Parish Council Response to the A303 Stonehenge Scheme Public Consultation

The Parish Council has today uploaded its response to the A303 Stonehenge Scheme Public Consultation to the Documents section of this website.  This has had to be split into two parts because of size limitations.  The quick link to Part 1 is here and the link to Part 2 is here.

From the outset, it is important to note that this is not the response the Parish Council would have wished to have made.  We have said from the outset, back in mid-January, that we were not going to indicate a preference for one route proposal or another, as we had quickly learned the feelings of the village were divided in a non-binary way and the majority of those to whom we spoke, or who had contacted us, wanted more information on which to base an informed decision. So whilst we were not going to presume to tell you what the best solution for you, your families or the village was going to be, we did want to provide you with as much factual information as we could to help you come to that decision.

Lobbyists for both route options have, quite understandably, been active in the village; we wouldn’t expect any less; it’s an important issue that will impact on lives irrevocably and for some the consequences could be disastrous.   It’s possible, even likely, that the lobbyists have won folks over to their respective causes – we wouldn’t presume to say how they’ve done this  – but this is not an election, it’s not a simple numbers game.  Highways England insist, somewhat ironically,  that the route selection will be evidence based and that your reasoned concerns as expressed in your responses to the consultation are what really matter; in theory, one good argument from Mrs Miggins could prove to be a show stopper.    Of course, Highways England will know every respondents route preference by postcode – they don’t need the Parish Council to tell them that- and they are unlikely to be unduly influenced by seeing the same formulaic answer for the umpteenth time.  Nor would the numbers have necessarily helped the Parish Council – our role is to represent the interests of the whole community and those interests are the same, regardless of which route is ultimately chosen – ideally that the bypass should not worsen the lives of any villagers and would, hopefully,  improve the lives of all.  But to discharge that role we needed information.

We had believed, from the initial responses of Highways England, that the questions posed by the Parish Council and parishioners alike, would be answered quickly, expansively and informatively.  Instead, we have been met with delay, denial and obfuscation.  Despite a considerable amount of effort, not a single question has been answered in a way that would allow us to put more information in front of you.

Even when, through the good offices of John Glen MP, we managed to secure a meeting with Highways England for Parish representatives from Winterbourne Stoke, Shrewton and Berwick St James, we were not allowed to have copies of the view foils used by Highways England as they did not believe we, or you would be able to interpret that information “in context”.   Last week, a formal request to Highways England under the Freedom of Information Act, to ask for their predictions of noise impact for each of the routes,  was delayed .  The reason?  Well, that seems to be that they don’t think it is in the public interest to tell you!

Representatives of Highways England have said, from the outset, that they had conducted no baseline surveys for noise, pollution etc.   They have also told us, individually and collectively in meetings that no historical data was available that could have been used to check and at least partially validate their claims.  Shortly before our meeting with them on 23rd February, we were made aware of the Environmental Impact Assessment (EIA) conducted for the last bypass scheme back in 2003 which was said to contain much of this important baseline information.  This was raised specifically with Highways England who denied both having a copy, or having access to a copy.  Worrying that information gathered at huge expense to the public purse has been lost or thrown away.

Despite what we had been told, we refused to believe that such valuable material was not available from somewhere.  Help came from two unlikely directions – a member of the World Heritage Site Committee who recalled seeing a copy in the Wiltshire and Swindon History Centre in Chippenham and someone at the now defunct Salisbury District Council who had the foresight to deposit their copy in the archive.  We were able to see it for the first time only on 1st March.  It contains a wealth of material that, whichever bypass option you might favour, you need to see.   You need to see it for a whole raft of reasons, not least to show you the sort of baseline information you might have expected to see even at this stage of the project.  You would also have seen the sort of preliminary impact predictions that were available even then.   Very different to the level of information we have been offered thus far.    If you want to take a look for yourselves, go to the History Centre, get a day pass, and ask for file G29Add29 – Salisbury District Council – Stonehenge A303 Improvement Public Inquiries (sic!). The EIA comes in 9 volumes and you can get pages photocopied at 55p a page, or better, buy a photography license for £8.50 per day.

As a consequence of all of the above, the Parish Council feel that even asking for people to state a preference at this stage is inappropriate, as it cannot be done in an informed way.  Yes, as individuals we can all have a preference based on our own imperative concerns, views and opinions, but no official information has been provided to answer the most basic question of:  “How might each of the proposed routes affect me, my family and my village”. The best Highways England have to offer is from the top level of their economic model which claims that there is little to choose between the two options.   Like all models, it is a case of garbage in and garbage out!  That is why we are pressing for an extension to the consultation period to allow Highways England to collect the data we believe essential, to allow them to present it to you in a way that addresses your legitimate questions and concerns and lets you and us make an informed choice.

You have only hours left to make a response, electronically, to Highways England.  If you haven’t yet done so, please do so, asap!

 

 

A Lot of Furious Paddling

It has been almost a week since we held the Meeting for the Parish to discuss concerns about the proposed A303 bypass routes around Winterbourne Stoke. If everything seems to have gone quiet, rest assured that that is simply an illusion – like the old saw that describes a swan gliding silently along the river, whilst underwater its legs are paddling away furiously, we have been asking further questions and keeping the pressure on both John Glen MP and the Highways Agency. That has been a constant, daily effort.

Many questions were asked last week by villagers, some who supported one or other of the options and others who were desperate for some hard evidence to help them decide; feeling that what Highways England had offered so far was woefully insufficient. John Glen offered to seek answers to many of these questions and to ask Highways England to release some of the information that underpinned the high level assessments of each route in their Technical Appraisal Report (TAR). So far, whilst we have yet to receive an answer to any of the questions posed, or receive any further information, we know that John has been in touch with Highways England on our behalf and asked them for it. Furthermore, he’s been told that Highways England are working on responses to to both our questions and those asked by other interested parties.

Last Saturday at the Manor Barn, and contrary to things that had been said to villagers and Parish Councillors at previous meetings, Highways England finally admitted that they hold information on the predicted noise levels for each property within the 1.2 Km corridor (i.e. 600 metre either side of the centre line) for each of the alternative route Options 1N and 1S. This has been asked for informally through the consultation process and also formally as a Freedom of Information Act request. This is the critical bit of assessment that will give some idea of likely unmitigated sound levels at the properties close to each route and can be used to give at least a little idea of likely sound levels in Winterbourne Stoke in the case of the northern route and both Winterbourne Stoke and Berwick St James in the case of the southern route. It will be interesting to see when and if this information will be provided, either to John Glen or individuals.

One of the other key questions we asked of John was in relation to the relative weights Highways England would put on consultation responses from, say, the occupant of Rivendell, Winterbourne Stoke compared to the occupant of Rivendell in the Upper Hutt Valley in New Zealand. Both are at liberty to respond to the consultation exercise and both can express a preference as to the route. We would like to think that the views of those living locally would count for more than those living further away for instance. In a private response, which we hope John is happy to have repeated here, he said: “It is clear that there will be a very strong emphasis on qualitative responses – not a tally of votes for either option”.

We tackled Andrew Alcorn, Highways England’s Project manager for the scheme on the same issue last Saturday. He also gave reassurance that the route wouldn’t be decided on the basis of a simple vote count, but didn’t give much away when it came to the relative weights of locals (despite their being a box for a postcode on every hardcopy and softcopy response), versus antipodeans and everyone else with a view between here and there, versus pressure groups of every conceivable flavour. We had assumed that, having done this sort of thing in the past, Highways England would have a process in place to handle the qualitative (and sometimes quantitative) feedback it was receiving in a way that could weight responses in relation to the respondent and capture critical information in a logical and formal way. It’s the sort of thing we Brits do very well, we even “invented” the science of Operational Research back in WWII to deal with these sorts of issues. It’s now called Operational Analysis(OA) and has spread into every walk of life from how to arrange goods on supermarket shelves to working out the best GCSE courses to take to maximise your chances of becoming a doctor. OA is frequently used in the field of transport; it’s what the Highways Agency are doing when they model traffic flows like those shown in the displays at the Manor Barn. So Highways England should be well versed in it and there is a whole branch called “soft operational analysis” that deals with the sort of “fluffy”, qualitative information they are going to receive back from the consultation process. Consequently, we were very surprised to hear from Mr Alcorn that Highways England have no specific process in place to tackle these responses. Let’s just hope he is wrong and those charged with doing the work are familiar with the sort of methods that could, and should, be employed.

Highways England have insisted, from the outset, that there is some latitude in the proposals they have put forward. The big question of the week is just how much latitude? Why ask about this sort of thing now? Well, if the degree of latitude meant that the southern route might be sunk in an earth-walled cutting rather than stuck up on a high embankment, or the northern route could be pushed further north and with a similar profile to the route that was found acceptable back in 2005, then folks might look slightly differently about the viability of each of the two routes. The same would be true of the location and design of the interchange with the A360 – how much latitude would there be here? Can this latitude, even at this early stage, be bounded; what would be seen as reasonable and what wouldn’t. If we knew the broad limitations within which Highways England are working, we wouldn’t waste time pushing for the unachievable, how ever sensible such a form of mitigation might appear to us, and decision making would be much easier.

An Evening at St Peter’s

Thank you to the Churchwardens of St Peter’s Church for allowing the Parish Council to host a meeting for parishioners to discuss their concerns about the Highways England route proposals last night (26th January 2017) and for turning on the heating so early  – it probably saved a few parishioners from hypothermia.  Thanks to Neil MacDougall, Chairman of Berwick St James’ Parish Meeting, who came along as an observer and who resisted overwhelming temptation to join in at every turn.   Thanks also to our MP,  John Glen, who gave up his evening to attend and made many of us wonder why anyone would voluntarily choose to become a politician.

Particular thanks though, to all those who turned out on a bitterly cold evening, who sat, listened, thought, and contributed questions and ideas.   We seemed to have a fair cross-section of the village: from north to south, east to west and the middle.   It was never going to be an easy meeting to try and organise, run or even attend, as across the village opinions on route are split in a non-binary way; as our door-stepping exercise over the weekend showed.

It isn’t just a question of north or south. Some villagers must opt for one route or another because of the huge impact on their personal circumstances,  others have opted for a route on the basis of their own understanding and knowledge.  Still others have no clear preference, or want to have a preference but can’t get answers to their fairly basic questions from Highways England.  Some because they can’t get answers, would prefer to stick with the status quo and some think the whole idea of a bypass is an enormous waste of money and are happy with the A303 as it is.   We know already that of the many villagers who want to go ahead with the bypass, a proportion are torn between the two routes, with their head saying one thing and their hearts the opposite.  This spread of views appeared to come as a bit of a surprise to some last night and was why the Parish Council did not want to host a discussion of  “which route is best” as it would have been highly emotive, it would have constrained discussion and could have so easily turned to frustration and even anger.  So thank you again, to all who came, for your forbearance, politeness and good humour.  Thanks again to John Glen MP, who was put on the spot for answers, time and time again, and who must have gone away with a shopping list of questions to seek answers to as long as your arm.

It’s going to take a while for us to distil out all the detail from the many questions and comments made last night, but we will do so as soon as we can and make them available both here and on the Parish Noticeboard, or directly to all who wish to see them, before the Parish Council send them off to Highways England.  But the big issues that came out were these:

  • The majority felt that a bypass would benefit the village.
  • There was an urgent need for 3D models and ground level fly-thrus, even at this stage, to give villagers a better idea of the routes and their impacts.
  • There was near unanimity that Highways England had failed to provide sufficient information to answer the most fundamental of questions posed by parishioners:
    • Will either route improve, or at least not make any worse, those environmental factors (noise, pollution, light, etc) that affect me and the village on a daily basis?
    • Which of the two routes offers the greatest environmental benefit to me and to the village?
  • Most of those present felt it was unreasonable for Highways England to ask us to state a preference for one route or another, until these questions were answered, and that they needed answering well before 5 March 2017.
  • There was a feeling that the design of both routes was driven more by the need to get rid of spoil than by good design principles, but that better design and creative use of the spoil to provide noise mitigation could be beneficial.
  • There was a general view that heights of the viaducts was being driven by the desire to get rid of spoil and was being justified by their impact on the River Till SSI.  There was near unanimity that the SSI status should be revoked at the point of the proposed crossings to allow lower viaducts to be built.
  • There was unanimous dissatisfaction with both the route proposals in regards to their connections to the current A303 back into the village and to the A360.  Both designs were believed likely to encourage rat-running north to Shrewton and south through Berwick by traffic keen to avoid the northern part of the A360 and the Airman’s Cross roundabout.  This was felt to apply to vehicles approaching Winterbourne Stoke on both bypass routes from the north and south.
  • There was unanimous concern about the impacts the construction would have on the community and the local area.  Early reassurance about mitigation measures was needed.  Again it was felt that insufficient detail as to the likely scale of impact had been made available

If we’ve missed any issues here, be assured they were all captured last night by our scriveners and will appear in due course.

Thanks, yet again to all who participated.

The Highways England Response To Our Request For More Detailed Information

Following the A303 Consultation Meetings of 13th and 14th January, and comments received, Highways England were asked for more detail.  A lot more detail:

…when you scratched away at the surface, there was very little supporting data and no clear indication or commitment that this would be available before the closure of the consultation period on 5th March.  So, in the absence of evidence how can anyone make an informed decision as to the best route?

the response we received was fairly anodyne:

…Can I recommend that anyone who is interested in more technical more supporting information can look at the Technical Appraisal Report which is all on the consultation site and offers a lot more information for people who wish to access it. All eight volumes are listed if you scroll down the page to the Technical Appraisal Report at www.highways.gov.uk/a303stonehenge/consultation . I hope that helps.

If you have any further questions after you have had a look do get in touch on a303stonehenge@highwaysengland.co.uk…

Sadly, whichever side of the debate you might be drawn to, the Technical Appraisal Report and its many appendices contains little hard information, despite its extreme verbosity.  This morning, and following further comments that have been made by villagers, we’ve sent the following reply to Highways England:

…Thank you for your quick response and we will indeed feed further low level questions in to Highway England at a303stonehenge@highwaysengland.co.uk
…However, there is a fundamental high level issue here that underpins the credibility of the work that has been done so far on the A303 Stonehenge Scheme; specifically in relation to the Winterbourne Stoke route options, but one that possibly applies to all the other corridor schemes.  That issue comes down to availability of data.

We expected, and you seem to believe, that something called the Technical Appraisal Report might actually contain some sort of technical detail, underpinning and justifying the routes and their impact.  Nothing could be further from the truth.  The TAR and its appendices contain little or no technical detail, particularly when it comes to environmental impacts such as noise, air quality and light pollution from vehicles; no mention at all is made of the latter and only Appendix D deals with noise and air quality in a very cursory way.

Annex D contains, at best a few bald contentions, with no underpinning data, details of methodologies or references to support these contentions.  For example, para 2.2.65 of Annex D states

“A noise analysis was carried out to identify potential changes as a result of the scheme. This was compared to current census data to assess the impact on nearby vulnerable groups. At this stage, the assessment considered changes to the route location along with changes in traffic flow as a result of the scheme.”

The output of this assessment is given in para 3.7.3:

“All options within Corridor D are classed as Moderate Beneficial, as these alignments would remove through traffic from Winterbourne Stoke and noise impacts on this section of the A303. Concentrations of children who would be particularly impacted by these changes have been identified in impacted areas for all alignments”.

Para 2.2.66 of Annex D says very much the same in terms of Air Quality:

“An air quality analysis was carried out to identify potential changes as a result of the scheme. This was compared to current census data to assess the impact on vulnerable groups. At this stage, the assessment considered changes to the route location along with changes in traffic flow as a result of the scheme.”

With the assessment in para 3.7.4:

All options within Corridor D are classed as Moderate Beneficial, as these alignments would remove through traffic from Winterbourne Stoke and air quality impacts on this section of the A303. Concentrations of children who would be particularly impacted by these changes have been identified in impacted areas for all alignments.

So, all very vague and wooly with no evidence presented to show any work has actually been done – save writing the sentences above.

The level of granularity we are seeking when we ask for data, is such that we could give it to an expert in the field for an independent evaluation.  That clearly isn’t possible from the above.  As a bare minimum we wish to be made available:

1.    The methodologies used for these analyses
2.    Evidence for the verification and validation of the methodology by independent subject matter experts
3.    The underpinning assumptions used in the analyses and their derivation.
4.    All raw data sets and evidence of their date and place of origin.

This is not an unusual level of detail, it is the basic stuff of science.  It is simply that necessary to allow a third party to repeat the work and, if it has been conducted appropriately, arrive at the same answer.  We would expect to see that standard models had been used in this work, for instance, the CONCAWE model for the effects of wind propagation on sound, or particulate and vapour transport models.

We provided them with an example of the sort of information detail we were looking for.   You can find it at: http://hayesmckenzie.co.uk/uploads/McKenzie_Bullmore_-_The_effects_of_wind_speed__-_2002.pdf

We need to see data based on multiple sampling points through the village for the existing route of the A303 and the model data for the alternative routes prior to the end of the consultation period in March and in sufficient time for it to be independently validated.  If this information is not currently available, then the assertions made regarding the environmental impact of either the northern are southern routes are unfounded and indefensible.  Effectively, it would mean we are being asked to make a choice based on faith, not evidence…

In the email, we further asked John Glen MP to raise these issues with Secretary of State, Chris Grayling MP and included in our reply Cllr Fleur de Rhé-Philipe, the Wiltshire Council Cabinet Member for Economic Development, Skills, Strategic Transport and Strategic Property.   We have also engaged with Professor Phil Blythe of Newcastle University, the Department for Transport’s Chief Scientific Adviser, as he is the key departmental adviser on issues such as the integrity of science conducted in, and on behalf of, DfT.  We have asked him to comment on both the nature of the work undertaken, its validity, robustness and whether or not the contentions made in the Technical Appraisal Report are, in his opinion, sufficiently detailed to reasonably permit anyone to make an informed choice as to a preferred route.

The responses ought to be telling.  Whilst we’ve focused on just a few aspects of the TAR (noise, pollution and light), we fear the same issue may apply to just about any aspect of the routes you care to ask about.

Watch out for an important announcement of a Meeting of the Parish – we hope to be able to hold it towards the end of next week to discuss the concerns of ALL villagers with the route options being proposed and their potential impacts on the village.

Please note that comments are NOT being accepted on this post.  Villagers, who have registered with the site may comment on the Forum.

A303 Presentation – Lots of Pretty Pictures But Was There Much Substance?

UPDATED: 1600 Mon 16th January

The Parish Council got  an early sight of the Highways England A303 options for Winterbourne Stoke on Friday 13th January (Not a very auspicious date if you are a Triskaidekaphobic!) and many of you took the first opportunity to take a look at the suggested options on the first public viewing on Saturday 14th of January.  We would love to hear what you thought and the best way of letting us know is here on the Forum.

First impressions were that whichever route you might have a preference for, it was all a bit glitzy.  Lots of pretty pictures and maps designed to impress, but when you started to ask questions it all seemed to fall apart a bit.  Smoke and mirrors and little real substance it seemed.

What concerned us on Friday was the absence of any real, hard data.  What would be the impact of either route on the village beyond its physical presence and visual appearance?  What about the noise levels, vehicular pollution such as PM10 particles from diesel engines, light pollution, impact on the 200-year flooding risk, undiscovered archaeology, rational for the vertical location (embankments and cuttings) of each scheme.  The list went on and on?  The answer to most of these questions seemed to be mainly, “We don’t know yet”. Where they did claim to have such data, it wasn’t available and you have to question the wisdom of holding a consultation meeting without providing this type of data.

The big question is, when will they have collected this detailed information and when will it be made available?  Of course, we’ve asked Highways England for all the hard numbers behind their many assertions as to likely impacts, but we find it somewhat bizarre that we are being asked to make an irrevocable choice on the basis of little more than a few pretty pictures.

The level of comprehension of the local area was typified on Saturday when a member of the Highways England team was asked about the current speed limit on the A303.  “50 mph” insisted the chap to a visitor, with all the conviction of a used-car salesman!   That was perhaps the simplest example, but there was a trend in the answers received and the worst calls into question the whole basis of the consultation.  During the Saturday session, a villager asked a member of the Highways England team about whether detailed information about the impact of each route on the village would be made available before consultation closed on the 5th of March – a reasonable question one might think.  After a bit of tooth-sucking, the chap wandered off to “consult someone more senior” and never came back with the answer.  Actually, it was worse than that, the chap didn’t reappear for the 30 minutes the villager hung round waiting for them! Not very encouraging.

Few of those Highway England staff questioned seemed to have the faintest idea of how the physical location of the village, the terrain, the meteorology, the current route of the A303 and the two proposed routes would impact on a whole host of factors that villagers might have been expected to have an interest in.  Those sort of things that are going to affect on their day-to-day lives, their enjoyment of their homes, their recreation, their businesses and their health.  All this applies whichever route is ultimately chosen and it all is needed to inform a decision as to the best route, even at this stage.

UPDATE: 1600 Mon 16th January

We have seen the following comments from a villager from Berwick St James which accords with comments made above:

“…We spent about an hour with the acoustics consultant discussing the southern route but she was unable to say to what extent noise from traffic would be heard in Berwick St James.  The reason, she said, was that full studies had not been done and will not be done until a final decision on the route is made…”

This seems to be true for both routes which, as we wrote above, calls into question how we are supposed to make an objective route selection when no data is yet available.

A303 Consultation Begins

At a meeting of the Stonehenge Traffic Action Group  (STAG) this evening (5th Jan),  Ian West advised the meeting that he had been told earlier in the day by John Glen MP that the Highways England A303 improvement consultation exercise was imminent.   We are led to understand that “events” will be held at the Manor Barn, Winterbourne Stoke on the 13th and 14th January and at Shrewton Rec the following week.  There is little detail at present, but Highways England advised the Parish Council that this will follow imminently and the first public indications are likely to found at:

https://highwaysengland.citizenspace.com/cip/a303-stonehenge/

or:

http://www.highways.gov.uk/a303stonehenge/consultation

We will provide updates here, as and when they are available.  However, as of 07:15am on Friday 6th January, neither of these landing pages is yet active.  This may suggest the formal starting gun has not yet been fired.

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