Objections to the Defence Technical College & Aerospace Business Park

Cynefin y Werin - St Athan Campaign Group

Objections to the Defence Technical College & Aerospace Business Park

Planning Applications nos. 2009/00500 and 00501/OUT


Cynefin y Werin – the all-Wales network of organisations promoting international peace, social
justice, human rights and equality – considers that the placing of a ‘Defence Technical College’
(DTC) in Wales is a matter of interest and concern to all people in Wales. This is because it will
have far-reaching implications for the environment, economy, sustainability and security of the
nation, for our educational and cultural traditions, and more generally for the projection of a
distinctive ethos of Wales in the world.
A ‘St Athan Campaign Group’ has been established over the past 2 years within the network
(see: www.cynefinywerin.org.uk) to monitor developments there, and this submission
represents the views of our organisational members and those active in the Campaign Group.

● The St Athan Development Brief of 2006 was based on overly-high figures for DTC personnel
and trainees (at least twice the current estimated numbers) so must now be considered out
of date. The northern access road – with a junction on the B4265, destructive of meadows,
causing flooding problems and approaching close to dwellings – can therefore no longer be
assumed to be justified. The case for £15 million or so of public spending on this, compared
with the alternative access at West Camp, needs full consideration.

● The DTC was initially promoted by the Welsh Development Agency (WDA), a quango, and
then decided upon at the Westminster parliament, without an opportunity for consideration
by the people of Wales or our elected representatives in the National Assembly for Wales.
We call for a Planning Inquiry, to ensure that a higher degree of democratic scrutiny of the
DTC can take place before any further action is taken.

● The Aerospace Business Park (ABP) is a speculative development, based on a draft ‘businessas-
usual’ strategy and dependent on improbable public funding approval by the Welsh
Assembly Government (WAG). Its northern access road is contrary to the Vale of
Glamorgan’s (VoG) development plan, both in itself and in facilitating green-field housing
for the DTC. We seek its call in for a Planning Inquiry too.

The economic recession has swept away any unproven prospects the ABP had in 2000. The
Welsh Assembly Government’s policy for a low-carbon economy, if applied consistently,
should end plans to expand the aerospace business, Moreover, the earlier “Red Dragon”
project can hardly be considered a valid forerunner for this new development:
a) as the Defence Aviation Repair Agency (DARA) workforce there will be disbanded within
months, and DARA’s super-hangar becomes unavailable;
b) in an era of contraction, or at best stagnation, of the aerospace industry;
c) in a post-recession economic situation that rules out planning on the basis of recent
● We propose that both a reduced size DTC and a realistic scale ABP could readily fit within
the present airfield site. ‘Green-field’ development, departing from the VoG Council’s

Unitary Development Plan (UDP) as in the Planning Brief, is not justifiable. We support
local opposition to building service families’ accommodation on the western side greenfields.
“Key worker housing” of 553 (483 new-build) units is much more than can be
justified, and more could be sited on surplus parts of the existing Ministry of Defence (MoD)
site. The western access road is an environmentally damaging relic of the original planned
peripheral road, and we support the local proposal for alternative access via an improved
junction and rail bridge at West Camp.

● WAG’s plans range beyond this application. Its 2008 Prospectus for St Athan now calls the
ABP an “Aerospace and Defence Park”, promising “maximum security… for any aerospace
and defence work”. It promotes St Athan as the centre of an aerospace industry hub, linking
BA at Cardiff Wales Airport and Pontyclun, GE at Nantgarw, and growing numbers of
businesses on-site, with “potential for further land development – 200 acres” and “planned
new hangars … up to [the size of] 767/A330 aircraft”. Public expenditure considerations are
lacking, and no business case has been developed.

● Details of the extra land (approx. 100 acres) and specific requirements for maximum security
work should surely have been included in the present application. We believe that their
exclusion is disingenuous, and that the VoG Council should challenge WAG over them.
Making a decision on the current applications when the applicants have publicly indicated
that they intend further developments to extend the site would be to allow incremental
development. Permitting such applications has in other cases been an issue for the
Ombudsman. The Vale of Glamorgan Council should oblige WAG to disclose its entire plan
for the ABP. Likewise, the Council should oblige the MoD to disclose plans for surplus land
within its West Camp site (which it had nominated for housing in the Local Development
Plan [LDP] process).

● The security implications for the development are of a national and international nature.
These stem from the concentration of defence training that is proposed, made all the more
acute by the fact that military personnel from overseas will be trained there. In our view, it
follows that the planning application entails national security, an issue in Planning Policy
Wales. The failure to cover the issue to enable full scrutiny for planning purposes needs to
be raised with WAG as an unacceptable omission.

We view these planning proposals as contrary to the interests of the people of the Vale of
Glamorgan and of Wales - as being environmentally and economically unsustainable; based
upon an unsound, speculative aerospace prospectus; socially undesirable for the locality and
community; presenting security risks to people locally and in Wales as a whole; and
contrary to the traditions of peace that have historically been so strong in Wales.
Privatisation of military training is part of a trend of privatising military services. This puts
on a commercial basis certain defence activities which are fundamentally a public service,
and which should be delivered by people imbued with an ethos of national interest. This
underlies a further fundamental objection the Campaign has to the Metrix project.
In view of the grave importance to all the people of Wales, as well as those in the Vale of
Glamorgan, of these proposals we ask for both Applications to be called in by the Welsh
Assembly Government for further examination and for Public Inquiry.
1. We argue that the planning application by the Welsh Assembly Government’s Aerospace team:
a) promotes St Athan as a “Centre of Excellence for Aerospace and Defence”, yet has failed to address the
impact of the institution on the national security of Wales, on the achievement of ‘the Wales we want’, and on
our external international image;
b) has provided insufficient information on the full land-take envisaged, and on disclosing its plans for
“maximum security” military work and its land-use implications;
c) while discussing local security for the MoD site and the need to segregate civil from military maintenance,
fails to address any national security planning dimensions and the political implications for Wales of
association with military R&D, hardware and training of this type and scale.
We accept that the Vale of Glamorgan Council is not in a position to consider these national security issues.
Planning Policy Wales makes clear this is a Welsh Assembly Government responsibility. We ask VoG
Council Planning Authority to request that WAG call in the St Athan Defence Technical College planning
application for a Public Inquiry. The Council itself needs to press for full information on points a) to c)
above, in order to meet legislation on Environmental Impact Assessment.
2. We see that the plans and claims made in the publicity surrounding the Defence Technical College
development are at least in part based on exaggerated claims and speculation:
The scale of the DTC is still exaggerated: “The project involves developing a new military academy for
8,500 personnel” http://www.ibwales.com/business-sectors/aerospace-and-defence/news/stathan/
aerospace-business-park-update. The current numbers for personnel are in fact half that –
2,500 (maximum) trainees, 1,700 DTC and military staff, and 600 service staff (catering, cleaning,
maintenance and transport).

The actual training contract is uncertain:
● the huge cost has made it potentially “unaffordable”, even before the £30 billion deficit in MoD finances
which became clear in August 2009.
● the estimated benefits from selling vacated MoD sites for development are much reduced.
● the British Conservative Party has announced it will review all major defence commitments if it enters
government in 2010.

The St Athan focus has been scaled down, and this reduction may go further as:
● navy engineering training is to remain at Portsmouth, potentially until 2025 or later;
● there is reduced emphasis on centralised learning – nine satellite learning centres with Computer
Aided Learning are planned;
● a significant number of the experienced staff seem unwilling to move to St Athan;
● trainee contact hours have been reduced from the 1.5 million per year originally considered necessary
by the training staff.
Indeed, these and other changes mean that even the revised planning figures for staff and trainees that were
determined at the beginning of 2009 (approx. 4,200, set out above) are likely to be too high, and are out of

3. Environmental Impacts are excessive and inadequately addressed
Flemingston firing range and Flemingston field training area
Cllr R Eustace of Flemingston Community Council has detailed impacts of noise from use of the firing range
(at times up to 11 pm), and ambush training with the firing of blanks and thunder flashes. Although acoustic
fencing and bunding will be installed, he reports “there will still be a medium to high magnitude effect on
neighbouring properties”. As the firing range is already in use, people know how disturbing the sudden
sounds are. Intensified use should not be allowed, but a new, better-soundproofed facility built, remote from
any dwellings and preferably within the camp.
Northern Access Road
This roadway is very intrusive in an open landscape, crossing a scenic valley stream on a bridge, and over
meadows on an embankment. This is a very noisy design – the traffic noise would spread readily to housing
at Millands Park and Eglwys Brewis Road. The plans to light it at night make for further intrusion, and
unneeded light pollution. The land on which the road would be built is productive farmland and sections
severed from it will be lost to housing and development of ‘possible sports facilities’ instead.
Flooding Problems Enhanced
Flooding is a problem at Boverton, recently tackled by flood bunds to retain water on the fields affected by
the road. The disruption of the new system and the additional run-off from the road and adjacent housing
could have effects that cannot be met at acceptable cost by the assumed underground holding tanks. A
fuller study of the issue is needed.
Aero-engine Test Facility
The noise from the present aero-testing facility is in practice highly disturbing. No argument is given for
allowing a new facility to be sited anywhere in the neighbourhood of housing, especially one closer to
Boverton where the engine testing is already found to be disturbing. As Batslays Farm is to be retained for
offices, siting the test facility adjacent to the farm buildings is unacceptable. Section 16.15 of the application
confirms that the significant detrimental noise levels from the engine running will affect properties to the
south of Boverton. Though the consultants propose mitigation via earth bunds (three sides only) they do not
give figures to show if this would be effective.
The MoD should be objecting about this aspect on behalf of present and future occupants of staff housing:
presumably their conflicting interest takes precedence. Once the VC-10 contract ends in 2014, there is no
justification in continuing aero-engine testing on a site that is even more sensitive than the present one.
Moreover, the MoD did nominate land on the south of West Camp for housing under the LDP; use for
housing and other purposes will be prejudiced by the proposed test facility.
Watchman Radar system
This system would have to be moved to St Athan (from Cosford), yet is not mentioned in the documents.
The high power system would affect residents much more strongly than the non-ionising radiation emitted by
mobile phone transmitters. There is also a possibility that Watchman will interfere with aircraft
communications at Cardiff Wales Airport: Speke airport, which is far further from Cosford, has encountered
such interference.
Concerns on these counts should have been covered in the Environmental Statement. Since no information
is given, Metrix should be required to guarantee that it will not seek to bring the Watchman system - or a
similar tower and transmitter system - to St Athan at some later date.

4. Implications for existing Development Plans
a. The VoG Council has said that this is the most significant planning development it has ever
considered; planners therefore should themselves be calling upon WAG to hold a Planning Inquiry.
This would match public expectation of independent and fair planning that the Town & Country
Planning Act 1990 (TCPA90) is supposed to ensure.
b. The VoG Council should resolve that the housing and road proposals “significantly prejudice” the
Unitary Development Plan by reason of scale, nature and location (Planning Policy Wales, PPW
4.12.2), when WAG has to consider a call in for a Public Inquiry. The Council should point out the
“wide effects” and “substantial controversy” beyond the immediate locality, as well as “issues of
national security” (PPW 4.12.1).
It is worth noting that WAG has just announced it is calling an inquiry over the Junction 33 / M4
Motorway development because “Ministers have concluded that the scale and location of the proposed
development and its overall impact on the environment raise the possibility of substantive conflict with
national policy on development in the open countryside...”. The ‘possibility of substantive conflict’
likewise clearly applies to these St Athan applications.
c. Alternatively the VoG Council could trigger an appeal (PPW 4.11) by either not determining the
applications or rejecting them as premature until the new development plan (LDP) passes through its
consultation and inquiry processes (or pending a Conservative government review of MoD contracts,
several months post-election).
Should Metrix insist on an earlier decision and appeal, there should result a Public Inquiry under the
Planning Inspectorate (PPW s. 4.12.1), unless WAG recovers the appeals for their own determination
because of “novel planning issues”.

5. Unrealistic and speculative Aerospace development
The Aerospace Business Park started as a means of replacing jobs servicing the RAF base, and to make
use of the St Athan airfield’s assets. When the Red Dragon Project was conceived to take over from the
Defence Aviation Repair Agency (DARA), it was said that the £77m high-tech aircraft repair and
maintenance centre would be the basis for a world-class aviation centre with 2,000 jobs. This never
a. We are concerned that there has been no sober risk and business assessment for the current
proposal. The consultants Mott MacDonald were appointed in December 2008 by WAG to update
demand studies. They claim as a key finding: “The current economic downturn, although severe,
should have only a short term impact on the aerospace industry.” That statement is based on a world
view inconsistent with the WAG policy of changing Wales to a low carbon, sustainable economy. The
Prime Minister calls it a "historic mistake to think we can now return to business as usual" (Gordon
Brown, Interview with FT, 1 Sept.09).
b. Even in 2007, the UK Maintenance Repair and Overhaul (MRO) market was decreasing, and the
further decreases in the recession are surely stronger than the 0.9-1.8% guessed at in the Planning
Statement (s.218).
c. The prognosis for MoD work did not take into account the expected shortfall in MoD funds, which is
due to worsen in public expenditure cuts. The expectation of ‘business as usual’ from 2010 ignores
the government’s own expectations of public expenditure cuts for a decade or so, and was slated by
the Prime Minister himself in the interview cited above. It was also in ignorance of the huge overrun in
MoD project expenditure, set recently at over £30 billion, and new concerns about military equipment
requirements, especially in Afghanistan.
d. The original aim for the development at St Athan – regeneration, and continuing employment for
DARA’s engineering workers – has failed and much of the workforce has disappeared (to other sites or
jobs, or retired). While the publicity claims a “large, local skilled and flexible workforce”
(www.ibwales.com/server.php?show=ConWebDoc.5069), jobs for the remaining 400 people based
there will end within months and this new development of hangars and other buildings to handle large
aircraft will not produce any for approx. 5 years.
e. A poor record in attracting companies: the 2008 brochure has added “highly competitive rents”,
because of the dearth of companies seeking the empty sites/buildings at St Athan. Firms on site are
dwindling (down to three) and there is little prospect of any newcomers in the short-term with the
current recession in aerospace in the UK.
f. Little evidence of other skills: the Welsh Aerospace skills brochure lists 49 Welsh skill centres but cites
only MPI Aviation at MoD St Athan, which it describes as a ‘Project Support Specialist’ with an office in
Telford. It undertakes cargo conversions, repair schemes, maintenance and structural modifications,
as well as interior refurbishment and re-configurations (www.mpi.ltd.uk/aviation.asp).
g. Since Wales has other sites for civil aviation work, already with MRO workforces and facilities, what
justifies investing at St Athan in competition with them? The 2,500 jobs that “could be created” are not
particularly needed more in the Vale of Glamorgan than elsewhere, but would put unwanted pressures
on services and housing.
h. Mott MacDonald’s projections envisage winning work on a speculative basis:
● huge new hangars to allow MRO work on large military transport aircraft (Globemaster III and
FSTA). Yet the fleet of FSTAs (a modified Airbus) will be based at Brize Norton in Gloucestershire; the
RAF’s future A400M and Globemaster Transporter will only be open for MRO bids after the DARA
skills/workforce has been disbanded.
● retrofits of communications, navigation and surveillance systems to civil and military aircraft; no
reason is given why retrofits could be better done at St Athan than elsewhere, not even “some of this
● maintenance and storage of unmanned combat air vehicles (UCAVs). No reason is given for
maintenance and storage of UCAVs, compared with Aberporth in Ceredigion or elsewhere.
i. While we are told that “strict segregation” of maintenance of military and civil aircraft will be necessary,
the proposals do not explain how this would be feasible, including segregation for runway purposes.
j. The strategy drawn up by the ‘dedicated aerospace team’ is a “draft” only that has not passed
Treasury-standard assessment, nor gone to public consultation, nor gained WAG approval. The
realistic expectations for aerospace jobs would be fewer than the 2,000 originally given, and well below
the 2,500 of Mott MacDonald. We believe that the VoG Council must therefore treat it as unfounded,
speculative development and apply strict planning rules.
Hence, the plans as submitted, and promotional publicity for the Aerospace Business Park development, are
based on speculative claims. On the evidence supplied the ABP lacks a sound business case, and is likely
to be abandoned if subject to Westminster government Treasury criteria. The case in the Planning
Statement (s.231-236) is reminiscent of the Cardiff Wales Airport expansion that the WDA supported in
1999-2000 but which never came to pass.
6. Lack of Openness on Area for ABP development
The 166 hectare area given in the Planning Statement includes the runway and wide exclusion areas
either side – the real area available is about 250 acres, as given in publicity material. However:
● the 2007 promotional pamphlet ‘Come fly with us’ of Aerospace Wales (and International Business
Wales) says at least 346 acres is “available for bespoke development”;
● the Aerospace Wales 2008 St Athan promotional brochure refers to a “secure 250 acres” and a
further 200 acres “potential for further land development” (as also does
● ABP South comprises an area of 117 acres (46.84 hectares) south of the runway at
Batslays, West Orchard and Beggars Pound.
Part of ABP South is for the access road, while Batslays Farm development depends on compulsory
purchase. This potential for development is thus under 120 acres. We infer that WAG is envisaging
at least a further, as yet unspecified, 80 acres as “potential for further land development”.
Omitting to describe its full ambitions – presumably for land closer to St Athan housing – is wrong on
the Welsh Assembly Government’s part. The Council Planners should oblige WAG to disclose all of
the areas of land it envisages developing in its promotional literature.
7. Security Risks of the DTC and Aerospace and Defence Park
a) The DTC would be a prime target for ‘terrorist’ attack for at least two reasons:
● Metrix (as does Raytheon already) will boast of it as a flagship training centre, making it a high profile
● trainees will be on site from military forces of countries like Saudi Arabia and Malaysia (associated with the
weapons systems sold to them by British companies) and potentially from other regimes or even private
forces to which Metrix may sell its training packages.
While the recipients of Metrix training would be subject to MoD policy, government policies can change and
the planning authority has to anticipate the worst case. Even present practice in training non-UK forces
would make St Athan/Wales a target and so raise “issues of national security” in the words of Planning
Policy Wales (4.12.1). Potential conflict with the National Assembly for Wales’s commitment to human
rights also needs to be considered.
b) The 2008 St Athan promotional brochure calls the ABP an “Aerospace and Defence Park”, and includes in
the ‘St Athan – a centre of excellence’ section “maximum security – suitable for any aerospace and
defence work” (also at www.ibwales.com/aerospace). This proposal was not in the 2007 Aerospace
Wales pamphlet and is not admitted in the planning application 2009/00501, but is in the St Athan
Aerospace and Defence Park brochure.
The ABP planning application is inadequate in omitting the land use implications of this ‘maximum security’
area. More importantly, it omits the implications for the ‘national security’ of Wales, noted as meriting
special planning consideration (PPW 4.12.1).
Thus both developments would identify St Athan and Wales with work on military systems up to the most
sensitive level. Plans have to be made to cover St Athan and the surrounding area becoming a prime
target for ‘terrorist’ attack.
Cynefin y Werin : St Athan Campaign Group 8 September 2009
Temple of Peace, Cathays Park Cardiff CF10 3AP

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