ICOMOS-UK Outline Statement of Case

ICOMOS UK Register charity number: 1057254

International Council on Monuments & Sites UK 10 Barley Mow Passage London W4 4PH Tel: 020 8994 6477 Fax: 020 8747 8464 Email: icomos-uk@icomos.org www.icomos.org/uk/

 
 

STONEHENGE A303 ROAD IMPROVEMENT: PUBLIC INQUIRY
 
 
 
 

ICOMOS-UK OUTLINE STATEMENT FOR PRE-INQUIRY MEETING:

October 2003
 
 

1. ICOMOS-UK

ICOMOS-UK is recognised by Government as having special status with regard to World Heritage sites. With its parent body, ICOMOS, it is official advisor to UNESCO on cultural World Heritage sites. 2. World Heritage Convention In signing and ratifying the Convention Concerning the Protection of the World Cultural and Natural Heritage (World Heritage Convention), the UK Government, through this international treaty, is committed to:

• Protecting and sustaining the identified the Outstanding Universal Values for which World Heritage sites in the UK are inscribed on the World Heritage List

• Protecting the Integrity of such sites

Any changes affecting World Heritage Sites must be measured for their impact on the Outstanding Universal Values of the site and on the overall integrity of the site and of its setting.

In the UK, currently the measurement of impact must respect PPG 15, which acknowledges that �the impact of proposed development upon a World Heritage Site will be a key material consideration in determining planning applications�.

We will be drawing attention to the responsibilities of World Heritage status.
 
 

3. Stonehenge World Heritage Site: Statement of Significance Stonehenge has internationally acknowledged Outstanding Universal Value through its inscription (with Avebury) on the World Heritage List in 1986 as a cultural World Heritage site.

Outstanding Universal Value is an assessment of the combined value of cultural and natural qualities in a site. Outstanding Universal Value is usually articulated in a Statement of Significance for the site.

The Stonehenge World Heritage Management Plan, drawn up in 2000, sets out the Statement of Significance for the site. This encompasses why the site is of Outstanding Universal Value and thus why it is unparalled in the world and has come to have such a unique position in our national heritage. The Statement sets out the following qualities:

• Extensive, highly complex and evolving archaeological/historical cultural landscape

• Unparalleled dense concentration of archaeological monuments

• Complex spatial layout with strong ceremonial and cosmological associations

• High visual interconnectedness of the key landscape features

• Influence of the site on the development of landscape appreciation

• Powerful inspirational visual/aesthetic qualities

• Strong spiritual associations

• Iconic status of the main monument

• High levels of access and enjoyment which the site is perceived to offer

These are the qualities which all need to be sustained for the whole World Heritage Site

We will assess these Outstanding Universal Value of the site in detail at the Inquiry and set out the characteristics of the World Heritage �asset�.

4. Approach to assessing the impact of change: Both English Heritage�s �Power of Place� in 2000 and the subsequent response by the DCMS, �A Force for our Future, 2001, highlighted the need to consider cultural heritage not just in terms of discrete sites, but through understanding the way our landscapes reflect a cultural identity.
 

World Heritage site inscription reinforces this holistic approach as outlined above.

ICOMOS-UK therefore considers that an assessment of the impact of the road proposals on the Stonehenge World Heritage site should consider their impact on the overall World Heritage site.

This means considering the impact on the qualities which, when combined, give the site its Outstanding Universal Value.

We consider that it is:

• Inappropriate to consider Stonehenge merely as a collection of Scheduled Ancient Monuments, or as one major scheduled monument surrounded by a collection of lesser monuments

• Inappropriate to measure impact in terms only of damage to individual monuments or to the setting or context of individual scheduled monuments

• Inappropriate to restrict impact to the area known as �Stonehenge Bowl� (an area within which the main Stonehenge monument has high visibility)

These approaches do not encompass all the Outstanding Universal Values of the whole World Heritage site.

The site is the whole World Heritage Site. If setting is being considered it must be the setting of the World Heritage Site as a whole rather than the setting of individual sites within the World Heritage Site.

The Management Plan stresses the need for:

�recognition of the importance of the WHS as a whole and its need for special treatment and a unified approach by government departments, agencies and statutory bodies with responsibility for making and implementing national policies and undertaking activities that may impact on Stonehenge and its environs�.

We strongly support this assertion. This Planning Inquiry must have a methodology for evaluating impact on landscape valued as whole rather than as a collection of parts, where the whole has a higher value than the sum of its parts, and where the landscape is valued for its international importance through inscription as a World Heritage Site.

Current planning tools tend to deter consideration of overall Outstanding Universal Values and joined up approaches between departments and agencies. Nevertheless ratification of the World Heritage Convention by the UK Government brings with it an obligation to sustain Outstanding Universal Values across the whole World Heritage site.

We will thus stress the need to take a principled and wider outlook on the impact of this scheme on the Outstanding Universal Values of the whole World Heritage site.
 
 

5. Environment Impact Statement We will be questioning aspects of, and arguments put forward in, the Environmental Impact Statement. These will include:

• Use of the latest available evidence

• Assessment of the overall landscape as a single entity

• Interrogation of the evidence for its impact on Outstanding Universal Value
• Impact of the scheme on intangible as well as tangible qualities of the World Heritage site
• Concept of severance
• Concept of setting
• Impact on integrity
• Analysis and assessment of benefit/disbenefit
• Methodology

In particular, we will outline areas that we have found to be inadequately covered by the Environmental Impact Assessment.

We consider it:

• Does not adequately define the asset from available evidence
• Does not draw adequate conclusions from evidence on overall qualities, value and significance of the asset
• Does not adequately measure the impact of the published proposals against the asset in terms of:
• Overall scope
• Range of qualities and significance
• Integrity issues

We will also draw attention to particular aspects of the Environmental Impact Assessment where we consider that sufficient evidence has not been put forward, where the evidence does not support the conclusions reached, or where the logic is, we believe, flawed.

We consider the assessment:

• Does not detail the cumulative impact of the proposals
• Does not detail the disbenefits on what are called the margins of the World Heritage site
• Does not properly evaluate the weight of benefits versus disbenefits
• Does not evaluate adequately non-monetary benefits and disbenefits
• Does not consider benefits in a long time frame
• Does not consider the long-term implications of the proposed scheme on the site
• Does not properly evaluate other considered options

In order to assess the Published Proposals according to international best practice, we consider that the existing planning framework and planning tools need to be used more creatively then in the current Environmental Impact Assessment. We would thus like to consider the impact of the proposals on:

• The Outstanding Universal Value of the World Heritage site as a whole
• The Integrity of the World Heritage site as a whole

And then consider the overall benefits and disbenefits of the published scheme to the World Heritage site as a whole 6. Options: We consider that the value of the Stonehenge World Heritage site as an international asset means that it is incumbent on all government departments and agencies to deliver a scheme for the A303, which:

• Does not adversely affect or diminish the Outstanding Universal Values and Integrity of the site
• Offers substantial benefits to people and landscape
• Enables the delivery of a long term Vision for the site in terms of optimising its assets, as set out in the Management Plan
• Will deliver long-term sustainable development for the site

We do not consider that the present scheme satisfies these criteria. It impacts substantially on the Outstanding Universal Values and Integrity of the World Heritage site through:

• Cutting a 2km swathe through the highly complex archaeological/historical cultural landscape

• Damaging considerable archaeological monuments and below ground archaeology

• Disrupting the complex spatial layout with its strong ceremonial and cosmological associations

• Severing the visual interconnectedness of the key landscape features

• Introducing damaging visual and aural intrusions

• Preventing access which supports understanding of the key qualities of the site

• Creating a dual zoned World Heritage site with a protected core and unprotected outer zone

• Removing the possibility of delivering a long-term vision for the site which could:
• Reunite its connected features
• Create a proper wide setting for the main monument linking it to its complex supporting landscape
• Allow understanding of the complex ceremonial and other uses of the pre-historic and later landscapes
• Offer wide-ranging and meaningful access across the whole site
• Offer spiritual reflection and quite enjoyment
• Improve the overall visual landscape
• Offer understanding and appreciation of this unique landscape

We will be reviewing other options, longer tunnel routes and previously considered alternative road routes to the north of the site, in a similar way to the analysis of the proposed tunnel option, for their impact on the overall World Heritage site and its values and integrity.

We will therefore be outlining which other options, on the basis of present knowledge, could apparently satisfy these criteria

7. Conclusions:

We will be drawing the following conclusions:

• World Heritage inscription means that a long-term approach should be adopted for the World Heritage site and its sustainable development

• The UK government should be promoting a �best practice� scheme for the A303 and its relationship with the World Heritage site, which not only sustains the Integrity and Outstanding Universal Values of the World Heritage site but offer substantial benefits in terms of access, appreciation and understanding and also allows the delivery of a long-term Vision for the site

• There should be a presumption against major infrastructural projects within the World Heritage site.

• The A 303, as a major national trunk road, should avoid the surface of the World Heritage site altogether

• A longer bored tunnel with no surface works interrupting the World Heritage site might be acceptable

• Proper evaluation should be given to alternative and cheaper surface road proposals to the north of the World Heritage site which could be acceptable

• An acceptable scheme must be accompanied by detailed strategies for:

• Access movement across the whole World Heritage landscape � for both locals and visitors

• Optimum access points to the World Heritage site

• Landscape objectives for the whole site

• Knowledge dissemination of the significances of the World Heritage landscape in order to promote wide appreciation and understanding of the site and its assets

8. Summary of ICOMOS-UK views

We will be setting out and summarising ICOMOS and ICOMOS-UK statements on the road scheme as a correct record.