Heathrow airport expansion consultation: respond before 13th September

The Heathrow airport expansion consultation closes this Friday, 13th September.

EHID is encouraging supporters and local residents to respond to the consultation and object to the construction of a huge immigration detention centre as part of the expansion. EHID’s response to the consultation, focusing on the detention centre, is reproduced below. You can use this for ideas for your own response; you can of course also comment on any other aspects of the expansion plan you feel strongly about, from the impact on your local neighbourhood to the environmental damage expansion threatens across the region and globally.

How to respond

You can submit a response through the airport expansion consultation website. There are questions on a range of topics and on the impact on neighbourhoods around the airport. In EHID’s response below we have linked to the questions we answered.

There are other ways to respond, including by email to feedback@heathrowconsultation.com. See the how to respond page on the consultation website for more information about submitting a response through the website or in other ways.

If you are happy to share your response, or parts of it, with EHID please send it to info@ehidcampaign.org or use our contact form. If you respond through the consultation website and enter your email address, you will receive an email copy of your response which you could forward to us.

Arguments behind our response

EHID opposes the airport expansion as such: climate justice and migrant justice are inseparable.

We are also concerned at the loss of Green Belt open fields and hedgerows, and increased air, noise and traffic pollution which the plan entails.

Our arguments based on solidarity and human rights include:

  • It is wrong to imprison people without charge, judicial oversight, or time limit.
  • Abuse in detention is systemic: Since Mitie took over the Heathrow detention centres, there have been almost a hundred recorded allegations of staff assaulting detainees. In 2018 alone, there were 233 incidents of self-harm that required medical attention in Harmondsworth and Colnbrook.
  • Financial as well as human costs are high: community based alternatives are cheaper.
  • If the 28-day time limit on detention supported by many MPs is enacted, the number of people who could legally be detained would shrink by as much as 60%. Even more reason not to build a costly replacement detention centre.
  • Stated government policy is to detain fewer people for shorter periods. A replacement detention centre (it would be the biggest in Europe) makes no sense in that context.

EHID’s response

Topic: Our preferred masterplan – Airport masterplans 2022–2050

Respond on this topic

Question 2: Please tell us what you think about the sites we have identified for buildings and facilities we are proposing to move.

The proposed site for the relocation of the Harmondsworth and Colnbrook Immigration Removal Centres, at Hatton Cross/Fagg’s Road, is inappropriate for a number of reasons.

Part of the land is designated as a Site of Importance for Nature Conservation (SINC) (see drawing No. B2.3 in the Hounslow Green Belt Review June 2019). The immigration detention centre would be built right over this site; therefore, it is likely that any development will have an adverse impact on biodiversity. This is in conflict with the following of Hounslow Council’s objectives, as outlined in their West of Borough Integrated Impact Assessment Report (2019) under Theme 2:

  • To maintain and enhance biodiversity (areas of nature conservation and interest, wildlife and habitats); and
  • Improve and protect air, land and water quality in the West of Borough.

The land is also currently under green belt protection. In Hounslow Council’s Local Plan, they are proposing to lift this designation. However there is no mention of the development of an immigration removal centre. Thus the development of this site has been mishandled by both HAL and Hounslow Authority. The Heathrow Plan does not give adequate justification for removing this land from the green belt, or from public recreational use, where it contributes to the health and wellbeing of the local population.

According to Policy 7.1 of the 2016 London Plan, new local developments should ‘enable people to live healthy, active lives; should maximize the opportunity for community diversity, inclusion and cohesion; and should contribute to people’s sense of place, safety and security’. An Immigration Removal Centre Does none of these things for the people of Hounslow, especially when it is built on land currently used for recreational purposes, that provides access to green space in a built-up area. This is doubly so given that IRCs have a publicly proven record of institutional abuse, high levels of drug use and self harm, and disproportionately target working class people and people of colour. Such a discriminatory and hostile institution is unlikely to cultivate the same community spirit as free public space where people can meet, exercise and socialise.

According to section 5.112 and 5.113 of the Airport National Policy Statement: “Existing open space, sports and recreational buildings and land should not be developed unless the land is no longer needed or the loss would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location. If the applicant is considering proposals which would involve developing such land, it should have regard to any local authority’s assessment of need for such types of land and buildings … During any pre-application discussions with the applicant, the local planning authority should identify any concerns it has about the impacts of the application on land use, having regard to the development plan and relevant applications and including, where relevant, whether it agrees with any independent assessment that the land is no longer needed. These are also matters that local authorities may wish to include in their Local Impact Report which can be submitted after an application for development consent has been accepted.” (p.65)

Hounslow council have outlined in their Local Plan consultation review how they want to use the Mayfield Farm and the Hatton Cross/Faggs Road site in order to meet their local needs for employment and housing. Hounslow council have outlined their concerns about Heathrow Airport relocating the detention centre there, saying that relocating the detention centre to the Mayfield Farm site is completely inappropriate and would significantly impact upon their ability to use the site to meet their employment and housing needs. Likewise, building the detention centre at the Hatton Cross/Faggs Road site will significantly prevent the council from using the site to meet their needs for industrial floor space as outlined in the council’s Employment Review. Detainees carry out a significant amount of the work in detention, such as cleaning, cooking, serving food, and running recreational activities, but are paid only around £1 per hour. It cannot be argued then that a detention centre helps meet the employment needs of the local population, and in any case, working in such a vicious and inhumane environment is not the type of work that any sane person would want to be employed in.

Therefore, these two sites should not be used to construct an unnecessary immigration detention centre.

Neighbourhood: Bedford and Mayfield Farm

Respond on this neighbourhood

Question 4: Please tell us what you think about our development proposals and the measures proposed to reduce effects in your area.

If the land at Hatton Cross/Faggs Road site is developed it will mean the loss of a loved, vital green space in Hounslow. It will also mean:

  • Disruption to local area for around two years because of building work to construct the centre.
  • Part of the site is designated as a Site of Importance for Nature Conservation (SINC) (see drawing No. B2.3 in the Hounslow Green Belt Review June 2019) – the immigration detention centre would be built right over this site; therefore, it is likely that any development will have an adverse impact on the biodiversity. This is in conflict with the following of Hounslow Council’s objectives, as outlined in their West of Borough Integrated Impact Assessment Report (2019) under Theme 2:
    • To maintain and enhance biodiversity (areas of nature conservation and interest, wildlife and habitats); and
    • Improve and protect air, land and water quality in the West of Borough.
  • Hounslow council themselves admit in their local plan review that “new development in the area may have unavoidable impact on some habitat and species through land-take, disturbance and impacts on ecological connections. This is significant given the biodiversity sensitivities present in the area.” There is a global climate crisis, and it is unacceptable that the council want to destroy a green space to build an unnecessary, racist immigration detention centre. This is in conflict with the following of Hounslow Council’s objectives, as outlined in their West of Borough Integrated Impact Assessment Report (2019):
    • To maintain and enhance biodiversity (areas of nature conservation and interest, wildlife and habitats); and
    • Improve and protect air, land and water quality in the West of Borough.

Topic: Managing the effects of expansion – Health

Respond on this topic

Question 14: Please tell us what you think about our proposals to help health and well-being. Are there any other proposals that you think we should consider to address the effects of the Project on the health and wellbeing of our colleagues, neighbours and passengers?

Detention centres are racist, violent and inhumane places, and the people targeted for detention are disproportionately people of colour and those from working class communities. People there are held in prison-like conditions for an indefinite amount of time, sometimes for years. They are snatched from their families, their loved ones and their communities. It is well documented that many human rights abuses happen inside. There are regular occurrences of hunger strikes, self-harm and suicide – in the Heathrow centres in 2018 alone there were 233 documented instances of self-harm requiring medical attention. That’s equivalent to one incident of self-harm every 1.5 days. The Institute of Race Relations found Harmondsworth to be one of the most deadly places to be detained; and of the 34 deaths in detention since 1989, a total of 14 of these were people who were detained at Harmondsworth and Colnbrook.

If Heathrow Airport Limited (HAL) wants to take serious measures to help health and wellbeing of their neighbours, there is no justification for building and facilitating the construction of an immigration detention centre.

If HAL also wants to take serious measures to help health and wellbeing, they should not build a detention centre on the Land at Hatton Cross / Faggs Road site. This site is Green Belt land that is used by locals as a public green space for leisure and recreational activities. In their Local Plan consultation, Hounslow council note that their borough has high rates of obesity.The loss of such a large area of public green space (approximately 145,000 square metres) will have a huge impact on the ability of local people to enjoy the health benefits of fresh air and nature, as well as the opportunity to play sports or take exercise.

Local green spaces are also important ‘carbon sinks’ that help mitigate the impact of air pollution and the climate crisis. Hounslow has illegal levels of air pollution, already greatly exacerbated by the air traffic from Heathrow airport.

In this context, there is no justification for destroying community green space to build a costly, racist and unnecessary immigration detention centre.

Topic: General – Development Consent Order

Respond on this topic

Question 22: Do you have any comments on what we think will need to be contained in our DCO and do you have any views on anything else the DCO should contain?

You should not contain the Immigration Removal Centre (IRC) as part of your DCO application.

Many of the facilities that are being displaced are not being included in the DCO, such as the Waste treatment facility, the asphalt plant, Harmondsworth Primary School, the special needs centre, the BA headquarters, etc. etc.

It is clear that the IRC is being included in the DCO so as to minimise the opportunity to prevent its development as no local person would want that built in their area, and neither would a council allow one to be built were it to be routed through the local planning application route. This is a blatant disregard to the democratic process, to the wants and needs of local people and of the migrant community.

HAL should not be including the detention centre in your DCO, nor should HAL be helping build a racist, inhumane, exploitative centre unless it wants blood on its hands.