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Date submitted

6 August 2026

Submitted by

Interested party

Dear Planning Inspectorate, Please accept this written submission as we have some error when we were submitting this and did not fully accept the writing. Crown Development Application CROWN/2026/0000005 Written Representation by the Association of Visitors to Immigration Detainees (AVID) The Association of Visitors to Immigration Detainees (AVID) – objects to the proposed expansion of Haslar Immigration Removal Centre (Phase 2). 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. We also have a network of people with direct experience of immigration detention across the UK and furthermore, half of our staff members within AVID team have direct experience of immigration detention including the writer to this submission. It is from this perspective that we ask the Inspector to consider this application. Based on our expertise – our objections are as follow: Firstly, we object to the proposed expansion of Haslar Immigration Removal Centre (IRC), Dolphin Way, Gosport, from an as-yet-unopened 130-bed facility to a total of 600 detained people — an increase of 470 places sought before a single day of operational evidence exists for the site in its current form. Our primary objection, developed in detail below, is that the applicant's own Planning Statement (May 2026) fails, on its own terms, to establish a robust, site-specific evidential case for this scale of expansion. We set out that argument first, because it is decisive: if the need case does not withstand scrutiny, no amount of design, ecological or flood mitigation can make this application acceptable. We then address the human, heritage, flood and ecological harms that follow from the scale proposed. 1. The applicant is seeking to expand a centre that has not yet opened, using a need case that is generic, self-perpetuating and shared verbatim with another application 1.1 Phase 1 has not been tested — the application seeks to build on an evidential vacuum The Government department’s (The applicant) own Planning Statement is unambiguous on this point. Table 3.1 of the Statement describes the existing IRC as "Opening 2027 and outside the application red line," with an operational capacity of 130. Paragraph 6.3 confirms that "the IRC is currently being refurbished and is due to open in 2027." In other words, at the point this application is determined, Haslar IRC will not have accepted a single detained person under its post-refurbishment operating model. There is no data on how the reopened 130-bed centre performs: no evidence on casework throughput, incident rates, self-harm, healthcare demand, legal access, or operationality specific to the reopened facility and its new operator. The application nonetheless asks the Inspector to approve a near-fivefold increase in capacity at this specific site — from 130 to 600 — based entirely on generic national demand modelling rather than any lived operational evidence from Haslar itself. AVID submits that this is the wrong sequence. Planning permission for an expansion of this magnitude should, at minimum, follow a period of operation that allows the reopened centre's actual performance — on casework progression, welfare outcomes, and legal access — to be assessed against the standard the applicant itself sets out in paragraph 5.4 of the Statement, namely that detention should be used "only when necessary and for the shortest period possible." Approving the expansion now asks the Inspector to take entirely on trust that a facility which does not yet exist in its new form will perform well enough, at nearly five times the scale, to justify the harms identified elsewhere in this representation. 1.2 The need case is not site-specific — 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. AVID has separately made representations on the linked Home Office application to expand Campsfield IRC (CROWN/2026/0000004). Comparing the two Planning Statements, the case for need at Haslar is not an independent, site-specific assessment — it is substantially the same national narrative, in places using identical phrasing and even the same paragraph numbering (5.5, 5.10, 5.11–5.12, 5.31 in both documents), applied mechanically to two different sites. Both statements assert, using the same construction, that demand "vastly outstrips supply," that small-boat arrivals and prison capacity pressure demonstrate "urgent need," and that demand modelling shows even more capacity is required "beyond" the places currently sought. A genuine, site-specific case for why Haslar in particular requires an additional 470 places — as opposed to expansion elsewhere, or investment in casework resolution, legal aid and exploring alternatives to detention for the cases the Home Office already holds — should not read as an interchangeable template. The Inspector should treat the reuse of identical justificatory text across simultaneous applications as evidence that the "need" being relied upon is a top-down national capacity target being retrofitted onto individual sites, rather than a bottom-up assessment of what Haslar itself, in its local context, actually requires. Those propositions are central to the planning balance and should therefore be capable of careful and rigorous scrutiny. Paragraph 5.5 of the Planning Statement asserts that demand for detention capacity "vastly outstrips supply." Yet the Home Office's own published statistics — Immigration System Statistics, Year Ending March 2026 — show that only 44% of people leaving immigration detention in that period were returned from the UK. 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 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. AVID asks the Inspector to put the following question to the applicant: what evidence demonstrates that the constraint on removals is a shortage of physical detention capacity, rather than the continued use of existing places for people who are ultimately not removed? Without an answer to that question, grounded in Haslar-specific or at least disaggregated national data, the headline "vastly outstrips supply" framing in paragraph 5.5 is an assertion, not a demonstrated fact capable of carrying the planning balance. 1.3 The consequence of a flawed need case for the planning balance Under paragraph 11 of the NPPF, and in the applicant's own exception-test reasoning on flood risk (paragraph 6.76 of the Statement, which relies on the claimed public benefit of "a nationally important need" to outweigh flood risk), the strength of the need case is not a peripheral matter — it is the load-bearing justification for accepting every other harm identified in this representation, including heritage-equivalent harm to the Conservation Area, biodiversity net loss, and flood risk to a locked population that cannot self-evacuate. If the need case is generic, self-perpetuating and untested at this specific site, it cannot do the work the applicant's own Statement asks it to do at paragraphs 6.71–6.77 in overriding those harms. 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 both phases of Haslar IRC. 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. 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 Haslar 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. Haslar's own inspection history shows the human cost when detention capacity outpaces safeguards We want to bring your attention to the last full inspection on Haslar IRC by full HM Inspectorate of Prisons report (February 2014, attached to this representation) recorded an operational capacity of 170 and a population of around 160 — a centre HMIP described as "one of the smallest" in the immigration detention estate, where "good relationships between staff and detainees underpinned many of the centre's strengths" and 95% of detainees said staff treated them with respect. The proposed development would take the site to 600 — not from that historic 160, but from a phase 1 reopening capacity of just 130, a scale never before operated at this site. AVID's direct experience, through the Haslar Visitors Group and elsewhere in the detention estate, is that the relational and welfare strengths HMIP documented in 2014 are products of scale: visible, engaged management; named officers who know named detainees; a workable daily regime. The applicant's own Design and Access Statement (summarised at paragraph 6.23 of the Planning Statement) confirms that the height of the new accommodation blocks — 12 metres, taller than the site's own 5.2-metre secure perimeter fence — reflects "institutional floor to floor dimension requirements for secure custodial environments." AVID submits that this description is candid and significant: the applicant is not proposing a larger version of the small, converted-barracks IRC that HMIP inspected in 2014, but a new-build, purpose-designed secure custodial institution at a scale and character the site has never held. This point to the human harm that will occur in these scaled up institutions. “The truth is, it’s torture because I’ve got kids, I’ve got a mother I want to talk to in my home country - they are worried as well. I can say it’s torture AND it’s like you get to eat what you don’t want to eat. You don’t have a choice. Just not being free, you know, free to do anything. It’s not healthy, mentally it’s not healthy.” Extract testimonies from a former detained person at Haslar IRC, 2009. AVID does not raise the 2014 HMIP report as a hypothetical concern. It is the most recent full independent inspection of this specific site, and it documents serious, recurring failures rooted in Home Office casework practice and legal aid provision — structural problems that a near-fivefold increase in population will not resolve and may make harder to manage. 3.1 Prolonged and unlawful detention The 2014 report records a man released "into the UK during this inspection after three-and-a-half years in detention," and a case in which Home Office lawyers warned in October 2011 of possible unlawful detention proceedings, yet detention continued until February 2014. A third man had, by the time of inspection, been held for over a year with no prospect of removal within a reasonable period. HMIP's recommendation — that decisions to continue detention "should be based on a realistic appraisal of the prospects of removal, and made in accordance with the law" — restates the Hardial Singh principle the Home Office has repeatedly been found, including at Haslar, to have breached in practice. “People are very low in mood and depressed because of the uncertainty of their situation. Distressing events occur like deaths of your relatives and illness of someone close to you and you can’t even go and visit them at hospital. You also become lazy and get physical pains and relationships break up. Long-term detention without knowing what will happen, you lose hope and you can’t look forward to think about the future. Some people lose their education and some get forced into deportation. Developing arguments – everyone is arguing in there. Then, when you get released can’t cope with the outside world because you have been programmed.” – Extract testimonies from previously held detained person at Haslar(2009) for 9 months. 3.2 Access to legal advice and self-harm 22% of surveyed detained people said they needed an immigration lawyer but did not have one, and only 26% of represented detainees said their lawyer had visited them — a marked decline from 51% at the previous full inspection. HMIP also found that detainees at risk of self-harm or suicide were "too many" times held in the special accommodation unit "without the unit being staffed," meaning that "detainees in crisis could be two locked doors away from a member of staff" — a repeat finding from the previous inspection. 3.3 Use of force, restraint and notice of release Custodial staff carried batons, described by HMIP as "inappropriate" for an IRC. One person was given three hours' notice of release after seven years in detention and sent to bail accommodation "at the other end of the country late in the afternoon." AVID submits that expanding the population exposed to these structural risks by nearly five times, before the reopened centre has demonstrated it can avoid repeating them even at a fraction of that scale, is the wrong order of operations. 4. Heritage harm that the applicant's own local planning authority regards as unresolved Gosport Borough Council's pre-application advice records that four three-storey blocks, 12 metres high, two of which sit within 20 metres of the low-slung, predominantly single-storey historic Haslar Barracks, are "considered overbearing and harmful to the setting of the Conservation Area," such that "substantial public benefits would need to be demonstrated to offset this" harm. The Council went further, describing the applicant's Heritage Impact Assessment conclusion — that the development would be "complementary" to the Conservation Area — as reached without the benefit of plans or elevations, and as producing findings the Council considered "seemingly illogical" and "perverse." The Planning Statement (paragraph 6.22) states that blocks have since been moved "a minimum of 20 metres" from the Conservation Area in response to this criticism, and that landscaping will "soften the impact." AVID notes that 20 metres is the same distance the Council's pre-application advice had already identified as giving rise to harm, and that a landscaped buffer is a mitigation the Council's own 2018 Conservation Area Appraisal had already anticipated would be necessary — not evidence that the harm identified has been resolved. Given that the public-benefit case being relied upon to outweigh this harm rests on the need case addressed in section 1 above, AVID submits the balance does not currently favour the applicant. We asks the Inspector to examine that conclusion closely. 5. Flood risk and the evacuation of a population that cannot self-evacuate The site lies across Flood Zones 1, 2 and 3, with the applicant's own Flood Risk Assessment (paragraph 6.69 of the Planning Statement) acknowledging "moderate risk of tidal flooding" across the central-to-northwest extent of the site and areas of "potential high risk surface water ponding" to the north. Gosport Borough Council's pre-application response records an unresolved internal inconsistency in the applicant's Flood Emergency Management Plan between a description of a breach producing "rapid inundation of the site at short notice" and simultaneous assurance that warning will normally be available — and observes that the secure, locked nature of an IRC, including an extra-secure separation unit that in effect holds people in prison-like conditions, makes evacuation planning materially more difficult than for ordinary residential development. AVID submits this is a basic humanitarian and life-safety concern that the scale of this application makes more acute, not less: nearly five times as many people, none of whom can self-evacuate, held on a coastal site the applicant's own assessment places substantially within flood risk zones. The Planning Statement's argument (paragraph 6.71–6.76) that the Sequential Test need not apply and that the Exception Test is passed rests entirely on the same contested "nationally important need" addressed in section 1. If that need case does not hold, the flood risk balance shifts accordingly. 6. Ecological loss dependent on off-site mitigation that is not yet legally secured The application site is ecologically sensitive, lying directly adjacent to the Solent and Dorset Coast Special Protection Area (SPA) and close to the Portsmouth Harbour SPA/Ramsar site and the Solent Maritime Special Area of Conservation (SAC) . The existing sports field on-site is designated as a "Primary Site" (Core Site G63) for overwintering birds under the Solent Waders and Brent Goose Strategy . The proposed development will result in a devastating net on-site habitat loss of -86.21% . While the applicant proposes off-site credits and the creation of a Brent Geese Reserve at Stubbington , Natural England has warned that the shadow Habitats Regulations Assessment (sHRA) lacks a robust "in-combination" assessment and remains incomplete regarding its legal and financial security . Additionally, GBC’s Ecologist has raised significant objections to the outdated ecology surveys (which rely on data from 2022 and 2023) . No up-to-date bat activity surveys have been conducted despite the direct loss of foraging grassland . Furthermore, the proposed mitigation for the local reptile population—which relies on allowing reptiles to disperse or relocating them by hand without securing an approved off-site receptor—is legally and ecologically unacceptable. AVID submits that habitat loss of this scale should not be treated as resolved at outline stage while the compensatory mechanism remains legally unsecured. 7. Overheating and the humanity of scale As with the linked Campsfield application, AVID is concerned that the applicant has not demonstrated the proposed accommodation will remain safe during extreme heat, in line with the Home Office's own Detention Services Order 06/2018 (reissued March 2026), which sets a maximum room temperature of 28°C. People detained at Haslar cannot leave an overheated building or seek a cooler space; their exposure is entirely determined by the design and operation of the institution. Any thermal assessment must model the buildings as they will actually function as secure detention accommodation, not as ordinary housing. 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? 8. 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. But the planning question is not simply whether a visitors' building exists. For an institution designed for 600 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 should be refused, principally because the applicant's own evidence does not establish that this specific, near-fivefold expansion at this specific, as-yet-unopened site is necessary. The Planning Statement's case for need is generic, shares templated language with a simultaneous application for a different site, and by its own admission (paragraph 5.31) will not be sufficient even if granted in full — meaning it provides no principled basis for concluding that 600 beds, rather than any other figure, is the right outcome for Haslar. That flawed foundation matters because every other harm identified in this representation — heritage harm the local planning authority itself regards as unresolved, flood risk to a population that cannot self-evacuate, and significant on-site ecological loss dependent on an unsecured mitigation scheme — is being asked to be outweighed by that same contested need. Layered on top of this is Haslar IRC’s own history of harm, which shows that even at a fraction of the proposed scale, this specific site has struggled with prolonged and at times unlawful detention, inadequate legal access, an unstaffed crisis unit, and grossly inadequate notice of release. People deprived of their liberty are not deprived of their humanity. Building capacity for hundreds more of them, at a site that has not yet reopened even at a tenth of that scale, on the strength of a need case that admits it has no ceiling, is not a sound basis for a planning decision of this magnitude. AVID therefore asks the Inspector to refuse planning permission. If it is not refused at this stage, we ask that it be determined by public inquiry, given the scale of the proposed change, the untested status of the underlying facility, and the unresolved heritage, flood and ecological objections raised by the applicant's own consultees. The State should not be permitted to build more places of confinement first and justify their necessity afterwards. Supporting References and Bibliography 1. HM Chief Inspector of Prisons, Report on an Unannounced Inspection of Haslar Immigration Removal Centre, 10–11 and 17–21 February 2014 (attached). 2. Home Office / Cushman & Wakefield, Planning Statement – Haslar IRC, May 2026 (application document reference 01LFF32MN34UQB2HHCD5BZE6IDHWU7BPKX), in particular paragraphs 5.4–5.31, 6.3, 6.22, 6.69–6.76, and Table 3.1. 3. Home Office / Cushman & Wakefield, Engagement Report – Haslar Immigration Removal Centre, May 2026 (application document reference 01LFF32MKNRNQFYODP6BBIRN7W3IENUWAG). 4. Gosport Borough Council pre-application advice, Pre-Application No. P.103/026/25. 5. Hampshire County Council Highways pre-application response, 18 March 2026. 6. Home Office, Immigration System Statistics, Year Ending March 2026: How many people are detained under immigration powers in the UK?, May 2026. 7. Home Office, Detention Services Order 06/2018: Accommodation – Lighting, Heating and Ventilation, Version 3.0, reissued March 2026. 8. AVID's separate written representation on the linked application CROWN/2026/0000004 (Campsfield IRC), for comparison of the near-identical need case advanced by the same applicant.