value judgement that its expected environmental benefits are worth at least £35.1 million. (We appreciate that they have not chosen to use these words: We am arguing that it is logically implied in their proposal).

We also know that the Highways Agency feels that there is some additional ‘headroom’ in this minimum value, for example they judge any loss in economic value (that they agree would be some) which would arise from including induced traffic in the economic appraisal, would not be enough to outweigh the environmental benefit they expect to be produced.

But it is not conceivable that the Highways Agency judge that the environmental benefits are so huge and certain that there is no upper limit to the economic price it would be justified to pay in order to achieve them. One might speculate: suppose the NPV were -£100m or -£200m or -£1000m? There must be some economic price at which the planned environmental benefits of the scheme could not command the degree of priority in funds, over other schemes elsewhere in the country.

We are sure that the Agency would be reluctant to state what that upper limit might be, even though it has in fact made a judgement about what the lower limit is: it is confident that the environmental benefits are worth more than £35.1m, and it will (we prejudge) accept that there does exist some upper limit even though it is not certain what it is.

There are two useful implications that follow from this logic.

First, the degree of confidence that may be placed on the environmental benefits is a material issue. The more uncertain they are, the less likely it is that they will be sufficiently high to outweigh the poor economics of the scheme.

Secondly, the question of a longer tunnel may be handled within the same logic. No doubt a longer tunnel would cost more, and therefore its expected economic appraisal would probably be poorer. But, by exactly the same argument, it is possible that its environmental benefits might be sufficient to outweigh a poor economic appraisal. Exactly the same issues arise: a value judgement is necessary about whether the minimum value of the environmental benefits exceeds the potential negative economic value. And then an additional value judgement is necessary about whether the extra environmental benefits obtained from the longer tunnel are greater than the extra economic costs of the longer tunnel.

 

Conclusions

The scheme has an adverse impact on the wider WHS which is not justified by the economic and traffic benefits. The HA say that this scheme would not have proceeded without the extra heritage funding, yet the rest of the A303 is being upgraded as a result of the SWARMMS multi-modal study and it is clear that the Government places a value on the upgrade of the whole of the route and that this has driven the approach to Stonehenge which underplays its heritage value and overplays its value in traffic and economic terms.

We have drawn attention to uncertainties about the traffic levels to be expected at Stonehenge, with and without the scheme. We argue:

1. that it is possible to influence traffic levels and growth, especially at a local level
2. that a range of alternatives and smaller scale approaches could in principle deal with many of the problems in and around Stonehenge while a more acceptable longer term solution is found
3. that the Agency’s approach to this scheme, using a fixed trip matrix, is likely to understate or misrepresent the impact and benefits of these alternatives.

We further argue that there are wider uncertainties about the traffic levels to be expected and catered for in the future. We have noted, and the Agency has accepted, that there is a process of change in modelling and appraisal underway at national level; we understand that this is outside this inquiry’s scope, but ask that the Inspector note this uncertainty and to caveat his recommendations accordingly if new forecasts or appraisal methodology are agreed at national level.