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Date submitted

5 August 2026

Submitted by

Interested party

We are writing to object to the Home Office’s proposed expansion of Haslar Immigration Removal Centre. We ask that the application is refused. If the application is not refused at this stage, we ask that it is determined through a full public inquiry, for the reasons set out at the end of this letter. This submission is made by Right to Remain. We are a registered charity, charity number 1192934, that works with communities, groups and organisations across the UK. We provide information, resources, training and assistance to help people establish their right to remain and challenge injustice in the immigration and asylum system. Summary of objections Our objection is based on material planning considerations and on the wider human, community and environmental harm caused by immigration detention. We believe that the planning concerns show how the harm of the detention estate reaches far beyond the barriers of the detention centre itself and affects wider communities, local services, ecosystems, heritage and the history and memory of the place. In summary: • • • Haslar has not yet reopened. The Home Office is asking for permission to expand it from 130 places to 600 places before the refurbished • centre has even operated in practice. • • • • The Home Office has not shown why 470 additional detention places are needed at Haslar specifically, or why existing capacity, improved • casework, alternatives to detention or other estate options would not be sufficient. • • • • The site raises serious flood risk, coastal safety and climate change concerns particularly as parts of the site are in Flood Zone 3, • and people detained at Haslar would not be free to leave in an emergency. • • • • The Flood Evacuation Management Plan shows that evacuation would be a serious operational issue, depending on a complex system of warnings, • staff action, staged movement, secure transport, emergency services and local coordination. • • • • The expansion would affect open land, wildlife, coastal habitats and the England Coastal Path. The Home Office relies on mitigation and • offsetting, but this does not remove the loss and disturbance caused by the development. • • • • The proposal raises serious heritage and design concerns, especially because of its relationship with Haslar Barracks Conservation Area. • • • • The proposal would increase pressure on roads, parking, healthcare, emergency services, utilities, drainage, public services and local • infrastructure. • • • • Key information has been withheld or redacted. The public cannot properly scrutinise the full impact of the proposal while important information • on layout, design, landscape, lighting, ecology, flood risk, transport and operational matters is missing or obscured. • • • • The application presents employment, procurement and social value as benefits, which should not be overstated. The Home Office’s own assessment • accepts that people detained at Haslar will not be able to access the local economy. • • • • Immigration detention causes serious harm. The Home Office presents this expansion as neutral infrastructure, but a 600-bed secure detention • centre would have serious human and community consequences. • We recognise that the Planning Inspectorate’s decision will focus on material planning considerations. However, this representation is also part of the public record. Human rights, lived-experience and community concerns should be recorded, especially where they reinforce the need for full scrutiny of a development of this scale and sensitivity. 1. Haslar has not yet reopened Haslar IRC is not currently operating as a reopened 130-bed centre. The Home Office is still in the process of refurbishing the site, with reopening expected in 2027. Despite this, it is already asking for permission to expand Haslar to 600 places. This means the Planning Inspectorate is being asked to approve a major expansion before there is any real operational evidence about how the refurbished centre would work in practice. These issues include: • • • transport and staff travel; • • • • parking and local road pressure; • • • • healthcare demand; • • • • emergency services demand; • • • • flood evacuation; • • • • secure transport arrangements; • • • • the impact on visitors and families; • • • • community impact; • • • • local service pressure; • • • • how the site would operate with people detained there. • The proposal would add up to 470 additional detention places - this is a major increase turning Haslar into a huge detention centre before the smaller refurbished centre has even been tested. The Planning Inspectorate should not accept assumptions about how a 600-bed Haslar would operate when the 130-bed centre has not yet reopened. 2. The need and national importance for the expansion have not been evidenced The Home Office relies heavily on the claim that more immigration detention capacity is needed. In the Haslar Planning Statement, it says the Government wants to increase detention capacity to 3,500 places by 2030, and that Immigration Enforcement has been tasked with delivering 1,000 additional detention bedspaces. This includes the reopening of Campsfield, the reopening of Haslar, the expansion of Campsfield, and the proposed 470-place expansion of Haslar. The Planning Statement also says the expansion of Haslar is “essential” to meeting this need and that the expansion from 130 beds to 600 beds would help increase removals and support wider government enforcement priorities. This claim does not prove the need for this development besides the Home Office’s current political desire to expand detention and it does not show that 470 additional places are needed at Haslar specifically. The public material also does not provide enough detail to properly test the Home Office’s case. It does not clearly set out current IRC occupancy and use, how existing capacity is being used, what operational constraints affect the current estate, how long people are expected to be detained, how many people are expected to be removed rather than released, or why alternatives to detention would not be sufficient. The Home Office’s own Planning Statement says that effective capacity is lower than the headline figure because of operational constraints such as single-sex facilities, isolation requirements, maintenance downtime and contingency headroom. If the Home Office relies on those constraints, it should disclose the evidence behind them. The Planning Statement also refers to demand modelling, including returns history, average bed nights, returns percentage, policy changes, the returns agreement with France. But the public material does not provide enough detail for the public to test those assumptions. The Home Office should be required to explain: • • • why more immigration detention places are needed at all; • • • • why 470 additional places are needed at Haslar specifically; • • • • why the expansion is being sought before the reopened 130-bed centre has operated in practice; • • • • what current IRC capacity, occupancy and utilisation are; • • • • what operational constraints affect existing capacity; • • • • what modelling has been done and whether it can be tested; • • • • how long people are expected to be detained; • • • • how many people are expected to be removed rather than released; • • • • what alternatives to detention have been considered; • • • • why improved casework, early legal advice or community-based alternatives would not reduce the need for detention; • • • • why a locked 600-bed detention centre is suitable on a coastal site affected by flood risk and climate change. • The latest published detention statistics also show why the need for expansion should not be assumed. The number of people held in detention at the end of March 2026 was higher than the previous year, but detention levels had been relatively stable over the previous two and a half years. In the year ending March 2026, more people leaving detention left on immigration bail than were removed from the UK. Detention is often presented as if it directly leads to removal, but the evidence is clear that many people are released back into communities after being detained. The harm has already happened by then, and communities and local services are left to pick up the pieces and further absorb this harm. The Home Office may try to rely on recent Channel crossing figures, increased returns activity, and the UK-France “one in, one out” pilot scheme to argue that further detention capacity is needed. However, those matters do not answer the planning question. The Home Office’s own detention statistics state that the latest increase in detention intake partly reflected the use of detention to facilitate increasing numbers of returns, and that asylum-related cases entering detention increased by 10% during a period when people were being detained under the UK-France agreement. [Home Office, Immigration system statistics, year ending March 2026: How many people are detained under immigration powers in the UK?, section 1.] This suggests that recent detention figures may have been affected by a new and politically specific operational scheme, rather than demonstrating a stable, long-term need for major permanent expansion of the IRC estate. Recent operational fluctuation cannot, without proper evidence, justify permanent new detention infrastructure with such a detrimental impact to the ecology, heritage and community. The UK-France pilot scheme should therefore be tested carefully. The Government has said that, under the scheme, some people arriving by small boat may be detained immediately on arrival and returned to France, with an equal number of people admitted to the UK from France through a legal route. It also stated that Immigration Enforcement had set aside space in Immigration Removal Centres for the pilot. However, the publicly available figures indicate that the scheme was limited in scale by early March 2026, with 377 people returned to France and 380 people admitted to the UK under the scheme. Commentators have also questioned how far the pilot can affect overall trends because it applies to a relatively small number of people. [Home Office, UK-France treaty targeting illegal crossings comes into force, 4 August 2025; House of Commons Library, Unauthorised migration: UK-France border cooperation, 13 May 2026.] If the Home Office relies on increased Channel crossings, the UK-France agreement, or projected returns activity to justify a 600-bed detention centre, it should disclose the evidence behind that reliance. This should include the number of people detained pending possible return to France, average detention periods, the number actually returned, the number released on bail, the number of IRC spaces set aside or required for that scheme, and whether the scheme is expected to continue, expand or remain temporary. The Home Office’s site selection material also needs proper scrutiny. It appears to place strong weight on speed, cost, existing Home Office ownership, value for money and operational convenience. That is not the same as asking what option would cause the least harm. The Home Office should be required to show what alternatives were considered before proposing a major expansion on a coastal, flood-risk site that has not yet reopened. This should include community-based alternatives to detention, better casework, early legal advice and other estate options. In 2015, the Government announced that Haslar IRC would be handed back to the prison estate, and said it did not want to see growth in the number of people held in immigration detention. The current application reverses that direction by bringing Haslar back into the detention estate and seeking to expand it to 600 places. Policy has changed before, and it will likely change again - a 600-bed detention centre, with new buildings, fencing, hardstanding, parking, lighting and security infrastructure, would create long-term enforcement infrastructure of harm felt not just by local communities but across the entire country - people who are detained and released and live anywhere in the UK. The Home Office has not shown that this expansion is necessary. It has not shown that there is a properly evidenced need for 470 additional places at Haslar. It has not shown why existing capacity, improved casework, alternatives to detention or other estate options would not be sufficient. Without that evidence, the Planning Inspectorate should not accept the Home Office’s claimed need or claimed national importance. 3. Flood risk, coastal safety and climate change Haslar is a coastal site next to the Solent. The Flood Risk Assessment says the site is partly in Flood Zone 3, is over 1 hectare, and is at risk of surface water flooding. It also says the proposed IRC expansion is classed as a “more vulnerable” use [1st Horizon, Haslar IRC, Gosport Flood Risk Assessment, Rev E, 1 May 2026, paras 2.1.6 and 1.8]. This matters because Haslar would be a locked detention centre. People detained there would not be free to leave if there was a flood warning, severe weather, a failure of flood defences or another emergency. There are also serious concerns about safe access to and exit from the site during flooding or severe weather. The Flood Risk Assessment identifies two areas of potential high-risk surface water ponding in the north of the site, and states that the route used to enter and leave the site has a high risk of surface water flooding [1st Horizon, Haslar IRC, Gosport Flood Risk Assessment, Rev E, 1 May 2026, para 8.2.3]. Climate change makes these concerns more serious. The Flood Risk Assessment says it must take account of climate change over the lifetime of the development, including sea level rise, increased rainfall intensity, offshore wind speed and extreme wave height [1st Horizon, Haslar IRC, Gosport Flood Risk Assessment, Rev E, 1 May 2026, paras 2.1.3 and 2.2.3–2.2.4]. This is supported by the wider Partnership for South Hampshire Level 1 Strategic Flood Risk Assessment, which assesses flood risk now and in the future, taking account of climate change and cumulative development impacts. The strategic assessment includes East Solent coastal modelling for Gosport to Warsash and identifies a breach location at Haslar sea wall, south of Dolphin Way [Partnership for South Hampshire, Level 1 Strategic Flood Risk Assessment: Part 1 Main Report, 2024, paras 3.6.2 and 3.6.5–3.6.7; Appendix B1, East Solent Model Re-Simulations, 2024]. The Coastal Modelling Report prepared for the application gives sea-level rise estimates from a 2017 base year to 2125 of 1.093m under the higher central allowance and 1.467m under the upper end allowance [1st Horizon, Haslar IRC, Gosport Coastal Modelling Report, Rev E, 17 April 2026, Table 2.3]. Coastal Partners, the council’s flood risk and coastal erosion specialists, have also warned that the site will be increasingly affected by climate change and will move further within Flood Zones 2 and 3 during the lifetime of the development. They also noted that there is no current or proposed investment to improve the flood defence, and that Environment Agency coastal erosion mapping shows the site at risk of erosion by 2055 [Gosport Borough Council pre-application advice / Coastal Partners comments, reproduced in Appendix C to the Haslar Planning Statement]. The Home Office has produced a Flood Evacuation Management Plan and relies on measures such as raised floor levels, flood-resilient construction, flood warnings, staged evacuation procedures and drainage systems. But the existence of an evacuation plan does not remove the planning concern. It shows that flood evacuation is a serious operational issue. The Flood Evacuation Management Plan says Haslar would have capacity for 600 beds and that, in some circumstances, residents may need to be evacuated in stages, with people moved to another IRC or holding centre if transport is delayed [1st Horizon, Haslar IRC Flood Evacuation Management Plan, Rev F, 10 April 2026, paras 2.2.1 and 3.2.1]. It also says that, in an extreme flooding event, the whole site would be required to evacuate [1st Horizon, Haslar IRC Flood Evacuation Management Plan, Rev F, 10 April 2026, para 2.3.4]. The Coastal Modelling Report also shows why the breach scenario needs proper scrutiny. Under the modelled breach scenario, the maximum modelled flood depth within the developable area exceeds 1.20m, and the south-eastern boundary of the proposed buildings shows typical flood depths of 1.20m to 1.50m [1st Horizon, Haslar IRC, Gosport Coastal Modelling Report, Rev E, 17 April 2026, paras 7.1.2–7.1.3]. These are not minor technical details. They are central to whether a locked 600-bed detention centre can safely operate on this coastal site over the lifetime of the development. The Planning Inspectorate should require clear evidence that the proposed arrangements would be realistic and sufficient during coastal flooding, surface water flooding, storms, sea level rise, flood defence failure and emergency evacuation. That evidence should cover people detained at Haslar, staff, visitors, emergency services, escort vehicles, transport providers and the local road network. A plan on paper is not enough. The question is whether evacuation and emergency access would work in practice for a locked detention centre holding up to 600 people. 4. The Flood Evacuation Management Plan does not remove the concern The Home Office has produced a Flood Evacuation Management Plan, but this does not remove the flood risk concern and in fact highlights how flood evacuation is a serious operational issue for this site. The plan confirms that Haslar would have capacity for 600 beds when fully operational [1st Horizon, Haslar IRC Flood Evacuation Management Plan, Rev F, 10 April 2026, para 2.2.1]. It also says that, in an extreme flooding event, the whole site would be required to evacuate because emergency services may not be able to access the site if needed [para 2.3.4]. This is a major concern. Haslar would not be an ordinary residential building where people can leave independently - it is a locked detention centre. People detained there would depend on staff, flood warnings, staged movement, secure transport, emergency services and coordination with local bodies. The plan says evacuation would only happen in extreme circumstances, and that efforts should first be made to move people to lower-risk buildings on site. If this is not enough, people may need to be moved to another IRC or holding centre. The plan also says people may need to be securely held in low-risk areas until secure transport arrives [para 3.2.1]. This raises obvious questions about whether the plan would work in practice. People detained at Haslar may have health needs, medication needs, trauma, mobility issues, language needs, legal appointments, family contact needs or no local support nearby - they cannot simply decide to leave. The plan itself shows a complex picture of moving parts that would need to work at once relying on staff receiving and acting on flood warnings, deploying an evacuation team, moving people in phases, using loud hailers, carrying out roll calls, arranging taxis for some visitors and staff, waiting for secure transport, and coordinating with emergency services [section 4]. There are also concerns about communication. Hampshire County Council’s emergency planning comments raised the need to communicate with people detained at Haslar where English is not their first language [Appendix D]. In an emergency, people need clear, accessible information they can understand and act on. The Planning Inspectorate should require clear evidence that evacuation would work in real life, including: • • • how warnings would be communicated to people detained there; • • • • how people with limited English would be informed; • • • • how people with disabilities, trauma or health needs would be moved; • • • • how medication, healthcare and legal contact would be protected; • • • • how secure transport would arrive quickly enough; • • • • where people would be taken if the site had to evacuate; • • • • whether emergency services could safely access the site; • • • • how staff, visitors, escort vehicles and the local road network would be affected; • • • • what local emergency planning bodies would be expected to do. • Haslar has not even reopened so these arrangements have not been tested with a detained population of 130 people, let alone 600. The Planning Inspectorate should not approve the expansion unless the Home Office can show that evacuation and emergency access would be realistic, safe and sufficient over the lifetime of the development. 5. Wildlife, ecology, open land and the England Coastal Path The expansion would affect open land, coastal habitat and public access to the coast. The Planning Statement says the site includes disused pitches now overgrown with grass and scrub, Haslar Sea Wall car park, and a grassed area through which the Coastal Path runs [Planning Statement, para 2.4]. This is not simply ordinary hardstanding. The Home Office itself describes the new buildings as being proposed “within the wire”, on an area of recreational open space surrounded by a 5.2 metre security fence [Planning Statement, para 6.6]. The proposal would also involve removal of trees and vegetation, new fencing, lighting, CCTV, internal roads, hard surfacing, parking and changes to the England Coastal Path [Planning Statement, paras 3.6–3.9]. The ecology impacts are serious. The Home Office’s engagement material says the proposal would result in a net loss of 86.21% of on-site habitat, with off-site contribution proposed [Engagement Report, para 4.30]. It also says a mitigation package has been agreed for the replacement of Brent geese habitat, including the creation of a Stubbington Brent Geese Reserve [Engagement Report, para 4.31]. That should not be treated as if the harm disappears. Off-site mitigation is not the same as no loss. The proposal would still remove or disturb habitat at Haslar itself, including open land in a sensitive coastal environment. Gosport Borough Council’s pre-application advice also identified ecology as a key planning issue. It said development on a Primary Site in the Solent Waders and Brent Goose Strategy requires suitable mitigation, an up-to-date ecology assessment, 10% Biodiversity Net Gain and evidence of nutrient neutrality [Planning Statement, para 2.19]. Natural England’s pre-application advice also needs proper scrutiny. It said the Shadow Habitats Regulations Assessment lacked a full in-combination assessment, and that the one other project considered was unlikely to be comprehensive [Engagement Report, Appendix C]. This matters because the Planning Inspectorate should not look at Haslar in isolation from wider coastal, housing, infrastructure and environmental pressures. There are also concerns about the England Coastal Path. The proposal includes realignment and “improvements” to the path, but it would also place public access near new fencing, car parking, security infrastructure and a larger detention centre. The Planning Statement says fencing along the car park boundary with the England Coastal Path could be up to 2 metres, while internal and external zonal fencing within the IRC compound could be up to 5.2 metres [Planning Statement, para 3.7]. The Planning Inspectorate should consider whether the route would remain open, safe and accessible, but also whether it would feel narrowed, enclosed or dominated by security infrastructure. The ecology point is not separate from the human point and shows how the Home Office treats life as something to be managed around its enforcement plans. Land, birds, plants, coastal paths, people and communities are treated as things to be controlled, enclosed, offset or moved out of the way. The Planning Inspectorate should require clear evidence on habitat loss, wintering birds, protected species, biodiversity net gain, off-site mitigation, long-term habitat management, lighting and disturbance, construction impacts, the England Coastal Path and the wider coastal environment. The Home Office should not be allowed to treat ecology, public access and open land as problems to be offset later. 6. Heritage, design and the character of the site Haslar is situated beside Haslar Barracks Conservation Area, and the access route to the proposed expansion crosses through the Conservation Area. The Planning Statement also says the site is close to Fort Monckton Scheduled Ancient Monument. The Home Office accepts that great weight should be given to the conservation of designated heritage assets. The proposed expansion includes 4 x three-storey accommodation blocks, around 12 metres high. Gosport Borough Council’s pre-application advice has already raised serious concerns about this [Gosport Borough Council Pre-Application advice, 17 November 2025, reproduced at Appendix I to Cushman & Wakefield, Engagement Report – Haslar IRC, May 2026]. It said two of the blocks would be within 20 metres of low, mainly single-storey historic barrack buildings, and considered the proposed development overbearing and harmful to the setting of Haslar Barracks Conservation Area and that substantial public benefits would be needed to outweigh that harm. This directly contradicts the Home Office’s attempt to present the heritage impact as harmless. The Home Office relies on a Heritage Impact Assessment which says the development would have no harm to designated heritage assets, including Haslar Barracks Conservation Area and Fort Monckton Scheduled Monument. But Gosport Borough Council questioned how a valid assessment could be made when the draft Heritage Impact Assessment had been prepared without the benefit of plans or elevations. The Council also described the conclusion that the development would cause no harm and be “complementary” to the Conservation Area as “perverse”. The Conservation Area Appraisal also says the western boundary should retain a landscaped strip between the historic buildings and future development, with any development needing to avoid being overbearing or harmful to the setting. A 600-bed secure detention centre with large accommodation blocks, fencing, lighting, CCTV, parking, hardstanding and operational traffic needs to be judged against that historic setting. The flood mitigation is also relevant for considering the impact on heritage. Gosport Borough Council’s advice said careful consideration would need to be given to the visual impact of land raising, if this is used as flood mitigation, because of the site’s relationship with Haslar Barracks Conservation Area. This shows how the planning issues are connected and that flood risk cannot be treated separately from design, heritage and visual impact. Local residents and the local MP also raised concerns about the height of the proposed three-storey blocks, privacy, overlooking, screening, windows, fencing and the effect of the proposed buffer zone. The Home Office’s response says detailed building design will progress later through reserved matters. That is not good enough where the Planning Inspectorate is being asked now to accept the principle of expanding Haslar to 600 places. The Planning Inspectorate should require proper scrutiny of: • • • the height, scale and massing of the proposed buildings; • • • • the relationship between the new blocks and the low historic barrack buildings; • • • • the impact on Haslar Barracks Conservation Area; • • • • the impact on Fort Monckton Scheduled Ancient Monument; • • • • the effect of fencing, lighting, CCTV, car parking and security infrastructure; • • • • the visual impact of any land raising for flood mitigation; • • • • views from nearby homes, roads, public routes and the coastal area; • • • • whether the design responds properly to the maritime and military heritage of the site; • • • • whether the Home Office’s claimed public benefits are strong enough to outweigh heritage harm. • The Home Office should not be allowed to rely on broad claims of need while treating heritage and design harm as secondary. The documents show that serious concerns have already been raised by the local planning authority. Those concerns should be tested fully before any permission is granted. 7. Transport, parking, healthcare and local infrastructure The proposed expansion would create a much more intensive use of the Haslar site. The Planning Statement says the expanded IRC would operate 24 hours a day, 365 days a year, and would be run by a private service provider on behalf of the Home Office. It also says staff numbers would increase by 265, taking the total to 414 staff, with shift patterns creating peak staff traffic between 7am–9am and 5pm–8pm [Cushman & Wakefield, Planning Statement – Haslar IRC, May 2026, paras 3.11–3.14]. This should not be treated as ordinary employment traffic, particularly as a secure detention centre has specific operational demands. It would generate staff travel, visitor travel, contractor access, deliveries, escort movements, healthcare trips, emergency access, secure transport, and vehicle movements linked to people being brought to or taken from the site. The Planning Statement says detained people would enter and leave the site by vehicle, except in rare cases where someone is discharged and collected by family [Planning Statement, para 3.18]. The application itself shows that car use is expected to be significant. Hampshire County Council’s highways advice recognises that, because of the security requirements of the employment and the 7am and 7pm shift changeovers, there may be limited take-up of sustainable travel by staff. It also says current bus service timings will be of limited benefit to staff, despite the nearby route 11 service, and notes that Fareham railway station is about 12.9km from the site [Hampshire County Council Highways pre-application advice, reproduced in Appendix G to the Engagement Report]. Parking is also a serious issue. The Engagement Report says the completed scheme would provide between 294 and 302 parking spaces, including up to 259 spaces in the Haslar Sea Wall car park. Hampshire County Council also says it receives regular complaints from local residents about parking along Fort Road and Clayhall Road, particularly around the junction between Fort Road and Dolphin Way [Engagement Report, paras 4.48–4.49 / Appendix G]. The proposed Traffic Regulation Order for Fort Road shows that the application already anticipates pressure around the junction with Dolphin Way and the need to protect emergency access. This should be examined carefully. The question is not only whether there are enough parking bays on paper. The question is how a 600-bed secure detention centre would affect local roads, residents, emergency access, the England Coastal Path, the Haslar Sea Wall car park, visitors, staff and people being transported under escort. The expansion would also increase lighting, fencing, CCTV, hardstanding, internal roads and security infrastructure on a sensitive coastal site. These impacts should be assessed not only as operational requirements, but as planning impacts affecting landscape, ecology, heritage, public access, nearby residents and the character of the coast. Healthcare is also a planning concern. The Engagement Report says healthcare was one of the main themes raised through engagement. Residents raised concerns about potential strain on community services and asked for reassurance that medical support inside the IRC would not affect local healthcare provision [Engagement Report, paras 4.50–4.54]. The Home Office says primary healthcare would be provided on site and that only exceptional accident and emergency needs would be provided by hospitals. But that does not mean Haslar would be self-contained. A 600-bed detention centre could still generate demand for local hospitals, ambulance services, mental health crisis support, medication issues, emergency escorts and secondary care. Gosport Borough Council’s pre-application advice treated suitable health infrastructure as a key planning consideration and said the applicant should consult the Hampshire and Isle of Wight Integrated Care Board. NHS England also recommended further consultation with healthcare providers [Engagement Report, paras 4.51–4.52]. The Planning Inspectorate should require clear evidence on: • • • staff numbers, shift patterns and staff travel; • • • • parking demand and parking management; • • • • daily vehicle movements; • • • • construction traffic and deliveries; • • • • visitor access, including public transport and shuttle arrangements; • • • • secure escort movements; • • • • emergency access from Fort Road and Dolphin Way; • • • • impact on Fort Road, Clayhall Road, Dolphin Way and nearby residential streets; • • • • impact on the Haslar Sea Wall car park and public access to the coast; • • • • pressure on hospitals, ambulance services, mental health crisis support and secondary care; • • • • pressure on police, fire and emergency planning services; • • • • drainage, utilities, waste and long-term site management; • • • • whether local bodies have confirmed that they can safely absorb the extra demand. • The public material does not give enough reassurance that local infrastructure could absorb a locked 600-bed detention centre. Haslar has not reopened yet, so there is no real operational evidence showing how the 130-bed centre would affect transport, healthcare, emergency services or local infrastructure in practice. The Planning Inspectorate should not approve a major expansion before those impacts have been properly tested. 8. Claimed economic and social value benefits should not be overstated The application presents employment, procurement and social value as benefits of the proposal. These benefits should be treated carefully. A 600-bed detention centre should not be justified by general claims about jobs or local spending. The Planning Statement says the construction phase would create 491 additional construction jobs, with a further 364 net additional jobs linked to construction, and estimates a construction GVA uplift of about £19.7 million per year. It also says around 265 additional jobs could be generated once the expanded IRC is operating [Cushman & Wakefield, Planning Statement – Haslar IRC, May 2026, paras 6.112–6.115]. The Home Office links these jobs to social value, saying they could provide opportunities for local people who are unemployed or have “poor labour market contributions” [Planning Statement, para 6.112]. Gosport Borough Council’s pre-application advice also says improving the skills of the local population is one of the most critical issues for the borough’s economy and residents, and says the development should meet local skills and training policy requirements. The Planning Inspectorate must properly scrutinise these claims and not accept this at face value. The Home Office has not shown that these would be secure, good-quality, well-paid jobs that would meet local need and failed to provide enough public evidence about pay, conditions, local recruitment, training routes, retention, staff wellbeing, or whether the jobs would be direct public-sector roles or contractor roles. The Home Office’s own Local Community Impact Assessment also gives a more limited picture of local economic benefit. It accepts that people detained at Haslar are unlikely to have any socio-economic impact on local businesses because Haslar would be a secure IRC and people detained there would not be able to leave or access the local economy [AtkinsRéalis, Haslar IRC: Local Community Impact Assessment, Rev 3.0 final, 21 May 2026, section 5.1.2]. That means the claimed local economic benefit rests mainly on construction activity, procurement and jobs connected to operating the centre. It does not come from Haslar being part of the local community in the ordinary sense and the people locked within the detention centre would be deliberately cut off from the local economy and the wider area. The Local Community Impact Assessment also describes the operational employment effect as a “relatively insignificant boost” compared with the wider local labour market [Atkins Réalis, Haslar IRC: Local Community Impact Assessment, Rev 3.0 final, 21 May 2026, section 5.1.2]. That should be given real weight. The Planning Inspectorate should require clear evidence on: • • • what jobs would actually be created; • • • • how many would be permanent; • • • • how many would be local; • • • • pay, conditions and skill levels; • • • • whether jobs would be direct Home Office jobs or contractor jobs; • • • • what training and progression routes would be available; • • • • how staff wellbeing, retention and safeguarding would be supported; • • • • what procurement would stay in the local area; • • • • what social value commitments would be legally secured; • • • • whether the Skills and Training Plan would be enforceable; • • • • how long construction benefits would last; • • • • whether claimed benefits would outweigh the planning, environmental and community harms. • The Home Office’s social value language should be treated with caution. A detention centre is not ordinary employment development and jobs linked to confinement, security, surveillance and enforced removal should not automatically be treated as a social good, especially where the Home Office has not shown that they would provide decent, secure and genuinely beneficial work for local people. The proposal itself is controversial and the fact that the Home Office carried out engagement should not be treated as evidence of local support. The Engagement Report records serious concerns about planning, highways, parking, healthcare, design, heritage and transparency. Engagement is not the same as resolving those concerns and does not equate to consent. Training plans, procurement promises and engagement commitments cannot remove the planning harms or the human consequences of expanding immigration detention. Jobs and procurement cannot erase flood risk, ecological harm, heritage harm, pressure on services, lack of public scrutiny, or the harm caused by detention itself. 9. Key information has been withheld, so the application cannot be properly scrutinised This application cannot be properly scrutinised on the public material currently available. The Home Office has applied for outline planning permission, with all matters reserved except access [Cushman & Wakefield, Planning Statement, Haslar IRC, May 2026, para 1.1]. This means the Planning Inspectorate is being asked to decide whether the expansion should be allowed in principle, before the final layout, scale, appearance, landscaping and other details are fixed. That is serious because, if outline permission is granted, the basic principle of turning Haslar into a 600-bed detention centre would already have been accepted. Later reserved matters would deal with the detail, but the public may not get another meaningful chance to challenge whether the expansion should happen at all. The public information is also limited. The Planning Statement says only three plans are submitted for approval: the Site Location Plan, Existing Site Plan and Proposed Site Access Plan [Planning Statement, para 1.5]. It then lists several important plans as being provided “for information” only, including the indicative site layout, development parameters, elevations and sections, floor plans and roof plans, landscaping plan and lighting plan [Planning Statement, para 1.6]. These plans are described as official sensitive information and “not submitted for approval or public consideration”, but only to assist the decision-maker [Planning Statement, footnote 1]. These are not minor details as they go directly to the public’s ability to understand the development affecting questions about scale, height, massing, design, visual impact, heritage, lighting, landscape, ecology, flood safety, access, movement, outdoor space, and how the site would operate. The Secretary of State’s sensitive information direction makes this concern stronger. It treats the entirety of several documents as sensitive information, including general arrangement plans for accommodation blocks, the Care and Separation Unit, dining hall plans and sections, and the Biodiversity Net Gain calculation spreadsheet [Annex A, Secretary of State Direction, Sensitive Information in Application Documents]. Other important documents have also been redacted, including the Transport Assessment, Travel Plan, Heritage Impact Assessment, Lighting Assessment, Landscape and Visual Impact Assessment, Flood Risk Assessment, Flood Evacuation Management Plan, Coastal Modelling Report, Ecological Impact Assessment, Habitat Regulations Assessment, Biodiversity Net Gain material, Local Community Impact Assessment and Design and Access Statement [Annex A, Secretary of State Direction, Sensitive Information in Application Documents]. Some security-sensitive information may need to be protected. However, this cannot justify leaving the public without enough information to understand the planning impacts. The public cannot properly respond to a proposal of this scale if key material about layout, design, movement, lighting, ecology, transport, flood evacuation, landscape, heritage and operation is missing or obscured. This is especially important because Haslar is not an ordinary development. It would be a locked 600-bed detention centre on a coastal site affected by flood risk and climate change, close to heritage assets, open land, coastal habitat and public access routes. The withheld information may be material to the decision. The Planning Inspectorate should require the Home Office to provide enough information for proper public scrutiny, redacting only what is genuinely necessary. If some information cannot be made public, that does not weaken the need for scrutiny. It strengthens the case for a full public inquiry, where the Home Office’s evidence can be tested properly. 10. The application is silent on the harm detention causes The Home Office presents the expansion of Haslar as infrastructure. The Planning Statement says Immigration Removal Centres form part of Immigration Enforcement’s infrastructure and that the proposal responds to a need to expand IRC provision. However, the Home Office fails to acknowledge the well documented harm the infrastructure causes to people. Immigration detention is not neutral accommodation - it is the deprivation of liberty, with no time limit, for administrative immigration purposes, often affecting people who have not been convicted of any crime. The harm caused by detention has been repeatedly documented by official reviews, inspection bodies, monitoring boards, parliamentary inquiries and people with lived experience. The Shaw Review, formally the Review into the Welfare in Detention of Vulnerable Persons, was commissioned by the Home Secretary and examined Home Office policies and operating procedures affecting the welfare of people detained in immigration detention. The follow-up Shaw report assessed the Government’s progress and looked again at healthcare, casework, safer detention, oversight, staff culture and alternatives to detention [Shaw, Review into the Welfare in Detention of Vulnerable Persons, Cm 9186, 2016; Shaw, Assessment of government progress in implementing the report on the welfare in detention of vulnerable persons, Cm 9661, 2018]. The House of Commons Home Affairs Committee’s 2019 report on immigration detention found serious problems across the detention system, including wrongful detention, detention of vulnerable people, prolonged detention, weak safeguards, poor casework and harm to mental health and wellbeing. The Committee said the Home Office had shown a “shockingly cavalier attitude to the deprivation of human liberty and the protection of people’s basic rights” [House of Commons Home Affairs Committee, Immigration detention, HC 913, 2019]. That inquiry also heard evidence from people with lived experience of detention, including people formerly detained at Harmondsworth, Morton Hall and Yarl’s Wood. This matters because detention harm should not only be understood through policy language. People who have been detained have described the fear, uncertainty, isolation and damage caused by being locked up without knowing when detention will end [House of Commons Home Affairs Committee, Immigration detention inquiry, oral evidence, 20 March 2018]. The Brook House Inquiry also shows why the Home Office should not be allowed to present detention expansion as routine infrastructure. The public inquiry investigated the mistreatment of people detained at Brook House Immigration Removal Centre between 1 April and 31 August 2017. Its findings show that serious abuse and degrading treatment can happen inside immigration detention, and that safeguards have failed before [K Eves, Brook House Inquiry Report, 2023]. The most recent evidence is also serious. The Independent Monitoring Board 2025 National Annual Report: adult prisons, young offender institutions and immigration detention found systemic failings across immigration detention. IMBs reported prolonged and unnecessary detention, failed safeguards, healthcare delays, barriers to legal advice and interpretation, routine use of force and isolation, serious self-harm and suicide attempts. The IMB also reported that many people detained were ultimately released, often after prolonged periods in detention, meaning detention had caused harm without leading to removal [Independent Monitoring Boards, Independent Monitoring Board 2025 National Annual Report: adult prisons, young offender institutions and immigration detention, 2026]. This is the system the Home Office wants to expand at Haslar. Haslar also has its own detention history. HM Inspectorate of Prisons recorded in 2014 that Haslar was the UK’s oldest operating IRC, had held people under immigration powers since 1989, and had been formally redesignated as an IRC in 2002. The site closed in 2015. The current proposal would not simply reopen that history, but expand it into a 600-bed detention centre [HM Inspectorate of Prisons, Report on an unannounced inspection of Haslar Immigration Removal Centre, 10–21 February 2014, 2014]. The impact of Haslar would not only be felt in Gosport. People detained there could be taken from anywhere in the UK. People released from Haslar could return to communities anywhere in the UK. Families, friends, support groups, faith groups, legal advice services, healthcare services and local communities are left to pick up the pieces after detention. The Home Office cannot treat these harms as if they are outside the planning process entirely. A 600-bed detention centre is not neutral infrastructure. It is part of the infrastructure of enforcement: reporting, raids, detention and deportations. It carries harm into every place it touches. 11. The application should be refused or determined by public inquiry For the reasons set out above, we ask that the application is refused. The Home Office has not properly evidenced the need for 470 additional detention places at Haslar. It has not shown why this expansion is needed before the refurbished 130-bed centre has reopened. It has not shown that existing detention capacity, improved casework, community-based alternatives or other estate options would not be sufficient. The planning harms and unresolved questions are serious. The proposal raises concerns about flood risk, coastal safety, climate change, flood evacuation, ecology, public access, heritage, design, transport, healthcare, emergency services, local infrastructure and public scrutiny. These issues go to the heart of whether a locked 600-bed detention centre can safely and appropriately operate on this site - these are are not minor details that can be left to later management plans or reserved matters. The application also relies on withheld and redacted information. The public cannot properly test the Home Office’s claims while key information remains unavailable. This is especially serious because the application is for outline permission, with all matters reserved except access. The Planning Inspectorate is being asked to accept the principle of expanding Haslar to 600 places before the full details are settled. If the application is not refused at this stage, it should be determined through a full public inquiry. The use of the Crown Development route makes this even more important. This proposal would normally be decided locally by the local planning authority. However, under the Crown Development route, the local authority is reduced to consultee status and the decision is removed from ordinary local determination. We believe this should mean more scrutiny is given to the application. This application raises complex and disputed questions of fact and evidence, including: • • • whether there is a properly evidenced need for 470 additional detention places at Haslar; • • • • whether the claimed national importance has been made out; • • • • whether the site is safe over the lifetime of the development; • • • • whether flood evacuation would work in practice for a locked 600-bed detention centre; • • • • how climate change, sea level rise, surface water flooding, coastal flooding and flood defence failure affect the site; • • • • whether emergency services could safely access the site during flooding or severe weather; • • • • how the proposal affects open land, wintering birds, protected species, habitat loss, biodiversity net gain and off-site mitigation; • • • • how the proposal affects the England Coastal Path and public access to the coast; • • • • how the proposal affects Haslar Barracks Conservation Area and nearby heritage assets; • • • • whether the height, massing, layout, fencing, lighting and security infrastructure are acceptable in this location; • • • • whether transport, parking, healthcare, emergency service and local infrastructure impacts have been properly assessed; • • • • whether claimed jobs, procurement and social value benefits should be given significant weight; • • • • whether the withheld and redacted information prevents proper public scrutiny. • Planning Inspectorate guidance says an inquiry is appropriate where evidence needs to be tested through formal questioning, where issues are complex, or where substantial local interest means a hearing would not be enough [Planning Inspectorate, Criteria for determining the procedure for planning, enforcement, advertisement and discontinuance notice appeals, 5 August 2024]. The Crown Development guidance also says that, where an application is subject to a sensitive information direction and that sensitive information could be material to the decision, it will be appropriate to determine the application by inquiry. We believe this applies to this application as the withheld material is not peripheral and will likely affect the assessment of layout, scale, design, safety, flood evacuation, ecology, lighting, transport, welfare, operational impacts and cumulative effects - all of which are central planning issues. There is also substantial public interest in this application. Haslar is controversial locally and nationally. It raises serious questions about immigration detention, public scrutiny, climate risk, coastal safety, ecology, heritage and the use of an exceptional national planning route. In combination, the scale of the proposal, the sensitivity of the site, the flood and climate risks, the ecological and heritage issues, the withheld information, the human impact of detention and the level of public interest all weigh strongly in favour of refusal. If the application is not refused, those same factors weigh strongly in favour of a full public inquiry, where the Home Office’s evidence can be properly tested. For these reasons, we object to the application and ask that it is refused. If it is not refused at this stage, we ask that it is determined by public inquiry.