Representation by English Heritage
- Date submitted
- 10 January 2019
- Submitted by
- Members of the public/businesses
Application by Highways England for an Order Granting Development Consent for the A303 Amesbury to Berwick Down
English Heritage relevant representation to Planning Inspectorate
10th January 2019
- Introduction:
1.1 English Heritage (EH) is a charitable trust which cares for over 420 historic buildings, monuments and sites across the country on behalf of the nation. Our role is to conserve these historic sites to the highest possible conservation standards, in-keeping with their status as scheduled ancient monuments which form part of England's national heritage.
1.2 The prehistoric stone circle of Stonehenge is the best known site within our care and as part of the wider Stonehenge and Avebury World Heritage Site (WHS), it is a powerful witness to the once great communities of both the Neolithic and Bronze Age. We are responsible for conserving and managing a significant element of the WHS and welcome over 1.5 million visitors a year to Stonehenge from all around the world.
1.3 To date, EH has been involved in the A303 scheme as a stakeholder being represented on a number of Highways England groups including the Heritage Monitoring and Advisory Group (HMAG) and the Stakeholder Strategy Board. EH has offered our expert advice to Highways England as a major conservation body and operators of the globally iconic visitor attraction of Stonehenge.
1.4 EH is also an “affected person” under S59 of the Planning Act 2008 in that Highways England proposes to acquire EH land and land interests.
1.5 Removing the old Stonehenge visitor facilities adjacent to the Stones and the grassing over of the A344 in 2013 through EH’s Stonehenge Environmental Improvements Project have had a significant positive impact for the public and WHS. We consider that the current proposed A303 road scheme has the potential to further transform the Stonehenge part of the World Heritage Site and make significant improvements to the setting of the Stonehenge monument (which is one of the WHS’s attributes of Outstanding Universal Value (OUV)). Provided it is well designed and located sensitively, this scheme could greatly enhance the OUV of the WHS whilst simultaneously improving the setting of the Stones themselves, and people's experience of them.
- English Heritage interests
2.1 Impacts on Stonehenge and the World Heritage Site
2.1.1 EH is particularly interested in the design details and finishes of the scheme and how they might impact upon the WHS and its attributes of OUV. EH has taken note of the documents provided in the DCO application and understands that the design details of some elements are not provided at this stage. However, given the highly sensitive heritage environment and significance of Stonehenge and the WHS, EH considers that further information is required at this stage in order to properly assess the proposals in order to understand the physical and visual impact of any infrastructure within the WHS - to ensure all elements of the scheme are designed and located to allow the benefits of the scheme within the WHS to be fully realised. These details include the surfaces and extent of proposed Non-Motorised User (NMU)/PROW routes, fencing, signage, lighting, street furniture, the portals, articulation and form of the cutting and walls and the green bridge (within the WHS) design and any other significant changes/introductions.
2.1.2 EH intends to continue discussions with Highways England over the further details required.
2.1.3 EH understands that there is potential for the 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.
2.2 Access to the English Heritage Visitor Centre and Stonehenge
2.2.1 As well as conserving the site of Stonehenge, it is part of EH’s remit to welcome visitors to the site hoping that we will inspire people to value, visit and enjoy it. EH wants to ensure visitors have an easy route to the Stonehenge Visitor Centre, both during the construction phases and after the scheme is finished. Ease of access and signage to the Stonehenge Visitor Centre is key to this. The DCO and application papers do not give any detail on what road signage will be installed to ensure it is clear and intuitive for drivers wanting to visit Stonehenge. There is a lack of detail on the temporary infrastructure for the construction period therefore EH is unable to assess its impact on the WHS and our visitor operation.
2.3 Public Rights of Way, NMU routes and vehicular access across the World Heritage Site
2.3.1 EH supports the opportunity this scheme offers to connect rights of way and remove unnecessary vehicular access within the WHS so that there is increased access and potential for people to explore the landscape on foot or on a bicycle or horse (where appropriate) in order to enjoy and understand Stonehenge within its wider landscape setting.
2.3.2 During the public consultation process EH voiced its objection to the proposal to link existing byways open to all traffic (BOATS) 11 and 12 with a new byway open to all traffic which we believed would create a new line of traffic across the WHS and negatively impact upon views from and towards the Stonehenge monument. EH welcomes the removal of the link but still remains concerned about the negative impact of traffic within the WHS particularly past Stonehenge itself caused by the existing BOATs.
2.3.3 As outlined above, EH feels there is a lack of information about the form of various NMU routes across the WHS.
2.3.4 EH objects to the section of the proposed restricted byway running alongside the A360 within the boundary of the Stonehenge Visitor Centre complex, creating a 4-metre wide byway for pedestrians, cyclists and carriages within the boundary of the Stonehenge Visitor Centre. EH objects to this proposal for the following reasons: • Potential safety risks particularly conflict between non-motorised byway users and motorised visitors • Potential security risks • Potential negative impact on EH visitor operation • Potential negative knock-on impacts for A360/B3086 road users • Negative impact on design principles of the Stonehenge Visitor Centre • Negative impact on recent investment in car parking
2.3.5 There are alternative routes that are better that would not give rise to the impacts above, including following, but outside the boundary of the Visitor Centre site as suggested by EH. The proposal for the restricted byway across part of the Visitor Centre site was introduced late and there was failure to consult and liaise with EH on the proposed right of way route selected before submission. EH has suggested the alternative route outside of the boundary of the Visitor Centre site, which is the subject of discussions with Highways England. The fact that EH’s suggested alternative route mentioned above is outside the land identified for compulsory acquisition does not a constitute compelling reason in the public interest to compulsorily acquire the land and interests in question, given the impacts.
- Other Matters
3.1 EH’s last representation dated 13 August 2018 should be read in conjunction with and taken into account as part of these representations.
3.2 As an “affected person”, EH wishes to exercise its right to be heard at an examination hearing.
3.3 EH reserves the right to make additional representations including on any heritage assessments and impacts, impacts on EH’s property, land interests and operations including its Visitor Centre, impacts on its customers and the public, public right of way issues, any application documentation, the details and detailed design of the scheme and representations and documents of other people and bodies.
- Conclusion:
4.1 For the reasons outlined above, EH registers as an interested party in the examination of the A303 DCO application.