Dr Karl Brazier's Objection to the Draft Orders, 26 August 2003

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

Dear Sir or Madam

This is by way of objection to the A303 Stonehenge Improvement Draft Orders, a nomenclature that is in itself objectionable, value-laden as it is, but which, as such, at least does us the favour of alerting us to the bias in the outlook of those presenting it. While there are potentially many points of detail on which objections might be raised, the key reason for my objection at this point is on the fundamental grounds of the inadequacy of the consultation process so far, particularly the limited availability of the Draft Orders and Environmental Statement for the perusal that would be required to permit objection to details.

The area in question is a World Heritage Site and the proposals hence require a level of scrutiny that goes beyond the parochiality of the arrangements up to this point. My understanding from my reading of the "Explanation of the Scheme and Non-Technical Summary of the Environmental Statement" published by the Highways Agency is that the lowest price for which a copy of the Environmental Statement may be obtained is £20 for the CD version. This sum, while not exorbitant for many of us represents a substantial obstacle for the unwaged and should anyone be unable to afford the computer facilities required to read the CD version, the cost is potentially much higher, either to obtain a hard copy or to travel to a location at which the statement is on public display. Even the cost of the CD version is sufficient that for many it could reasonably be expected to represent the choice between being informed of the reasoning put forward with respect to environmental concerns and a week�s food. It is not reasonable to expect potential objectors to make the choice between obtaining adequate information to determine whether they have reason to object and having enough to eat. This conflict would not arise for those living close to a public display location, however the range of locations falls far short of what is warranted to fill this information gap where a World Heritage Site is concerned. It is a clear implication of the designation World Heritage Site that it is of importance on a world scale and yet the consultation so far does not extend even to a national level, restricted as it is by cost, as outlined above, to those in proximity to the public display locations.

Similarly the opportunity for perusal of the Draft Orders appears to have been even more restricted, extending only to the locality of Amesbury on a certain highly limited range of dates. If this appearance is misleading then it is clear that other opportunities have not been sufficiently well publicised. While I presume that the consultation process so far has been sufficient to satisfy the requirements of the British law, this serves only to indicate that those requirements are insufficient for a site of recognised world importance. This is unsurprising as they were probably not laid down with a site of this significance in mind.

The issue raised earlier of the cost of obtaining information is a particularly important one with respect to this site as the recent history of the site strongly suggests that many potential objectors may be people of severely limited resources. Furthermore, the site�s recent history is, sadly, such as to generate widespread suspicion regarding the motives behind any proposals affecting it, road scheme or otherwise. Anecdotally, on describing the range of routes considered and rejected for the scheme to a far from militant relative the response I received was "Do you think maybe they�re just being bloody-minded?" If this was the response of a moderate thinker with little interest in the site, what may we imagine would be the response of those (and there are many) who care deeply about it and have, owing to the English Heritage�s appalling stewardship of the monument, developed a mistrust of proposals for the site�s development. I am afraid that merely fulfilling the letter of the law instead of consulting as widely as possible could end in unpleasant confrontation. In particular, I would expect limitations on the availability of information, real or perceived, to contribute substantially to resentments that might lead to this.

A vital step towards satisfying all concerned that plans had been exposed to the proper scrutiny would be to hold a Public Inquiry. While this alone might not entirely overcome the parochiality associated with the process, needing, presumably, to be based in the region of the country in which the site lies, it would at least put the matter on a footing that the British public recognises as a proper and open consultation and one that is more appropriate to a site important enough to carry the World Heritage designation. As such it is as much in the interests of the advocates of the scheme that a Public Inquiry be held as it is in the interests of objectors. Imagine how the public would feel if they found themselves in a position to say, "This scheme is going ahead, affecting a World Heritage Site, and they wouldn�t even hold a Public Inquiry." And imagine how that would affect their perception of the developers, the Highways Agency, the planning authorities and the relationships between them.

Apart from the above-outlined issues with the consultation process, I object to the scheme on the grounds that it is contrary to the requirements of a sustainable environment and transport infrastructure. It has now been recognised for some time that this demands a reduction in usage of motor vehicles and that the provision of increased road capacity leads to increased usage of motor vehicles. Some of the adverse environmental results will accrue to the locality of the usage, and hence to the Stonehenge World Heritage Site, others to localities to which the roads in question are connected and still others on the national and global level. Modern thinking is that sustainability demands reduced usage of motor vehicles and the only proposals that should be seriously considered are ones that reduce road capacity.

In addition, I wish to add my voice to the particular objections raised by the Save Stonehenge campaign. These are:

* The proposed highway scheme would cause considerable environmental damage to the Stonehenge World Heritage Site and the archaeologically and environmentally important surrounding area. According to the Stonehenge Management Plan, prepared for UNESCO: "The Stonehenge World Heritage Site is internationally recognized as an outstanding archaeological landscape. Inscription on the World Heritage List places Stonehenge, with Avebury and its associated sites, beside other World Heritage Sites of outstanding universal value such as the Pyramids in Egypt, the Taj Mahal in India and the Great Wall of China." People would not accept building a new four-lane highway through the middle of the Pyramids, the Taj Mahal, or the Great Wall of China; we will not accept this at Stonehenge either.

* The proposed highway would have negative impacts on the internationally important rivers Till and Avon, noise impacts on Stonehenge and local communities, and a number of other adverse environmental impacts that the Highways Agency's plans do not properly consider or address.

* The proposed highway would be over twice as wide as the existing one. This would encourage traffic growth, causing knock-on safety problems elsewhere along the A303 route and in neighbouring communities.

* The proposed highway contravenes a number of important policies and plans, most notably the Stonehenge World Heritage Site Management Plan, but also planning policy guidance notes.

* A variety of alternative plans for Stonehenge have not been explored, publicized, or costed out. There is reason to believe that it is contrary to European environmental law to pursue the current highway scheme before other alternatives have been properly considered.

Please hold a Public Inquiry. I thank you for your attention and hope that you will find my contribution of value.

Yours faithfully
 

Dr. Karl J. Brazier