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Date submitted

5 August 2026

Submitted by

Interested party

Objection to Application CROWN/2026/0000005: Proposed Expansion of Haslar Immigration Removal Centre I strongly object to this application. The proposal would transform Haslar from a refurbished 130-bed facility into a 600-bed immigration detention centre by adding up to 470 further places. This is not a modest extension. It is a fundamental intensification of the nature, scale and operational consequences of the site. The application is premature, inadequately evidenced and procedurally deficient. It seeks approval in principle for a substantial secure institution in an exceptionally sensitive coastal location before the first phase has even opened or been tested in operation. It also asks the public and the Planning Inspectorate to assess that proposal while important design and operational information remains reserved, redacted or deferred. For the reasons set out below, permission should be refused. 1. The asserted need for this expansion has not been established The Home Office has not demonstrated, through sufficiently clear and site-specific evidence, why an additional 470 detention places are required at Haslar. The refurbished 130-bed centre has not yet reopened. There is therefore no operational evidence from the site concerning occupancy, staffing, healthcare provision, traffic movements, emergency response, flood evacuation, legal and family access, environmental effects or demands upon local services. Nevertheless, the Planning Inspectorate is being asked to approve an almost fivefold increase from 130 to 600 places before the initial facility has admitted a single detained person. That sequence is fundamentally unsatisfactory. It replaces evidence with assumption. It also deprives the decision-maker of the opportunity to evaluate the actual effects of the reopened centre before determining whether such a dramatic intensification is necessary, proportionate or sustainable. A general policy preference for increased detention capacity cannot, without more, establish that Haslar is the appropriate location. The applicant should be required to demonstrate: • the evidence supporting the claimed national and site-specific need; • why existing detention capacity is insufficient; • what reasonable alternatives have been examined, including community-based alternatives to detention; • why 600 places are said to be necessary at Haslar specifically; • why the application is being advanced before Phase 1 has been tested; • whether less harmful sites, designs or scales were properly considered; and • why the identified environmental, humanitarian and infrastructure consequences are said to be outweighed by the asserted need. In the absence of that evidence, the claimed need should be afforded little weight. Planning permission should not be granted speculatively for a development of this magnitude and sensitivity. 2. Flood risk, coastal vulnerability and the impossibility of independent evacuation Haslar occupies a coastal site adjoining the Solent. The applicant’s Flood Risk Assessment acknowledges that parts of the site fall within Flood Zone 3, that the site exceeds one hectare, that it is exposed to surface-water flooding and that the proposed use is classified as “more vulnerable” development. Those matters are especially serious because this is not ordinary residential accommodation. It would be a locked institution. The people held there would have no legal or practical ability to respond independently to a flood warning, leave the site or seek safety. Their survival would depend entirely upon the effectiveness of institutional decision-making, staffing, secure transport and accessible evacuation routes. The Flood Risk Assessment identifies areas of potentially high-risk surface-water ponding and records that the route used to enter and leave the site is itself at high risk of surface-water flooding. The Coastal Modelling Report identifies modelled flood depths exceeding 1.20 metres within the developable area, with typical depths of between 1.20 and 1.50 metres along the south-eastern boundary of the proposed buildings. These are not abstract or negligible risks. The wider Partnership for South Hampshire Strategic Flood Risk Assessment identifies a potential breach location at the Haslar sea wall. Coastal Partners has reportedly advised that, over the lifetime of the development, the site will become increasingly affected by climate change and move further within Flood Zones 2 and 3. Of particular concern is the absence of any current or proposed investment to improve the relevant flood defence, alongside Environment Agency mapping identifying erosion risk by 2055. The applicant relies upon raised floor levels, resilient construction, drainage, flood warnings and a Flood Evacuation Management Plan. Those measures do not eliminate the underlying planning objection. On the contrary, the need for a plan contemplating staged evacuation—and, in an extreme event, evacuation of the entire centre—confirms the gravity of the risk. Moving hundreds of detained people from a secure site is not comparable to evacuating an ordinary residential development. It would require sufficient trained staff, secure vehicles, receiving facilities, emergency-service coordination and routes that remain passable during the very event requiring evacuation. It would also require arrangements for detained people who are elderly, disabled, physically ill, traumatised or experiencing acute mental distress. A written management plan cannot be treated as an answer unless the practical viability of every essential element has been independently demonstrated. The application does not establish with the necessary degree of confidence that up to 600 detained people, together with staff and visitors, could be evacuated safely during coastal flooding, surface-water flooding, severe storms, defence failure or simultaneous disruption to the surrounding road network. The consequences of error would be catastrophic and would fall most severely upon people who are physically prevented from protecting themselves. That is an inherent and weighty planning consideration. 3. Inadequate assessment of healthcare and emergency-service demand The Home Office states that primary healthcare will be provided within the centre. That does not establish that the development will have no material effect upon external healthcare or emergency services. A 600-bed secure institution will inevitably generate requirements that cannot all be met onsite, including secondary care, hospital appointments, ambulance attendance, emergency admissions, mental-health crisis intervention, specialist treatment, medication support and secure escorts. The operational consequences extend further. Police, fire and rescue services, ambulance services and hospitals may be required to respond to medical emergencies, safeguarding incidents, self-harm, psychiatric crises, deaths, disturbances, fires, floods or other major incidents. The proper question is not whether discussions have occurred with the relevant bodies, but whether those bodies have assessed the likely demand and confirmed—on evidence—that they possess the capacity, staffing and infrastructure to meet it without an unacceptable effect upon existing services. General assurances are insufficient. The Planning Inspectorate should require quantified, independently scrutinised evidence addressing ordinary operations, foreseeable emergencies and credible worst-case scenarios. Unless that evidence is produced, the development’s consequences for local healthcare and emergency resilience remain materially uncertain. 4. Human impact and the documented harms of detention This proposal cannot properly be understood merely as the construction of accommodation blocks. Its purpose is to confine up to 600 human beings who are not serving criminal sentences and whose detention is administrative and potentially of uncertain duration. In my professional experience as an immigration lawyer, detention is not a neutral condition of accommodation. It can profoundly damage mental health, intensify existing trauma, separate people from their families and support networks, disrupt legal representation and create acute vulnerability. Those effects are particularly grave for individuals who have experienced persecution, torture, trafficking, bereavement or other serious trauma. The effects do not end at the perimeter fence. They generate foreseeable demands involving medical treatment, mental-health intervention, emergency response, safeguarding, legal and family visits, secure transport, community support and assistance following release. Families and wider communities also experience the consequences of separation, uncertainty and deteriorating mental health. The scale of a 600-bed institution is material. Concentrating hundreds of detained people within a locked environment increases the importance of adequate healthcare, suicide and self-harm prevention, safeguarding, legal access, independent monitoring, staffing, emergency response and humane living conditions. These concerns are not advanced as a request for the Inspector to determine national immigration policy. They are relevant because the human consequences of the proposed use translate directly into the design, capacity, location, staffing, healthcare, transport, emergency-planning and community impacts of the development. The applicant should not be permitted to rely upon the secure nature of the centre when that assists its case—for example, by arguing that detained people will not create recreational pressure upon protected sites—while treating the consequences of involuntary confinement as irrelevant when they expose the proposal’s impacts. Security is not merely a fence on a plan. It is the defining operational characteristic of the development. The same locked nature of the facility that prevents recreational access also prevents independent evacuation, restricts access to families and legal representatives, complicates medical treatment and places detained people entirely in the hands of institutional systems during an emergency. 5. Environmental, ecological and heritage harm This is a sensitive coastal environment near designated habitats, heritage assets and the England Coast Path. The proposal would introduce substantial additional built form, accommodation blocks, fencing, lighting, CCTV, hardstanding, roads, car parking and continuous institutional activity. Those elements have the potential to affect landscape character, visual amenity, coastal openness, public access, heritage setting, wildlife and the experience of residents and coastal-path users. The Habitat Regulations Assessment identifies six European designated sites within the zone of influence. It also identifies potential hydrological and nutrient effects, cumulative effects, disturbance or loss of functionally linked land used by wintering birds, and noise, lighting and visual disturbance. The ecological case therefore depends materially upon mitigation and off-site measures. Permission should not be granted unless the Inspector is satisfied, on complete and publicly examinable evidence, that the mitigation is specific, effective, secured and capable of remaining effective throughout construction and operation. The same care is required in relation to the Haslar Barracks Conservation Area, Fort Monckton and the wider historic coastal setting. The scale, height, massing and appearance of the development cannot sensibly be separated from the decision whether development of this magnitude is acceptable in principle. Yet those are among the matters substantially deferred by this outline application. A later reserved-matters process cannot cure an unacceptable principle of development or guarantee that a development of this capacity can be accommodated without material harm. 6. Traffic, access, waste and operational infrastructure remain insufficiently resolved The development would generate construction traffic, staff journeys, visitors, deliveries, waste collection, healthcare transport, detainee escorts, emergency vehicles and other continuous operational movements. Those demands must be considered cumulatively and in realistic operating conditions. This includes shift changes, emergencies, severe weather, road disruption and any simultaneous requirement for large-scale evacuation. Operational waste would include food waste, medical and potentially hazardous waste, cooking oil, bulky items, electrical equipment, batteries and residual waste. Yet the Waste Statement acknowledges that exact operational volumes will not be known until a future waste strategy is developed. That is symptomatic of a wider defect in the application: the Inspector is repeatedly invited to accept the development in principle while matters essential to assessing whether it can operate acceptably are deferred. Conditions should not be used to postpone the resolution of questions that go to the basic suitability and deliverability of the proposal. 7. Outline permission and withheld information prevent proper public scrutiny The Home Office seeks outline permission with all matters except access reserved. It is therefore asking the Inspector to accept the principle of a 600-bed detention centre before the final layout, scale, appearance and landscaping have been determined. At the same time, important material concerning layout, accommodation, lighting, landscaping, flood evacuation, coastal modelling, ecology, transport, heritage, community impact and the Care and Separation Unit has reportedly been withheld or treated as sensitive. I accept that genuinely security-sensitive details may require appropriate protection. That does not justify depriving the public, consultees or the decision-maker of the information necessary to understand and test the proposal’s environmental, operational and humanitarian effects. The applicant cannot simultaneously argue that the facility will be safe because of detailed secure systems and then withhold so much of the relevant detail that those assurances cannot be meaningfully scrutinised. The coastal modelling itself recognises limitations relating to source data, simplified ground levels, modeller judgment and the possibility that climate-change allowances may change. Modelling is a decision-support tool, not a guarantee. Its assumptions and sensitivity must be capable of independent examination. Once outline permission is granted, the central principle of expanding Haslar to 600 places will have been established. Later stages will not provide an equivalent opportunity to revisit whether this development should exist at this scale and in this location. Procedural fairness therefore requires the essential evidence to be available now. Conclusion This application asks the Planning Inspectorate to approve an enormous expansion before the existing 130-bed centre has reopened; before its actual operational effects can be measured; while essential design matters remain reserved; while important information is unavailable for full scrutiny; and despite acknowledged coastal, flood, ecological and emergency-planning risks. The applicant has not demonstrated that the asserted need for 470 additional places at Haslar outweighs those substantial and unresolved harms. This is not ordinary infrastructure. It is a major locked institution proposed on an increasingly vulnerable coastal site. The consequences of inadequate planning would be borne not only by the surrounding community and public services, but by hundreds of people who would be legally and physically unable to leave or protect themselves. The precautionary course is not to approve the proposal and hope that its defects can later be managed. It is to refuse permission unless and until the applicant can establish, through complete, transparent and independently tested evidence, that the development is necessary, appropriately located, environmentally acceptable, operationally deliverable and safe. On the evidence presently available, it has not done so. I therefore respectfully request that application CROWN/2026/0000005 be refused. If it is not refused at this stage, I request that the Planning Inspectorate examine it through a full public inquiry following the close of consultation. The serious and interrelated questions raised—including flood and coastal risk, climate resilience, emergency evacuation, the scale and asserted need for the expansion, pressure upon healthcare and emergency services, ecology, heritage, public coastal access, detention-related harm, and the withholding or deferral of material information—cannot adequately be resolved through written representations alone. A full public inquiry is necessary so that the Home Office’s evidence, assumptions and proposed mitigation can be examined transparently, challenged by interested parties and properly tested before any decision is reached.