Representation by The Historic Buildings and Monuments Commission for England (The Historic Buildings and Monuments Commission for England)
- Date submitted
- 10 January 2019
- Submitted by
- Non-statutory organisations
Introduction
Historic England is the government’s statutory adviser on all matters relating to the historic environment, including world heritage. It is our duty under the provisions of the National Heritage Act 1983 (as amended) to secure the preservation and enhancement of the historic environment. There is also, in this case, the requirement in Article 4 of the 1972 Convention Concerning the Protection of the World Cultural and Natural Heritage to protect, conserve, present and transmit the values of the Stonehenge, Avebury and Associated Sites World Heritage Site (WHS). Our objective therefore is to ensure that the historic environment generally and, in particular, the WHS element is fully taken into account in the determination of this DCO.
The proposal raises a wide range of issues affecting heritage assets, including monuments scheduled under the provisions of the Ancient Monuments and Archaeological Areas Act 1979 (as amended) and structures listed under the Planning (Listed Buildings and Conservation Areas) Act 1990 along the length of the route, including the section that passes through the Stonehenge component of the WHS. Accordingly we consider that it would be very beneficial if the Examination Panel included a person with expertise in heritage matters, particularly World Heritage Sites and archaeology.
Current Position
The existing A303 trunk road has a substantial adverse impact on the Outstanding Universal Value (OUV) of the WHS and we accept the need to improve the road between Amesbury and Berwick Down. We have engaged with Highways England and other stakeholders to encourage a scheme which delivers benefits to the historic environment while avoiding and minimising adverse impacts. This applies particularly to the Stonehenge component of the WHS and the many other designated heritage assets, together with their settings, within and adjacent to the development limits.
We support the aspirations of the road scheme proposed in the DCO and believe that it offers the potential to deliver a beneficial outcome for the historic environment and to sustain and enhance the OUV of the WHS, by putting much of the current surface road into a bored tunnel and allowing archaeological features currently separated by the A303 to be appreciated as part of a reunited landscape. However if this potential is to be realised in practice we believe it is essential for a number of matters to be addressed satisfactorily and we set these out below.
Outstanding Matters
We note that PINs issued a S51 letter requesting various documents to be submitted and the Applicant has now responded. Although relationships between these documents have been clarified, we are concerned that a number of items, which we consider to be of key importance to the examination of the DCO, are not yet available. We believe that the following documents should be made available in advance of examination in order to inform the detailed consideration of the DCO:
• the Detailed Archaeological Mitigation Strategy (DAMS); • an Overarching Written Scheme of Investigation to accompany the DAMS; • a Preliminary Outline Environmental Management Plan for preliminary works including archaeological mitigation. The Applicant’s response to the S51 advice indicated that the REAC table 3.2a of the OEMP provided specific measures to apply to works. However this contains insufficient detail given the very high sensitivity of the proposal. • completed archaeological evaluation reports for the scheme. These are essential to a proper understanding of the archaeological impacts of the scheme and of the basis on which the DAMS has been drawn up.
We consider the applicant has not yet produced the necessary detail on some elements of the scheme which have the potential to affect adversely the OUV of the WHS. In particular there is an absence of detailed proposals for:
• design and visual representations for key elements of infrastructure within the WHS, including the western tunnel portal and its extension, the eastern tunnel portal, the articulation and form of open cutting retaining walls and the design, construction, form and appearance of Green Bridge 4; • proposed Non-Motorised User (NMU) routes, their articulation and form, and how they relate to sections of the A303 and A360 made redundant by the scheme; the removal of road infrastructure that will be made redundant by the scheme and the proposed reinstatement of land within the former highway boundary beyond that required for new NMU routes. There is also uncertainty about the relationship between the byways proposed by the scheme and the implications of the recent Experimental Traffic Regulation Order; • lighting, signage, fencing, drainage, balance ponds, landscaping including tree planting in and adjacent to the WHS; and • construction-period temporary infrastructure and reinstatement of affected land post-construction
We are also concerned about a lack of clarity and consideration of some aspects of the scheme and the resultant impacts that these could have including:
• tunnel limits of deviation: the location of the proposed western portal has been carefully considered – yet there is a proposed limit of deviation of up to 200m westwards, which is a significant variation in relation to the local topography. • potential restriction of future archaeological research within the affected part of the WHS (e.g. above the tunnel route). This would be contrary to the provisions of the Stonehenge WHS Management Plan, reflecting obligations accepted by the UK Government in ratifying the World Heritage Convention. Restrictions on future archaeological research could have an adverse impact upon the OUV of the WHS. • appropriateness of some of the provisions of the draft DCO (in light of the scheme traversing the WHS) to secure the protection of the historic environment and to ensure that there are mechanisms to implement and deliver the mitigation, benefits and legacy provisions and aspirations of the scheme. • adequacy of measures for consultation and engagement of Historic England in the Discharge of Requirements – in light of the impact on the WHS and archaeology.
There are also a number of points of detail within the documents submitted which raise issues of accuracy, clarity and consistency which should be resolved either in the written representations, statement of common ground or via the Applicant submitting an errata report as appropriate.
We would also note that the DCO encompasses compulsory purchase provisions which will have a bearing on Historic England landownership. The English Heritage Trust will be leading the response to this aspect.
Conclusion
For the reasons outlined above, Historic England wishes to register its interest in the examination of the A303 Amesbury to Berwick Down Road Improvement.