To: West Berkshire Council (WBC) Planning Committee. Objection to Application Number: 06/02326/FULMAJ, AWE Aldermaston Nuclear Weapons Development Office Accommodation
The proposed plan for accommodation for 1,400 additional staff and 1,500 car park spaces suggests that this major development is more than replacement of out-dated existing offices and involves an expansion not seen at AWE in the last 20 years. Further evidence is published in the August edition of AWE’s in-house magazine, ‘AWE Today’, reporting that a team of 23 recruiters are working to advertise jobs and that an increase in staff is expected to reach 1000 plus1200 extra contractors during construction. As Crown Immunity no longer protects the site, the local authority is required to ensure that the application is within planning law. Given the major status of the plan and its place in the context of the whole AWE Site Development Strategy Plan, a public inquiry is needed to determine if this application is legal.
1. The Statement of Community Involvement (SCI)
The SCI states that the consultation begins at the earliest stages of each document's development so that communities are given the fullest opportunity to participate in plan making and to make a difference.
Every Statement of Community Involvement must provide open access to information, actively encourage the contribution of ideas and representations from the community and provide regular and timely feedback on progress.
Objection 1.The plans and supporting documents do not explain what is going on in the 8 rooms marked West Plantroom and East Plantroom on each floor of both buildings. These rooms are not offices and are not normal service facilities for offices. Further information is needed. It is not possible to comment on the use of this part of the buildings until a response to Nuclear Information Service (NIS) requests submitted to officers has been received.
2. West Berkshire Planning Strategy Submission
NIS is to make representations to the Council on the new Strategy Plan in relation to the AWE Site. The questions to be raised are relevant to this application, primarily to ask why there is no published policy on AWE, as a major employer and extensive hazardous site in the district? Many other employers and particular sites are referred to individually in the Strategy Plan; whereas AWE, the hazardous nature of the site and the surrounding 3 Km countermeasure zone are ignored.
In relation to rural areas including that around AWE, the Council’s views are expressed as:
Spatial Policy 11
Rural West Berkshire
The overall approach to development with rural West Berkshire is that development should be generally restrained in order to protect the rural character of the area whilst allowing for development which supports the continued well being of the countryside and rural settlements.
The proposed offices at AWE do not comply with WBC planning policy.The two large buildings near the edge of the site impact directly onto rural surroundings and are anything but restrained. In fact they are described in terms of being designed to achieve maximum visual impact.
3. Public Inquiry
WBC Planning Committee has triggered a Public Inquiry in February 2007 into the suitability of land on Paices Hill opposite AWE for house building when an expert Inspector will decide the case. Expert advice concerning the impact of this application and whether or not AWE is expanding and extending its operation is needed, and the current application provides an
excellent opportunity to do so. If planning consent were refused, AWE could appeal, and a Public Inquiry held to allow a Planning Inspector to examine the facts. No special treatment can be afforded AWE. (See 8. below)
This application is controversial and should not be approved. In the same way that other controversial planning applications are dealt with, a public inquiry is needed.
4. Local Plan
The Aldermaston map in the local plan shows an open aspect across AWE as viewed from the A340 along Paices Hill between ‘the citadel’ weapons production plant in the north of the site and buildings near the west gate. This open aspect should be preserved and large buildings that obscure the skyline and reduce the green open space should be located away from the fence in the interior of this extensive site. The huge laser building is already reducing light and open sky at this location and two further buildings will make matters worse.
Objection 4.The office buildings are too large and located too close to the fence, reducing the open aspect from the A340. Together with the laser building they will form an extensive block of buildings at the periphery of the AWE site rather than being discretely sited in the interior of AWE’s land.
5. AWE Development Plan
The AWE Strategic Site Development Plan published in 2002, revised in 2003 and 2005 is a complete site development package that should have been submitted to the Planning Authority as a complete plan. The drip-feed of applications gives rise to the over development of one side of the site along Paices Hill and a dangerous concentration of HGV construction traffic on the A340 over several years, apart from the long term traffic increase on this side of the site. The public, statutory consultees and WBC Planning Committee had no opportunity to comment on how the whole plan would affect the area.
This application for offices and plantrooms at this location should have been submitted at the time of the first AWE Site Development application and at least at the time of the laser application. Before this plan can be considered, the proposed site of the Hydrodynamics building must be disclosed.
Existing traffic problems on the A340 due to normal traffic levels plus the laser construction HGV traffic will be compounded by construction traffic to the office site. The A340 is a fast major road through a rural area that links the M4 and M3. It is already nearing saturation point and has been the site of serious accidents. Both at construction and operational stages, traffic turning into and out of AWE from the A340 will massively increase, given the parking spaces for 1,500 cars shown in the plan. The plan has to be taken at face value and caveats suggesting that car spaces may not be additional to existing ones should be ignored. The 1,400 additional highly technological staff to be employed cannot be relied upon to give up the use of their cars to get to work in this rural location. The remedial proposals to provide cycle lanes and pedestrian crossings will not avoid the traffic problem and the suggestion in the Application that there will be an overall benefit in this context is disingenuous.
The plan to further increase road traffic on the A340 should be refused on safety and density grounds.
7. Environmental Impact
The Environmental Impact Assessment supporting document explains that both ground water and land contamination analysis has yet to be done. This is unacceptable. The data should be available before plans are approved. Otherwise, Consultees have no opportunity for ‘input’ on the subject of land disturbance. The issue has always been of great concern and consequence for the surrounding land outside the fence. The Environment Agency has raised concerns about land near this area on the AWE site in the past, suggesting that the problems may exist. It is surprising that AWE has failed to prepare the basic information required for an Environmental Impact Assessment, indicating only that it intends to do so. Similarly, drainage problems are not resolved and appear to be treated lightly by the applicant.Objection 7.
Transparency of ground water, contaminated land and drainage data is required during the consultation period since consultees are entitled to evaluate any disturbance that may impact on the environment outside the boundary of this hazardous site.
8. Crown Immunity
Since Crown Immunity is no longer required, some outstanding questions arise relating to the plan:i. Will Building Regulations apply and be inspected?
ii. Will there be ‘no-go areas’ for the inspector?
iii. Why are the financial contributions under Planning obligations yet to be agreed?
In the new regime of planning transparency for AWE, public information should include details of how AWE will comply with building regulations and what the financial contributions will be at the consultation stage, as this may well be an area where objections require the adjudication of a Planning Inspector.