Salisbury Transport 2000: Objection to Draft Orders, 18 August 2003
Dear Sir,
A303 Trunk Road (Stonehenge Improvement) Order 200 & related slip roads, side roads and detrunking orders
Salisbury Transport 2000 wish to object to the draft A303 Trunk Road (Stonehenge Improvement) Order 200 on the following grounds:
1. Scheme appraisal
1.1 Objectives of the scheme
There are two distinct aspects to this scheme, the transport objective, and the heritage objective, which briefly seem to be defined as follows:
The heritage objective: "removal of busy roads and other 20th century clutter from sight of Stonehenge" [Non-Technical Summary of ES].
Turning to transport objectives, it seems that the scheme has not been properly justified on transport grounds. We suggest that, given the large amount of public money which it is proposed to spend on this road scheme, it needs to be judged against criteria for environment, safety, economy, accessibility and integration in the same way as other road schemes.
1.2 Methodology Used to Appraise the Scheme
It is stated that an objective of the scheme is "to provide a solution to the current congestion and safety problems on this section of the A303 which is fully in accordance with Government and County transport policy" [ES, 16.16.2]
However, government policy states that road schemes should be appraised in the light of both the guidance on Environmental Statements given in the Design Manual for Roads and Bridges, Vol 11, and a Cost benefit Analysis (COBA) and Transport Users Benefit Appraisal (TUBA). The methodology provided in the Bridging document is supposed to be used for? all Highways Agency capital improvement projects in England [DETR, Applying the Multi-Modal New Approach to Appraisal to Highway Schemes, March 2001, para 1.3.1]. This methodology does not seem to have been followed, as there is no reference to the Bridging Document, no COBA and no Appraisal Summary Table (AST) supplied.
We note that the Environmental Statement Scoping Report, dated January 2002, stated that the approach set out in the Bridging Document would be considered "as appropriate", and that "an Appraisal Summary Table, under GOMMMS, will be prepared separately to the ES". [Highways Agency, A303 Stonehenge Scoping Report, January 2002, para 6.4]. There is an implication here that the latest government guidance as set out in the Bridging Document will be followed only when it suits the purposes of the Scheme promoters, something which is confirmed by the absence of both AST and COBA, and we believe this is entirely wrong for a scheme of this size and importance.
Salisbury Transport 2000 believe that the AST and COBA should have been prepared concurrently with the Environmental Statement to allow for full public consultation and review. Also, that the philosophy embodied in the Bridging Document, namely that "a key requirement of the new approach to appraisal is the need to consider a wide range of alternatives, aimed at solving the problem, rather than merely mitigating the symptoms of the problem" [DETR, Applying the Multi-Modal New Approach to Appraisal to Highway Schemes, March 2001, para 3.2.4] should have been followed.
1.3 SWARMMS recommendations
The SWARMMS study never appraised the need for the Stonehenge/Winterbourne Stoke scheme, and the statement that "the upgrading proposed via the Published Scheme is consistent" with the SWARMMS conclusions that the A303 should be dualled at least to Ilminster [ES 2.3.1.4] is misleading since it is acknowledged that SWARMMS accepted dualling of the A303 at Stonehenge as a given [ES 16.4.2.10]. The assumption of this capacity increase at Stonehenge was used as a justification by SWARMMS for capacity increases further westwards on the corridor. SWARMMS did not therefore give proper consideration to improvements to this corridor which do not require road dualling schemes. Despite government policy to promote a modal shift from roads, it is noteworthy that SWARMMS seemed to work on the assumption that a modal shift from the car could not be achieved, and produced a package which guaranteed that the SW region would be developed in a car-dependent and unsustainable manner. Thus capacity improvements on the Salisbury-Exeter line were deferred until 2011-2016, while A303 dualling, boosted by the assumption of capacity increases at Stonehenge, was scheduled before 2011.
2. Consideration of Alternatives
It is clear from Chapter 17 that only dual-carriageway road schemes have been considered among the alternatives considered since 1991. In view of the environmental and economic cost of such schemes it seems inexplicable why other alternatives have not been properly considered and costed. We suggest briefly some of these alternatives below.
2.1 Closure of A344
The non-technical summary of the environmental statement indicates that the "Removal of busy roads and other 20th century clutter from sight of Stonehenge has long been a government objective". However it is clear that the commitment made by the UK government to the World Heritage Committee, when Stonehenge was inscribed on the World Heritage List, related only to the closure of the A344 [ref ES 2.1.2.2].
The statement quoted from the 1998 Roads Review suggests that closure of the A344 is conditional upon an improvement scheme for Stonehenge "The Scheme will also open up the possibility of closing that part of the A344 which runs alongside the monument and separates it from its ancient landscape" [ES 16.4.1.11]. However there is no such dependency, as the A344 could be closed, with traffic being rerouted via the A360 and Longbarrow roundabout, without further road infrastructure changes.
2.2 Improvements to Rail Infrastructure and Services
The potential for modal shift on the London-Exeter corridor has never been properly considered (see also comments on SWARMMS in 1.3 above). Any comprehensive assessment of alternative transport resources in this corridor would also have investigated the role of the railway line from Southampton, via Salisbury to Westbury and Bristol and its potential for attracting passenger and freight traffic from the east-west highway corridors provided by the A303 and M4. This requires a recognition that A303 upgrading is designed partly to take traffic off the overheating M4 to Bristol and South Wales and that the M4 is already part of the preferred route specified by the Highways Agency for journeys between Southampton and Bristol. The railway from Southampton to Bristol also has a role to play in a local public transport network serving Stonehenge. In addition, as we outline in 4.1 below, there is scope for the development of rail and light rail services in the immediate vicinity of Stonehenge to cater for visitors arriving by non-car modes.
3. Environmental Impacts
3.1 World Heritage Site
The proposed highway scheme would cause very significant environmental damage to the Stonehenge World Heritage site. While a tunnel would keep the road out of sight in the immediate proximity of Stonehenge itself, there would still be approximately 2.4km of new dual carriageway above ground within the boundaries of the World Heritage Site, together with the tunnel portals and associated earthworks and buildings, and slip roads linked to the roundabouts to both east and west of the World Heritage Site. Both during construction and in operation this scheme would cause significant visual intrusion and noise, light and exhaust pollution within the World Heritage Site. We note that ICOMOS-UK have stated that the short (2.1km) tunnel which forms part of the current scheme "would not allow the reinstatement of key spatial features and associations within the WHS, particularly the Avenue which would remain divided by the road, and the relationship of the Normanton Barrow to the Stones, which in visual as well as access terms would remain compromised".
3.2 Impacts on River Systems
It is acknowledged in the Environmental Statement that construction and operation of the road will have an adverse impact on both the River Till and the River Avon.
The ES notes that there is "no prescriptive methodology available to carry out the necessary assessment" of the impact which the tunnel structures will have on the chalk aquifer. [ES 8.2.1.3]. It is of concern that a significant structure will be inserted beneath the surface whose impact on groundwater, both in terms of flows and displacement, is unknown.
3.3 Cumulative Impacts
This scheme needs to be considered in conjunction with others which will have an impact on traffic and the environment. Specifically the impacts of the proposed Stonehenge Visitor Centre needs to be considered, since this forms another part of the overall �Stonehenge Project� being promoted jointly by English Heritage, the National Trust and the Highways Agency.
Dualling of the A303 at Stonehenge will encourage traffic growth, causing knock-on safety and capacity problems elsewhere both along the A303 route and in neighbouring communities. There will be a cumulative effect on the landscape and ecology of the South West, notably in the heavily protected Blackdown Hills. Transport 2000 share concerns about these impacts with other environmental groups: "So road building is back. The December decisions included widening of the M1 in the east Midlands and the M6 from Birmingham to Manchester, and dualling the A303 to the South-west past Stonehenge. But these schemes have big environmental impacts � the A303 goes through two Areas of Outstanding Natural Beauty � and are catering for projected traffic growth that would undermine the Government�s targets to tackle climate change (the Transport Select Committee estimated that the traffic growth allowed for in just nine of the studies would mean an extra 7.6 million tonnes of carbon by 2016)." (Extract from �Danger! Major Roads ahead? Press Briefing from Transport 2000, Friends of the Earth, the Woodland Trust and the RSPB issued 4/7/2003)
The Avon River system is now threatened by a number of schemes, and, given the level of protection which this system now has as a candidate Special Area of Conservation it is vital that cumulative impacts on this river system are comprehensively assessed.
4. Sustainable travel options to and around Stonehenge
4.1 Green Travel Plan
We would like to see the opportunity taken for a visionary Green Travel Plan for Stonehenge, worthy of this world heritage site, and something which would be a world-class showcase for sustainable tourism in the 21st century.
This Green Travel Plan could encompass a number of possibilities which include, but should not be limited to, the following:
- Improvement of the existing tour bus service from Salisbury railway station.
- The development of dedicated shuttle bus services from reopened railway stations at Wilton and Porton.
- Through- ticketing from London to Stonehenge, well-promoted, could be part of a package of measures to reduce car-dependent trips to Stonehenge, removing traffic from the A303.
- Dedicated cycleways/footpath networks enabling visitors to reach the site from a variety of locations, such non-car routes to be promoted as part of the 'Stonehenge experience' and to be rewarded by discounts on entry tickets or incentivised by stiff parking charges.
- Development of a light railway scheme, using existing and new railway tracks, and new stretches of on-road track. This could run from Salisbury and serve Newton Tony, Amesbury, Bulford, Durrington, Larkhill and Stonehenge, and with new stations on the existing railway at Idmiston, Porton, Gomeldon, the Winterbournes and Bishopdown.
4.2 Cycling
Wiltshire County Council aim to increase cycling trips by 25% by 2005 and 60% by 2010 (Wiltshire County Council 2003 Annual Progress Report, target C6). However, the draft orders contain some negative features from the point of view of cyclists:
- We note that it is planned to convert the A344 to a footway and to exclude cyclists from this road. This needs to be reconsidered, as this is an important link for cyclists travelling to/from Shrewton and Salisbury Plain, and the proposed alternative route (via the old A303 and Byway A12) is longer which will be a disbenefit to cyclists.
- It has not so far been possible to obtain from English Heritage any details of what facilities for walkers and cyclists might be available within the World Heritage Site, and whether there will be bicycle parking facilities and toilets at the site of the current (sunken) visitor facilities off the A344. It seems crucial that this point is established and tied in with appropriate access facilities for walkers and cyclists. The exclusion of cyclists from the A344 needs to be considered in the light of this point.
- There is no indication of surface quality and treatment on the new restricted byways (e.g. the former A303 alignment). Surfacing needs to be suitable for all cyclists in all weathers, and the opportunity should be taken to make a proper commutable cycle route from Winterbourne Stoke to Amesbury.
5. Conclusions
We believe that the proposed highway contravenes a number of important policies and plans, including the Stonehenge World Heritage Site Management Plan. We request that you ensure that a full public inquiry is held into the Stonehenge scheme to allow objections to be discussed and alternatives to be explored in detail. Please keep us informed about the progress of the scheme.
Yours faithfully
Margaret Willmot
For Salisbury Transport 2000