Stonehenge Alliance written representations, responses and rebuttals inserted

IMPORTANT NOTICE: 6 March 2024 – The Planning Inspectorate moved the A303 Stonehenge project documents to a new Beta website here.  Some URLs have changed.  Hyperlinks below are in the process of being updated.  

Planning context

The Stonehenge road scheme was a Nationally Significant Infrastructure Project (NSIP) that required approval by the Secretary of State for Transport.

NSIPs as defined in the 2008 Planning Act apply to large scale developments such as roads (promoted by National Highways), railways, harbours, power stations, transmission lines, oil pipelines, gas storage and others.  These projects are taken through a separate planning application process to obtain a Development Consent Order (DCO) granted by the relevant Secretary of State, in this case, managed by the Department for Transport.   Here is our explainer about NSIPs and the DCO planning process.

2025

• July 14 – Decommissioning of trial boreholes by National Highways who sent the following statement: “Following the government decision to withdraw funding of the A303 ]Stonehenge project in summer 2024 […] as part of the Development Consent Order, we’re required to decommission the boreholes originally put in place to carry out a variety of soil and water table tests.  We’ve now completed the surveys to access the work needed and can begin to conclude this element of the close down. Work began on the 14 May and will be completed by winter 2025. During this time, you may see National Highways and members of our supply chain working in the surrounding area.” 
• May 14 – SSWHS was refused permission to pursue its challenge at the Supreme Court. This was bad news not just for the campaign but for all decision making, where according to the courts a Minister needs nothing more than a passing acquaintance with the facts before approving a development. There are also outstanding concerns as to how World Heritage Sites are treated in the planning system that we were unable to get clarified.
• January 17 –  Our ally, Transport Action Network (TAN), launched their report ‘Connecting South West England: in place of A303/A358 widening’.  We need to recognise that transport networks, particularly public transport, in the South West is in a poor state requiring urgent action.  This was covered by the BBC.  Read more here

2024

• November –  Application to the Supreme Court submitted: Planning permission for the proposed new road and tunnel remained in place and could be resurrected at any time should the politicians change their minds (up to 4 August 2028).  Two key issues at stake are too important to be left hanging i.e.
  • (i) the protection of decision-making of World Heritage Sites remains unresolved, and
  • (ii) the question of the extent of detail that ministers should know to inform their decision-making.  Consultation with donors to the legal challenge agreed that the case should be pursued.  The application is likely to take 3 or 4 months.
• October 16 – The Judgment from the Court of Appeal was handed down this afternoon.  Regrettably the application for permission to apply for judicial review was refused by the High Court.
  • Link to our statement:  “Judgment disappointing, relief at Labour’s scheme cancellation.’
  • Link to the judgment  here.
• July 30 – The Development Consent Order remains in place unless the Court of Appeal quashes the Transport Secretary’s approval.  Judgment expected in the autumn.
• July 29 – Chancellor Rachel Reeves announced cancellation of the £2.5bn A303 Stonehenge scheme [2] as a “low value, unaffordable commitment” [3].
• 29 July 2024 – The Chancellor, Rachel Reeves, cancelled the £2.5bn Stonehenge scheme as a “low value, unaffordable commitment”.  Unless the Court of Appeal quashed the Transport Secretary’s approval the Development Consent Order however, remains in place until 4 August 2028.
• July 24 – The inaccurate amendment from Kenya to overturn the World Heritage Centre’s draft decision to place Stonehenge and Avebury WHS on the List of World Heritage in Danger passed at the World Heritage Committee, effectively overturning all previous Committee decisions despite the letting of the scheme’s contracts.  More here.
• July 21 – UNESCO’s World Heritage Committee starts its 10 day meeting in Delhi to consider whether to place Stonehenge WHS on the List of World Heritage in Danger.  The World Heritage Centre’s draft decision recommending the WHS on the List of World Heritage in Danger is here (see page 10).
• July 17 – Close of Court of Appeal hearing.  Judgment reserved.
• July 15 – International Petition letter handed in to Secretaries of State for Transport and Culture, Media and Sport.  See article.
• May 17 – Save Stonehenge World Heritage Site given Leave to Appeal the decision by Mr Justice Holgate 
• April 2 – A360 south of A303 closed for installation of high voltage and fibre optic cables along the A360 to serve the tunnel ahead of legal processes 
• February 19 – Judge Holgate dismissed the case.  Appeal lodged with the Court of Appeal in March.
• February 1 – UK Government to submit State of Conservation report to World Heritage Centre with further information on scheme modifications.  Unusually, this has been published by UK Government (DCMS) as a summary only.  Full report suppressed.

2023 – Secretary of State’s DCO Approval

• September 10-25 – UNESCO’s World Heritage Committee meeting: agree to place property on List of World Heritage in Danger if road scheme proceeds, and requested State Party to submit further information of proposed modifications and State of Conservation report to the World Heritage Centre by 1 February 2024 for examination by World Heritage Committee
• August 26 – Legal proceedings initiated on Stonehenge road scheme by Save Stonehenge World Heritage Ltd 
• August 4 – The A303 (Amesbury to Berwick Down) Development Consent Order 2023  came into force
• July 14 – Secretary of State approves the A303 Stonehenge DCO for road widening scheme again: Decision taken at the end of the summer parliamentary session, and prior to the World Heritage Committee meeting contrary to UNESCO’s Mission request.
• March 14 – Spring Budget: Following two changes of Government the Secretary of State’s much awaited decision failed to appear in the Chancellor of Exchequer’s Spring Budget and statements on infrastructure.

2022 – Redetermination process

• October 14 – Stonehenge Alliance response to UNESCO’s Advisory Mission
• October 14 – All responses to UNESCO’s Advisory Mission Report
• September 14 – New Transport Secretary letter inviting Interested Parties to provide comments on the Applicant’s response by 28 September 2022.
• August 26 – Transport Secretary letter inviting the Applicant to provide comments on the Advisory Mission’s report by 9 September 2022.  Request that no decision should be made before the WH Committee meet in 2023.
• August 14  – Stonehenge Alliance response together with wider comment on published responses.
• August 25 – The responses to the Secretary of State’s consultation letter of 13 July published together with UNESCO’s Advisory Mission report.
• July 18 – Stonehenge Alliance responses to various deadlines and comment: 10 June /4 April 
• July 13 – Invitation by Transport Secretary to comment on Applicant’s replies to concerns, Deadline 3 August 2022
• July 12 – Submissions by National Highways’ replies to concerns
• June 20 – Transport Secretary issues letter requesting further comments from the Applicant
• June 17 – Responses to consultation to National Highways’ submissions on carbon
• April 29 – Invitation by Transport Secretary to comment on Applicant’s update to  Section 4 on Carbon.  Deadline 10 June 2022.
• April 26 – Stonehenge Alliance specialists’ responses published as a single document. For individual topics see blog.
• April 26 – 1,237 entries published in response to Transport Secretary’s consultation letter of 24 February 2022
• April 4 – Deadline for comment on National Highways’ reapplication and justification.  Members of public (unregistered Interested Parties) have responded, but their comments will only be published at the Transport Secretary’s discretion.
• February 24 – Sec of State’s invitation to Interested Parties to comment on his Statement of Matters and National Highways’ responses by 4th April 2022
• January 23 to February 23 – National Highways responses and further information submitted to Transport Secretary’s Statement of Matters published under Documents dated 23/01/22, 24/01/22 and 23/02/22

2021 – Legal challenge and Quashing of scheme

• November 30 – Secretary of State’s Statement of Matters and invitation to the DCO Applicant to make further representations for the purposes of his re-determination of the scheme
• October 27 – Chancellor’s spending review omits budget for A303 Stonehenge scheme – see media report
• August 10 – Notice that the Transport Secretary will re-determine the DCO Application
• July 30 – Scheme quashed: High Court judge rules against the Secretary of State’s decision to proceed with the scheme: judgment by The Hon. Mr Justice Holgate: Summary | Full

2020 – Examining Authority’s report and SoS’s Decision

• November 12 – Publication of Examining Authority’s Recommendation Report (Submitted to the Transport Secretary on 2 January 2020, published by the Planning Inspectorate at the same time as the Transport Secretary’s decision)
  – Appendices (See page 111, Appendix C for list of abbreviations)
• November 12 – Decision by Transport Secretary (cover letter) and his Decision Letter  (giving reasons for going ahead with scheme)
• September 28 – Department for Transport invitation to key players for comments on responses
• August 13 – Stonehenge Alliance response to consultation on Late Neolithic Pit Structures  and response from Consortium of Archaeologists and the Blick Mead project team
• July 17 – Decision by Transport Secretary (delayed)
• July 16 – SoS requests further information and consults on Late Neolithic Pit Structures
• June 25-26 – Stonehenge Alliance and the Consortium of specialist archaeologists write to Transport Secretary about implications of major new archaeological find in WHS
• May 28 – Stonehenge Alliance to Transport Secretary: response to queries of 4 May 2020 
• May 27-28 – Stonehenge Alliance and Council for British Archaeology comment to SoS on responses from Highways England, Historic England, and Wiltshire Council
• May 18 – all responses published on Infrastructure Planning website
• May 16 – Stonehenge Alliance responds with comments
• May 4 – Transport Secretary asks for comments and information from Highways England, Historic England and Natural England
• April 29 – Transport Secretary announced Decision delayed until 17 July 2020
• April 2 – Expected Decision by Secretary of State for Transport
• March 12 – The Stonehenge Alliance reacts to Chancellor’s budget announcement on 11 March 
• January 2 – Examining Authority’s Report and Recommendation sent to Secretary of State for Transport (not published)

2019 – Examination of draft DCO

• 2019 Stonehenge Alliance submissions:

– Deadline 1 Submission (25 April 2019) – Suggestions for sites to include in itinerary for Accompanied Site Inspection on 21 May 2019

– Deadline 1 Submission (18 April 2019) – Highways England: Response to Stonehenge Alliance concerning missing information

– Deadline 2 Submission (3 May 2019) – Introduction to Case

– Deadline 2 Submission (3 May 2019) – Written Representation on Principal Issue 3 Alternatives Dr. Kate Fielden, BA, D.Phil. and George McDonic, MBE, BL, DIPLTP, DPA, FFB

– Deadline 2 Submission (3 May 2019) – Written Representation on Principal Issue 4 Biodiversity, Biological Environment and Ecology Dr. Kate Fielden, BA, D.Phil., with advice of Tracé Williams, MSc., BSc.

– Deadline 2 Submission (3 May 2019) – Written Representation on Principle Issue 7 Flood Risk groundwater protection Dr George Reeves, CGeol, CEnv, PhD, MSc, BSc (Hons), FGS, FIMMM

– Deadline 2 Submission (3 May 2019) – Written Representation on Principal Issue 9 Heritage and the Historic Environment Dr Kate Fielden, BA., D.Phil.

– Deadline 2 Submission (3 May 2019) – Written Representation on Principal Issue 10 Landscape and Visual Aspects of the LVIA Andy Norfolk, MSc, Dip.L.A

– Deadline 2 Submission(3 May 2019) – Written Representation on Principal Issue 11 Noise and Vibration (Tranquillity) Clive Bentley, BSc (Hons), CEnv, CSci., MCIEH, MIEnvSc. MIOA

– Deadline 2 Submission (3 May 2019) – Written Representation on Principal Issue 11 Vibration from tunnel boring Rupert Thornely-Taylor, FIOA

– Deadline 2 Submission (3 May 2019) – Written Representation on Principal Issue 13 Transport Planning and Economics Issues Dr Simon Temple, BSc, MSc, D.Phil.

– Deadline 2 Submission (3 May 2019)- Written Representation on the Cultural Heritage Value Report Alan James, MA, BSc.

– Deadline 2 Submission (3 May 2019) – Written Representation on Concerns about consultation on the Scheme Dr Kate Fielden, BA, D.Phil.

– Deadline 3 Submission (from 22 May to 14 June) – Open Floor Hearings Tom Holland, Dr Simon Temple & Dr Kate Fielden and Dr Temple, Dr Fielden and Dr George Reeve

– Deadline 3 Submission – Summary of Open Floor Hearing on Climate Change Mike Birkin, Friends of the Earth

– Deadline 4 Submission (21 June) –  Our Summary of Oral Representations made at Specific Hearings and Further comments 

– For later submissions and correspondence with Examiners and Planning Inspectorate by the Alliance, please search ‘Stonehenge Alliance’ on the Planning Inspectorate’s Examination Library site

– 2019 Other mutual objectors:

• Consortium of Archaeologists and the Blick Mead Project Team
• Council for British Archaeology (CBA)
• Wiltshire Archaeological and Natural History Society
• ICOMOS UK
• Avebury Society

– Examination process 

• December 14 – Deadline to register as an Interested Party
• October 2 – Examination closed
• September 25 – Stonehenge Alliance summary of case submitted to the Planning Inspectorate
• May 17 – Stonehenge Alliance to Planning Inspectorate concerning information still missing
• April 17 – Stonehenge Alliance to Planning Inspectorate : concerning Hydrogeological reports, Groundwater Monitoring & Modelling reports
• April 11 – Planning Inspectorate’s Examination procedure with timetable (Annex A)
• April 2 – Start of Examination of Scheme: Examining Authority’s Preliminary Meeting for Interested Parties at Salisbury Racecourse
• January 30 – Stonehenge Alliance to Planning Inspectorate : concerning lack of critical information from Environment Agency
• January 10 – Stonehenge Alliance relevant representation – accepted

2018 Draft DCO application submitted

• December 14 – Stonehenge Alliance to Jesse Norman, Minister of Transport: concerning limited registration period
• December 8 – Registration of Interested Parties and submit Relevant Representation begins
• November 16 – Planning application accepted by Planning Inspectorate.
• October 19 – Draft DCO Application by Highways England received by the Planning Inspectorate
• 2018 July 17 – August 14 Supplementary Consultation on minor alterations
• 2018 June 5 – Westminster debate led by Alex Burghart MP
• 2018 February 8 to April 23 – Statutory consultation on proposed scheme. Cost increases to £1.6bn.

2017

• 2017 September – Announcement of preferred route
• 2017 July 20 – Institute for Government: red RAG rating in report Government delivery of major infratructure – less is more
• 2017 March 22 – National Audit Office: Highlights construction risks in its Progress with the investment strategy 
• 2017 January 12 to March 5 – Non-statutory consultation on route option. Cost increases to £1.4bn.

2015/2016 – Route assessment

• 2015-2016 – Route assessment and identification

2014

• 2014 – Scheme included in the Roads Investment Strategy. Budget cost £1.2bn.

2013

• 2013 – A303 feasibility study announced as part of the Autumn Statement

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