Monday 26 September 2016

Stonehenge Visitor Numbers Kept Secret

An FOI request:

Dear Historic Buildings and Monuments Commission for England,
Please can you provide the daily visitor numbers to Stonehenge between 1st March 2015 - 31st December 2015
Yours faithfully,
Edward Shepherd

An Answer from Lynda Bennett, Historic England

I can confirm that English Heritage holds information that falls within
the scope of your request. However, I have decided to withhold this
information as I believe it to be exempt from disclosure under Section 43
(2) of the Freedom of Information Act 2000. Section 43 (2) provides an
exemption from disclosure of information which would or would be likely to
prejudice the commercial interests of any person. (A person may be an
individual, a company, the public authority itself or any other legal

A commercial interest relates to the organisation’s ability to participate
competitively in a commercial environment. I have concluded that the
information does fall within the scope of the exemption as it relates to
services provided by English Heritage and the level of usage of those

In considering the nature of the prejudice I have concluded that the
disclosure of the information would be likely to prejudice the commercial
interests of English Heritage. The charity is facing the challenge of
becoming self-funding within eight years of its launch. This is dependent
on achieving ambitious revenue targets which are, in part, connected to
Stonehenge, which accounts for a significant proportion of the charity’s
earned income. It is crucial for the on-going commercial viability of the
charity that it is able to operate in a commercial environment on a level
playing field with its competitors.

Despite being an iconic attraction, Stonehenge relies heavily on
attracting inbound tourists out of London and to do this the charity has
to negotiate and work with multiple domestic and international travel
trade operators each of whom are seeking a favourable commercial package
individual to them. At the same time, other attractions outside of London
are seeking to win this market, including those within the South West and
along the M4 corridor, including Bath and Windsor. London remains by far
the major beneficiary of inbound tourism to the UK and attractions outside
of the capital have to work hard to persuade London-based tourists to
journey outside. When they do, they typically visit on very tight
itineraries, normally only one day. Additionally there is a further
challenge at Stonehenge of managing the site during a period of major
upheaval to local traffic routes with the proposed A303 tunnel
development, which is likely to make it harder to continue to attract

The B2B pricing strategy for Stonehenge is complex with a range of
discounting measures. Disclosure of the daily figures weakens the ability
to use differential pricing as a tactic and exposes business data to other
players. This information would be useful to competitors and place
English Heritage at a distinct disadvantage particularly as its
competitors are not required to publish detailed visitor statistics, as
the vast majority are not subject the Freedom of Information Act. I
consider it is more probable than not that competitors would be likely to
use this information to target their own services and that it would likely
compromise English Heritage’s position in negotiations with travel trade

As section 43 is a qualified exemption and is therefore subject to a
public interest test I also have to consider whether the public interest
in withholding the information outweighs the public interest in disclosing

In favour of disclosure I have considered the public interest in
accountability and transparency of public authorities in the spending of
public money and facilitating the accountability and transparency of
public authorities for decisions taken by them. I have also taken into
consideration that English Heritage provides annual figures which provides
a degree of accountability and transparency in this respect.

In favour of maintaining the exemption I have considered that the grant in
aid funding received by English Heritage is tapering under the New Model
arrangements and that generating additional income is necessary to
conserve and safeguard a priceless collection of unique monuments and
sites in keeping with their status as part of England’s national heritage.
Therefore there is a strong public interest in English Heritage achieving
its key priority of becoming financially independent by 2022/23.

Having considered the above arguments I have concluded that the public
interest is best served by maintaining the exemption.

Lynda Bennett

Head of Information and Records

Information Management & Technology Department

Room 2/07, Engine House, Swindon, SN2 2EH


  1. Wow indeed...

    The legal equivalent of Bugger Off not telling.

    as the Marx Brothers would have said this should have a Sanity Clause and we all know there aint no........

  2. Thanks for posting Tim. Very interesting, and is this proof that EH are giving different travel trade operators different rates, therefore giving preferential rates to some and not to others? Is this allowed under their charity charter?