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Date submitted

11 Aug 2025

Submitted by

Interested Party

***PINS note: Although attachments are cited in this correspondence, and these have been sought when the representation was submitted, these have not been supplied. Nevertheless, for transparency, we have retained the representation as on the website. Crown Development Case Team*** Marcus Huntley ███████ Planning Department Ashford Borough Council Civic Centre Tannery Lane Ashford, Kent TN23 1PL FORMAL OBJECTION – Planning Application [Reference Number] – Sevington Inland Border Facility, Mersham, Ashford, TN25 6GE Dear Sir/Madam, I am submitting this formal objection to the above planning application for the continuation and expansion of the Sevington Inland Border Facility (“the Proposal”). This objection is lodged on the basis of material planning grounds, demonstrating clear and measurable breaches of the National Planning Policy Framework (NPPF), the Ashford Local Plan 2030, and statutory environmental obligations. ⸻ 1. Unacceptable Highways Impact The continuous 24/7 operation of this facility will generate a sustained increase in HGV traffic volumes on the A2070, M20, and surrounding local roads. • This constitutes an unacceptable impact on highway safety and a severe residual cumulative impact within the meaning of NPPF paragraph 111. • The Applicant’s Transport Assessment is inadequate, relying on outdated data and failing to model peak disruption scenarios (including Operation Brock and emergency diversions). • Policy TRA7 (The Road Network and Development) of the Ashford Local Plan is breached as the proposal will clearly prejudice the free flow of traffic and highway safety. ⸻ 2. Noise, Light, and Amenity Harm The proposed 24-hour operation, involving refrigeration units, vehicle movements, security sirens, and high-intensity floodlighting, will result in constant noise and light pollution. • This is contrary to NPPF paragraph 185, which requires developments to avoid noise giving rise to significant adverse impacts on health and quality of life. • It also breaches Policy ENV3a (Landscape Character and Design) and Policy ENV4 (Light Pollution and Promoting Dark Skies) of the Ashford Local Plan. • The Environmental Noise Report provided by the applicant fails to assess cumulative impacts from concurrent port and logistics activities in the vicinity, which is a fundamental methodological flaw. ⸻ 3. Air Quality and Environmental Non-Compliance Prolonged HGV idling and the use of diesel-powered refrigeration units will cause elevated nitrogen dioxide (NO₂) and particulate matter (PM₂.₅) emissions. • This is a direct breach of NPPF paragraph 186 and Policy ENV12 (Air Quality), which requires development to demonstrate no significant adverse impact on air quality. • The proposal fails to comply with Part IV of the Environment Act 1995 and associated Air Quality Management Area duties. • The absence of mitigation measures for emissions from refrigeration units is an omission so significant it renders the Environmental Statement legally deficient. ⸻ 4. Irreversible Visual and Landscape Damage The scale of the built form, hardstanding, and perimeter security infrastructure is entirely incompatible with the existing rural and agricultural character of the site and its surroundings. • This conflicts with NPPF paragraph 174, which requires planning decisions to recognise the intrinsic character and beauty of the countryside. • It breaches Policy SP1 (Strategic Objectives) and Policy ENV3a of the Ashford Local Plan, which mandate protection of valued landscapes. ⸻ 5. Lack of Ongoing Need and Policy Justification This facility was presented to the public as a temporary, emergency measure post-Brexit. The applicant has not demonstrated an evidenced, long-term operational necessity. • Permanent authorisation of such a disruptive and environmentally damaging use without compelling public need risks breaching section 38(6) of the Planning and Compulsory Purchase Act 2004 by failing to determine in accordance with the development plan. • This also raises a potential ground for judicial review on the basis of irrationality and procedural unfairness, should consent ⸻ 📎 APPENDIX PACK — Objection to Planning Application [] – Sevington Inland Border Facility Appendix A – Location Map & Site Context • Purpose: Show proximity to residential areas, schools, and sensitive receptors. • Contents: • Annotated Ordnance Survey map of the site. • Distance measurements to nearest dwellings (e.g., 400m to Mersham village centre). • Highlighted local road network showing constrained access routes (A2070, Church Lane). ⸻ Appendix B – Traffic Impact Evidence • Purpose: Demonstrate the severe impact on local highways. • Contents: • DfT traffic count data for the A2070 (latest year available). • Historical accident data from CrashMap for the last 5 years within 2km of the site. • Map showing Operation Brock diversion routes causing congestion in Ashford town. • Extracts from Ashford Local Plan TRA7 and TRA8, underlining policy breaches. ⸻ Appendix C – Noise and Light Pollution Analysis • Purpose: Prove the 24-hour operation will disrupt nearby residents. • Contents: • DEFRA noise contour maps for the Ashford area, showing existing high baseline from M20/A2070. • Photos of existing facility floodlighting taken from residential viewpoints. • WHO guidelines on night-time noise exposure (<40dB recommended for health) compared with likely HGV yard noise (>60dB). • Extract from Local Plan ENV3a and ENV4. ⸻ Appendix D – Air Quality Data • Purpose: Show the scheme worsens an already sensitive air quality area. • Contents: • DEFRA Modelled Background Pollution data for TN25 6GE. • PM₂.₅ and NO₂ baseline readings from the nearest Ashford BC Air Quality Monitoring Station. • Research link between diesel HGV emissions and respiratory illness risk. • Policy ENV12 extract with key wording highlighted. ⸻ Appendix E – Planning Law & Policy Extracts • Purpose: Arm the letter with direct citations for legal challenge. • Contents: • Relevant NPPF paragraphs (111, 174, 185, 186). • Relevant Ashford Local Plan policies (SP1, TRA7, TRA8, ENV3a, ENV4, ENV12). • Section 38(6) of the Planning and Compulsory Purchase Act 2004. • Environment Act 1995 Part IV (Air Quality duties). Conclusion The Proposal is in clear conflict with multiple provisions of the NPPF and the Ashford Local Plan, and fails to comply with statutory environmental obligations. The application is fundamentally flawed and legally vulnerable to challenge. I therefore formally request that Ashford Borough Council refuse this application in full. Should the Council be minded to approve, please be advised that I reserve my position to pursue all available legal remedies, including judicial review. Yours faithfully, Marcus Huntley