Objection to Beachlands Development Application by Save Our Island Dave Parham
- Anne Skennerton
- 23 hours ago
- 4 min read
Save Our Island has written a careful analysis of the Beachlands, together with illustrative diagrams.
Please note: The author Dave Parham's full document with photos is available from hello@ or HIRA.
Save Our Island wish to record a strong objection to APP/25/00781 for change of
use from commercial fair site to residential site for 55 flats in 5No. 4 storey blocks
with associated parking and landscaping.
The major justification in the application is based on the fact that this site was
allocated for housing in the 2014 HBC Local Plan. This Plan was rejected by the
Inspectorate in 2022 in part because there was no consideration of coastal flood
risks or a mitigation plan included. A new Local Plan was required to be submitted,
and that is currently in progress. The flood risk mapping in place for the 2014 Local
Plan was based on EA data at the time. In 2025, the EA revised their flood risk map,
and the new map clearly shows a much higher level of risk to the whole of Hayling
Island with approximately 50% of the area now in Zone 3, with an additional large
area at risk of inundation resulting from climate change from 2070.
As a consequence, HBC has determined with the new Local Plan that no new
housing will be allocated on Hayling Island because the single A3023 bridge/road
access route is within the Cat 3 flood zone which also covers most of the Island.
The area of the Beachlands’ proposal is contained in the 3, 2, & Climate Change
zones.
The Planning Statement for this development says this development:
“ will make a valuable contribution towards meeting HBCs housing need. “
However, there is no longer a sustainable case for additional housing on Hayling
Island. In fact, as a result of the 2025 EA flood risk mapping, HBC have determined
that new permanent housing on Hayling Island is no longer considered economically
viable in any way, and will further increase the number of families placed at risk with
increasing inundation of the land mass as a result of climate change.
The applicant has engaged Ardent Consulting Group to provide a report named
Flood Risk Assessment & Drainage Statement FINAL (FRA), which can be found
under FILES in the application. This report is referred to numerous times in the
following sections.
The applicants’ statement that no further flood risk (sequential) assessment is
required for this application (see 3.1 FRA) cannot be justified in light of the EA
reappraisal of the risk to the health and welfare of the Island community. Relying on
an allocation made 10 years before the EA 2025 reappraisal of flood risk is
unsupportable. The revised 2024 NPPF (see Ref 180 below) clearly recommends a
new sequential test where significant new flood risks arise – as is the case here.
Therefore, a new flood risk analysis should be mandated by the HBC Planning
authority.
The Coastal Partners’ Shoreline Management Plan categorises the Hayling Island
beachfront as “hold the line” but that is recognised as aspirational and subject to
funding being available. This funding is not guaranteed and has proven to be hard to
justify based on the EA cost/benefit algorithms.
The rock groynes noted (see 6.10 FRA) are intended to control the natural east to
west migration of the shingle beach. Rock groynes will not prevent the annual – and
dangerous – overtopping, which is the reason for sea flooding along all of the 4km
south beachfront. There is no factual evidence to support the consultant’s opinion
that the development will be protected from coastal erosion throughout its lifetime.
This development is on the south beach of Hayling Island. The latest EA flood risk
maps for planning show that the whole coastline – and 50% of the land mass – are in
Cat 3 flood zones. This area also includes the single-access A3023 route via
Langstone Bridge and a large portion of the Island road network. During flooding
events, access to the Island by road transport, emergency services, primary care
services and parental & guardian access to schools will all be curtailed.
The FRA does accept that the area will flood from sea incursion, but the presentation
used (see PIC 2) covers up to 2065 only. This represents a point in time 30 years
following construction – not the 100-year period that the NPPF requires a
development to be safe and sustainable for (as presented in the EA Planning
Climate Change Map. (See PIC 3.)
Picture 2 also specifies a “dry” route to the development for emergency vehicles, but
it does not cover the NPPF-required lifetime period. Also, the “dry” route identified in
the 2065 presentation as indicated by the green arrows in picture 2, from 2070 will
be in the Climate Change and Cat 3 flood zones indicated in picture 3. And the last
100m of that emergency route to Sea Front is not a road. It is a shingle pathway
providing foot access to the beach. It is marked PRIVATE and has a gated barrier to
restrict vehicle access. (See PIC 4)
Editor's note: please contact HIRA for the full document for full information and illustrative photos and graphics.
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