UK Rivers Network: Objection to Draft Orders, 27 June 2003

27 June 2003.

The Secretary of State for Transport
Stonehenge Team
Highways Agency
Zone 2-05/K
Temple Quay House
2 The Square
Temple Quay
BRISTOL
BS1 6HA

Your reference: HA/65/44/23

Dear Sir,

A303 Stonehenge Improvement: Draft Orders

I am writing to object to the draft orders for the A303 Stonehenge "Improvement" on behalf of the UK Rivers Network.

Our outline grounds for objection are:

Damage to surface and ground waters: The proposed scheme would have a major adverse effect on the Rivers Till and Avon, the River Avon cSAC, and the chalk aquifer and is not consistent with the British government�s obligations under the EU Habitats Directive. We do not accept that the proposed mitigation strategies would reduce the impact sufficiently.
Economic case not made: According to the EU Habitats Directive, a scheme of this kind can proceed to damage a cSAC only for reasons of overriding economic importance. The Highways Agency has not yet supplied a full cost-benefit analysis (COBA) for the scheme or given us an opportunity to examine the proposed economic case. In 1998, a report by Halcrow described this scheme as being of "marginal economic benefit" when the estimated cost was around £125 million (compared to the current estimated cost of £192 million).
Alternatives not properly considered: According to the EU Habitats Directive, a scheme of this kind can proceed to damage a cSAC only when other alternatives have been exhausted. We feel a number of other alternatives have not even been explored.
Environmental statement not sufficient or invalid: It is our view that, as the British government and its various departments have always promoted the Stonehenge Project as a single scheme in its own right, the Environmental Statement should consider the interrelated environmental impacts of both the A303 road scheme and the proposed visitors� centre at Countess East. It does not matter that they are being advanced by different government departments or through different statutory processes. We believe this view to be consistent with the EU EIA directive (97/11/EEC). We also believe that there are numerous factual errors and deliberate distortions in the Non-Technical Summary that amount to a deliberate attempt to mislead. For this reason, we believe the Non-Technical Summary is not an accurate summary of the Environmental Statement.

These are our principal grounds for objection. We also have concerns about:

Cultural heritage
Landscape impacts
Biodiversity impacts
Noise
Impacts on local communities
Knock-on transport effects elsewhere in the South West region.

We would expect these issues to be covered by other objectors and objections, but we reserve the right to add detailed additional objections on these grounds if we feel that other objectors do not adequately cover them.

We request you to hold a public inquiry at which we can supply more details of these objections.

Yours faithfully,

UK Rivers Network.