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Asylum Welcome Objections to Planning Application 14/01778/F

Asylum WelcomeObjections to Cherwell District CouncilPlanning Application 14/01778/FDecember 2014

Home Office/Ministry of Justice Planning Application 14/01778/F - Expansion of existing immigration removal centre to provide additional detainee accommodation, ancillary detainee and staff facilities, car parking, landscaping and internal fencing, Campsfield House Detention Centre, Langford Lane, Kidlington, OX5 1RE.

Asylum WelcomeUnit 7, Newtec Place, Magdalen Road

Oxford OX4 1RE, UK

T. 01865 722082F. 01865 792532

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Asylum Welcome is a registered charity, no 1092265, and a company limited by guarantee, no 4361627

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1 CONTENTS

2 EXECUTIVE SUMMARY 4

3 ASYLUM WELCOME 6

3.1 ABOUT ASYLUM WELCOME..........................................................................................................6

3.2 DETENTION EXPERTISE..................................................................................................................6

4 PLANNING LAW: GREEN BELT, ‘VERY SPECIAL CIRCUMSTANCES’7

5 THE STANDARDS THAT APPLY TO IMMIGRATION DETENTION 9

5.1 LAWFUL AND UNLAWFUL DETENTION..........................................................................................9

5.1.1 VULNERABLE DETAINEES AND ‘RULE 35’ REPORTS.............................................................10

5.1.2 NO TIME LIMIT FOR PERIODS IN DETENTION......................................................................10

5.1.3 DETENTION OF PEOPLE WHO CANNOT BE RETURNED TO THEIR COUNTRY OF ORIGIN.....11

5.2 CONDITIONS OF DETENTION.......................................................................................................11

5.2.1 RULES AND ORDERS............................................................................................................11

5.2.2 HM INSPECTORATE OF PRISONS: ‘EXPECTATIONS’.............................................................12

6 NO ‘NEED’ FOR INCREASED DETENTION CAPACITY 13

6.1 NUMBER OF DETENTION SPACES AVAILABLE..............................................................................13

6.2 LONG TERM TREND: MORE VOLUNTARY RETURNS, FEWER ENFORCED REMOVALS..................15

6.3 UNNECESSARY CASES OF DETENTION.........................................................................................15

6.4 TACKLING SYSTEMIC INEFFICIENCY WOULD REDUCE THE NEED FOR DETENTION......................17

6.5 ALL PARTY PARLIAMENTARY GROUP INQUIRY INTO DETENTION...............................................19

7 CONCERNS ABOUT EXPANSION AT CAMPSFIELD HOUSE20

7.1 INCREASED RISK OF SERIOUS INCIDENTS....................................................................................20

7.2 DATA ON SIZE AND DISPROPORTIONATE INCREASE IN SERIOUS INCIDENTS..............................21

7.3 CONCERNS BASED ON ASYLUM WELCOME’S DAY TO DAY EXPERIENCE.....................................23

7.3.1 HEALTH CARE......................................................................................................................23

7.3.2 ACCESS TO LEGAL REPRESENTATIVES..................................................................................24

7.3.3 PASTORAL CARE PROVIDED BY WELFARE OFFICE WITH ASYLUM WELCOME......................24

7.3.4 INDEPENDENT MONITORING BOARD CONCERNS 2013......................................................25

7.4 HARMONDSWORTH - A WARNING OF WHAT’S TO COME.........................................................26

7.5 DESIGN OF PROPOSED EXPANSION AT CAMPSFIELD HOUSE......................................................28

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8 FURTHER FACTORS WEIGHING AGAINST ‘VERY SPECIAL CIRCUMSTANCES’ 30

8.1 DAMAGE TO GREEN BELT............................................................................................................30

8.2 NOT CONSISTENT WITH LOCAL PLAN..........................................................................................31

8.3 CHOICE OF SITE...........................................................................................................................32

8.4 DRAINAGE...................................................................................................................................32

8.5 TRAFFIC.......................................................................................................................................33

8.6 CHANGE IN NATURE OF THE FACILITY/PREVIOUS APPLICATIONS...............................................33

8.7 NOISE AND DISTURBANCES.........................................................................................................33

9 APPENDIX 1 35

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2 EXECUTIVE SUMMARY Asylum Welcome is the charity that, for 20 years, has run the volunteer visitor group for

detainees at Campsfield House. Asylum Welcome’s mission to support detainees and our long experience of doing so explain our interest in responding to this application. (Section 3)

Development in green belt land should only be approved in “very special circumstances” and the Home Office makes the case that the need for extra detention places amounts to very special circumstances. (Section 4)

Asylum Welcome believes that there is a legal duty on planning authorities to assess the merit of the proposition that the expansion is needed. The planning decision-maker cannot put all the detention system arguments on one side by saying that they cannot consider the merit of Home Office policies - it would appear (however surprising this may be) that the context of this planning dispute does bring the policy issues into the centre of the appeal. (Section 4)

Asylum Welcome’s assessment of publicly available information – including government statistics – is that there are already sufficient detention spaces available for the current need, especially when considered against the long-term trend of declining ‘Enforced Removals’ and increasing ‘Voluntary Departures’. (Section 6, esp. 6.1, 6.2)

Furthermore, demand for detention spaces would be less if it was properly used in accordance with legal and procedural guidelines: detention is intended to be used only as a last resort and for the shortest possible time, in order to facilitate removal from the UK, but there are too many instances where this is not the case. (Section 6, esp. 6.3, 6.4)

For example, there are people in detention who cannot be removed from the UK because the government of their country of origin refuses them travel permits. There are victims of torture held in detention when Home Office policies say that they should be exempt. There are people taken into detention who later successfully argue that they should be released on bail – their detention could have been avoided if these arguments had been considered before they were detained. There are people in detention because they have been refused asylum but who later win the right to remain in the UK – their detention could have been avoided if the Home Office got more asylum decisions right first time. (Section 6, esp. 6.3, 6.4)

In addition to concerns that there is no need for this expansion, Asylum Welcome has concerns about the risk of harm if the expansion goes ahead. Government statistics reveal a disproportionate increase in the risk of serious incidents occurring within a centre, when compared to the increase in numbers of detainees held in a centre. There is a reasonably strong correlation between centre size and the rate of serious incidents per 100 beds, statistically speaking. (Section 7, esp. 7.1, 7.2)

Asylum Welcome’s experience (backed by other local service providers) is that healthcare and legal advice provided in Campsfield is insufficient to meet needs even at current numbers of detainees. Our fear is that these services will not be expanded sufficient for the needs of an increased number of detainees. (Section 7.3)

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The design for the new extension to the centre indicates prison-like conditions (e.g. toilets in cells without privacy) whereas guidelines for detention centres are that they should meet a higher standard, recognizing that no criminal offence has been committed. (Section 7.5)

Asylum Welcome asks planning authorities to consider as an example the detention centre at Harmondsworth. Following its rapid expansion to accommodate over 600 detainees, inspectors raised numerous serious concerns about the quality of management, the safety and welfare of the detainees and the frequency of disturbances. It seems unlikely that Campsfield House would avoid a similar experience. (Section 7.4)

Finally, Asylum Welcome asks planning authorities to weigh the case for need against other relevant factors – the harm to the green belt, and the impact of the expansion on local people because of difficulties relating to traffic and drainage. We ask planning authorities to note the incompatibility of this planning application with the vision of the Langford Lane area Local Plan, and to note the fears and concerns that the expansion plan is generating among local residents. (Section 8)

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3 ASYLUM WELCOME

3.1 ABOUT ASYLUM WELCOME

Asylum Welcome exists for people fleeing persecution and danger in their own countries, who seek refuge in Oxford and Oxfordshire. Our volunteers, members, donors and staff, of various faiths and politics, share values based on a common humanity and social justice.

Our work is to reduce poverty, suffering and social isolation and to enable asylum seekers and refugees to live with the respect and dignity to which they are entitled. To these ends, we:

- provide advice, information and support to asylum seekers and refugees- befriend, visit and support the rights and welfare of detainees- work with other service providers and the public to meet the needs of immigration

detainees, asylum seekers and refugees.

Asylum Welcome was established in 1993 (the same year that Campsfield House became a detention centre) and became a registered charity in 1996. Asylum Welcome volunteers and paid staff have long-standing experience of immigration detention. Many volunteers have high-level expertise in detention issues from their professional lives and a number are senior academics, lawyers, social workers, NGO workers and refugees.

3.2 DETENTION EXPERTISE

Asylum Welcome tries to make contact with all new arrivals in Campsfield House and offers to meet with them for an assessment. Each detainee is offered a trained volunteer visitor who can visit him on a one-off or weekly basis. During these visits the visitor provides emotional support and a listening ear to the hardships the detainee is experiencing and has endured in the past. Our office-based volunteers provide additional practical support including:

- writing letters on the person’s behalf- following up on issues concerning effective legal representation- referring the person to independent doctors for medical advice and the production of medico-

legal reports where necessary- arranging for the person to receive phone cards and help towards essential travel costs- helping the person to get in touch with the Red Cross, who will try to find family- helping individuals get their possessions returned to them- supporting individuals to contact their MPs- liaising with solicitors

Asylum Welcome’s mission to support detainees and our long experience of doing so explain our interest in responding to the Home Office/Ministry of Justice Planning Application 14/01778/F - Expansion of existing immigration removal centre to provide additional detainee accommodation, ancillary detainee and staff facilities, car parking, landscaping and internal fencing Campsfield House Detention Centre Langford Lane Kidlington OX5 1RE (hereafter called ‘the application’).

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4 PLANNING LAW: GREEN BELT, ‘VERY SPECIAL CIRCUMSTANCES’

Campsfield House is located in Green Belt land. Due consideration should be given to the importance that the government increasingly places on preservation of green belt.1

The National Planning Policy Framework 20122 says:

" inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances".3

Construction of new buildings in Green Belt should be considered inappropriate unless they fall into one of six categories of exceptions.4 The application accepts that the proposals constitute inappropriate development, not covered by the exceptions. Therefore, it concedes, "very special circumstances" are required for the grant of planning permission.

Paragraph 88 NPPF states:

"When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations".

The Home Office and Ministry of Justice position is that the need for the expansion amount to very special circumstances that outweigh inappropriateness and harm.

1 There has been a series of Government interventions in 2014 which highlight the Governments renewed emphasis on the value attached to preserving greenbelt. This includes: i) March 2014 the Government published new web-based Planning Practice Guidance to accompany and give

further detail about the policies in the NPPF. This guidance makes clear that unmet housing need in a particular area is unlikely to meet the “very special circumstances” test to justify green belt development.

ii) On 4 October 2014 the Government announced that it had updated its online Planning Practice Guidance. The aim of this was to reaffirm local authorities’ abilities to “safeguard their local area against urban sprawl, and protect the green lungs around towns and cities”.

iii) On 16 October 2014 the Secretary of State for Communities and Local Government announced that he had “strengthened the policy on planning for waste facilities such as recycling plants making clear that companies and councils looking to build these should first look for suitable sites and areas on brownfield land.”

Source: Standard Note: SN/SC/934 Green Belt, House of Commons Library, 10 December 2014. www.parliament.uk/briefing-papers/sn00934.pdf .2 National Planning Policy Framework, Department for Communities and Local Government, March 2012. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf .3 Ibid., para 87.4 Ibid., para 89.

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http://www.parliament.uk/briefing-papers/sn00934.pdf


The application states:

“The Needs case provided by the Home Office identifies a demand for an additional 850 bed spaces within their estate. The bed spaces proposed will assist with achieving this figure. The Needs case is considered to provide very special circumstances.”5

The Home Office claims that there is a need to provide additional bed spaces to address a shortfall in accommodation resulting from enhanced enforcement activity and the desire to decrease bed spaces currently utilised in prisons, which are not considered appropriate for immigration detainees.

In the application, a primary question is whether there is a ‘Need’ at all for increased detention facilities. The Home Office asserts the ‘Needs’ case without providing any evidence. Paragraph 6.4 of the application states that:

“Modelling by the Home Office has indicated that an estate of just over 5,000 beds is required to accommodate detainees in appropriate conditions”.6

Andrew Smith MP, in a letter sent in October 2014, asked for the modelling to be supplied but no further information has been forthcoming.

Asylum Welcome believes that there is a duty upon planners to weigh the evidence of need, as set out in SSCLG and others -v- Redhill Aerodrome Limited and believes it would be an error in law for Planning Decision-Makers not to make an assessment of the evidence on ‘Need’ when coming to a decision on ‘Very Special Circumstances’.7

Even if a 'Need' to increase the detention estate was shown, Asylum Welcome believes that Decision-

5 Planning Statement, CGMS for The Home Office/Ministry of Justice, October 2014, Executive Summary, Page 4.6 Ibid, Page 21, Paragraph 6.4.7 On 24th October 2014 the Court of Appeal, in SSCLG and others -v- Redhill Aerodrome Limited gave judgment on the meaning of the words “any other harm” when interpreting Paragraph 88 of the National Planning Policy Framework 2012. The Court held that if all of the "other considerations" in favour of granting permission, which will, by definition, be non-Green Belt factors, must go into the weighing exercise, there is no sensible reason why "any other harm", whether it is Green Belt or non-Green Belt harm, should not also go into the weighing exercise. If, having carried out this balancing exercise, a decision maker or Inspector concluded that "very special circumstances" did not exist, they should refuse planning permission on the ground that the proposed development did not "comply with national policy to protect the Green Belt set out in the Framework".http://www.bailii.org/ew/cases/EWCA/Civ/2014/1386.html .So in a case where a shortfall in Housing is claimed to be 'Very Special Circumstances' there has to be assessment of that shortfall and whether the 'Need' for Housing outweighs the damage to the Green Belt and other countervailing factors, a similar weighing of available evidence needs to be made by Decision-Makers in this case, e.g. City and District Council of St Albans - v - The Queen (on the application of) Hunston Properties Limited, Secretary of State for Communities and Local Government and another. www.bailii.org/ew/cases/EWCA/Civ/2013/1610.html .

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http://www.bailii.org/ew/cases/EWCA/Civ/2014/1386.html


Makers need to weigh up all the material factors for and against the proposed expansion before deciding whether ‘Very Special Circumstances’ exist. Failure to do so, and to show reasons, we respectfully submit would be an error in law8. Asylum Welcome argues in this document, that even if the Home Office were to show ‘Need’ for an increase in detention capacity as a whole, the nature of this particular proposal for expansion, and the dangerous risks it presents, mean that the Home Office would still fail to show ‘Very Special Circumstances’. In addition there are other various ‘planning matters’ which weigh against a finding of ‘Very Special Circumstances’.

5 THE STANDARDS THAT APPLY TO IMMIGRATION DETENTION

5.1 LAWFUL AND UNLAWFUL DETENTION

Detention is deprivation of physical liberty. Everyone, whatever their immigration status, has a basic freedom from detention. In accordance with the guidelines produced by the United Nations High Commissioner for Refugees (UNHCR):

“The fundamental rights to liberty and security of person and freedom of movement are expressed in all the major international and regional human rights instruments, and are essential components of legal systems built on the rule of law. The Executive Committee of the High Commissioner’s Programme (ExCom) has addressed on a number of occasions the detention of asylum seekers. These rights apply in principle to all human beings, regardless of their immigration, refugee, asylum-seeker or other status”9.

Immigration detention is not prohibited in the UK but it must be a last resort and used sparingly.10 If it is not necessary to detain in order to achieve the purposes of either preventing a person’s unlawful entry to the UK, or, in order to remove a person from the UK, a person should not be detained.

The Home office has statutory powers to detain under paragraph 16 of Schedule 2 of the Immigration Act 1971; paragraph 2 of Schedule 3 of the Immigration Act 1971 and Section 62 of the Nationality Immigration and Asylum Act 2002 and Article 5 (1) (f) of the European Convention on Human Rights (ECHR). These general powers to detain migrants are subject to the Home Office policy and guidance11, which sets out constraints on their use and on procedures that are to be followed. The Home Office is also constrained by a general requirement in law that the exercise of the power to detain must be done in a way that is lawful, and according to a lawful process12.

8 E.g. Para 30, THE QUEEN on the application of MARK WILDIE -v- WAKEFIELD METROPOLITAN DISTRICT COUNCIL -and- MRS JACKIE AVISON. http://www.bailii.org/ew/cases/EWHC/Admin/2013/2769.html .9 UNHCR Detention Guidelines (2012), Guideline 2 §12.10 Enforcement Instructions and Guidance (EIG), Home Office, Chapter 55 (1)(3). https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/307995/Chapter55.pdf .11 Ibid., Chapter 55.12 There is extensive Court of Appeal, Supreme Court as well as Strasbourg Court case-law reflecting these principles which are enshrined on the European Convention on Human Rights.

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http://www.bailii.org/ew/cases/EWHC/Admin/2013/2769.html


Detention will be unlawful where there is no power to detain; where there is power to detain but has persisted for a period that is unreasonable in all the circumstances or it is apparent that detention will persist for such a period; where detention is contrary to the substantive requirements of published policy and where detention breaches the European Convention on Human Rights (ECHR), whether Article 5 or otherwise.

5.1.1 VULNERABLE DETAINEES AND ‘RULE 35’ REPORTS

The Home Office’s own Enforcement Instructions Guidance13 says that some people should only be detained in exceptional circumstances.

These are:

Unaccompanied children and people under the age of 18; The elderly, especially where supervision is required;

Pregnant women, especially after 24 weeks of pregnancy;

Those suffering from serious medical conditions or serious mental illness which cannot satisfactorily be managed in detention;

Those where there is independent evidence that they have been tortured (including rape);

People with serious disabilities.

If any of these circumstances apply, an IRC doctor must properly assess the situation, record it and report it to the IRC manager - this is known as a ‘Rule 35 Report’. The doctor must also report his findings to the Home Office if the doctor is concerned that the detainee may have been the victim of torture or concerned that detention may be injurious to a detainee’s health. Any Rule 35 report must be countersigned by the detainee to show that it is accurate (though they are routinely inaccurate) and that the detainee has given consent for the distribution of this confidential information. The detainee and his/her lawyer (if any) must receive a copy.

If the Home Office receives a Rule 35 report the Home Office must contact the detainee within 72 hours, either granting release from detention or giving reasons for refusal. Very few Rule 35 Reports lead to release and this has been a source of grave concern. The Home Affairs Select Committee has recently strongly criticised the way in which so few detainees are released following a Rule 35 Report14.

5.1.2 NO TIME LIMIT FOR PERIODS IN DETENTION

According to the Home Office’s own Enforcement, Instructions and Guidance, immigration detention must be for the shortest period necessary,15 although there is no fixed time limit on immigration detention. Around the UK, there are many detainees who are locked up for months or years without trial or charge. Unlike prisoners they do not know when they will be released as their detention is without

13 Enforcement Instructions and Guidance (EIG), Home Office, Chapter 55(10).14 The work of the Immigration Directorates (October–December 2013), Home Affairs Select Committee, House of Commons, July 22nd 2014, Page 31. http://www.publications.parliament.uk/pa/cm201415/cmselect/cmhaff/237/237.pdf .15 Enforcement Instructions and Guidance (EIG), Home Office, Chapter 55 (1)(3).

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time limit. Many detainees “find it hard to bear not knowing what will happen in their case”.16 Nowhere else in our society are people locked up with so few safeguards. One wonders what the purpose of such prolonged confinement is, since most migrants detained for long periods are eventually released back into the UK.

Indefinite immigration detention is a uniquely British phenomenon, at least within Europe. The EU Returns Directive17 has limited detention to a maximum period of 18 months, but many countries have much shorter limits. For instance, France has a maximum of 45 days. The UK however does not apply EU immigration law, and stands alone with no time limit on detention. This stance continues to undermine the UK’s international reputation for defending civil liberties. The UN Committee Against Torture has condemned the practice, urging the UK to “introduce a limit for immigration detention and take all necessary steps to prevent cases of de facto indefinite detention.”18

5.1.3 DETENTION OF PEOPLE WHO CANNOT BE RETURNED TO THEIR COUNTRY OF ORIGIN

The Enforcement, Instructions and Guidance state that “Detention can only lawfully be exercised under these provisions where there is a realistic prospect of removal within a reasonable period.”19

Despite this, there are a number of individuals who remain in detention for indefinite periods of time (in some cases for years) because they cannot be returned to their country of origin, for example because their country of origin refuses to recognize them and refuses them travel permits.20

5.2 CONDITIONS OF DETENTION5.2.1 RULES AND ORDERS

The Detention Centre Rules 2001 stipulate the way in which the centres are to be run, seeking to ensure minimum standards for the treatment of all detainees. Every detained person should be provided with a document, known as a 'compact', outlining their rights and responsibilities under the rules, and information about life in the centre.

The Detention Centre Rules cover such things as Welfare and Privileges. For example, a detainee's entitlement to visits from family members, agencies and legal representatives; the provision of wholesome and nutritious food and suitable clothing; time in the open air; recreational and educational activities; facilities for the practice of diverse religions; and access to healthcare.

The rules also cover General Security and Safety and state that this is to be maintained, "but with no more restriction than is required for safe custody and well-ordered community life."

16 Policy Primer, Immigration Detention: Policy Challenges, Migration Observatory, Oxford University, 2011, p.5.17 Directive 2008/115/EC of the European Parliament and of the Council of 16 December 2008 on common standards and procedures in Member States for returning illegally staying third-country nationals.http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:348:0098:0107:EN:PDF .18 Fifth periodic report of the United Kingdom (6-31 May 2013), UN Committee against Torture.19 Enforcement Instructions and Guidance (EIG), Home Office, Chapter 55(2).20 http://pointofnoreturn.eu/wp-content/uploads/2014/01/PONR_report.pdf .

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In addition Immigration Removal Centres are subject to the Detention Service Orders (DSOs). These are more detailed instructions outlining procedures to be followed by all staff in the IRCs and contractors employed on behalf of detention services, and again are intended to ensure certain minimum standards for detainees. A full list of all DSOs is available on the Home Office website.21

5.2.2 HM INSPECTORATE OF PRISONS: ‘EXPECTATIONS’

HM Inspectorate of Prisons publish ‘Expectations’, the criteria they use during their inspections to assess the treatment and conditions of those held in Immigration Removal Centres22. These state:

“The four tests of a healthy establishment are:

Safety - that detainees are held in safety and with due regard to the insecurity of their position.

Respect - that detainees are treated with respect for their human dignity and the circumstances of their detention.

Activities - that the centre encourages activities and provides facilities to preserve and promote the mental and physical well-being of detainees .

Preparation for removal and release - that detainees are able to maintain contact with family, friends, support groups, legal representatives and advisers, access information about their country of origin and be prepared for their release, transfer or removal. Detainees are able to retain or recover their property.”

“Although this was a custodial establishment, we were mindful that detainees were not held because they had been charged with a criminal offence and had not been detained through normal judicial processes. In addition to our own independent Expectations, the inspection was conducted against the background of the Detention Centre Rules 2001, the statutory instrument that applies to the running of immigration removal centres. Rule 3 sets out the purpose of centres (now immigration removal centres) as being to provide for the secure but humane accommodation of detainees:

- in a relaxed regime

- with as much freedom of movement and association as possible consistent with maintaining a safe and secure environment

- to encourage and assist detainees to make the most productive use of their time

21 https://www.gov.uk/government/collections/detention-service-orders .22 Criteria for assessing the conditions for and treatment of immigration detainees Version 3, Her Majesty’s Inspectorate of Prisons, 2012. http://www.justiceinspectorates.gov.uk/prisons/wp-content/uploads/sites/4/2014/02/immigration-expectations.pdf .

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https://www.gov.uk/government/collections/detention-service-orders


- respecting in particular their dignity and the right to individual expression.

The statutory instrument also states that due recognition will be given at Immigration Removal Centres to the need for awareness of:

- the particular anxieties to which detainees may be subject and

- the sensitivity that this will require, especially when handling issues of cultural diversity.”

(Emphasis added)

Asylum Welcome expects the standards applied by HM Inspectorate of Prisons to be observed at all times.

6 NO ‘NEED’ FOR INCREASED DETENTION CAPACITY

6.1 NUMBER OF DETENTION SPACES AVAILABLE

The UK’s use of detention has been steadily increasing as the Home Office official statistics table below shows. This is contrary to trends elsewhere in Europe.23

People entering, leaving and in detention, solely under Immigration Act powers

Year Entering detention Leaving detention In detention (1)Year ending September 2011 26,363 26,323 2,909Year ending September 2012 28,702 28,479 3,091Year ending September 2013 30,384 30,102 3,115Year ending September 2014 29,492 29,151 3,378Change: latest 12 months -892 -951 +263Percentage change -3% -3% +8%

(1) The ‘in detention’ figures are as at the end of September in each year.

Nevertheless there appears to be more than adequate capacity. The Home Office application at paragraph 3.12 gives the current capacity of the Immigration Estate, taking into account the newly opened IRC facility at HMP Verne with a capacity of 580. The estate has a total current capacity of 4,270. This comprises 3,690 long term male beds, 345 long term female beds, 102 family rooms and 133 short term beds. This represents an increase of 1600 beds since 2010. The Home Office also has a Service Level Agreement with the National Offender Management Service (NOMS) in 2012 to allow for 1,000 prison bed spaces to be used for immigration detention purposes. In fact 23 http://www.globaldetentionproject.org/countries/europe.html .

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according to the Home Office statistics as at 29 September 2014 there were only 425 detainees held in prison establishments. This means that the total capacity for detention under immigration regulations is already approximately 5,270. Even allowing for increased transfer to IRCs of the current 425 FNO’s in immigration detention in prisons (having completed their prison sentences), there would appear to be more than adequate capacity in the detention estate.

At paragraph 3.17 of the application it says:

“There is a particular need for accommodation suitable for longer stays for men. There are currently 162 men who have been in detention for over 6 months. This reflects the increased complexities of removal for some cases (including former FNOs) in terms of securing travel documents and cooperation from home authorities”. 24

Again the Home Office’s own official statistics largely refute this (see table below) and further below we deal with the very recent findings of the Independent Chief Inspector of Borders and Immigration in his Inspection of Emergency Travel Documents (ETDs) which identified that:

“several thousand of these documents had already been agreed by embassies, with some dating back more than ten years, but had not been used by the Home Office to remove the individuals concerned”25

He concluded:

“This demonstrates that there is room for significant improvement in this important area of enforcement.”26

Numbers and % of Detainees Leaving Detention by Period in Detention

Year Ending

0 to 7 days

8 to 28 days

29 days to 2 months

2 to 4 months

4 months to 1 year

1 to 2 years

2+ years

Total

Sep 2014 10,820 7,345 5,105 3,932 1,775 144 30 29,151Dec 2013 10,610 7,934 5,628 3,988 1,627 199 50 30,036

0 to 29 daysDec 2012 18,804 4,782 3,046 1,584 255 67 28,538

It is true that between the year ending December 2012 and the year ending December 2013 the numbers of detainees staying between 29 days and 4 months did increase significantly, but the numbers staying more than 4 months actually decreased. Moreover comparing the two most recent statistical periods, the changes in length of stay have generally been downward – the increase of 148 detainees staying between 4 months to 1 year being more than set off by decreases in the other categories of stay of more than 29 days, including sharp drops in very long stays of more than a year.

24 Planning Statement, CGMS for The Home Office/Ministry of Justice, October 2014, Page 9, Paragraph 3.17.25 Annual Report for the period 1 November 2013 - 31 October 2014, Independent Chief Inspector of Borders and Immigration, December 2014, Page 7. http://icinspector.independent.gov.uk/wp-content/uploads/2014/12/ICI-Annual-report-2013-14-FINAL-web.pdf .26 Ibid.

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6.2 LONG TERM TREND: MORE VOLUNTARY RETURNS, FEWER ENFORCED REMOVALS

The graph below, reproduced from the official Home Office immigration statistics for July to September 2014, clearly shows the continuing long-term trend of declining need for enforced removals and the rise in ‘voluntary departures’, in the case of migrants who have no lawful basis to remain in the UK. According to the Official Statistics for July to September 2014 there were 9% fewer enforced removals from the UK (12.461) compared with the previous 12 months (13,740). This is relevant because a justification for detention is to facilitate enforced removal.

(1) Recent figures for Total Voluntary Departures are particularly subject to upward revision due to the nature of the data-matching.

6.3 UNNECESSARY CASES OF DETENTION

As discussed at Section 5.1 detention is only lawful according to the Government’s own Guidance if used as a last resort and used sparingly.27 There are many alternatives to detention where the Home Office is concerned about absconding – e.g. regular reporting, sureties, electronic tagging.

Asylum Welcome’s experience is that there are many people in Campsfield House, as in all IRCs, who do not need to be detained and many who may not be lawfully detained who are subsequently released on application to a Judge of the First Tier Tribunal (Asylum and Immigration Chamber), either on Bail or on Temporary Admission by the Home Office prior to the hearing. The most recent Home Office

27 Enforcement Instructions and Guidance, Home Office, Chapter 55 (1)(3).

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Immigration Statistics, July to September 2014, show that for the year ending September 2014, of the 29,151 detainees leaving detention in that year, 45% were released or obtained Bail. To Asylum Welcome this suggests that many of these 13, 000 people may never have needed to be in detention. In addition there are those people who were removed, where they should not have been detained due to low risk of absconding, health conditions or experience of torture.

We visit many detainees already in Campsfield House who have fled persecution in their home countries, have experienced torture (with medical evidence to support this), or who have serious mental and physical health conditions which cannot be adequately managed, contrary to Rule 35 of the Detention Centre Rules 2001.28 The Home Affairs Select Committee Report The Work of the Immigration Directorates (October – December 2013) expressed concern at:

“the small number of Rule 35 Reports which lead to a detainee being released – 9%”.29

This figure has not improved since.

Matrix Evidence undertook an economic analysis of alternatives to long-term detention and produced a Final Report in September 2012.30 They concluded as follows:

“The UKBA currently carries out a risk assessment of ex-offenders prior to the decision to detain. The scope of this risk assessment could be extended in order to identify those individuals who cannot be deported within a reasonable and lawful period of detention, and who will, therefore, eventually be released back into the community. Early identification and timely release of these individuals would save the cost of their protracted and fruitless detention. This more efficient use of detention space would mean that the same numbers of removals could be achieved using a reduced number of detention spaces.

The analysis summarised in this report estimates that an improved risk assessment could result in cost savings of £377.4 million over a 5-year time period. This estimate comprises:

- £344.8 million in detention cost savings over 5 years.- £37.5 million in avoided unlawful detention payments over 5 years.

- Minus £5.0 million in the extra cost of Section 4 support, including housing and living costs, for the additional time that migrants spend in the community.

28 Detention Centre Rules 2001. http://www.legislation.gov.uk/uksi/2001/238/contents/made#35 .29 The work of the Immigration Directorates (October–December 2013), Home Affairs Select Committee, House of Commons, July 22nd 2014, Page 31. http://www.publications.parliament.uk/pa/cm201415/cmselect/cmhaff/237/237.pdf .30 An economic analysis of alternatives to long-term detention Final Report, Matrix Evidence, September 2012, Pages 4-5.http://detentionaction.org.uk/wordpress/wp-content/uploads/2011/10/Matrix-Detention-Action-Economic-Analysis-0912.pdf .

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http://detentionaction.org.uk/wordpress/wp-content/uploads/2011/10/Matrix-Detention-Action-Economic-Analysis-0912.pdf

http://detentionaction.org.uk/wordpress/wp-content/uploads/2011/10/Matrix-Detention-Action-Economic-Analysis-0912.pdf



http://www.legislation.gov.uk/uksi/2001/238/contents/made#35


When analysing the savings over time, it is estimated that improved risk assessment could result in cost savings of £71.5 million, £81.2 million, £78.1 million, £74.9 million, and £71.6 million in each of the next 5 years, respectively. This amounts to average savings of £75.5 million per year, which could result in cost savings of £377.4 million over a 5 year time period. To contextualise these savings, it costs roughly £20 million per year to run a detention centre (UKBA, 2011b, Home Office, 2011b). Based on these costs, the analysis indicates that, by providing timely release for migrants, the UKBA could save the equivalent of the cost of running at least three detention centres over the next 5 years.

A proportion of the expected savings could be reinvested in more intensive community-based support, which can be expected to generate increased rates of case resolution and voluntary return. For example, in Australia, migrants who would in the past have been detained are provided with case management support to resolve their immigration cases. The evidence from Australia suggests that case management is effective in increasing uptake of voluntary return. Currently in the UK, interventions are being piloted that replicate elements of Australian case management, although they have not been used as alternatives to detention. The analysis suggests that providing case management in the UK to all the migrants who would be released promptly in the above analysis would cost around £164.2 million, about 44 per cent of the savings made as a result of avoided detention. However, as voluntary returns are far cheaper than enforced removals, this could lead to further savings as well as increased overall numbers of returns.”31

Asylum Welcome believes that the Matrix Evidence Report adds to the compelling evidence of a need to review and reduce the use of immigration detention in the UK.

6.4 TACKLING SYSTEMIC INEFFICIENCY WOULD REDUCE THE NEED FOR DETENTION

Nicola Blackwood observes in her objection to the application:

“‘efficiency’ in the immigration system will not be achieved by increasing the number of detention spaces but rather by speeding up decision making on immigration and asylum applications and by improving the quality of those decisions so that they are not overturned on appeal, leading to lengthy delay and litigation.”

“The solution, however, is emphatically not to perpetuate this problem by simply expanding the detention estate to allow for more failure within the Immigration Directorate.”

Asylum Welcome agrees and notes that the recent report on the Immigration Directorate by the Home Affairs Select Committee published on 22 July 2014, found that the Home Office have ample room for improvement where it comes to speeding up and improving the quality of decision making.

One good example of a way to free-up spaces in the detention estate is to process requests for Bail Accommodation. Bail for Immigration Detainees recently carried out research which concluded:

31 Ibid.,

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“Inability to get a Home Office Section 4 (1)(c ) bail address in a timely fashion is a major factor behind some of the very lengthy periods of immigration detention endured by detainees in the UK. Having to wait weeks or months to apply for a bail address before an application for release can be lodged adds to the length of time spent in detention. This research carried out by BID during 2014 has found evidence of systemic and significant delay at every stage of the application process for Section 4 (1)(c ) bail accommodation.”32

Many further systemic inefficiencies were recently confirmed in the latest Independent Chief Inspector of Borders and Immigration Annual Report for the period 1 November 2013 - 31 October 201433.

“I still find too much evidence that the Home Office does not get the basics right. This includes the quality and consistency of decision making but also having caseworkers with the right skills, aligning resources to the right priorities and having high quality management information that provides a sound basis on which to make decisions on future strategy and resourcing.”34

“Finally, there is an ongoing need for the Home Office to maintain management grip of the quality, consistency and fairness of its work. I have repeatedly had to report on the lack of quality assurance by managers across the board and I have identified a number of backlogs of work that senior officials had not been aware of. Going forward, there needs to be improved strategic cohesion between the directorates within the Home Office in delivering a seamless immigration function, coupled with better management oversight and assurance processes to provide Ministers with confidence that policy is being delivered effectively and that guidance is being followed by staff.”35

“Some years ago I was critical of the then UK Border Agency for publicly accepting some of my recommendations in principle but showing little enthusiasm to take action to implemented them. I still have some concerns in this area and I often have to repeat recommendations made in previous reports that have been accepted by the Home Office but which do not appear to have been implemented. This has included recommendations on change management, record keeping and the analysis of appeal outcomes. It can be both frustrating and disappointing, when I encounter the same issues over and over again. It is a particular concern when the Home Office fails to take action where I make recommendations that relate to the treatment of individuals and the efficiency of the decision making or removal process. For example, I have made repeat recommendations on the detention of immigration offenders in my 2011 report on Foreign National Offenders, my 2012 report on Detained Immigration Casework and my 2014 report on Emergency Travel Documents.”36

32 No Place to Go: Delays in Home Office Provision of Section 4(1)(C) Bail Accommodation, Bail for Immigration Detainees, September 2014, Page 5. http://www.biduk.org/980/news/new-bid-report-on-bail-address-delays-no-place-to-go-delays-in-home-office-provision-of-section-41c-bail-accommodation.html .33 Annual Report for the period 1 November 2013 - 31 October 2014, Independent Chief Inspector of Borders and Immigration, December 2014. http://icinspector.independent.gov.uk/wp-content/uploads/2014/12/ICI-Annual-report-2013-14-FINAL-web.pdf .34 Ibid., Page 6.35 Ibid., Page 7. 36 Ibid.,Page 9.

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http://www.biduk.org/980/news/new-bid-report-on-bail-address-delays-no-place-to-go-delays-in-home-office-provision-of-section-41c-bail-accommodation.html

http://www.biduk.org/980/news/new-bid-report-on-bail-address-delays-no-place-to-go-delays-in-home-office-provision-of-section-41c-bail-accommodation.html


“In certain circumstances, Home Office enforcement officers investigating immigration offences can enter business premises and make arrests without the need for a search warrant. My inspection therefore focused on whether the power was being exercised appropriately, in accordance with the law and Home Office guidance. I found that in almost two-thirds of the cases I examined, I disagreed with the decision made by an Assistant Director to authorise the use of this power. This was because of weak justifications or because the need for swift action was not supported by the evidence. I also found six cases where the power appeared to have been used unlawfully, primarily because either the authorising officer was not at the appropriate grade or the power was not used within the time-frame set out in the legislation.”37

“I was concerned to find that the Home Office did not have a strategy in place that linked ETD applications to removals performance. Too many applications were being made that had little prospect of being agreed. Management information on the ETD process was inadequate and did not give an accurate picture of performance.

Several thousand ETD applications had been agreed by embassies, but the Home Office had not used the documents. Some of these agreements dated back more than ten years. Many of these cases were not being actively progressed, leaving individuals’ immigration status unresolved.

While the Home Office complains that noncompliance with the ETD process by individuals is a major source of delay, it did not have a clear picture of the scale of the problem, other than for criminal cases, nor an effective strategy for tackling it.

Too often the Home Office’s default approach, particularly in the case of ex-Foreign National

Offenders, was to keep the individuals in detention in the hope that they would eventually comply with the ETD process. This was particularly disappointing given recommendations I had made on this issue in a number of previous reports. Given the legal requirement only to detain individuals where there is a realistic prospect of removal, this is potentially a breach of their human rights. It is also extremely costly for the taxpayer.”38

(emphasis added)

Asylum Welcome believes that the Chief Inspector’s findings need urgent remedial action by Government.

37 Ibid., Page 17.38 Ibid., Page 18.

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6.5 ALL PARTY PARLIAMENTARY GROUP INQUIRY INTO DETENTION

A Parliamentary Enquiry into Detention is currently on-going. Asylum Welcome contributed to this enquiry and we believe the enquiry could make wide-ranging recommendations which have consequences for the size of the detention estate needed.

7 CONCERNS ABOUT EXPANSION AT CAMPSFIELD HOUSE

As already argued Asylum Welcome, along with many others from across the political spectrum, do not believe there is a ‘Need’ to increase capacity in the Detention Estate. However, if the Government is going to increase capacity, then the proposal to expand capacity at Campsfield is dangerously flawed.

7.1 INCREASED RISK OF SERIOUS INCIDENTS

The proposed development will make Campsfield House one of Europe’s largest detention centres, by more than doubling the size of the current centre.

As a charity working with asylum seekers and detainees our paramount concern is the welfare of the people we work with, who have often experienced traumatic events and are particularly vulnerable. Detention makes anyone vulnerable, by its very nature, although there are also certain groups – including torture victims – who are already very vulnerable. In this sense Asylum Welcome’s primary concern about expansion, design and conditions at the proposed IRC at Campsfield House relates to the impact on our client-group.

While we very much hope this will be of equal concern to Planning Decision Makers we are mindful that they will be thinking also about people outside, especially in the vicinity of Campsfield House. Of course incidents at Campsfield House which affect detainees the most, will also impact on local residents in the form of increased traffic around the centre, disturbance, loss of amenity and associated publicity.

HM Inspectorate of Prisons inspected Campsfield House in the summer of 2014, but the report is not yet available. The last previous HM Inspectorate of Prisons report was conducted in May 2011 when GEO Group were contracted by the Home Office to run Campsfield House. The report concluded that conditions were reasonable although commented on the uncertain future facing the centre being a cause for concern. However since then there have been a number of serious incidents, including a large fire, alleged assaults of detainees, self-harm, suicide attempts, deaths and hunger-strikes.

There is much secrecy shrouding incidents and conditions at IRCs. Even Members of Parliament asking Parliamentary Questions about the details of specific incidents are often met with bland responses or an array of standard reasons for not providing the information. On a number of previous occasions

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Members of Parliament have sought and been given assurances by then Government Ministers that Campsfield House would be closed as an Immigration Removal Centre.

The reasons for Asylum Welcome’s concern at the proposals for expansion at Campsfield House can be conveniently grouped into four headings:

1) The data showing a correlation between size of IRC and a disproportionate increase in the rate of serious incidents

2) Those arising from our daily experience of visiting detainees in Campsfield House in recent times

3) The alarming parallels with the terrible situation that has developed at Harmondsworth following expansion in a way that is very similar to the proposed expansion at Campsfield House.

4) The design of proposed expansion at Campsfield House

7.2 DATA ON SIZE AND DISPROPORTIONATE INCREASE IN SERIOUS INCIDENTS

From a Parliamentary Answer given in July 2014 by Karen Bradley, then Minister of State at the Home Office, we can compare size of IRC and ‘Red and Amber Incidents’.39 Red Incidents are generally those relating to serious disturbances and/or fires within a centre. Amber Incidents may be those involving threats to the centre, external demonstrations, or co-ordinated food or fluid refusal.

Large Scale Incidents correlated with Capacity by IRCSerious Incidents (Red and Amber)(For period 1 July 2013 to 9 March 2014) 1

IRC Date of Capacity Capacity Red Amber Total Total Incidents Total Incidentslast HMIP at last at Incident Incident Incidents per 100 Beds per 100 BedsInspection2 HMIP September (based on capacity (based on capacity

Inspection2 20143 at last Inspection) at Sep 2014)

Haslar Feb-14 170 197 0 2 2 1.2 1.0Dover Mar-14 280 401 1 39 40 14.3 10.0Harmondsworth Aug-13 615 661 0 145 145 23.6 21.9Yarl's Wood Jun-13 406 372 1 109 110 27.1 29.6Brook House May-13 448 448 2 59 61 13.6 13.6Morton Hall Mar-13 392 392 6 29 35 8.9 8.9Colnbrook Feb-13 420 408 4 109 113 26.9 27.7Tinsley House Dec-12 154 153 0 17 17 11.0 11.1Dungavel House Aug-12 217 249 0 3 3 1.4 1.2Campsfield House May-11 216 276 1 14 15 6.9 5.4

1 Source: Hansard 14th July 20142 Last Inspection for which HMIP report available (data from Inspection Report)3 Home Offi ce figures

39 Parliamentary Question by Andy Sawford MP, answered by Karen Bradley, Minister for Modern Slavery and Organised Crime, based in the Home Office, Hansard: House of Commons 14 July 2014 : Column 500W. Full Question and Answer at Appendix 2.

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The 3 best performing IRCs in terms of fewest incidents per 100 detainees are all smaller IRCs with under 300 residents which includes Campsfield House. The 3 worst performing IRCs in terms of greatest number of incidents per 100 detainees are all larger IRCs with capacity of over 400. The difference between the best and the worst IRCs in terms of incidents per 100 detainees is a multiple of more than 20.

We have plotted the above figures using Excel and reproduced the graphs below which show a reasonably strong correlation between size of IRC and the Serious Incident Rate (i.e. number of Incidents per 100 beds). Excel calculates a ‘Correlation Co-efficient’ which is included in the graphs. A Correlation Co-efficient figure of 0 would represent no correlation, a figure of 1 perfect correlation.

Graph 1Serious Incident Rate plotted against size of IRC (each point represents a particular IRC)X Axis: IRC Capacity at last HMIP InspectionY Axis: Rate of Serious Incidents (Serious Incidents per 100 beds), 1 July 2013 to 9 March 2014Excel Correlation Coefficient 0.73

Graph 2Serious Incident Rate plotted against size of IRC (each point represents a particular IRC)X Axis: IRC Capacity at September 2014Y Axis: Rate of Serious Incidents (Serious Incidents per 100 beds), 1 July 2013 to 9 March 2014Excel Correlation Coefficient 0.57

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Although we are not aware of any analysis by the Home Office regarding size, conditions and incidents, based on talking to other visitor groups and AVID40, and research conducted by Asylum Welcome volunteers in academic posts, size would seem to be a reasonably strong factor in determining the rate and level of serious incidents.

Campsfield House has been beset with ‘incidents’ since it opened, and yet is still a ‘better’ centre, with a far lower rate of problems than the bigger centres. The risk is that expanding it will mean a far, far greater number of incidents. Again – this puts people at much greater risk inside and outside the centre.

Bigger population size means that detention custody officers and Home Office/MITIE managers cannot know everyone in their care, with implications for the type of regime employed. At Campsfield House currently it is possible for the manager to walk around the centre and know the people in her/his care, to know when someone is off colour and to talk to them and see what is going on. A manager at a smaller IRC can strive to build decent relationships with the detainees, so that if there are any incidents, they can draw on those to resolve things quickly and peacefully. As a previous manager of Campsfield House told an academic researcher and volunteer at Asylum Welcome, “I could say to them ‘look guys, I’ve always been good with you, we’ve shared tea. Work with me here.’” She wouldn’t have been able to do that with a centre with twice as many people. In addition, Asylum Welcome talks to detainees and staff who tell us that the men in a large centre are more likely to be strangers with each other and to be afraid. Small and intimate set ups work better. Dungavel is a good example.

40 AVID is the Association of Visitors to Immigration Detainees, it is the membership network for all volunteer visitors to immigration removal centres.

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7.3 CONCERNS BASED ON ASYLUM WELCOME’S DAY TO DAY EXPERIENCE7.3.1 HEALTH CARE

There is a need for specialised healthcare. Within the application proposal there is no provision for further special and prompt medical, mental and physical care, for instance for torture survivors. So far the treatment of torture survivors in Campsfield House has been remiss and inadequate. There is no separated regime for asylum seekers, who are already traumatised and often need specialist health care. Asylum Welcome is worried about the impact of expansion on the already heavily criticised health services.

The issue of mental health is vitally important. It is often the case that persons detained for prolonged periods of time, who suffer from a mental disorder, are more susceptible to feelings of anxiety, inferiority and powerlessness.41 These persons will often need the support and care of Asylum Welcome visitors.

Asylum Welcome is concerned that lack of suitable medical care is a potential breach of Article 3 of the European Convention on Human Rights for failing to provide adequate mental health care or adequate conditions of detention with regard to the detainee’s level of disability (including mental), more so should the expansion go ahead. This situation would amount to inhuman or degrading treatment and be contrary to the UK’s obligations under Article 3 ECHR. The assessment of the level of suffering and whether it exceeded the threshold of severity of Article 3 ECHR must take into account the person’s vulnerability and their potential lack of capacity to effectively complain about their situation. There have been several cases in the last 3 years where British courts have found detention to be in breach of detainee’s Article 3 rights because of the impact on their health. It is worth mentioning that the recent fire at Campsfield House was started by a detainee with mental health problems and, speaking to eye witnesses, we believe the recent alleged assault at Campsfield was sparked when one detainee had an epileptic fit, leading to another detainee shouting at officers for detaining someone with serious health problems, which led to escalation and segregation. People with serious health problems are detained, not just in “exceptional circumstances”, which, as well as being bad for the individuals concerned, also stresses and worries others detained, and can raise tensions and therefore lead to ‘incidents’.

41 Coffey, G., I. Kaplan, R. Sampson & M. Montagna-Tucci (2010). 'The meaning and mental health consequences of long-term immigraiton detention for people seeking asylum', Social Science and Medicine, 70, 2070-2079.Gatwick Detainees Welfare Group (2012). ‘A prison in the mind’: the mental health implications of detention in Brook House Immigration Removal Centre. London: GDWG.McGinley, A. & A. Trude (2012). Positive duty of care? The mental health crisis in immigration detention. A briefing paper by the Mental Health in Immigration Detention Project. AVID and BID.Pourgourides, C., Sashidharan, S. & Bracken, P., (1996) A Second Exile: The Mental Health Implications of Detention of Asylum Seekers in the United Kingdom, Birmingham: Northern Birmingham Mental Health Trust.Robjant, K., I. Robbins & V. Senior (2009). 'Psychological Distress Amongst Immigration Detainees: a Cross-sectional Questionnaire Study', British Journal of Clinical Psychology, 48(3), 275-286.Siva, N. (2013). 'Time in detention', The Lancet, 381(9860), 15 - 16.Steel, Z., S. Momartin, D. Silove, M. Coello, J. Aroche & K. Wei Tay (2011). 'Two year psychosocial and mental health outcomes for refugees subjected to restrictive or supportive immigration policies', Social Science and Medicine, 72, 1149-1156.Zimmerman, S.E., D. Chatty & M.L. Nørredam (2012). 'Health needs and access to care in immigration detention: perceptions of former detainees', International Journal of Migration, Health and Social Care, 8(4), 180 - 185.

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7.3.2 ACCESS TO LEGAL REPRESENTATIVES

The current provision of legal services within Campsfield House, based on a rota of three law firms which visit Campsfield House on a weekly basis, is not satisfactory access to justice. It is often the case that detainees have to wait two weeks or more to be seen by a solicitor for a few minutes in the hope of having their case taken up, during which time they may be transferred to another centre or removed from the UK. Detainees tell Asylum Welcome that the quality of legal service offered is currently variable and the problems often cited in HM Inspectorate of Prisons reports on IRCs are reflected in complaints by detainees. Asylum Welcome frequently gets the impression that the existing firms are over-stretched and rarely spend 30 minutes with detainees in their surgeries as detainees are entitled to. If the proposed expansion goes ahead it seems likely that access to justice will continue to be hindered with longer queues, marginalisation and little hope of improvement.

7.3.3 PASTORAL CARE PROVIDED BY WELFARE OFFICE WITH ASYLUM WELCOME

Asylum Welcome visitors to Campsfield House have found that many if not most detainees suffer from the symptoms of depression or other mental health problems, even if they do not have a clinical diagnosis of these conditions. Most commonly detainees tend to have difficulty concentrating, sleeping problems and low mood. Visitors encourage them to use the gym or stay busy in other ways but many can't quite get out of bed to go to the gym. It seems that the fact of being detained is what causes these symptoms. Often detainees are astonished to be locked up when they have committed no crime and have only come here for safety, for education or been settled in the UK for years. They tend to be hugely disillusioned with Britain, which was previously a country of hope, opportunities and new beginnings and which many risked their lives to get to.

Because of these mental health symptoms, it is very important to have the support of Asylum Welcome visitors and the Campsfield House Welfare Office, who can provide a listening ear and a 'believing' ear. Where the Home Office often approaches asylum seekers with disbelief, Asylum Welcome approaches them with kindness, willingness to listen and to help. Similarly the Campsfield House Welfare Office tries to help detainees with practical issues such as getting their belongings and other issues. This is crucially important. Detainees have lost everything, even their imagined future. They have no idea how long they will be detained, whether two days of two years, and they have no idea whether they will be released in Britain or sent back to their home countries from which they escaped. Many have no friends of families that visit them. They are totally alone. So a visitor from Asylum Welcome can be a hugely important person in that situation.

Over the years Asylum Welcome and the Campsfield House Welfare Office have created a very positive partnership, referring to each other and working together to support detainees with their needs. This joint pastoral care is key to the well-being of detainees; they feel there are people who are supportive and kind. It is also crucial for Campsfield House staff in general as they want to make sure the centre is calm. If, with the proposed expansion, there were to be a significant increase in numbers of detainees in Campsfield House, neither the Welfare staff nor Asylum Welcome visitors could provide the same quality of service as at present. As a result, detainees would suffer; it would adversely affect the already precarious mental health of detainees.

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“The fire in October 2013 was caused by a detainee suffering from poor mental health, which several studies have shown is exacerbated by immigration detention.”42

7.3.4 INDEPENDENT MONITORING BOARD CONCERNS 2013

The latest available Independent Monitoring Board report covers 1st January to 31st December 2013 and was written after the fire at Campsfield House on 18th October 2013 43. A number of outstanding concerns were raised as follows:

The poor design of Campsfield House is highlighted:

“Campsfield House Immigration Removal Centre (IRC), located near the large village of Kidlington in North Oxford, was acquired by the Immigration Service (IS), now the Immigration Enforcement (IE) in 1993. The facility had been a Young Offender’s Institution; the building is far from ideal and lacking in space. Parts of the Centre were built as the Officer mess for RAF Kidlington.”44

The Independent Monitoring Board says that even at the current size of Campsfield it is hard for them to maintain an effective standard of work. The IMB is already understaffed and struggling to recruit. They can’t currently manage providing independent oversight of a bigger centre. This has major implications for accountability, oversight and safety:

“The Board has experienced difficulties maintaining the standard of working due to the reduction in numbers. We have recruited 2 new members who are now independent members and have 3 more who are awaiting their clearances before coming into the Centre. We will still have to recruit more members to maintain the monitoring standards of care and will initiate a recruitment campaign in the New Year.”45

Continued lack of progress against Independent Monitoring Board recommendations from the Independent Monitoring Board 2012 Report is also detailed in respect of the following issues:

1) A minimum of 3 days notice for removal from the centre for any reason be given. (reword this sentence maybe?)

2) Complaints allocated to CSU’s other than the IRC and to Tascor left much to be desired in the way they were handled.46

The Independent Monitoring Board also criticized the showers and toilet areas (in Yellow Block) for frequent water leaks into the ground floor of the Centre and the current system of welfare and support (calling for a formal detainee support scheme with training from Samaritans to a comparable standard as HMPS ‘listener’ scheme ).47

42 See footnote 41.43Campsfield House Immigration Removal Centre Annual Report For 2013, Independent Monitoring Board.http://www.justice.gov.uk/downloads/publications/corporate-reports/imb/annual-reports-2013/campsfield-house-2013.pdf .44 Ibid., Page 7, Section 3.1.45 Ibid., Page 13, Section 4.14.46 Ibid., Pages 14-15, Section 4.16.47 Ibid., Page 16, Section 5.1.

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http://www.justice.gov.uk/downloads/publications/corporate-reports/imb/annual-reports-2013/campsfield-house-2013.pdf

http://www.justice.gov.uk/downloads/publications/corporate-reports/imb/annual-reports-2013/campsfield-house-2013.pdf


Asylum Welcome shared the concerns raised by the IMB at the time of their report.

7.4 HARMONDSWORTH - A WARNING OF WHAT’S TO COME

There are alarming parallels between what is proposed at Campsfield House and what has happened at Harmondsworth. Expansion at Harmondsworth was very similar to that proposed at Campsfield House.

IRC Harmondsworth opened as a purpose-built facility in September 2000. In 2006, following a second major disturbance, two of the four original residential units were out of commission pending a substantial rebuild, reducing the operational capacity to 259. The GEO Group became the operating contractor in June 2009. In August 2010, five new residential house blocks, built to category B prison specifications, were officially opened, increasing operational capacity to 615.48

Harmondsworth currently comprises the following residential units: Cedar House and Dove House are the remaining residential units from the original building, housing 143 and 100 residents, respectively. Ash, Beech, Gorse and Fir Houses are new units, opened in August 2010, holding approximately 90 residents each. Elm House is a six-cell unit certified to hold residents removed from association and temporarily confined.49

At Harmondsworth expansion has led to a serious deterioration of conditions, an escalation in serious incidents, and very serious concerns about safety expressed by HM Inspectorate of Prisons.

We note that on the basis of relative success in managing Campsfield House, GEO Group obtained the contract to manage Harmondsworth, with the Campsfield House Manager transferring there. Despite this experienced and well liked manager, GEO Group were not able to replicate their ‘success’ with Campsfield House at the much larger expanded Harmondsworth. The contract was lost to MITIE.

We think it is worth listing here some of the concerns raised in the introduction to the report by the Chief Inspector of Prisons, Nick Hardwick, and which entirely dominate the introduction50:

“When we last inspected Harmondsworth we found an IRC that was working hard to sustain improvements after the opening of a significant amount of new accommodation. This report is more mixed. The evidence suggested to us that improvement had slowed and that some outcomes had clearly deteriorated, notably in safety. A major concern is an inadequate focus on the needs of the most vulnerable detainees, including elderly and sick men, those at risk of self-harm through food refusal, and other people whose physical or mental health conditions made them potentially unfit for detention.”

“the way detainees were received into the centre was in many respects poor. Detainees were kept in vehicles waiting to disembark, sometimes for hours, and reception procedures were completely inadequate. Detainees reported negatively about their initial experiences and too few felt safe over their first night”

48 Report on an unannounced inspection of Harmondsworth Immigration Removal Centre (5–16 August 2013) by HM Chief Inspector of Prisons, HMIP, Page 7. http://www.justiceinspectorates.gov.uk/prisons/wp-content/uploads/sites/4/2014/03/harmondsworth-2014.pdf49 Ibid.50 Ibid., Pages 5-6.

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http://www.justiceinspectorates.gov.uk/prisons/wp-content/uploads/sites/4/2014/03/harmondsworth-2014.pdf


“There had been an increase in the number of self-harm incidents since our last inspection”

“a significant number of detainees who were refusing to accept food, although we were concerned that immigration enforcement requirements were interfering with the contractor’s attempts to focus on the care needs of some very sick and vulnerable individuals.”

“The centre was now holding fewer ex-prisoners but a number of security procedures lacked proportionality. Separation was being used excessively and was not in line with the Detention Centre Rules. Disturbingly, a lack of intelligent individual risk assessment had meant that most detainees were handcuffed on escort and on at least two occasions, elderly, vulnerable and incapacitated detainees, one of whom was terminally ill, were needlessly handcuffed in an excessive and unacceptable manner. These men were so ill that one died shortly after his handcuffs were removed and the other, an 84 year-old-man, died while still in restraints. These are shocking cases where a sense of humanity was lost.”

“The number of legal advice surgeries had increased but fewer detainees than we typically see had a lawyer. The role of peer supporters needed to be better regulated: we found evidence that some were filling the gap in legal support by providing advice about bail applications and other issues, something they were neither trained nor competent to do. The contact management team that interfaced between detainees and enforcement case workers was stretched and not fully meeting need, and the Rule 35 procedure that identified victims of torture and others with special conditions, was failing, as we often see, to safeguard possible victims.”

“The centre environment was divided between two older wings and newer accommodation that was prison-like in character. Some rooms were overcrowded and much of the centre was dirty and bleak. Engagement between detainees and staff was just adequate and too many staff seemed confined to their offices. In our survey too few detainees felt respected. Structures to support and encourage equality and diversity were not effective and poorly promoted,”

“significant gaps in health care remained and we were concerned that the continuing uncertainty and disruption likely with the imminent change of health provider meant there was significant risk and potential for deterioration in this service. The clinical management of substance misuse was, in our view, unsafe.”

Paid work places were mundane and participation in education remained low. Attendance, punctuality and access was constantly undermined by needless security and control impediments which served little discernible purpose. There was little that was formal or meaningfully accredited about learning provision.

“[during removals] more could have been done to reduce the potential for conflict escalation during what is a tense and stressful moment in the deportation process.”

“It was hard to dispel the feeling that Harmondsworth was in a state of drift.”

(Emphasis added)

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Asylum Welcome believes these findings by the Chief Inspector of Prisons offer a disturbing precedent for the proposed expansion at Campsfield House.

7.5 DESIGN OF PROPOSED EXPANSION AT CAMPSFIELD HOUSE

The Home Office state:

“Due to matters of security for Campsfield House the drawings submitted do not show the detailed floor layout of the proposed development but do identify the various uses by area within the proposed building.”51

We find this incongruent with the provision of a more detailed Ground Floor Plan of the existing facility which leads us to wonder what material information the Home Office is withholding and why.

Nicola Blackwood MP and the Independent Monitoring Board have raised a number of serious design concerns, and we assume they are privy to information we have not seen and which is not included in the application. Some of the main concerns arise from the fact that all living accommodation in the proposed expansion is designed for two person occupancy with a toilet in the room, behind a small screen or curtain. This raises a number of issues:

- Privacy and dignity of people who may be from very different cultural backgrounds.- Inclusion of toilets in rooms as small as 8.9 m2 could result in unpleasant smells and lack of

hygiene, contrary to Rule 15(2).

- A similar design, with toilets in the rooms, at Harmondsworth, meant that the rooms could be ‘locked down’ at night, enabling the contractor to reduce the number of staff on duty.

- The inferred prison style ‘lock down’, consistent with Category B prison specifications, is undignified and appears to contravene Detention Rules, including Rule 15(2).

- The inferred prison style ‘lock down’ suggests that two different regimes will be operated (a ‘two-tier’ complex), with a lack of free flow between the two sites.

- Having a two-tier regime will create managerial difficulties and could result in major disturbances.

- Lessons appear not to have been learned from the expansion of Harmondsworth, where HM Inspectorate of Prisons reported that:

“the new accommodation had been built to prison specifications, which was out of keeping with how a detainee population should be managed (…) the prison-like design of the new units is regrettable and such an environment will always be unsuitable for people held under immigration powers”52

51 Planning Statement, CGMS for The Home Office/Ministry of Justice, October 2014, Page 8, Paragraph 1.8.52 Nicola Blackwoods footnote: “HMIP, Harmondsworth IRC, 2011”.

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Further concerns arise from the particular arrangements for the duplication and sharing of facilities, especially when combined with the likely mentioned restrictions on free flow of movement between the existing buildings and the proposed extension. These give rise to the following particular concerns:

- Among the facilities to be shared will be healthcare, reception, discharge, detainee visits, legal visits – assuming a ‘two-tier’ regime access to these vital facilities will be unacceptably restricted. Given the serious concerns already about healthcare and access to legal services, this is especially disturbing.

- Duplicated facilities include, faith requirements, education, internet access, shop, fitness suite and barbers – i) this reinforces the inference there will be a two-tier regime ii) although these facilities will be duplicated there is no mention whether there will be two sets of staff to operate the two sets of facilities – so again this could lead to alternating opening and unacceptably restricted access.

-

Another serious concern are the proposals for a ‘Care and Separation’ Unit, more commonly seen within the prison estate rather than within an IRC. The existing ‘Removal from Association Unit’ at Campsfield has attracted criticism from the IMB that it is “barely suitable for temporary confinement” and is “completely unsuitable for use by detainees removed from association”. Questions remain as to whether existing problems will be compounded.

Two additional concerns are:

- The inadequate provision for worship for Muslims who currently comprise over 50% of detainees at Campsfield House (an issue repeatedly raised by HM Inspectorate or Prisons but not remedied).

- A Sports Hall has been omitted from the new building – again reinforcing the sense of a two-tier regime and proving unacceptable restricted access for exercise, especially in adverse weather conditions and hours of darkness.

8 FURTHER FACTORS WEIGHING AGAINST ‘VERY SPECIAL CIRCUMSTANCES’

We have set out reasons why this planning application does not demonstrate ‘Need’ capable of amounting to Very Special Circumstances. In addition Asylum Welcome believes the following factors weigh further against a finding of ‘Very Special Circumstances’.

8.1 DAMAGE TO GREEN BELT

The proposed expansion is physically much larger than the facility that exists at present, and higher, with a big increase in parking. At present the centre has little visual impact on the surrounding area, but the

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Home Office’s proposals will have very significant visual impacts from the immediate area and also from major roads and footpaths. The height of the proposed main block is of particular concern. None of the existing buildings are three storeys high. A build of three storeys makes the buildings visible from locations where they are currently not visible, resulting in an undue visual intrusion into the open countryside. The Landscape and Visual Appraisal submitted together with the application admits that from certain viewpoints, particularly along Begbroke Lane and from the A44, the building would “introduce built form into a skyline which is currently characterised by a belt of vegetation”.

The appraisal only considers the impact on views from publicly accessible locations, and not from the homes of residents living in Begbroke, who would also be adversely impacted. It will be more intrusive, and inevitably seriously impact on the “openness” of the Green Belt.

Nicola Blackwood’s constituents have discussed with her obtrusive lighting at Campsfield House, which will inevitably be increased with the expansion.

There is cross-party consensus, at a constituency level, that the proposal should be rejected on the basis of unwarranted damage to the Green Belt. Kidlington Parish Council and Yarnton Parish Council in particular have voiced their opinion that that the ‘Need’ as set out in the Planning Statement does not justify building on their Green Belt.

CPRE Oxfordshire oppose the Planning Application because of the detrimental impact on the Oxford Green Belt as does Oxford Green Belt Network.

8.2 NOT CONSISTENT WITH LOCAL PLAN

The Local Plan allows for small local Green Belt review in the Langford Lane area, but solely to allocate land for “higher value employment uses such as high technology industries in the research and development sector”, which clearly does not cover a Detention Centre. The Local Plan goes on to say:

Subject to the outcome of the small scale local review of the Green Belt the following design and place shaping principles will be applied:

- Design for buildings that create a gateway with a strong sense of arrival from theairport and to the industrial estate

- Layout of development that enables a high degree of integration and connectivitybetween new and existing development, including surrounding employment areas andservices, including through the provision of footpaths and cycleways that link withexisting networks

- Good accessibility to public transport services should be provided for- A Travel Plan should accompany any development proposals- A well designed approach to the urban edge, which achieves a successful transition

between town and country environments- Development that respects the landscape setting of the site- A comprehensive landscaping scheme to enhance the setting of buildings onsite and to

limit visual intrusion into the wider landscape- Public art will need to be provided for

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- A development that preserves and enhances biodiversity, with the enhancement,restoration or creation of wildlife corridors

- A high quality design and finish, with careful consideration given to layout,architecture, materials and colourings to create a Technology Park for high valueemployment uses.

- The height of buildings to reflect the scale of existing employment development in theVicinity

- Provision for sustainable drainage, including SuDS, in accordance with ‘Policy ESD 7:Sustainable Drainage Systems (SuDS)’ and taking account of the Council's StrategicFlood Risk Assessment

- Demonstration of climate change mitigation and adaptation measures includingexemplary demonstration of compliance with the requirements of policies ESD1 – 5 An assessment of whether the site contains best and most versatile agricultural land,including a detailed survey where necessary

- A soil management plan may be required to be submitted with planning applications toensure that soils will be retained onsite and used where possible.

It is difficult to think of a proposal that is more contrary to the design and place shaping principles, than the proposal to expand Campsfield House.

The following extract from Close Campsfield’s submission to Cherwell District Council objecting to the Planning Application, reinforces the point:

“3.6 The proposed development fundamentally changes the character of the existing facility. By more than doubling its capacity, it will become one of the largest immigration detention facilities in Europe. Whereas the existing facility attracts a monthly protest of up to 20 people, an annual demonstration of up to 100, and ad hoc protests when suicides, hunger strikes and other serious incidents take place within the site, centres comparable to the proposed facility attract more attention and much larger protests. For example, Harmondsworth, run by the same company as Campsfield, attracts regular “Surround Harmondsworth” demonstrations attended by 100+ protesters and which involve simultaneous protests inside and outside of the facility. As immigration detention is highly controversial, any businesses considering investing in land adjoining the site may be concerned about reputational damage as well as security. It could be argued that academics are particularly likely to be susceptible to concerns. A recent letter calling for Campsfield to be shut was signed by 9 heads of Oxford colleges and 61 other senior academics at the University of Oxford. This is particularly relevant as paragraph C.194a of the new Local Plan specifically refers to the role of the University of Oxford in any employment use of the surrounding land. Not only is the development not in accordance with new Local Plan policies, it may also reduce the likelihood that surrounding land can be used in accordance with them.”

8.3 CHOICE OF SITE

The Home Office give their “Alternative Sites Assessment” at 6.6ff of their application. Given the Government's increasing commitment to protecting Green Belt already mentioned, we suggest whether a site was 'Green Belt' should have been an important part of the decision process. Moreover some of the selection criteria are questionable.

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The criteria are presented as stages, which means that if a site is not in Home Office ownership, other criteria are not considered against the site. In fact, the proposed site is not in Home Office ownership but rather in Ministry of Justice ownership, so Campsfield ought to have been rejected for the same reason as Morton Hall, Dover, Haslar and The Verne were rejected, without considering other criteria. It is not impossible for the Home Office to acquire a site which is not currently in its ownership.

The proposed site is considerably older than other facilities (being the first immigration detention centre), and the site was not originally designed as an immigration detention facility: it is one of the worst available candidates for expansion.

The final criteria used “Value for Money” is asserted with little evidence offered by the Home Office. We do not believe this is a relevant planning consideration, and in any case believe a greater level of detailed evidence amenable to scrutiny by decision makers would need to be provided by the Home Office to advance its case.

8.4 DRAINAGE

There are no plans for foul drainage included with the application even though Kidlington has experienced severe problems with foul water flooding over the past few years.

The impact of the new development on the existing sewage system has been a concern repeatedly raised by residents. Residents recently faced a £2,000 bill for repairs to the sewage system, which is not capable of dealing with the stress that is currently placed on it, especially during floods when they have had sewage on the streets.

Having liaised with Thames Water, Nicola Blackwood MP states that Thames Water are concerned that the development may lead to sewage flooding, and that the calculated net peak flow from the proposed development will consume too much of the receiving sewage network’s maximum flow capacity.

8.5 TRAFFIC

The application estimates a 70% increase in traffic. Putting aside the increased construction traffic during building, given the Centre will more than double in size 70% seems an unrealistically low estimate. Oxfordshire County Council has expressed its concern that regarding traffic:

‘much of the material submitted with this application is either inadequate or missing’

The Kidlington Area Strategy published by Oxfordshire County Council (OCC) is clear that all major junctions along the A4260 regularly suffer from delays during peak traffic times53. Accidents tend to be concentrated on the busier roads such as the A4360 Kidlington roundabout and the A44/ Langford Lane junction.54 Kidlington Parish Council have also voiced their concern that congestion on the A4260 has

53 Oxfordshire Local Transport Plan 2011-2030 Revised April 2012, Oxfordshire County Council, Chapter 23, “Kidlington Area Strategy”, Paragraph 23.24.54 Ibid., Paragraph 23.25.

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already reached saturation level, and will be aggravated by a number of current and planned developments such as the new Oxford Parkway station at Water Eaton, the Northern Gateway, the proposed Langford Lane employment development and a possible new development in Woodstock. With the roads already heavily congested even a small increase, particularly during construction phase, will undoubtedly have an adverse impact on congestion.

8.6 CHANGE IN NATURE OF THE FACILITY/PREVIOUS APPLICATIONS

The application stresses that another application on a Green Belt site has been accepted on the basis of a ‘Needs’ case. However this previous application did not extend so far to the West and was only two storeys in height and the purpose was different, to contain multi-faith, education and workshop facilities which related to the welfare of existing detainees.

8.7 NOISE AND DISTURBANCES

Asylum Welcome believes that the following point Nicola Blackwood MP makes in her submission objecting to the application is a forceful one.

“When speaking with local residents about the impact of the expansion on the neighbouring area, it has become apparent that a large number are concerned about noise pollution and other issues which could be disruptive. There have been numerous disturbances at Campsfield House over the last decade which residents have had to endure. For example, the disturbance caused by a riot in March 2007 and a fire in August 2007, which led to 26 detainees escaping. Many local residents in this area are elderly, and I am concerned that not enough assurance has been given to them with regard to the proper control and management of a detention centre of the proposed size and scale.

Of course, during construction phase residents will also have to put up with a large volume of traffic and noise as the building work takes place. Over recent years, some residents have voiced their concern that the existing detention centre has an adverse impact on house prices in the area, these concerns are now heightened as the Home Office look to expand on this land to make a 580 bed estate.”

Asylum Welcome maintains that in our experience, the detainees at Campsfield House are ordinary human beings in difficult circumstances who do not in any way represent a threat to local people. Asylum Welcome nevertheless is concerned that the massive expansion of the centre plays into local fears of disturbance, and fears of foreigners.

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9 APPENDIX 1Parliamentary Question by Andy Sawford MP, answered by Karen Bradley, Minister for Modern Slavery and Organised Crime, based in the Home Office, Hansard: House of Commons 14 July 2014 : Column 500W.

Karen Bradley: Incidents in the detention estate are reported in accordance with Detention Services Order (DSO) 12/2008. Incidents are classified according to their seriousness as red, amber or green.Examples of the types of red or amber incidents are given in the DSO. Red incidents are generally those relating to serious disturbances and/or fires within a centre. Amber incidents may be those involving threats to the centre, external demonstrations, or co-ordinated food or fluid refusal.This data has been collected by different business areas in the Home Office over the data period requested and has not been collated centrally.Management information is available only for the period 1 July 2013 to 9 March 2014 in the following table and is in line with the data period for published statistics.This data is management information collected and collated from Immigration Removal Centre suppliers. This information does not form part of published statistics and is not subject to the detailed checks that apply for National Statistics publications. It is provisional and subject to change.

Incidents in immigration removal centres for the period 1 July 2013 to 9 March 2014 by status

IRC Red incidents Amber incidents Total of incidents

Brook House 2 59 61

Campsfield 1 14 15

Colnbrook 4 109 113

Dover 1 39 40

Dungavel 0 3 3

Harmondsworth 0 145 145

Haslar 0 2 2

Morton Hall 6 29 35

Tinsley House 0 17 17

Yarlswood 1 109 110

Total 15 528 541

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