Representations received regarding A303 Stonehenge
The list below includes all those who registered to put their case on A303 Stonehenge and their relevant representations.
The list below includes all those who registered to put their case on A303 Stonehenge and their relevant representations.
|Representation - click on an item to see more details|
Royal Society for the Protection of Birds
"any representation made will be with regard to the statement of common ground to be drawn up between the RSPB and Highways England"
Kate Tobin on behalf of Forestry Commission
"I will be representing the Forestry Commission who are the government's experts on forestry and woodland. I will be looking at the application in relation to the protection, improvement or expansion of woodland, where relevant. I will also be looking at the role woodland might play in improving the wider environmental, economic or social aspects of the proposal. "
Ministry of Defence
"Abnormal load access from A303 to Boscombe Down MOD establishment. Access is currently via Allington Track which is due to close under current proposal. Assurance of new road scheme access for abnormal loads required."
Public Health England
"PHE considers that the public health impacts likely to arise from the impact of the development on air, land and water have been adequately considered in the related sections of the submission. However, in its scoping opinion PHE highlighted that the potential for impacts from electric and magnetic fields (EMF) had not been addressed in the available documentation. PHE could not identify any subsequent consideration of EMF within the ES either. While human health impacts from EMF are not typically of concern for projects of this nature, we have registered an interest simply to assure that this hazard is considered (if only to be scoped out). PHE did not raise any issues regarding the wider determinants of health during the earlier consultation phases and as such will not at this later phase. "
Esso Petroleum Company, Limited
"Dear Sirs Esso Petroleum Company, Limited (Esso) and its agents, Fisher German, have been engaging with Highways England (HE) in relation their proposals for the A303 at Stonehenge (the Project) since 04 October 2017. The Project potentially impacts and interferes with Esso's existing underground 6” fuel pipeline which runs from Esso’s Fawley refinery near Southampton to Esso’s fuel distribution terminal at Avonmouth. This pipeline is one of a network of fuel distribution pipelines that form a critical part of the UK’s fuel supply network. Please note that Esso has funded, constructed and now operates this pipeline as a private company and not pursuant to any statutory undertaker powers. This pipeline is protected by easements secured through deeds of grant with the individual landowners and occupiers who host the pipeline. Construction works near or over the Esso pipeline can damage the pipeline or affect its future operation for the following reason. • Restriction of future access by surcharging the pipeline easement, thus rendering the pipeline unsafe should a fault or feature be identified by future in line inspections. • Third party damage during construction including strikes and pipeline failure due to repeated heavy plant crossing • Stress to the pipeline by overburdening without correct support Subject to the comments below, whilst Esso does not have concerns with the Project as a whole, Esso does have concerns over any impact to the operation of its pre-existing pipeline. Esso therefore objects to any interference with. extinguishment or suspension of the land rights relating to the pipeline or any Project activity that risks the operation of the pipeline. Barring infrequent maintenance, the pipeline operates on a continual 24/7 basis and interruption to its operation will have a significant impact on fuel supply in the south west of England and will have serious financial consequences for Esso. From Esso's engagement with HE to date, we understand that HE ‘s order limits at Ordnance Survey Grid Ref 407031,141374 encompass Esso's pipeline (and in particular the 6.125 meter “easement strip” where potentially damaging operations are prohibited by the land owner). This creates a risk to the pipeline. In addition HE has requested that Esso divert its pipeline in this area. The diversion will be in parallel to the existing line and constructed out of heavier wall pipe to allow for the over burden from the A303 Amesbury to Berwick Down Project. It is necessary to reflect that Esso will not gain future access to its pipeline as a result of the planned new road level. Any such works requires alternative land to be made available to us and requires careful planning and co-ordination to ensure the continued operation of the pipeline during the diversion works and wider Project construction works. There are therefore two areas in which HE and Esso will need to reach agreement. Firstly, the protective provisions to be included within the DCO regarding how HE will work in proximity to the pipeline asset, and secondly a diversion agreement to cover the funding, routing, procurement, associated land rights and construction of the requested pipeline diversion and subsequent abandonment of the diverted section of pipeline. Any such diversion will need to allow for the continued operation of the pipeline during the construction and commission of the diversion works. Esso fully expects these works to be at HE’s costs and in addition Esso expects, in the usual way, that HE will cover its advisor's costs in preparing and negotiating the protective provisions and the necessary agreements to cover the diversionary works. Esso have internally prepared drafts of the relevant protective provisions and diversion agreement. Esso's lawyers, VWV, first approached Pinsent Masons (lawyers for HE) for a cost undertaking on 22 August 2018. VWV finally received an acceptable undertaking for protective provisions on 24 October and sent Pinsent Masons Esso's proposed protective provisions on 22 October 2018. To date Esso or VWV have not received any response or comment on these proposals. VWV also requested on 31 October 2018 that an extended undertaking be provided to cover the diversion agreement. To date, VWV has not received this undertaking. Therefore, despite Esso's (and its advisors) best efforts and its proactive engagement with HE, Esso is unable to progress at this stage the necessary documentation or state it is close to an agreed position with HE. Esso is confident that the parties, acting responsibly, will be able to progress matters but at this stage Esso must make a relevant representation regarding the risk to its pipeline asset and Esso objects to any interference or risk by the Project to this asset and its related land rights. Esso looks forward to updating the Planning Inspectorate upon the state of negotiations and, if necessary, detailing our continued concerns in subsequent written representations to the Planning Inspectorate. "
The Historic Buildings and Monuments Commission for England
"Introduction Historic England is the government’s statutory adviser on all matters relating to the historic environment, including world heritage. It is our duty under the provisions of the National Heritage Act 1983 (as amended) to secure the preservation and enhancement of the historic environment. There is also, in this case, the requirement in Article 4 of the 1972 Convention Concerning the Protection of the World Cultural and Natural Heritage to protect, conserve, present and transmit the values of the Stonehenge, Avebury and Associated Sites World Heritage Site (WHS). Our objective therefore is to ensure that the historic environment generally and, in particular, the WHS element is fully taken into account in the determination of this DCO. The proposal raises a wide range of issues affecting heritage assets, including monuments scheduled under the provisions of the Ancient Monuments and Archaeological Areas Act 1979 (as amended) and structures listed under the Planning (Listed Buildings and Conservation Areas) Act 1990 along the length of the route, including the section that passes through the Stonehenge component of the WHS. Accordingly we consider that it would be very beneficial if the Examination Panel included a person with expertise in heritage matters, particularly World Heritage Sites and archaeology. Current Position The existing A303 trunk road has a substantial adverse impact on the Outstanding Universal Value (OUV) of the WHS and we accept the need to improve the road between Amesbury and Berwick Down. We have engaged with Highways England and other stakeholders to encourage a scheme which delivers benefits to the historic environment while avoiding and minimising adverse impacts. This applies particularly to the Stonehenge component of the WHS and the many other designated heritage assets, together with their settings, within and adjacent to the development limits. We support the aspirations of the road scheme proposed in the DCO and believe that it offers the potential to deliver a beneficial outcome for the historic environment and to sustain and enhance the OUV of the WHS, by putting much of the current surface road into a bored tunnel and allowing archaeological features currently separated by the A303 to be appreciated as part of a reunited landscape. However if this potential is to be realised in practice we believe it is essential for a number of matters to be addressed satisfactorily and we set these out below. Outstanding Matters We note that PINs issued a S51 letter requesting various documents to be submitted and the Applicant has now responded. Although relationships between these documents have been clarified, we are concerned that a number of items, which we consider to be of key importance to the examination of the DCO, are not yet available. We believe that the following documents should be made available in advance of examination in order to inform the detailed consideration of the DCO: • the Detailed Archaeological Mitigation Strategy (DAMS); • an Overarching Written Scheme of Investigation to accompany the DAMS; • a Preliminary Outline Environmental Management Plan for preliminary works including archaeological mitigation. The Applicant’s response to the S51 advice indicated that the REAC table 3.2a of the OEMP provided specific measures to apply to works. However this contains insufficient detail given the very high sensitivity of the proposal. • completed archaeological evaluation reports for the scheme. These are essential to a proper understanding of the archaeological impacts of the scheme and of the basis on which the DAMS has been drawn up. We consider the applicant has not yet produced the necessary detail on some elements of the scheme which have the potential to affect adversely the OUV of the WHS. In particular there is an absence of detailed proposals for: • design and visual representations for key elements of infrastructure within the WHS, including the western tunnel portal and its extension, the eastern tunnel portal, the articulation and form of open cutting retaining walls and the design, construction, form and appearance of Green Bridge 4; • proposed Non-Motorised User (NMU) routes, their articulation and form, and how they relate to sections of the A303 and A360 made redundant by the scheme; the removal of road infrastructure that will be made redundant by the scheme and the proposed reinstatement of land within the former highway boundary beyond that required for new NMU routes. There is also uncertainty about the relationship between the byways proposed by the scheme and the implications of the recent Experimental Traffic Regulation Order; • lighting, signage, fencing, drainage, balance ponds, landscaping including tree planting in and adjacent to the WHS; and • construction-period temporary infrastructure and reinstatement of affected land post-construction We are also concerned about a lack of clarity and consideration of some aspects of the scheme and the resultant impacts that these could have including: • tunnel limits of deviation: the location of the proposed western portal has been carefully considered – yet there is a proposed limit of deviation of up to 200m westwards, which is a significant variation in relation to the local topography. • potential 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, reflecting obligations accepted by the UK Government in ratifying the World Heritage Convention. Restrictions on future archaeological research could have an adverse impact upon the OUV of the WHS. • appropriateness of some of the provisions of the draft DCO (in light of the scheme traversing the WHS) to secure the protection of the historic environment and to ensure that there are mechanisms to implement and deliver the mitigation, benefits and legacy provisions and aspirations of the scheme. • adequacy of measures for consultation and engagement of Historic England in the Discharge of Requirements – in light of the impact on the WHS and archaeology. There are also a number of points of detail within the documents submitted which raise issues of accuracy, clarity and consistency which should be resolved either in the written representations, statement of common ground or via the Applicant submitting an errata report as appropriate. We would also note that the DCO encompasses compulsory purchase provisions which will have a bearing on Historic England landownership. The English Heritage Trust will be leading the response to this aspect. Conclusion For the reasons outlined above, Historic England wishes to register its interest in the examination of the A303 Amesbury to Berwick Down Road Improvement. "
"We are submitting more detailed representations (Via email: Our ref A303Stonehenge_RReps_11.01.19) to assist your understanding of the outstanding information requirements and issues of concern that we wish to be addressed by Highways England (the applicant). Our detailed relevant representation outlines where further work, clarification or mitigation is required to ensure that the proposal has no detrimental impact on the environment. In summary these areas cover the following topics: - Groundwater Protection and Land Contamination (Baseline Groundwater modelling*, drainage, construction impacts, site investigation, etc.) - Flood Risk Management (Baseline modelling/Flood Risk Assessment*, floodplain compensation) - Fisheries and Biodiversity (Environmental Enhancements, Protected species, Invasive species) - Protective Provisions (Environment Agency Protective Provisions / disapplication of permissions) Each section highlight concerns which we believe need to be addressed prior to a development consent order being granted. In some instances, it may be acceptable for additional information to be provided later, by requirement. *Groundwater and Flood Risk Modelling - To date there is still outstanding work on these matters being undertaken on behalf of the applicant It is imperative that these are finalised prior to the examination, as they underpin the Technical Reports submitted to support this application. Please note that at the point of submission of the relevant representations we do not have any agreed deadlines for the submission of this work outstanding work to support the DCO submission. Our current estimate is that it may be, due to the amount of outstanding work on the flood model, a minimum of 4 weeks from when the works commence for the information to be made available for us. We would highlight that due to the technical nature of reviewing this baseline modelling that it is likely to take several weeks for us to review. It is our opinion that the submission of evidence in relation to Groundwater Modelling and Flood Risk Modelling / Assessment must be required prior to the Examination for any Development Consent Order (DCO). As the evidence in the baseline has implications for the position in the Technical Reports, and therefore the positions in the Environmental Statement that support this submission. Our position on this matter that they should be resolved prior to examination would be supported by National Policy Statement for National Networks, section 5.96 which confirms the preference for these technical matter should be agreed prior to submission. "