Tuesday 28 March 2017

Questions about Planning Application 17/00280/VAR

What date was it registered? I think it wasn't on the Wiltshire Website until the last week of March 2017 but the document claims to have been Registered on 23rd January 2017



And it appears on the Weekly List for 23rd January





But the search function on the Wiltshire website says it was registered on 23rd March


And the Document properties also show 23rd March


And the MOD were sent the documents on the 23rd of March as well

Which ties in better with the consultation period.

But English Heritage are asking for a year's grace prior to opening the path by the 1st October 2017 - so why the delay in asking for permission?

Monday 27 March 2017

A344 Permissive Path Planning Application



STONEHENGE ENVIRONMENTAL IMPROVEMENTS PROJECT
Variation of Condition Application

The application seeks approval to vary condition 27 of planning permission S/2009/1527/FULL (dated 23/06/10) for the decommissioning of existing visitor facilities and a section of the A344; the erection of a new visitor centre, car park, coach park and ancillary services building and related highways and landscaping works.

The variation of condition 27 is to allow to allow a further year for the proposed permissive path to establish itself on the grassed over section of the former A344 near Stonehenge prior to it being open to the public as a pedestrian and cycle route by 1" October 2017.

See http://www.sarsen.org/2017/03/english-heritage-plans-to-block.html for more details on this path.

LOWER PALAEOZOIC SANDSTONE DEBITAGE FROM THE STONEHENGE LANDSCAPE

The petrography, geological age and distribution of the Lower Palaeozoic Sandstone debitage from the Stonehenge Landscape

by Rob Ixer, Peter Turner, Stewart Molyneux, and Richard Bevins

Wiltshire Archaeological & Natural History Magazine, vol. 110 (2017), pp. 1–16

Abstract:

The three major groups of debitage found in the Stonehenge Landscape are dolerites, rhyolitic tuffs (almost exclusively from Craig Rhosyfelin, now designated as Rhyolite Group A–C) and 'volcanics with sub-planar texture' now designated as Volcanic Group A and Volcanic Group B. The only other significant debitage group, but only accounting for about 5% by number, is an indurated sandstone now called the Lower Palaeozoic Sandstone. The Lower Palaeozoic Sandstone is a coherent lithological group with a slight metamorphic fabric and is a fine-grained feldspathic sandstone with characteristic dark, mudstone intraclasts. Palynological (acritarch) dating of the sandstone suggests that it is Late Ordovician or younger whilst the petrography suggests that it is older and more deformed than the Devonian (ORS) sandstones exposed in South Wales. Spatially, as with all the major debitage groups, the Lower Palaeozoic Sandstone is widely and randomly distributed throughout the Stonehenge Landscape; temporally, almost none of the debitage has a secure Neolithic context but some may have later Roman associations. The debitage cannot be matched to any above-ground Stonehenge orthostat but may be from one or two buried and, as yet, unsampled stumps. The lithology is believed to be from an unrecognised Ordovician (or less likely Silurian) source to the north or northeast of the Preseli Hills. Although there has been confusion within the archaeological literature between the 'Devonian' Altar Stone, Lower Old Red Sandstone (Devonian) Cosheston Group sandstone and the Lower Palaeozoic Sandstone, all three are very different lithologies with separate geographical origins.

Friday 17 March 2017

Stonehenge Ticket Prices Up At Three Times The Inflation Rate, Again.


These are the new online prices for tickets to Stonehenge   You will be encouraged to add another 10% or so as a Gift Aid contribution. Turning up at the site without tickets you will be charged more for the tickets, about another £1 a person.

The price to rent an audio guide increased in 2016 from £2 to £3 - the tour can be downloaded for free from Apple App or Google Play Stores and then played on your own device.










The average increase in price is 6.58% this year 
The Consumer Prices Index increase for the year to February 2016 was 0.3%  from then to Feb 2017 was 1.8%

Monday 13 March 2017

English Heritage Plans to Block Historic Path at Stonehenge - Update

31 JULY UPDATE - the threat of the fence move and change has been averted

RE: P00557101 SVEP works Stonehenge variation at bus drop off point 17 01217 VAR HE planning advice

The planning agent has confirmed the following:

 Historic England comments – I confirm that the existing post and wire fence between the southern platform and the monument field to the south is to be retained as a post and wire fence.

 WHS Officer comments – I confirm that the proposed movable tensile barrier system would be of similar design to the existing barriers currently in use around the bus turnaround areas.

Lucy Minting
Senior Planning Officer



In November 2016 I reported on English Heritage's plans and how they block the historic footpath promised on the route of the A344. http://www.sarsen.org/2016/11/english-heritage-plans-to-block.html

In February 2017 English Heritage have gone back to Wiltshire Council with new plans for a variation on their plans for an improved Visitor Transit System and have kept, with small variation the plan to block the footpath.

This time not only have I objected* for the reasons below but so have Historic England

Historic England Advice
These proposed variations to planning consent 16/03988/FUL are largely acceptable with one exception. The proposal to vary the previously agreed post and wire fence on the south side of the Stonehenge-end visitor pick up/drop off would result in an adverse visual impact to views across this part of the WHS, including views towards Stonehenge.


Recommendation
Historic England has concerns regarding the application on heritage grounds.
We consider that the proposed variation to fencing at this location will have an adverse visual impact on this part of the WHS and in certain views towards Stonehenge. This would be contrary to the previously agreed principles of the Stonehenge Environmental Improvements Project (SEIP) and the Stonehenge Visitor Enhancement Project (SVEP) to minimise or remove visible infrastructure from the landscape. These principles are enshrined within the 2015 Stonehenge and Avebury WHS Management Plan, and whilst at face value a very minor issue, the proposed fence variation is in such a sensitive location as to run counter to the guidance in NPPF pargaraph 137 that new development within WHSs should be supported where it enhances or better reveals significance. A post and rail fence would not achieve this.



The background: English Heritage has failed to open the permissive path they are obliged to provide on the route of the old A344, which should have been done by summer 2016. They claim the grass surface won't be ready until 2017. It is no secret they wish they didn't have to provide this path despite it being an important historic route which will boost the sustainability and local access of the site.



The latest impediment to the permissive path is hidden away in a document where they are asking Wiltshire Council to approve a variation in how the Visitor Transit System works at the monument.

One small detail is they want to move a stock fence 3m from the field edge onto the route of the A344. There is no practical reason to do so apart from narrowing the A344 route. Leaving the fence where it is and using crowd barriers is more sensible if they want to corral the visitors.

But if they do erect the stock fence there then, as they point out, there is no room for pedestrians to walk along the route of the A344.





Click plans to enlarge


Quote from the planning document:

As a result of this layout people visiting the stones on foot along the A344 will cross Byway 12 and then cross the entrance to the bus turning circle east of Byway 12 to access the monument field (see Appendix A).  This is because there is not enough space on the southern VTS platform area to accommodate the loading of passengers on the bus and walkers coming from the west.  Visitors wishing to walk back to the Visitor Centre will walk along the southern platform and then cross Byway 12 onto the A344 designated pedestrian route.


Planning Condition these revised plans are designed to meet:

Planning Condition 4 states: 
‘Notwithstanding the submitted drawings showing the proposals for directing pedestrian arrivals in the vicinity of the A344 junction with Byway 12, prior to the commencement of the development hereby approved further details shall be submitted to and approved in writing by the Local Planning Authority demonstrating how pedestrians using the signed and lined route on the southern side of the A344 can access the Stones without having to cross the A344 or to walk within the route used by the Visitor Transit System to the east side of Byway 12. The approved details shall be implemented before the proposed bus turning arrangements are brought into effect.  

Note the requirement is that visitors should not have to walk within the route and yet the plans require them to do so  purely because the fence move makes the path too narrow. If the fence isn't moved then there is no problem and the planning condition could be met.

The only logical purpose of the fence move is therefore to prevent the permissive path being established. Wiltshire Council must not fail in their duty and approve these plans.

The suggestion the fenced off area is to allow the establishment of "swathes of meadow planting helps enhance the naturalistic feel of the space whilst helping integrate the facilities into the natural landscape." doesn't make sense as the area will be in a sheep field and English Heritage have shown us with the rest of the A344 it takes many years to establish such grass and it mustn't be trodden on during the establishment phase. A temporary barrier and leaving the stock fence where it is  would be more suited for grass establishment.

To comment by email click  Wiltshire Council

* My objection email:

The connected application 17/01217/VAR has plans which show their intended solution to the Condition and whilst they are an improvement on previous plans they still fail to meet the requirements of the planning committee.

To recite: Notwithstanding the submitted drawings showing the proposals for directing pedestrian arrivals in the vicinity of the A344 junction with Byway 12, prior to the commencement of the development hereby approved further details shall be submitted to and approved in writing by the Local Planning Authority demonstrating how pedestrians using the signed and lined route on the southern side of the A344 can access the Stones without having to cross the A344 or to walk within the route used by the Visitor Transit System to the east side of Byway 12. The approved details shall be implemented before the proposed bus turning arrangements are brought into effect."


The new plan whilst retaining the existing gate to the south of the road, which is an improvement, still has a crossing area just to the east of the gates within the route used by the Visitor Transit System.  The need for this crossing, which is contrary to the planning instructions, is purely because of the bottleneck introduced into the area by the erection of the new stock fence 3m further north east of the existing fence. If this fence is not moved but just renewed in its existing position and, as proposed, the existing gate is retained then there is no need for the crossing area. It is a simple fix that would allow the proposed plans to meet the requirements of the planning condition.

Sunday 12 March 2017

Tuesday 7 March 2017

Brer Rabbit and the Tunnel - a modern fable



Department of Transport
Confidential briefing note
A303 upgrade

  1. We promised the South West Lib Dems a fast A303 to keep them happy in the last parliament – most of them lost their seats but the deal can’t be unravelled as new Tories down there need to show we care for the peninsular.
  2. Southampton – Salisbury – M3 and M4 these routes need upgrading for trade.
  3. Stonehenge is the blocking point on the A303.
  4. Divert the A303 nearer to Salisbury to pick up traffic as above cuts the cost of Salisbury road upgrades and it is cheaper than keeping the beardies happy around Stonehenge.
  5. English Heritage and National Trust desperate to keep main road near Stonehenge for revenue reasons – “Tourists won’t leave the major road to visit a bunch of rocks”.
  6. Operation “Brer Rabbit” – put forward a Stonehenge Tunnel Scheme that we claim we desperately want will keep EH and NT onside. But make it outrageous to upset beardies by blocking out Winter Solstice view – subtle enough to get past the headquarter wonks at EH and NT but will be picked up as we consult (we can make sure of that.)
  7. "Very sorry, we tried" to EH & NT. We get cheaper road where we want it, and any complaints as we put new road plans in we can blame the Stonehenge crowd. 
  8. Result: Highways England happy, Road transport lobby happy, Road blockers happy, South West happy, Southampton and Salisbury happy, Treasury happy - just English Heritage will be unhappy but they can't say anything as they have to show they care more for the monuments than the cash.


International Astronomical Union response to the Stonehenge Tunnel Proposals

Commission C4 (World Heritage and Astronomy) of the International Astronomical Union

1. To what extent do you agree with our proposed option?
Tend to disagree

Please provide any comments to support your answer for question 1:
The proposal clearly has benefits, in particular by removing the A303 from the landscape immediately to the south of Stonehenge. This would not only help restore the monument to its landscape setting but would also eliminate the stream of vehicle lights passing within 250m of the monument which are so intrusive at night.
Nonetheless, the proposal places the western tunnel portal directly on the solstitial sightline to the SW from Stonehenge. In addition, the southern route option seems to envisage roughly 2 km of open dual-carriageway road running out broadly along the sightline together with a new two-level road junction, also placed within the sightline. All this appears to be directly contrary to Policy 3c in the 2015 Management Plan and viable strategies for implementing it (see §7). It also raises serious concerns that the integrity of the SW sightline from Stonehenge could be permanently destroyed, eliminating forever the possibility of visitors to Stonehenge once again seeing the winter solstice sun setting behind the distant natural horizon along the axis of the monument. It is the view of this Commission that we should be aiming to preserve this key sightline for eternity. There are currently stands of trees blocking the sightline but trees are temporary; on the other hand, the landscaping accompanying major roadworks could compromise the sightline irreversibly.

Key features of the proposed option
2. To what extent do you agree with our proposed location of the eastern portal?
Tend to agree

The location of the eastern portal does not directly raise any astronomical concerns. We note favourably that it is placed so as to restore the route of the Avenue, the formal approach to Stonehenge, whose final approach is along the solstitial axis. This final approach has itself only recently been restored, following the removal of the A344 road in 2013.

3. To what extent do you agree with our proposed locationof the western portal?
Strongly disagree

The proposed western portal lies almost exactly on the winter solstice sunset alignment. See §7 for discussion.

4. Of the two possible routes for the Winterbourne Stoke bypass which do you consider is the best route?
Option 1N – a northern bypass of Winterbourne Stoke

The proposed southern route (option 1S) would result in a dual-carriageway road running down the solstitial alignment for approximately 2km (mostly within the WHS) to a new two-level road junction (just outside the WHS), again on the alignment. See §7 for discussion.

5. What are the most important issues for you aswe develop our proposals for the A303/A345 Countess junction?

Our main concern is that, in order to maintain as dark a sky as possible from the vicinity of Stonehenge, light scatter into the sky from any lighting at the junctions hould be minimised by using full cut-off luminaires.

6. What are the most important issues for you as we develop our proposals for the A303/A360 Longbarrow junction?

Q6:
Our main concern is that under the proposed southern route (option 1S), this new junction would lie right on the solstitial alignment to the SW. See §7 for discussion.

7. Do you have any other comments?

Q7:

ABOUT US
Our Commission, on behalf of the International Astronomical Union (IAU), works alongside UNESCO to implement the Astronomy and World Heritage Thematic Initiative (whc.unesco.org/en/astronomy/). This Initiative aims to improve the identification, conservation and management of specific types of properties connected with astronomical observations and traditional astronomical knowledge. We are concerned with Stonehenge as one of a very small number of existing World Heritage Sites with a strong relationship to astronomy. This response is confined to issues of direct interest to our Commission although we are, of course, aware of a range of broader issues.

Clive Ruggles, who has submitted this response as President of the Commission, is also a member of a "Consortium of Stonehenge experts" who are separately submitting a broader archaeological view.

THE IMPORTANCE OF THE SOLSTITIAL SIGHTLINE TO THE SW
Stonehenge is famous worldwide as an, and arguably the, iconic example of an ancient monument connected with the sky. The most tangible aspect of this is its solstitially aligned axis. Upon entry to the Visitors’ Centre, a prominent sign introduces visitors immediately to the fact that the solar alignment is one of the most important features of the site.
Since 2011, various sightlines within the Stonehenge World Heritage Site (WHS) have been recognized as carrying attributes of the Outstanding Universal Value (OUV) that qualifies the area for World Heritage status. The sightline to the SW at Stonehenge itself, being the principal direction faced by the monument, is indisputably the most important of them. The removal of the A344 road in 2013 allows visitors once more to approach the monument along the intended formal
route (the Stonehenge Avenue) from the NE, facing the direction of winter solstice sunset. This helps considerably to strengthen visitors’ appreciation of the importance of the view straight ahead through the monument at the final point of approach.
The 2009 and 2015 Management Plans list the seven attributes that express the Outstanding Universal Value (OUV) of the Stonehenge World Heritage Site [MP09, p. 28; MP15, p. 32]. (N.B. The 2015 Management Plan includes Avebury but all 7 attributes apply to the Stonehenge part.) Attribute 4 is “The design of Neolithic and Bronze Age funerary and ceremonial sites and monuments in relation to the skies and astronomy”.
The significance of the solstitial axis at Stonehenge is recognized explicitly in the Statement of Significance agreed by UNESCO’s World Heritage Committee in 2008 (see [MP09, pp. 26–27]) as well as in the Statement of Authenticity that forms part of the revised statement of OUV submitted to UNESCO in 2011 (and formally adopted in 2013) [MP15, p. 28]. “An outstanding example [of a highly organised prehistoric society able to impose its concept upon the environment] is
the alignment of the Stonehenge Avenue ... and Stonehenge stone circle on the axis of the midsummer sunrise and midwinter sunset” [MP09, p. 27].
Preserving the integrity of the solstitial sightlines in the Stonehenge WHS is a major theme of an extended case study included in the second ICOMOS–IAU Thematic Study on astronomical heritage. The case study [ECS15] was one of a set presented at a side-event at the 2015 UNESCO World Heritage Committee (39COM) in July 2015, and was published in March 2016 on the UNESCO-IAU Portal to the Heritage of Astronomy (www.astronomicalheritage.net). It has since been widely disseminated both within the UK and internationally, for example at the Avebury and Stonehenge Archaeological and Historical Research Group (ASAHRG) in Jan 2015, at the European Association of Archaeologists' annual conference in Sep 2015, and at a public workshop on Science and Technology at Stonehenge held at the Politecnico Milano in May 2016. The whole Thematic Study volume is due for publication in time for presentation at the 41st meeting of the UNESCO World Heritage Committee (41COM) in July 2017.
The need to preserve (and, where possible, to restore) the integrity of the sightlines is recognized in the 2015 Management Plan. Policy 3c [MP15, p. 105] is to “Maintain and enhance the setting of monuments and sites in the landscape and their interrelationships and astronomical alignments with particular attention given to achieving an appropriate landscape setting for the monuments and the WHS itself”. Action 31, already undertaken (see [ECS15]), is to “identify key views between the attributes of OUV and both into and out of the WHS [and] identify key astronomical alignments”.
Strategies for implementation could, and in the opinion of our Commission should, include:
• Improving and restoring ridges and horizons within the sightlines by removing visual obstacles such as buildings and trees;
• Avoiding new planting that, when fully grown, could obscure the sightlines; and
• Defining a buffer zone that includes the sightline corridors extending beyond the WHS. Fountains Abbey WHS (see [ECS15, fig. 8]) provides a precedent.

PRESERVING THE INTEGRITY OF THE SOLSTITIAL SIGHTLINE TO THE SW FROM STONEHENGE
The winter solstice sightline to the SW from Stonehenge is the single most important sightline in the WHS. Currently, its integrity is compromised by the existing A303 road, crossing the sightline just ~500m from Stonehenge, and by three plantations of tall trees—Normanton Gorse, ~1km from the site; The Diamond, just over 2km from the site; and a narrow plantation enclosing a trapezoidal area just over 3km from the site— each of which blocks the view to the distant horizon, formed by part of a hill ~1km WNW of Druid’s Lodge (4.4 km from the site).
Thanks to the removal of the A344 road, direct approach to Stonehenge is now possible once again along the Avenue. This means that the view straight ahead is of prime importance at all times, not just around the time of sunset on days close to the winter solstice.
We believe that an important priority, especially given the prospect of removing the current A303, should be to clear a strip through the trees currently blocking the SW sightline so as to restore it to its original state and permit the view both of the setting solstitial sun nowadays and also of the position where the sun would have set at the time of construction.
This implies opening up, and keeping clear, a sector of landscape at least 2° wide in azimuth, so as to include the whole sun as the lower limb contacts theground, the last gleam, the sun’s position in 2500 BC, and a margin of at least one solar diameter (0.5°) on each side. A sector ~2° wide opening out from Stonehenge would be ~150m wide at a distance of 4.4 km.
We feel strongly that any form of lighting (either fixed lighting or vehicle lights) needs to be avoided along the full extent of the sightline. Even at a distance of a few kilometres, lighting would affect the view directly along the sightline at sunset or at night, running counter to all the progress being made in restoring the site to its landscape and sky.

SPECIFIC RECOMMENDATIONS
Ideally, and perhaps essentially, the landscape topography within the SW sightline (sector) should be left completely intact. Only this would guarantee absolutely that the integrity of the sightline is preserved for the future. This would imply that the western tunnel portal would need to be moved to the west of this sector, and that no part of the approach road should be cut through this sector.
A crucial question, then, is whether it might be acceptable for road construction to take place within the sightline, but too low to be visible from Stonehenge in the
absence of trees. In our view the following points, at least, would need to be addressed:
a) All parts of the road and its associated earthworks within the solstice sector would need to be invisible below the natural topography (in the absence of trees),
i.e. screened behind natural ridges (even when these have been cleared of trees) and below the distant horizon. Under no circumstances should existing or additional trees be used for screening.
b) All vehicles must be screened from view at all times. Not only would vehicle lights be intrusive at night: the eye would be drawn to any movement during the daytime. This implies that at all points the road surface must be at least 5m below the visible natural topography (when cleared of trees) and horizon. In particular, there must be no direct view of headlights/rear lights from vehicles, especially those travelling directly or almost directly towards or away from the monument.
c) For a two-level road junction, given that road vehicles may be up to 5m in height, (a) and (b) imply that the ground surface would need to be at least 11m below the viewshed from Stonehenge at every point.
d) Even if no lighting is installed at the tunnel entrance and junction, having these on the sightline opens up the possibility that lighting will be required (perhaps as a legal requirement, e.g. because of altered health and safety regulations) at some point in the future.
In sum, no part of the road, built constructions (bridges, viaducts) or earthworks, signage, vehicles, street lights, vehicle lights, or diffuse or reflected light from vehicles should be visible along the sightline. Trees cannot be taken into account: any screening by trees is temporary but changes to the visible topography are permanent and irreversible. It would be doubly bad to rely on trees to screen the road, related constructions, or lights.
The onus would need to be upon the planners to demonstrate that the proposed earthworks would NOT compromise the sightline. This would not only involve topographic modelling; it would also require specialist input from archaeoastronomers.
Even if the above concerns are addressed, it is possible that roadworks might still be visible from other points along the sightline, such as the “Sun Barrow” immediately to the NE of Normanton Gorse. This is relevant to Attribute 3 as well as Attribute 4. The composite visibility plan (Map 10) in the 2009 Management Plan [MP09, p. 184] might be helpful in regard to this issue.

CONSTRAINTS AND ALTERNATIVES
The eastern tunnel portal is placed so as to preserve the line of the destroyed Avenue, and should not, therefore, be moved further west. Thus it appears that if the tunnel length is constrained at 2.9km, then the western portal could not be moved westwards out of the SW sightline sector.
The proposed western portal is placed at a low point in the landscape, and the two proposed approach routes follow relatively inconspicuous courses through the landscape: in particular, the southern route runs close to a dry valley. This implies that it may be tricky or impossible to find alternative approach routes without either destroying archaeological features or making the roadway more visible.
Together, these imply that it could be challenging to find acceptable alternatives under current constraints. This makes it all the more imperative to ensure that the integrity of the solstitial sightline to the SW is not compromised, simply in order to find a swift workable solution.

BIBLIOGRAPHY
[ECS15] Chadburn, A. and Ruggles, C. (2015). Stonehenge World Heritage Property, United Kingdom: Extended Case Study.
www.astronomicalheritage.net/index.php/show-entity?identity=49&idsubentity=1
[MP09] Young, C., Chadburn, A. and Bedu, I. (2009). Stonehenge WHS Management Plan 2009. English Heritage, on behalf of the Stonehenge WHS
Committee. www.stonehengeandaveburywhs.org/assets/Full-MP-2009-low-res-pdf.pdf
[MP15] Simmonds, S. and Thomas, B. (2015). Stonehenge, Avebury and Associated Sites World Heritage Site Management Plan 2015 (ed. Nichols, E. and
Tyson, R.). Published on behalf of the Stonehenge and Avebury WHS Steering Committees.
www.stonehengeandaveburywhs.org/management-of-whs/stonehenge-and-avebury-whs-management-plan-2015

UNESCO Astronomer Experts Response to the Stonehenge Tunnel Proposal

A response from the co-authors of the extended case study on Stonehenge on the UNESCO–IAU Portal to the Heritage of Astronomy - Dr. Amanda Chadburn and Prof. Clive Ruggles


1. To what extent do you agree with our proposed option?
Strongly disagree
Please provide any comments to support your answer for question 1:
We are responding as archaeologists and co-authors of The Extended Case Study on Stonehenge [ECS15]. This response reflects the personal views of the
authors and not necessarily those of their employers or of the International Astronomical Union who published ECS15, and who work alongside UNESCO to
implement the Astronomy and World Heritage Thematic Initiative.
In this response, we are only considering the archaeoastronomical aspects of Stonehenge, and not the other attributes of Outstanding Universal Value (OUV) nor
any other designations and their settings such as Registered Parks and Gardens, Listed Buildings, Scheduled Monuments which are not of OUV, SSSIs and so
on. Of course, we believe that all such designations, places of significance and attributes of OUV should be systematically and fully assessed and taken into
account, but here we concentrate on Attribute 4 of OUV (see below), which is the subject of ECS15 (see bibliography). The public consultation documents contain
no evidence that this issue has been addressed or taken into account.
Clive Ruggles is also a member of a consortium of 21 "Stonehenge experts" who have submitted a broader archaeological view.
See section 7 for reasons why we disagree with the proposed option.
Key features of the proposed option
2. To what extent do you agree with our proposed location of the eastern portal?
Tend to agree
Please provide any comments to support your answer for question 2:
The eastern portal does not directly raise any astronomical concerns. We agree that it is preferable to place the portal to the eastern side of the line of the
Stonehenge Avenue, the processional approach to Stonehenge, whose final approach is along the solstitial axis.
3. To what extent do you agree with our proposed location of the western portal?
Strongly disagree
Please provide any comments to support your answer for question 3:
See section 7 for full reasons.
4. Of the two possible routes for the Winterbourne Stoke bypass which do you consider is the best route?
No preference
Please provide any comments to support your answer for Question 4:
We disagree with the location of the western portal so cannot agree with either consultative route, so "no preference" is our only option, although "neither" would
be more accurate. Additionally both routes run along the solstitial axis for a distance. See section 7 for full reasons.
5. What are the most important issues for you as we develop our proposals for the A303/A345 Countess junction?
Q5:
To preserve as dark a night sky as possible.
6. What are the most important issues for you as we develop our proposals for the A303/A360 Longbarrow junction?
Q6:
Option 1S has the junction at almost the exact spot where the midwinter solstice sun would set – the very spot critical to the design and use of Stonehenge, and
therefore critical to its understanding and significance. This would be highly damaging and should be avoided.
7. Do you have any other comments?
Q7:
ASTRONOMICAL SIGHTLINES IN THE STONEHENGE WHS AND THEIR OUV
Since 2008, various sightlines within the Stonehenge World Heritage Site (WHS) have been formally recognized as carrying attributes of the Outstanding
Universal Value (OUV) that qualifies the area for World Heritage status [MP09, pp 26-7]. The sightline to the SW at Stonehenge itself, being the principal direction
faced by the monument, is indisputably the most important of all of them. The approach to the monument has only recently been restored, following the removal
of the A344 road in 2013, allowing visitors once more to approach the monument along the intended formal route (the Stonehenge Avenue) from the NE, facing
the direction of winter solstice sunset. This helps considerably to strengthen visitors’ appreciation of the importance of the view straight ahead through the
monument at the final point of approach.
The 2009 and 2015 Management Plans list the seven attributes that express the OUV of the Stonehenge World Heritage Site [MP09, p. 28; MP15, p. 32]. 1
Attribute 4 is “The design of Neolithic and Bronze Age funerary and ceremonial sites and monuments in relation to the skies and astronomy”.
The significance of the solstitial axis at Stonehenge is recognized explicitly in the Statement of Significance agreed by UNESCO’s World Heritage Committee in
2008 (see [MP09, pp. 26–27]) as well as in the Statement of Authenticity that forms part of the revised Statement of OUV submitted to UNESCO in 2011 (and
formally adopted in 2013) [MP15, p. 28]. “An outstanding example [of a highly organised prehistoric society able to impose its concept upon the environment] is
the alignment of the Stonehenge Avenue ... and Stonehenge stone circle on the axis of the midsummer sunrise and midwinter sunset” [MP09, p. 27].
Preserving the integrity of the solstitial sightlines in the Stonehenge WHS is a major theme of an extended case study included in the second ICOMOS–IAU
Thematic Study on astronomical heritage. This case study [ECS15] which we co-authored was one of a set presented at a side event at the 2015 UNESCO World
Heritage Committee (39COM) in July 2015, and was published in March 2016 on the UNESCO-IAU Portal to the Heritage of Astronomy. The whole volume is due
for hard copy publication in time for presentation at the next World Heritage Committee (41COM) in July 2017. The case study is on-line and additionally has
been widely disseminated within the UK and internationally, for example at the Avebury and Stonehenge Archaeological and Historical Research Group
(ASAHRG) in Jan 2015, at the European Association of Archaeologists annual conference in Sept 2015, and at a public workshop on Science and Technology at
Stonehenge held at the Politecnico Milano in May 2016.
The need to preserve (and, where possible, to restore) the integrity of the sightlines is recognized in the 2015 Management Plan. Policy 3c [MP15, p. 105] is to
“Maintain and enhance the setting of monuments and sites in the landscape and their interrelationships and astronomical alignments with particular attention
given to achieving an appropriate landscape setting for the monuments and the WHS itself”. Action 31, already undertaken by us (see [ECS15]), is to “identify key
views between the attributes of OUV and both into and out of the WHS [and] identify key astronomical alignments”. Strategies for implementation include:
• Improving and restoring ridges and horizons within the sightlines by removing visual obstacles such as buildings and trees;
• Avoiding new planting that, when fully grown, could obscure the sightlines; and
• Defining a buffer zone that includes the sightline corridors extending beyond the WHS. Fountains Abbey WHS (see [ECS15, fig. 8]) provides a precedent.
The need to assess and preserve views to and from historic assets – and this view is an example of the highest significance (OUV) - is well understood and
guidance on how to do this is readily available [SHV11] [GPA3].
THE IMPACT OF THE PROPOSALS
Under these proposals, the western entrance of the tunnel lies almost exactly on the winter solstice sunset alignment. There are two options for the route of the
emerging dual-carriageway approach road to/from the west. In both routes, the road broadly follows the solstitial alignment for a distance, but then the options
diverge as one heads west. In Option 1S, the southern option, the road runs broadly down the alignment for approximately 2km (mostly within the WHS) to a new
road junction (just outside the WHS), again on the solstitial alignment. This raises serious concerns that the integrity of the SW sightline from Stonehenge could
be destroyed, eliminating forever the possibility of visitors to Stonehenge once again seeing the winter solstice sun setting behind the distant natural horizon
along the axis of the monument.
The winter solstice sightline to the SW from Stonehenge is the single most important sightline in the WHS, reflecting as it does, the design of the monument.
However, its integrity is compromised by the existing A303 road, crossing the sightline just c.500m from Stonehenge, and by three plantations of tall trees each of
which blocks the view to the distant horizon, formed by part of a hill c.1km WNW of Druid’s Lodge (4.4 km from Stonehenge).
The proposal clearly has benefits, in particular by removing the A303 from the landscape immediately to the south of Stonehenge, which at present seriously
compromises the integrity of the SW sightline. This would not only help restore the monument to its landscape setting but would also eliminate the stream of
vehicle lights passing within 250m of the monument which that are so intrusive at night.
Nonetheless, the current proposals appear to be directly contrary to Policy 3c in the 2015 Management Plan (see above) and the strategies for implementing it
[ECS15]. We should be aiming to preserve this key sightline for eternity. Trees are temporary; on the other hand, the landscaping accompanying major roadworks
could compromise the sightline irreversibly.
RECOMMENDATIONS
Lighting (either fixed lighting or vehicle lights) needs to be avoided along the full extent of the sightline. Even at a distance of a few kilometres, lighting would
affect the view directly along the sightline at sunset or at night, running counter to all the progress being made in restoring the site to its landscape and sky.
Ideally, and perhaps essentially, the landscape topography within the SW sightline (solstitial sector) should be left completely intact. Only this would guarantee
absolutely that the integrity of the sightline is preserved for the future. This would imply that the western tunnel entrance would have to be to the west of this
solstitial sector, and that no part of the approach road should be cut through this sector.
A crucial question, then, is whether it might be acceptable for any road structures to be placed within the sightline, but too low to be visible from Stonehenge in
the absence of trees. The following concerns, at least, would need to be addressed:
a) All parts of the road and its associated earthworks and structures within the solstice sector would need to be invisible below the natural topography (in the
absence of trees), i.e. screened behind natural ridges (even when these have been cleared of trees) and below the distant horizon. Under no circumstances
should existing or additional trees be used for screening.
b) All vehicles must be screened from view at all times. Not only would vehicle lights be intrusive at night: the eye would be drawn to any movement during the
daytime. This implies that at all points the road surface must be at least 5m below the visible natural topography (when cleared of trees) and horizon. In particular,
there must be no direct view of headlights/rear lights from vehicles, especially those travelling directly or almost directly towards or away from the monument.
c) For a two-level road junction, given that road vehicles may be up to 5m in height, (a) and (b) imply that the ground surface would need to be at least 11m below
the viewshed from Stonehenge at every point.
d) Even if no lighting is installed at the tunnel entrance and junction, having these structures within/on the sightline opens up the possibility that lighting will be
required (perhaps as a legal requirement, e.g. because of altered health and safety regulations) at some point in the future. This would be damaging.
e) There may still be diffuse or reflected light from vehicles at night.
In sum, no part of the road, built constructions (bridges, viaducts) or earthworks, signage, vehicles, street lights, vehicle lights, or diffuse or reflected light from
vehicles should be visible along the sightline. Trees cannot be taken into account: any screening by trees is temporary but changes to the visible topography are
permanent and irreversible. It would be doubly bad to rely on trees to screen the road, related constructions, or lights. The onus would need to be upon the
planners and road engineers to demonstrate that the proposed structures would NOT compromise the sightline. This would not only involve topographic
modelling; it would also require specialist input from archaeoastronomers.
Even if the concerns above are addressed, we recognise that such a road may have adverse impacts on other attributes of OUV and this would need to be
addressed. Additionally, it is possible that the road and related works might still be visible from other points along the sightline, such as from the “Sun Barrow”
immediately to the NE of Normanton Gorse. This is relevant to Attribute 3 as well as Attribute 4. The composite visibility plan (Map 10) in the 2009 Management
Plan [MP09, p. 184] may be helpful in regard to this issue, and full and detailed “bare earth” topographic modelling will be needed to ensure that all attributes of
OUV including Attribute 4 are fully taken into account.
BIBLIOGRAPHY
[ECS15] Chadburn, A. and Ruggles, C. (2015). Stonehenge World Heritage Property, United Kingdom: Extended Case Study.
www.astronomicalheritage.net/index.php/show-entity?identity=49&idsubentity=1
[MP09] Young, C., Chadburn, A. and Bedu, I. (2009). Stonehenge WHS Management Plan 2009. English Heritage, on behalf of the Stonehenge WHS
Committee. www.stonehengeandaveburywhs.org/assets/Full-MP-2009-low-res-pdf.pdf
[MP15] Simmonds, S. and Thomas, B. (2015). Stonehenge, Avebury and Associated Sites World Heritage Site Management Plan 2015 (ed. Nichols, E. and
Tyson, R.). Published on behalf of the Stonehenge and Avebury WHS Steering Committees.
www.stonehengeandaveburywhs.org/management-of-whs/stonehenge-andavebury-whs-management-plan-2015
[SHV11] English Heritage. 2011. Seeing History in the View. A method for assessing Heritage Significance within Views

Society of Antiquaries of London Response to the Stonehenge Tunnel Proposal

1. To what extent do you agree with our proposed option?

Tend to agree.

The Society welcomes in principle the Highways England proposals for a 2.9km bored tunnel for the A303 from just west of the Countess Roundabout to a point west of Normanton Down. This is a positive recognition of the importance of the World Heritage Site (WHS), a potentially deliverable means of significantly reducing the adverse impact of the A303 on the landscape round Stonehenge, and of providing a solution to the bottleneck caused by the existing road. As the scheme is designed in more detail, the Society will wish to see that there is minimal impact on scheduled monuments, the least possible new construction within the WHS, and that this solution to traffic within the WHS proves to be the least visible and audible from key monuments. We will also wish to see the results of archaeological evaluation work carried out in advance of some of the key areas on the surface where the proposed road will run, and we have a number of observations (below) about the impact of construction work on the Stonehenge landscape.

We are also aware, however, of Paragraph 110 of the Operational Guidelines for the Implementation of the World Heritage Convention, which states that ‘Impact assessments for proposed interventions are essential for all World Heritage properties.’ To make an adequate impact assessment it is necessary fully to understand the range of impacts, positive and negative, on the attributes that carry the outstanding universal value (OUV) of the site before a decision is made. A sound decision to proceed with either of the short-listed routes therefore needs to be based on a full understanding of the impacts of each option on the OUV of the property, including buried archaeology both on the route lines, and within the often extensive additional land that could be disturbed by temporary construction works and ecological mitigation measures.

We understand that archaeological evaluation is being undertaken, but until that work is complete and available for public scrutiny, together with realistic and affordable construction management plans, including precise details of the design, especially for the portals and their approach ramps, lighting, fencing, signage, and drainage, as well as ecological mitigation plans for each option, the evidence base to inform a sound and defensible decision to adopt a specific route, especially one which clearly will have some impact on the WHS, is seriously defective. When this information is available, heritage impact assessments of the options should be produced and published in accordance with Guidance on Heritage Impact Assessments for Cultural World Heritage Properties (ICOMOS International, 2011), following the advice of the 2016 ICOMOS/UNESCO Advisory Mission (4.2.1, p25).

2. To what extent do you agree with our proposed location of the eastern portal?

Tend to agree.

The tunnel mouths, both to east and west, are very close to significant archaeological features in the World Heritage Site landscape. The tunnel length at present proposed is 200m less than the 3km length which the consultation document asserts is the most that can be constructed without ventilation shafts. A modest small extension of the tunnel’s length, particularly at its western approach would give a little more breathing space to key monuments within the WHS.

We must, however, see the detailed proposals for the eastern tunnel portal and its screening. We must see well-reasoned evidence that the buried remains of the Avenue will be secure, and will wish to be able to gauge how Highways England will ensure there is no impact on the Stonehenge Avenue in the positioning and, importantly, during the construction of the eastern portal.

In any proposal to excavate a tunnel, it is the approaches that do the harm. Design drawings do not necessarily reveal the full extent of the permanent and temporary impacts of construction based on the reality of the large scale civil engineering, which can reach substantially beyond the line of the road itself. The fact that parts of this road, and the tunnel mouths themselves, where much of the activity of construction will be concentrated, are within the WHS means that the practical aspects of the engineering works need to be considered at the outset and be included in the assessment. The results from the new evaluation trenches along the course of the proposed new road alignments west of the western tunnel portal will be of key interest here.

3. To what extent do you agree with our proposed location of the western portal?

Tend to disagree.

See our answer above to Q2. The tunnel mouths, both to east and west, are very close to significant archaeological features in the World Heritage Site landscape. The tunnel length at present proposed is 200m less than the 3km length which the consultation document asserts is the longest that can be constructed without ventilation shafts. A modest extension of the tunnel’s length at the western approach in particular would enable the new road alignment to give a wider berth to the Normanton group of barrows at the western end.

The prospect of boring beneath the Normanton barrow group is on the face of it alarming. This is arguably the most famous barrow group in the country and unintended damage through fracturing of the chalk bedrock could destroy the integrity of intact deposits. There could also be a shaft burial amongst the mounds, which tunnel boring would disturb. The reasons for placing the western portal in this sensitive location have not been explained.

The portal in the location proposed will also be roughly on the line of the mid-winter sunset as viewed from Stonehenge, as is pointed out by the Royal Astronomical Society. Even if the lighting of the portal and the headlights of cars are not directly visible from Stonehenge, they will in all probability create a significant glow, thus adversely impacting upon the desired quality of darkness at the horizon. As that sightline is one of the major attributes of the WHS’s central monument, it would seem to be counter-productive to align the road so nearly on it, even though at the depth planned for the tunnel portal, this will not be visible from Stonehenge itself.

All in all, therefore, it might seem less risky to place the portal further to the north west (west of Normanton Gorse and south of the existing A303) thus avoiding the Normanton Down Group altogether. The road could still utilise lower ground south of Longbarrow Crossroads, and the existing A303 could still be closed, albeit that the new route would be closer to that barrow group and the extant scheduled long barrow on Wilsford Down. The current proposal favours the Winterbourne Stoke Longbarrow Group at the expense of (and potential risk to) the Normanton Down Group. A fuller Impact Assessment examining the siting of the western tunnel mouth, to seek an optimised route for the A303, is required.

We therefore wish to see the detailed proposals for the western portal and any proposed screening. We wish to be able to gauge how Highways England will ensure there is no impact on the Normanton group of barrows. We wish better also to understand whether a bored tunnel could cause a threat or damage to Bush Barrow, the most celebrated round barrow in the region.

4. For the Winterbourne Stoke by-pass, which is the best route?

The northern route has had archaeological evaluation work carried out, and in consequence can be more easily planned for in detail. If the western tunnel portal can be moved marginally north and westwards, this make it perhaps easier to link with a northern by-pass for Winterbourne Stoke.

5. What are the most important issues for you as we develop our proposals for the A303/A345 Countess junction?

We have no substantive issues over the proposals for the Countess junction.

6. What are the most important issues for you as we develop our proposals for the A303/A360 Longbarrow junction?

The most important issues are the impact that such a junction, whether on the northern or southern route round Winterbourne Stoke, will have on the landscape, both during hours of daylight and darkness. The introduction of a significantly lit junction into the landscape at this point will be a substantial distraction to the WHS landscape. We also understand that the site of the proposed junction, wherever it will be placed on the A360 or on the A303, may be the chosen location for much of the necessary plant, storage, and equipment compounds for the overall roads construction. If so, it will be very important to ensure that the full area of the site to be affected is properly evaluated for its archaeological and ecological evidence as part of the Heritage Impact Assessment.

7. Do you have any other comments?

In 2006, responding to the then published proposals for the A303 in the Stonehenge area, the Society strongly endorsed the principle of a bored tunnel, expressing the view that this was far preferable to a cut-and-cover version, would remove the negative impacts of surface traffic and its routes within the WHS, and would go a long way towards restoring the completeness of the historical landscape within which Stonehenge stands. We also urged moving rapidly towards implementation. The view we have stated above is consistent with this stance, and welcomes the fact that a longer tunnel is now being actively considered.

There could be permanent direct and indirect impacts on designated and undesignated heritage assets as a result of the construction process. Constructing the boring machines, removing the chalk and transporting it away, shipping in the reinforced concrete to line the tunnel will need a significant land take. There is no indication of where any of that might occur, or its scale. Details of construction methods and of enabling works, whether temporary or permanent, must also be considered, and be subject to the promised consultation later in 2017 and prior to the submission of the Development Consent Order. Such proposals must also reveal what is to be done with the bed of the existing A303.

The presence of a major dual carriageway road on the character of the landscape through which it passes is felt over a very wide area, far beyond its zone of visibility. Such roads, where they are on the surface, cannot be crossed on foot (as the A303 can at present); they need underpasses or overbridges. Noise is a key impact, but those who will be encouraged to walk through the landscape around Stonehenge will always be conscious of its proximity and its presence in the landscape. Highways England need to take every care to minimise the impact of the finished road on the landscape they are seeking to protect through the construction of this tunnel and the approaches to it.

Download the response here-: https://www.sal.org.uk/news/2017/03/public-consultation-on-a303-and-stonehenge/#sthash.xGRyDsOM.dpuf

Monday 6 March 2017

ICOMOS-UK RESPONSE TO HIGHWAYS ENGLAND PUBLIC CONSULTATION ON PROPOSED A303 2.9KM TUNNEL SCHEME


STONEHENGE, AVEBURY AND ASSOCIATED SITES WORLD HERITAGE SITE

ICOMOS-UK RESPONSE TO HIGHWAYS ENGLAND PUBLIC CONSULTATION ON PROPOSED A303 2.9KM TUNNEL SCHEME


1. OVERALL SUMMARY:
On the basis of evidence set out below, ICOMOS-UK firmly objects to the current option for a 2.9km tunnel for the substantial negative and irreversible impact if would have on the attributes of Outstanding Universal Value (OUV) of the World Heritage site (WHS) of Stonehenge, Avebury and Associated sites.

To suggest that this damage can be mitigated by benefits brought by the tunnel to the centre of the WHS, is to fundamentally misunderstand the commitments made to sustain OUV at the time of inscription of the property on the World Heritage List.

Although we approve in principle with the idea of a tunnel for the A303, this is only if:
• All options for constructing a bypass located outside the WHS have been adequately considered via a robust and consistent methodology, and an informed consultation process;
• The tunnel is long enough to ensure that its tunnel portals, associated approach roads and cuttings do not impact in any way on the WHS or its setting;
• That construction impacts arising from a tunnel solution do not have a permanent adverse impact on the attributes of Outstanding Universal Value (OUV);
• All necessary Heritage Impact Assessments (HIAs) have been undertaken independently undertaken on the basis of a clear understanding of the attributes of OUV.

ICOMOS-UK does not consider that these parameters have been satisfied, as set out in more details below, and thus we cannot support the 2.9km tunnel option, either with a corresponding by-pass to the north, or with one to the south, of Winterbourne Stoke, as currently proposed in the public consultation document.

The reasons provided for excluding the southern route F010 are not substantial, and inexplicably the lack of harm to the WHS has not been given adequate weighting. Given that this option has no adverse impact on the WHS and can be built for substantially less money than the tunnel, we consider that the decision to exclude if from consultation must be re-considered. Subject to further refinements, this surface route option provides the opportunity to improve the A303 and to safeguard the whole of the WHS and its setting which must be the twin aims of this project.

ICOMOS-UK strongly suggests that further consultations be held that explore options for a longer tunnel as well as comparative routes to the south of the WHS, with an equal and consistent methodology and scoring being applied for all route options, and one that recognises that WHS status is at least equal to that of an AONB, and arguably of much greater significance.

During the pre-consultation options assessment process, we consider that the potential impact on the OUV of the WHS should have been given the highest priority, in terms of determining appropriate parameters for assessing impact on OUV, and this in our view does not appear to have been the case.

ICOMOS-UK understands the financial constraints that are in place, and the need to resolve ongoing difficulties with the road network, but does not consider that such constraints can be a justification for compromising a full assessment of potential adverse impact of various options on the OUV of the WHS in advance of decisions being taken, or indeed for inflicting considerable irreversible harm on the WHS which we consider that the proposed tunnel option would do.


2. STRUCTURE OF RESPONSE
Below are set out more detailed comments on the
• Overall consultation process
• Assessment of options o Lack of adequate acknowledgment of the implications of WH status o Benefits to parts of a WHS cannot outweigh irreversible negative impacts on OUV in other parts of the site
• Lack of clarity in distinguishing between the main henge monument and the Stonehenge part of the WHS
• Inconsistent parameters used for measuring impact o Lack of HIAs
• Length of tunnel appears to be based on cost rather than cultural heritage considerations
• Lack of adequate detail to allow a full analysis of options
• Lack of compliance with NPPF
• Conclusion

NOTE:
ICOMOS-UK understands that the two variations of the single tunnel route currently being consulted on are referred to by Highway’s England under the following designations:
• Highways England Route D061 (tunnel and by-bass to the north Winterbourne Stoke) and
• Highways England Route D062 (tunnel and by-pass to the south Winterbourne Stoke)
• Highways England - Route F010 (a 21.5km surface dual carriage way that bypassed the World Heritage site to the south) was a 3rd option that we understand performed well but that was excluded from the current consultation.

For clarity we will refer to these routes by their Highway’s England designation.


3. OVERALL CONSULTATION PROCESS
ICOMOS-UK is concerned at the way the consultation process for the proposed A303 has been organised. Following the report of the joint UNESCO World Heritage Centre/ICOMOS Advisory mission carried out between 27th and 30th October 2015, we had expected a structured process that fully evaluated different tunnel and other options in relation to the OUV of the WHS, and with the options appraisal involving key stakeholders, In the event, one tunnel option has been put out for consultation, with two sub-options for either a northern or southern by-pass of Winterbourne Stoke, D061 or D062 respectively. This limited variation of two near identical options has been presented:

• Without any accompanying HIAs being carried out in line with ICOMOS
Guidelines on Cultural Heritage Impact Assessments;
• Without indications being set out as to how the proposed tunnel interacts with or impacts on the attributes of OUV;
• With relatively few details being provided of other options that have been discarded; and
• With an apparent pre-set length for the tunnel.

Up until now, it is disappointing to note that there appears to have been no dialogue or consultation by the Government with key cultural heritage stakeholders, apart from Historic England and the National Trust.

As the problems of the Stonehenge road have been on the agenda for at least two decades, amongst these stakeholders there is considerable technical knowledge and understanding of the issues and the potential solutions that have been considered as well as of the OUV of the WHS. This understanding of OUV has been enhanced by recent extensive fieldwork and archaeological investigations that are beginning to show the scope, interconnectedness and current rich archaeological potential of the wider Stonehenge landscape, of which the main henge monument is the most conspicuous part.

Perhaps not surprisingly, widespread concerns are being expressed by archaeological, cultural heritage and landscape organisations who have so far not been engaged in the consultation and evaluation processes.


4. ASSESSMENT OF OPTIONS
ICOMOS-UK does not consider that the methodology that has been used for assessing potential road options can be said to be robust for the following reasons:

i) Lack of adequate acknowledgement of the implications of WH status The commitments of the State Party under the WH Convention to protect the international status of the WHS has not been given the status needed to reflect the commitments of the State Party to the WH Convention. We do not understand why the need to protect the WHS has apparently been given such a low priority in the overall assessment process, below AONBs, leases and general environmental concerns, and consider that this reflects poorly on the overall credibility of assessment process.

The hierarchy of constraints applied to this (and to the other two A303 upgrade projects in the same Highways England funding commitment) appears to have little logic with WH status being given lower priority than an AONB, environmental factors and existing leases.

At the earliest stage of the planning process, for one of the other two A303 upgrade schemes within the funding commitment that includes the Amesbury to Berwick Down section, the then Highways Agency were directed to avoid the Blackdown Hills Area of Outstanding Natural Beauty (AONB). As a result they now propose instead to upgrade a branch road to a dual carriageway link between the M5 at Taunton and the A303 rather than upgrading the existing A303 corridor. The justification for this proposal by Highways England was taken purely because the existing A303/A30 runs through an AONB.

AONBs have national status for their nature conservation and visual qualities. If there is a presumption in favour of respecting the integrity of areas with national designation, there must also logically be an enhanced commitment to international designations, such as a WHS. As the Government has committed itself to sustaining the OUV of the WHS of Stonehenge, Avebury and Associated Sites for the benefits of all humanity following its inscription on the WH list in 1998, it is not logical or acceptable to suggest that this means that the WHS has lesser value than an AONB.

Similarly, in the consideration of the various potential options for the Amesbury to Berwick Down section, it appears the then Highways Agency were instructed not to consider any options for a southern route that crossed land within the boundaries of RAF Boscombe Down. We understand this MoD site is leased to QinetiQ on a 25-year Long Term Partnering Agreement (LTPA), thus Boscombe Down remains a government airfield but is operated by QinetiQ on behalf of the MOD.

Publically available sources suggest the land is leased until 2025 or 2026, but it remains outside the WHS, and we do not consider that the commercial or strategic non-availability of the land should have been a prima facie reason for excluding it in the options assessment. No reason is offered in the current consultation for the exclusion of the RAF Boscombe Down land from areas to be considered. It has no other known specific designations or constraints beyond its ownership and lease status.

It is our view that all the other southern routes that were investigated prior to the current public consultation were longer in distance, and in their geographical divergence, from the current course of the A303 than they would have been if the land at RAF Boscombe Down had been ‘available’ and considered as part of the initial options assessment process.

On the basis of the methodology set out by Highways England in consultation meeting with the Stonehenge and Avebury WHS Steering Groups, it was clear that many of the southern routes, including the ‘3rd’ place route F010, were discarded for perceived traffic and sustainability issues that could have been eliminated, or substantively addressed, if the Boscombe Downland had been included in the assessment process.

Indeed it is likely from what was presented on the scoring for the options assessment criteria that if the Boscombe Down land had been taken into consideration, and new routes for a southern bypass of the WHS had been assessed on the basis of its availability, then these routes could have provided a much more favourable scoring outcome than the variations on the single tunnel route D061 and D062 currently being consulted on. Moreover these new southern routes, or a variation of F010 redirected with a more efficient route through Boscombe Down, do not have any direct or irreversible harm on the OUV of the WHS such as result from routes D061 or D062.

ii) Benefits to parts of a WHS cannot outweigh irreversible negative impacts on OUV in other parts of the site
Such a claim is made in the justification for Routes D061 and D062 when it is said that the benefits of the tunnel in the central part of the WHS will outweigh the dis-benefits resulting from damage to the setting of known archaeological sites as a result of the construction of portals and approach roads. Direct damage to attributes of OUV is a direct threat to OUV, and this damage or threat cannot be mitigated by benefits elsewhere in the WHS.

It is a fundamental principle of WHSs that the OUV for which they were inscribed must be sustained wholly not partially; however great the benefits of an improvement project might be, these cannot compensate for loss to the attributes of OUV resulting from that same project.

iii) Lack of clarity in distinguishing between the main henge monument and the Stonehenge part of the WHS
The main henge monument is said to be of international status equivalent to the Pyramids, whereas what has been recognised as being of international status, through inscription as a WHS, is not just the henge monument on its own but the whole of the two parts of the WHS of Stonehenge and Avebury and Associated Monuments. This includes all the relevant monuments and archaeology (known and currently unknown) therein that contribute to the attributes that make up OUV.

This lack of clarity has been exacerbated by the lack of HIAs that would have set out formally the potential impact on attributes of OUV, and indeed by the lack of any mention in the consultation process of the attributes of OUV as set out in the Statement of OUV.

Archaeological details on even a very basic level, particularly in relation to solstice alignments, are absent from the Technical Assessment that accompanies the consultation. The focus of the consultation relates mainly to the visual and acoustic improvements arising from diverting the A303 away from Stonehenge itself (i.e. the main henge), and the fact that proposed portals are said to be invisible from Stonehenge, with the implication that this is the main consideration.

The assessment lacks any analysis or appreciation of the irreversible impacts on archaeology and on archaeological associations and alignments that will result from Routes D061 and D062 in other parts of the WHS and thus on the attributes of OUV for which the property was inscribed.

iv) Inconsistent parameters used for measuring impact
For the previously discarded southern surface Route F010 outside the WHS, (not brought forward in this consultation) it is stated that the footprint of the road would be imposed on an area rich in archaeology, with known sites and a high potential for revealing undiscovered sites. Inexplicably, no such similar concerns are set out for tunnel Routes D061 and D062, notwithstanding that these routes will involve around 2 km of new dual carriageway in the WHS, in places where there has never been a road, and where surveys over the past decade have highlighted the extraordinarily high archaeological importance of these areas and the potential for further major archaeological discoveries. For the proposed tunnel option it is crucial to acknowledge that it would be imposed on an area rich in archaeology, with known sites and a high potential for revealing undiscovered sites, where preference should always be preservation in situ, in line with national guidance from Historic England2

2 Preserving Archaeological Remains: Decision-taking for Sites under Development (Published 8 November 2016) - https://historicengland.org.uk/images-books/publications/preserving-archaeological-remains/ and the provisions for heritage assets of archaeological interest set out in the Planning Practice Guidance.

v) Lack of HIAs
Without detailed HIAs having been undertaken that consider impact on the OUV of the WHS, it is difficult to understand precisely how the disbenefits of the various options have been assessed in relation to OUV.

From the information provided, there appears to be a considerable disparity between the considerable dis-benefits of the tunnel Route Options D061 and D062 in terms of impact on OUV, and those of the discarded southern Route F010 outside the WHS, which are minimal. The southern F010 route would be sufficiently to the south of the WHS that while it might give rise to some impacts on the setting it would not directly impact at all on the OUV of the WHS. Furthermore, it is understood that the constructions costs of the southern route F010 have been estimated to be £400m less than those for the tunnel.

No convincing grounds have been put forward as to why the southern route entirely outside the WHS was discounted before the public consultation, other than to say it might promote ‘rat running’ on the remaining existing routes within and around the WHS in the vicinity of the former (then closed/removed) section of the current A303.

However, it is noted that the data used to support the claim that ‘rat running’ would occur, leading to significant local traffic dis-benefits, was presented without any mitigation that could result from a fully designed southern option that could include measures to prevent/discourage this effect. We understand that these mitigation measures could have been delivered if this Option had been taken forward for full design. On this basis, the data used to eliminate the southern option F010 on the basis of sustainability and traffic grounds appears flawed. And in terms of impact on OUV, the lack of impact has not been given a high weighting.

vi) Length of tunnel appears to be based on cost rather than cultural heritage considerations
ICOMOS-UK does not consider that the length of the proposed tunnel is satisfactory as it will result in:
a. highly adverse and irreversible impacts on the attributes of the cultural and archaeological landscape that convey OUV, particularly in the south-west part of the WHS;
b. Such damage cannot be mitigated by benefits elsewhere in the WHS,

It is understood that the location of the western portals is a cost base decision, rather than a decision based on detailed understanding of the location and significance of cultural heritage assets that contribute to OUV. As much of the cost of a tunnel derives from the initial setting up costs, the cost of extending it would not necessarily be proportionate (i.e. the price per metre would reduce the longer the tunnel was, subject to other considerations relevant to the design of a longer tunnel). It is further understood that the Highways Agency consider that is it would be possible technically to extend the tunnel length to allow portals to be placed at the edge of the WHS (albeit this would also require detailed HIA analysis in terms of impacts on the setting of the WHS), but that they are constrained by their brief and the funds so far allocated.

vii) Lack of adequate detail to allow a full analysis of options
Without detailed HIAs to set out clearly and formally the potential adverse impacts (or benefits) of the various previously discarded route options on the OUV of the WHS – which has not been done – the consultation on this single tunnel option, with its two sub-options for a Winterbourne Stoke bypass, does not stand up to scrutiny either in terms of the methodology for its initial selection over other potentially less harmful options, or in terms of the assessment procedures that have been applied to this specific option. With regard to the latter, the potential impact of the western portal and the associated c. 2km of new dual carriageway in previously undeveloped land within the WHS has the potential for irreversible damage the settings of and relationships between a number of highly significant monuments (both upstanding and below ground) in the SW quadrant of the WHS, which contribute to the OUV of the property. And has been set out above, no amount of benefit to the centre of the WHS resulting from the tunnel can mitigate that damage.

The details provided in the documentation do not allow an understanding as to how the severe damage to the WHS deriving from either Highways England Routes D061 or D061 can be compared to the harm/benefits/costs of the other options or the status quo.

viii) Lack of compliance with NPPF
The NPPF makes extremely clear at Paragraph 132 that:
“Substantial harm to or loss of designated heritage assets of the highest significance, notably scheduled monuments, protected wreck sites, battlefields, grade I and II* listed buildings, grade I and II* registered parks and gardens, and World Heritage Sites, should be wholly exceptional.” [Emphasis added.]

For clarity, on this basis, we consider that both Options D061 and D062 presented under the current public consultation would likely result in a very high level of substantial harm (under Para 133 of the National Planning Policy Framework (NPPF)) to a designated heritage asset (the WHS) of the highest international significance, and similarly to many other high value designated national heritage assets within the WHS.

Furthermore, it is clear to us that none of the other exceptions set out in the points at Paragraph 133 of the NPPF apply, and, as other equally, or more favourable, routes for the upgrade of the A303 have been excluded to the south of the WHS, there is no justification for the harm arising to the WHS when this could be entirely avoided, whilst also delivering the same traffic benefits that may result from the removal of the current route of the A303 in routes D061 or D062.


5. CONCLUSIONS
On the basis of evidence set out above, ICOMOS-UK firmly objects to the current option for a 2.9km tunnel for the negative and irreversible impact if would have on the attributes of OUV of the WHS.

To suggest that this damage can be mitigated by benefits resulting from the tunnel to the centre of the WHS, is to fundamentally misunderstand the commitments made to sustain its OUV at the time of inscription of the property on the World Heritage List.

Although we approve in principle the idea of a tunnel for the A303, this is only if:
• All options for constructing a bypass located outside the WHS have been adequately considered via a robust and consistent methodology, and an informed consultation process;
• The tunnel is long enough to ensure that its tunnel portals, associated approach roads and cuttings, and supportive infrastructure do not impact in any way on the WHS or its setting;
• It is clearly demonstrated that temporary works associated with the construction of an acceptable road/tunnel scheme do not cause damage to the WHS and setting, including by construction compounds, haulage roads, and ground treatment/dewater plant and spoil holding lands.
• That construction impacts arising from a tunnel solution do not have a permanent adverse impact on the attributes of Outstanding Universal Value (OUV);
• All necessary Heritage Impact Assessments (HIAs) have been undertaken on the basis of a clear understanding of the attributes of OUV.

ICOMOS-UK does not consider that these parameters have been satisfied, as set out in more details below, and thus we cannot support the 2.9km tunnel option, either with a corresponding by-pass to the north, or with one to the south, of Winterbourne Stoke, as currently proposed in the public consultation document.

The reasons provided for excluding the southern route F010 are not substantial, and inexplicably the lack of harm to the WHS has not been given adequate weighting. Given that this option has no adverse impact on the WHS and can be built for substantially less money than the tunnel, we consider that the decision to exclude if from consultation must be re-considered. Subject to further refinements, this surface route option provides the opportunity to improve the A303 and to safeguard the whole of the WHS and its setting, and these must be the twin aims of this project.

ICOMOS-UK strongly suggests that further consultations be held that explore options for a longer tunnel and also comparative routes to the south of the WHS, with an equal and consistent methodology and scoring being applied for all route options, and one that recognises that WHS status is at least equal to that of an AONB and arguably of much greater significance.

During the pre-consultation options assessment process, we consider that the potential impact on the OUV of the WHS should have been given the highest priority, in terms of determining appropriate parameters for assessing impact, and this in our view does not appear to have been the case.

ICOMOS-UK understands the financial constraints that are in place, and the need to resolve ongoing difficulties with the road network, but does not consider that such constraints can be a justification for compromising a full assessment of potential adverse impact of various options on the OUV of the WHS in advance of decisions being taken, or indeed for inflicting irreversible harm on the WHS which we consider that the proposed tunnel option would do.

4th March 2017

Wednesday 1 March 2017

A303 Stonehenge feedback from a consortium of Stonehenge experts

A303 Stonehenge feedback from a consortium of Stonehenge experts
27 February 2017

About us
We, the signatories to this contribution to the consultation, are senior archaeologists who have carried out internationally recognised research within the Stonehenge WHS within the last ten years or more. Most of us are employed by UK universities; many were employees of various universities or of English Heritage when doing that research. Together, we have been responsible for many of the major discoveries of recent times. We ask this submission be noted with the respect due to the large group of proven experts who have compiled it. This text has been jointly written; it represents our shared collective view.

Until now there has been no effective consultation with us, the wider community of archaeologists studying the Stonehenge landscape. So the opportunity has so far been missed to incorporate into the plans for the A303 our great, fast-growing and fast-changing knowledge of archaeology in and around the World Heritage Site (WHS). All of this knowledge is material which is crucial if the Highways England proposals are to have justified merit. The document we are responding to has evident weakness, as it is clearly based on inadequate and obsolete information. The only effective conduit for upwards communication of archaeological information and evaluation appears to have been through HMAG (Heritage Monitoring and Advisory Group) and Arup Atkins. Neither has thus far consulted the leading experts.

In a public consultation, responses are often measured by counting: X respondents preferred option 1, Y preferred option 2. We ask that this submission not be treated in that way. In constructive spirit, we have made a collective expert group and make this submission, which we respectfully ask be considered in its own right, not just as another view, informed or not, to be counted amongst the Xs or the Ys.

Prof. Mike Parker Pearson FBA FSA FSA(Scot) MCIfA PhD University College London
Dr Umberto Albarella PhD University of Sheffield
Dr Mike Allen FSA PhD Allen Environmental Associates
Dr Barry Bishop PhD University of Buckingham
Prof Nick Branch FSA PhD University of Reading
Dr Christopher Chippindale FSA MCIfA PhD University of Cambridge
Prof Oliver Craig MSc PhD University of York
Dr David Field FSA PhD Formerly English Heritage
Prof Charly French FSA PhD University of Cambridge
Prof Vince Gaffney FSA PhD University of Bradford
Paul Garwood MSc University of Birmingham
Prof David Jacques FSA MPhil University of Buckingham
Dr Nicholas James PhD University of Cambridge
Dr Joshua Pollard FSA PhD University of Southampton
Prof Colin Richards PhD University of the Highlands & Islands
Dr David Robinson PhD University of Central Lancashire
Prof Peter Rowley-Conwy FSA FSA(Scot) RSNA PhD University of Durham
Prof Clive Ruggles FSA DPhil University of Leicester
Prof Julian Thomas MA PhD FSA University of Manchester
Prof Christopher Tilley PhD University College London
Prof Kate Welham MSc PhD University of Bournemouth

1. Do you agree with the proposed option?
No (i.e. the tunnel routes D061 & D062).

The option for the surface road beyond the southern edge of the World Heritage Site (option F010) is the only one which does not have a severe impact on the WHS. Therefore it must be taken. The others have dreadful consequences for the world’s most famous archaeological site and its landscape setting.

Option F010 is cheaper than a tunnelled route through the WHS, another reason for its being adopted. The tunnel options (D061 & D062) have major drawbacks, documented below. These could be allayed if the length of the tunnel is increased to protect much more of the WHS.

The major negative consequences of the tunnel options (D061 & D062) are:
a) The landscape/astronomical impact of the proposed western portal, and its approach road, on the key midwinter sunset alignment from Stonehenge.
b) The destructive impact of the approach roads to the western and eastern portals within the WHS.
c) The expensive and time-consuming requirement to maintain high standards of archaeological recovery, both of artefacts from plough soil and of ephemeral features from hand-trowelled subsoil surfaces, within the WHS.
d) The setting of a bad precedent by allowing large-scale destructive development within a WHS. This ‘lowers the bar’ for allowing development to over-rule conservation within a WHS. It is especially bad when a more beneficial option (F010) is possible.

2. Do you agree with the proposed location of the eastern portal?
We cannot agree until there is adequate information on the character and survival of archaeological deposits east of the proposed portal as far as the Countess junction, site of the present roundabout on the edge of Amesbury

Very little is known about the flanks of the Avon valley at this point. A considerable quantity of flint artefacts of the Neolithic period (the era of Stonehenge) has been collected from the King Barrow Ridge over the years: this was a favoured settlement location at that time and also in the period before (the Mesolithic). A long barrow (burial monument older than Stonehenge) and small groups of round barrows (burial monuments a little younger than Stonehenge) are close to the proposed portal. It is very likely that important, fragile archaeological deposits survive within the vicinity – deposits not yet discovered.

The line of the Stonehenge Avenue, the prehistoric approach route to Stonehenge, should be preserved and reinstated by this scheme. That is good.

Blick Mead is a recently discovered site here on the edge of the Avon Valley. There is concern about impacts of any groundwater reduction on deposits associated with this prehistoric site, which lies immediately next to the present A303. Blick Mead has the longest dated sequence for a settlement of Mesolithic date (the era well before the time of Stonehenge) yet found in Britain, its dates spanning the 8th–5th millennia BC. This long-term use of the area by Mesolithic hunters may explain why the Stonehenge area became a significant focus for the Neolithic people who built Stonehenge just over the ridge from Blick Mead. The D061/D062 road proposal could affect and damage this important Mesolithic site if remains survive north of the current A303 (as is known from archaeological evaluation close to Countess junction). Major modifications to the landscape have been suggested as likely to change groundwater conditions, leading to dewatering and oxidisation on the south side of the A303 where part of this site lies. Any possible effect on groundwater needs to be evaluated before any impact can be properly assessed.

The proposed eastern portal will badly damage the visual setting of the prehistoric hill-fort of Vespasian's Camp and affect its extra-mural archaeological deposits. The hill-fort’s entrance faces north, so any works on the southern flank of the A303 will impinge on this, its natural access point.

3. Do you agree with the proposed location of the western portal?
No.

To understand this point, a brief astronomical mention will help. For more than a century, it has been well-known to the largest public that Stonehenge is oriented towards the north-east, the direction of the midsummer solstice sunrise. This is why tens of thousands go there each Midsummer’s Day. But new research and analysis clearly shows that the primary orientation is on the same axis, but in the other direction, towards the south-west, towards the direction of the midwinter solstice sunset. This remarkable astronomical dimension of Stonehenge is today the most widely known aspect of its singular character, the strongest basis for its world-wide fame. It is one of the most important features of the Stonehenge landscape, one which most of all must be respected and preserved.

But the proposed western entrance of the tunnel lies almost exactly on this winter solstice sunset alignment!

The proposed road-line west of the western portal (and within the WHS) is also broadly on this alignment. If the integrity of this south-west solstice sightline from Stonehenge is destroyed, it will forever prevent visitors to Stonehenge properly seeing the winter solstice sun setting behind the distant natural horizon – exactly as was possible in prehistoric times. This calamity would contravene Policy 3c of the 2015 WHS Management Plan: that the monuments’ astronomical alignments be maintained and enhanced to achieve a good landscape setting.

The proposal will increase the area of road surface within the WHS, particularly at the western portal and to the west of it. Here, the new stretch of road would destroy important prehistoric features that formed Bronze Age field boundaries. One is probably part of a still little-understood ‘palisade’ ditch complex, dating to the Early Bronze Age (the period after Stonehenge). There seems to have been a network of enclosure around Stonehenge, and the area around the monument was in this era apparently devoid of fields, creating a cordon sanitaire around the monument. We can show a similar and fitting respect today by not having a tunnel portal and deep approach cuttings here.

The entrance to this palisade ditch complex – where parallel ditches form a trackway leading in the direction of Stonehenge – is close to this projected line of the new road. Either side of the trackway are Bronze Age field systems, each a separate co-axial unit that may focus on a settlement nearby. All these features are integral to understanding later stages of the construction and subsequent use of Stonehenge. Research excavations in 2008 of an area of Bronze Age field systems north of the proposed road line revealed evidence for Mesolithic, Neolithic and Early Bronze Age activity before the fields were formed, and this is also likely to be the case among these prehistoric field remains that will be destroyed by the proposed tunnel.

This south-western approach to Stonehenge was important not only during the Bronze Age, after the stones of Stonehenge were put up, but much earlier – before the age of Stonehenge. Important visual components of these are three famous barrow cemeteries, specifically the huge Neolithic long barrows at Winterbourne Stoke and Lake. Together standing sentinel over the southwestern approach to Stonehenge, they would have been significant to those occupying the intervening valley. Their prominence a full two millennia after construction – a length of time equivalent to a Roman construction being still of compelling significance to ourselves in the 21st century – is evident from the construction of a Late Bronze Age linear ditch that runs between them.

There are other, vitally important examples of these singular and archaic long barrows here: another is extant to the north of the woodland known as The Diamond; a now-levelled example is in the field system close to the A360. Additionally within view is yet another, the superb and well-preserved long barrow on the southern flank of Normanton Down, with a mysterious and now-levelled ‘mortuary enclosure’ alongside. There is another at Normanton Gorse, and we understand that recent evaluation has encountered another. So we have as many as seven of these Early Neolithic long barrows across that part of the valley where the western portal would be placed. Such a grouping of long barrows in a small area is unique in the world, not just unusual. It shows that this area was out-of-the-ordinary significance during the Early Neolithic period. We can expect that the fast-evolving techniques of field archaeology will lead to major revelations here – if the monuments and their precious setting are not wrecked.

Part of the point of a tunnel or new route is to re-unite the northern and southern parts of the WHS, which are split by the present surface A303 – a road so busy it is dangerous to try to cross it on foot. But the archaeology is just as important in this western area as further east. It is definitely desirable to re-unite this part of the landscape so that one could walk between the Winterbourne Stoke and Lake barrow groups. But the present proposal would only move the road a little, and leave a far larger blot on the landscape than exists at present.

The approach cutting to a western portal here – deep and wide – will inflict a vast gash on the landscape. With the western portal here, this new gash is not in a peripheral or archaeology-free zone, but in one which is, in a different way, as genuinely unique, just as the famous stones are at Stonehenge itself.

The portal and approach road will also be a visual blemish when seen from round barrows right along the flanks of Wilsford Down valley and including parts of the Lake and Winterbourne Stoke groups.

4. Of the two possible routes for the Winterbourne Stoke bypass which do you consider is the best route?
The southern route.

The least damaging option for the WHS is route F010, which follows this southern route. If D062 is adopted (against our recommendations), the line of the southern route (at its east end) needs to be altered so as to avoid the deleterious impact on the landscape setting of one of Stonehenge’s two principal astronomical alignments.

5. What are the most important issues for you as we develop our proposals for the A303/A345 Countess junction?
The Mesolithic site at Blick Mead, already mentioned, is exceptional and precious. In addition, round barrow cemeteries along the Avon valley to both the north and south of Amesbury show that the valley was heavily utilised during the Early Bronze Age. So we can forecast that there will be traces of archaeological activity on the valley floor. The destruction of archaeological deposits existing here has not been given adequate consideration.

6. What are the most important issues for you as we develop our proposals for the A303/A360 Longbarrow junction?
Bronze Age settlement occurs around the present crossroads, and damage of any kind to the surface will require comprehensive excavation. The present lighting here already has a distracting effect on the ‘dark sky’ around Stonehenge because it makes a glowing ‘light-spot’ in the landscape as it is seen in many directions.

This lighting will remain a problem if the junction is moved to the south. While it would be possible to use reduced-height lamp-posts, and full cut-off luminaires to reduce light scatter, in its proposed position this lighting would still distract from the midwinter sunset axis as seen from Stonehenge. Headlights of on-coming cars will be another source of light impacting on the solstice axis.

The importance of the archaeology of this area is outlined above: a significant Early Neolithic focal point pre-dates Stonehenge and the area then continues in importance through the Early and Middle Bronze Age (that is, also post-dating Stonehenge). The archaeology here is subtle and fragile – and at present little understood. It deserves to be preserved and treated with extreme care, rather than regarded as not of consequence

7. Do you have any other comments?

1) Radical and continuing changes in our understanding of Stonehenge, its landscape and archaeology
Archaeology, like so many scientific studies, is radically changing in its methods. New technologies, such as the 3-dimensional radar method of «LIDAR», have transformed our ability to detect traces too faint for the naked eye. Old techniques of excavation and field survey have been transformed by hi-tech innovations. So our knowledge of the Stonehenge landscape has been radically changed in the last 20 years: too many new and astonishing finds to state here, they fill many recent books. The extraordinary and unique Blick Mead site (above) is a new find, and so are astonishing new aspects to Durrington Walls, a long-known site within the WHS that continues to yield new information about the Neolithic people of Stonehenge. We can anticipate that these new discoveries will continue to be made. It is dangerous to plan on the basis that what we know now of the ancient landscape is all that exists in the ancient landscape.

2) The short term and the very long term in planning the future of Stonehenge
The standing stones and structures – the famous part of Stonehenge – are well over 4,000 years old. Other parts, less obvious to the untrained eye, are many centuries older. Other monuments in the WHS landscape are yet older still, by many more centuries. The Blick Mead Mesolithic site is twice as old as the stones at Stonehenge! Where planning normally deals with the short term, of decades extending perhaps into a century or so going forward, and often must notice the medium-term surviving traces such as 18th- or 19th-century or even medieval buildings, planning in the Stonehenge landscape must deal with a long term, indeed a very long term of several thousands of years.

It follows that planning at Stonehenge must be cautious and always propose minimal intervention. There is no area in the WHS where we can say, ‘We know that it is safe to place a tunnel portal or major new surface road here because there is nothing there which is important now or will be seen as important in the future.’

Therefore the whole tunnel option is misconceived. The option avoiding the WHS must be preferred.

3) A history of soon-regretted, short-term errors in caring for the Stonehenge landscape
In the century since Stonehenge came into public ownership at the end of the First World War, there have been several big buildings put into its landscape. Each was seen as sensible at the time. Yet within as short a time as a decade (!) each was seen as a mistake, so grave a mistake it was not just regretted but demolished. So each modern structure has now disappeared from visible view. Yet the scars left, irretrievably wrecking the archaeology, will never be repaired. Here are three of them.

• Immediately after the then Ministry of Works began to care for Stonehenge, it was obvious that houses for its custodial staff should be built nearby, so the stones would always have guardians close by: within 15 years, the houses were demolished as a hideous and wrong intrusion.

• At much the same time, it was obvious that visitors needed refreshment and facilities, so a Stonehenge Café was built close by: again, within 15 years, the café was demolished as a hideous and wrong intrusion.

• In the 1960s, it was obvious that the car-park was too small, the working buildings for custodians too small and the refreshment facilities were poor. And it was dangerous for visitors to walk across the fast and busy A344 road to reach the stones. So in 1969/70 a large car-park, semi-underground buildings, and access tunnel under the A344 were built. This was uncontroversial, an obvious improvement. Yet, within 15 years, the head of English Heritage declared their abolition to be its highest priority, and MPs called these facilities a ‘national disgrace’ which must be removed. Now they have been, leaving a wrecked area so close to Stonehenge covering several hectares.

4) The two Stonehenge astronomical alignments, that to the north-east and that to the south-west, in public understanding and perception
Because Stonehenge is so famous, public perceptions of it are held right across the world and are often understandably out of date. In the 1960s a widespread notion was that Stonehenge was not just astronomically aligned but was itself some kind of prehistoric computer or calculating machine to predict eclipses: this idea is still broadly held, although the evidence is strongly against it.

We can see that informed and expert opinion has now decidedly shifted towards understanding that the main astronomical alignment at Stonehenge is not north-east towards the midsummer sunrise, but south-west towards the midwinter sunset (above). Yet only now are the public beginning to visit to see the midwinter sunset rather than the midsummer sunrise. We can expect it will be 20 or 30 years before that newer understanding is commonplace. Notice the time-frame it takes for mistakes to be understood: between 10 and 15 years. If a western tunnel portal is built on that midwinter solar alignment, in the early 2020s, we can forecast that it will be universally seen by the late 2030s to be another short-term disaster – one which is far bigger, has far more impact and is irreversible in a way that the disasters of the previous century were not. The wretched 10–15 year time-span from ‘sensible’ to ‘disastrous’ will have been repeated!

5) The cost and timetable of the required highest-quality archaeological study
Any proposed works on the line of the A303 will require considerable and costly archaeological excavations. These must be carried out to the standards maintained by recent research projects within the WHS. The Stonehenge Environs Project of the 1980s and the Stonehenge Riverside Project of 2004–2009 proved that much archaeological evidence for prehistoric activity around Stonehenge survives only in the plough-soil. And evidence which survives as truncated, features cut into the chalk – pits, post-holes, stake-holes and tree-holes – is mostly ephemeral, so it is not always detected by standard excavation strategies that concentrate on machine-stripping to bedrock and only cursory surface cleaning of the bedrock’s surface.

Such hard-to-recognise evidence may be unwittingly destroyed without record. So the mitigation work must include arrangements for sampling and screening/sieving a suitable proportion (2%–4%) of the plough-soil prior to machine-stripping, and hand-trowelling of all machine-stripped trench surfaces to ensure recovery of all archaeological features regardless of size or visibility. This work is expensive in labour and time, especially since the proposed scheme would require the largest archaeological excavation ever undertaken within the WHS. Without shared standards within the WHS, there will be no possibility of drawing comparisons between different 21st-century excavations to evaluate and understand the character, date and extent of the more ephemeral traces of prehistoric activity around Stonehenge.

6) The integrity of the Stonehenge World Heritage Site
Until a century ago, it was only the stones themselves which were seen to constitute precious prehistoric Stonehenge. First World War photographs show artillery field guns being hauled through the very monument – ‘safe’ as long as they did not hit the actual stones. Increasingly, we have come to understand that Stonehenge is not only the stones, not only the eroded earthworks immediately near the stones, but a whole landscape extending to the horizon in most directions and even beyond. This fact was recognized when the WHS was defined as an area extending several kilometres from Stonehenge in each direction.

The integrity of the WHS was respected when new visitor provision was designed in the 2000s. Sites for a visitor centre were not sought within the WHS: the visitor centre must be on its margin, and was so built. Further access paths and roads to and from Stonehenge must not cross the WHS and interfere with its archaeology: so a scheme was devised which uses the former A344 line for access, a choice which has meant nil new impact with in the WHS.

The proposal for D061/D062 is a sad and retrograde step. Instead of respecting the WHS as defining the area to be protected, it recognizes only the land which is visible from the stones themselves – a throwback to the limited ideas of 1916! It seeks to protect archaeological remains along the 2.9 km across the WHS which lies above the line of the tunnel, but cheerfully destroys everything within (and, in places, beside) the road’s footprint along a length of over 2 km – nearly as long – of the WHS. And it inflicts within the WHS two enormous and deep approach cuttings to the tunnel portals.

7) Cost and benefit: why is Highways England’s preferred option both more expensive and more damaging?
We are at a loss to understand the preference for the tunnel scheme. It is more expensive than the southern surface route (option F010). It is vastly more damaging than that option avoiding the WHS. The international significance of the Stonehenge WHS should, in our view, trump a collection of middle-order concerns about effects on nationally or locally important aspects of the broader environment that were given as reasons for rejection of route F010 prior to this public consultation.

8) Standards in heritage protection: the UK’s deserved high reputation
The UK has an international reputation for the quality of its heritage protection and enhancement; that reputation can only be maintained – setting the bar high enough to encourage others to reject large-scale damaging developments in other WHS sites around the world – if the length of the proposed tunnel is more appropriate to the 5km-width of the WHS which the road line will traverse, or if the southern surface route is chosen.