Representation by Campaign for Better Transport (Campaign for Better Transport)
- Date submitted
- 10 January 2019
- Submitted by
- Members of the public/businesses
The A303 at Stonehenge is promoted as being part of a programme of improvements to unlock benefits for the South West economy, local communities and the Stonehenge World Heritage Site (WHS). However, the scheme has serious problems that undermine these claims.
In the first instance there does not appear to have been any Strategic Environmental Assessment of the programme of improvements along the A303 / A358 corridor which we feel is essential to properly understand the full range of options and their impacts. This is an essential pre-requisite to ensuring the best possible solution is developed.
We do not consider that the full range of alternative options has been properly assessed, either at the corridor level or for this specific scheme.
We are particularly concerned with the way that Highways England appears to have ignored the advice and requests of UNESCO’s World Heritage Committee: • to take more time with the process to ensure the right solution is found and in recognition of the site’s international importance • to reduce the impact of the road on the WHS, including considering alternatives that would remove the road from the WHS altogether.
Consequently, we are concerned that the UK Government could be in breach of its international duty to protect the Stonehenge World Heritage Site if it proceeded to approve this development as proposed.
In addition, we are concerned about:
• the severe and irreversible damage to the WHS, its landscape, including archaeology, and its setting
• the loss of the view of Stonehenge from the A303
• the quality of the information provided for the examination
• noise and air pollution, including carbon emissions
• an inadequate consultation process including insufficient data to allow for informed responses
• misleading publicity in the scheme consultation and promotion
• ignoring public opinion in consultation responses
• inadequate time for the planning process including the registration period, the latter of which was one of the shortest registration periods for any road scheme submitted as a Nationally Significant Infrastructure Project and in addition took place over Christmas and the New Year when many people were otherwise occupied.
Significantly we do not believe that Highways England has made a compelling case for the need of the scheme for an area that suffers only seasonal problems. Although these might be severe over the summer months and occasionally at other times, overall the congestion experienced on this route is nothing like as severe as many other roads, particularly in and around urban areas.
The economics for the case do not stack up either and the scheme has a very low value for money and only has a positive benefit-cost ratio because of the inclusion of the monetised heritage impacts. Without this questionable and partial assessment, the scheme would not even cover its costs. Combined with the damage this road will cause, the lack of demonstrable need, the case for this road is fundamentally flawed. This sets it at odds with the National Policy Statement for National Networks and therefore it should be refused permission.