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Arguments Against the Super Prison, the JVA in Weißenfels - Statements by BUNDThe decision on whether the JVA – the super prison – will be built in Weißenfels has not yet been made. The BUND has submitted a detailed statement to the Weißenfels city administration, listing reasons from their perspective that speak against the construction of the correctional facility. 
Statement on the 3rd Amendment to the Land Use Plan (FNP) for the Area of Development Plan No. 13 – Special Area Correctional Facility in the Langendorf District, City of Weißenfels; Early Participation According to § 3 Para. 1 and § 4 Para. 1 BauGBDear Mr. Bumann, Dear Sir or Madam, As the Burgenlandkreis regional group of the environmental protection organization BUND LV Sachsen-Anhalt e.V., we see it as our collective task to point out, in the context of such statements, the implementation of legal regulations for compliance with environmental and species protection provisions. This also includes significant interventions that affect the sustainable protection of our landscape and the preservation of our future-oriented livelihoods, such as those concerning social cohesion. Relevant principles and notes can be found in our statement. Regarding the project, we take the following position: 1. Scope of Application and Initial SituationOn June 19, 2025, the Weißenfels city council, in its public meeting, decided with a 3rd amendment to the land use plan in the area of development plan No. 13 to abandon previous plans for an industrial or commercial area in favor of building a correctional facility (JVA). Instead of an industrial area “Am Sandberg,” a competing alternative to the long-term planning of a new JVA in the Halle-Tornau area of the city of Halle is now to be prepared. To date, no final decision has been made by the decision-makers (Justice or Finance Ministry LSA) for either of the two locations. According to § 3 Para. 2 of the Building Code (BauGB), renewed public participation and involvement of public interest bodies (TöB) must take place in Weißenfels. The size of the plan amendment area, located directly at the A9, Weißenfels/Zeitz junction, is 34.4 hectares, slightly smaller than the previously planned industrial area at the same location.Details and the significant environmental and social impacts on people and nature are only inadequately addressed in a mere 11-page justification and an attached plan drawing. The new plans, involving massive building complexes and further sealing through concreted yard and traffic areas, would significantly exacerbate the burdens on nature and environmental protection compared to previous plans. Regarding the construction of a new JVA in Weißenfels and the time- and cost-intensive problems to be resolved, the BUND regional group takes the following position: 1. Fundamental RejectionThe planned designation of a special area for the construction of a correctional facility (JVA) in Weißenfels, replacing the previously planned site in Halle-Tornau by the state of Saxony-Anhalt, is rejected. From the perspective of nature and environmental protection, monument preservation, health protection, and safety aspects, the project is not compatible with the principles contained therein at the proposed location.2. Drinking Water ProtectionThe planned special area for the JVA is located within a drinking water protection zone, one of the most significant drinking water extraction zones for supplying the residents of Weißenfels and surrounding districts, as well as for industry and commerce. The most important industrial consumer with a guaranteed need for high-quality drinking water is Mitteldeutsche Erfrischungsgetränke GmbH (MEG), part of the Schwarz Group.According to the Water Management Act (WHG), extensive usage restrictions and prohibitions must be observed in the building permit process and its implementation. Unfortunately, details regarding the cost increase of the project due to drinking water protection are missing, but they are of utmost importance when comparing the sites. 3. Wastewater DisposalThe statement in the justification for the JVA regarding secured wastewater disposal cannot be adequately substantiated by the project proponent.Connection via a pressurized wastewater pipeline integrated into Marie-Curie-Straße is technically feasible but means that expected wastewater loads of approximately 1,000 to 1,500 population equivalents will be discharged at the upper vertex point into a gravity sewer. This will likely result in significant odor emissions (H2S) from sewer openings due to decomposing wastewater in the residential areas extending to the Saale River. This situation is exacerbated by the existing oversized combined sewer system, leading to significant concrete corrosion and additional maintenance needs. Furthermore, it is expected that the currently available minimal reserve population equivalents will be exhausted by the time the JVA is operational, necessitating the planned expansion of the sewage treatment plant from the current 125,000 population equivalents to 145,000 population equivalents (Stage II) to be implemented concurrently. Whether these additional costs will be fully borne by the state is questionable. A corresponding expert assessment is urgently required for further planning! 4. 110kV Railway Power LineThe existing central crossing of the planned special area by a 110-kV railway power line fundamentally questions the suitability for the JVA construction in Weißenfels. Such a plan requires highly cost-intensive construction measures for the necessary relocation.According to Deutsche Bahn, these can only take place once a concrete plan for the JVA is available. Planning and constructing a new railway power line, along with preliminary archaeological excavations, represent a significant time factor that will further increase the planned construction costs. A construction period of one year is specified for the relocation (source: City of Weißenfels). The provided description lacks corresponding information on costs and expected construction delays! 5. Monument PreservationMeasures for monument preservation are required throughout the JVA planning area, as it is a highly significant archaeological site according to the Halle Monument Preservation Office. According to § 2 of the Saxony-Anhalt Monument Protection Act (DenkmSchG LSA), comprehensive exploration and safeguarding measures are necessary for all areas to be developed. Large-scale soil removals will be required before any construction activity, which inherently precludes any temporal planning. Depending on the findings, a general construction ban may result.6. Noise ProtectionAlthough no preliminary execution plan for the large prison near the A9 in Weißenfels has been attached to the description by the applicant, it can be assumed to be of similar size and design as the previous plans for Halle-Tornau. This means providing space for approximately 440 inmates, including living and sleeping areas, workplaces, and spaces for leisure, sports, and recreation. The distance to the A14 motorway in Halle-Tornau is approximately 215 meters. In contrast, the high-rise buildings of the Weißenfels JVA would be only about 100 meters from the six-lane A9 motorway and the A9/B91 junction. This location in a “traffic noise triangle” requires a determination of the expected noise levels before further planning. According to the Federal Immission Control Act and the Traffic Noise Ordinance, permissible noise levels must not exceed 57 dB(A) during the day (6 AM to 10 PM) and 47 dB(A) at night. Before the JVA Weißenfels can be commissioned, direct construction measures (noise barriers along the A9) and indirect measures on the JVA building (windows, etc.) must ensure compliance with these values. Additionally, plans for a 250-hectare intermunicipal industrial and commercial area (IKIG) east of the A9, with significant traffic volume, must be considered.This would result in significant cost increases and delays in implementation for the Weißenfels site. Before further planning, the relevant expert reports on admissibility and necessary noise protection measures must be provided. 7. Public Safety ConcernsThe proximity of the planned JVA to residential areas in the Langendorf district and the city of Weißenfels raises legitimate public safety concerns.High-security facilities should be built at a sufficient distance from residential areas from an urban planning perspective. This aligns with the precautionary principle and public safety under § 1 Para. 5 BauGB. The previous plans for Halle-Tornau considered distances of 650 to 1,700 meters from residential areas, and the JVA would be situated in open countryside. This is not the case for the Weißenfels site due to the contiguous forest areas up to the town boundaries, significantly restricting the safety needs of residents in urban and peripheral areas. Additionally, the large, heavily frequented shopping center (Kaufland, etc.) on Max-Planck-Straße nearby is a potential attraction for day-release prisoners or other potential threats. Contrary to statements by the city administration and the mayor, there is widespread rejection of the planned JVA construction in Weißenfels across all population groups. The local council of the Langendorf district, in whose area the project would be located, has rejected the construction by a majority. 8. Lack of Alternative AssessmentThe justification for the plan only refers to the abandonment of the Halle-Tornau site.No recognizable alternative assessment (§ 2 Para. 3 BauGB, § 2 Para. 4 UVPG) within the city area or the district by Weißenfels itself is evident. Thus, a legally required comparative site evaluation, particularly considering environmental and safety concerns as well as cost comparisons, is missing. The alternative proposal by the city of Weißenfels to build the JVA at the A9 instead of Halle does not contribute to faster construction but, on the contrary, leads to further delays in the urgently needed modern JVA due to numerous unresolved issues and problems. The additional costs for such delays are estimated by the responsible department head in the Finance Ministry at 20 million euros per year (source: FDP politician Kosmehl). 9. Workforce RequirementsAlmost the entire staff of well-trained correctional officers resides in Halle and its surrounding areas. It remains entirely unclear whether and how many of them would opt to relocate to Weißenfels. The numerous service relationships that would be lost due to a move to Weißenfels must also be considered.In any case, significant follow-up costs for structural development in Weißenfels, such as training new correctional officers, creating housing, and ensuring social infrastructure (kindergartens, schools, medical care, etc.), would arise, potentially all to be borne by the state. 10. DemandConsidering the aforementioned cost and time factors, as well as urgently needed safety considerations, a factual and economically viable alternative for relocating the JVA construction from Halle-Tornau to Weißenfels is not even remotely apparent!The BUND Burgenlandkreis regional group demands that the 3rd amendment to the land use plan in its current form not be pursued further. The concerns of environmental protection, public safety, and residents must take precedence! The statements made by the administration and the mayor regarding approval for the JVA construction in Weißenfels do not reflect reality. Following the sudden public disclosure in early 2025 of plans to relocate the JVA from Halle to Weißenfels, there have been strong citizen protests. In particular, statements in the press about pushing the project through “with a crowbar if necessary” have fueled public sentiment in Weißenfels and led to the formation of a citizens’ initiative against the JVA. Additionally, the following statement in the specially drafted “Letter of Intent” (LOI) to the Minister President of Saxony-Anhalt on March 20, 2025: Quote: “It is of particular concern to the Weißenfels city council and me to involve the citizens of the city and the adjacent Langendorf district in the further planning processes. Despite the need for accelerated decision-making, we will ensure transparent communication and engage in dialogue with the public together.” Unfortunately, it must be noted that these promises have not been fulfilled so far. The claim by the city of Weißenfels that building rights would be granted in 2026 after the new development plan is presented by the end of this year must be strongly doubted (see points 1–10). Given the preparatory construction measures already undertaken with excavators and nearly completed planning for the Halle-Tornau JVA site, a fundamentally different picture emerges in favor of Halle-Tornau. Furthermore, the BUND points out that abandoning the Halle-Tornau site would mean wasting the 5.2 million euros already spent on it. 11. ConclusionThis planning contradicts the principles of sustainable, environmentally friendly, and safe urban development.It endangers drinking water protection and creates difficult-to-resolve problems regarding wastewater, the railway power line, monument preservation, health, noise protection, and the necessary safety of the population. The BUND regional group rejects the planned designation of a special area for a new JVA in Weißenfels. Signed, Thomas Kuhlbroth Chair of the Regional Group Diana Harnisch 1st Deputy Wolfgang Gotthelf 2nd Deputy Notes to be Observed: The objections from the BUND Burgenlandkreis regional group’s statement on the draft of development plan No. 13 for the commercial area “Am Sandberg” in the Langendorf district, city of Weißenfels, dated August 16, 2024, for the planning of an industrial and commercial area remain fully valid, as they also apply to the JVA construction. In particular, due to the necessary preservation of valuable agricultural soil (BWZ 90) and the given nature and species protection considerations, we consider the JVA construction, as well as the now-abandoned industrial and commercial settlement in the “Am Sandberg” plan amendment area, to be impermissible. Should the expected rejection of the JVA construction in Weißenfels occur, we consider the previous plans for an industrial and commercial area “Am Sandberg” no longer feasible. The sudden shift from an industrial or commercial area to a JVA has clearly shown that there is no need for additional industrial and commercial areas in Weißenfels. There are still plenty of larger vacant areas in the city and its districts, particularly in the form of industrial wastelands. Addendum to Our Statement of August 28, 2025; Project: Construction of a Correctional Facility (JVA) “Am Sandberg,” City of Weißenfels (FNP 3rd Amendment)Dear Mr. Bumann, Dear Sir or Madam, 1. Introduction — Purpose of This AddendumThe BUND Burgenlandkreis regional group supplements its previously submitted statement, explaining why, for environmental, spatial planning, and safety-related reasons, the proposed JVA site on the western edge of the A9/B91 (“Am Sandberg” area, approximately 35 ha) is incompatible with the planning objectives and interests of the simultaneously planned intermunicipal industrial and commercial area (IKIG) east of the A9/B91, approximately 250 ha. This addendum calls for specific reviews, expert reports, and procedural steps as prerequisites for a legally secure and responsible decision on the JVA construction.We expressly point out that the BUND LV Sachsen-Anhalt and the members of the regional group firmly oppose the planned development of an intermunicipal industrial and commercial area (IKIG) by the district and individual municipalities, as only unsubstantiated and thus highly questionable benefits have been communicated so far. The need for such an area has not been demonstrated, just as it was not for the previous “Am Sandberg” industrial area. The decisive factor for rejecting the IKIG is the irreversible loss of valuable soil for our future food security. Additionally, there are numerous concerns regarding nature, species, and environmental protection. We have therefore attached a statement from the BUND Saxony-Anhalt state association, which provides a strong justification for this. The focus of our criticism lies in the dual-track approach of the application process, as the proposed JVA construction in Weißenfels is presented as if there were no further plans on the opposite eastern side of the A9 that need to be considered. 2. Summary of Main PointsImage and Location Conflict:The immediate proximity of a high-security facility (JVA) and a large-scale industrial and commercial park impairs the marketability and location image of the IKIG. The IKIG has been marketed as a “beacon” of structural change, but a directly adjacent large JVA shapes the western access. This sends a completely different image, weakening the external perception at the motorway entrance. Cumulative Traffic and Safety Risks: Both projects concentrate significant traffic flows at the A9/B91 junction; without an integrated traffic concept, congestion and hazardous situations are likely (shift changes, visitors, delivery traffic, construction traffic + peak truck traffic from IKIG). Incompatibilities with High-Risk Operations: Potential Seveso/incident-prone operations in the IKIG or other hazardous businesses are difficult to reconcile with a JVA in close spatial proximity. Cumulative Emissions and Disturbance Factors: Noise, light, and emission accumulations, as well as nighttime operational burdens from an industrial park, impair the suitability of the JVA site and lead to usage and conflict risks. If facilities under the 12th Federal Immission Control Ordinance (BImSchV) are involved, safety distances, emergency, evacuation, and access routes for the JVA (high-security facility, visitor traffic) are hardly compatible. This may lead to restrictions on settlements or, conversely, restrictions on JVA safety. Open industrial areas also compromise JVA security (drone drops/smuggling and covert approaches). Collectively, these factors undermine the required “safe and quiet” institutional environment (general planning requirement!). Lack of Comprehensive Spatial Assessment: There is no reliable, comprehensive compatibility assessment between IKIG and JVA (spatial planning coordination under § 1 BauGB in conjunction with regional planning requirements). Two mega-projects directly along the same corridor exacerbate land sealing, landscape fragmentation, and barrier effects across the A9. This weakens the ecological compensation concepts of both projects and impairs retention/cold air corridors (especially since the JVA area was originally designated as the “Am Sandberg” commercial area and is now being repurposed). In June 2025, the city council initiated the 3rd FNP amendment for a special JVA area, while the district, together with municipalities, is advancing the IKIG east of the A9. This requires a comprehensive spatial assessment (§ 1 Para. 6 BauGB) and verifiable compatibility and target assessment with regional and state review – instead of isolated individual procedures! 3. Detailed Addendum Points / Review AssignmentsThe following review assignments are deemed mandatory minimum requirements by the BUND for the further process. We demand that the city and responsible authorities obtain and publicly present the following documents before continuing the FNP amendment and further plan approval procedures:3.1 Integrated Traffic Report (Joint Consideration of JVA + IKIG) Examination of the traffic impacts of both projects in combination (construction and operational phases), including: peak loads from shift changes, JVA visitor traffic, construction traffic, and truck traffic from IKIG. Simulation of congestion and traffic safety risks up to the A9 junction; review of incidents (accidents, road closures) and their impact on JVA escape/emergency routes. Specific required results: capacity assessment of junctions, proposals for structural measures (access roads, turning areas, separate access concepts), truck routing, staggered operating hours, and specific proposals to avoid congestion on the motorway. 3.2 Safety Compatibility Assessment / Seveso-Domino Check Systematic review of whether and which categories of operations (e.g., with incident risks) could be established in the IKIG and what impact their events (fire, explosion, release of hazardous substances) would have on the JVA. Evaluation of necessary protection distances, operational and evacuation routes, and interfaces with police/fire services. Result: binding exclusion criteria or minimum distances for certain types of operations, as well as adjustments to the JVA’s rescue and safety concepts. 3.3 Cumulative Emission Forecast (Noise, Light, Air) Determination of the additive emission situation from the motorway, IKIG operations (24/7 operation possible), and JVA operation/lighting. Inclusion of nighttime considerations and peak events; proof that the JVA environment meets the conditions required for correctional operations (e.g., maintaining peace, good visibility for security functions). If limit exceedances are likely: Proposals for mitigation measures or alternative site assessments. 3.4 Spatial Compatibility Assessment / Alternative Assessment Comparative presentation of alternative sites for the JVA within the city or district area, and explanation of why these should not be considered. Presentation of compatibility with regional structural objectives (IKIG as a priority location for economic development) and determination of whether the JVA impairs the IKIG’s priority. Demand: The FNP amendment must not proceed in isolation; it must be linked to the IKIG planning unless the latter is abandoned for economic and financial reasons. 3.5 Ecological/Landscape Planning Impacts Supplementary study on drinking water protection (also affecting IKIG areas), fragmentation effects, green connections, cold air and retention functions, and necessary compensation areas cumulatively required by both projects. 3.6 Public Participation and Transparency Extension of the display and participation deadlines until the public is informed and the above-mentioned statements and reports are reviewed, considering competing sites. For the IKIG, these would be the Leuna III site and the expansion of the Zeitz Tröglitz industrial park. Conducting a joint public hearing/information event for both projects, moderated by an independent body. 4. SummaryThe BUND regional group calls on the city of Weißenfels and the responsible approval authorities to suspend the FNP amendment for the JVA Am Sandberg until the following documents are prepared and reviewed and integrated into the further process:1. An integrated traffic report for JVA and IKIG 2. A safety compatibility assessment, including a Seveso/Domino check 3. A cumulative emission forecast (noise, light, air) 4. A spatial compatibility and alternative assessment 5. An economic impact analysis on the location’s effect on the IKIG 6. An ecological impact assessment 7. Establishing planning coherence through overarching coordination (region/state) Until these documents are provided and reviewed, the FNP amendment must not be decided. Otherwise, the legal reviewability of the assessment is not ensured. The decision made in the process is a spatially significant determination with considerable impacts on the regional development axis. According to § 1 Para. 6 BauGB, urban planning assessment must be conducted comprehensively; considering the JVA site in isolation without linking it to the IKIG violates the requirement for comprehensive spatial assessment. Traffic and safety-related risks necessitate planning needs that must be clarified before a final determination. Otherwise, remediation and retrofitting costs, as well as irreconcilable location conflicts, are imminent. JVA Weissenfels 3. Aenderung Flaechennutzungsplan Begruendung.pdf JVA Weissenfels 3. Aenderung Flaechennutzungsplan Planzeichnung_Vorentwurf 250515.pdf JVA Weissenfels Bekanntmachung Vorentwurf.pdf Author: AI-Translation - BUND Kreisgruppe Burgenlandkreis | |
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