Stonehenge Public Inquiry, A brief summary, May 2004
Last updated: 25 May 2004
We are very grateful to Kate Fielden of the Stonehenge Alliance for writing this summary of the Stonehenge Public Inquiry.
The 12-week Public Inquiry into draft Orders for the A303 Stonehenge Improvement Scheme ended on 11 May. The Stonehenge Alliance, a group of environmental and archaeological organisations, joined forces some time ago to oppose the road proposals and made a joint case for objection.
The Alliance gave specialist evidence on the following issues: planning matters (CPRE); archaeology, legal considerations, and the process of decision-making on the scheme (Rescue and CPRE); transport considerations (Transport 2000 and Friends of the Earth); landscape and spiritual issues (The Pagan Federation and The Ancient Sacred Landscape Network); and hydrogeology (Stonehenge Alliance, including The UK Rivers Network). We employed experts in hydrogeology and transport economics, and paid for some legal assistance in preparing our case. Our costs were in the region of £11,000 and funds are still needed to meet them. The scope and length of the Inquiry were such that it would have been beyond the means, in terms of time and expense, of any of our individual organisations to cover all of the issues satisfactorily; and presenting a joint case proved helpful to ourselves and to the Inspector.
The Highways Agency's (HA) case was largely based upon the visual and environmental improvement the 2.1km bored tunnel would bring to the immediate landscape setting of Stonehenge. The Agency had been asked in 1997 by English Heritage to work up the road dualling project (then with a 2km cut-and-cover tunnel) and indicated that without the promised £70m input from the DCMS, the scheme would not have been placed in the Roads Programme. This naturally gave rise to questions about the value placed on the heritage by the promoters and supporters of the scheme -- to which no sensible answers were given. We noted in our evidence to the Inquiry that English Heritage had advocated a 4.5km tunnel at the 1995 A303 Planning Conference, so that the archaeological heritage of the World Heritage Site (WHS) would be adequately protected, and that little weight could now be given to its support for proposals that would not meet that purpose.
The principal supporters of the scheme were English Heritage and Wiltshire County Council, who made representations at the Inquiry, and the DCMS and Salisbury District Council who presented written evidence. There were numerous objectors, including the National Trust, ICOMOS-UK, the Council for British Archaeology (CBA), the Prehistoric Society, and the Wiltshire Archaeological and Natural History Society (WANHS).
The National Trust, earlier supporters of the 2km cut-and-cover tunnel scheme and now objectors to the 2.1km tunnel on environmental and archaeological grounds, came forward with an entirely unexpected suggestion for a 2.9km bored tunnel that would extend 600m east of the Published Scheme's tunnel portal on King Barrow Ridge, to include the Avenue, and 200m west of the proposed western tunnel portal. This suggestion was not officially put forward as an alternative and was therefore not fully examined by the Inquiry. It was not supported by the Alliance, or by most other objectors, since it would leave the western approaches to the WHS irremediably damaged. The Trust mentioned the inalienability of its land holding at Stonehenge but made no firm commitment to challenge any attempt to obtain land by Parliamentary procedure.
At the close of the Inquiry, The Alliance's views remain unchanged: the road scheme would inflict severe and permanent damage on the WHS and ought not to be allowed. Though the place has been much damaged in the past, that is no reason to implement a scheme that English Heritage described as no more than 'the best we have on offer' and falls far short of protection and rehabilitation of the Stonehenge landscape. Our case against the scheme was given in our Closing Statement to the Inquiry and it can be summarised as follows.
The World Heritage Convention demands that the whole WHS should be protected and conserved for future generations. The Nomination Document (1986) mentions the Stonehenge 'landscape without parallel in Britain or elsewhere' as an integral part of the Site; thus it is unacceptable to suggest that the central area is more important or more worthy of protection.
The protection offered by the Convention is supported by Government guidance in PPG15, which elevates the WHS designation to a key material consideration in planning terms and points to the requirement for WHS management plans. This advice is reflected in the Regional Planning Guidance and in County and Local Plan policies which argue strongly for the protection of the whole WHS against development that would damage its archaeology and setting.
We drew the Inspector's attention to the outcome of the Coal Contractors Ltd v the Secretary of State and Northumberland County Council legal case, concerning proposals for opencast coal mining temporarily affecting the setting of Hadrian's Wall WHS. The appeal against refusal of planning permission was rejected. At Stonehenge, the temporary effects of the scheme (extensive construction compounds, haul roads, excavation and construction work in Stonehenge Bottom, etc.) would affect the setting of the WHS and the Site itself for up to 4 years, while other damaging effects would be permanent.
The Stonehenge WHS Management Plan, with its Supplementary Planning Guidance status, appeared strong in defence of the WHS. There was no disagreement that the document was very relevant, despite differences in interpretation of crucial Plan objectives concerning the treatment of roads and traffic within the WHS. Objectors pointed to Management Plan aims for removal of the A303 from E of the Avenue to W of Longbarrow Crossroads (some 4.5km). The Stonehenge 'Master Plan' road scheme, developed outside the context of the Management Plan and offering only a 2.1km tunnel, would not meet this aim, although the Highways Agency and English Heritage argued that the Management Plan and Master Plan were compatible in this respect. The Published Scheme would destroy and damage archaeological remains along its overland route, possibly including as yet undiscovered important sites; it would also compromise the settings of the WHS and many of its monuments. There would be substantial residual scarring of the land surface.
The decision to opt for a short bored tunnel was taken by Ministers in December 2002 when it had long been decided, on grounds of cost, to proceed with a short tunnel. By this time, the National Trust had expressed its preference for a long (4.5km) bored tunnel -- making it all the more surprising to learn of their last-minute reversal of concern to protect the whole WHS.
The DCMS, whose role may be seen as that of a developer of the Published Scheme, heads the UK Government's delegation to UNESCO's World Heritage Committee. It appears that the Committee had not been informed of the damage the road scheme would cause to the archaeology and setting of the WHS. ICOMOS International, now in possession of the facts, opposes the scheme and has indicated its views to the World Heritage Committee. Meanwhile, it seems that the House of Lords, advised by Lord Whitty in July 1998, remains under the impression that the road scheme would result in no damage to archaeological sites.
English Heritage and the Highways Agency sought to undermine the value of the WHS by suggesting that only the Scheduled Neolithic and Bronze Age sites and monuments were of 'outstanding universal value' (OUV). They pointed out that the road scheme would avoid direct damage to important sites.
We and other objectors support ICOMOS-UK's view that although some parts of the Site are not of OUV, for example, the car park and visitor-centre, the contextual and physical interrelationships between monuments and sites are of OUV, and this naturally includes the spaces in between them. Thus 'layers' of OUV can be identified which, taken together, give OUV to the WHS as a whole.
'Setting' was a much-debated issue at the Inquiry, not least because the HA and EH, unlike archaeologist objectors, considered impacts on setting to be 'indirect'. The HA divided 'setting' into three elements: archaeological context, and visual and aural considerations. All significant sites were given scores according to the scheme's magnitude of impact on each of these elements but, owing to a subsequent balancing exercise, a poor visual setting could be neutralised by better scores for noise and context. Sites with no visible upstanding remains, such as the Avenue E of King Barrow Ridge, were said to have no setting. Sites inside and outside the WHS were dealt with in the same manner and there was no consideration of the setting of the WHS as a whole.
The views of ICOMOS-UK, the CBA, the Prehistoric Society and WANHS on the importance of setting, including the concept of a progressive setting experienced as one moves between monuments within the WHS, were entirely convincing. It was suggested that prehistoric people might have considered the River Avon to be a link between Durrington Walls and Stonehenge and that any processional route between these henge monuments -- or indeed elsewhere in the landscape -- might have been significant, in terms of setting, to those who passed along it. Challenging ideas of this kind could lead to greater enhancement of visitors' experience of the wider landscape.
Archaeologists Alasdair Whittle, Mike Parker Pearson and Colin Shell underlined the importance of new work being undertaken in studying the relationships between monuments and landscape, and the significance of the settings of unseen archaeological remains. The discovery of the important below-ground remains of palisaded enclosures at Avebury highlights the considerable potential for future discoveries at Stonehenge. New and currently developing investigations and techniques have helped to underline the wealth of archaeology that survives at Stonehenge. Lidar survey allows construction of a digital terrain model with clear definition of only very slightly upstanding archaeological remains. Lidar images of the western part of the WHS provided an astonishing record of the way in which the Neolithic and Bronze Age monuments and landscape were deliberately linked. Barrow cemeteries, for example, at Normanton Down and Longbarrow Crossroads, were clearly designed to be intervisible -- a feature that could be better revealed to visitors by removal of present-day woodland. These links would be physically severed and visually compromised by the proposed above-ground dual carriageway and other road works.
We were particularly concerned about the impact of the scheme in the eastern and western parts of the WHS, to either side of the proposed short tunnel. To the east, the ancient Avenue would be severed to the extent that it would never be wholly practicable to restore it as a route to be followed and understood by visitors. Although the land involved is now in private ownership, it is conceivable that ownership could change and the route of the Avenue here might eventually be more clearly marked.
On the west side of the WHS, a grade separated junction some 300m across, with roundabouts flanking a dual-carriageway underpass, slip roads, a new byway close to the long barrow, and considerably increased lighting and signage, would impose a very large and inharmonious development at the western entrance to the WHS and beside the magnificent Winterbourne Stoke barrow group.
Visitors entering the WHS from the west, either by road or along the newly created byway, would have a clear view of the junction; walkers would pass alongside the dual carriageway and see a long barrow perched on top of the west tunnel portal. Vehicles (exposed at above ground level over some length of dual carriageway) would be visible from Stonehenge Down and from barrows at Normanton Down. The sound of traffic would still be heard across the landscape and road fences would remain in full view.
The Highways Agency did not challenge our view that the scheme would be at odds with critical demands of the Management Plan -- relating to conservation of the heritage of the whole WHS and the enhancement of its landscape setting; recognition of the importance of inter-visibility of sites and the gradual change in visual relationships as one moves through the landscape; identification of opportunities for enhancement of sites in the wider landscape to improve visitor-appreciation and understanding; and recognition of the 'fundamental importance' of Stonehenge and its landscape as 'a place that continues to offer sanctuary and spiritual sustenance'. No Historic landscape Character Assessment had been undertaken, as required by the Management Plan. No photomontages were produced to show the layman what the completed scheme would look like from critical viewpoints within the WHS.
Turning to hydrogeology, there are concerns about lateral groundwater drainage and the concrete slab construction in Stonehenge Bottom. The shallow depth of a short tunnel here would require surface excavation and insertion of a large concrete slab to support the tunnel roof. The tunnel, being close to the water table, could cause changes in groundwater flow. A longer tunnel, constructed by a (deep) tunnel boring machine below the water table, could present fewer problems. Contamination of the groundwater arising from a possible incident in the tunnel could not be ruled out. A serious incident in the tunnel could lead to pollution of the River Avon candidate European Special Area of Conservation (cSAC), a site protected under European law. A full Appropriate Assessment of the potential effects of the scheme on the cSAC, alone or in combination with other projects in the area was not presented to the Inquiry.
Although the road scheme has been promoted as 'an exceptional environmental scheme', it clearly falls short of that aim in terms of protection of the exceptional, WHS environment. The Government's intention to dual the A303 from the M3 to Exeter is well understood, despite the fact that the Stonehenge section of the A303 was deliberately excluded from the London to South West and South Wales multi-modal study that recommended dualling. The HA's assertion that the Published Scheme would not have been brought into the roads programme on transport grounds alone is accepted for it was agreed that the economics of the scheme in terms of transport were not 'robust'. We have no sensible estimate of how much induced traffic would result from road improvements at Stonehenge or along the A303 as a whole: this figure could have a further impact on the economic assessment. The scheme therefore stands or falls on its claimed environmental benefits (which have not been assessed in terms of monetary value). We argued that current changes are taking place in transport policy, with Government recognition of the necessity for national road user charging after 2010, in response to the much higher than expected levels of forecast traffic growth and congestion figures for the decade 2000--2010. Other methods of addressing traffic congestion on the A303, such as road-user charging and traffic demand management measures ought to be considered.
Christopher Chippindale, for the Prehistoric Society, drew attention to the regrettable outcome of precipitate development undertaken during the last century at Stonehenge. At the same time there has been gradual recognition of the value of the wider landscape, culminating with the WHS designation. A narrow-minded approach has allowed English Heritage and the DCMS to endorse road proposals that are oriented solely towards improving the environment of the henge. The same under-valuation of the WHS can be seen in the National Trust's proposals for an alternative that would compromise an area in the western half of the WHS shown by archaeologists at the Inquiry to have been of particular significance during the Neolithic.
We, like other objectors, see no reason why the Government should be in a hurry to implement damaging road improvements at Stonehenge. There is no urgency for road widening on transport grounds. More time is needed in which to find a solution that inflicts no further harm on the WHS.
Both sides at the Inquiry agreed that the removal of roads from as much as possible of the surface of the WHS would be better than the Published Scheme. The Alliance shares the view of ICOMOS-UK and others that the Published Scheme would be so damaging that it should be rejected without consideration of the benefits it might bring to the central area of the WHS, for these would be gained at too high a cost to the remainder. We are not, however, advocating a 'Do Nothing' situation. We would be prepared to consider serious proposals for a 4.5km tunnel or for alternative routes outside the WHS. Though alternative route proposals were brought to the Inquiry we did not have the resources to assess them thoroughly.
A fundraising appeal for a 4.5km tunnel and the potential to raise funding through, for example, a tunnel toll, ought to be considered. Damaging the WHS simply because a better solution cannot be 'afforded' is unacceptable; and we would welcome any opportunity to work with others towards a programme of protection, conservation and repair, in line with Management Plan objectives.
The Inspector aims to complete his report and make his recommendation to the Secretary of State at the beginning of September. We hope that the final decision on the Stonehenge road scheme will not be one that serves as a permanent and prominent reminder to poorer countries of how not to treat a heritage site that is of outstanding international significance to mankind.