Avebury WHS Management Plan (revised, 2005)
A note to clarify the concerns raised by the Avebury Society with UNESCO’s World Heritage Committee
The Avebury Society warmly welcomes the revised Management Plan and is pleased that many of the objectives of the earlier Plan have been achieved. We hope that co-ordinated efforts continue to be effective over the coming years in realising the objectives of the new Plan.
There is one part of the revised Plan, however, that is of great concern to us: the definition of what is to be considered to be of Outstanding Universal Value in the World Heritage Site together with the removal from the Plan of recognition of Avebury as a cultural landscape. Although this may appear to be a side issue, we think that it is fundamental to what the Plan is about and what it is that we should be aiming to manage and conserve.
Section 3.2 of the revised Plan sets out what is considered to be of ‘World Heritage Outstanding Universal Value’ at Avebury: i.e. what it is about Avebury that warrants designation as a World Heritage Site.
It appears from para.3.2.10 in the Plan that, in defining what is of OUV at Avebury, the emphasis is on ‘six key Neolithic monuments specifically mentioned in nomination documents’. Para. 3.2.15 of the Plan indicates that these are the six key monuments in guardianship (Scheduled monuments managed by EH and the NT). These guardianship monuments are: Avebury Henge (and Stone Circles), Silbury Hill, West Kennet Avenue, The Sanctuary, West Kennet Long Barrow and Windmill Hill.
Beckhampton Avenue, although mentioned by name in the World Heritage Site nomination documents, is neither Scheduled nor in guardianship. It is not counted in the new Plan as one of the ‘six key Neolithic monuments’ that are of OUV at Avebury. We think that this does not make sense and that specific mention of this monument in the nomination documents suggests that it ought to be counted alongside the other ‘key Neolithic monuments’ at Avebury. We also think that the Beckhampton Avenue should have been Scheduled long ago, giving it additional legal protection against unsuitable development, in line with its recognised status.
Section 3.3 of the revised Plan considers ‘Cultural Heritage Values’ as distinct from ‘World Heritage Outstanding Universal Values’. At the head of these is the ‘rich archaeological landscape spanning 10,000 years’ within which the ‘six key guardianship monuments’ lie.
In our view, it is illogical to separate the monuments from the landscape. We think that the monuments and the landscape, i.e. the whole World Heritage Site, should be considered to be of Outstanding Universal Value. Our reasons for this are as follows.
The Convention indicates that designated WHSites are in themselves of OUV. In accordance with the Convention, boundary lines have been drawn around both parts of the Stonehenge and Avebury WHS to delineate the areas that are of OUV.
2. The Nomination Document for Stonehenge and Avebury mentions the monuments and the landscape
The Nomination Document for the inclusion of Stonehenge and Avebury and Associated Sites on the World Heritage List was drawn up in 1986. Justification for inclusion of Stonehenge and Avebury on the WHList, as a cultural property, includes the statement that these two monuments, ‘Together with the associated sites and monuments . . . provide a landscape without parallel in Britain or elsewhere and provide an unrivalled demonstration of human achievement in prehistoric times.’
In our view, mention of the unique and unparalleled landscape alongside Stonehenge and Avebury and their associated sites and monuments underlines that the whole archaeological landscape of the WHS must be considered to be of World Heritage Outstanding Universal Value – not just the key monuments. This view was endorsed by ICOMOS-UK, UNESCO’s watchdog on UK World Heritage Sites, at the A303 Stonehenge Inquiry last year.
3. Planning guidance and policy aims to protect the whole WHS and its setting
Government Guidance in Planning Policy Guidance Note 15 (PPG 15: Planning and the Historic Environment; published 1994), clearly demonstrates that the WHS itself is considered to be of OUV and that the whole site and its setting must be protected against damaging development. The Wiltshire Structure Plan and Kennet Local Plan both recognise the WHS as an archaeological and historic landscape and, following advice in PPG 15, contain policies designed to protect the whole site from damaging development.
4. Agreed Management Plans for the WHS describe the WHS as a cultural landscape
The current (2000) Stonehenge WHS Management Plan (para. 2.2.3) and the old (1998) Avebury WHS Mangement Plan (para 3.2.2.), both consider the WHS as ‘not so much a site as a cultural landscape’. Both of these Plans point out that, at the time of nomination of the WHS, the sub-category of ‘cultural landscape’ did not exist; but if the site were to be seeking inscription today, it might well be classed as ‘an outstanding example of a cultural landscape’.
We think that these statements should appear again in the Revised Avebury WHS Management Plan but they have been removed.
Together with the AONB and other designations that bring additional protection for the Avebury landscape, the Avebury WHS should be well protected.
However, we believe that it does matter that our revised Plan considers only the key (or Scheduled) monuments to be of OUV at Avebury and that recognition of Avebury as a cultural landscape has been removed from the Plan. It changes the emphasis of the overriding importance of the site from that of a cultural landscape to that of a group of individual monuments that must be protected for future generations. It introduces a hierarchy of importance that does not exist in planning policy, apparently making certain parts of the WHS more worthy of protection than the rest. This change is now in the new Management Plan, even though it runs contrary to agreed Local and Structure Plan policy for the WHS; it might also be accepted by UNESCO’s World Heritage Committee unless Avebury stakeholders say that they do not agree with it.
If these new concepts about the landscape and OUV remain in the Revised Management Plan, it is likely that the Revised Stonehenge Plan (2006) will be altered too and a new ‘Statement of Significance’ for both parts of the WHS will be drawn up next year to reflect the new understanding. Ultimately, this could lead to a change in Government advice on World Heritage Sites, perhaps proposing that some parts of WHSites like Stonehenge and Avebury are more important than others and need to be better protected, while others could undergo damaging development, such as new road schemes. This would not only make the Avebury WHS more difficult to protect in planning policy terms but also more difficult to care for in management terms.
Why have these changes been made in the revised Avebury Management Plan?
We believe these changes came about as a direct result of the Government’s need to justify its A303 Improvement scheme at Stonehenge. The Government admits that it would be too expensive to protect the Stonehenge WHS by burying the A303 in a long bored tunnel. Their ‘affordable’ scheme, considered at Public Inquiry last year, involved the construction of a 2.1km bored tunnel that would leave long tunnel cuttings and dual carriageways across about two thirds of the WHS, whilst a major interchange at the western edge of the WHS would severely compromise the setting of a magnificent barrow group. At the A303 Inquiry it was argued by English Heritage that only the Scheduled monuments were of Outstanding Universal Value and that Stonehenge could not be considered to be a ‘cultural landscape’: thus, so long as the monuments were not physically damaged, the road scheme would be acceptable. ICOMOS-UK as well as numerous archaeological and environmental groups argued otherwise but, unfortunately, the Inquiry Inspector agreed with English Heritage, in spite of protection afforded to the WHS landscape by Structure and Local Plan policies. The A303 Inquiry Inspector’s recommendation is no more than that. It has no status in law and could be challenged on legal and planning grounds – but only if the Government decided to proceed with a damaging road scheme at Stonehenge. The future of the A303 at Stonehenge is now under review but the threat to the WHS remains until the A303 scheme is abandoned or modified to respect the WHS boundary.
We think that the arguments put forward by English Heritage and the DCMS at the Stonehenge Inquiry were not consistent with the demands of the World Heritage Convention, under which the UK Government is pledged to recognize its ‘duty of ensuring the identification, protection, conservation, presentation and transmission to future generations’ of the WHS. The arguments put forward by the promoters and developers of the road scheme at the Stonehenge Inquiry appeared to us to be weasel words that would enable the UK to back away from its international commitments by re-interpreting the Convention to suit its purse.
We now see those arguments embedded in the new Avebury Management Plan. We hope that you will consider writing to the Director of the World Heritage Centre to support us in continuing to regard the whole of the WHS as being both a cultural landscape and of Outstanding Universal Value.