No, I don't think so at all. It's pretty much completely flat other than the points at which you have to get up off the beach to the road and then the (low) sea wall which is actually more of a levee.
The only things I found tough about it were the heat -- it was somewhere around 30 degrees that day and there's NO shade, and the bits on the beach. I haven't done much running on sand, so found it a bit of a challenge. That said, it's only the start that's on loose sand and that doesn't last that long before you go up onto a road. Toward the end you're back on the beach a bit, but last year the tide was out so you could go out on the harder sand. Even with the tide in I don't think it'd trouble anyone too much.
I really enjoyed this race. Interesting landscape, odd non-standard distance, runners of ALL levels. Despite the heat and feeling like I took it really easy, I was only 5 mins behind my 1/2 mara PB. Only thing tough about it really is that quite long stretches are on paths that in last summer's heat had baked very hard and lumpy, so if you only ever run on roads it's a bit harder, but no biggie.
I'm doing it again this year -- go for it!