Submissions on the latest consultation prior to redetermination of the A303 Stonehenge road scheme have now been published. The consultation gave the Department for Digital, Culture, Media and Sport (DCMS) the opportunity to publish the report by UNESCO’s Joint Advisory Mission (World Heritage Centre, ICOMOS and ICCROM) following their visit to Stonehenge last April.
National Highways (NH) provided new information on cut and cover and bored tunnel extensions, as well as other matters requested by the Transport Secretary.
The Stonehenge Alliance response is contained in three separate documents by topic area:
Key points and responses to note:
- The Alliance questioned why the tunnel extensions should terminate only 80m beyond the western WHS boundary whilst repositioning the A303/A360 interchange further west and out of sight from the WHS.
- The Advisory Mission said that ideally the road should be taken outside the WHS, but stated that any tunnel should extend at least to the western WHS boundary. However no decision should be taken on the scheme before the next World Heritage Committee meeting.
- The Council for British Archaeology, ICOMOS-UK as well as the Alliance asked for further investigation of a southern WHS bypass. It would be both beneficial to the WHS and less expensive.
- The National Trust and Wiltshire Council saw benefits in longer tunnel alternatives, should they be considered both acceptable and viable, whereas the Consortium of Stonehenge Experts did not recommend the cut and cover extension as “it would involve significant loss of the physical fabric of the WHS“.
- At a time when Government decarbonisation policy is to facilitate a reduction, or at least a stabilisation, in traffic, the Alliance repeated arguments for consideration of non-road building alternatives, including effective traffic management measures.
- The scheme would generate massive carbon emissions in construction and operation, and is entirely out of step with advice by the Climate Change Committee which warns that reduction in car use is essential to tackle the climate emergency.
Geology, soils and hydrology
- We once again expressed grave concerns about the problems that would arise from tunnelling through the unique chalk geology of the WHS which lacked specialist assessment
- The Environment Agency concluded, on the extended tunnel alternatives, that there is “insufficient evidence to support the Environmental Appraisals” especially in relation to “potential impact on groundwater and flood risk matters.”
- The Alliance challenged National Highways’ revised business case which improved the case for the scheme despite its reliance on a discredited heritage valuation survey without which the scheme would show negative value for money spent on it.
- Furthermore, the scheme is being progressed in isolation from other identified bottlenecks along the A303 corridor, undermining the time savings and benefits attributed to it.
- Any substantial change to the design of the original DCO would require a fresh application.
- The Stonehenge Alliance continues to argue that the proposed project is so flawed, and its negative impacts so great, that the Secretary of State should refuse the Development Consent Order.
- If, as National Highways proposes, the Transport Secretary is minded to proceed with the present scheme unchanged, it should be formally re-examined, so that all the new information made available since 2019 may be properly considered and the Transport Secretary receive independent specialist advice.
New consultation deadline
- DCMS restated its commitment to NH’s scheme but sought to address the Advisory Mission’s recommendations “to the fullest extent that is reasonably practicable”. Accordingly the Transport Secretary has now issued a letter inviting the Applicant to provide comments on the Advisory Mission’s report by 9 September 2022.
- Interested Parties will once again be invited to comment on the Applicant’s response, this time in the context of new Government leadership.
- Amesbury Museum and Heritage Trust response
- Avebury Society response
- National Highways: Sequence of 9 documents dated 12/13 July 2022
- Planning Inspectorate Overview/What happens next
- Wiltshire Archaeological and Natural History Society response
- Media reports:
- New Civil Engineer, 26 August 2022 ’UNESCO continues to push for alternative to planned Stonehenge Tunnel’ (subscription) Read here as PDF
- Mail Online, 2 September 2022 ‘Unesco says ‘substantial’ amendments are needed to controversial £1.7billion two-mile tunnel near Stonehenge – after planning officials warned it would cause ‘permanent, irreversible harm’ to the World Heritage Site’