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Date submitted

12 Sep 2025

Submitted by

Interested Party

Christine Drury for CPRE Ashford 1. This application is for a continuation of the now existing built structures and installations at the Sevington IBF. It is an opportunity to correct some of the mistakes that were made when the Sevington IBF was built in great haste and with scant regard for good planning practice during 2020 under the present Statutory Development Order. CPRE wrote to the SoS for Transport, Grant Shapps in July 2020 to urge the Department to work with both the local communities impacted and the wider community of stakeholders in a highly complex situation at that time : junction 10a and the A2070 link were still in construction and HMG had also requisitioned the then recently enlarged and upgraded Waterbrook Truck Stop as a Plan B in case the IBF was not ready to open for 1st Jan 2021 when the UK border became non EU. It is not surprising that critical details including a proper landscape assessment and details of the building design and lighting were not fully discussed at the time. This application is the right time to do so informed by the in use experience since then. 2. CPRE does not object in principle to changing the planning status from temporary to permanent provided this is combined with a thorough discussion of how it can now be made compliant with Planning policy and good practice. CPRE also recognises that the operations at Sevington are of national importance, and contribute to the economy of Ashford; and the location and choice of this particular site is a part of that national importance. This adds weight to the need to mitigate the impacts of this site choice, and to take great care to deliver all aspects of Sevington well. 3. Understanding the prominence of the site. The application papers do not describe the location and setting of the site correctly. The site is on elevated ground that was previously in arable rotation. Highfield Lane runs between the West Sevington IBF site and the East Sevington agricultural field The name of the Lane describes the location and its rural land use: the high field. As built the site is still at the eastern edge of the built environment of Ashford. The eastern boundary is now a hard urbanising industrial edge of high security fencing fully visible day and night. The site directly abuts a field on the opposite side of Highfield lane and is very clearly a rural edge site at this eastern boundary. The as built bund of topsoil in the field needs maintenance and managed replanting. This remediation is acknowledged in the application. It needs to happen. To the north the site abuts the A2070 link road to the immediately adjacent Junction 10a of the M20 which passes in a cutting some way below the IBF. This means the site by its elevated position has uninterrupted visual connection to the escarpment of the Kent Downs National Landscape(KDNL) to the N and NE, and is, under national planning policy, clearly in the setting of the KDNL. CPRE agrees with the detailed explanation and analysis submitted by Katie Miller on behalf of the Kent Downs National Landscape Unit. To the south and east the site connects to the historic village of Sevington, and across the railway lines to the commercial district at Waterbrook including the International Truck Stop and the major new residential areas south at Finberry now extending closer with the residential development at Waterbrook . All of these have residential amenity or commercial good practice reasons to minimise avoidable impacts from the development and operations at the IBF while also appreciating the local employment and business links it provides . 4. Correcting the mistakes made under the temporary permission. The application documents acknowledge that the residual landscape impacts are significant and on lighting assume that the environmental standard E04 applies ( town centre urban night time economy ). This is not inevitable and it is also inadequate because it fails to acknowledge the urban / rural edge of the site and fails to recognise that the site is in the setting of a designated landscape. These are major mistakes in this application for permanent planning permission . there is a planning duty to respond to this context. Furthermore these mistakes could be corrected relatively easily by measures including : a) reconsidering the design of the buildings – in particular their external colour , choosing a colour that would blend better into the landscape in the long distance views from the KDNL. Light grey stands out as incongruous, intrusive and poorly designed on this elevated site. A design retrofit should be a condition if the application is approved . There are plenty of local references of how to do this better. b) adding to the programme already underway to correct the lighting: this has correctly focussed initially on reducing the intrusion and loss of amenity for residential neighbours. The programme now needs to address the wider rural and countryside impacts . The application documents say that the swim lane lights would be turned off when not in use. This has not happened yet: on a visit this week only two lanes were in use with 3-4 queuing vehicles at each, but all lights were on. This is particularly important because it is the swim lanes area that had both dense lighting and is the area most directly seen from the KDNL , and across the rural landscape towards Mersham and with the greatest sky glow including from reflected light from the swim lanes area and the north east perimeter road . This needs a correction plan as a condition if this application is approved. The condition should be to achieve E02 (Rural) outside the site boundary including upwards . 5. Understanding the transport issues The purpose and operation of the site has significant transport impacts . The transport assessment in this application is inadequate. It assumes that all issues are resolved by the sites proximity to junction 10a and by a staff travel plan ( which contains avoidable errors including reference to an Ashford Park and Ride ) . There is no discussion of customer transport issues other than an inadequate reference to signage that assumes “ drivers will learn “. Although outside the planning remit it may be that the impacts will only be resolvable if the operations protocol identifies and treats drivers as customers ( this would be logical as they are entirely responsible for their vehicle and its load ). a) Signage : This is a major border control site which is used by cross channel logistics operators inbound from Dover Port and Eurotunnel or outbound . As a multi agency site drivers will either use it voluntarily if needed or by instruction ( Follow Me vehicles are a frequent sight) . Only a small proportion of the 6000 / day logistics vehicles using the Short Straights crossing use the IBF: this is as set out on the BTOM ( Border Target Operating Model). As there are approximately 20k drivers regularly using the crossing some may never use it or only very occasionally. The signage is therefore incredibly important, and needs to be properly researched so that one time drivers fully understand it and it makes sense with a wide variety of sat nav’s. This needs more and continuing effort to help the drivers and the residents of Mersham and Sevington who frequently help ‘lost drivers’. b) Drivers Hours : the transport assessment makes no reference to the issue of drivers hours. Drivers arriving at the IBF are customers of the government departments and agencies operating there. As there is a prohibition on parking up on the site, drivers who arrive close to a driving hours limit requiring them to stop will be parking up in the area ; not all will be using the Ashford truck park adjacent at Waterbrook. Drivers are well experienced in managing drivers hours regulations , but if required to attend the IBF the issue of parking up nearby for drivers hours reasons will arise and needs to be factored into the transport assessment . Local experience of the issue by neighbouring residential and business areas should be researched and understood so that if needed appropriate arrangements can be included in this planning application by amendment or condition . If a hearing is planned this would be a useful topic to include. 6. Delivering development excellence There is much in the planning application that is commendable such as the clearly described detail of the waste management strategy including the preventative bunding. This consultation and any hearings that follow are an opportunity to achieve excellence in all aspects of the Sevington development. As a development of national importance Sevington should also be a development of national excellence. This means not only recognising but also managing and reducing its impacts as a prominent and secure edge of town site in the Kent countryside. For the local community there has been some operational progress by reducing some lighting and light spill but the number and density of lights and reflections on light coloured buildings have a huge, incongruous and wide impact across the Kent countryside . Likewise the details of the transport and parking impacts in the surrounding Ashford area need to be understood and improved under this planning application . Changing from a temporary facility as part of the UK leaving the EU, to a long term permanent facility as part of border control operations for freight is a significant milestone . It is an opportunity for the planning aspects to be improved particularly in design , lighting , screening and transport with wider than local criteria and input. The aim should be excellence as a development in Ashford in the setting of the Kent countryside. There is much to do, continuing the progress already started : it is still principally known for the blaze of night time lights with not much of the area in use and the lost trucks in the surrounding rural lanes.