Objections to the Defence Technical College & Aerospace Business Park

Cynefin y Werin - St Athan Campaign Group

Objections to the Defence Technical College & Aerospace Business Park

Planning Applications nos. 2009/00500 and 00501/OUT

INTRODUCTION

Cynefin y Werin – the all-Wales network of organisations promoting international peace, social

justice, human rights and equality – considers that the placing of a ‘Defence Technical College’

(DTC) in Wales is a matter of interest and concern to all people in Wales. This is because it will

have far-reaching implications for the environment, economy, sustainability and security of the

nation, for our educational and cultural traditions, and more generally for the projection of a

distinctive ethos of Wales in the world.

A ‘St Athan Campaign Group’ has been established over the past 2 years within the network

(see: www.cynefinywerin.org.uk) to monitor developments there, and this submission

represents the views of our organisational members and those active in the Campaign Group.

EXECUTIVE SUMMARY

● The St Athan Development Brief of 2006 was based on overly-high figures for DTC personnel

and trainees (at least twice the current estimated numbers) so must now be considered out

of date. The northern access road – with a junction on the B4265, destructive of meadows,

causing flooding problems and approaching close to dwellings – can therefore no longer be

assumed to be justified. The case for £15 million or so of public spending on this, compared

with the alternative access at West Camp, needs full consideration.

● The DTC was initially promoted by the Welsh Development Agency (WDA), a quango, and

then decided upon at the Westminster parliament, without an opportunity for consideration

by the people of Wales or our elected representatives in the National Assembly for Wales.

We call for a Planning Inquiry, to ensure that a higher degree of democratic scrutiny of the

DTC can take place before any further action is taken.

● The Aerospace Business Park (ABP) is a speculative development, based on a draft ‘businessas-

usual’ strategy and dependent on improbable public funding approval by the Welsh

Assembly Government (WAG). Its northern access road is contrary to the Vale of

Glamorgan’s (VoG) development plan, both in itself and in facilitating green-field housing

for the DTC. We seek its call in for a Planning Inquiry too.

The economic recession has swept away any unproven prospects the ABP had in 2000. The

Welsh Assembly Government’s policy for a low-carbon economy, if applied consistently,

should end plans to expand the aerospace business, Moreover, the earlier “Red Dragon”

project can hardly be considered a valid forerunner for this new development:

a) as the Defence Aviation Repair Agency (DARA) workforce there will be disbanded within

months, and DARA’s super-hangar becomes unavailable;

b) in an era of contraction, or at best stagnation, of the aerospace industry;

c) in a post-recession economic situation that rules out planning on the basis of recent

trends.

● We propose that both a reduced size DTC and a realistic scale ABP could readily fit within

the present airfield site. ‘Green-field’ development, departing from the VoG Council’s

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Unitary Development Plan (UDP) as in the Planning Brief, is not justifiable. We support

local opposition to building service families’ accommodation on the western side greenfields.

“Key worker housing” of 553 (483 new-build) units is much more than can be

justified, and more could be sited on surplus parts of the existing Ministry of Defence (MoD)

site. The western access road is an environmentally damaging relic of the original planned

peripheral road, and we support the local proposal for alternative access via an improved

junction and rail bridge at West Camp.

● WAG’s plans range beyond this application. Its 2008 Prospectus for St Athan now calls the

ABP an “Aerospace and Defence Park”, promising “maximum security… for any aerospace

and defence work”. It promotes St Athan as the centre of an aerospace industry hub, linking

BA at Cardiff Wales Airport and Pontyclun, GE at Nantgarw, and growing numbers of

businesses on-site, with “potential for further land development – 200 acres” and “planned

new hangars … up to [the size of] 767/A330 aircraft”. Public expenditure considerations are

lacking, and no business case has been developed.

● Details of the extra land (approx. 100 acres) and specific requirements for maximum security

work should surely have been included in the present application. We believe that their

exclusion is disingenuous, and that the VoG Council should challenge WAG over them.

Making a decision on the current applications when the applicants have publicly indicated

that they intend further developments to extend the site would be to allow incremental

development. Permitting such applications has in other cases been an issue for the

Ombudsman. The Vale of Glamorgan Council should oblige WAG to disclose its entire plan

for the ABP. Likewise, the Council should oblige the MoD to disclose plans for surplus land

within its West Camp site (which it had nominated for housing in the Local Development

Plan [LDP] process).

● The security implications for the development are of a national and international nature.

These stem from the concentration of defence training that is proposed, made all the more

acute by the fact that military personnel from overseas will be trained there. In our view, it

follows that the planning application entails national security, an issue in Planning Policy

Wales. The failure to cover the issue to enable full scrutiny for planning purposes needs to

be raised with WAG as an unacceptable omission.

SUMMARY CONCLUSION

We view these planning proposals as contrary to the interests of the people of the Vale of

Glamorgan and of Wales - as being environmentally and economically unsustainable; based

upon an unsound, speculative aerospace prospectus; socially undesirable for the locality and

community; presenting security risks to people locally and in Wales as a whole; and

contrary to the traditions of peace that have historically been so strong in Wales.

Privatisation of military training is part of a trend of privatising military services. This puts

on a commercial basis certain defence activities which are fundamentally a public service,

and which should be delivered by people imbued with an ethos of national interest. This

underlies a further fundamental objection the Campaign has to the Metrix project.

In view of the grave importance to all the people of Wales, as well as those in the Vale of

Glamorgan, of these proposals we ask for both Applications to be called in by the Welsh

Assembly Government for further examination and for Public Inquiry.

………………………………………………………….

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DETAILED OBJECTIONS

1. We argue that the planning application by the Welsh Assembly Government’s Aerospace team:

a) promotes St Athan as a “Centre of Excellence for Aerospace and Defence”, yet has failed to address the

impact of the institution on the national security of Wales, on the achievement of ‘the Wales we want’, and on

our external international image;

b) has provided insufficient information on the full land-take envisaged, and on disclosing its plans for

“maximum security” military work and its land-use implications;

c) while discussing local security for the MoD site and the need to segregate civil from military maintenance,

fails to address any national security planning dimensions and the political implications for Wales of

association with military R&D, hardware and training of this type and scale.

We accept that the Vale of Glamorgan Council is not in a position to consider these national security issues.

Planning Policy Wales makes clear this is a Welsh Assembly Government responsibility. We ask VoG

Council Planning Authority to request that WAG call in the St Athan Defence Technical College planning

application for a Public Inquiry. The Council itself needs to press for full information on points a) to c)

above, in order to meet legislation on Environmental Impact Assessment.

2. We see that the plans and claims made in the publicity surrounding the Defence Technical College

development are at least in part based on exaggerated claims and speculation:

The scale of the DTC is still exaggerated: “The project involves developing a new military academy for

8,500 personnel” http://www.ibwales.com/business-sectors/aerospace-and-defence/news/stathan/

aerospace-business-park-update. The current numbers for personnel are in fact half that –

2,500 (maximum) trainees, 1,700 DTC and military staff, and 600 service staff (catering, cleaning,

maintenance and transport).

The actual training contract is uncertain:

● the huge cost has made it potentially “unaffordable”, even before the £30 billion deficit in MoD finances

which became clear in August 2009.

● the estimated benefits from selling vacated MoD sites for development are much reduced.

● the British Conservative Party has announced it will review all major defence commitments if it enters

government in 2010.

The St Athan focus has been scaled down, and this reduction may go further as:

● navy engineering training is to remain at Portsmouth, potentially until 2025 or later;

● there is reduced emphasis on centralised learning – nine satellite learning centres with Computer

Aided Learning are planned;

● a significant number of the experienced staff seem unwilling to move to St Athan;

● trainee contact hours have been reduced from the 1.5 million per year originally considered necessary

by the training staff.

Indeed, these and other changes mean that even the revised planning figures for staff and trainees that were

determined at the beginning of 2009 (approx. 4,200, set out above) are likely to be too high, and are out of

date.

3. Environmental Impacts are excessive and inadequately addressed

Flemingston firing range and Flemingston field training area

Cllr R Eustace of Flemingston Community Council has detailed impacts of noise from use of the firing range

(at times up to 11 pm), and ambush training with the firing of blanks and thunder flashes. Although acoustic

fencing and bunding will be installed, he reports “there will still be a medium to high magnitude effect on

neighbouring properties”. As the firing range is already in use, people know how disturbing the sudden

sounds are. Intensified use should not be allowed, but a new, better-soundproofed facility built, remote from

any dwellings and preferably within the camp.

Northern Access Road

This roadway is very intrusive in an open landscape, crossing a scenic valley stream on a bridge, and over

meadows on an embankment. This is a very noisy design – the traffic noise would spread readily to housing

at Millands Park and Eglwys Brewis Road. The plans to light it at night make for further intrusion, and

unneeded light pollution. The land on which the road would be built is productive farmland and sections

severed from it will be lost to housing and development of ‘possible sports facilities’ instead.

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Flooding Problems Enhanced

Flooding is a problem at Boverton, recently tackled by flood bunds to retain water on the fields affected by

the road. The disruption of the new system and the additional run-off from the road and adjacent housing

could have effects that cannot be met at acceptable cost by the assumed underground holding tanks. A

fuller study of the issue is needed.

Aero-engine Test Facility

The noise from the present aero-testing facility is in practice highly disturbing. No argument is given for

allowing a new facility to be sited anywhere in the neighbourhood of housing, especially one closer to

Boverton where the engine testing is already found to be disturbing. As Batslays Farm is to be retained for

offices, siting the test facility adjacent to the farm buildings is unacceptable. Section 16.15 of the application

confirms that the significant detrimental noise levels from the engine running will affect properties to the

south of Boverton. Though the consultants propose mitigation via earth bunds (three sides only) they do not

give figures to show if this would be effective.

The MoD should be objecting about this aspect on behalf of present and future occupants of staff housing:

presumably their conflicting interest takes precedence. Once the VC-10 contract ends in 2014, there is no

justification in continuing aero-engine testing on a site that is even more sensitive than the present one.

Moreover, the MoD did nominate land on the south of West Camp for housing under the LDP; use for

housing and other purposes will be prejudiced by the proposed test facility.

Watchman Radar system

This system would have to be moved to St Athan (from Cosford), yet is not mentioned in the documents.

The high power system would affect residents much more strongly than the non-ionising radiation emitted by

mobile phone transmitters. There is also a possibility that Watchman will interfere with aircraft

communications at Cardiff Wales Airport: Speke airport, which is far further from Cosford, has encountered

such interference.

Concerns on these counts should have been covered in the Environmental Statement. Since no information

is given, Metrix should be required to guarantee that it will not seek to bring the Watchman system - or a

similar tower and transmitter system - to St Athan at some later date.

4. Implications for existing Development Plans

a. The VoG Council has said that this is the most significant planning development it has ever

considered; planners therefore should themselves be calling upon WAG to hold a Planning Inquiry.

This would match public expectation of independent and fair planning that the Town & Country

Planning Act 1990 (TCPA90) is supposed to ensure.

b. The VoG Council should resolve that the housing and road proposals “significantly prejudice” the

Unitary Development Plan by reason of scale, nature and location (Planning Policy Wales, PPW

4.12.2), when WAG has to consider a call in for a Public Inquiry. The Council should point out the

“wide effects” and “substantial controversy” beyond the immediate locality, as well as “issues of

national security” (PPW 4.12.1).

It is worth noting that WAG has just announced it is calling an inquiry over the Junction 33 / M4

Motorway development because “Ministers have concluded that the scale and location of the proposed

development and its overall impact on the environment raise the possibility of substantive conflict with

national policy on development in the open countryside...”. The ‘possibility of substantive conflict’

likewise clearly applies to these St Athan applications.

c. Alternatively the VoG Council could trigger an appeal (PPW 4.11) by either not determining the

applications or rejecting them as premature until the new development plan (LDP) passes through its

consultation and inquiry processes (or pending a Conservative government review of MoD contracts,

several months post-election).

Should Metrix insist on an earlier decision and appeal, there should result a Public Inquiry under the

Planning Inspectorate (PPW s. 4.12.1), unless WAG recovers the appeals for their own determination

because of “novel planning issues”.

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5. Unrealistic and speculative Aerospace development

The Aerospace Business Park started as a means of replacing jobs servicing the RAF base, and to make

use of the St Athan airfield’s assets. When the Red Dragon Project was conceived to take over from the

Defence Aviation Repair Agency (DARA), it was said that the £77m high-tech aircraft repair and

maintenance centre would be the basis for a world-class aviation centre with 2,000 jobs. This never

happened.

a. We are concerned that there has been no sober risk and business assessment for the current

proposal. The consultants Mott MacDonald were appointed in December 2008 by WAG to update

demand studies. They claim as a key finding: “The current economic downturn, although severe,

should have only a short term impact on the aerospace industry.” That statement is based on a world

view inconsistent with the WAG policy of changing Wales to a low carbon, sustainable economy. The

Prime Minister calls it a "historic mistake to think we can now return to business as usual" (Gordon

Brown, Interview with FT, 1 Sept.09).

b. Even in 2007, the UK Maintenance Repair and Overhaul (MRO) market was decreasing, and the

further decreases in the recession are surely stronger than the 0.9-1.8% guessed at in the Planning

Statement (s.218).

c. The prognosis for MoD work did not take into account the expected shortfall in MoD funds, which is

due to worsen in public expenditure cuts. The expectation of ‘business as usual’ from 2010 ignores

the government’s own expectations of public expenditure cuts for a decade or so, and was slated by

the Prime Minister himself in the interview cited above. It was also in ignorance of the huge overrun in

MoD project expenditure, set recently at over £30 billion, and new concerns about military equipment

requirements, especially in Afghanistan.

d. The original aim for the development at St Athan – regeneration, and continuing employment for

DARA’s engineering workers – has failed and much of the workforce has disappeared (to other sites or

jobs, or retired). While the publicity claims a “large, local skilled and flexible workforce”

(www.ibwales.com/server.php?show=ConWebDoc.5069), jobs for the remaining 400 people based

there will end within months and this new development of hangars and other buildings to handle large

aircraft will not produce any for approx. 5 years.

e. A poor record in attracting companies: the 2008 brochure has added “highly competitive rents”,

because of the dearth of companies seeking the empty sites/buildings at St Athan. Firms on site are

dwindling (down to three) and there is little prospect of any newcomers in the short-term with the

current recession in aerospace in the UK.

f. Little evidence of other skills: the Welsh Aerospace skills brochure lists 49 Welsh skill centres but cites

only MPI Aviation at MoD St Athan, which it describes as a ‘Project Support Specialist’ with an office in

Telford. It undertakes cargo conversions, repair schemes, maintenance and structural modifications,

as well as interior refurbishment and re-configurations (www.mpi.ltd.uk/aviation.asp).

g. Since Wales has other sites for civil aviation work, already with MRO workforces and facilities, what

justifies investing at St Athan in competition with them? The 2,500 jobs that “could be created” are not

particularly needed more in the Vale of Glamorgan than elsewhere, but would put unwanted pressures

on services and housing.

h. Mott MacDonald’s projections envisage winning work on a speculative basis:

● huge new hangars to allow MRO work on large military transport aircraft (Globemaster III and

FSTA). Yet the fleet of FSTAs (a modified Airbus) will be based at Brize Norton in Gloucestershire; the

RAF’s future A400M and Globemaster Transporter will only be open for MRO bids after the DARA

skills/workforce has been disbanded.

● retrofits of communications, navigation and surveillance systems to civil and military aircraft; no

reason is given why retrofits could be better done at St Athan than elsewhere, not even “some of this

work”.

● maintenance and storage of unmanned combat air vehicles (UCAVs). No reason is given for

maintenance and storage of UCAVs, compared with Aberporth in Ceredigion or elsewhere.

i. While we are told that “strict segregation” of maintenance of military and civil aircraft will be necessary,

the proposals do not explain how this would be feasible, including segregation for runway purposes.

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j. The strategy drawn up by the ‘dedicated aerospace team’ is a “draft” only that has not passed

Treasury-standard assessment, nor gone to public consultation, nor gained WAG approval. The

realistic expectations for aerospace jobs would be fewer than the 2,000 originally given, and well below

the 2,500 of Mott MacDonald. We believe that the VoG Council must therefore treat it as unfounded,

speculative development and apply strict planning rules.

Hence, the plans as submitted, and promotional publicity for the Aerospace Business Park development, are

based on speculative claims. On the evidence supplied the ABP lacks a sound business case, and is likely

to be abandoned if subject to Westminster government Treasury criteria. The case in the Planning

Statement (s.231-236) is reminiscent of the Cardiff Wales Airport expansion that the WDA supported in

1999-2000 but which never came to pass.

6. Lack of Openness on Area for ABP development

The 166 hectare area given in the Planning Statement includes the runway and wide exclusion areas

either side – the real area available is about 250 acres, as given in publicity material. However:

● the 2007 promotional pamphlet ‘Come fly with us’ of Aerospace Wales (and International Business

Wales) says at least 346 acres is “available for bespoke development”;

● the Aerospace Wales 2008 St Athan promotional brochure refers to a “secure 250 acres” and a

further 200 acres “potential for further land development” (as also does

http://www.ibwales.com/business-sectors/aerospace-and-defence/news/st-athan/aerospace-businesspark-

update);

● ABP South comprises an area of 117 acres (46.84 hectares) south of the runway at

Batslays, West Orchard and Beggars Pound.

Part of ABP South is for the access road, while Batslays Farm development depends on compulsory

purchase. This potential for development is thus under 120 acres. We infer that WAG is envisaging

at least a further, as yet unspecified, 80 acres as “potential for further land development”.

Omitting to describe its full ambitions – presumably for land closer to St Athan housing – is wrong on

the Welsh Assembly Government’s part. The Council Planners should oblige WAG to disclose all of

the areas of land it envisages developing in its promotional literature.

7. Security Risks of the DTC and Aerospace and Defence Park

a) The DTC would be a prime target for ‘terrorist’ attack for at least two reasons:

● Metrix (as does Raytheon already) will boast of it as a flagship training centre, making it a high profile

target.

● trainees will be on site from military forces of countries like Saudi Arabia and Malaysia (associated with the

weapons systems sold to them by British companies) and potentially from other regimes or even private

forces to which Metrix may sell its training packages.

While the recipients of Metrix training would be subject to MoD policy, government policies can change and

the planning authority has to anticipate the worst case. Even present practice in training non-UK forces

would make St Athan/Wales a target and so raise “issues of national security” in the words of Planning

Policy Wales (4.12.1). Potential conflict with the National Assembly for Wales’s commitment to human

rights also needs to be considered.

b) The 2008 St Athan promotional brochure calls the ABP an “Aerospace and Defence Park”, and includes in

the ‘St Athan – a centre of excellence’ section “maximum security – suitable for any aerospace and

defence work” (also at www.ibwales.com/aerospace). This proposal was not in the 2007 Aerospace

Wales pamphlet and is not admitted in the planning application 2009/00501, but is in the St Athan

Aerospace and Defence Park brochure.

The ABP planning application is inadequate in omitting the land use implications of this ‘maximum security’

area. More importantly, it omits the implications for the ‘national security’ of Wales, noted as meriting

special planning consideration (PPW 4.12.1).

Thus both developments would identify St Athan and Wales with work on military systems up to the most

sensitive level. Plans have to be made to cover St Athan and the surrounding area becoming a prime

target for ‘terrorist’ attack.

Cynefin y Werin : St Athan Campaign Group 8 September 2009

Temple of Peace, Cathays Park Cardiff CF10 3AP