Representation by Stonehenge and Avebury WHS (Stonehenge and Avebury WHS)
- Date submitted
- 11 January 2019
- Submitted by
- Members of the public/businesses
Stonehenge and Avebury World Heritage Site Partnership Manager, World Heritage Site Coordination Unit
The Stonehenge and Avebury World Heritage Site Coordination Unit (WHSCU) welcomes the opportunity to register as an interested party. The role of the WHSCU is to coordinate the implementation of the Stonehenge and Avebury World Heritage Site Management Plan working with national partner organisations, the local authority, landowners, farmers, local communities and other stakeholders. In addition, it monitors and reports on the condition of the WHS and revises and updates the Management Plan.
The WHS Management Plan is endorsed by the major partner organisations who sit on the local WHS Committees and the WHS Partnership Panel but this registration is on behalf of the WHSCU. Partner organisations submit their own responses to consultations and register independently as interested parties.
A key role of the WHSCU is to offer impartial and independent advice on issues relating to the implementation of the Management Plan and its overarching aim, the protection of the WHS and its OUV. Alongside the statutory spatial planning system and designation of specific assets the development of WHS Management Plans represents a major element of the United Kingdom Government’s approach to fulfilling its obligations under the UNESCO Convention Concerning the Protection of the World Cultural and Natural Heritage to identify, protect, conserve, present and transmit WHSs to future generations (UNESCO 1972, Article 4). The ICOMOS Guidance on Historic Impact Assessment for Cultural World Heritage Sites (2011) suggests that proposals should be tested against policy frameworks and the Management Plan for the WHS. In its written representation, the WHSCU will highlight points based on a review of how the current proposed scheme aligns with the aims and policies set out in the WHS Management Plan and other elements of the relevant policy framework including Policy 59 of the Wiltshire Core Strategy.
Policy 1a of the Stonehenge and Avebury WHS Management Plan 2015 states the Government departments, agencies and other statutory bodies responsible for making and implementing national policies and for undertaking activities that may impact on the WHS and its environs should recognise the importance of the WHS and its need for special treatment and a unified approach to sustain its OUV. The WHSCU appreciates Highways England’s commitment to this policy and their considerable efforts alongside partner organisations to reflect this in their submission.
The scheme offers a remarkable opportunity to remove the harmful impacts of the A303 in line with the aims of the WHS Management Plan. The potential to create new and damaging impacts is however a real possibility. This needs to be avoided through a carefully designed, detailed scheme based on comprehensive modelling allowing accurate, expert assessment and meaningful mitigation.
In response to consultations during the development of the scheme the WHSCU underlined the need for a comprehensive and robust Heritage Impact Assessment (HIA) in line with ICOMOS guidance. We welcome the preparation of the detailed HIA undertaken to accompany the application. Several points however remain regarding both the alignment of the current scheme with the WHS Management Plan vision, aims and policies and the ability to fully assess this. The WHSCU unit would welcome the opportunity to expand on these points and relate them to the policy framework in its written representation. At the registration stage we have limited our comments to the bullet points below.
Summary of principal points
• The WHSCU welcomes the beneficial impacts of the scheme on the WHS and its OUV in the central part of the landscape where the A303 is underground. The written representation will expand on this and how it meets the aims and policies WHS Management Plan and the wider policy framework.
• A WHS landscape access plan will need to be developed and implemented to fully realise beneficial impacts in this central area in line with WHS Management policies.
• The approach to the management of byways open to all traffic (BOATS) within the WHS should be considered as associated development as it is essential to the achieving a beneficial outcome that aligns with the policies of the WHS Management Plan.
• Agreement on a treatment for the decommissioned A303 is required. The currently proposed 4.5m wide bound surface would not be compatible with the aims and polices of the WHS Management Plan nor its vision of a tranquil, rural landscape.
• The proposed Western Portal and expressway remains an adverse impact on the WHS and its OUV. The area of new dual carriageway continues to represent a significant impact on the relationship both visual and physical between monument groups and to the integrity of the WHS landscape.
• One of the criterion under which Stonehenge and Avebury qualify for WHS status is criteria i: The monuments of the Stonehenge, Avebury, and Associated Sites World Heritage Sites property demonstrate outstanding creative and technological achievements in prehistoric times. It is essential that modern engineering interventions are not dominant in the WHS landscape.
• Although the HIA indicates an overall slight beneficial impact on the WHS, it identifies potential slight adverse impacts on particular asset groups in the western part of the WHS. Where negative impacts are identified, these should be either avoided or mitigated in line with the policy framework. Mitigation should include detailed consideration of an extended tunnel or covered cutting.
• Modelling of alternative design solutions in this area such as a complete cover would help to assess the proposal and compare its benefits with other possibly more beneficial design options. It should assist in arriving at a recommendation that would address the decision of the World Heritage Committee in 2018 which urged the State Party “to continue to explore further design refinement, with a view to avoiding impact on the OUV of the property, including longer tunnel options that do not require an open dual carriageway cutting within the property and to avoid impact due to noise, lighting and visibility; and urges furthermore, the State Party to minimize the length of the culvert part of the tunnel in order to reduce the impact on the cultural landscape and the archaeology”. (UNESCO Decision: 42 COM 7B.32). The documentation appears to provide inadequate consideration of alternatives and justification for the current proposal.
• A virtual reality modelling of walking over the green bridge would provide valuable perspective alongside other evidence on how the scheme would impact on the experience of the WHS landscape and to what extend the proposed 150 m wide green bridge would mitigate this. The need for this modelling would of course be unnecessary if the cutting were to be covered or the tunnel extended.
• Currently there is an allowance for a 200m deviation for the western portal. Lack of clarity on limits of deviation could result in unforeseen negative impacts on the WHS and its OUV. An agreed detailed design allowing for adequate mitigation is required.
• Photomontage evidence has been relied on in the HIA. A more accurate assessment of impacts on the attributes of OUV (including attribute 5 - the siting of Neolithic and Bronze Age funerary and ceremonial sites and monuments in relation to each other, and attribute
6 - the disposition, physical remains and settings of the key Neolithic and Bronze Age funerary, ceremonial and other monuments and sites of the period, which together form a landscape without parallel) would include flythrough or virtual reality modelling. This approach would better reflect the impact on the experience of the attributes of those visiting and moving through the landscape. For an asset of this significance the most advanced modelling, where appropriate, is justifiable. Its results would also assist with detailed design of solutions.
• Green Bridge No 4 is 150 m wide and therefore unlikely to resolve completely the concerns set out above. Issues such as the impact of headlights passing under and out of the covered section have not yet been modelled. Further work should be done on identifying how to avoid impacts on the barrow groups and other monuments in this area in particular those at Winterbourne Stoke, the Normanton Down Group and the Diamond Group.
• Lack of design detail makes it difficult to accurately assess impacts. Although detailed design may not normally be provided at this point in the DCO process, the great sensitivity and international importance of the WHS landscape make it is essential that decisions are reached in way that will not result in adverse impacts on the WHS and its OUV. This could be as part of the DCO process or an agreed process of consultation with WHS curators and stakeholders.
• The design of lighting as well as road marking, signage and boundary treatments have the potential to either increase or mitigate the impact of roads on the surrounding landscape. It is advised that a set of design principals are adopted for roads within the WHS and its setting such as those agreed for the Avebury half of the WHS [Redacted] This will help to guide detailed design of the scheme and any future interventions.
• A detailed archaeological mitigation strategy is required as well as a detailed Environmental Management Plan.
• Detail on the implementation phase is also required to ensure adverse impacts on the WHS are avoided. Impacts on the Avebury half of the WHS need to be carefully considered and any necessary mitigation measures put in place.
• Restrictions proposed on land use above the tunnel are inappropriate in the WHS as they could represent a constraint to research. An approach to this challenge needs to be agreed with WHS partners as part of the DCO process.