Inaccuracies and misleading statements
This short paper from the Stonehenge Alliance is in response to the proposed Kenyan amendment (22.07.2024) to the draft decision (46.COM 7B.18) on Stonehenge. [Link here, and pasted below for ease of reference]
It brings delegates’ attention to the inaccuracies and misleading statements made within the proposed amendment, as follows:
Para 5. “… the design can be refined following the granting of the DCO” – substantial modifications are ruled out in the DCO process. Therefore, any modifications would be superficial and cosmetic.
Para 6. This is untrue. The ‘corrective measures’ included in the State Party’s State of Conservation Report 2024 do not modify the Scheme to reflect the Committee’s decisions. Adverse impacts will be considerable: the UK’s Planning Inspectors who recommended the scheme be refused, said it would cause ‘permanent and irreversible’ harm to the WHS. It would cause the loss without record of c. 360,000 artefacts, along with the destruction of c. 1,300 buried natural features, many of which are likely to contain further artefacts and other remains.
Para 7. “… the State Party has considered over 50 different options for the Scheme” – the majority of these ‘options’ were only superficially examined and dismissed without a full assessment. Even the main viable alternatives have not been subject to proper scrutiny.
“…has the support of the national heritage agency and major heritage NGOs” – There is only one ‘major heritage NGO’ supporting the scheme and it has a financial interest in seeing it built. Most NGOs, such as the Council for British Archaeology, Prehistoric Society, CPRE, RESCUE, etc. oppose the scheme, as do the Consortium of Stonehenge Experts, a group of 22 senior scholars who have carried out internationally recognised research within Stonehenge WHS.
Para 8. “… which constitute a set of corrective measures to modify the Scheme” – see comments above, these modifications will do little to prevent permanent harm to the landscape at the western end, nor prevent an enormous loss of artefacts. They do not meet UNESCO’s requested changes.
Para 9. “…but recognises that the proposed design developments offer enhanced mitigation of the impacts on the integrity of the property.” – This is untrue. The design modifications do little to prevent permanent harm to the WHS. The struck-out text needs to be reinstated.
Para 11. “… an extension of the tunnel in cut-and-cover would not minimise ‘the extent of archaeological resources which must be removed” – This is a distraction, as this is not the case for a bored tunnel, nor is it the case for the cheaper surface route around the WHS. Both less damaging options than the current proposal.
Para 12 – the deletions effectively undermine all previous Mission reports and Committee decisions and should be reinstated.
Para 13. “Also notes that the proposed Scheme would have a significant positive impact on the OUV of the property, as acknowledged by the 2022 Advisory Mission…” – This is untrue. The Mission spoke of a positive impact on OUV in relation to the complete removal of the road, not the scheme.
Para 14. “recognises that the proposed design developments offer enhanced mitigation of the impacts on the integrity of the property…” – This is untrue. The changes are superficial.
Para 15. “Notes that the Scheme, with the proposed design developments, provides the most feasible solution for the State Party to the impact of the A303 on the integrity of the property” – This is untrue. At least one cheaper option is available, as is a longer bored tunnel.
We urge you to vote down this amendment and inscribe Stonehenge on the List of World Heritage in Danger.
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