planning report PDU/1611/01
23 May 2007
Belmarsh Prison East
in the London Borough of Greenwich
planning application no. 07/0821/F
Strategic planning application stage 1 referral
Town & Country Planning Act 1990 (as amended); Greater London Authority Act 1999;
Town & Country Planning (Mayor of London) Order 2000
Proposed new 480 place prison for young adult male offenders. The prison will be
accommodated in two four-spur houseblock units each holding 240 prisoners along with
ancillary prison facilities. Each houseblock will have three floors accessed through three
The applicant is National Offender Management Services (Home Office), and the architect
is HLM Architects.
The principle of a training prison within the existing perimeter walls of Belmarsh prison is
acceptable in land use terms. In strategic terms the expansion is required to meet the needs of
a growing prison population in London, to locate more prisoners of London origin closer to
their families and homes and thus to reduce re-offending rates. The proposal will bring about
a significant number of permanent employment opportunities for prison related jobs. There
are however a number of significant issues that require resolution before the application is
referred back to the Mayor for a decision relating to energy, transport and landscaping.
That Greenwich Council be advised that the application is acceptable in strategic planning
terms subject to the identified issues being addressed.
1 On 23 April 2007 Greenwich Council consulted the Mayor of London on a proposal to
develop the above site for the above uses. Under the provisions of the Town & Country
Planning (Mayor of London) Order 2000 the Mayor has the same opportunity as other
statutory consultees to comment on the proposal. This report sets out information for the
Mayor’s use in deciding what comments to make.
2 The application is referable under Category 1B of the Schedule of the Order 2000:
”Development (other than development which only comprises the provision of houses, flats, or houses and
flats) which comprises or includes the erection of a building or buildings (c) outside Central London and
with a total floorspace of more than 15, 000 square metres”.
3 If Greenwich Council subsequently decides that it is minded to grant planning
permission, it must first allow the Mayor an opportunity to decide whether to direct the
Council to refuse permission.
4 The environmental information for the purposes of the Town and Country Planning
(Environmental Impact Assessment) (England and Wales) Regulations 1999 has been taken
into account in the consideration of this case.
5 The Mayor of London’s comments on this case will be made available on the GLA
6 Her Majesty’s Prison Belmarsh is approximately 1km east of Woolwich and 800m
south of the River Thames. The proposed development covers an approximate total area of 7
hectares, the majority (4.5 hectares) of which will be constructed within the existing secure
perimeter on the disused sports pitches and former farm and gardens at the eastern end of
HMP Belmarsh. In addition construction works will also occur in areas immediately adjacent
to the north and east of the secure perimeter wall.
7 To the north of the proposed development lies the A2016 dual carriageway, with a
residential housing estate beyond. To the east lies an area of raised green space created to
screen the existing prison and an undeveloped area of the White Hart Triangle business park.
To the south lies the West Thamesmead Business Park and Crown Industrial Estate. To the
west of the proposed development area lies the existing HMP Belmarsh, Woolwich Crown and
Belmarsh Magistrates’ Court and the former Royal Arsenal East Site. The Royal Arsenal East
site is the proposed location of Belmarsh West development, a 720-place remand prison.
8 The nearest Transport for London Road Network (TLRN) is the A205 John Wilson
Street located approximately 2km away to the south-west of the site. Although Plumstead
station is the closest rail facility, it is not considered to be within a reasonable walking distance
from the site (1.6km). Three bus routes serve the site but only the nearest stops located on the
A2016 are considered to be within a reasonable walking distance. As a result, the site records a
low public transport accessibility level (PTAL) of 2, out of a range of 1 to 6 where 1 is
considered as very low.
9 The site should however benefit from the introduction of the Greenwich Waterfront
Transit (GWT) Phase 1 along the A2016 and the DLR extension to Woolwich, both currently
scheduled for 2009, which would improve the PTAL score. The current application is
however, assessed on the basis of the existing transport infrastructure provision.
Details of the proposal
10 The proposed new training prison will comprise two houseblock units each
accommodating 240 prisoners. Each houseblock will have three floors accessed through three
landings. Each landing will consist of single occupancy cells, cells capable of double occupancy
and a full double occupancy cell. Each accommodation unit will also have three disabled/low
mobility cells on the ground floor.
11 To enable independent operation of the prison the following ancillary facilities will also
Administration unit – administrative offices for prison staff.
Reception and discharge unit – facilities for receiving/discharging prisoners.
Education facilities and workshops.
Gatehouse and entry building.
First night/induction centre.
Staff facilities - changing areas, training facilities etc.
12 Access to the proposed development will be via the existing entrance road for HMP
Belmarsh and Woolwich Crown Court from Western Way (A2016). Two separate car parks
for staff and visitors will be constructed. The visitor car park will be situated to the northeast
of the development and provide 74 parking spaces. The staff car park will be located to the east
of the development and provide 272 parking spaces. Both car parks will incorporate spaces for
disabled badge holders located close to the prison entrance and will be screened by tree
13 The new training prison is due to become fully operational in September 2009. The
new training prison will operate to serve Woolwich Crown Court, the Central Criminal Court,
Basildon Crown Court and their associated dependant Magistrates’ Courts. The purpose of the
prison is to provide accommodation and an appropriate regime of education, improvement of
employment opportunities and other rehabilitation programmes for young adult, male
prisoners (aged 18-24). The aim of the prison regime is to reduce the risk of prisoners
14 The concept of the prison is to work with offenders to change their behaviour and
address the issues that may lead them to re-offend. In London each prisoner will have their
individual needs assessed via the ‘London Induction Screening Assessment and Referral Tool’
by an offender manager. This programme is delivered under the following themes:
Education, training and employment.
Drugs and alcohol.
Finance, benefit and debt.
Attitidues, thinking and behaviour.
Children and families.
15 None relevant.
Strategic planning issues and relevant policies and guidance
16 The relevant issues and corresponding policies are as follows:
Urban design London Plan; PPS1
Regeneration London Plan; the Mayor’s Economic Development Strategy
Transport London Plan; the Mayor’s Transport Strategy; PPG13
Parking London Plan; the Mayor’s Transport Strategy; PPG13
Employment London Plan; PPG4; draft Industrial Capacity SPG
Sustainability London Plan; the Mayor’s Energy Strategy; Sustainable Design
and Construction SPG
Access London Plan; PPS1; Accessible London: achieving an inclusive
environment SPG; Planning and Access for Disabled People: a
good practice guide (ODPM)
Equal opportunities London Plan; draft Planning for Equality and Diversity in
Meeting the spatial needs of London’s diverse communities SPG;
Diversity and Equality in Planning: A good practice guide
River Thames/flooding London Plan; Mayor’s draft Water Strategy; PPS25, RPG3B
17 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004,
the development plan in force for the area is the 2006 Greenwich Unitary Development Plan
and the 2004 London Plan (with 2006 Alterations).
18 The following are also relevant material considerations:
The Further Alterations to the London Plan, which have undergone public
Land use issues
19 The proposed development site is not allocated within the Greenwich UDP for any
particular development, and there is no specific policy guidance within the UDP as to the
development of a new prison within the borough.
20 There is also no strategic planning guidance in the London Plan in respect of prisons.
However, the need for prison places in London is acknowledged in the East Sub Regional
Development Framework, which states that during the consultation process the National
Offender Management Service (NOMS) identified the need for additional prison
accommodation in or near to London. The SRDF states that this is an issue that affects all of
London and will need to be explored in more detail following the publication of this SRDF. It
goes on to state in Action 1E (iv) that the Mayor will initiate discussions with NOMS and
other key stakeholders in relation to the potential need for additional prison accommodation in
21 Given the established use and the proposal to accommodate the new training prison
within the existing prison perimeter wall there can be no in-principle objection to the land use
proposed. Although the new facility will be located on unused sports pitches and former farm
and garden area replacement facilities for an all-weather astroturf pitch, a sports pavilion with
changing facilities, a complex of sports courts, and pitches for basketball will be provided
elsewhere within the perimeter walls. The applicant states that due to security reasons, the
existing pitches are not used and have not been in use for some two years.
Prison population and services
The national picture
22 The prison population has risen significantly over recent years to reach an all time high
of 80,175 on 1 December 2006 including those held in police cells under ‘Operation Safeguard’.
In the 1970s the prison population in England and Wales was in the order of 40,000; during
the 1980s it generally remained below 50,000 and it first reached 60,000 in 1997. Subsequently
prison population has risen by a further 30%. It is anticipated that if current trends continue
then the prison population will reach 98,190 by the year 2013, far exceeding the current prison
estate capacity of 80,400.
23 In a response to this anticipated demand, the Home Secretary announced that an extra
8000 prison places would be provided by 2012, through the construction of new prisons and
additional accommodation at existing prison sites. The prison training facility that constitutes
the basis for this report forms part of these proposals. The first 900 of these new places are
targeted to be fully operational by Autumn 2007. The proposal to develop a new training
prison on the unused sports pitches and former farm and gardens of HMP Belmarsh is part of a
large number of schemes either currently on site or under construction to contribute to the
strategy to provide an additional 8000 places in the prison estate. Since 2004, new
accommodation units totalling 2800 places have been provided at fourteen prison
The position in London
24 In addition to the national need for prison places there is also a local requirement for
extra capacity in London. The National Offender Management Service is working to reduce
the likelihood of re-offending in part by locating prisoners closer to their family and homes, in
what is termed a ‘regional model’. As a result of the lack of prison places in London, many
prisoners are currently held in prisons outside of the London area. By increasing the number
of places in London, prisoners can be closer to their home and maintain ties with their families
and the local community into which they will be released. It is hoped that this will aid a
reduction in reoffending rates.
25 At the end of September 2006 there were around 13,500 prisoners from the London area
held in custody. Within the London area there are a total of only 7000 prison places. The male
population with a London origin are mostly held in prisons in London, southeast and eastern
England. Most remand cases, but less than a quarter of the sentenced population, are in
prisons within the capital. Just 6% of the sentenced young adults from London are held in
London prisons, all but 2% in Feltham. A further 6% are held at Highdown. However, the
majority are held at Aylesbury, Rochester and Portland, the latter of which is approximately
170 miles from London.
26 For a regional balance to be achieved in London, moves to address the regional
shortfall of over 6500 places needs to be occur. A profile of the placement of prisoners
originating from the London regions is illustrated below.
Table - Proximity of prisoners to home in the London region, September 2006 (Home Office)
Prisoner with London origin Numbe Proximity to home (average
(type) r miles)
Adult Male Remands 2463 12
Adult Male Sentenced 8101 61
Young Adult Male Remands 429 34
Young Adult Male Sentenced 975 69
Juvenile Male Remands 124 29
Juvenile Male Sentenced 403 74
Female Remands 267 12
Female Sentenced 786 52
Origin (type) Number Proximity toe) Number Proximity to Home(Mile
27 The table above illustrates that young male sentenced prisoners originating from the
London region are on average held almost 69 miles from their home. The proposed new
training prison is designed to provide a regime focused on education, improvement of
employment opportunities and other such rehabilitative programmes. For example, it is
thought that alliances with their Offender Manager and corporate, civic, and voluntary/faith
sectors made whilst serving their prison sentence will be accessible on release therefore
reducing the desire and/or need to re-offend.
Employment and social infrastructure
28 In employment terms the new training prison is projected to generate in the order of
600 jobs. This will include 350 full-time staff, many of whom will be uniformed roles and
administration staff along with 150-250 contracted staff i.e. those providing education support,
healthcare and catering services. Approximately 60% of the positions provided will be filled by
established staff i.e. those that have experience of working in a prison. The proposal would
support overarching London Plan objectives designed to generate employment opportunities.
29 In respect of the training prison itself this should support London Plan policies, which
seek to improve the skills and employment opportunities for Londoners (Policy 3B.12) by
removing some of the barriers to employment for former prisoners. The local authority will
need to satisfy itself that it has the voluntary and community structures in place to
accommodate the demands arising from prison expansion in this area.
30 The BREEAM methodology has being used to ensure that the proposed new training
prison development meets high sustainability standards. The BREEAM Prisons ‘Secure
Prison Accommodation’ 2006 methodology was used to undertake a preliminary assessment
and both houseblock assessments have been registered with BRE. The results of the
assessment indicate that a BREEAM score of 70.55% is likely to be achieved, which equates to
a BREEAM rating of ‘Excellent’. The local authority should ensure these standards are
secured through any planning consent.
31 As the site lies in a flood defended area that is categorised Zone 3a High Probability
under PPS25, a detailed flood risk assessment has been carried out to assess both the risk of
flooding to the proposed development, and the potential impact that the development may have
upon the localised flooding regime. The likelihood and consequence of flooding within the
proposed development site has been comprehensively and carefully considered. The
development is fully contained within the existing HMP Belmarsh site, and will in no way
impact upon the current flooding regime.
32 No detailed modeling work has been done at this stage, which is disappointing.
However, the strategy indicates that an approved software tool (like SBEM) will be used to
establish the sizing of the renewable plant. The sizing of the plant should be derived from a
thermal calculation rather than simply designed to meet the Mayor’s target.
33 The benchmarks chosen for the site appear to come from a relatively old Energy
Consumption Guide on prisons (ECG084). This does not provide a substantial amount of
information on what the new building will comprise e.g. laundry, kitchens, shower blocks etc.
These are all important in looking at the buildings energy use.
34 The report states that prisons are exempt from building regulation requirements.
However, it would appear that there are minimum standards applied by the Home Office for
construction. With this in mind the consultant has stated an improvement of 28.9% in the
efficiency of the building. This is assumed to be over 2002 building regulations rather than
2006 building regulations, which is stated as having a 0.9% improvement.
35 Clear evidence of the improvements to be made in energy efficiency is required as it is
clear that greater improvements can be made in U-Values and inflitration rates. This should be
quantified in a clear SBEM style graph. The indicative 0.9% improvement beyond an
equivalent 2006 building regulations compliant building is unsatisfactory even taking into
account the constraints of a prison.
36 The energy strategy is supported by a further study by Arup into a proposed Combined
Heat and Power (CHP) plant planned on a site in close proximity to the proposed new training
prison development. Although recognised as a potential source of low carbon heat and power
for the site, Arup conclude that the risk involved in the plant not being ready to supply the new
prison site is too great to proceed with connection at this stage, although future connection
could be possible.
37 The applicant and the local authority should ensure the installation of mains or similar
infrastructure to enable the connection in the future. Ideally, this would include a spur all the
way to the boundary of the neighbouring site.
38 The report doesn't mention CHP on-site as required by London Plan policies. Prisons
are generally accepted as an ideal case for CHP due to the constant loads and 24 hour residency
requiring 24 hour heat and hot water.
39 A full CHP analysis for this site that would lead to installation of CHP in the short term
with the option to connect to adjacent sites in the longer term is required at this stage and
before the application is referred back to the Mayor for a decision. The application is unlikely
to be acceptable in strategic planning terms unless this is completed. This should contain some
load analysis and consequent estimation of engine/thermal store size.
40 The applicant proposes the installation of biomass boilers in an energy centre located in
a separate building outside of the prison walls. The biomass boiler option is a reasonable one
given the location of the prison in a low-density area. The report states that there may be
security issues with some renewable technologies although these should be straightforward to
overcome. There is no real background work to the supply chain, fuel type and cost. The
applicant is asked to provide this also. Also, further information on how biomass can be
integrated with either on-site or (in the future) off-site CHP is also required before the
application is referred back to the Mayor for a decision.
Design and landscaping
41 Self-evidently the prison is largely driven by functional and other security
requirements designed from the architects experience of designing prisons elsewhere and
Home Office design requirements. Given that the form, scale and design of the majority of
accommodation will be contained within the existing prison envelope and perimeter walls the
design raises no strategic issues.
42 These design comments are therefore confined to the design and landscaping outside
the perimeter walls. This includes the new car parking area for the prison and the new energy
building. In the current application quite a significant amount of green space will be
transformed into car park. It is important to make the most efficient use of the existing car
park and green space on the north side of the site, to minimize the impact on the east side.
43 The proposal includes a significant expansion in the amount of hard standing for cars.
Despite this insufficient attention appears to have been paid to landscaping at this stage. Tree
planting is shown on some plans but a full landscaping plan is required. The car parking
should be integrated fully into the landscaping strategy rather than the reverse. The
landscaping should be capable of screening the car parking and softening the edges of the
prison. If this cannot be delivered at this stage the local planning authority should ensure this
is secured by condition.
44 In respect of the energy centre a similarly functional design approach has been adopted
and this could benefit from improvements to make a virtue of necessity particularly as these
elements will face the road. This could include a greater variety of materials and colour rather
than only metal and steel elements inlcuding the use of more sustainable facade finishes. The
applicant could also consider a green/brown roof on the energy centre and relocated receipt,
issue and despatch (RID) unit.
London Development Agency
45 The LDA supports this application in principle given the number of employment and
training opportunities this development would provide. The development meets the objectives
of the Mayor's Economic Development Strategy in relation to:
Investment in Places and Infrastructure: Delivering an improved and effective
infrastructure to support London's future growth and development.
Investment in People: Tackle barriers to employment.
Investment in Enterprise: Improving the skills of the workforce.
46 The proposed development will provide accommodation and an appropriate regime of
education, improvement of employment opportunities and other rehabilitation programmes for
young adult, male prisoners (aged 18-24) with the aim of reducing the risk of prisoners
reoffending and improving employment prospects on release.
47 In accordance with London Plan policies 3B.1 and 3B.12, the Council should seek to
ensure that local residents and businesses benefit from jobs created by this proposal,
particularly BAME and disabled persons or groups, in both the construction and operational
phases of the development. Initiatives to create training and employment opportunities for
local people during construction should be formalised through a section 106 agreement
between the local borough and the applicant where possible as well as the need to address other
barriers to employment (e.g. child care). Similarly the applicant should also secure the use of
local businesses during construction, as well as, in the procurement of services and supplies
from small and medium size enterprises or micro businesses.
Transport for London
48 Car parking provision for the site appears high compared to the existing car parking
ratio currently on site and should therefore be reduced. Furthermore, efforts to reduce car
parking should be pursued through the travel plan.
49 TfL is concerned about existing parking overspill problems affecting traffic flows,
including public transport services, during the peak periods onto the surrounding roads
associated with the adjoining uses (e.g. Crown Court). TfL therefore requests that additional
information be provided to assess the current parking restrictions in place for the area and
identify the potential for review, monitoring and eventually funding for any additional
restrictions, if shown to be necessary.
50 TfL also questions the trip generation assessment contained in the Transport
Assessment (TA). Clarification on the trip generation calculations, the service vehicle
movements, the derivation of the trip rates and modal split for both staff and visitors, as well as
daily movement profiles for all modes split between staff and visitors should be provided. In
addition, the modelling results contained in the transport assessment show capacity and
queuing issues along Western Way as a result of the development impact on the highway and
this is a concern for TfL as no mitigation measures are proposed.
51 In pre-application discussions TfL asked the applicant to take the Thames Gateway
bridge (TGB) traffic into account in the assessment as part of sensitivity testing. However, this
information has not been submitted to date. TfL suggests that if permission is granted,
construction traffic will need to be phased with other committed developments and transport
schemes in the area, including Greenwich Waterfront Transit and Thames Gateway Bridge,
and therefore a construction traffic management plan will be required.
52 Given the existing poor pedestrian environment and low PTAL for the area, TfL would
encourage pedestrian and cycle linkage improvements. The mitigation measures contained in
the TA including new pedestrian access, signage, safety and security improvements, road
markings, and increase in local bus service frequencies, to coincide with shift work patterns, are
all supported. The proposed improvements to footways, cycle route and crossings however,
remain vague and clarification on the type of improvements should therefore be provided. In
addition, TfL encourages the applicant to further investigate the possibility of bus stop
relocations and the re-opening of an additional new pedestrian access to Nathan Way, in order
to improve accessibility between the site and public transport amenities.
53 TfL accepts that the additional non-car trips generated by the site will be
accommodated on the public transport network and that this will be further addressed by the
future introduction of new transport schemes in the area. As the site will however directly
benefit from the Greenwich Waterfront Transit service, TfL requests that a contribution be
sought towards its specific stops and services. TfL also requires accessibility improvements at
existing bus stops to be provided. All bus stops located in the vicinity of the site should be
assessed for their accessibility and, where not in conformity to TfL’s standards, funding
through s106 agreement is required to enable their upgrade to full compliance.
54 TfL welcomes the travel plan for the site, which will encourage more sustainable
transport modes. The subsequent initiatives proposed such as car parking management plan,
introduction of car sharing, appointment of travel plan co-ordinator, and regular monitoring
and review are also supported. However, a commitment to implement the identified measures
should be provided at this stage. In addition, TfL would support the introduction of the
Government Cycle Scheme at the site. With the introduction of a travel plan, together with
the expectation of a 10% cycle modal share target, TfL would require the cycle parking
provision on site to be increased in line with TfL’s cycle guidance. The proposed staff shuttle
bus during peak periods between the site and transport amenities such as train and bus stations
is also supported.
55 In the light of the above comments and concerns raised especially in relation to the
highway impact of the development, TfL is not currently in position to support the proposals
and therefore request that additional information be provided to address the outstanding issues
before the application is reported back to the Mayor for a decision.
Local planning authority’s position
56 It is likely that officers will recommend the application for approval.
57 Under the arrangements set out in article 3 of the Town and Country Planning (Mayor
of London) Order 2000 the Mayor has an opportunity to make representations to Greenwich
Council at this stage. If the Council subsequently resolves to grant planning permission, it
must allow the Mayor an opportunity to decide whether to direct it to refuse planning
permission. There is no obligation at this present stage for the Mayor to indicate his
intentions regarding a possible direction, and no such decision should be inferred from the
Mayor’s comments unless specifically stated.
58 There are no financial considerations at this stage.
59 The principle of a training prison within the existing perimeter walls of Belmarsh
prison is acceptable in land use terms. These facilities are required to: provide more prison
spaces in London for Londoners with the aim of regional self-sufficiency; reduce distances
between London prisoners and family/community networks and increase rehabilitation
programmes for young adult, male prisoners with the stated aim of reducing the risk of
prisoners reoffending. The proposal will bring about a significant number of permanent
employment opportunities for prison related jobs.
60 Notwithstanding the above the applicant should address the issues raised in this report
relating to landscaping and the transport issues raised by Transport for London before the
application is referred back to the Mayor for a decision.
61 A full CHP analysis for this site that would lead to the installation of CHP in the short
term with the option to connect to adjacent sites in the longer term is also required at this
stage along with the other energy issues raised. The application is unlikely to be acceptable in
strategic planning terms unless this is completed before the application is referred back to the
Mayor for a decision.
for further information, contact Planning Decisions Unit:
Giles Dolphin, Head of Planning Decisions
020 7983 4271 email firstname.lastname@example.org
Colin Wilson, Strategic Planning Manager (Development Decisions)
020 7983 4783 email email@example.com
James Farrar, Senior Strategic Planner, Case Officer
020 7983 6589 email firstname.lastname@example.org