Dr Christopher Gillham: Objection to A303 Stonehenge "Improvement" Draft Orders

1st September 2003

Stonehenge Project Team
Highways Agency
Zone 2-05/K
Temple Quay House
2 The Square
Temple Quay
BRISTOL BS1 6HA

Dear Sir/Madam

A303 Trunk Road (Stonehenge Improvement) Order 200
(Plus Related Slip Road, Side Roads and Detrunking Orders)

I wish to register as an objector to the above A303 order and I lay out a summary of this objection below. I wish to expand upon these objections at the Public Inquiry, which I assume will inevitably follow the receipt of objections.

The bases of my objection are:

that the scheme is fundamentally misconceived, performing neither a valid transport nor environmental purpose

that the reasons given for the scheme are construed so as to fundamentally mislead the public as to its true nature and purpose:

the elaborate and lengthy impact study, though useful and even interesting as a collection of data, mistakes method for analysis, and obscures the fact that essential matters (such as the wider environmental impact) are simply ignored

all the introductory matter concentrates on the "exceptional environmental scheme", as though that were the reason for its promotion and not the completion of a shadow M4 road

that this scheme is a profound misuse of public money that could be better spent on securing far greater environmental benefit elsewhere

that the scheme serves a transitory (and fundamentally mistaken) transport purpose and tourist benefit, at the cost of permanent damage to a great archaeological and spiritual or imaginative landscape:

transitory because the future of motorised transport, based on any current estimate of fossil fuel reserves, or of likely technological advances, or of the limitations brought about by climate change predictions, is measured in decades, while Stonehenge spans 10000 years

the perceived benefits are selfish in that we do not look to the importance of Stonehenge to future generations - for the narrow gratification of tourism today we are proposing to remove parts of the heritage of the future

that a road underneath Stonehenge, though invisible to the eye, is present to the imagination and the spirit -- it alters the place and the feel of the place

that this scheme is designed to increase capacity of the A303 and will increase the corridor traffic, thereby:

increasing traffic through other places along the A303 corridor and into the regions it feeds

specifically, bringing pressures to bear on the A303 in Somerset and threatening the Blackdown Hills

specifically, in generating new traffic into north-south corridors such as the A350 and A36 increasing pressures on areas already threatened by madcap road schemes

that the Highways Agency"s analysis of this scheme computes benefits to the village of Winterbourne Stoke and the immediate area of Stonehenge, without computing the consequent costs to the wider environment and all the communities and landscapes affected by the traffic-generative effect of this scheme

that the traffic-generative effect of this scheme will lead to increased greenhouse gas emission, contrary to international commitments

that the traffic-generative effect of this scheme will include, in addition to new trip generation, modal transfer from public transport

thus helping to make public transport less viable, leading to less efficient transport for the carless in society

thus contributing to increased motorisation of society, leading to further dispersal of economic activity (shops, housing etc.) and hence to less access to this activity for the carless ---i.e. further social exclusion

that this scheme claims advantages that can be secured by other means and at much less cost

such as the removal of the A344, which could be achieved easily and cheaply, and which would probably achieve most of the presumed accident benefit of this scheme

such as the displacement of the visitor centre to a more distant location

that no real analysis of the transport "need" for this scheme has been carried out, nor alternative policies investigated that might achieve the same or better transport ends

in particular that there is no argument to show that this is a development of "last resort" as required by government policy

there is no evidence at all concerning alternative modes of transport

that the scheme justification calls erroneously on the SWARMMS study, when that study took the scheme as a given -- a very specific variant of the old circularity chestnut -- it is national policy to build roads, subject to examination of the need; there is a need for this road because it is national policy to build roads. The difference now ought to be that building roads is no longer supposed to be first resort transport policy

that the promoters of the scheme proclaim an exceptional environmental" purpose and yet have no credibility or credentials for doing this. The Highways Agency has perpetrated some of the most disgraceful environmental abuses in this country and has never expressed any regret for doing this. There are hundreds of examples of terrible damage done to landscapes, habitats and communities, but by way of illustration I refer to one with which I am most familiar -- Twyford Down (which, note, represents the same combination of promoters HA and scheme consultants and project managers, Mott Macdonald (MM)):

misrepresenting the landscape effects of a scheme -- the infamous Twyford cutting, for example, turned out to be 35% wider than HA"s and MM"s predictive photomontage issued to the public. HA/MM furthermore claimed that the cutting and the road would not be visible from all but a handful of locations, specifically excluding places in central Winchester and the Itchen Valley. It is visible from many of these and especially from the latter.

poorly calculating the noise effects of a scheme. HA/MM proclaimed a major improvement would result in the noise environment of Winchester -- all of central Winchester was to benefit and the St Cross area was to benefit enormously (this prediction generating almost the only public support the scheme attracted) and the immediate landscape of Winchester in the Itchen Valley and on ancient St Catherine"s Hill. In fact all these places have been made massively worse for noise.

Poorly calculating the traffic effects of the scheme. A central HA/MM claim was that central Winchester traffic would reduce as a result of this scheme -- it did not.

The promises of care to be taken during construction (see for example §5.5.3.3 of the Environmental Statement for Stonehenge) should also be compared with the realities of Twyford Down. The wonderful Scheduled Ancient Monument and SSSI of the Dongas (within an AONB) was, of course largely sacrificed to the M3, as was the whole of the Iron Age SAM site village. But so careless was the construction that damage was needlessly done to the Dongas area outside the trace of the road. Much was made by the HA/MM of the promised translocation of Dongas turf to another part of the Down. In fact the turf was badly damaged by construction vehicles from the outset, was ripped up in a very short time and when translocated to a stripped area of chalk, was left without watering -- most of it died and, 10 years later, the turf has nothing of the quality of the original Dongas site.

The HA/MM made much of their proposed care for the precious chalk stream watercourse of the River Itchen. In the construction, however, there was no sign of any care taken. In building the footings of the river crossings, for example, huge quantities of chalk were simply dumped in the river, leaving it turbid for miles downstream. There were many other abuses of the watercourses of the Itchen, including arbitrary and unpredicted culverting, damming and breaching of banks.

Despite assurances given at public inquiry that the construction period would be attended with constant public liaison, no such activity took place.

One of the strongest promises that was made before Twyford Down was that the old A33 bypass would be removed and the land restored to downland meadow and restored to the people of Winchester as a landscape amenity. It was and was done well, but 10 years on we are witnessing the start of its redevelopment as a car park. Despite assurances given by the Roads Minister only 6 years ago, that no such use would be allowed, the DfT gave its permission to the County Council to rip the land up again. This abuse may not be laid directly at the door of the HA, but its master the DfT has certainly reneged on the promises the HA made to us.

that the scheme increases the generation of greenhouse gases; that, outrageously, the increase of 4% due entirely to the scheme, is described as "negligible". The UK is committed to a significant reduction of greenhouse gases overall and reductions so far have been entirely fortuitous (destruction of the coal industry) rather than brought about by any government policy or practice, and the reduction is unlikely to be maintained. All sectors of the economy are supposed to contribute to reduced fossil fuel consumption and yet the transport sector grows inexorably. The 4% rise in local emissions of greenhouse gases due to this scheme are considered negligible by comparison with what the Highways Agency preposterously calls "natural growth" of 37% by 2023.

My general view of Stonehenge is that in any civilised society road traffic would not be allowed within many miles of it. It is a measure of the wrongheadedness of our society that any areas of our countryside should be subject to the levels of traffic that some of our great landscapes endure. The answer to Stonehenge, however, is not to engineer our precious landscapes to hide the very worst abuses, at the cost of making things worse everywhere else. The answer to Stonehenge is the answer to all our environmental problems -- it is to work towards a sustainable future that does not consume finite, irreplaceable resources in pursuit of a temporary and ultimately illusory notion of economic growth. The answer to Stonehenge is to reduce traffic everywhere, the answer is to make motoring pay its true costs.

If we start to come to our senses, then within the lifetime of this scheme the post-war growth of traffic that has so ruined our society and blighted so many of our precious landscapes, townscapes, communities and habitats, will be reversed. If we do not come to our senses then this reversal will be forced upon us, probably in a not much greater timescale. Climate change and resource depletion are inexorable and imperative. Whatever way we go the madness of the Highways Agency can only last decades.

Yet in the lifetime of Stonehenge this really is negligible. Thus anything that takes away anything from Stonehenge and its landscape that is irreplaceable must come to be seen as folly by our children and their children. The proposed scheme destroys several kilometres of archaeological landscape forever, for a supposed gain that can only be temporary.

The proposed scheme drills a hole under a site, which for many people is of the most profound spiritual significance, evokes the most atavistic longings, or at least kindles imagination and a sense of wonder. I would contend that most people for whom these responses are natural, would feel that the knowledge of a road underneath this mysterious ground was more obnoxious than the sight and sound of the existing road above it.

The best thing to do with Stonehenge is to do nothing of an engineering nature except remove the existing A344, move the visitor centre and attempt to restore the agricultural wasteland in the vicinity to traditional grassland. For the rest we should work towards a better future for this precious landscape by pursuing proper environmental policies throughout the nation, that will eventually take the pressure off all roads and eventually, sufficiently off the A303 that the really radical policy of closing the road altogether can be contemplated.

Yours faithfully

(Dr.) Christopher Gillham