Take Action to Stop the New Mega-Prison in Yorkshire

The situation: Yorkshire is set for a new Mega Prison which could have serious repercussions for local people, as well as those harmed by the prison system. Local Group, Yorkshire Campaign Against Prisons, have asked for solidarity to help fight this development.

On this page you will find information about how to object to the planning application for the new prison.

How to submit a planning objection

1. Visit: https://newplanningaccess.eastriding.gov.uk/newplanningaccess/applicationDetails.do?activeTab=summary&keyVal=OPBCVZBJL8J00
2. You will find the application summary. Click the Comments tab.
3. Click “Make a comment.”
4. Fill in your details and submit your comment. You have a maximum of 1000 characters.

How to Find Background Information about the Prison

You can find all the planning documentation for proposed prison next to HMP Full Sutton here: https://newplanningaccess.eastriding.gov.uk/newplanningaccess/applicationDetails.do?activeTab=summary&keyVal=OPBCVZBJL8J00

Use the search function and enter the reference.

The Planning Application Reference is: 17/01494/STOUT

You can also send questions to the Planning Department:

Planning and Development Management Team
East Riding of Yorkshire Council
County Hall
Cross Street
Beverley
HU17 9BA

Potential Points to Make

Everyone will have different reasons for why they are concerned about having a new prison in their local area. For people that do not live locally, they may feel concerned about the harm the prison system causes and not want any more to be built anywhere.

This page aims to summarise some of the key points about the prison.

Click here to read about the ethical arguments against building a new prison.

Environmental Impact and Health and Safety

  • The Environmental Health Department at East Riding of Yorkshire Council has identified the site (and surrounding land) as potentially contaminated land due to its historical use as a ‘bomber airfield’. It has been ranked as ‘A1’; a high priority for inspection; however, the Council stated that it has no plans to investigate the site or any site within 250m in the near future as part of its duties under Part 2A of the Environmental Protection Act 1990 (its Contaminated Land Strategy). The Council stated that if redeveloped, the site is likely to require an intrusive environmental investigation as part of the planning process. No intrusive or adequate investigation has been instigated. We believe it is of deepest concern to undertake these investigations before considering any potential development on the site.
  • A detailed unexploded ordanance threat and risk assessment has not been carried out in accordance with CIRIA C681 ‘Unexploded Ordnance – A guide for the construction Industry’. The site is high-risk for both construction workers and later prisoners and workers at the site.
  • The site poses an unacceptable risk of radiological contamination. It would not be acceptable for a housing development, therefore, it should not be acceptable for prisoners.
  • An independent of a specialist radiological consultant needs to be commissioned before any planning application is approved to appraise radiological risks associated with historical uses and provide guidance on the need or otherwise for further screening and assessment.
  • Shallow groundwater is present beneath the site within superficial deposits, and this could provide a pathway for mobile contaminants to migrate laterally onto the site from off-site sources, away from the site onto third-party land or vertically into the underlying groundwater body.
  • Ramboll Environ state that the presence of potentially contaminative materials which could pose a risk to Controlled Waters cannot be discounted.
  • It is impossible for the planning committee to grant permission for this development until the plan for the internal energy plant of the prison is finalised. Without this, the air quality assessment is redundant because the stack design of the plant could have such an impact on emissions.
  • Yorkshire water have said that “The public sewer network does not have adequate capacity available to accommodate the anticipated foul water discharge from this proposal site.
  • Should the results of the feasibility study find that upgrade of the existing pump station cannot be upgraded and no alternate connections are available then, onsite treatment or tanker/truck collection for offsite disposal will need to be considered. This then needs to be accounted for in the transport impact and air pollution assessments in the application.
  • The MOJ are considering discharging surface water to the nearby tributary of the River Derwent, Millsike Beck via a culvert under Moor Lane. Despite articulating compliance with legal run-off rates, this is still an unnecessary development and unnecessary polluting impact on this waterway. Combined with the contamination risks, it is simply unacceptable.
  • A number of water-related recommendations have been made, which the MOJ have not complied with or included in their application. These include:
    – Full geotechnical investigation to confirm soil infiltration rates and variations of groundwater levels
    – On-site geo-environmental testing to confirm level of contamination on the site
    – Analysis of detailed topographic level survey data to inform detailed design of finished
    surface falls and surface water features
    – Further surveys and analysis to be conducted to better understand the existing on-site
    surface water system, including the ditch and pond capacity and pluvial flooding
    – Ecological impact assessment for the increased flows, expected contaminants and
    potential accidental discharges for the proposed development
    – Further determination of the suitability of SuDS within a prison environment
    – Liaison with the LLFA and EA regarding surface water discharge consents and ecological
    mitigation strategy
    – Progress feasibility study with Yorkshire Water regarding foul water connection
    – Assessment of new connection points and coordination outside of the site boundary (for
    example with other utilities)
    – Design of a full detailed drainage strategy
  • We emphasise that it is not SAFE or appropriate for outline planning permission to be granted at this stage, because once approved, construction processes will start and the above issues will not be resolved, putting local residents and the environment at risk.
  • The prison will have several negative landscape impacts including:
    – Field amalgamation and neglect of hedgerows with consequent increased size of fields and increased openness of the landscape.
    – Pressure for industrial development in the vicinity of Full Sutton, Full Sutton Airfields and Industrial park with consequent adverse effects, including ‘in-combination’ effects on the character and amenity of the landscape. This is likely to be exacerbated by increased openness arising from field amalgamation and hedgerow losses that will increase intervisibility and expose the edge of developments.
    – Growth in residential developments in the vicinity of Full Sutton, Stamford Bridge and Pocklington. The effect of residential development will inevitably be exacerbated by any increased openness in the landscape, thereby increasing the visibility of settlement edge developments.
  • To the east of the proposed prison is a surface water attenuation pond which accepts runoff from HMP Full Sutton and drains via a ditch to the west into off-site water features. These features provide habitat for species including water vole and the attenuation pond has been managed for its value for wildlife. Both areas will be destroyed if the prison is built, and ecological mitigation strategies have not been included in the planning application.
  • A project of this scale demands a full and comprehensive Environmental Impact Assessment. It is not sufficient that the local planning authority deemed it unnecessary historically, when the project is significantly larger and will have a higher environmental impact.
  • It is impossible for the local Planning Authority to approve this planning application, even at outline stage, when the number of buildings, their use and layout of the prison are not fixed.

Social & Economic Impact

  • The number of jobs that the prison will generate has been exaggerated by the Ministry of Justice, who have said there would be 508.5 staff employed directly at the prison based on guidance from the MoJ’s Economic Impact of a New Prison report that indicates that 275 of these could be undertaken by people from the local area. This however is based on a 1:2 staff to prisoner ratio. The ratio of prisoner to prison officers (including specialist) as at 30 September 2015 was 4.8 at male establishments and 3.5 at female establishments.
  • When prisons disproportionately harm black and ethnic minority communities so significantly, a Council whose ward is 97.9% white should not be allowed to determine the decision of a new prison that will so significantly impact local people of colour.
  • According to the MOJ’s own commissioned assessment, the construction process would require specialist skills and techniques. Therefore, it is assumed that the majority of these jobs would be filled from outside the local area, within the wider region.
  • The construction of the Proposed Development may displace construction activity, which would have occurred elsewhere.
  • It is not acceptable to build a prison that will imprison over a one thousand individuals with complex needs (homelessness, substance misuse, mental health issues etc) to create 34.5 net new regional jobs in building the prison.
  • The Socio-Economic Assesment undertaken for this project states that it is likely that the number and/or capacity of local and regional community organisations would increase as a result of the new prison becoming operational and the associated additional numbers of prisoners in the local area, particularly given their Category C status. These are commonly organisations from the public and third sectors. They are often funded through Government contracts and charitable donations. There is ZERO evidence quoted to underpin this statement. There is no evidence to prove that this prison will not harm, strain and seriously impact local services. It is the responsibility of the planning committee to pressure the applicant to better substantiate their statements in protection of the public.
  • Proposed working hours for construction include Saturday mornings, which may have an adverse affect for those requiring rest at weekends.
  • There is no guarantee that the prison will not become overcrowded like other prisons in the UK. What promises are there from the MOJ that it will operate at it’s advertised capacity (1,017) rather than being subject to the doubling up of cells.
  • No alternative uses for the site have been explored by the Local Authority, nor has the community been consulted on alternative uses.
  • There is inadequate information about the workshops within the prison and their relationship to local companies and the local labour force. The size, scale and purpose of the workshops have not been disclosed and are essential to the decision making on the prison.
  • The planning documentation does not adequately assess the impact of the prison on the local ambulance service. HMP Oakwood, which is a similar size to the proposed new prison had more than 358 calls to the ambulance service in 2014 alone. (1)
  • The planning documentation does not adequately assess the impact of the prison on the local police force. Data produced by North Wales Police estimates that “Based on the available data, incident and crime prediction work has been undertaken and current estimates put the police staffing costs at £147,000 per annum with £52,500 capital costs in year one and £21,000 per annum associated revenue costs thereafter.”(2)
  • The socio-economic impact assessment is completely inadequate. It does not adequately assess or analyse the impact of the prison on local services. Data must be provided on the new prison’s impact on mental health services, the NHS, local housing, social care and other welfare services.
  • The planning documentation states there will be “workshop buildings where prisoners will carry out a variety of activities”. More information is required about these activities and their impact on local people, especially if they involve the use of prison labour.

East Riding Local Plan 2012-2029

  • Prisons do not feature once in the East Riding Local Plan – this is a project imposed by the Ministry of Justice that is not in the best interests of people in Yorkshire.

The shared vision of the plan is:

Children and young people are happy, healthy, confident, safe and reach their full potential
Older people enjoy a healthy, independent lifestyle
Communities are healthy, thriving, prosperous and safe
Regeneration transforms deprived areas and reduces health and other inequalities
We value and care for the diverse character of the area.

NONE of these objectives will be achieved by a new prison in East Yorkshire

References

1. https://www.parliament.uk/business/publications/written-questions-answers-statements/written-question/Commons/2015-12-01/18366/
The ratio of prisoner to prison officers (including specialist) as at 30 September 2015 was 4.8 at male establishments and 3.5 at female establishments.

2. http://www.bbc.co.uk/news/uk-25809660

3. http://www.cape-campaign.org/wrexham-prison-will-cost-north-wales-police-extra-147000-a-year/