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Date submitted

23 July 2026

Submitted by

Interested party

We contend that there are powerful and clear reasons for the Secretary of State for Housing, Communities and Local Government not to grant permission for this development. We object to the expansion of Campsfield House firstly on humanitarian grounds, on the basis that immigration detention is a cruel practice which has no place in a humane migration policy. A Green Government would end the routine use of immigration detention. However, in the substance of what follows we expound on the various material planning considerations which mark out why this application is so unsuitable for the proposed development. We outline these reasons with our substantial claim being that the Home Office has failed to make a coherent and evidenced based case for building and running the new facility and that, therefore, this application should be refused. We contend this on the basis of the following factors: 1- The Need for this development is not proven: The Home Office has failed to provide any evidence to support its claim that further immigration detention spaces are needed. As such, the claim for overriding “national importance”, which is required for developments under the Crown Development Route, is not made out. The Home Office’s own data on the use of detention capacity, in fact, disproves the case for expansion. Across Immigration Removal Centers, more than a quarter of places were empty in March 2026. This equates to 651 empty places out of a total of 2356. As this shows, the claim that a lack of space is a barrier to government policy is manifestly not proven. It is also important to point out that a majority (approximately 56%) of people who left immigration detention over the past year remained in the UK. To echo David Neil, the former Independent Chief Inspector of Borders and Immigration, this raises longstanding questions about why these people were detained in the first place, given the absence of any reasonable prospect of removal. As this suggests, it is likely that the availability of existing space could be further maximised if the UK Home Office complied with its own policies. This, of course, further undermines the case for expansion of this facility being a matter of overriding ‘national importance’ as it shows that the barriers to current policy objectives lie more in the failure of government departments to comply with their own stated policies, than they do in a lack of available space. 2- Reliance on Unevidenced assertions. The case put forward by the Home Office makes a number of unfounded assertions. For example, it states that the proposal represents ‘value for money’. However, no financial information is provided to support this assertion. As such, the application rests on unproven foundations and should be reverted to the applicant to ensure that there is an evidential foundation for the claims made in the proposal. In any regularised planning proposal, the absence of evidence to support the application would suggest that the application was not ready for approval. Given this, we would submit that the Secretary of State for Housing and Local Government should refuse the application and require the Home Office to fully substantiate their claims. 3- Inappropriate use of former Green Belt site: The expansion is a direct contradiction of the national vision, echoed in the current local plans of both Oxford City and Cherwell District Councils, for the area where Campsfield House is located to form a part of a science, innovation and business district at the heart of the Oxford-Cambridge ‘growth corridor. The land on which this proposal focuses was released from the Green Belt as a part of the Cherwell District Local Plan Partial Review 2020. The rationale at this time was to facilitate high-value employment sites and economic growth as a part of the development of the Oxford Technology Park. This expansion would be sited in the centre of this area that was designated for high–value employment such as digital science and engineering. A detention facility would not provide the kind of employment for which this land was released from the Green Belt. While the Oxford City Green Group does not endorse the lab focused development that is envisaged under either local or government plans, it notes the need for Secretary of State to be consistent with both national and local planning policy when making a determination on this application and contends that this use of the land to expand Campsfield does not deliver this consistency. In coming to this conclusion we note the response of former Oxford West and Abingdon MP Nicola Blackwood (Conservative Party)to the previous application for expansion of this site where she stated that she ‘[Could not] see how this Local Plan Policy, calling for “higher value employment uses such as high technology industries in the research and development sector”, could possibly be interpreted to include employment at an Immigration Removal Facility.’ Given that the application documents outline that this is land which ‘has not been previously developed’, we argue that its use for the expansion of Campsfield House would also be incompatible with the purpose of its removal from the Green Belt, this further making the case for the Secretary of State to deny this application. 4- Impact on Local Community: The expansion has not been factored into the current local plans of either Cherwell District Council or Oxford City Council. As such, the increased strain that the expansion would place on local roads and water and sewage have not been accounted within either the Adopted or Proposed Local Plans of either authority. Impacts on other local services such as healthcare and social care have also note been accounted for. Indeed, the submitted planning documents outline that it would be necessary to move a Thames Water pump, which may directly affect local households and this, again, does not appear to have been given appropriate consideration. Of particular concern in terms of roads is the fact that the access roads proximate to the facility are narrow and would not be fit for large scale transportation vehicles or coaches of the kind which would be necessary to allow charter flights, thus frustrating the stated purpose of the development. As this suggests, the proposed development risks significant disruption to the local community and may, even after this disruption, be ill suited by local infrastructure to deliver on the purpose identified by the Home Office. In light of this, we would suggest that it would be Irrational for the Secretary of State to approve the development. Further, the Secretary of State should note that detaining traumatised people has well documented negative effects on the health and well being of those who are detained. The impacts of those treating people who have been detained, in a manner that exacerbates existing trauma, falls on local services and charities. As such, the Secretary of State should also be mindful of the impact on broader local communities and organisations. 5- The Planning Documents contain significant redactions that make genuine analysis on planning grounds impossible: For a standard planning application the applicant needs to provide adequate detail to enable the application to be considered on planning grounds. However, within the applicant documents, the Home Office has redacted key information such as floor plans and all matters relating to the movement of people within the space. This means that analysis of the welfare and safety dimensions emerging from the plan is not possible. Additionally, the transport assessment has been redacted which means that it is not possible for the application to be assessed in terms of its impact on highways. This makes analysis by both respondent individuals, organisations and authorities and the Secretary of State for Housing, Communities and Local Government on standard planning grounds impossible. As such, it cannot be said that the applicant has appropriately engaged regarding the impact on highways and the application should be refused. These redactions mean that the consultation is procedurally improper in that local organisations and individuals have not been equipped to properly assess the merits of the application. In the absence of information, it is fair to assume that relevant assessments such as consideration of the impact on transport are not satisfactory and this again tends towards a refusal of the application. 6- Significant Opposition from Local Communities: In 2018, Campsfield House was thankfully closed following a long running local campaigning effort. This effort included activities from the District, City and County Councils as well as impacted Parish Councils. Faced with the prospect of the return and expansion of Campsfieldhouse, Cherwell District Council and Oxford City Council have both passed motions in opposition to the re-opening and development of Campsfield House. Further, Oxford City Council is a recognised and accredited City of Sanctuary, while Oxfordshire County Council have declared themselves a County of Sanctuary. With both signing up to the values of the City of Sanctuary initiative. Additionally, both the University of Oxford and Oxford Brookes University have committed themselves to the values of the University of Sanctuary initiative. As this shows, local organisations– in representing the views of local communities– are clearly opposed to the expansion of this facility. In light of the above, The Secretary of State should also consider the impact on local communities of being required to host further Immigration Detention, given that such a clear and consistent view that such practices are cruel and vindictive has been expressed. This includes potential impacts on community cohesion. Residents of Oxford and Oxfordshire have already expressed significant concern at the activities of immigration enforcement agents in the city and broader county. Many residents, understandly, view their presence as both unwanted and as having a damaging impact on community cohesion. We submit that further development of Campsfield would exacerbate these sentiments and therefore cause significant harm tof the local community. 7- The proposals ignore clear evidence on viable alternative approaches: Following an extensive national enquiry Sir Steven Shaw concluded that immigration detention was not only harmful to those detailed, but also wasteful and inefficient. Specifically, it was identified that community based approaches were actively cheaper and thus resulted in the attainment of better value for money. Following his review, Campsfield was one of four centres to be closed. The fact that alternatives which, following the findings of the Shaw review, can be said to be proven more cost effective have not been considered undermines the claim that this development is value for money. Further, the Shaw reviews findings undermine the claim that this development is a matter of ‘national importance’ as other policy avenues which do not require this intrusion onto local planning control would be possible if the Home Office were to depart from seeking to expand a practice that has already been proven, within Home Office commissioned reviews, to be ineffective and wasteful. 8- Inappropriate use of the Crown Development Route: This application by the Home Office which, as identified above, is without a clearly identified matter of ‘national importance’ represents a misuse of the Crown Development Route. This is because, as identified above, neither the case for the importance of the development nor the material planning factors required to secure permission have been made out. It is notable that this application has been retrieved from the planning Inspectorate by the Secretary of Housing and Local Government. This leaves a situation where one Secretary of State is asked to make a determination on a proposal by another. We contend that this represents a dangerous precedent which strips control from local communities and eliminates the power of Local Authorities to effectively plan for service delivery and sustainable development within their local authority area. The Prime Minister has identified his belief that power operates best when decentralised and has pledged to empower local and regional authorities, we contend that the use of the Crown Development route in this manner is incompatible with his stated position. Acknowledging that this application was logged prior to his taking office, we hope that the government now intends to deliver on his words and commit to regional and local devolution. The withdrawal of this application would be a show of good faith in this regard. For the reasons outlined we argue that the Secretary of State for Housing Communities and Local Government should not grant permission for this development to proceed. As identified in the introduction, we have focused squarely on matters relating to planning and the Crown Development Route. But we note here that Immigration Detention is a cruel and inhumane practice which causes harm both to those detained and to those forced to live with this scourge on the doorsteps of their communities. Study after study has shown that the use of immigration detention facilities, as well as other large sites, is significantly more expensive than housing people with irregularised immigration status within communities. As such, while we have responded to the specifics of the application to expand Campsfield, we encourage the Secretary of State, when refusing this application, to ask that the Home Secretary consider a return to evidence based policy and an abandonment of the kind of gimmick laden performative cruelty that this expansion represents. To this end, we have provided an initial list of research that the Home Secretary might find illuminating: 1- https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/728376/Shaw_report_2018_Final_web_accessible.pdf 2- ███████████████████████████████████████████████████████████ 3- █████████████████████████████████████████████████████ 4- ██████████████████████████████████████████████████████ 5- █████████████████████████████████████████████████████████████