Stonehenge, Avebury and Associated Sites

• Need for information on the management (issue resolved)
• Site Museum project (issue resolved)
• Risks of collapse of Silbury Hill (issue resolved)
• Lack of visitor management (issue resolved)
• Upgrading of the A303 trunk road project
• Infrastructure development pressure
• Proposals for sections of dual carriageway and tunnel portals within the property
• Effects arising from use of transportation infrastructure
• Ground transport infrastructure
• Underground transport infrastructure

N/A

On 1 February 2024, the State Party submitted a report on the state of conservation of the property which is available at https://whc.unesco.org/en/list/373/documents/, and which reports on the conservation issues addressed by the Committee at its previous sessions, as follows:

• Partnerships between property owners, regulators, individuals and organisations continue to support the management of the property and its surroundings;
• There is a strong focus on the holistic stewardship of the landscape of the property through day-to-day management, as demonstrated through a wide range of initiatives such as exhibitions and events, links with other World Heritage properties and tertiary institutions, guided walks, improved walking path access, cross-farm approaches, chalk grassland reversion, agri-environment schemes, and a new Avebury community exhibition space;
• Work continues on a new partnership governance structure, which will be completed during 2024. The World Heritage Site (WHS) Coordination Unit is updating the Management Plan for the property which is expected by March 2026;
• The Trust Transition Project has progressed and the Board, which includes a representative from each organisation and key stakeholder group on the WHS Partnership Panel, has agreed to establish a charity to raise funds for projects arising from the Management Plan;
• Progress on the Setting Study has been delayed but it will resume during 2024 with the intention that it will be adopted as a Supplementary Planning Document that will become a material consideration in the determination of planning applications in or affecting the property. It will therefore undergo public consultation and be submitted to the World Heritage Centre;
• Wessex Archaeology has been commissioned to undertake the Site Condition Survey and has completed a desk-based assessment to inform the fieldwork phase, which is due to be completed during 2024 and which will be submitted to the World Heritage Centre;
• The locations and designs for new education facilities to support the Stonehenge Visitor Centre have been revised following technical review by ICOMOS, with revised designs submitted to the World Heritage Centre in January 2024.

In relation to the A303 road Improvement Scheme (Scheme), which would include the construction of a tunnel section and an open four-lane [motorway][highway] within the Stonehenge component of the property:

• A second Development Consent Order (DCO) was issued by the Secretary of State for Transport in July 2023 providing consent for the project and setting parameters for its implementation, (as already acknowledged by the Committee);
• In January 2024, the State Party provided a package of information to the World Heritage Centre, which identified the following design developments:
  • The addition of 3.5 m-wide cantilevered sections along each side of the length of the proposed western cutting; and
  • The addition of a second 150 m-wide green bridge across the proposed western cutting;
• The State Party considers that the above design developments, which would cost an additional £50 million (and sit within the parameters of the approved DCO), will help to reduce the visual impact;
• The information submitted by the State Party includes a ‘Heritage Impact Assessment for Cantilevers and an Additional Green Bridge’, identification of possible locations for the additional green bridge, and advice from the project’s Heritage Monitoring Advisory Group [members];
• The information provided by the State Party indicates that a longer bored tunnel extending to the boundary of the property, or a cut-and-cover section of the same length, as requested by the Committee and recommended by the 2022 Advisory mission, would present various practical challenges and incur additional costs;
• The State Party also advised that a comprehensive programme of archaeological investigations would occur prior to the construction of cuttings on either side of the proposed tunnel, following a Detailed Archaeological Mitigation Strategy, which will meet the DCO requirements;
• The State Party considers that the consented Scheme provides the ‘best available solution to remove the existing busy road from the surface of the property, delivering a positive heritage impact and the best available outcome for the OUV of the property’;
• The State Party further states that, in its view, the consented Scheme does not meet any of the criteria of Paragraph 179 of the Operational Guidelines, which would justify the inscription of the property on the List of World Heritage in Danger.

Following the Committee’s request to the State Party to ‘consult with the World Heritage Centre and the Advisory Bodies, to ensure consistency in this regard [proposed modifications to the Scheme conforming to the requests by the Committee in its decisions as well as in line with the recommendations of the 2022 Advisory mission]’, two meetings between the State Party, the Advisory Bodies and the World Heritage Centre were organised on 11 January and 11 April 2024.

At the meeting on 11 January 2024, the State Party presented the above design developments and informed that contracts for the construction of the Scheme had been awarded (subject to the necessary approvals), but that substantive construction would not commence until 2025.

In February 2024, the State Party notified the World Heritage Centre of the UK High Court’s decision to dismiss a judicial review application brought by the Stonehenge Alliance challenging the legality of the Secretary of State’s decision to grant the DCO, and of the Court of Appeal’s dismissal of a related challenge to the Department for Transport’s environmental assessment of the cumulative carbon impact of road schemes. On 11 April, the UK Department for Culture, Media and Sport informed the World Heritage Centre and the Advisory Bodies that the A303 Scheme was awaiting a decision from the Court of Appeal by the end of April, following an appeal brought by the Stonehenge Alliance.

The World Heritage Centre became aware through a media article of a road closure outside the western boundary of the property and of works being undertaken by Scottish & Southern Electricity Networks (SSEN) on behalf of National Highways to lay high voltage electricity and fibre optic cables required for the A303 Stonehenge Project. The State Party states that such works are not covered by the DCO.

On 22 May 2024, the World Heritage Centre was informed that the Stonehenge Alliance had been granted permission to appeal against the High Court’s decision of February 2024.

Progress continues on the revised management and governance of the property, including through collaboration and partnerships among interested individuals and organisations, and initiatives such as exhibitions and events. The commitment by the State Party to submit the draft Setting Study and Site Condition Survey to the World Heritage Centre for review by the Advisory Bodies responds to previous Committee requests (Decisions 44 COM 7B.61 and 45 COM 7B.62). The design of the proposed new educational facilities within the Stonehenge component of the property has addressed the findings of the Technical Review by ICOMOS.

The proposed A303 Scheme remains a threat to the Outstanding Universal Value (OUV) of the property. Notwithstanding the Committee’s requests at its last session that the Scheme be redesigned to remove the [circa 850 m of open cutting at the western end of the][3.5 km] four-lane highway [in cuttings] within the property, the proposed design developments put forward by the State Party retain these cuttings. The proposed changes are for 3.5 m-wide cantilevered sections along each side of the length of the proposed western cutting, and a second 150 m-wide green bridge also across the proposed western cutting. Moreover, contracts for the construction of the DCO Scheme have been awarded (subject to necessary approvals) and [preliminary[preparatory] works are taking place in 2024, with substantial construction to proceed in 2025. While the [preliminary[preparatory] works are outside the property and not subject to the DCO, they do not comply with the request of the Committee in Decision 45 COM 7B.62 that ‘all further decisions or actions to implement the Scheme in its current approved state are halted until the Committee has reviewed the comprehensive information package of proposed modifications at its 46th session.’

The reason why the Committee requested that the cuttings be removed from within the inscribed property was that they would have major negative impact on the overall prehistoric landscape. This impact is not only due to the adverse visual effect of the [motorway][highway] cuttings. The excavations necessary to create the [3.5 km] cuttings would require the removal of extensive archaeological deposits and features dating from the early Neolithic period, and in particular material dating to the Beaker/Early Bronze Age (c. 2450-1700 BC), which is generally contemporary with the later stages of construction of the main henge monument. This intervention would therefore also compromise the physical intactness of the highly significant ancient cultural landscape.

The name Stonehenge applies to both the main henge and to the wider landscape and this has at times led to confusion. What needs to be protected is not just the henge but the overall landscape of which the henge is a central focus. The main henge is a highly visible and well-known monument and the proposed tunnel would improve its immediate setting, but this monument has to be considered in its context, surrounded by and inextricably linked to a large number of prehistoric features, which together form an ancient landscape. It is the entirety of the inscribed landscape that constitutes the Stonehenge component of the property, not just the main henge monument. This interrelated ensemble of sites is regarded as a designed ritual landscape, with barrows and other features deliberately sited to be mutually visible. The proposed cuttings would sever some of those important connections and compromise the integrity of this prehistoric landscape.

Although the State Party considers that the consented Scheme provides ‘best available outcome for the OUV of the property’, that is within the limits that the State Party itself has set for this project. The Scheme has been the subject of four Advisory missions since 2015, and five Committee Decisions since 2017. An initial DCO was first issued in 2020, contrary to the requests of the Committee and the findings of the State Party’s own Examining Authority but was later quashed by the UK High Court in 2021. The second DCO, issued by the Secretary of State for Transport in in July 2023, granted consent for the project and set out implementation parameters, and was also the subject of an appeal to the High Court, which upheld the 2023 decision to grant the DCO on judicial review in February 2024.

The proposals for changes to the consented Scheme put forward by the State Party would have only very modest visual benefits. The two bridges would allow access across the four-lane highway, but would not minimise, or even reduce the impact on archaeological resources or the integrity of the landscape. The current main road through the landscape is undesirable, but the proposed cuttings represent a more serious and irreversible threat to the OUV of the property. Furthermore, these changes do not comply with the ‘minimum’ requirements previously determined by the Committee, nor do they align with the recommendations of the 2022 Advisory mission, and they do not offer what was sought in the request for corrective measures set out in Decision 45 COM 7B.62, which provided an explicit indication that:

“the minimum change required must include an extension of the underground section of the western approach (in tunnel and/or cut-and-cover) to at least the western boundary of the property, with the western portal relocated as far west as reasonably practical, thereby reducing the length of the cut-and-cover section and minimising the extent of archaeological resources which must be removed”;

and noted that:

“the approved A303 road improvement scheme within the Stonehenge component of the property retains substantial dual carriageway sections exposed in cuttings, particularly those at the western end of the Stonehenge component of the property and that, at the present time, the A303 road improvement scheme, as approved by the DCO, constitutes a potential threat to the property, in conformity with Paragraph 179 of the Operational Guidelines, which, if implemented, would have deleterious impacts on the OUV of the property including its integrity, warranting inscription of the property on the List of World Heritage in Danger”.

The package of information provided by the State Party includes a Heritage Impact Assessment (HIA) for the proposed cantilevers and additional green bridge, an indication of possible locations for the additional green bridge, and advice from the project’s Heritage Monitoring Advisory Group [members]. The State Party has strongly argued that the consented Scheme does not meet any of the criteria set out in Paragraph 179 of the Operational Guidelines, citing in particular: iv) serious deterioration of urban or rural space, or the natural environment; and v) significant loss of historical authenticity; and therefore contends that: there are no justifiable grounds for the inscription of the property on the List of World Heritage in Danger. However, this view is not consistent with the likely impact of the construction of the Scheme which, even as modified in January 2024, retains substantial dual carriageway sections exposed in cuttings, particularly at the western end of the Stonehenge component of the property.

It has been the clear and consistent view of the Committee, the Advisory Bodies and the World Heritage Centre for a number of years that the proposed intrusion of a portal and surface road on the eastern side of the property was accepted as the least impactful practical solution, but that the minimum requirement to the west comprises an extension of the underground section of the western approach (in tunnel and/or cut-and-cover) at least to the western boundary of the property.

The Scheme should not proceed with the cuttings as currently proposed, even with cantilevers and an additional green bridge, as the longer tunnel options are feasible. The State Party itself has provided costings for a longer bored tunnel or a longer cut-and-cover section but contends that such solutions are not ‘available’ because the funding has not been approved or cannot be justified by the State Party’s cost-benefit methodology. By ratifying the Convention, a State Party has committed to ‘do all it can to this end [‘ensuring the identification, protection, conservation, presentation and transmission to future generations of the cultural and natural heritage referred to in Articles 1 and 2 and situated on its territory’], to the utmost of its own resources’ (Article 4, emphasis added). World Heritage status therefore requires that the best available option be pursued, not the one that would be best within budgetary constraints. In view of the significant adverse impact on an inscribed World Heritage property, the State Party should not proceed with a project if the revisions required to meet World Heritage Convention obligations cannot be financed at a given time.

In its current form, including the modifications proposed in January 2024, the Scheme, if built, would result in ascertained danger to the OUV of the property, within the meaning of Paragraph 179(a) of the Operational Guidelines, in terms of the permanent irreversible loss of attributes underlying the property’s OUV, the loss of integrity of the overall integrated prehistoric landscape, and the negative impact on ritual associations within the landscape. The potential for these impacts to occur as a result of the Scheme now approved means that, in accordance with Paragraph 179(b) of the Operational Guidelines, the property is faced with threats which could have deleterious effects on its inherent characteristics, in particular through the threatening effects of the project (criterion b.iii).

In its approved form, the A303 Improvement Scheme constitutes a potential threat which, if implemented, would have ascertained negative impacts on the attributes, authenticity and integrity of the property, thereby adversely impacting its OUV in accordance with Paragraph 179 of the Operational Guidelines. It is therefore recommended that the property be inscribed on the List of World Heritage in Danger. It is further recommended that the State Party be invited to engage further with the World Heritage Centre and Advisory Bodies with a view to preparing a Desired state of conservation for removal of the property from the List of World Heritage in Danger (DSOCR) and a related set of corrective measures, which must include either discontinuation of the Scheme, or the modification of the Scheme in accordance with the recommendations of the 2022 Advisory mission and World Heritage Committee decisions.