Back to list

Date submitted

6 August 2026

Submitted by

Interested party

Dear Planning Inspectorate Re: Objection to the proposed expansion of Haslar Immigration Removal Centre (Application Reference: CROWN/2026/0000005) I write to object to the Home Office’s application for outline planning permission to expand Haslar Immigration Removal Centre. The proposal seeks to establish the principle of expanding the refurbished Immigration Removal Centre from an intended operational capacity of approximately 130 detention places to a facility capable of accommodating up to 600 detained people. This represents a substantial increase in both the scale and operational intensity of the development and, in my view, requires particularly careful scrutiny before planning permission is granted. I am a prospective resident intending to relocate my family to the Alverstoke/Gosport area in August 2026. We are in the process of making this community our long-term home because of employment, education and family circumstances. As such, I have a genuine interest in whether major developments affecting the area’s environment, public infrastructure, coastal resilience and community character have been properly assessed before planning permission is granted. I appreciate that the Planning Inspectorate’s role is not to determine wider Government immigration policy. My representation is therefore confined to planning matters arising from this application and whether the evidence before the Inspectorate demonstrates that this particular site is suitable for a development of the scale proposed. Having considered the application documents that have been made publicly available, I remain unconvinced that the Home Office has demonstrated that outline planning permission should be granted at this stage. My concerns do not arise from one single issue but from the cumulative effect of a number of significant planning considerations, including: • the suitability of a major secure detention facility on a constrained coastal site identified as being subject to present and future flood risk; • the implications of climate change and sea-level rise throughout the lifetime of the development; • the practicality of emergency access and evacuation arrangements for a secure facility accommodating up to 600 detained people; • the cumulative impact upon healthcare provision, emergency services and local infrastructure; • the environmental, ecological and heritage sensitivity of the surrounding area; • the adequacy of the evidence relied upon to justify such a significant expansion before the refurbished centre has reopened and its operation has been evaluated in practice; and • whether sufficient information has been provided to enable both the public and the Planning Inspectorate to reach an informed decision on the principle of development. Although each of these matters is addressed individually within the application documents, I am concerned that their cumulative implications have not been sufficiently considered. Planning decisions require consideration of how these issues interact rather than treating each technical assessment in isolation. Flood resilience, climate adaptation, emergency planning, healthcare capacity, environmental protection and operational management are closely linked, and it is their combined effect that should inform the overall planning judgment. Throughout the application there is considerable reliance on future operational procedures, future management plans and later stages of the planning process to address important issues. While this may be appropriate for matters of detailed design, I do not believe it should replace the need to demonstrate, at this stage, that the principle of a development of this scale is appropriate for this location. The central question for the Planning Inspectorate is not simply whether individual impacts might ultimately be mitigated. Rather, it is whether the Home Office has demonstrated, through sufficiently robust evidence, that outline planning permission should now be granted for the expansion of Haslar Immigration Removal Centre to approximately 600 detention places. For the reasons set out below, I do not believe that the current application has met that evidential threshold. Flood Risk, Coastal Safety and Climate Resilience The proposed development occupies a constrained coastal location adjacent to the Solent. The application’s Flood Risk Assessment identifies that parts of the site are located within Flood Zone 3, that the site is at risk of surface water flooding and that the proposed use falls within the category of “more vulnerable” development. These are important planning considerations because the proposal concerns a secure detention facility rather than conventional residential or commercial development. The operational requirements of a secure Immigration Removal Centre mean that emergency response arrangements, evacuation procedures and continued access to the site require particularly careful consideration during periods of flooding or other major incidents. The application includes a Flood Evacuation Management Plan and supporting flood modelling. While these documents demonstrate that these issues have been recognised by the applicant, they also illustrate the complexity of managing a secure facility of this scale during severe weather or flood events. The application documents identify potential risks associated with surface water flooding affecting parts of the site and access routes. They also recognise that future climate change, including sea-level rise and increased rainfall intensity, must be considered throughout the anticipated lifetime of the development. The supporting coastal modelling similarly examines future flood scenarios and breach modelling, recognising that coastal conditions will continue to evolve over time. Taken together, these documents indicate that flood resilience is not a peripheral issue but a central consideration in assessing the long-term suitability of the site. I acknowledge that the application proposes a range of mitigation measures, including flood-resilient construction, drainage measures and emergency management procedures. However, in my view, the existence of mitigation measures does not remove the need for the Planning Inspectorate to be satisfied that they would remain realistic, deliverable and effective throughout the lifetime of a secure detention facility accommodating up to 600 people. This is particularly important where emergency evacuation would depend upon secure transport, staff availability, functioning access routes and coordination with emergency services during circumstances in which flooding or severe weather may already be affecting the surrounding transport network. In considering the application, I respectfully ask the Planning Inspectorate to be satisfied that the available evidence demonstrates not only that flood risks have been identified, but that the site would remain suitable, safe and operationally resilient throughout the lifetime of the proposed development, taking account of climate change, coastal flooding, surface water flooding, emergency access and the practical realities of operating a secure detention facility during major incidents. Where significant uncertainty remains regarding these matters, I believe that uncertainty should weigh carefully in the overall planning balance before outline planning permission is granted. Healthcare, Emergency Services and Supporting Infrastructure The application acknowledges that healthcare provision for the proposed Immigration Removal Centre would extend beyond services provided within the site itself. It recognises that detained individuals may require access to secondary healthcare and other specialist services within the wider local area. This is an important planning consideration because a secure detention facility accommodating up to 600 people is likely to interact with a range of existing public services, including hospitals, ambulance services, mental health services, emergency planning arrangements and secure transport providers. My concern is not that detained people should receive anything other than appropriate healthcare. Rather, it is whether the application has demonstrated that the necessary capacity exists within the wider system to accommodate the operational requirements of a facility of this scale without creating unacceptable impacts upon existing public services or local communities. The Planning Inspectorate should therefore be satisfied that the relevant statutory bodies have been appropriately consulted and that there is sufficient evidence demonstrating that the cumulative demands generated by the proposed development can be accommodated throughout its operational lifetime. This includes consideration of matters such as: • access to secondary healthcare; • emergency ambulance provision; • hospital attendances requiring secure escort arrangements; • mental health assessment and crisis support; • emergency planning and major incident response; • police, fire and rescue service involvement where operationally required; and • the interaction between these services during periods of exceptional operational pressure. Planning decisions should consider not simply whether individual organisations may be capable of responding to isolated incidents, but whether the overall public infrastructure supporting the development has been demonstrated to be adequate for a permanent secure facility of this scale. As someone intending to relocate my family to this area, I naturally attach considerable importance to the resilience of local healthcare and emergency services. I therefore respectfully ask the Planning Inspectorate to ensure that sufficient evidence has been provided demonstrating that the proposal can be accommodated without creating unacceptable cumulative impacts upon existing public provision. Transport, Access and Operational Resilience The proposal would significantly increase the operational scale of the existing site. This has implications not only for the movement of staff, service vehicles and deliveries, but also for secure transport associated with healthcare appointments, transfers between facilities, court appearances, removals and emergency situations. The application documents recognise that transport forms an important component of the operational management of the proposed Immigration Removal Centre. Equally, transport infrastructure plays a critical role within the wider flood resilience and emergency planning strategy described elsewhere within the application. For that reason, I believe the Planning Inspectorate should consider whether the available evidence demonstrates that the surrounding highway network and access arrangements would remain sufficiently resilient during both normal operation and foreseeable emergency situations. This is particularly relevant because the flood risk documentation identifies the importance of maintaining safe access and evacuation routes during severe weather events. Where emergency planning depends upon reliable transport infrastructure, the interaction between highway resilience, flood risk and operational management becomes a material planning consideration rather than a purely operational matter. The Planning Inspectorate should therefore be satisfied that the evidence demonstrates: • reliable access for emergency services throughout foreseeable flood scenarios; • practical arrangements for emergency evacuation where required; • sufficient resilience within the surrounding transport network to support the operational demands of the development; • appropriate consideration of construction traffic alongside long-term operational activity; and • realistic assumptions regarding the availability of transport during severe weather or major incidents. Where future operational procedures form part of the proposed mitigation, I believe those procedures should be sufficiently evidenced to enable the Planning Inspectorate to conclude that the proposal is acceptable in principle. Cumulative Infrastructure Impacts One of my principal concerns is that many of the technical assessments consider individual topics separately, whereas the practical operation of a secure detention facility depends upon those systems functioning together. Flood resilience, transport infrastructure, healthcare provision, emergency services, operational management and environmental mitigation are closely interconnected. Each assessment may conclude that its own subject can be appropriately managed. However, planning judgment requires consideration of whether the combined effect of those individual conclusions demonstrates that the development as a whole is appropriate for this location. For example: • emergency evacuation depends upon transport infrastructure remaining available during adverse conditions; • healthcare provision depends upon both NHS capacity and secure transport arrangements; • flood resilience depends upon operational management and emergency access functioning effectively; • construction impacts may interact with transport capacity and emergency access; and • environmental mitigation often relies upon ongoing operational management throughout the lifetime of the development. Taken together, these interactions reinforce the need for the Planning Inspectorate to consider the proposal holistically rather than simply relying upon individual technical reports viewed in isolation. In my view, the application would be strengthened by clearer evidence demonstrating how these cumulative issues have been assessed collectively. Where important elements of that assessment remain dependent upon future operational arrangements or future management plans, I respectfully suggest that the Planning Inspectorate should carefully consider whether sufficient certainty presently exists to justify granting outline planning permission for a development of this scale. Environmental Effects, Heritage and the Character of the Area The application site occupies a particularly sensitive coastal location within an area of recognised environmental, recreational and historic significance. This part of the Gosport coastline contributes to the area’s distinctive character through its combination of coastal landscape, historic military heritage, public access to the waterfront and internationally important ecological habitats. The Planning Inspectorate is therefore being asked to determine not simply whether additional development can physically be accommodated within the site boundary, but whether a substantial expansion of a secure detention facility has been demonstrated to be appropriate within this wider environmental context. In my view, that assessment requires careful consideration of the proposal’s cumulative environmental effects throughout both the construction period and its long-term operation. Ecology and Protected Habitats The application recognises that the site lies within the influence of internationally designated ecological sites, including Special Protection Areas (SPAs), Special Areas of Conservation (SACs) and Ramsar sites associated with the Solent and Portsmouth Harbour. These designations reflect the exceptional environmental importance of the surrounding coastline. The submitted Habitat Regulations Assessment considers a range of potential effects arising from both construction and operation, including matters such as hydrological impacts, nutrient discharge, noise, lighting, visual disturbance and cumulative effects alongside other development. I recognise that the application proposes mitigation intended to address these matters. However, much of the environmental assessment necessarily depends upon assumptions regarding future operational management, ongoing mitigation and long-term compliance. Where mitigation forms an essential part of the conclusion that significant effects can be avoided, I believe the Planning Inspectorate should be satisfied that those measures are sufficiently certain, deliverable and capable of being maintained throughout the operational life of the development. This is particularly important given the international significance of the protected habitats surrounding the site. Coastal Environment and Public Access The coastline surrounding Haslar forms an important public asset that contributes significantly to the identity of the wider area. The application acknowledges that the proposal includes alterations affecting the England Coast Path together with associated operational changes around the site. While changes to access arrangements may be capable of mitigation, the Planning Inspectorate should also consider the wider effect of the proposal upon the character, openness and experience of this section of coastline. These qualities cannot be measured solely by whether physical access remains available. The scale, operational nature and associated infrastructure of a development may also influence how the surrounding coastal environment is experienced by residents and visitors. As someone intending to relocate my family to this community, one of the reasons the area appealed to us is precisely because of its coastal setting, public open spaces and historic character. My concern is therefore not simply whether access can technically be maintained, but whether the cumulative effect of a development of this scale has been sufficiently assessed in relation to the qualities that make this coastline distinctive. Heritage and Sense of Place The application site sits within an area of considerable historic significance, including nearby listed buildings, the Haslar Barracks Conservation Area, Fort Monckton and the wider historic military landscape that contributes to Gosport’s identity. Planning decisions are required to consider not only direct physical effects upon designated heritage assets but also whether development preserves or enhances their setting and significance. The application seeks outline planning permission, meaning that many detailed aspects of the final development—including building appearance, landscaping and elements of site layout—will be addressed at later stages. While this is an established part of the planning system, it inevitably limits the extent to which the completed development can presently be understood. In my view, the Planning Inspectorate should therefore exercise particular care before concluding that the principle of a development of this scale has been demonstrated to be compatible with the surrounding historic environment. Construction, Operational Activity and Environmental Management The proposal would involve a substantial programme of construction followed by the long-term operation of a significantly larger secure detention facility. The application addresses a number of practical matters including construction management, operational servicing, waste management, lighting, drainage and environmental mitigation. I recognise that many of these issues are capable of being addressed through planning conditions and future management plans. However, I am concerned by the extent to which important operational details remain dependent upon future documents that have yet to be prepared. This is particularly relevant where the effectiveness of environmental mitigation depends upon the successful implementation and long-term maintenance of those future arrangements. Planning conditions play an important role within the planning system. However, they should not substitute for demonstrating that the principle of the proposed development is acceptable on the basis of the information presently before the Planning Inspectorate. The Environmental Planning Balance The individual environmental assessments submitted with the application each examine particular topics within their own technical discipline.That is entirely appropriate. However, planning judgment requires those individual assessments to be considered collectively. The question is not whether each technical issue can be considered separately. Rather, it is whether the environmental evidence, taken as a whole, demonstrates that a substantial expansion of a secure detention facility is appropriate in this particular coastal location. Having reviewed the application material, I remain unconvinced that this cumulative assessment has been sufficiently demonstrated. The proposal depends upon numerous future mitigation measures, future operational procedures and subsequent approvals. While these may ultimately prove effective, I believe the Planning Inspectorate should be satisfied now that the environmental consequences of the proposal have been adequately assessed before establishing the principle of development through the grant of outline planning permission. Where important questions remain regarding the interaction between environmental protection, heritage, coastal character, operational management and long-term mitigation, those matters should form part of the overall planning balance when determining this application. The Principle of Outline Planning Permission I recognise that outline planning permission forms an established part of the planning system and can be an appropriate mechanism for determining the principle of development before all detailed design matters have been finalised. However, that approach depends upon the Planning Inspectorate being satisfied that sufficient information exists to conclude that the principle of the proposed development is acceptable. This application seeks outline permission for a substantial expansion of a secure Immigration Removal Centre to accommodate approximately 600 detained people. Given the scale of the proposal, the operational complexity of the development and the environmental sensitivity of the site, I believe the Planning Inspectorate should be particularly satisfied that the evidence presently available is sufficient to justify establishing that principle. In my view, that requires more than demonstrating that individual technical matters may ultimately be capable of mitigation. It requires demonstrating that the proposed development is appropriate for this location when all material planning considerations are considered together. Matters Reserved for Later Consideration The planning system appropriately allows certain matters to be reserved for later approval, including aspects of layout, appearance, landscaping and detailed design. I fully recognise the purpose of that process. My concern is not that reserved matters exist, but whether some of the remaining uncertainties extend beyond matters of detail and instead relate to whether the development has been demonstrated to be acceptable in principle. Throughout the application there is reliance upon future operational procedures, management plans, environmental mitigation, servicing arrangements and implementation strategies. Planning conditions can undoubtedly play an important role in securing these matters. However, where the acceptability of the proposal depends upon future arrangements that have not yet been fully developed, I believe the Planning Inspectorate should carefully consider whether sufficient evidence presently exists to conclude that the principle of the development has been established. Planning conditions should assist in implementing an acceptable development. They should not be relied upon to resolve fundamental questions about whether the development has been shown to be appropriate in the first place. Public Participation and Transparency The planning process depends upon meaningful public participation. Members of the public can only make informed representations where sufficient information is available to understand the likely planning implications of a proposal. I recognise that a secure detention facility inevitably gives rise to operational and security considerations, and that some information may legitimately require restricted disclosure. However, where parts of the supporting material cannot be made publicly available, I believe this increases rather than reduces the importance of ensuring that the remaining evidence is sufficiently comprehensive to allow proper public scrutiny. The Planning Inspectorate has access to information that members of the public may not. Nevertheless, public confidence in the planning process depends upon the decision being capable of being understood and explained by reference to evidence that is available for public consideration wherever reasonably possible. In my view, this is particularly important where the proposal represents a substantial expansion of an existing facility rather than a minor alteration to its operation. Technical Evidence and Remaining Uncertainty The application is supported by a substantial number of technical reports addressing matters including flood risk, coastal modelling, transport, ecology, environmental effects and operational management. These documents clearly represent significant professional work and provide an important part of the evidence before the Planning Inspectorate. However, many of those assessments necessarily rely upon modelling, assumptions regarding future operational management and predictions about long-term environmental conditions. That is an inevitable feature of many planning applications. The relevant planning question is therefore not whether uncertainty exists—because some degree of uncertainty will always remain—but whether the evidence provides a sufficiently robust basis upon which to establish the principle of development. In my view, where conclusions depend upon future operational arrangements, future management plans or long-term mitigation measures, the Planning Inspectorate should carefully consider whether those assumptions are sufficiently certain to justify granting outline planning permission now. Cautious and Evidence-Led Approach Throughout this representation I have sought to focus upon the adequacy of the evidence rather than speculate about future outcomes. I accept that many of the matters identified within the application may ultimately prove capable of being satisfactorily managed. Equally, it is possible that some concerns may prove less significant than currently anticipated. The purpose of the planning process, however, is to determine whether the applicant has demonstrated that the proposed development is acceptable on the evidence currently available. Given the scale of the proposed expansion, the environmental sensitivity of the site and the interaction between flood resilience, infrastructure, emergency planning, environmental protection and long-term operational management, I believe a cautious and evidence-led approach is appropriate. Where significant questions remain regarding the suitability of the site or the practical operation of the development, those questions should be resolved before the principle of development is established through the grant of outline planning permission. Overall Procedural Concern Ultimately, my concern is not directed at the use of outline planning permission itself. Nor is it based upon the fact that future management plans or reserved matters will inevitably follow if permission is granted. Rather, my concern is that the Planning Inspectorate is being asked to establish the principle of a substantial expansion before I am satisfied that all of the material planning considerations have been demonstrated with sufficient certainty. Having considered the publicly available application documents as a whole, I remain unconvinced that the evidence presently before the Planning Inspectorate demonstrates that outline planning permission should now be granted for a development of this scale on this site. For that reason, I believe granting outline planning permission at this stage would be premature. Overall Planning Balance I appreciate that the Planning Inspectorate’s role is to determine this application in accordance with the development plan and other material planning considerations. My representation is not intended to question wider Government immigration policy, nor to oppose development in principle. Rather, it is concerned with whether the Home Office has demonstrated that this particular proposal, on this particular site, has been shown to be appropriate through sufficiently robust planning evidence. Having considered the application documents that have been made publicly available, I remain unconvinced that the evidence presently before the Planning Inspectorate demonstrates that outline planning permission should be granted for the proposed expansion of Haslar Immigration Removal Centre. This conclusion is not based upon any single issue. It reflects the cumulative planning balance arising from the matters addressed throughout this representation. These include: • the suitability of a substantial secure detention facility on a constrained coastal site; • the long-term implications of flood risk and climate resilience; • the interaction between emergency planning, transport infrastructure and operational resilience; • the cumulative implications for healthcare, emergency services and supporting public infrastructure; • the environmental, ecological and heritage sensitivity of the surrounding area; • the extent to which important aspects of the proposal remain dependent upon future operational arrangements and management plans; and • whether sufficient information has been provided to establish the principle of development through the grant of outline planning permission. When these matters are considered collectively rather than individually, I do not believe the application has yet demonstrated that the proposed development has been shown to be appropriate in planning terms. Reasons the Application Should be Refused The decision before the Planning Inspectorate is a significant one. It is not simply concerned with the detailed design of new buildings. It is concerned with establishing the planning principle for a substantial expansion of a secure detention facility that could remain in operation for many years. For that reason, I believe the evidence supporting the application should provide a high degree of confidence that the proposal is appropriate for this location and that its cumulative planning implications have been properly assessed. While the application contains a considerable volume of technical material, I remain unconvinced that it has yet demonstrated, on the balance of the available evidence, that this threshold has been met. For the reasons set out throughout this representation, I respectfully object to the proposed development. In my view, the application should not be approved unless and until the Planning Inspectorate is satisfied that the principle of expanding Haslar Immigration Removal Centre to approximately 600 detention places has been demonstrated to be appropriate for this site through sufficiently robust planning evidence. Where important questions remain regarding flood resilience, infrastructure capacity, environmental effects, operational management and the cumulative interaction between these matters, I believe those questions should be resolved before outline planning permission is granted rather than after it. Accordingly, I respectfully request that the Planning Inspectorate refuses this application. Alternative Request for a Public Inquiry If, having considered the evidence, the Planning Inspectorate is not minded to refuse the application, I respectfully request that it is examined through a full public inquiry before any final decision is reached. This proposal raises complex issues concerning flood risk, climate resilience, environmental protection, emergency planning, infrastructure capacity, public access, heritage, operational management and the adequacy of the evidence supporting the proposed expansion. In my view, these issues would benefit from detailed public examination so that the evidence can be fully tested before the principle of such a significant development is established. Given the scale of the proposal and the sensitivity of its location, I believe that would best serve both the public interest and confidence in the planning process. Concluding Remarks Thank you for considering my representation. I appreciate the responsibility placed upon the Planning Inspectorate in determining applications of this nature and hope that the concerns raised in this submission assist in the careful consideration of the planning issues presented by this proposal. For the reasons explained throughout this representation, I respectfully request that the application be refused. Should the Planning Inspectorate conclude that further consideration is required before reaching a final decision, I respectfully ask that the proposal proceeds to a full public inquiry so that the evidence can be examined in greater detail before the principle of the proposed expansion is determined. Yours faithfully