Representation by CPRE South West (Campaign to Protect Rural England) (CPRE South West (Campaign to Protect Rural England))
- Date submitted
- 10 January 2019
- Submitted by
- Members of the public/businesses
CPRE SW represents the seven county branches in the South West of England and thousands of individual CPRE members. These comments add to and reiterate the concerns/objections already stated in our consultation responses of 28th February 2017 & 17th April 2018. CPRE SW objects to the proposed A303 Stonehenge Expressway for the following reasons: • Causing severe and irreparable damage to the WHS, its archaeology and setting, described by UNESCO as a ‘landscape without parallel’. UNESCO’s international advisers say this scheme should not go ahead.
• It will not as purported improve the overall tranquillity and setting of the WHS.
• Images used do not show the negative impacts from signage, lighting and other infrastructure, and the predicted increased traffic.
• Damage to the archeological landscape and heritage features that remain including these still to be examined and discovered.
• Failure to protect unique assets for future generations to enjoy.
• Inadequate heritage impact assessment
• Being contrary to relevant national planning policy, local plan policy and the WHS management plan, and to national and international legislation and conventions.
• Negative impacts on the integrity of the River Avon SAC from construction of the tunnel (pollution and changes in groundwater movement).
• Threats to the integrity of the ANNEX 1 Stone Curlew and Great Bustard population (Salisbury Plain SPA) from construction and operation of the road, and in breach of the Habitats Regulations and Habitats Directive.
• There is no convincing evidence to show that the scheme would meet its fourth ‘broad objective ‘to improve biodiversity’
• The consultation has throughout been flawed with inadequate consideration of options, including non-road transport approaches and public transport.
• A paucity of evidence and analysis has been provided for informed responses, and to justify the suggested ‘benefits’, including benefit or disbenefit to local communities
• Will be damaging to local tourism businesses and the local economy.
• Now to state that a road through the World Heritage Site is the “preferred route” is highly misleading.
• The A303/385 scheme overall is poor value for money and even without the questionable, and from our evidence, ill-conceived benefit of the ‘heritage contingent valuation’, the economic case is extraordinarily weak.
• No convincing evidence that the overall scheme would bring economic benefit to the South West.
• The predicted increase in traffic on the route ranges from 20% to 40% or more, though the A303 Public Information brochure “improving journeys” makes no mention of this.
• The Infrastructure Commission identified the need for connectivity improvements, and Highways England’s own stats show that the need is for better sub regional business and leisure connections and the benefits of highway and public transport options have not been considered together.
• No assessment of the cumulative effects of the programme in terms of increased traffic and emissions.
Given the above it is impossible to understand how this scheme has been justified, and we remain astounded that Government wishes to take forward a development that will damage forever what is one of the most important cultural places nationally and globally.