UNESCO REPORT WARNS GOVERNMENT HERITAGE POLICY POSES RISKS FOR STONEHENGE TUNNEL PROJECT

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The media messaging from the National Trust, Historic England and English Heritage has been to welcome the UNESCO/ICOMOS report into the proposed Stonehenge Tunnel.

However, underneath the broadly positive reception given to an opportunity to finally treat the Stonehenge World Heritage Site with the care it merits, by burying the intrusive A303 in a tunnel, the report contains a number of substantial criticisms of Government heritage policy under David Cameron and also some significant warnings about the capacity and future prospects of Historic England and the English Heritage Trust, which the bodies involved are asked to take on board as the project moves forward, writes Andy Brockman

 

 

The chief executives of English Heritage, Historic England and the National Trust have been quick to respond positively to the publication of UNESCO’s report assessing the development, execution and impact of the proposed tunnel on the A303 which is designed to bypass Stonehenge.    Helen Ghosh, director general of the National Trust, stated that the report, which the UN cultural body undertook jointly with the International Council On Monuments and Sites [ICOMOS], “recognises the unmissable opportunity” to remove “the blight of the existing A303” through the excavation of a tunnel.  Meanwhile Duncan Wilson, chief executive of the Government’s statutory adviser for heritage, Historic England, welcomed the report, but cautioned “sensitive design” of the new road elements would be essential.  Finally, Kate Mavor, chief executive of the charitable English Heritage Trust, which took over the national property portfolio of historic sites including Stonehenge when Historic England was created last year, added: “Provided that it is designed and built in the right way, a tunnel would reunite the wider landscape around the ancient stones, helping people to better understand and enjoy them.”  English Heritage is the chief beneficiary of those visits as it runs the new £27 million Stonehenge visitor center.  However, dig a little deeper into the content of the report and UNESCO’s team of experts make some sharp criticisms of the current state of developer led archaeology and heritage management in England, as well as flagging up a series of warnings over the future capacity of the English Heritage Trust and Historic England to deliver and sustain the controversial Stonehenge Project to an appropriate standard of International best practice.  In perhaps the most devastating paragraph in the entire report the authors summarise the current state of expectation and morale among the professional archaeologist it consulted as follows;

“The professional community seems to be in a guarded ‘wait and see’ mode, both because of past experiences and trends towards a downgrading of financial and decision-making capacities in heritage management, and because the idea that ‘nobody really knows’ seems to prevail, and that decisions taken at high level are not fully thought-through or considered in terms of guidance and long-term responsibility.

In other words far from being a clean bill of health for the project, let alone an endorsement of current plans, the report is actually both a sometimes highly critical assessment of the capability of the key national stakeholders to deliver a Stonehenge project to an appropriate standard in the long term and a closely delineated and argued road map, laid out for the National Trust, Historic England, English Heritage and above all the Government to follow.  A road map which carries the clear underlying message that if they depart from the approved route for the A303 project they will see UNESCO’s flashing blue lights in the rear view mirror as they are pulled over and asked to explain why?

…the most severe criticisms and concerns contained within the report lead directly back to the British Government and its perceived attitude to heritage

The report states from the outset that it is merely an interim response, primarily to the issues raised by the proposal to build a tunnel of at least 2.9 kilometers on the A303, which is designed to bypass Stonehenge.  It also makes clear that, because the issues of construction are fairly clear cut and routine for the construction industry, the primary focus of the expert team was on issues of governance, monitoring and the creation of operational systems capable of delivering a sustainable solution for the World Heritage Site [WHS] to meet current international standards for best practice.  It is here that the report will make less than welcome reading  for the senior management of English Heritage, the National Trust and Historic England, not to mention ministers and civil servants in Whitehall at the Department for Culture Media and Sport, the Department for Transport, and at the Treasury.  This is because the most severe criticisms and concerns contained within the report lead directly back to the British Government and its perceived attitude to heritage.  In particular, what the authors of the report see as a splintering of responsibility for heritage protection, coupled with a downgrading of capability resulting from falls in funding support given to key regulators and curators, and the pressure on those regulators and curators to deliver “operational efficiencies” [cuts] and, in the case of the new English Heritage Trust, financial returns capable of funding its entire operation by 2021.

At a design level, there has been detailed criticism of options which included intrusive features such as tunnel portals within the WHS, by archaeological experts and groups such as the Stonehenge Alliance.  This has resulted in a campaign to force the Government to adopt a so called “Long Tunnel” solution, minimising activity within the boundaries of the existing World Heritage Site, albeit at greater cost.  Here the report is particular critical of the proposed placing of the tunnel’s eastern portal with the WHS.  Indeed, the authors express some bafflement at the suggested location writing;

“It is not clear why the option of placing the eastern portal…further to the east of the King Barrow ridges…has so far not been considered (or is not being considered, except in the case of 4.5 km tunnel). Is it because of the costs incurred by lengthening the tunnel by approximately 250 metres? Because placing the tunnel entrance there will mean decommissioning a stretch of the A303 that is already dual carriageway? Or is it, beyond economic or logistical considerations, because some known heritage features (which ones?) might be situated on some other planned eastern portal and could be impacted, or cannot be mitigated?”

The suggestion that the existing  proposals might be driven by costs as much as by the needs to protect the integrity of the World Heritage Site, is picked up elsewhere in the report.

In another comment with potentially far reaching implications the report observes;

“It is urgent to assess cultural values, landscape values and viewpoints within a greater scale well beyond the current boundaries of the WH property and its buffer zone. It is crucial to encompass wider archaeological links in the landscape and to define archaeological and landscape sensitive zones.”

This issue of the sensitivity of archaeological landscapes, and the recognition that observing current and often arbitrary, boundaries, real and legal, can lead to archaeologically relevant features being sidelined in decision making, is precisely what is currently causing a major controversy at Old Oswestry Hill Fort where Historic England has declined to oppose the inclusion of an area adjacent to the nationally important hill fort in Shropshire Council’s development plan.  The campaigners at Old Oswestry, and elsewhere, are very likely to observe that what is recognised as best practice at Stonehenge would be equally best practice anywhere else in the country, to the extent that such wide view decision making should become the norm.

Meanwhile, away from the precise issues of  where to place the tunnel within the Stonehenge landscape and turning to operational matters, the report authors recommend that Highways England develop and adopt a project specific process route map which takes account of all the ramifications, local , national and international of a major roads project within a World Heritage Site, rather than employ its generic development process.

Highways England are also told to research and adopt international best practice for design and materials rather than use those they would routinely adopt.

In short the report endorses an approach which recognises that the integrity of the Stonehenge landscape as a World Heritage Site and asserts the quality of the project, should override all other considerations.

This conclusion leads directly to the most significant and far reaching recommendations in the report.  Those related to the management and funding of the project.

The most fundamental issue is funding the currently estimated £1.2 billion cost of the project

The most fundamental issue facing the A303 Stonehenge Tunnel is funding the currently estimated £1.2 billion cost of the project and here the report is unequivocal.  There must be no avoiding the fact that the established principle in UK legislation is that the polluter, in this case the Government through Highways England,  pays the environmental cost of any development.   That means no archaeology related to the development should be funded by Historic England or the English Heritage Trust, the National Trust, the National Lottery, or even donations from new age millionaires who want to do well by the Druids.  The entire project has to be fully funded by the developer, ultimately the Chancellor sitting in No 11 Downing Street.  Given the Government has already tried to spin the project as an investment in heritage, heritage bodies will be watchful for any attempt by the Government to pass on some of the costs to other bodies.  Indeed, it might be considered that certain danger signs have already been picked up by the report authors.

In considering the issue of who runs the archaeology of the Stonehenge Tunnel project on a day to day basis, the report makes a point of stating that the current view of the National Trust and Historic England, largest landowner and the regulator for the WHS, that  they expect to be “involved in the appointment” of the lead heritage consultants for the project, as stated, by Phil MacMahon of Historic England in a document dated October 2015,  is not nearly strong enough with the two organisations apparently subordinating themselves to Highways England.  The UNESCO report has an answer for this stating;

“Notwithstanding the prevailing practices in developer-funded archaeology in England, the wholehearted and decisive involvement of HE/National Trust in these matters should be a sine qua non condition, including the ability to formulate requirements, veto proposals, orient others etc., in order to ensure that the heritage and archaeology dimensions of the project are clearly and consistently identified and managed for the benefit of the OUV [Outstanding Universal Value] of the World Heritage site in particular, and of heritage and archaeology in general, and not solely in view of the interests of the developer, funder or operator of the construction project.”

This is to avoid;

“… a situation where heritage decisions are taken (or appear to be taken) with commercial or operational considerations foremost in mind.”

Critics of developer funded archaeology will be quick to note that this recommendation is a direct response to a longstanding criticism of developer funded system as it operates currently in the UK under the National Planning Policy Framework [NPPF], and previously under PPG16.  Namely that it gives far too much power to developers who can appoint consultants who are tasked to argue down the archaeological commitments and costs, which their employers project will incur.

It will be interesting to say the least, to see if Historic England and the Government accept this recommendation as many independent archaeologists and heritage lobby groups will hope earnestly that they will.

“…it is recommended to explore what implications there might be to a possible insolvency of English Heritage Trust”

The report is also sceptical of the ability of the new English Heritage Trust to maintain its level of financial commitment to the project, warning that the Government’s insistence that the Trust is financially independent by 2021 could lead to financial pressures and that;

” Such pressure may result in lowering expenditure, such as specialized or expert personnel, maintenance, standards of archaeological curation, etc.”

Of perhaps even greater concern to the Treasury and the Department for Culture, Media and Sport, the report states openly what many archaeologists discuss in private, the potential of the new English Heritage trust to miss its financial targets, and perhaps, in extremis, to fail completely.

The report states;

“…it is recommended to already enshrine now certain principles of access and public service in the Stonehenge management plan 3 or documents by English Heritage Trust. In addition, it is recommended to explore what implications there might be to a possible insolvency of English Heritage Trust by 2021 – whether bailout mechanisms might exist, or whether properties might have to be rented out or even sold to other bodies, such as local authorities, and indeed whether such a fate might possibly apply to Stonehenge itself.”

All this goes to the concept at the heart of the report driving all the recommendations.  That is that the Stonehenge landscape is of such “Outstanding Universal Value” [OUV] that the planning process must establish quality locks which fix the ability to deliver best practice, to look beyond routine processes and even to adopt a longer timescale than twenty five years, in modelling impacts and outcomes for the project.

 

Government and its agencies losing ability to “formulate and enforce statuary measures of heritage protection”

However, perhaps the most trenchant criticism in the report lies in the response to the Government’s changes to planning rules and the perceived fragmentation of decision making on planning issues.

The liberalisation of planning has been a cornerstone of Chancellor George Osborne’s reign at the Treasury, with large infrastructure projects such as the upgrading of the A303 to the West Country,  seen as crucial to the Chancellor’s vision of getting Britain working.  However, the UNESCO/ICAMOS team warn that the Government should ensure that the management of the project is capable of addressing, what the report calls;

“…divergences or lack of common purpose between the State Party national bodies and local authorities with planning-process control, or indeed the diminishing possibilities (in terms of professional capacities, funding or legislation, such as NPPF) of the central government and its agencies (Historic England) to formulate and enforce statuary measures of heritage protection.” 

To illustrate the point the report notes the controversial treatment of two other UNESCO World Heritage Sites, the Liverpool waterfront and the Edinburgh historic centre which the authors argue were brought about by the devolution of powers under the Localism Act 2011 and other legislation which, the report team suggests, has diluted the ability of regulators to intervene in planning issues and ensure that national and international implications of planning proposals are discussed and acted upon by local planning authorities.

Pointedly this section of the report concludes with the comment that the UK Government should remember that 2016 is the 30th anniversary of Stonehenge becoming a World Heritage property and that it should take the opportunity to celebrate this and also to demonstrate its “obligations and commitment” to the World Heritage Convention.

This placing of conservation and not “sustainable” growth at the heart of the planning process for the project is unlikely to be welcome at No 11 Downing Street.

For this reason the Government might find it difficult to swallow one of the most far reaching recommendations of the report.  That the Government put in place a system of expert oversight of the project, to be provided through UNESCO, which would; “…provide DCMS and the project with expert international advice to report on compliance with obligations under the UNESCO World Heritage Convention on quality control, and provide guidance and international perspective..”

In the current climate of Euroscepticism, even though UNESCO is a UN body and nothing to do with the EU, the idea of being seen to cede that kind of control to an extra-governmental, international body might well be too much for ministers to stomach.  Particularly as it carries the implied suggestion that, left to its own devices, the Government might not understand, or be compliant with, its international obligations under the World Heritage Convention.  The Treasury and other Government departments involved in development such as the Department for Transport, will also be loath to set the precedent that heritage/environmental considerations and mitigation, should drive the framing of development relating to listed heritage and be subjected to external checks and balances.   Even when that heritage is of outstanding value and international importance.

 

 

 

…the Stonehenge tunnel is not an investment in heritage.  It is a road development

 

The UNESCO/ICOMOS report rightly concludes that;

“The A303 road improvement project has the potential to become a best practice case regarding the governance of the project, the design, implementation and management of heavy infrastructure within a World Heritage property.”

However, there are notable caveats and criticisms of significant aspects of current Government heritage policy and practice.  Notably relating to funding and the devolution of decision making.

This means that, while the report has been welcomed to a greater or lesser extent by all three principal stakeholders, as well as the sceptical Stonehenge Alliance, albeit for different reasons and from different perspectives, the Government must be concerned at the detailed comments and critiques contained within the text.

Perhaps one of the most powerful of these comments lies in the warning to the Government and stakeholders not to talk about the projected £1.2 bn cost of the Stonehenge Tunnel as an “investment in heritage.”  The term used, perhaps somewhat ill advisedly, by the former Chief Executive of English Heritage Dr Simon Thurley in 2014.

Not only is the statement, in the words of the report authors, “objectively questionable”, it begs difficult questions from critics on both sides of the debate on heritage spending; “why that level of investment in heritage?” and “why not invest that level of support in other heritage sites?”

More fundamentally, it is also spin.

But then so too was the welcoming of the report by the National Trust, Historic England and English Heritage.

As the report makes clear, the Stonehenge tunnel is not an investment in heritage.  It is a road development, and Highways England, the Government’s front organisation developing the project, is the polluter which must pay the full and appropriate price of that development, even if the ultimate effect of the tunnel is to mitigate finally a longstanding heritage embarrassment to the UK.

With that marker now clearly placed, the archaeological world, and not least UNESCO, is watching to see if the Cameron Government will accept the recommendations of the report and undertake to deliver a bespoke,  state of the art project for the World in a uniquely important pre-historic landscape.  However, it emerged in the last few days that the Government’s senior civil servant, Cabinet Secretary Sir Jeremy Heyward, was reviewing another major infrastructure project, HS2, with a view to reducing costs and the fear must be that the the project parameters at Stonehenge will be set by the Treasury and not UNESCO.  If that is the case the Government is likely to have a significant fight on its hands and Historic England, the English Heritage Trust and the National Trust will need to be extremely careful not to get caught on the wrong side of the lines.