Representation by The Campaign to Protect Rural England - Wiltshire (The Campaign to Protect Rural England - Wiltshire)
- Date submitted
- 9 January 2019
- Submitted by
- Members of the public/businesses
CPRE Wiltshire Branch objects to the A303 Preferred Route and proposed alterations as an individual charity and as a supporter of the Stonehenge Alliance of NGOs. Our objections, supported by CPRE nationally, are substantially based on planning policy considerations, the World Heritage Site (WHS) Management Plan, and the Government’s commitments under the World Heritage Convention. Our concerns about the proper protection of the WHS and its setting are underlined by the advice given to the Government by joint Advisory Missions of international specialists and UNESCO’s World Heritage Committee to seek alternative options for the A303 scheme that would not impact adversely on the WHS and its Outstanding Universal Value. Highways England’s third key objective for the scheme, ‘to help conserve and enhance the WHS’ could not be met. Images of the completed scheme fail to show the contrasting impact of major alterations to the landscape, the extent of future signage, lighting and other infrastructure, and increased traffic on the Expressway. Full information is lacking on the hydrogeology of the WHS, giving rise to uncertainty concerning the potential for adverse impacts on the integrity of the River Avon SAC from construction of the tunnel (pollution and changes in groundwater movement). Furthermore, there would be adverse impacts on the integrity of the Stone Curlew population of the Salisbury Plain SPA during construction and operation of the road scheme, as well as adverse impacts on the Annex I Great Bustard population. The scheme proposals may be in breach of the Habitats Regulations and Habitats Directive and appear also to breach certain considerations and articles of Directive 2014/52/EU. There is no convincing evidence to show that the scheme would meet its fourth ‘broad objective’: ‘to improve biodiversity’. We are concerned about impacts of the scheme on the archaeology along the Preferred Route, especially within the WHS and its setting, despite lack of information concerning evaluations undertaken. There is little recognition or understanding of the WHS as an exceptional “landscape without parallel”. There would be further destruction of the integrity of the Nile Clumps, part of the former Amesbury Abbey park, with the restoration of which CPRE has been involved. There would be adverse visual impacts on Listed buildings, Registered parkland and the Amesbury Conservation Area. We note assessment of the scheme’s low value for money and that it would be poor value for money without the benefit of a questionable ‘heritage contingent valuation’. Convincing evidence that the scheme would bring economic benefit to the South West (another of the scheme’s four ‘broad objectives’) is absent – as is a Strategic Environmental Assessment of the impacts of the different scheme proposals planned for the A303/A358 corridor, both individually and in combination: essential to establishing the credibility and practicality of that aim. Finally, we again raise concern that consultation on scheme options avoiding the WHS was absent – as was full information on discarded options such that informed decisions could be made. We are also concerned about Highways England’s misleading statements concerning apparent benefits of the scheme.