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Date submitted

6 August 2026

Submitted by

Interested party

Reference: CROWN/2026/0000005 Site Address: Haslar Immigration Removal Centre (IRC), Dolphin Way, Haslar, Gosport, PO12 2AW Proposed Development: Outline Planning Application with all matters reserved (except for access) for the expansion of Haslar IRC comprising the development of new accommodation blocks and ancillary supporting accommodation, the conversion and expansion of existing site infrastructure including internal roads, demolition of existing structures, minor amendment to coastal path to accommodate the creation of additional car parking, landscaping and associated site infrastructure. Response: Thank you for consulting Coastal Partners on the above application. Coastal Partners offer the following comments. The site is shown by both the Partnership for South Hampshire's Strategic Flood Risk Assessment (PfSH SFRA) and the Environment Agency's Flood Map for Planning to partially lie within Flood Zones 2 and 3 in the present day, and therefore is at risk from a 1:200 year (0.5% annual probability) extreme tidal flood event. The site will be increasingly impacted by climate change and will move further within the extent of these flood zones within the development’s lifetime. Flood Risk Assessment The applicant has submitted a Flood Risk Assessment (FRA) compiled by 1st Horizon, dated 01/05/26 in support of the application. The FRA states that defence that bounds the site is assumed to be owned by Gosport Borough Council. We can confirm that this is not the case. We wish to reiterate the following comments provided as part of a pre-application consultation for the site under reference P.103/026/25. It is noted that the FRA states that there is ‘no current nor proposed investment to improve the defence’ to the site. Notwithstanding the long term flood risk to the site, the Environment Agency’s National Coastal Erosion Risk Mapping (NCERM) show the site to be at risk of erosion by 2055. Therefore the management and maintenance of these defences is important for the use and safety of the site and its residents. It is important that the FRA or a defence management strategy should explain who owns the existing defences and is responsible for their continued maintenance. How this will be secured and funded for the duration of the development’s planned lifetime should also be stated. This does not appear to have been submitted for this application. The FRA included modelling flood levels for various node points at the site. The node closest to the proposed accommodation is 10 which has a 200 year Higher Centra 2125 PPG flood level of 4.27m AOD and 200 year Upper End 2125 PPG flood level of 4.64m AOD. It is also stated that the Finished Floor Level for any proposed sleeping accommodation should be above 4.64m AOD potentially resulting in raising floor levels between 1.08m and 1.27m depending on the building and its respective aspect. Coastal Partners would strongly recommend that, in line with the latest guidance, finished floor levels should be set at least 600mm above the estimated flood level, especially given that this is for more vulnerable use, placing more people in an area at risk of flooding. The FRA has assessed the flood hazard classification and determined that there would be ‘Danger for Most’ in the area where the accommodation is proposed. We would expect a sequential approach to be taken at the site; whereby more vulnerable uses are placed in the lowest risk area of the site. This has not been achieved with the current proposal. Modelling report The updates made to the coastal modelling report have addressed the majority of the pre-app review comments. However, there are a couple of points that would benefit from clarification. Flooding from the Harbour is considered but a bit of a clearer acknowledgement on the flow path from Haslar Creek would have been a welcome inclusion. Our previous response stated that “the modelling report mentions that the wave overtopping boundaries were based on nearshore wave climate generated using SoN, with SoN itself is based on Met Office WAVEWATCHIII hindcast and Coastal Flood Boundary Dataset (CFBD)”. More explanation on this is required as to whether it is the old or newer (2018/19) CFBD. There appears to be no clear confirmation that this has been updated, or explanation as to why it hasn’t been, therefore we would appreciate confirmation on this from the applicant. Evacuation Management Plan An evacuation management plan has been submitted by the applicant. Whilst Coastal Partners defer to Gosport Borough Council’s Emergency Planning team to confirm the contents of this are satisfactory, it should be noted that the proposed evacuation route for 2122 requires travel across areas of ‘significant’ and ‘extreme’ flood hazard (using the undefended scenario), therefore safe access and egress may not be possible during a tidal flood event for the duration of the lifetime of the development. Should the Planning Inspectorate be minded to grant permission, it is suggested that the defence management strategy and flood resilience and resistance measures should be secured by condition, together with minimum finished flood levels. The Planning Inspectorate should satisfy themselves that they are content with the risks and considerations highlighted in our response and should consider any emergency planning and rescue implications in arriving at their decision. End Note: Coastal Partners makes comments only in relation to tidal flood and erosion risk, and it is for the LPA to consider all other forms of flood risk as required by the NPPF and PPG, taking advice from any relevant consultees. Equally, it is for the LPA to satisfy themselves that any NPPF / PPG / local policy requirements for passing the sequential and exception tests have been met for all forms of flooding, including for tidal risk.