Friends of the Earth Wiltshire Network: Objection to Draft Orders, 3 September 2003
3 September 2003
Stonehenge Project Team
Highways Agency
Zone 2-05/K
Temple Quay House
2 The Square
Temple Quay
BRISTOL BS1 6HA
Dear Sir
Objection to A303 Stonehenge Project and Winterbourne Stoke Bypass
Wiltshire Friends of the Earth is a network of five local FOE groups covering the five districts in Wiltshire (which includes Swindon). We have voiced our concerns and opposition to the Government's scheme at Stonehenge and Winterbourne Stoke on numerous occasions.
We object to the proposals to the Draft Road Orders and the CPO for the Highways Agency A303 (Stonehenge Improvement) Scheme. Our grounds for objection are comprehensively set out in the objection submitted by Salisbury Transport 2000 and Friends of the Earth South West.
We wish to add two further grounds for objection to theirs on heritage
and transport:
Heritage
We object very strongly to the narrow view taken in terms of the heritage
area to be conserved, enhanced or improved. The wider heritage impact on
the curtilage of the Stonehenge World Heritage Site and its approaches
have not been properly considered in tangible or intangible
terms. The Highways Agency has admitted that heritage would be compromised
and that not all landscape effects would be positive. This has been expressed
in the unacceptable terms of trade offs or re-engineering of an ancient
landscape. Effectively this is to replace 20th century clutter
with 21st century clutter spread even more widely.
Transport
For many years dualling of the A303 has been enthusiastically pursued by the Highways Agency knowing that (a) increasing road capacity would not necessarily resolve the traffic problem the scheme is attempting to address and (b) there would always be adverse impact on highly sensitive sites along this route. Effectively this is an agenda of accommodating traffic and increasing pressure on outstandingly sensitive sites along the whole of this route. In pursuing this course of action there have been two serious omissions of process which are contrary to Government's own transport policy: the failure to incorporate the scheme within the SWARMMS process, a matter covered by Salisbury Transport 2000's objection and the failure to treat the road proposal as a scheme of last resort � a Government position, which FOE South West points out, we endorse.
We would additionally argue that the alternatives have only been considered in terms of roads instead of a robust and visionary traffic management, demand management, speed and safety scheme which could be combined with exceptionally high standards of alternative modes, publicity and marketing. We are dismayed that this sequential multi modal approach was not pursued with equal enthusiasm a decade ago before advancing this proposal in its current form. Nor is a multi modal agenda being advanced now.
Regarding the conspicuous absence of Stonehenge section of A303 from SWARMMS, we refer to the Minister of Transport's supportive response of 9 August 2001 to South West Sustainable Transport Round Table's letter of objection to this omission on 20 July 2001 in which Mr Jamieson acknowledges clear linkages in approach to all trunk road schemes arising from SWARMMS � a matter that the promoters of the Multi Modal Study should be mindful of.
"Reducing the Growth in Travel Demand" (aka "Soft Measures") was considered
within the SWARMMS Strategy and have been subject to intense scrutiny by
the Department for Transport's consultants and peer review. The evidence
now suggests that the SWARMMS strategy was overly pessimistic in terms
of its potential to cut travel demand and that cutting traffic growth is
not only achievable but so is absolute traffic reduction. Nevertheless
this scheme has been designed for increased traffic. It should have
been designed to reduce and discourage traffic.
Procedure and Participation
We have an additional ground for objection in terms of participation. The Highways Agency's A303 five day Planning Conference held in Salisbury in 1995 arrived at a set of resolutions through a rigorous consensual process with all interested parties. These resolutions, several of which were put forward by our Network, formed the basis for principles developed in the Management Plan.
This formed part of a new confidence building democratic process that we supported in good faith. We feel this participatory process has been usurped by a scheme which fails to adhere to the outcome of that lengthy trust building process. This is contrary to Natural Justice and therefore forms part of our objection.
We believe that the Government's assessment that this is an 'exceptional scheme' has been misunderstood and wrongly interpreted. This scheme does not measure up to the Government's own policy aspirations. Our interpretation of the phrase is that standards in all aspects of this 'improvement' should be exceptionally high and not an excuse to reduce quality in one area in order to achieve a higher quality elsewhere. This scheme appears to fail that test.
We request a full public inquiry to allow these objections to be fully explored.
Yours faithfully
Kate Freeman
for Wiltshire Friends of the Earth