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Date submitted

24 July 2026

Submitted by

Interested party

Crown Development Application CROWN/2026/0000004 Representation by the Association of Visitors to Immigration Detainees (AVID) The Association of Visitors to Immigration Detainees (AVID) – objects to the proposed expansion of Campsfield Immigration Removal Centre. AVID is the national network of visitor groups supporting people held under immigration powers across the UK. Through our members, independent volunteers regularly enter places of immigration detention. We exist to reduce the immediate suffering of people in immigration detention by providing practical and emotional support. This gives AVID a particular perspective on what detention environments mean in practice: not simply as buildings or pieces of national infrastructure, but as places in which people are incarcerated, often for uncertain periods, without the freedom to leave. There is a volunteer visitor group at every immigration detention facility in the country. Through our members, volunteers enter places that are otherwise largely closed to public view and hear directly from people about the conditions in which they are detained and the effect detention has upon them. Our evidence and advocacy are therefore informed by what people living in detention tell independent visitors about their experiences. It is from this perspective that we ask the Inspector to consider this application. Based on our expertise – our objection is twofold: First, it concerns the planning justification for the development itself: whether a need for expansion on this scale has actually been demonstrated; whether the claimed national benefits are capable of outweighing Green Belt and other planning harms; and whether realistic alternatives have been adequately assessed. Second, it concerns the living environment the development would create for people deprived of their liberty: its scale and institutional intensity, overheating and climate resilience, access to healthcare and services, visiting and social connection, and the cumulative consequences of increasing Campsfield from 160 to as many as 400 detained people.[1] 01. The central claimed need for this development has not been adequately demonstrated The Government (The applicant) expressly identifies national demand for additional immigration detention capacity as the justification for the development. Planning Statement paragraph 1.3 says that the proposed development is made in response to a need to expand IRC provision in the UK. Section 5 is devoted specifically to that alleged need, under the heading ‘Demand’. At paragraph 5.5, goes considerably further, asserting that demand for detention capacity “vastly outstrips supply”. Paragraph 5.10 says that small-boat arrivals and pressure on prison capacity demonstrate an “urgent need” to expand the detention estate. Paragraphs 5.11 and 5.12 assert ‘sustained and increased demand and that national demand exceeds available supply’. [2] The separate Statement of National Importance similarly states that insufficient detention capacity is a “critical bottleneck”, that the sentencing review and the UK-France arrangement have created unprecedented demand, and that the additional 240 places are critical to Government priorities. [3] Those propositions are central to the planning balance and should therefore be capable of careful and rigorous scrutiny. The difficulty is that a Government policy objective to increase removals does not, in itself, establish that an additional 240 permanent detention places are required at Campsfield. These are distinct propositions, and the latter requires its own evidential basis. The Home Office’s own statistics show that, in the year ending March 2026, only 44% of people leaving immigration detention were returned from the UK[4]. In other words, the majority of people leaving detention were not removed at the end of their detention. This is not a new or exceptional pattern. The Home Office has itself reported that the average proportion of people removed on leaving detention between 2015 and 2019 [5] was also 44%. The 44% removal rate recorded in both 2025 and 2026 therefore represents a return to broadly the same level that prevailed during the period in which Stephen Shaw was raising serious concerns about the excessive and inefficient use of immigration detention.[6] [7] AVID’s recent experience at Campsfield also gives this issue a direct and current relevance. Since the centre reopened, AVID has encountered at least two people who have been detained there for close to three months. While individual cases cannot by themselves establish a systemic pattern, they demonstrate that prolonged detention continues to occur at Campsfield and underline the importance of scrutinising whether detention is in fact being used only where there is a realistic prospect of removal within a reasonable period. This evidence is particularly significant because the applicant itself states at paragraph 5.4 of the Planning Statement that detention should be used only where necessary and for the shortest possible period.[2] Taken together, these matters expose a fundamental evidential question which the Inspector should require the applicant to answer: • What evidence demonstrates that the claimed constraint on removals is a shortage of physical detention capacity, rather than the continued use of existing detention places for people who are ultimately not removed, or whose removal is not achievable within a reasonable timeframe? And, more fundamentally: • If, even after the Government’s recent increase in removals, the majority of detention episodes still end without removal, what evidence establishes that the claimed “critical bottleneck” is a shortage of physical bedspace rather than the detention of people for whom removal cannot presently be achieved? 2. The Government refers to demand modelling, but the evidential basis needs proper scrutiny Planning Statement paragraph 5.31 is particularly important. It says: “demand modelling indicates that even more demand, beyond an additional 1,000 places, is required to meet projected case flows.” It then uses that proposition to reinforce the asserted importance of Campsfield. This appears to be one of the most significant factual assertions in the entire planning application. Yet the critical questions are: what modelling; using what assumptions; over what period; based on what predicted detention lengths; based on what predicted removal rates; and after taking what account of alternatives? There is a further concern in the reasoning of section 5. At paragraphs 5.7–5.10 the Planning Statement moves from Government announcements about increasing enforcement and returns to the conclusion that expansion of detention capacity is urgently required.[2] At paragraphs 5.28–5.30 it states that expansion would support immigration enforcement, create resilience and enable higher removal volumes, before asserting that failing to grant permission would have serious consequences for border infrastructure and Government policy. AVID submits that this reasoning risks becoming circular: Government wishes to increase removals → therefore more detention is needed → therefore Campsfield must expand → therefore national need outweighs the harm. It should not be accepted merely because the policy objective itself is politically important. This is especially significant where claimed need is being relied upon to justify development which would otherwise carry substantial planning harms. 3. Green Belt: the applicant's own pre-application advice demonstrates that the evidential case matters The Campsfield site lies within the Oxford Green Belt.[2] The applicant's Planning Statement records Policy ESD14 and acknowledges that development within the Green Belt must be assessed against national Green Belt policy. The Council's pre-application advice is even more important. It concluded that the proposal would constitute inappropriate development causing harm to openness and Green Belt purposes and said that substantial weight should be given to that harm. It stated that a proposal might only be capable of support if accompanied by a robust, evidence-based case, including clear operational evidence and an assessment of alternatives. [8] The current Planning Statement seeks to avoid that conventional very-special-circumstances route by arguing at paragraphs 6.31–6.35 that part of the site is previously developed land, the remainder qualifies as “Grey Belt”, and the development would not fundamentally undermine the purposes of the wider Green Belt. [2] AVID asks the Inspector to examine that conclusion closely. In particular, the fact that part of the land sits within an existing secure perimeter should not by itself obscure the planning reality of what is proposed: substantially greater permanent built development, increased institutional capacity, additional staff and traffic, new supporting infrastructure and the intensification of a secure residential institution from 160 to up to 400 occupants. The Council's own pre-application assessment described the issue as finely balanced and emphasised the importance of clear evidence of operational need and alternatives. If the applicant's underlying evidence of need is weak, that weakness necessarily affects the weight capable of being placed on the public benefits advanced against Green Belt and other harm. 4. A 400-person detention centre is not simply a larger version of a 160-person centre The development parameters show the scale of the proposed change. The Planning Statement identifies an existing operational capacity of 160 detained people and a proposed increase of up to 240, producing a total of 400. It also anticipates an increase in staffing from 256 to approximately 432. [2] That is a 150% increase in detained population. It should not be treated simply as the addition of bedrooms. Four hundred people necessarily generate substantially greater demands upon healthcare, welfare provision, visiting, legal consultations, recreation, exercise, outdoor space, catering, drainage, electricity, water, transport, waste, staffing and emergency response. Planning is concerned with the environment buildings create for the people who occupy them. At Campsfield IRC those occupants have an unusual and important characteristic: they cannot leave. A person living in ordinary accommodation can respond to an intolerable indoor environment in ways unavailable to a detained person. They may leave the building, stay elsewhere, seek cooler surroundings, spend an evening in a park, visit friends or simply go home. A person detained at Campsfield cannot make those choices. Their access to fresh air, quiet, privacy, visitors, exercise, healthcare, shade and alternative spaces is determined almost entirely by the design and operation of the institution. This gives matters such as temperature, ventilation, natural light, crowding, noise and outside space unusually significant consequences. 7. Overheating and extreme heat require specific scrutiny AVID considers the risk of overheating and extreme heat to be a significant and insufficiently addressed aspect of this application. It is both a planning and design issue and a matter directly relevant to the dignity, health and humane treatment of the detained people who will be and are held there. The Home Office’s own mandatory Detention Services Order 06/2018, reissued in March 2026, establishes measurable accommodation standards for Immigration Removal Centres. It requires sleeping accommodation to provide adequate space, lighting, heating and ventilation for health. Importantly, it states that room temperatures must not exceed 28°C, and that where mechanical cooling is required the summertime design temperature should be 23°C ±2°C. [9] These arepart of the Home Office’s own framework for ensuring that detention accommodation is safe and suitable for human occupation. Yet the government’s Planning Statement does not appear to contain any substantive assessment of overheating as a distinct risk. Although the application refers to an Energy Statement and addresses sustainable construction and energy efficiency, this is not the same as demonstrating that the proposed accommodation can remain safe and habitable during prolonged periods of extreme heat. That distinction is particularly important in immigration detention. People detained at Campsfield will not occupy these buildings in the same way as residents of ordinary housing. They cannot decide to leave an overheated building, sleep elsewhere, spend the day in a cooler public space, or simply go home. Their ability to regulate their own exposure to heat is constrained by the secure nature of the institution, the detention regime and the physical design of the accommodation. For that reason, the relevant planning question is not simply whether the buildings comply with ordinary energy-efficiency or ventilation standards. It is whether the applicant has demonstrated that the proposed development will provide safe and humane living conditions for people who are compelled to remain within it.[9] The Inspector should therefore ask: • Has the overheating and thermal assessment modelled the buildings as they will actually function as secure immigration detention accommodation, including the restrictions placed on the people living inside them? That assessment should take account of the practical extent to which windows can be opened; security screens and other restrictions on ventilation; periods when people may be confined to bedrooms; occupancy levels; access to cooler communal areas; the availability of shaded and genuinely usable outdoor space; night-time temperatures; prolonged and consecutive days of extreme heat; future climate scenarios over the lifetime of the development; and resilience in the event of failure of mechanical cooling or electricity supply. During recent periods of extreme heat, AVID and the visitor group currently supporting people detained at Campsfield have already experienced disruption to visits because of the conditions at the centre. On several occasions visits have had to be cancelled during heatwaves in the last three heatwaves declared in England. Visitors have also received direct accounts from people detained inside Campsfield describing bedrooms becoming extremely hot. Those experiences matter because they illustrate the difference between theoretical building performance and the lived reality of a secure institution. The people affected cannot compensate for poor thermal conditions through ordinary choices available to people living in the community. Extreme heat can also interact with the particular vulnerabilities of a detained population. Independent scrutiny of immigration detention, including the Shaw Reviews, the Brook House Inquiry and more recent findings of the Independent Monitoring Boards, has repeatedly documented significant levels of physical and mental ill-health, vulnerability, distress and self-harm among people in detention. In that context, prolonged exposure to excessive heat should not be regarded merely as an issue of comfort. It has the potential to intensify distress, disrupt sleep, exacerbate existing health conditions and increase the pressures within an already restrictive institutional environment. There is therefore an important human-rights dimension to the planning assessment. People deprived of their liberty remain entitled to be treated with dignity and to be held in conditions compatible with their health and wellbeing. Where the State controls virtually every aspect of a person’s physical environment, the responsibility to ensure that environment is safe is correspondingly greater. This makes the physical design of Campsfield especially important. The planning system should not authorise accommodation for hundreds of people on the assumption that shortcomings can later be managed through operational procedures. If the government’s overheating assessment assumes ordinary forms of occupant adaptation — such as unrestricted window opening, free movement between rooms, or the ability to leave the building during periods of extreme heat — those assumptions may not reflect the reality of immigration detention and may materially underestimate the actual risk. AVID therefore submits that the Inspector should require clear and transparent evidence that the proposed accommodation can remain within the Home Office’s own temperature standards during both present-day and foreseeable future extreme weather conditions, taking account of the restrictions inherent in detention. Unless that can be demonstrated, the application has not established that the proposed development will provide an acceptable, safe and humane living environment for its intended occupants. 11. Visitors and connection to the outside world should be treated as essential supporting infrastructure This is an area in which AVID has particularly relevant experience. Independent visitors provide something the institution itself cannot: an ongoing human relationship with somebody who is neither employed by the Home Office nor by the detention contractor. For some people, visitors provide an important connection with family, lawyers, community organisations and life outside detention. The planning register confirms that the proposal includes a separate visitors' building amongst the indicative plans. [1] [2] But the planning question is not simply whether a visitors' building exists. For an institution designed for 400 people, the Inspector should consider whether its capacity and configuration are proportionate to the detained population: sufficient rooms; privacy; accessibility; waiting space; safe pedestrian access; public-transport accessibility; arrangements for legal advisers and voluntary organisations; and facilities appropriate to family and community contact. This is particularly important because isolation from the outside world can exacerbate the experience of detention. Conclusion AVID submits that this application (CROWN/2026/0000004), according to the statement has not demonstrated a sufficiently robust case for expanding Campsfield from 160 to 400 places. The Home Office asserts that additional detention capacity is urgently needed, yet its own statistics show that the majority of people leaving detention are not removed from the UK.[4] Independent scrutiny by the HMIP, IMBs, Shaw Reviews and Brook House Inquiry also points to persistent problems of prolonged detention, vulnerability, self-harm and systemic failure.[6 – 14] Against that background, the Inspector should not treat increased detention capacity as an inevitable or self-evident response to Government removal objectives. The need for this development must be proved, not asserted. Nor can the human consequences be separated from the planning decision. Every additional “bedspace” represents a person who will be required to live in this development and who cannot choose to leave when conditions become unsafe, overcrowded or unbearably hot. People deprived of their liberty are not deprived of their humanity. The fact that they cannot leave makes the quality, safety and necessity of this development more important, not less. AVID therefore asks the Inspector to refuse planning permission. If it is not refused at this stage, we ask that it is determined by public inquiry. The State should not be permitted to build more places of confinement first and justify their necessity afterwards. Bibliography [1] Planning Inspectorate, CROWN/2026/0000004: Campsfield Immigration Removal Centre – Application Information, 2026. The application is for outline permission, with access not reserved, for new accommodation blocks, supporting accommodation, infrastructure, parking and associated works. [2] Home Office / Cushman & Wakefield, Planning Statement – Campsfield Immigration Removal Centre, CROWN/2026/0000004, April 2026. Relevant paragraphs include 1.3; 2.14; section 5, including 5.4, 5.5, 5.7–5.12, 5.28–5.31; and 6.31–6.35. Paragraph 2.14 records reopening at an operational capacity of 160 following the Shaw Review. [3] Home Office, Statement of National Importance – Campsfield Immigration Removal Centre, March 2026. Relied upon by the applicant in support of claims concerning national importance, detention capacity and alleged constraints on removals. See also the analysis of those claims in Amnesty International UK's consultation response. [4] Home Office, Immigration System Statistics, Year Ending March 2026: How many people are detained under immigration powers in the UK?, May 2026. Records 22,586 people entering detention; 51% of leavers leaving on immigration bail; 44% being returned; and explains that bail may arise where there is no immediate prospect of removal. [5] Home Office, Immigration System Statistics, Year Ending March 2025: How many people are detained under immigration powers in the UK?, 2025. Records 10,697 people, or 51% of leavers, leaving on immigration bail and 9,190, or 44%, being removed. [6] Stephen Shaw, Review into the Welfare in Detention of Vulnerable Persons, Cm 9186, January 2016. Independent review commissioned by the Home Secretary examining Home Office policy and practice affecting the welfare of people in immigration detention. [7] Stephen Shaw, Assessment of Government Progress in Implementing the Report on the Welfare in Detention of Vulnerable Persons, Cm 9661, July 2018. Follow-up review covering healthcare, caseworking, safer detention, oversight, staff culture and alternatives to detention. [8] Cherwell District Council, Pre-Application Advice: Campsfield House IRC, 2026. Concludes that Green Belt harm attracts substantial weight and states that a proposal for approximately 400 people would require a robust evidence-based case, clear operational evidence and an assessment of alternatives; describes the planning balance as finely balanced. [9] Home Office, Detention Services Order 06/2018: Accommodation – Lighting, Heating and Ventilation, Version 3.0, reissued March 2026. Contains mandatory instructions. Paragraphs 6–19 include requirements that accommodation be adequate for health, new rooms be audited against Building Regulations/CIBSE standards and non-compliant rooms be taken out of use; the Order contains the applicable thermal and ventilation standards. [10] Brook House Inquiry, The Brook House Inquiry Report, Vols I–III, HC 1789, September 2023. Statutory public inquiry into mistreatment at Brook House IRC. The report resulted in 33 recommendations across ten areas of concern. [11] HM Chief Inspector of Prisons, Report on an Unannounced Inspection of Brook House Immigration Removal Centre, 5–22 August 2024, published November 2024. Found increases in violence and self-harm, longer detention and increased frustration; almost half of respondents reported mental-health problems and 35% said they had felt suicidal while at the centre. [12] HM Chief Inspector of Prisons, Independent Review of Progress at Brook House Immigration Removal Centre, 29–31 July 2025, September 2025. Records progress but states that violence remained too high and further work was required in supporting vulnerable detained people. [13] Home Office, Adults at Risk in Immigration Detention, current statutory guidance. Recognises a general presumption of liberty, strengthened where a person is vulnerable, and states that detention of vulnerable people requires immigration considerations to outweigh individual risk factors. [14] HM Chief Inspector of Prisons, Campsfield House Immigration Removal Centre – Inspection Report, 2018. The final inspection before closure recorded, among other matters, poorly ventilated rooms associated with damp and peeling paint and limitations in communal provision.