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Stonehenge - the alert in depth
The effect of the proposals
Little has been made of the legal and logical bases upon which these plans for the Stonehenge Project are being promoted but what little has been said is surprising, to say the least.
Access by means of a “Land train”
As part of the plans English Heritage is promoting a state-of-the-art replacement visitor centre close to the eastern edge of the WHS. An improvement is clearly needed but a number of other potential sites for it exist, all of which would enable access onto the WHS along existing access tracks and roads. The location chosen by EH does not, unless the A303 is either diverted or placed in a long bored tunnel, so a brand new “land train” system is proposed in order to ferry visitors from the visitor centre to points closer to the stones. This would involve transit vehicles each comprising up to four articulated coaches running on roads on built-up embankments laid over a specially laid geotextile layer. Claims that the tracks will not damage archaeology cannot be demonstrated and in any event, all sides have acknowledged that the land trains and their tracks would be a significant new visual intrusion into the landscape. It would be fair to say that support for this concept outside EH is limited.
Compliance with the World Heritage Convention
Britain has a Convention obligation to protect the whole of the World Heritage Area; so deliberate major damage to any part of it would not seem to be an available option. Yet EH has sought to address this apparently insurmountable reality by claiming that it is acceptable to weigh the benefits of the Project in one respect (the “rehabilitation of the setting of the henge itself”) against negative effects elsewhere (the detrimental impact of the A303 works and the 'land train' ). But it is not clear how such a right arises. Nothing in the Convention text appears to sanction causing damage on the basis that “the ends justify the means”.
Damage might well be acceptable in cases where it was minor and unavoidable, but this situation is hardly of that nature: the land train would be a major new intrusion, not a minor matter, as would the building of two miles of four lane highway across the World Heritage Site, and in neither case is the intrusion unavoidable – alternative choices most certainly could have been made.
Image by Pebs
That alternatives do exist and were previously explored has been openly acknowledged, but the government has recently made it clear that the cost is unacceptable. Hence, the A303 Published Scheme is being presented and supported by EH and others as the only deliverable solution even though other non-damaging solutions such as a longer tunnel or a bypass around the whole area do exist and are rejected purely for financial reasons. This is crucial, since Section 111 of the Operational Guidelines for the WH Convention identifies “the allocation of necessary resources” as an appropriate element of a management system and Article 4 of the Convention itself commits participating governments to protect monuments “to the utmost of their resources” and beyond that with “international assistance”.
Consequently, EH’s support for the A303 Published Scheme looks puzzling at best. A unilateral interpretation of the Convention claiming that damaging the Stonehenge WHS is acceptable because non-damaging solutions exist but have been rejected on cost grounds seems no basis at all. EH has yet to demonstrate convincingly how the road and visitor centre schemes are compliant with the World Heritage Convention.
In addition, EH’s statutory position makes its support for these schemes doubly strange: it has a statutory duty to protect monuments and is the government’s statutory advisor on the historic environment. In its own words it acts as “a national and international champion for the heritage”. As such, we would contend that its responsibility to protect heritage is a long-term one and not primarily connected to fleeting political or financial policies. Whilst it cannot insist that politicians spend sufficient money to properly protect Stonehenge, it can advise them and publicly state what IS the best for Stonehenge. Instead, we seem to have reached a position where EH is publicly promoting a damaging solution and interpreting the Convention to fit. In our view, EH’s proper role should be to advise the government that the A303 Published Scheme is simply not adequate and if Stonehenge is to be properly protected either the road must not be built or it must be built fully under or fully away from the Stonehenge World Heritage Site. Similarly, a land train track should not be constructed across the open Stonehenge landscape.
Two more bodies in favour.
The UK National Commission for UNESCO (set up by the government to advise it on UNESCO matters) has recently joined EH in supporting the road and visitor centre schemes. As in the case of EH however, the cited reasons do not centre upon the damage but upon matters of a pragmatic nature – an evaluation of alternatives would involve years of further delay, the Published Scheme is the only one that could be delivered within the next five years, further delay would be unfair on visitors, local residents and businesses and would fail to address safety and congestion issues or the potential tourism benefits that the Olympics are likely to bring.
Again like English Heritage, this body does not explain how the building of dual carriageways across the WHS is compliant with our UNESCO obligations. It does mention that in 2003 the World Heritage Committee “indicated that a bored tunnel solution would be appropriate”, but this is of course not the same as UNESCO having said that a short tunnel would be acceptable, which it hasn’t.
We should stress that despite its name, The UK National Commission for UNESCO is not a UNESCO body but one set up to report to the UK government. It is important that the public does not confuse it or its views with ICOMOS-UK, the British division of the International Council on Monuments and Sites. ICOMOS is one of UNESCO’s named key advisors and ICOMOS-UK is one of the very many organisations that are entirely opposed to the Stonehenge proposals.
A third body which has supported the proposals is The Society of Antiquaries (although by no means unanimously – some of its Fellows are reported to support small-scale, interim improvements to the existing road network pending further investigation into options that avoid impacting on the World Heritage Site, as put forward by a group of conservation organisations).
Once again, this body cites non-archaeological reasons in favour of the A303 Published Scheme – “added economic value to the SW of England”, “other options will require years of further consultation”, “the best chance for completing the road improvement in time for the Olympics” and “the disproportionate added cost of significantly extending the length of the bored tunnel”. Yet again however, the damage that the proposals entail is not at the centre of the submission.
That the A303 Published Scheme is not the ideal solution is very clearly acknowledged by all those supporting it. As the Society of Antiquaries says: “Whilst in an ideal world longer bored tunnel solutions would bring maximum benefits they would also add significantly to engineering and hydrological difficulties”. It is noteworthy that these words are precisely the ones employed by the UK National Commission for UNESCO. Read in conjunction with the government’s unambiguous view that longer tunnels “are deemed unaffordable” and EH’s view that the Published Scheme is the only deliverable solution, the implication is clear: the crux of the pro-road scheme case is that it is not the best option, it is the only option the government is prepared to pay for. Stonehenge is not to be offered the best.
Remaining voices in favour
In June 2006 (employing what strikes us as a somewhat forced use of the term “news”) EH published a "news item" on its website titled “Support for the 2.1 km tunnel at Stonehenge continues”. This contains a selection of quotes from those who support the scheme.
Readers must judge for themselves, but our own view is that considering the importance of the heritage issues involved, the number of pro-Scheme voices from the world of archaeology or heritage is not high. Indeed, apart from the two supporting bodies mentioned above, only four individual archaeologists are cited as supporting the Published Scheme and the remaining quotes come from the non-archaeological worlds of motoring or politics. In addition it is evident that the reasons given for supporting the scheme are once again mainly pragmatic ones and do not address the most important issues - “damage” and “UNESCO obligations”. There is also emphasis upon the great advantage of replacing the visitor centre, but since replacing it in some form and in some location is universally agreed as being a central and easily achievable aim whatever solution is adopted it is hardly something that can be represented as a point in favour of the A303 Published Scheme.
Readers may wish to consider whether a news item that contains 750 words in praise of the road Scheme and not a single one even mentioning that it involves building two miles of new highway over the World Heritage Site is fully informative for the public.
Some puzzling aspects of the pro-scheme case
It is a matter of some confusion that the supporting bodies represent as acceptable the archaeological damage that would be caused by constructing new highways across the WHS under the Published Scheme, while they are vigorous in saying damage is unacceptable when considered in relation to rejected alternatives. EH say the “Southern route” is unacceptable “because it proposes a new above ground line in the WHS” and because it breaches the principle contained in the WHS Management Plan that “acceptable improvement must be on line and in a tunnel because the impact of any major new highway in the WHS is unacceptable”. In addition, all the other options were “unacceptable because they either damage archaeology and the WHS or fail to deliver the aims of the WHS Management Plan.” The UK National Commission for UNESCO says much the same: “New surface routes within the WHS would be significantly damaging to archaeological and historical sites” as does The Society of Antiquaries in making reference to “The inferiority of the surface routes and their negative impacts on archaeology and natural environment of the WHS”.
We are at a loss to see how these five quotations do not also apply to the two miles of new surface highways across the WHS proposed by the A303 Published Scheme, and the 3.5km of new road for the land train access routes. New highways will damage archaeology to an enormous degree. We doubt if the pro-Scheme bodies would disagree. They have simply not said so in the case of the Published Scheme.
In all three cases the A303 Published Scheme is supported on the basis that it provides a balance. In the words of the UK National Commission for UNESCO: “the Published Scheme is the best balanced option for achieving a sustainable solution to meet the objectives of the Management Plan, the principles of the [World Heritage] Convention and deriving substantial public benefit”. In our view major damage should not be available for balancing against other considerations, especially when it is avoidable by spending more money – or none al all by not pursuing the Scheme. As to balancing the requirements of the World Heritage Convention, we do not see any justification for doing that either (see later). Finally, balancing the demands of the Management Plan also seems invalid here since that document is clear that protecting the archaeological landscape is its primary aim.
Image by Jimit
Unlike the proponents of the Stonehenge proposals we do not believe it is acceptable to compromise on the welfare of Stonehenge in order to enable the government to deliver the road within the financial limits it has imposed. In view of this we are particularly dismayed by two aspects of the way in which EH as a government QUANGO (and therefore not entirely independent of HM Government) came to its current supportive position.
Firstly, the road scheme was the brainchild of EH not the Highways Agency. At the A303 Inquiry, it was established that EH was the initiator of the A303 Improvement Scheme and that the HA had been asked to draw up proposals for it, to include a short tunnel. The HA said at the Inquiry that they did not consider the scheme to be a priority on road transport grounds (there were other roads that had more pressing problems with congestion etc); the Stonehenge scheme was in the Roads Programme as a 'heritage' scheme! EH said at the Inquiry that it was the best scheme 'on offer'; it was 'affordable'.
Secondly, we are concerned by the apparent lack of transparency that seems to exist in regard to EH’s reasoning and the way they formulated their decision:
A.) Their submission in response to the government’s Public Consultation on the options commences with the phrase “As prefigured at our meeting with the Minister”;
B.) It goes on to state: “As supporting reports establish, English Heritage’s curatorial and WHS views are in accord with managerial ones. Detailed assessment to that effect has been validated by the EH Advisory Committee and endorsed by Commission”. But the supporting reports are not made public so EH’s reasoning is not known and was approved internally by, in its own words, “an internal validation process” and, in the case of the archaeological/heritage aspects relating to the Visitor Centre EH simply acted as advisor to itself.
C.) EH’s submission also states “This letter will not go into technical detail about archaeological impact; the long deliberations shared by the English Heritage curatorial team and the [Highways] Agency’s consultants have ensured mutual understanding of matters referred to in shorthand below.”
Bearing in mind all of the above we are left wondering whether this most important heritage decision of the century was conceived and formulated in an adequately open, inclusive or transparent fashion.
What will UNESCO say?
Will UNESCO be convinced by the scheme? It is a very moot point, despite the general statements made by the three pro-Scheme bodies that the proposals fulfil our Convention obligations.
UNESCO hasn’t done so yet, for certain. There does not appear to be any obvious scope in the Convention for State Parties to cause major damage that is demonstrably unnecessary because clear alternatives exist. Nor is there scope to plead cost reasons (as explained previously, the Convention appears to say precisely the opposite). Finally, it seems very probable that UNESCO will receive advice from ICOMOS, the International Council on Monuments and Sites (one of its named key Advisory Bodies) that the Published Scheme is unacceptable – since that is the view of ICOMOS –UK.
Yet the plans are proceeding and being promoted as if UNESCO issues are resolved. For instance, The Society of Antiquaries says their support for the Published Scheme is “in recognition of the intergovernmental World Heritage Committee's approval for a bored tunnel solution when published in 2003”. But that was for a long bored tunnel, not a short one. In the same way, EH has said: “Both the published Scheme and the new visitor facilities need to be delivered in full if the UK is to fulfil its responsibilities under the World Heritage Convention” whereas we and many others contend that the precise opposite is the truth.
For plans to have progressed so far without a strong understanding that they can be delivered seems inconceivable. Is it possible that the government intends to claim a sovereign right to act in the way it sees fit? A statement by the UK National Commission for UNESCO might signal this: “The UNESCO Convention is respectful of the sovereignty of the State Parties and those measures have clearly been followed in reaching the Published Scheme.” We suggest that from the viewpoint of anyone hoping to see Stonehenge protected under the WH Convention this statement could be characterised as ominous.
Further statements by the same body serve to heighten this concern: “Though ICOMOS has suggested a longer-bored tunnel might be better, this matter was fully considered at Public Inquiry, and we accept the Inspector took full and proper account of all arguments in reaching his conclusion. The UKNC does not concur with the view expressed in a recent press release that the Inquiry was flawed, nor that a judicial review is required.” Since no one, including the Inspector, could actually deny that a longer-bored tunnel would indeed be far better in protection terms, we find it disturbing that the tone is more suggestive of a wish to dismiss it on legal grounds not on its merits. If ICOMOS is right, it is right and the fact should be acknowledged wholeheartedly not undermined on the grounds that an Inspector has taken account of the government’s wish to save money or acknowledged vaguely or obliquely by phrases such as “in an ideal world”.
In Conclusion
A realistic view of the world leads us to wonder whether despite the fact that there appears to be no scope whatsoever for the A303 Published Scheme to be considered compliant with the UNESCO Convention, that body might well still approve it.
If that happens then it seems that despite the fact that, in the words of Lord and Lady Kennet, campaigners for the Stonehenge Alliance, “these plans are deeply wrong, and objected to by most of the relevant, well-informed, bodies”, vast permanent intrusions into the World Heritage landscape might soon be made.
Stonehenge requires a true champion. If, as seems likely, this role is not to be taken on by the government or the government’s statutory advisor on heritage matters or the government’s advisor on UNESCO matters or perhaps even UNESCO itself, it falls to the public to protect it.
We hope as many people as possible will voice their opposition to what is happening. Anyone who wishes to delve deeper into the issues can do so on the admirable website Save Stonehenge. A group of very prominent heritage bodies has been formed under the name The Stonehenge Alliance to express opposition to the plans and to propose small-scale improvements pending further investigation into non-damaging solutions. We commend their suggestions, voiced in Save Stonehenge and elsewhere, as an expression of what we truly owe to Stonehenge and posterity.
Our own expression of the suggestions for immediate and worthwhile small-scale improvements can be viewed on our page Achievable Stonehenge. Not a comprehensive or final solution but improvements nonetheless and as much as can be responsibly proposed until such time as there is a will to adopt a solution that doesn’t involve driving new highways in deep cuttings and new roads on embankments across the Stonehenge landscape.
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