Selection of responses from other organisations here
Summer 2018 – Response by The Stonehenge Alliance
- We deplore the continued misleading advertising of the preferred route by Highways England as seen on its A303 Stonehenge website under “Why we need this scheme”. The preferred route would very clearly not “protect or enhance the environment” of the WHS or its setting; nor would it help to “conserve and sustain the WHS and make it easier to reach and explore”.
- It is unreasonable of Highways England to select certain aspects of the public response to the statutory consultation for further consultation without explaining, even in summary form, the number and content of responses that were received from consultees and how these informed the present consultation.
- None of the proposed changes would ameliorate the severe damage that would be caused by the preferred route scheme to the World Heritage Site (WHS) and its outstanding universal value (OUV).
- Highways England has consistently disregarded the advice of the joint UNESCO World Heritage Centre/ICOMOS Advisory Missions to respect the Government’s commitments under the World Heritage Convention in the promotion of its preferred route scheme. Of particular relevance are the findings and recommendations of the March 2018 Advisory Mission which were not made known to the public at the time of the statutory consultation.
- The World Heritage Committee’s 2018 Decision (also not available to consultees at the statutory consultation stage) urges Government to continue to explore a solution which avoids adverse impact on the Outstanding Universal Value of the WHS.
- The Stonehenge Alliance considers that the Preferred Route scheme should be halted to take into account the findings and advice of the 2018 Advisory Mission and World Heritage Committee Decision this year.
- We fear that our Government intends to accept the loss of the WHS designation of the Stonehenge, Avebury and Associated Sites WHS.
- Should proposals for A303 widening still be considered necessary, international advice to seek solutions that would not impact adversely on the OUV of the WHS should be followed.
Spring 2018 – Read response by The Stonehenge Alliance
- The Stonehenge Alliance strongly disagrees with the proposed scheme in its entirety since it would severely and irreparably damage the WHS and its setting, along with a significant number of its attributes of outstanding universal value (OUV), in direct contravention of the World Heritage Convention, planning guidance and policy for the WHS and the Vision and aims of the WHS Management Plan.
- The scheme not only disregards but also fails to mention: the clear advice of the UNESCO/ICOMOS Advisory Missions to Stonehenge on Heritage Impact Assessment (HIA) and a choice of route; and the Decision of UNESCO’s World Heritage Committee on 6 July 2017.
- We deplore the fact that Highway England seeks no more than comments on a scheme intended to be implemented without asking respondees about their views of the fundamental suitability of the scheme as a whole for the WHS.
- We also deplore, in any consultation to date, the lack of route choices and the absence of detailed comparative information about rejected routes that would not damage the WHS and its OUV.
- Many of the points made in our response to the previous consultation remain valid for the current consultation, especially under planning policy, transport issues, consultation and value for money considerations.
MISLEADING AND INACCURATE INFORMATION ABOUT THE SCHEME
Misleading and inaccurate information has repeatedly appeared in Highways England’s public documents and press statements. We have referred to some of these in correspondence with Highways England (letter to Mr Parody, 15 January 2018). Numerous instances have been found throughout the consultation process. Here are a couple of examples:
- “Our proposal is to build a 1.8 mile (2.9 kilometre) tunnel under the World Heritage Site . . .”. (Public Consultation Booklet, January 2017, p.8. Note: The World Heritage Site is c.5.4km across.)
- “The removal of traffic along the existing A303 from much of the Stonehenge landscape would improve the setting of heritage assets within the WHS, including Stonehenge itself.” (PEI Report Non-technical summary, February 2018, p.11) Note: The WHS itself is a heritage asset of the highest significance: cf. NPPF para.132; while the settings of a number of heritage assets within the WHS would be adversely affected by the A303 scheme. Improving the setting of the henge is not the same thing as improving the setting of the Stonehenge WHS.
In addition to the misleading or untrue statements given as examples above, videos and illustrations of the completed scheme shown to the public are unrealistic, indicating very low levels of traffic, few lorries, no lighting or gantries, and minimal signage and indication of fencing.
The entire project should be reconsidered, in order to take into account the advice of UNESCO and the demands of the agreed protective planning framework for the WHS. We hope that Highways England will advise the Government that consultation on the A303 scheme is premature in view of the amount of missing data and that UNESCO’s advice needs to be fully considered in this proposal.
2017 – Response by The Stonehenge Alliance
Our key concerns were:
- Consultation period of 7 weeks was too short for a UNESCO World Heritage Site.
- No options offered to protect the World Heritage Site
- Tunnel too short (WHS is 5.4km/3.4 miles wide, tunnel is 2.9km/1.8 miles long).
- Serious damage to archaeology and landscape in direct contravention of planning policy and World Heritage Convention.
- Detrimental to wildlife especially the RSPB reserve for Stone Curlews.
- £1.4bn expenditure won’t solve traffic problems
The Stonehenge Alliance responded to Highways England’s consultation expressing these serious concerns both with the consultation and the proposals.