Wethersfield Parish Council Airbase Response Letter

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WETHERSFIELD PARISH COUNCIL
REPRESENTING WETHERSFIELD, BLACKMORE END & BEAZLEY END
4 Beazley End, Braintree, Essex, CM7 5JH
Clerk@Wethersfield-pc.gov.uk – 01371 829094

PO Box 347
Manchester
M21 3ES 5 November 2021

Dear Sir/Madam

Proposals for two new prisons near Wethersfield, Braintree District

I refer to the notification letter dated 27 September 2021 addressed to ‘Neighbours’ of this parish in connection with the construction of two proposed prisons at Wethersfield Airbase. Although you chose not to consult the Wethersfield Parish Council specifically, this matter has been brought to our attention by a large number of parishioners and through local media channels. Having looked at the proposals, the Parish Council wishes to submit representations and asks the Ministry of Justice to give these careful consideration before it decides whether to take these proposals forward.

The Council accepts that in a civilised society there is an urgent need for modern prison accommodation in this region of the country and whilst there is a high level of employment in the area, particularly in skilled and semi-skilled occupations, nevertheless the proposals could bring economic benefits to the local economy both during the construction phase and in the longer term. The Council has been aware of various announcements concerning closure of the airbase and suggestions made of possible future uses. Again, the Council accepts that there is a substantial quantum of existing built development at the base, mostly built during or shortly after the Second World War for security purposes and the Ministry of Defence (MOD) would have an expectation, upon permanent closure of the base, of securing a planning permission for alternative uses involving the replacement of outworn military buildings and obtaining a reasonable capital receipt.

However, notwithstanding the above, the Parish Council wishes to raise objections in the strongest possible terms to the scale and nature of these proposals which could have a devastating impact on this and nearby quiet rural areas. The consultation proposals do not appear to be underpinned by properly researched studies such as transportation and traffic, landscape, character assessments, community infrastructure, design, sustainability etc . However, the Parish Council is convinced that the proposals would leave the area with continued uncertainty surrounding the future of the base and have an exceptional, adverse impact on traffic, local amenity, landscape and rural character. These matters are explained in further detail below alongside other concerns to the Council.

Need for a holistic approach to the future of the airbase

There has been an expectation locally that upon the closure of the base reasonable proposals would come forward . In 2016, the MOD announced that Wethersfield MOD Police would be one of ten sites to be closed as apart of a programme of building more homes across the country and proceeds of sale being ploughed back into defence spending elsewhere. In 2019, MOD announced a partnership to dispose of the site for 4750 homes. In 2020 it was reported that Wethersfield MOD Police would close in 2025. Against this background you now have proposals for two prisons with accommodation for 3430 prisoners which together would constitute one of the largest prisons in Europe.

The two prisons are located in two complexes of buildings separated by about 1000 car parking spaces in one site stretching about 1.5 kilometres plus an additional 300 metres in length of existing runway approach at the western end. There appear to be no existing buildings on the site whatsoever. Consequently, the current base buildings, which are focused in an area approximately three times the built up area of Wethersfield village, would not be touched by the proposed prisons so it can simply be assumed that MOD remains intent on disposing of that area for housing. In that event, taken together the cumulative local impact would be even more overwhelming on local communities than the prisons alone. This overall impact is difficult to assess because MoJ representatives have stated that anything outside the prisons site is beyond their remit and are unable to respond to questions about the future of any other land. Furthermore, the prisons site and existing base buildings take up only about half of the whole MOD site leaving the potential for yet more development.

This creates a great deal of uncertainty to local people on the future of the base and gives a lack of context for the current prison proposals. Thus whilst the overall impact cannot be properly assessed even the prisons alone would have a devastating impact on local communities. This is discussed further below but the Parish Council believes that a holistic approach should be taken with the whole site and the prisons proposal should not be dealt with in a piecemeal manner leaving the rest of the base with an uncertain future. The base was not dealt with in the Local Plan (Part 1) which was recently the subject of examination but should nevertheless be subject of a Master Plan for the whole site ahead of any significant planning applications involving the base coming forward.

A Master Plan should be prepared as a collaborative project and set out a vision for the entire base including airfield. This would set out inter alia a balanced mix of uses over the whole area in the long term together with appropriate quantum of built development and open space . It could consider various options underpinned by a proportionate degree of analysis but including assessments of traffic impact, infrastructure and housing requirements, landscape impact, local character assessment/design code/heritage and sustainability. In this way the overall impact flowing from closure and appropriate reuse of the base can be properly understood and assessed so that a firm way forward can be established for the long term.

Transportation and traffic

The Parish Council is very surprised that MoJ should put forward the airbase site for two exceptionally large prisons as proposed. This location seems to run counter to national and local planning policies, fails to take account the remoteness of the site from national road network and public transport nodes and seems to disregard the difficulties of bringing a large volume of vehicles through several historic villages and narrow lanes with several pinch points, blindspots and hazardous bends over an extended building phase and beyond. As well as inhibiting the use of sustainable travel modes this remoteness would generate a very substantial need to travel by private vehicles . This in turn would create an unacceptable impact on the character of local villages and surrounding areas and result in an unacceptable impact on local amenity and highway users including the many cyclists and walkers who live in and visit the area.

The Parish Council is concerned that the MoJ Consultancy document demonstrated insufficient understanding of the road infrastructure in the area and cited erroneous information in this respect. It identified potential access for construction traffic vis the B1503 between Wethersfield and Finchingfield. This road designation does not exist, the road in question is the B1053. Further the document refers to access thereafter via Shaw Drive, but this road onto the base has to be accessed via Sculpins Lane, in some places a single carriageway lane.

The document also refers to access to the area via the M11 from Junction 9A. and wrongly stated to be 32 miles away This is confusing since traffic travelling from the south would on the M11 would presumably leave the M11 at Junction 8, the A120 junction towards Stansted Airport. For southbound traffic, there is no exit from Junction 9, so traffic would need to continue to Junction 8 or leave the M11 at Junction 10 (Duxford). These inaccuracies illustrate the lack of thought that has gone into this proposal.

The site is about ten miles from the national roadwork to the south (A120) and 20 miles from the motorway network to the west (junction 8 of the M11). The nearest A road is at Sible Hedingham about seven miles to the east but this is some 20 miles from Colchester, the nearest big town in that direction. Whichever route is selected, the journey to and from each of these main roads from the airbase is hazardous and of necessity traffic would have to travel through a number of historic villages, and including during the construction phase on country lanes whose road width and surfaces are unsuitable for large HGV traffic. Immediately after leaving the site, vehicles would need to travel through either of the historic villages of Finchingfield or Wethersfield which are constrained by a narrow bridge and village green respectively and narrow approach roads. From there, roads are narrow lanes with many pinch points. The attached photographs illustrate such difficulties at Finchingfield, Wethersfield, Great Bardfield and Sible Hedingham. This location contrasts with the Glen Parva and Five Wells prisons quoted in the consultation document which are considerably smaller projects and yet more closely accessible to major roads and built-up urban areas.

Without doubt, the likely volume of traffic would permanently change the rural character of the villages and countryside in this area and be a source of constant nuisance and danger in an area which has already been experiencing significantly increased movement of vehicles including heavy goods vehicles and delivery vans in the narrow streets of historic villages and surrounding lanes. These are based on a highway pattern that emerged in the centuries before the invention of the motor vehicle. Mitigation measures which would be needed to overcome these obstacles are likely to be so great in the context of this rural location that they would inevitably conflict in other ways with the countryside and village character in this beautiful part of north Essex.

The National Planning Policy Framework (NPPF) was revised just a few months ago but reiterated earlier policy that development should be located so as to promote sustainable development. Section 9 of the NPPF is titled “Promoting Sustainable Transport’ and there are several references to the need to minimise the need to travel. Para105 for example states that ‘Significant development should be focused on locations which are or could be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes.’ Para 106 states that planning policies should ‘support an appropriate mix of uses across an area, and within larger scale sites, to minimize the number and length of journeys needed for employment, shopping, leisure, education and other activities. ‘

Given the number and travel origin from a wide area of prisoners, visitors, permanent staff, support services, people involved in the supply chain, tradespeople, it is hard to see how placing these prisons in this relatively remote location with an absence of appropriate infrastructure could comply with national and local policies to minimise the need to travel. It is also hard to believe that a Green Travel Plan incorporating a shuttle bus service would make more than a marginal difference to those able to travel by private vehicle from around the country.

Landscape Impact

Again, in the absence of any studies to support the proposal the public is asked to visualize the impact of the buildings in open countryside without a proper level of information. Given this lack of information it is difficult to fully appreciate the visual impact of the proposals. However, it is very clear to the Parish Council that these vast complexes of buildings will have a scale and design wholly inappropriate in this area of open countryside and be at odds with the strong rural character which exists over a very wide area. This area has close historic association between villages and surrounding open countryside with a distinctive quality and varied landscape defined by its vegetation, topography, highway pattern and rural buildings. The proposals will be wholly incompatible with this distinctive character.

It is also very clear from the NPPF (sections12 and 15) that considerable weight should be given to good design. There are repeated references to this. Decisions should ensure developments ‘add to the overall quality of the area’ and be ’visually attractive’ and ‘are sympathetic to local character and history, including the surrounding built environment and landscape setting’. ‘ Design policies should be developed with the local communities so that they reflect local aspirations and are grounded in an understanding and evaluation of each area’s defining characteristics’. It is very clear that the proposals do not pay any regard at all to these national policies which are also reflected at local level. The proposed design is based on a template of current prison design which is intended to be applied across the country which in this case pays no regard to its historic rural setting, local distinctiveness or local character.

The existing buildings at the base are barely noticeable in the landscape because of their generally low profile and location. Occasional buildings, including historic aircraft hangars in open countryside beyond the main cluster of buildings often appear as rural buildings since they were designed to deter attacks from the air. However, the proposed buildings are wholly outside the existing built up area and located in open countryside. There are no existing buildings on the site and whilst technically seen as a brownfield site because of surface infrastructure in the form of aircraft runways the site has a greenfield character because of the lack of structures.

The cumulative visual impact of the many buildings proposed would be immense. There are fourteen cell blocks proposed, each four storeys in height plus pitched roofs or roof plant (there are contradictions between the site plan and layout drawings in the consultation document). Based on buildings erected at Glen Parva and Five Wells and information in the consultation document these are each in a cruciform shape and over 70metres across in width and depth. In addition a number of support buildings up to four storeys high with pitched roofs and up to about 110 metres in length are included.

The result is two clusters of large buildings creating a major complex of buildings for each prison separated by about 1000 parking spaces . It is akin to two large institutional building complexes or campuses constructed in contemporary design and materials. There is no similar complex of buildings for many miles around and the nearest examples are accessible and close to substantial built up urban areas, major roads and public transport. Moreover, other than perhaps local mediaeval village church spires marking the landscape there are no buildings similar in scale or design to just one four storey cell block again for many miles around.

The buildings in each complex would be spaced close together resulting in a ‘barrier effect’ facing the surrounding open countryside. These would be seen seen from public places at short range but also from key viewpoints over a wide area of countryside including Toppesfield Road, Hedingham Road and across the Pant Valley and from some key viewpoints could be seen as a backcloth to the village of Wethersfield. There is no attempt to explain this impact but it is clearly at odds with its surroundings and would not have any affinity at all with the historic rural environment within which the site is placed causing lasting damage to this important part of the county. There is some partial mitigation from some viewpoints from existing vegetation but much of this cover will be absent during winter months and this will accentuate the impact from a wide area.

Community Infrastructure
The Localism Act 2011 envisaged that communities affected by development should receive some benefits as a consequence of being impacted by development. Although it was intended that a Community Infrastructure Levy should be established by local planning authorities this has not been applied in this area. The MoJ has not suggested any mitigation or come forward with any proposals for enhanced community infrastructure so that apart from some economic benefit it is difficult to see how this proposal can have any benefit at all to local communities.Moreover, it is difficult to see what planning obligations might be sufficient to offset the very considerable impact that this proposal will inevitably have on this area and generations to come.

Sustainability
No sustainability impact statement is available but it is obvious that there will be a considerable impact. The light pollution generated by around 3000 cells, intense outdoor security lighting around the whole perimeter of well over two miles in length, associated lighting of circulation and access roads and car parking together with support buildings will be totally unacceptable in this open rural location. Amongst other effects, this may well be at odds with the rewilding project recently announced on recently acquired land between the village of Wethersfield and the base.

Construction is expected to take several years and this will impact very heavily on the villages surrounding the site. Heavy lorries have difficulty negotiating local roads and cause considerable nuisance and danger. This will be compounded many times over should this proposal proceed and this reinforces the Council’s view that the proposed prisons should be located closer to the national road and rail system in a more sustainable location.

There is a belief locally that the site is heavily contaminated and substantial removal of material would be required including the concrete runways. This could involve several thousands of tonnes of material which will add very substantially to the unacceptable traffic impact referred to above. To avoid this situation, an open use such as a solar park part of the site might has been suggested as one potential alternative.

In conclusion, whilst the Parish Council recognises that the proposal could have some limited local benefit, it strongly believes that this not an appropriate project for this site and that a Master Plan for the whole site should be prepared before any further proposals are put forward. But in any event, taken on its own in a piecemeal way the proposed prisons are grossly excessive in scale, out of character and totally inappropriate in their rural setting with a consequent excessive and unacceptable impact on the local environment to the detriment of people living, visiting and working in local villages and surrounding areas.

I hope you will give careful consideration to these points before a decision is taken on whether to take these plans forward.

Yours faithfully

Michelle Baker
Clerk to the Parish Council

Finchingfield

Finchingfield

Wethersfield

Great Bardfield

Sible Hedingham