Friends of the Earth: Objection to Draft Orders, 4 September 2003

Stonehenge Project Team
Highways Agency
Zone 2-05/K
Temple Quay House
2 The Square
Temple Quay
BRISTOL BS1 6HA
 

4 September 2003
 
 
 

Dear Sirs

A303 Trunk Road (Stonehenge) Order 200

and related slip roads, side roads and detrunking orders.

Friends of the Earth objects to the draft A303 (Stonehenge) order 200 on the following grounds:

The A303 dualling and 2.1 km tunnel is an unacceptable and unwarranted intrusion on a World Heritage Site that is described as "England's most important' (National Trust press release 05/06/03), and the "most sensitive archaeological site in Europe' (ICOMOS Press Release 12/12/03).

We endorse and support the Government position that there should be a strong policy presumption against new or expanded transport infrastructure that significantly damages designated sites and areas.

There can be no doubt that Stonehenge qualifies as such as site.

Nor can there be any doubt that that proposed scheme would entail significant damage. For about 2.4 km the A303 trunk road would be above ground, within and bisecting the World Heritage Site. This would be widened to two lane dual carriageway throughout, and with its associated deep cuttings and slip roads the published scheme could not be realised without very significant and effectively permanent damage to the WHS landscape. It could well be the largest single visible human intervention in the WHS throughout the millennia of its existence.

The scheme is reported as having heritage benefits because the A303 trunk road is removed from sight and sound of Stonehenge itself, but the World Heritage Site is the landscape as a whole, which has been described as "one of the most spectacular ritual and ceremonial, cultural landscapes in Europe where the spaces in between the monuments are as important as the monuments themselves" (ICOMOS Press Release 12/12/03).

We note that according to the Environmental Statement (paragraph 1.2.5) "such a scheme would be too expensive to warrant priority if assessed solely in terms of transport benefits". Whether or not it should go ahead therefore depends on whether or not the purported additional ("heritage") benefits are as significant as claimed for them by the Government, or, indeed, if they are benefits at all.

Only closure of A344 was identified as necessary when the Stonehenge landscape was inscribed onto the WHS list in 1986. Tunnelling the A303, still less expanding its capacity to two land dual carriageway, does not therefore appear to be necessary on heritage grounds

The presumption against transport infrastructure that damages designated sites also has a bearing on the Winterbourne Stoke bypass, which includes a crossing of the River Till, part of the River Avon candidate Special Area of Conservation.

Significant damage to the cSAC would contravene not only the Government policy presumption cited above, but also the EU "habitats" directive 92/43, which stipulates that such damage should not occur unless there is overriding public interest and no alternative.

Therefore we also lodge an objection to the Winterbourne Stoke bypass element of the scheme and believe it should not proceed unless it can be convincingly demonstrated that no significant damage to the cSAC would ensue.

Transport Issues

Our objection is also on the grounds that the supposed transport benefits may prove to be overstated or negated by unintended (but not unforeseeable) consequences elsewhere. A traffic impact report is not yet available so it is not possible at this stage to state in detail the main areas of concern. The scheme is however likely to lead to very substantial increases in local traffic (particularly in conjunction with the proposed new visitor centre, which this scheme unlocks), and a transfer of traffic onto the M3/A303 corridor.

Comparable expenditure on other transport measures has the potential to deliver much larger benefits without the additional consequence of fuelling traffic growth on both the local and regional scale.

According the the Environmental Statement, "Sustainable traffic and transportation objectives are a key issue for the Management Plan, and Objective 23 states that: "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". The published scheme certainly fails either to reduce traffic or, as argued above, to enhance the historic environment overall.

We request that a full public inquiry is called into the scheme which will allow alternative options to be examined in detail as well as the published scheme. Please keep us informed of the progress of the scheme.
 
 

Yours faithfully
 

Mike Birkin

Regional Campaigns Coordinator (South West)