A303 Stonehenge

The views expressed in this page do not represent those of the Planning Inspectorate. This page consists of content submitted to the Planning Inspectorate by the public and other interested parties, giving their views of this proposal.

A303 Stonehenge

Received 10 January 2019
From The Stonehenge Alliance


The Stonehenge Alliance is a group of five national NGOs: Ancient Sacred Landscape Network, Campaign for Better Transport, Campaign to Protect Rural England, Friends of the Earth and Rescue: The British Archaeological Trust.

1. We submit that any approval of the A303 Stonehenge scheme would breach/be contrary to the following:
• The Planning Act 2008
• The World Heritage Convention and advice given by the UNESCO’s World Heritage Committee and international specialists
• Relevant national planning policy and guidance
• Local Plan policy for the World Heritage Site (WHS)
• The WHS Management Plan
• The Environmental Impact Assessment Directive (85/337/EEC)
• The Habitats Directive (Council Directive 92/43/EEC) and The Conservation of Habitats and Species Regulations 2017 (Habitats Regulations) in respect of the Salisbury Plain SPA and River Avon SAC
• The Bern Convention on the Conservation of European Wildlife and Habitats
• The Birds Directive (2009/147/EC) in respect of Annex I species
• The Aarhus Convention, in respect of genuine public participation in environmental decision-making
• The European Convention on the protection of the Archaeological Heritage
• The European Landscape Convention
• The SEA Directive (European Directive 2001/42/EC) and The Environmental Assessment of Plans and Programmes Regulations 2004 (Statutory Instrument 2004, no. 1633) on the environmental impacts of the planned A303/A358 corridor improvements programme alone and in combination

2. In respect of the above, and in addition, we have concerns and/or objections on the following:

• severe and irreversible damage to the WHS, its archaeology, landscape and setting
• loss of archaeological evidence
• threat to World Heritage designation
• insufficient understanding of the archaeological landscape and its potential meaning to those who developed it over time
• insufficient protection of the WHS landscape for future generations to enjoy
• inadequate heritage impact assessment (omits full assessment of impacts on WHS and its OUV)
• loss of the view of Stonehenge from the A303
• insufficient consideration of value and susceptibility of internationally acclaimed landscape to adverse impacts as required under GLVIA3
• significant locations and visitor-receptors ignored in viewpoints considered, e.g., the A303
• LVIA misrepresents landscape and visual effects and omits adequate mention of adverse impacts in summaries
• problems of groundwater flow and contamination resulting from tunnel construction leading to adverse impacts on water quality and the integrity of the SAC
• potential damage in tunnel construction to archaeology and the WHS landscape
• threats to Annex I Stone curlews and Great Bustards from construction and operation of the scheme
• noise and tranquillity
• inadequate consultation, including insufficient data for informed responses
• misleading publicity/advertising in scheme consultation and promotion
• weight of public opinion disregarded in responses to consultation
• inadequate length of time for the planning process including the registration period
• information still lacking on ground characterisation and groundwater data from boreholes and associated geotechnical work carried out for Highways England during 2018.
• information lacking on archaeological evaluation
• need for the scheme is not compelling
• no economic case for the scheme on transport grounds
• weak economic case for the scheme overall
• inadequate range of options assessed
• implausible calculation of monetised heritage benefit
• impacts of tunnel closures
• climate change