The Stonehenge Alliance representation as submitted on 10 January 2019:

The Stonehenge Alliance is a group of five national NGOs: Ancient Sacred Landscape Network, Campaign for Better Transport, Campaign to Protect Rural England, Friends of the Earth and Rescue: The British Archaeological Trust.

1. We submit that any approval of the A303 Stonehenge scheme would breach/be contrary to the following:
• The Planning Act 2008
• The World Heritage Convention and advice given by the UNESCO’s World Heritage Committee and international specialists
• Relevant national planning policy and guidance
• Local Plan policy for the World Heritage Site (WHS)
• The WHS Management Plan
• The Environmental Impact Assessment Directive (85/337/EEC)
• The Habitats Directive (Council Directive 92/43/EEC) and The Conservation of Habitats and Species Regulations 2017 (Habitats Regulations) in respect of the Salisbury Plain SPA and River Avon SAC
• The Bern Convention on the Conservation of European Wildlife and Habitats
• The Birds Directive (2009/147/EC) in respect of Annex I species
• The Aarhus Convention, in respect of genuine public participation in environmental decision-making
• The European Convention on the protection of the Archaeological Heritage
• The European Landscape Convention
• The SEA Directive (European Directive 2001/42/EC) and The Environmental Assessment of Plans and Programmes Regulations 2004 (Statutory Instrument 2004, no. 1633) on the environmental impacts of the planned A303/A358 corridor improvements programme alone and in combination

2. In respect of the above, and in addition, we have concerns and/or objections on the following:

• severe and irreversible damage to the WHS, its archaeology, landscape and setting
• loss of archaeological evidence
• threat to World Heritage designation
• insufficient understanding of the archaeological landscape and its potential meaning to those who developed it over time
• insufficient protection of the WHS landscape for future generations to enjoy
• inadequate heritage impact assessment (omits full assessment of impacts on WHS and its OUV)
• loss of the view of Stonehenge from the A303
• insufficient consideration of value and susceptibility of internationally acclaimed landscape to adverse impacts as required under GLVIA3
• significant locations and visitor-receptors ignored in viewpoints considered, e.g., the A303
• LVIA misrepresents landscape and visual effects and omits adequate mention of adverse impacts in summaries
• problems of groundwater flow and contamination resulting from tunnel construction leading to adverse impacts on water quality and the integrity of the SAC
• potential damage in tunnel construction to archaeology and the WHS landscape
• threats to Annex I Stone curlews and Great Bustards from construction and operation of the scheme
• noise and tranquillity
• inadequate consultation, including insufficient data for informed responses
• misleading publicity/advertising in scheme consultation and promotion
• weight of public opinion disregarded in responses to consultation
• inadequate length of time for the planning process including the registration period
• information still lacking on ground characterisation and groundwater data from boreholes and associated geotechnical work carried out for Highways England during 2018.
• information lacking on archaeological evaluation
• need for the scheme is not compelling
• no economic case for the scheme on transport grounds
• weak economic case for the scheme overall
• inadequate range of options assessed
• implausible calculation of monetised heritage benefit
• impacts of tunnel closures
• climate change

Glossary of Acronyms

LVIA Landscape and Visual Impact Assessment

OUV Outstanding Universal Value

SEA Strategic Environment Assessment

WHS World Heritage Site

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