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Date submitted

11 Sep 2025

Submitted by

Interested Party

Crown Estates Heritage Conservation ECE GT Invicta House County Hall MAIDSTONE ME14 1XX Phone: ████████████ Ask for: Ms Wendy Rogers Email: ██████████████████████████ 11 September 2025 Crown Estates Heritage Conservation ECE GT Invicta House County Hall MAIDSTONE ME14 1XX Phone: ████████████ Ask for: Ms Wendy Rogers Email: ██████████████████████████ 11 September 2025 SENT BY EMAIL Re: CROWN/2025/00000025 - Sevington IBF Thank you for your letter consulting us on the planning application for the Sevington IBF complex. The site of scheme lies within an area of multi-period activity ranging from prehistoric through to modern archaeology. Archaeological investigations have taken place on the site. These investigations revealed important archaeology, most of it of significance, and in view of the limited information on the Kent HER prior to this scheme, the discoveries are a substantial contribution to the understanding of the prehistoric, Roman and Early Medieval activity of the Ashford area but also of the wider South East regional area. These investigations, undertaken by AOC Archaeology, included evidence of Bronze Age activity, an Iron Age trackway which crosses over Highfield Lane and then continues along the line of an existing public right of way, which follows a ridgeline east to west, linking the communities of Sevington, Mersham and on to Sellindge. At the crossroads of this track with Highfield Lane there seems to have developed a Romano-British settlement, industrial and cemetery site. The ridgeline topographical location seems to have made this area a focal point for multi-period burials, including Iron Age and Romano-British cremations and also an Anglo-Saxon cemetery. Towards the south west area of the site was evidence for later Medieval industrial activity associated with a mill and small community. In view of the earthworks needed for Sevington IBF and associated landscape area, the adjacent fields, other side of Highfield Lane, were also subject to archaeological investigations. Associated multi-period archaeology was revealed including a large Bronze Age barrow and continuation of the Roman and Medieval activity and the Anglo-Saxon cemetery. Only key areas of this Stour Park landscape area was investigated and significant archaeological remains survive in this part of the wider scheme. Adjacent and in the nearby area are several historic buildings, the most significant of which is Sevington Church and manorial complex of Church Farm, both designated heritage assets. There are expectations of a medieval settlement being at this location, but so far archaeological investigation has not revealed any settlement remains. However the Sevington IBF application site is surrounded by a variety of medieval and post medieval farm houses and historic residential properties, many of which are designated. Also at the crossroads of the ridgeline trackway and Highfield Lane are the remains of a WWII ROC structure. I welcome the consideration of cultural heritage in Chapter 10 of the ES, with associated figures, and in the Appendices 10.1 Heritage Statement and 10.2 Archaeological Statement. The Sevington IBF (Stour Park) and the Stour Park landscape area have been partially investigated. There is a post excavation report submitted as part of Sevington IBF and post excavation reporting on the land east of Highfield Lane is agreed but is on-going. In addition, the archaeological fieldwork was targeted and selective and some areas were not investigated. Given the significance of the archaeological discoveries here on the high ground above Sevington, there is a need to consider archaeology as a vulnerable and sensitive resource. I had a meeting with the applicant’s archaeological team, Lanpro, and it was agreed that archaeology would be scoped in despite the consideration of the application only referring to operational issues. I did raise concerns over the outstanding post excavation issues for the main scheme and for the adjacent, associated landscaped park scheme. I am disappointed that the main chapter 10 covering Cultural Heritage does not consider archaeology. However I do welcome Appendix 10.2 which provides an Archaeological Statement. I raised concerns about the impact of the operational scheme on the setting and significance of the sensitive archaeology, namely the Bronze Age barrow and the Anglo-Saxon cemetery, and the ROC structure. This is because the Bronze Age barrow, some parts of the Anglo-Saxon cemetery and the ROC unit survive as heritage assets. They have not been removed as part of the Sevington IBF. The Bronze Age barrow has not only been preserved in situ but I believe it has also been subject to positive landscaping, creating a large mound over the ring ditches, thereby providing very welcome heritage interpretation. If this Bronze Age barrow is going to be understood, there may be an impact from the operational side of the Sevington IBF scheme which needs mitigation. Parts of the Anglo-Saxon cemetery were disturbed by the vehicle movements for the Stour Park IBF construction but parts were excavated and are subject to an on-going post excavation programme. However there is potential for associated Anglo-Saxon inhumations to still survive on this adjacent landscape park site. Therefore impact on the setting and understanding of the AS burial site merited some consideration by the operational only Sevington scheme. Also the ROC unit survives at the crossroads of Highfield Lane and the east-west footpath which crosses the landscape site. It is in a vulnerable location with an access point off Highfield Lane into the Sevington IBF site. Impact from the use of this easterly access needs to be assessed but it seems possible that the ROC structure will not be directly impacted. However, as evidence of the country’s civil and military defence network, the ROC unit merits preservation and interpretation. In general, I welcome the inclusion of Cultural Heritage in the Environmental Statement but I am disappointed that archaeology was not considered in more detail. It is essential that any proposals for the associated but adjacent Stour Park landscape area appropriately consider and mitigate the significant and potentially significant surviving buried archaeology. I agree that it is unlikely that operational measures forming this application will impact on buried archaeology but I would stress the importance of assessing the more peripheral impacts arising from the operational scheme, both short term and long term. I remain concerned about the lack of assessment of the impact on the setting and significance of the nearby heritage assets, particularly of the Bronze Age barrow, Anglo-Saxon cemetery and the ROC unit. Despite the statements in the Cultural Heritage section of the ES, there are outstanding archaeological issues. The post excavation programme for the Sevington IBF is not yet complete. This post excavation assessment programme needs to be completed and then used to contribute to a publication. The post excavation assessment programme for the Stour Park Landscape area, associated with Sevington IBF application in view of the disturbance caused by the earthworks, also needs to be completed and then used to contribute to a publication. The archaeological contractor, AOC Archaeology, undertook a high quality and very efficient investigation balancing the needs of the urgently needed development with the significance and widespread nature of the archaeology. As mentioned above, the Post excavation assessment works are still underway although Post Excavation Assessment Reports, setting out a programme of works to inform a publication, in accordance with NPPF requirements, have been agreed. It is vital that this post excavation work is suitably completed. I would welcome updates on the works and the timing of completion. I would also welcome being consulted on the draft publication and how this important information is disseminated and placed in the public domain. The Sevington IBF scheme was established extremely quickly in this area of Ashford and it has had a major impact on the Sevington area. The archaeological discoveries have been outstanding but the dissemination of this information is not completed. I welcome the proposed replication of the Bronze Age barrow, adjacent to the public right of way, but it would be extremely beneficial to also consider archaeological interpretation boards along the footpath and accessible public outreach. This would be a good way to demonstrate the positive outcomes of the development and provide heritage information to the local community. I hope these comments are useful but would be happy to discuss any of the above further. Yours sincerely Wendy Rogers Senior Archaeological Officer Heritage Conservation