National Trust: Outline Statement of Case
OUTLINE STATEMENT OF CASE
OF
ENGLISH HERITAGE
- English Heritage
- Remit and Responsibilities
- English Heritage is recognised by the Government as the lead body for the historic environment. Its powers and responsibilities are set out in the National Heritage Act 1983 (as amended).
- Officially known as the Historic Buildings and Monuments Commission for England, English Heritage is an executive non-departmental public body sponsored by the Department of Culture, Media and Sport (DCMS).
- English Heritage works in partnership with central government departments, local authorities, voluntary bodies and the private sector to:
- conserve and enhance the historic environment;
- broaden public access to the heritage; and
- increase people’s understanding of the past.
- English Heritage meets these responsibilities by:
- acting as a national and international champion for heritage;
- advising government and local authorities on applications for scheduled monument consent, planning consent, listed building and conservation area consent and other planning and development proposals including those affecting registered historic parks and gardens and battlefields, and also providing pre-application advice to owners and developers;
- acting as manager on behalf of the nation for over 400 historic properties;
- maintaining the National Monuments Record as the public archive of the heritage;
- giving grants for the conservation of historic buildings, monuments and landscapes;
- encouraging broader public involvement with the heritage;
- promoting education and research; and
- generating income for the benefit of the historic environment.
- The work of English Heritage is overseen by a board of up to 17 Commissioners selected by the Government for the breadth of their expertise in areas such as archaeology, architecture and conservation of historic buildings. The Commission is, in turn, advised by several expert advisory committees and panels whose members are independent experts.
- Stonehenge
- Stonehenge is the most outstanding prehistoric monument in the British Isles. As such, English Heritage has special responsibility for its heritage and management.
- In discharging this responsibility English Heritage has certain distinct but related roles:
- a policy role vis-à-vis World Heritage;
- lead role, as curator of Stonehenge, in advising upon planning and scheduled monument consent applications, etc;
- responsibility with other stakeholders for implementation of the Stonehenge World Heritage Management Plan (explained at 3.1 below) including provision of a World Heritage Co-ordinator;
- as manager of the central part of the World Heritage Site (as described at 3.1(e) below); and
- as a partner in the Stonehenge Project (as explained at 3.1(b) below).
- Stonehenge World Heritage Site – Heritage
- World Heritage Convention
- In 1972 the United Nations Educational, Scientific and Cultural Organisation (UNESCO) adopted a special convention concerning the protection of the World Cultural and National Heritage in order to provide international support and protection for important sites. The World Heritage Convention (the Convention) aims to protect heritage sites which are of such "outstanding universal value" that their conservation is of concern for all people. It is for each State Party to decide how it will apply the Convention within its own territory. Internationally, application of the Convention is overseen by the UNESCO World Heritage Committee (the Committee), made up of 21 countries elected from among the member states of the Convention.
- The UK is a strong supporter of the Convention and the Government has an international obligation to identify, protect, conserve, present and transmit to future generations the Cultural World Heritage values of its inscribed sites. Under the Convention, sites are inscribed on the World Heritage List, the highest standard of international recognition. There are currently 754 such sites in the world, 25 of which are in the UK.
- World Heritage Site Inscription
- The international importance of Stonehenge, together with Avebury, was recognised by inscription onto the World Heritage List, as Site C373 (Stonehenge, Avebury and associated sites) in 1986 on the nomination of the UK Government. The nomination describes Stonehenge and Avebury as the two most important prehistoric monuments in Britain.
- For a site to be included on the World Heritage List, it must meet at least one of six criterias set out in the Operational Guidelines for the implementation of the Convention (UNESCO, 1990 revised). The inscription of Stonehenge and Avebury onto the List recognises that together they meet not just one, but three of these criteria as set out below:
- represent a masterpiece of human creative genius;
- exhibit an important interchange of human values, over a span of time or within a cultural area of the world, on developments in monumental arts or town planning and landscape design; and
- bear a unique or at least exceptional testimony to a cultural tradition to a civilisation which is living or which has disappeared.
- In addition to meeting the above criteria, the Stonehenge WHS was also recognised by the Committee as satisfying two further tests of having authenticity and having in place adequate legal protection and management mechanisms to ensure its conservation.
- At the time of inscription and subsequently, the Committee has expressed concerns about the impact of the A303 and A344 and about the poor standard of visitor facilities.
- Stonehenge World Heritage Site – Management
- Stonehenge World Heritage Site Management Plan
- Need for the Plan
- Concern for the conservation and management of Stonehenge, together with its associated monuments and the wider historic landscape within the WHS, has continued to intensify since the early 1960s. Stonehenge is under pressure not only as a result of the large number of visitors it attracts, but also from the impacts of traffic that uses the A303 to the south and the A344 a few yards from the Stones themselves. The visual impact and noise pollution of the roads has long been recognised as a significant detractor from the setting of the Stones. Post-war agricultural intensification, changes in military use of the northern area, around Larkhill and increasing demands for leisure and recreational use of the countryside are all continuing to contribute to changes in the character and quality of the WHS landscape.
- Operational Guidelines issued by the World Heritage Committee emphasise the importance of adequate management mechanisms as an effective way of managing WHSs, especially where there are a number of interests. In order to meet the UK’s obligations under the World Heritage Convention, the Government have recommended, in Planning Policy Guidance Note 15: Planning and the Historic Environment, that all World Heritage Sites should have management plans as well as effective policies for their protection in local plans. The Government and English Heritage are working with site owners and managers, local authorities and other interested parties to put comprehensive management plans in place for all World Heritage Sites in England.
- Formulation and Publication of the Plan
- Following extensive consultation with the Government, interested bodies and site owners, a Management Plan for the Stonehenge WHS was prepared by English Heritage and agreed by the stakeholders. The Plan was published in June 2000.
- This followed the announcement, in April 1999, of the Stonehenge Master Plan, now renamed "The Stonehenge Project". The Project is a partnership between the DCMS, the Department for Transport (DfT), the Highways Agency, English Heritage, the National Trust and the Heritage Lottery Fund. It sets out the Government’s commitment to improving the Stonehenge landscape and provides an action plan for such improvement. Running in parallel with the Management Plan, the Project is a mechanism by which some of the principal objectives of the Management Plan are proposed to be financed and delivered.
- Main Aims of the Plan
- The primary emphasis of the Management Plan is to conserve the outstanding universal value of the cultural heritage assets of the Stonehenge WHS.
- The main aims of the Management Plan are:
- to provide objectives for the 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;
- to increase public awareness of and interest in the WHS, and to promote the educational and cultural value of the archaeological landscape as a whole;
- to outline a sustainable approach to the future management of the whole WHS landscape which balances archaeological and nature conservation, visitor access and farming;
- to identify the economic and cultural benefits of the WHS and work with partners in the local community to maximise these benefits, without damaging the archaeological resource; and
- to suggest a prioritised programme of action that is achievable and will contribute to the conservation, understanding and, where appropriate, the improvement of the WHS for all of those who visit Stonehenge and live or work in the area.
- Status of the Plan
- Within the UK, World Heritage Sites are not statutory designations and their management plans have no statutory basis. Rather, they provide an advisory policy framework for guiding and influencing in a positive manner current, planned or potential management initiatives at a variety of scales and for different purposes. Achieving the desired conservation aims for the Stonehenge WHS depends on those signing up to it working effectively in partnership towards the agreed objectives summarised in the Plan.
- The Wiltshire Structure Plan and the Salisbury District Local Plan are the statutory development plans against which proposals for change in the WHS are determined. There are no additional statutory controls directly resulting from the WHS inscription on those living or working in or around the Site under current Government policy. However, it is incumbent on the local planning authorities to recognise the importance of the WHS as a "key material consideration" in their planning policies and proposals (Planning Policy Guidance Note 15, 1994). The Stonehenge WHS was adopted by Salisbury District Council as Supplementary Planning Guidance in relation to its Local Plan on 26 January 2000.
- Description of the WHS
- The WHS boundary is drawn to the north along The Packway, between Rolleston Camp and the A345 roundabout at Durrington; to the east largely along the west bank of the River Avon; and to the south along Parish boundaries past Roxhill to the A360. The western boundary is formed by the A360 and B3086.
- The boundary of the WHS encompasses over 2,500 hectares of land containing a high density of both buried and visible "upstanding" archaeology sites and monuments. In addition to the Stonehenge monument itself, the boundary has been defined to include a number of important ridge-topped barrow groups (Cursus Barrows, Normanton Down Barrows, New King and Old King Barrows, Lake Barrows and Winterbourne Stoke Barrows); Woodhenge and the henge enclosure at Durrington Walls; and The Avenue and Cursus earthworks. Much of the area surrounding the WHS is also of archaeological importance. The boundaries of the WHS also include the National Trust Stonehenge Estate managed with the specific intention of improving and protecting the setting of the stone circle and its surrounding monuments and landscape.
- Archaeological and Historic Significance
- Stonehenge is the finest achievement of megalithic architecture in England. The unique characteristics of Stonehenge – its bluestones, the lintels and the shaped stones and the wider archaeological landscape – are unrivalled anywhere. The diversity, density and composition of surviving sites and monuments richly demonstrate man’s spirit and achievement in pre-historic times.
- Stonehenge as a place occupies a unique position in our national heritage. Its archaeological importance is unquestionable. The landscape that we see today is the culmination of millennia of human activity. The remains unearthed within the WHS point both to the degree of status and to the substantial trade that existed in the past, indicating a highly developed society.
- The WHS contains much more than the Stones alone. As a whole it represents a rich assemblage of archaeological sites and monuments providing a unique insight into changing cultural values and land uses. There are 784 know archaeological features recorded within the WHS boundary and 175 distinct areas which are afforded statutory protection by scheduling because of their national importance. These 175 scheduled monuments include 416 individual archaeological items.
- Cultural Landscape Significance
- The archaeological sites throughout the WHS are evidence of the different cultures and the subtleties of a complex sequence of events and human activities which have influenced the development and character of the landscape over a period of 5000 years. In particular, the unusually extensive survival of the densest and most varied complex of Neolithic and Bronze Age monuments in England are a visible part of the present day landscape. Many individual monuments are typical of their period while other types are extremely rare. Other less well known, less visible, or buried sites all contribute to the understanding of the historic landscape and past cultures. As a whole, the combination of different monument types and their concentration in a relatively small area is unparalleled.
- Management Issues
- Current Management Arrangements
- In November 1998 English Heritage established the Stonehenge WHS Management Group. The main responsibility of the Group was to oversee the preparation of the Management Plan. Following publication of the Plan, English Heritage established the Stonehenge World Heritage Site Management Plan Implementation Group (now known as the Stonehenge World Heritage Site Management Plan Committee) to oversee implementation of the Plan
- The Group has identified various management issues affecting the WHS, particularly agricultural land use, military land use and woodland and forestry management. Individual issues identified by the Group include traffic impact upon the WHS and visitor management.
- Impact of Traffic and Roads
- Roads and road traffic have long had a serious impact on the WHS. In particular, the A303 Trunk Road and the A344 County Road are highly visible routes that cut through the heart of the WHS and adversely impact on the character of the immediate settings and people’s enjoyment of the Stones themselves.
- Use of the roads by substantial volumes of traffic causes considerable noise pollution across the WHS, detracting from its historic landscape and monuments.
- Visitor Management
- The rapid growth in visitor numbers in recent years has highlighted the inadequacy of existing visitor facilities and infrastructure at Stonehenge. The current location of the visitor centre, adjacent to the Stones and in a highly sensitive area in archaeological and visual terms, has limited the ability to expand and develop new facilities in line with the growth in visitor numbers. Overall, the existing facilities do not do justice to this internationally significant cultural site.
- There is a clear and widely acknowledged need for the removal of the existing visitor facilities near the Stones and for the development of an improved visitor centre for the whole WHS.
- Objectives of the Plan
- Vision of the Future
- The WHS Management Plan envisages a landscape which includes an extended core zone of permanent grassland surrounded by a wider landscape of sustainable low-intensity mixed farming.
- In the long term all farm land in the core zone would be restored to permanent grassland and all appropriate structures and roads removed or screened to provide an improved landscaping setting for the Stones, the protection of the archaeology from ploughing, and an area carefully managed for open access on foot for visitors. The zone would be primarily managed for both archaeological, landscape and nature conservation, and for the access and enjoyment of the very large number of visitors who it is anticipated will continue to concentrate, at least initially in the core zone.
- With a new high quality visitor centre outside the boundary of the WHS as a starting point, visitors would gain access to the Stones and the heart of the WHS via primary access links and drop-off points beyond the rim of the core area. Pedestrian access beyond the core to the wider, more tranquil, and more fully presented and interpreted landscape and archaeological sites of the southern WHS would be possible using the existing public rights of way network, and new links and pedestrian gateways and routes to currently inaccessible sites and areas. Researching and improving understanding of the WHS, and the development of its enjoyment and educational value for future generations, would be fundamental concepts for guiding the long term management of the Site.
- Working, but more environmentally sustainable, mixed farming in the wider landscape of the WHS would continue as the principal land use, and this would provide the landscape setting to the core zone. Outside the core, the improved conservation and management of improved archaeological monuments and ecological features would be balanced with the practical needs of modern arable or mixed farming, and military activities.
- Objectives of the Plan
- The Plan sets out certain objectives for the management of the WHS.
- The objectives include several overall long-term objectives, certain statutory and policy objectives and a number of policies aimed at landscape, nature and heritage conservation.
- The Plan addresses a number of specific issues identified in the Plan. As regards the acknowledged impact of roads and road traffic, Objective 23 of the Plan states:
- Implementing the Plan
- General Mechanisms and Programme
- The Stonehenge WHS Management Plan Committee is assisted in relation to implementation of Plan objectives by a locally based WHS Co-ordinator, supported by administrative staff. The Co-ordinator is employed by English Heritage with funding also from the National Trust, Salisbury District Council and Amesbury Town Council. An Advisory Forum, including all the organisations involved in the drafting of the Plan meets at least annually.
- The Management Plan Committee has formulated a programme for securing the objectives of the Plan. The responsibility for achieving these objectives falls to individual organisations (either singly or in the groups).
- Sustainable Traffic and Transportation Objectives
- The Plan identifies, in relation to Objective 23, measures that will provide comprehensive treatment of important road links within the WHS in order to reduce traffic movements and congestion, improve safety and enhance the historic environment. Such measures include, amongst others, the implementation of a scheme for the duelling of the A303 in a tunnel of appropriate length and the closure of the A344, and the relocation of the existing visitor centre to outside the boundary of the WHS.
- The first of these measures is being addressed through the Highway Orders referred to at 4.3 below. The latter measure is being actively addressed by English Heritage including in the context of Objective 18 of the Plan which states:
- In line with Objective 18, English Heritage is proposing the provision of a new visitor centre which will be located on land acquired for the purpose by English Heritage to the north east of the Countess Roundabout at the junction of the A303 and A345.
- English Heritage intends that a planning application for the new centre development will be submitted to Salisbury District Council as local planning authority by January 2004. The proposed development has been the subject of extensive discussions with the Council and other relevant bodies.
- A303 Stonehenge Improvement Scheme
- Evolution of the Scheme
- Consultation
- Plans to upgrade the A303 adjacent to Stonehenge (with related proposals for improving visitor facilities) have been proposed for many decades. English Heritage has been closely involved in the consideration of these proposals since its creation in 1984.
- In particular, English Heritage attended the Planning Conference in Salisbury in 1995 at which various options were considered in public forum. Following publication of the results of the Planning Conference, and a further round of consultation, a new "exceptional environmental scheme" for Stonehenge was announced in 1998 (in the Government’s plans to improve the strategic road network "A New Deal For Trunk Roads in England"). This proposed a northern bypass for Winterbourne Stoke and the inclusion of a 2km cut-and-cover tunnel adjacent to Stonehenge. This proposal was supported by English Heritage and the National Trust and included a financial contribution to the overall costs of the scheme from the DCMS with the bulk of funding coming from the DfT. The Government announced this scheme as the "Preferred Route" for the Stonehenge improvement in June 1999.
- Tunnel Options
- Following a review of tunnel options by the Highways Agency in 2002, English Heritage the National Trust and other parties were consulted about alternative schemes with tunnel lengths ranging from 2km to 4.5km, together with differing methods for construction – cut-and-cover, bored and combinations of both.
- English Heritage, through its Advisory Committee and Commissioners, considered these options in September 2002. The EH Commissioners resolved that the cut-and-cover method of construction was unacceptable, but that any of the proposed bored tunnels (2.1km, 2.67km and 4.1km) would meet the objectives of the Stonehenge WHS Management Plan to remove the roads from, and reunite, the landscape of the core area of the WHS. These views were conveyed to the Secretary of State for Transport and the Secretary of State for Culture, Media and Sport. The Secretaries of State subsequently announced the intention to proceed in relation to a scheme with a bored tunnel 2.1km in length.
- The UNESCO World Heritage Committee has subsequently welcomed the adoption of a bored tunnel.
- The Scheme
- Environmental Statement
- In designing the current scheme and preparing the comprehensive Environmental Statement accompanying the scheme the Highways Agency has continued to consult with relevant parties including English Heritage, English Nature, the Environment Agency, the Countryside Agency, and the National Trust.
- Consequently, these organisations were involved with the scoping of base line data, specifications for specific surveys and validation of results, including suggested mitigation measures. For the historic environment the number and extent of the investigations undertaken have gone beyond that normally associated with trunk road schemes, principally due to the exceptional nature of the area through which the published scheme passes and the number of route options that have been considered. The relevant knowledge required for an area of such archaeological, cultural, social sensitivity demands a deeper and more extensive pre-scheme investigation than any other project in the UK to date. So as to ensure that a consistent approach is taken throughout the entire length of the scheme, the same level of survey has been conducted throughout, and the degree of sensitivity necessitated by the WHS status of part of the route has therefore been extended to other parts of the scheme.
- Historic Environment Assessment
- In relation to assessment of the historic environment the Highways Agency set up an archaeology group which brought together representatives of English Heritage, the National Trust and Wiltshire County Council, together with members of the Highways Agency team developing the scheme. Through the regular meetings of this group it has been possible to have an oversight of the results of the surveys and to suggest modifications to the scheme where impacts were identified. The group has also had an oversight of the conduct of the various surveys, from their inception through to the reporting stage.
- The assessments undertaken for the Environmental Statement have been predicated upon two study areas that are directly drawn from the two types of impact that the published scheme could have. First and foremost is direct impact which can only occur within the road corridor or "trace". The trace comprises the area of permanent and temporary land take needed for the published scheme and includes road works, landscaping areas, drainage treatment areas and temporary haul routes, construction and storage compounds. The second study area is the outer study area which defines an area where there may be impacts upon the "setting" of archaeological or historic remains.
- The assessment of the historic environment has followed a three-step approach to determine the significance of the effects of the published scheme. These are:
- Step 1 – evaluation of importance of resource
- Step 2 – assessment of magnitude of impact of the published scheme on resources
- Step 3 – determination of significance of effect
- For the methodology outlined above to be successful it was necessary to have an agreed baseline data on which the assessment would be based. Stonehenge and its surrounding area have been extensively studied for several centuries and therefore there was a large corpus of data to which the environmental statement could add. An initial appraisal of the state of historic environmental knowledge and understanding for the proposed scheme was undertaken at the start of the Environmental Statement process in 2001. Combining this with the evolving scheme detail, it was possible to define the surveys needed to enable the creation of the comprehensive baseline data.
- At an early stage an agreement was reached with the Highways Agency and other relevant bodies, including the National Trust and Wiltshire County Council on a set of "archaeological principles" which would guide any work commissioned as a result of the published scheme. Subsequently these scheme-specific principles were ratified by the Stonehenge WHS Management Plan Committee and have become applicable to all work undertaken in the WHS (including that generated by the visitor centre proposals).
- Because of the level of involvement that the Highways Agency has sought from English Heritage since the publication of the draft orders, English Heritage has a high degree of confidence in the compilation of the baseline data, conduct and results of surveys and overall assessment of the impacts upon the historic environment and the way in which the results are reported in the Environmental Statement.
- Assessment of the scheme reveals some adverse impacts upon the historic environment, but these are more than balanced by the major benefits that the scheme brings – in particular at Stonehenge and the monuments within the core area (and the Winterbourne Stoke Conservation Area). Discussions with the Highways Agency over certain aspects of the scheme are still ongoing, including some detailed improvements that should see the assessed impacts reduced.
- English Heritage believes that overall the scheme meets the concerns of the World Heritage Committee
- Highway Orders
- Compulsory Purchase Order
- Tunnel Portal Design
- Cut Slopes and Fence Design
- Drainage Treatment Areas
- Lighting and Signage
- Side Roads Order
- Traffic Regulation Order
- Alternative schemes/proposals
- English Heritage wishes to reserve its position to comment upon any alternative road schemes or proposals which may be put forward at the public inquiry.
- Summary
- The proposed scheme recognises the significance of Stonehenge. It delivers significant benefits and improvements, particularly in terms of the setting of Stonehenge and the monuments within the core area. Consequently, the scheme meets international concerns and complies with relevant national and local planning policies aimed at conservation of the WHS. Importantly, the scheme fulfils the key objective of the WHS Management Plan in removing roads from the vicinity of Stonehenge.
- Consequently, English Heritage’s position is one of general support for the scheme being promoted subject to objections in respect of the matters set out in this statement. .
"Measures should be identified which will provide comprehensive treatment of important road links within the WHS in order to reduce traffic movements and congestion, improve safety and enhance the historic environment".
"A new world class visitor centre should be secured to act as a gateway to Stonehenge, to improve the visitor experience and to encourage the dispersal of visitors around the whole WHS."
English Heritage objects to some aspects of the scheme which underlies this order:
Both tunnel portals currently include provision for an anti-recirculation "splitter wall" projecting between the entrances to the tunnel bores. English Heritage has raised objections to this wall on design grounds. In particular, the wall would add to the general clutter of barriers and signage which are unwelcome in the WHS. The Highways Agency has since undertaken a detailed computer and fluid modelling to establish the need for the wall. English Heritage understands that the Highways Agency now accepts that the wall is not needed.
The Highways Agency has suggested a design of cut slopes which has a fairly relaxed side slope with an angle of less than 43 degrees. It also includes a notch where the original surface meets the cutting that is used to hide a stock fence from view. This design would be applied to all of the cutting slopes throughout the scheme including those running down into the portals. English Heritage has raised objections to these proposals on the basis that they run the risk of affecting more archaeology than is warranted. The Highways Agency is currently preparing a report on a variety of different cutting slope designs, including the amounts of land required.
The scheme makes provision to ensure that any liquid run off from the road is treated before it is allowed into the watercourses or acquifer. These treatment areas rely on natural rather than mechanical or chemical treatments to ensure that the run off meets the appropriate water quality standards. These treatment areas are at nine separate locations along the length of the scheme. English Heritage has raised serious concerns about the location of areas five and six given their proximity to the scheduled iron age hillfort of Vespasian’s Camp and the listed buildings on West Amesbury Farm respectively. In addition, recent archaeological evaluation of area six has revealed the presence of important Mesolithic deposits along the line of a relict river terrace. Discussions with the Highways Agency are underway to attempt to reduce or remove these impacts.
Considerable care has been taken in developing the scheme to ensure that the impacts from road lighting and signage are removed or kept to an absolute minimum. It has been agreed that there would be no overhead gantry type signs used on the road within the Stonehenge WHS. It had also been agreed that the road itself would not be lit, including the tunnel portals and extensive use would be made of reflective signs to remove the need for them to be lit. All tunnel lighting and lane control signage would be housed within the tunnel bores themselves. However, at a late stage in the process considerable amounts of lighting and signage have been introduced at Longbarrow Crossroads, in particular to the northern mini-roundabout close to the long barrow. English Heritage strongly objects to this on the basis of light pollution and visual amenity.
English Heritage supports the proposal in this order for the conversion of the A344 from Byway 12 to the current A303 in Stonehenge Bottom to a footpath as this is consistent with the objectives of the Stonehenge WHS Management Plan. However, English Heritage have sought an assurance that this proposal would not be implemented (at least from Byway 12 as far as the entrance to the existing visitor centre) unless and until the proposed new visitor centre is available. This is to ensure continuity in the availability of vehicular access to visitor centre facilities for Stonehenge.
English Heritage has objected to the Stonehenge Byway (Prohibition of Motor Vehicles) Order as regards detailed provisions in the draft. Certain detailed amendments to the order have been proposed which seek to ensure restriction in vehicular use of the proposed byway in line with Objective 23 of the Stonehenge WHS Management Plan.