That's what I thought and is what the press has focused on, but after I read brownbagtiger's post I checked and it isn't what the legislation says. The land requisition is for "any activity that forms part of, or is incidental to, functions required to be carried out by or on behalf of a border department in connection with vehicles (in particular goods vehicles) and goods entering or exiting, or that are about to enter or exit, Great Britain"These holding areas are for inward traffic, as they expect the checks to take longer to get them onto the ferries in the first place, there's little point in worrying about those who've already left.
I agree that congestion is more likely to be outbound than inbound and so this may be a just in case provision, but it's definitely there.