Letter of objection from Salisbury Transport 2000

26 June 2000

Lord Whitty
Minister for Roads
House of Lords
London SW1

Dear Lord Whitty,

A303 Amesbury-Berwick Down and the Stonehenge Management Plan

Following the publication of the Management Plan for the Stonehenge World Heritage Site on 6th June, Salisbury Transport 2000 is writing to ask you to withdraw the proposed A303 Amesbury-Berwick Down project from the roads programme.

The national office of Transport 2000 has already made its concerns about the scheme known to you. To summarize our own concerns:

Potential for induced traffic

We feel doubling the capacity of the A303 at Stonehenge is inconsistent with the conclusions of the 1994 Standing Advisory Committee on Trunk Road Assessment (SACTRA) report Trunk Roads and the Generation of Traffic (which DETR accepted), the Government�s stated objective to reduce dependence on the private car, and the objectives set out in A New Deal for Transport. The 1995 Stonehenge Planning Conference resolved that there should be no dualling of the A303 if that proved inconsistent with the findings of the SACTRA report. As you know, Somerset County Council opposes the scheme because of the potential for "induced traffic" to worsen conditions elsewhere on the A303.

Pre-empting of multi-modal study

Pressing ahead with another upgrade of the A303 without considering improvements to alternative transport modes pre-empts the South West and Wales Multi-Modal transport study. The New Deal was subtitled "Better for Everyone", not just better for motorists; pressing ahead with the Stonehenge scheme undermines your commitments to alternative forms of transport and to reducing social exclusion caused by over-dependence on cars.

No proper consideration of alternatives

We are very concerned about the lack of proper consideration of alternatives to the scheme. As you know, the most recent study of alternatives, Stonehenge: Review of English Heritage 2km Tunnel and Comparative Options, was commissioned by the Highways Agency from Halcrow & Partners in 1998. The remit of that report specifically asked for a re-evaluation of the options considered at the 1995 Stonehenge Planning Conference. Yet Halcrow�s report confined itself to the cut-and-cover tunnel and three "no-hope alternatives" (already rejected by English Heritage and the National Trust) and completely failed to evaluate a long-bore tunnel�by consensus, the preferred option of the Planning Conference. The inclusion in the Halcrow report of a map showing numerous previously considered and rejected routes for the road is no substitute for a proper consideration of the alternative favoured by consensus at the 1995 conference (namely the long-bore tunnel).

Since the Halcrow report was published, there have been more calls for a fair evaluation of the long-bore tunnel. A conference held by RESCUE (the British Archaeological Trust) in July 1999 revealed widespread unhappiness with the cut-and-cover tunnel. In February 2000, the International Commission on Monuments and Sites UK (ICOMOS-UK) called for "a full Environmental Impact Assessment, which we would expect to form part of the Planning Process. The alternatives, including the long bored tunnel, would need to be assessed in equal terms." Full consideration of the long-bore tunnel (including a detailed costing) will also be required to satisfy the legal requirements of the EIA Directive/Environmental Assessment regulations. Simply dismissing the long-bore tunnel in two words ("too expensive") is not acceptable.

We are disappointed to see that there has been no consideration at all of non-road alternatives to the scheme, such as upgrades of the Exeter-Salisbury-Waterloo railway line or light rail connections between Salisbury and Stonehenge (as recently proposed to the Highways Agency by our group).

Lack of economic justification

The scheme appears to be economically motivated, yet there are three questionmarks over how effective it might be in economic terms.

The latest SACTRA report, Transport and the Economy, suggests that any regenerative benefits to deprived areas of the South West from upgrading the A303 may be illusory: prosperity could be "sucked out" of the South West as a whole (or towns along the A303 route) by road upgrades just as easily as it could be "sucked in".
The failure of English Heritage to attract a commercial sponsor to operate the proposed new visitors� centre at Countess East has cast doubt on whether that centre will ever now be commercially viable. Without the centre, an improved "road to Stonehenge" has even less justification.
Even the 1998 Halcrow report admits the scheme is of "marginal economic benefit on transport grounds", with such a low benefit to cost ratio (BCR) that it compares very unfavourably with other road schemes (never mind other potential transport investments).

The proposed scheme has little or no economic justification using the traditional transport economics of COBA. An even greater investment in the more expensive long-bore tunnel would, clearly, produce an even lower benefit to cost ratio using those same economics. Yet a more visionary approach, considering the so-called "heritage value" of the site could justify a greater investment. Article 4 of the World Heritage Convention pledges the Government to ensure the "protection, conservation, presentation and transmission to future generations" of the Stonehenge site and to do "all it can to that end, to the utmost of its own resources and, where appropriate, with any international assistance and cooperation, in particular, financial, artistic, scientific and technical, which it may be able to obtain". We are not aware that the Government has explored the option of seeking "international assistance" of this kind.

Potential archaeological and ecological damage

We are also very concerned about potential archaeological and ecological damage from the scheme, though this is not Transport 2000�s primary area of expertise. Aside from the damage to the Stonehenge World Heritage Site itself, the 1998 Halcrow report highlights damage that will be caused to two internationally important sites by the proposed crossing of the River Till.

We believe that publication of the Stonehenge World Heritage Site Management Plan has now pushed the proposed road scheme into the realms of the completely unacceptable. The new Plan confirms that Stonehenge must be considered not as a single monument but as a large collection of interrelated sites and monuments and their entire landscape setting. The emphasis must be on preserving the entire World Heritage Site and, whatever benefits might be achieved for the central monument, constructing four lanes of new road through the site is completely at odds with the Plan.

The 1998 Halcrow report claims the proposed scheme is consistent with the aims of Regional Planning Guidance (RPG10) for the South West, with the exception of paragraph 4.23. Yet that paragraph is the single most important statement on protecting archaeology and heritage in RPG10. It reads:

"The South West contains an impressive range of archaeological features and remains, from individual sites to extensive historic and prehistoric landscapes such as Dartmoor and Bodmin Moor. Stonehenge/Avebury and associated sites are internationally important, having been designated a World Heritage Site by UNESCO. Development plans should carry forward the advice in PPG16 on the protection of nationally important archaeological remains and their settings." The relevant part of PPG16 states: "Where nationally important archaeological remains, whether scheduled or not, and their settings, are affected by proposed development there should be a presumption in favour of their physical preservation." In summary, RPG10, PPG16, and the Stonehenge World Heritage Site Management Plan all require the preservation of Stonehenge and its entire landscape setting, not just the central monument. The proposed road scheme is inconsistent with all of these accepted instruments of planning policy.

In the light of our concerns and those expressed by numerous other individuals and organizations, we would welcome an announcement from you that you intend to look again at alternatives to the proposed scheme.

Yours sincerely,
Salisbury Transport 2000