WETHERSFIELD PARISH COUNCIL
REPRESENTING WETHERSFIELD, BLACKMORE END & BEAZLEY END
4 Beazley End, Braintree, Essex, CM7 5JH
Clerk@Wethersfield-pc.gov.uk – 01371 829094
FAO Neil Jones
Development Management
Causeway House
Braintree
Essex
CM7 9HB 21 December 2021
Dear Sir/Madam
Town and Country Planning Act 1990 (as amended),
Town and Country Planning (Environmental Assessment) Regulations 2017
Scoping and Screening Opinion Requests ref 21/03405/SCO and 21/02425/SCR
Land at Wethersfield Airbase, Toppesfield Road, Wethersfield, Essex
I refer to the above screening and scoping requests on behalf of the Ministry of Justice in connection with two proposed prisons on land at Wethersfield Airbase. I have been asked to submit these representations on behalf of several parish councils in this area which I hope you will find helpful in your deliberations on this matter.
I should explain that following recent consultation with local residents by the Ministry of Justice (MoJ) this Parish Council formed a Wethersfield Airbase Scrutiny Committee (WASC) to focus on responses to proposals which come forward involving the base. This committee is formed upon the statute of the Local Government Act 1972 Section 102 and has been delegated powers by Wethersfield Parish Council to respond on their behalf to matters relating to the airbase. At present, this Committee comprises representatives of ten Parish Councils in this area.
The detailed screening and scoping requests appear to have been prepared before the expiry of the consultation period set by the MoJ and therefore could not have taken into account the very strong feelings of parishioners across several parishes. This is contrary to national guidance for developers to work closely with local communities before submitting proposals. Surprisingly, the Parish Councils in this area were not consulted by the MoJ on their consultation exercise and the WASC was disappointed to find at their meeting last week that your Council has not consulted any of the Parish Councils other than Finchingfield in connection with the screening and scoping requests.
Nevertheless, the Committee resolved at its last meeting to submit representations and to seek Counsel’s advice on the proposals generally. We have become aware of the time constraints to your response to requests under EIA regulations and also that under section 15 you are able to seek an extension of time beyond 35 days but where you fail to give an opinion the applicant may refer the matter to the Secretary of State for a direction should they so wish. However, this matter is still pending and I am obliged to you in agreeing to allow sufficient time for WASC to submit representations. On that basis WASC wishes to make the following initial comments: –
Need for a holistic assessment
The screening letter states that ‘The proposed prison site is in the northwest corner of the airfield and would ensure that the remaining land could come forward for development at a later date’’. Moreover, page 2 of the scoping request explains that the MoJ site comprises the extent of the proposed development and ‘’additional land that will form part of the MoJ’s ownership.’’ The EIA should disclose and take into account the anticipated use of this additional area and assess the cumulative environmental effects. Should, for example, there be a potential relocation of the remand prison from Chelmsford, it is important that such possibilities be discounted or scoped into the EIA. Furthermore, the MoJ assert that it has no interest in the remaining Ministry of Defence land. However, this amounts to around three quarters of the total area of the base including the built up area which no doubt will come forward for yet further development proposals in due course. Those intentions too, even if not finalised, should be disclosed and taken into account as part of the EIA.
Policy considerations
Given that under planning legislation applications should be determined in accordance with the Development Plan unless other material considerations indicate otherwise, it is surprising that this site should have come forward at all for these proposals. This is particularly so when the applicant and landowner are both government departments, thus challenging the integrity of the planning system.
The scoping request letter accepts that the proposals breach Local Plan policy. Several policies are listed but relevant existing and emerging policies are omitted- for example CS5, SP1, SP3, SP4, SP7, LLP1, LLP50, LLP71. It is acknowledged that the proposals would be contrary to Local Plan policies including those relating to ‘Countryside’, design, landscape and the fact that the site is not an allocated development site. Any planning application submitted on the site which is not for a ‘countryside use’ would be considered as in conflict with the adopted and emerging Local Plan and assessed in that context. The proposals could not be seen as appropriate countryside uses.
Moreover, the proposals are in strong conflict with policies in the National Planning Policy Framework including those relating to the need to site development in locations which avoid the need to travel and promote design which should have regard to context and surroundings of a proposed development. The EIA should evaluate how the proposals fare against environmental policies at all levels and attempt to explain how the proposals can be justified to override policy conflicts.
Lighting
The Scoping letter states on page 10 that a lighting design strategy will form part of the outline application for the site and as such lighting is scoped out of the EIA process. It is self-evident that lighting of these two prisons of such a vast scale on an open site around one mile in length and 2-3 miles in perimeter in a sensitive landscape setting on a plateau above surrounding countryside and with obvious security issues will be likely to have a major impact over a very wide area and have likely serious adverse effects on the rich wildlife around the site. The WASC consider that lighting be scoped in.
Ecology
The site as a whole should be considered as one of national significance, due the number of species recorded (and logged with Braintree District Council). These include 74 species of bird (several red list); 271 species of plant (several rare and unusual) and 401 species of invertebrates (including 4 UKBAP, 3 RDB, 4 Notable/NA, 11 Notable/NB, 7 Notable/N). The runways themselves are the habitat for unusual grasses, and the meadowlands around the runways contain orchids are home to many species of birds requiring open grassland – which cannot be mitigated for. It is imperative that a precautionary principle is applied and we believe that the Avoid action is the only outcome suitable in this unique situation.
Architectural design
There is little mention of architectural design and this should be scoped in and should certainly not be left as a detailed matter to be considered pursuant to an outline permission. The proposals are based on a template of a prison design originating in the US, and now being applied across the country. There is little indication that the design of the scheme is either of exceptional design or pays any regard at all to the wider rural vernacular character of this tranquil part of northwest Essex and South Suffolk which comprises beautiful open countryside of historic villages, scattered farmsteads, quiet lanes, distinctive landscape. The EIA should set out the environmental effects on the area arising from the scale, massing, local context, intensification of use and contemporary templated design of the proposed prisons.
Landscape Character
A landscape character assessment should take into account a much wider area than the area immediately surrounding the site and extend beyond analysis of the numerous seriously affected viewpoints at close and long range. It should look at character areas in a wide area around the site taking in the Pant Valley and the countryside areas to Saffron Walden, Castle Hedingham, Braintree and Haverhill. This should be a strategic character assessment of this area of northwest Essex into South Suffolk if there is to be a true understanding of the relationship between the proposals and the wider contextual environment touched on above.
Previous work carried out for mid Essex authorities in 2006 should be examined where it was concluded that only limited development could be permissible in the Stambourne Farmland Plateau and Pant River valley. The scoping letter appears to limit its focus to the immediate surroundings though even then omits the immediate impact on settlements such as Gainsford End. This limitation is at odds with basic principles of environmental geography and climate science that highlight the need to recognise the wider environment, as a complex integrated ecological system. Damage to one element has a fundamental effect on the wider landscape. Greenhouse gases do not simply stop at the edge of the runway.
For obvious reasons, any assessment should be based on landscape impact during all seasons of the year.
Alternative Options
The scoping request states that “Chapter 3 will briefly consider the need for the proposed development ‘ and a description of alternative options considered. This should describe how each option relates to the MoJ’s own policies and research on prison location and take cognizance of the recent White Paper ‘Prison Strategy’ dated December 2021. It is clear that the current proposals are contrary to MoJ policies for locating prisons close to families, health services and employment where the key indicators of ‘ensuring success is measured against our priorities: security and stability; substance misuse and mental health; and resettlement and family ties.’ It is difficult to see how this inaccessible location can be compatible with these goals. Moreover, providing prisoner release on license with local employers is unlikely to be successful in this area where employment levels are low and there are no significant employers nearby that could participate in such a program, so prisoners would need to be transported considerable distances to reach suitable areas.
The alternatives should examine not simply other sites for a prison based on acknowledged objectives but also alternative uses for the site which are compatible with local and national planning policy. That includes uses compatible with its status as ‘Countryside’ in the Local Plan and ‘green field’ character-these might include for example agriculture, rewilding, nature reserves, recreation, solar energy, reopening public access all of which should be explored in collaboration with the local community. Any significant new building should be contained within the existing built up area of the base and not extend into the open airfield, including the prisons site, which lies beyond the curtilage of existing structures and their associated surface infrastructure.
Traffic impact
Traffic impacts should include an analysis of how increased traffic will impact upon the character of surrounding villages and countryside, as well as carbon emissions. The WASC feels that it is often not appreciated how remote this area is from the national road network. If one takes the area prescribed by the nearest major road in each direction from Wethersfield, it is hard to find comparable inland areas elsewhere in the country that are as poorly served. The local road network was built up from routes connecting numerous small villages around a network of arable fields, which is why the all the roads pass through the centres of tightly knit communities, are contorted and narrow and often reduce to a single lane. The degree of accessibility should be a central criterion in selecting suitable sites for prisons of this scale. Constructing a spur to connect with a major road from the site would be several miles long and even more destructive to highly valued and attractive countryside. If the intention is to consider mitigation works to the existing road network full account should be taken of both capacity as well as the impact on the rural character of the affected routes.
There is no systematic evidence that prisons benefit isolated rural areas and thus reliance on minimising the need to travel by relying on local staff is misguided. Key Performance Indicators from Glen Parva suggested a journey distance for employees would include a radius of 25-40 miles, which if applied to this area equates to up to 5,000 sq. miles covering Stevenage, Ipswich and North London. When employee journeys are combined the huge HGV reliant supply chain, visitors and support services, a vast quantum of movements, and unjustifiable levels of carbon emissions would result, and this impact needs to be measured, particularised and rigorously assessed.
Heritage
Heritage impact should include evaluation of structures on the airfield for protection following recent Heritage England reports ‘Nine Thousand Miles of Concrete’ (with Airfield Research Group) and ‘Military Structures-Listing Selection Guide. These reports place Wethersfield amongst the most significant military airfields in the country in terms of heritage rating and should be seriously considered for listing and conservation area status. These include the hangars, chapel, weapon storage area, mess quarters, defensive structures and other areas of the so-called technical area and sections of runway. The MoJ should take on board the comments of Place Services which has responded to this scoping request that there is the potential for designated and non designated assets to be harmed by the proposals. The setting of these assets will be an important part of their significance.
Moreover, Place Services remark that ‘if not already undertaken early- stage consultation prior to the EIA with local communities, local heritage groups, historical societies, parish councils and other stakeholders would be appropriate including Britain Conservation Trust, the Wethersfield Airfield Museum, and the Wethersfield Local History Group, along with Historic England’. The WASC urges your Council and Ministry of Justice to begin meaningful consultation with the community on this and many other matters involving the future of the base.
A further important heritage issue that should be scoped into the EIA is the effect that the proposals would have on the setting of Wethersfield Conservation Area. The proposed buildings will appear on the skyline from many viewpoints and these include across the highly attractive Pant Valley to form an unattractive backcloth on a plateau above Wethersfield Conservation Area which has its special character largely defined by its historic landscape setting
There are listed buildings not referred to in the scoping request –Toppesfield Mill and many buildings in open countryside at a considerable distance beyond the 1 km limit referred to in the scoping letter would be adversely affected in terms the impact of the proposals on setting and arising from construction and operational traffic indefinitely. Moreover, many of the listed buildings nearby such as Sculpins Farm and Boyton Hall are recorded in the Doomsday book and date back to Saxon times. Their proximity to the prisons will change forever the setting of these historic buildings. The EIA should look carefully at the history of each of these buildings rather than make generic assumptions as to their worth based on their listing grade.
Archaeology
WASC endorse comments by Place Services that archaeology should be scoped in so that proper investigation can be carried out to determine likely evidence of prehistoric to Roman period remains before proposals are submitted.
Employment
Chapter 12 should assess the employment benefits to the immediate local economy, including information on the anticipated place of residence of employees and the need for new housing in the area. Evidence gathered from prisons elsewhere indicates that very few jobs within the latest prisons are filled by people within the parish where it is located. The ongoing HMP Grendon full planning application was submitted in July 2021 for a 1,468-inmate prison following MOJ consultation in Dec 2020. There are similarities in some respects, Parish prison employees at the existing prison were given as just seven. On the other hand, this area is popular with tourists, including cyclists and walkers and these proposals will do nothing to promote the appeal that this area has in the tourist sector of the local economy.
Water Supply
The WASC are concerned that the proposals on water supply in this area which is one of the driest places in the UK and where there are difficulties with water pressure. At the same time flooding in the surrounding area is a regular challenge including recent flooding at Toppesfield Bridge (despite recent alleviation works) and at the entrance to the site. We hope the EIA will give full consideration to these matters. It should be noted that part of the proposals site is within the River Pant Water Catchment Area.
The WASC considers that this site should never have been selected as a possibility for prisons of this scale. The location has poor accessibility, will have a dramatic impact on the landscape, ecology and character of the surrounding countryside, cause untold loss of amenity caused by increased traffic over a very wide area which is characterized by country lanes, open varied countryside, historic villages, scattered farmsteads. The proposals are wholly contrary to local and national planning policy and at odds with current and emerging prisons strategy-the site should have been discounted at an earlier stage. Had this been a scheme by a housing developer it is inconceivable that this scheme would have been entertained.
The only positive reason for locating the prisons on this site seems to be the net nil cost of land to government but even this would be offset by the long term costs arising from the huge number of construction vehicles having to travel over long distances from major roads or rail, the travel distance and hazards involved for massive supply chains to sustain the number of prisoners, visitors and staff, and proximity and journey routes to and from courts, visitors, access to specialist health services etc.
Would you please take the points raised in this letter into account in your response to the MoJ and keep Parish Councils advised of progress. WASC would be very pleased to discuss these proposals with your authority and provide any information it can to assist you.
Yours faithfully,
Michelle Baker
Clerk, Wethersfield Parish Council
A plan of the immediate area is below with the proposals superimposed.
I would just like to thank everyone involved in sending this email.
The preparation, research and attention to detail is excellent.
I hope the MOJ revokes this proposal of two prisons on this site which is clearly unsuitable.