Representation by Friends of the Earth (Friends of the Earth)
- Date submitted
- 10 January 2019
- Submitted by
- Members of the public/businesses
Relevant Representation from Friends of the Earth
The DCO should be rejected because:
- It fails to meet the tests set out in the National Networks NPS that:
“the Secretary of State must decide an application for a national networks nationally significant infrastructure project in accordance with this NPS unless he/she is satisfied that to do so would: • lead to the UK being in breach of its international obligations; • ... • ... • result in adverse impacts of the development outweighing its benefits; • be contrary to legislation about how the decisions are to be taken.
- The A303 Stonehenge scheme does not fulfil its stated objectives, specifically those of: “Cultural Heritage - To help conserve and enhance the World Heritage Site”
- in that it actually would cause serious and irreversible harm to part of the WHS, harm its setting and lead to loss in the site’s Outstanding Universal Value; and “Environment and Community - To improve biodiversity”
- in that there is a high risk of loss of two Annexe 1 breeding bird species, Stone Curlew and Great Bustard, from the locality as a result of construction and operation of the scheme
No alternatives that avoid harm to the WHS were properly appraised or consulted upon
The effects of the scheme have been consistently mis-represented during consultations, and feedback received from consultations not taken into account
The economic case is extremely weak and very strongly depends on a manufactured heritage “benefit” expressed in monetary terms
The impacts of dualling the entire A303/A30/A358 corridor – a longer-term plan to which the government has announced its commitment, and of which this scheme is a part - are not properly factored in. Future traffic growth and its impacts are calculated as though only this scheme and two others (A303 Sparkford – Ilchester and A358 Southfields – Taunton) were to be constructed. However the actual longer term aim includes another five schemes that are expected to be included in a future roads investment period, with the aim of creating a continuous dual carriageway expressway between the M3 and the South West. If carried out in its entirety this programme would fuel further traffic growth and transfer from other corridors that would in turn aggravate negative impacts on landscape, biodiversity, heritage, communities, air quality and climate change.
The decision to progress the A303 Stonehenge scheme, as part of the A303, A358 and A30 corridor, should have been subject to Strategic Environmental Assessment, as set out in European directive 2001/42/EC and The Environmental Assessment of Plans and Programmes Regulations 2004, but this was not done.