Context

The Secretary of State for Transport, Grant Shapps, wants to redetermine the Development Consent Order (DCO)  for the very same Stonehenge road scheme condemned by UNESCO, the panel of five independent planning inspectors, and hundreds and thousands of our supporters, following the High Court’s quashing of Shapps’ decision to go ahead in 2020.

Redetermination has grown into a protracted 3-way ping pong between Grant Shapps, the applicant National Highways [NH], and interested parties consulted on numerous aspects.  Our responses to the Transport Secretary’s further questions on all aspects were published on the Infrastructure Planning website in a single document file.  They are published below under separate topics and deadlines.

Our overarching conclusion

The Stonehenge Alliance considers that the DCO application for the Stonehenge new road scheme should be refused for legal reasons, and because the adverse impacts of the proposal would outweigh its benefits.  These, and other aspects, are explained in detail in the links to our responses below.

“There is only one sane outcome to this process and that is for Grant Shapps to refuse permission for this highly damaging road scheme. National Highways remains in complete denial about the impact of its plans for the Stonehenge landscape.

If Grant Shapps refuses to take the sensible course and tell National Highways to go
away and come back with something better, then at the very least he should hold a
new public examination.”  Tom Holland, 26 April 2022

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4 April 2022 deadline:

Stonehenge Alliance responses to the Secretary of State’s Statement of Matters of 30 November 2021 and the Applicant’s (National Highways) responses

1. Covering note and legal submission: prepared by Dr Kate Fielden with advice from Victoria Hutton of counsel 

Summary of content: The Stonehenge Alliance is of the view that the Secretary of State’s proposal to re-determine the scheme under Rule 20(2) of the Infrastructure Planning (Examination Procedure) Rules 2010/103 is unlawful. Our arguments in relation to this are in our response in the above link.

2. Alternatives: prepared by Dr Kate Fielden,  Dr Simon Temple and Chris Todd with advice from Victoria Hutton of counsel

Summary of content: The Stonehenge Alliance campaigns for the protection and enhancement of the World Heritage Site (WHS) and its setting.  The Proposed Scheme for road widening would not give that protection.  We therefore consider that the scheme should be rejected.  In Section 6 of our paper we suggest ways in which traffic flow could be improved, some of which would address the current Climate Emergency which was not of major concern when the Scheme was announced in 2014.

3. Environmental Information Review:  prepared by Dr Kate Fielden, Andy Norfolk Dip LA MSc, and with reference to specialist advice by Dr George Reeves CGeol CEnv PhD MSc BSc FGS FIMMM, Clive Bentley CEnv, CSci., MCIEH, MIEnvSc. MIOA and Rupert Thornely-Taylor Noise & Vibration Consultant

Summary of content: Response to matters relevant to

• Cultural heritage (Section 2)
• Landscape and Visual assessment (Section 3)
• Biodiversity (Section 4)
• Noise and Vibration (Section 5)

Our response references evidence presented to the Examiners in 2019.

4. Transport, Carbon and Economic Issues: prepared by Dr Simon Temple, Professor Phil Goodwin, and Chris Todd

Summary of content: This response is limited to National Highways’ submission at the time.  The Secretary of State for Transport requested a further update on carbon (see deadline 3 August below).

• Our view is that the Secretary of State for Transport should reject National Highways’ defence of its argument to proceed with its project, because its case is fundamentally flawed in numerous respects: NH has failed to robustly demonstrate the need for the scheme and the harms it will cause.
• The Secretary of State has already accepted that it will cause permanent and irreversible harm to the World Heritage Site and other assets. Evidence since the date of the Secretary of State’s decision reveals that the damning comments made by the Examining Authority and agreed by the Secretary of State are in fact underestimates of the harm.
• Further harm will arise in the context of carbon emissions (including through road traffic and embodied carbon), landscape and other harms previously outlined in our Examination submissions, set out in submissions made as part of this post-quashing exercise and inconsistent with current Government policy on Decarbonising Transport, 6th Carbon Budget and advice of the Climate Change Committee in a climate emergency.
• These harms could be avoided through alternative means and in the context of a scheme which risks the WHS losing its world heritage status the availability of alternatives (which has not been properly addressed by NH) should be given considerable weight.

5. Geology, Ground Investigation and Groundwater Monitoring: prepared by Dr George M Reeves 

Summary of content: Based on 14 reports made available to the Stonehenge Alliance in 2022 following repeated requests for data from 17 April 2019 onwards.  These packages of reports are described in Section 2.

This technical report lists concerns and risks:

• Main Issues for Concern [Section 4.1]
• Groundwater Disruption with particular reference to Blick Mead [Section 4.2]
• Subsidence and potential damage to undiscovered archaeology [Section 4.3]
• Conclusions and recommendations highlight the lack of benefit to the Examining Authority to examine and interrogate the data that has since been submitted, matters that could cause considerable cost and time over-runs in completing the works proposed. [Section 5]

6. Any Other Matters: prepared by Dr Kate Fielden with assistance of Victoria Hutton of counsel 

Summary of contents: 

• World Heritage Committee, its status, function, and advice relative to NH’s views [Section 1]
• Findings of the Secretary of State concerning the Proposed Scheme [Appendix]

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10 June 2022 deadline:

Stonehenge Alliance response to the Secretary of State’s call for further comments on the Applicant’s updated information on carbon

Updated Carbon Issues: prepared by Dr Simon Temple, Professor Phil Goodwin, and Chris Todd 

Summary of contents:

The Alliance continues to be concerned that NH is failing to properly assess the carbon emissions from its road schemes, including the A303 Stonehenge project.

We point out weaknesses and contradictions in NH’s submissions.  For instance in its response to meeting carbon targets NH which revealed two incompatible facts:

If NH implements government policy on carbon reduction, traffic will reduce or stabilise, thus traffic forecasts would no longer justify the scheme.

Or

By providing for an increase in traffic, and thus an increase in carbon, NH is planning for a decarbonisation policy failure.

Which scenario is NH aiming for?

We highlight:

• Inconsistency with Government’s Transport Decarbonisation Strategy [Section 2]
• National Highways’ failure to follow IEMA (Institute of Environmental Management & Assessment) guidance to minimise emissions [Section 3]
• NH together with its own guidance appears to downgrade the importance of the carbon impact of their projects – it diverges from EIA (Environmental Impact Assessment) guidance and is at odds with Parliament’s declared climate emergency [Sections 4 and 5]
• Cumulative Impacts and means of assessment [Section 6]
• We doubt the competency and thoroughness of the assessments carried out by NH [Section 7]

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3 August 2022 deadline: responses published 25 August

The Secretary of State issued a letter on 20 June requesting further comments from the Applicant on issues raised by Interested Parties in commenting on NH’s responses including tunnel extensions.

Stonehenge Alliance responses by topic area:

1. Review of environmental information including cultural heritage, tunnel extension and other planning issues
2. Transport issues and alternative options
3. Geology, soils, vibration and adverse impacts of tunnelling through chalk

Our commentary on responses including UNESCO’s Advisory Mission report published at the same time in ‘Short tunnel is no short cut.  Back to the drawing board?’

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