Written Evidence from Port of Dover (OPP0004)
The Port of Dover welcomes the opportunity to respond to this important Transport Select Committee call for evidence as part of its Operation Stack Inquiry.
1.1 As an island nation, the crossing between Dover and the French ports of Calais and Dunkirk is essential, along with the connecting motorways and trunk roads, as the UK’s gateway to Europe and is vital to the UK’s supply chain.
1.2 Annually, the Port and its ferry operator customers handle over 2.5m freight vehicles, approximately 2.5m tourist cars and coaches and 13m passengers. To handle such volumes every year requires a highly efficient system which meets the needs of complex supply chains and industries throughout the United Kingdom.
1.3 Volumes of freight vehicles through Dover have grown by over 30% in just the past three years, supporting economic growth. The trade carried through the Port of Dover was, very recently, independently valued at up to £119bn and representing circa 15% or more of the UK’s trade in goods. This helps support domestic consumption through imports, and helps grow the export market by providing the cheapest and most efficient route for goods to mainland Europe.
Background
2.1 In answering this question, it is important to set out the background in which such a new lorry park solution has been proposed.
2.2 In 2015, a unique set of external influences led to an unprecedented 35 individual days where Operation Stack was in place during the year.
2.3 The proposals taken forward by Highways England in their December 2015 consultation document deal only with off-highway measures, with no attention given to any on-highway measures.
2.4 As noted in the Highways England consultation document, prior to 2015 Operation Stack was used infrequently. During the five years between 2010 and 2014 Operation Stack was used for an average of just once per year, despite cross-Channel freight traffic growing during the same period by 15.8%. Of those Stack events, it is notable that most were due to extreme snow fall, which causes general disruption across the county and country’s transport systems, not just at the channel ports.
2.5 Growth on the cross-Channel route is a sign of positive economic growth for the country as a whole. This growth has always been met by both port and ferry operators with capacity enhancements to ensure that fluidity is maintained. Therefore, we strongly reject any implication that there is any causal linkage between the frequency of Operation Stack and growth in the underlying cross-Channel market; this is a dangerous over simplification of the situation.
2.6 The events of 2015 were unique and unprecedented; the loss of a ferry operator due to UK competition authority action, industrial action closing the Port of Calais and subsequent increased migrant activity affecting the Channel Tunnel. Nor were these events independent, each was linked by the underlying events and activity. Disruption at Eurotunnel and the Port of Dover, with the subsequent use of Operation Stack was a symptom of these problems; once the root causes were addressed (through security measures at the Channel Tunnel and the re-opening of the Port of Calais to all operators) the status quo returned quickly with record traffic volumes being handled on a daily basis with no disruption.
2.7 The underlying risk itself has also been reduced, in our opinion, by:
2.8 The events which came together during July 2015 were an exceptional set of circumstances. As such, any solution needs to be a proportionate response for the given level of risk.
The effect of a new lorry park
2.9 Against the above background, the introduction of a lorry park should mean that Operation Stack is needed much less and its potential implementation should therefore be delayed until the most extreme of circumstances.
2.10 There are some operational practicalities that need to be addressed. The current on-highway Operation Stack solution provides an easy way for freight vehicle drivers to see they are in a queue and therefore managing the integrity of the queue is easier. It is currently unclear as to how a lorry park solution may be managed within the designated site or how such vehicles will be prevented from trying to bypass the lorry park.
2.11 Having direct access, off-and-on to the M20, in the direction of travel towards the channel ports, is critical in ensuring that traffic can quickly be moved onwards to the ports as capacity becomes available. This helps reduce a key risk that the Port is left starved of traffic, leading to ferries having to leave port less than fully loaded.
2.12 If an exceptional situation, such as experienced in 2015, were to occur in the future, the proposed lorry park will not have sufficient capacity to handle the overall of volume of traffic required to be held, particularly when noting the growth in freight traffic volumes in just the past three years and future anticipated growth.
2.13 As a remote holding facility and in the context of its impact on Operation Stack, which is managed by Kent Police, it is perhaps not the Port’s place to comment on how a lorry park will affect the planning, management and implementation of Stack. However, the bottom line is that however this is managed, it is absolutely essential that, as and when it can be released, traffic reaches the Port and Eurotunnel in the amounts required at the time required to ensure ferries and trains to not leave only partially full. As a response to an emergency situation, which Operation Stack is, in getting back to business as usual as quickly as possible, which is in everyone’s interests, full ferries and trains must be an absolute imperative.
Call for full cost / benefit appraisal
3.1 The Port notes that Government wishes to ‘fully test the case for a permanent lorry area’. The Port of Dover agrees that this approach is the correct one. At this time of austerity across public spending, it is more important than ever to ensure that scarce funds are directed at the solutions which provide the greatest overall benefit for Kent and UK Plc.
3.2 Therefore, the Port has urged Highways England to undertake a full cost / benefit appraisal of the scheme alongside the other proposals set out in the European Gateway Group report, along with any other potential solutions. A full business case is imperative. This will ensure that the right solution is found to give taxpayers the best value for money.
3.3 Four options for the lorry park have been proposed and the Port sets out below its response to the question based on each scenario.
If Alternative One (Emergency use): Design and Operation
3.4 The use of an off-highway holding area for the Port of Dover’s traffic, positioned over 23km from the port is clearly going to have significant impacts upon the port’s business. Whilst the port understands the need for such an emergency reservoir for traffic in extremis, there is great concern regarding the practical application of the operating model.
3.5 The Port firmly believes its management team must be involved within the design of the operation of any such holding area. The design and operating model must ensure that it is capable of releasing the 400 freight vehicles per hour needed for the standard operation of the Port. Any freight vehicles released for Eurotunnel will need to be in addition to the required figure of 400 freight vehicles per hour. The model of operation must ensure that there is no greater cost burden on the Port of Dover than currently incurred in its management of Operation Stack. We note that the planning requirement for the holding area is for 3,600 freight vehicles.
3.6 This will not be sufficient capacity to eliminate all instances of Operation Stack and therefore has the potential, on some occasions, to require use of the existing Operation Stack arrangements. Therefore, Highways England must also compare methods of achieving two-way contraflow on the M20 to ultimately fulfil the Chancellor’s desire to relieve the pressure from Operation Stack. Such a method would result in the building of more flexible infrastructure, able to deal with both emergency uses and provide capacity for future growth.
If Alternative Two (General disruption): Design, Operation and Benefits of Dover TAP
3.7 Alternative Two sets out a proposal that would remove the need for the Dover TAP (Traffic Assessment Project), the traffic relief scheme for Dover, instead proposing that this traffic be routed to the Stanford West holding area. We believe this represents a fundamental misunderstanding of the role Dover TAP plays in traffic management for the Port of Dover.
3.8 Since its introduction in April 2015, Dover TAP has been implemented around 150 times and has been extremely successful at achieving the strategic aim intended for it, to reduce congestion though the town of Dover safely and efficiently, whilst maintaining fluidity of freight traffic to the port. Dover TAP has successfully enabled the use of a rolling road approach for queuing freight vehicles whilst keeping car and non-port freight traffic flowing freely. Indeed, since its inception, car and non-Port traffic has remained in free flow for 99% of the time on average.
3.9 When short-term traffic demand for the port exceeds uplift capacity, some amount of queuing will ensue; this is common across all modes of infrastructure. Where freight queues spill out of the port, they immediately cause disruption by queuing through the centre of Dover. This can have significant impacts upon local residents, businesses and emergency services. Dover TAP is an example of local stakeholders working together to address a local problem.
3.10 Following its introduction, Port of Dover has undertaken to police the Aycliffe Roundabout on the western edge of Dover throughout 2015, at its own expense, in order to benefit the local stakeholder community. It has been warmly welcomed by most residents and local businesses and its retention is also favoured by Dover District Council and Dover’s MP, Charlie Elphicke. The Dover TAP scheme has been a success achieving the free running of traffic through the centre of Dover, whilst ensuring the fluidity of traffic to the port.
3.11 As part of meeting the Chancellor’s request to relieve the pressure on Kent’s roads, we believe that Highways England should be looking at how Dover TAP can be enhanced to avoid a permanent 40mph speed limit, and to improve safety for all road users.
3.12 We also have severe concerns over the operability of any system solution which forces vehicles to leave the main highway 23km from their ultimate destination in close proximity to our major competitor Eurotunnel. In any event, Highways England’s consultation is silent on any proposals as to how this can be administered, any form of day to day operation is unlikely to be regarded as a civil contingency and the burden will therefore fall on Highways England to direct traffic on and off the highway. Therefore, the Port of Dover strongly rejects any suggested proposal which would result in the removal of the Dover TAP.
If Alternative Three (General disruption and overnight parking) and Four (As Three plus Truckstop): Imposition and Market Interference
3.13 The infrequency of Operation Stack means a desire to seek different uses for the proposed lorry park site, when not used for its primary function. However, the increased level of facilities required for lorry parking and a truck stop can only reduce the amount of space available to deal with the core objective of the site. This creates an inevitable trade-off between space given over to other facilities and space supporting the Chancellor’s desire to relieve the pressure on roads in Kent from Operation Stack.
3.14 With growing cross-Channel freight traffic volumes, this trade-off will only become more challenging. Over the last 20 years, the number of goods vehicles travelling from the UK to mainland Europe has increased by 83%; this growth is expected to continue with predictions for the average daily demand for freight movements passing through Kent to increase from 10,000 vehicles per day currently to between 14,000 and 16,000 per day in the next decade.
3.15 The Port is also concerned at the competition issues raised by the private sector use of any lorry holding area. Currently, there is a buoyant and competitive market for lorry parking in Kent, with the private sector already willing to invest in the provision of lorry parking. Current estimates indicate there could be anything up to 1,000 lorry parking spaces in Kent, with key competitors being Motis in Dover, Priority Freight in Dover, Stop24 at Westenhanger, and the Ashford International Truckstop. Therefore the creation of a 3,600 space lorry parking facility would create a position of dominance within this currently competitive market place.
3.16 This approach threatens to distort competition by favouring one undertaking granted the operating rights. We are extremely worried that this could force the closure of businesses in Dover, leading to a loss of jobs and economic activity in the area.
4.1 The Port of Dover can see why a lorry park will help with Stack as an ‘in extremis’ solution to keep the M20 open and to minimise disruption to the people of Kent and others using the county’s strategic road network.
4.2 The day to day issues of traffic management need to address the matter of fluidity. The commentary in paragraphs 3.7 to 3.11 cover the points about the need to retain Dover TAP as part of any lorry park solution in order that the negative impacts of queuing traffic through Dover are not re-introduced and fluidity is maintained.
5.1 Maintaining fluidity close to the Port is paramount. This can and is already being achieved in a number of ways through a mix of the Port’s own significant investment and external highway management measures.
Port of Dover's Traffic Management Improvement Project
5.2 The Port of Dover itself has recently opened an internal buffer zone within the confines of the port. This aspect of a three year Traffic Management Improvement Project, which was incepted before the recent high levels of freight growth, provides the equivalent of 220 freight spaces (or approximately two ship loads) off highway. This investment coupled with the planned introduction of two ferries onto the Dover-Calais route by DFDS in February 2016 will further serve to support fluidity.
Dover TAP
5.3 By operating Dover TAP as a local buffer at times when Operation Stack is in place, between Stack and the Port of Dover, it will be possible to ensure that the Port has freight traffic primed for a quick transit to the Port at the time when the Port is able to receive it, rather than coming from half way across Kent.
5.4 Both of the above solutions together will help to ensure fluidity by feeding the Port with enough traffic at the right time – keeping the internal buffer zone full by keeping Dover TAP full and feeding the buffer zone, which feeds the ferries. This will see ferries sailing full and therefore minimising the time for which Operation Stack may be required.
Need for a freight corridor approach
6.1 The Port of Dover broadly agree with the key criteria for a lorry park set out in the Highways England consultation document, but note the clear exception of any thought of the impact on the A2/M2 corridor of the proposals. The key transport corridors of the A20/M20 and A2/M2 routes converge in Dover and both are viable routes from the M25 and the north to the Port.
6.2 Presently between 60% and 70% of freight vehicles use the M20 corridor to reach the Port, with the remainder coming via the A2/M2. This consistent bias is due to the higher standard of the A20/M20 with at least two lanes throughout; this contrasts with the A2 which remains single carriageway for 5.5km between Lydden and Whitfield. However at times of incident on the M20 or whilst Operation Stack is in force, freight vehicles quickly re-route to the A2/M2 corridor in an attempt to minimise disruption to their journey. This is a predictable response by lorry drivers, as it would be for any motorist in response to knowledge of network stress elsewhere, and was witnessed during the instances of Operation Stack during 2015.
6.3 Use of any lorry park or holding facility solely on the M20 corridor will result in the same behaviour, leading to an increase in traffic on the A2/M2 corridor on a route which is already unsuitable with traffic levels above its design capacity. The impact will be increased levels of queuing at Brenley Corner, around Canterbury, at Lydden and on approaches to Dover. This also results in a cost of ensuring compliance from vehicles arriving by this route at the Port and directing them back to Operation Stack or any proposed lorry park.
6.4 This lack of resilience in Kent’s strategic road network is of national strategic importance due to the importance of the cross-Channel route for UK trade. With the UK economy set to continue growing, this will lead to more imports and exports requiring use of the most efficient route to market.
6.5 The Port and ferry operators will continue to play their part in providing capacity to meet demand, but this must be matched on the connecting motorways and trunk routes to ensure continued economic prosperity. Improved resilience in the Strategic Road Network through the enhancement of the alternative A2/M2 route would also provide a better diversionary route during times of disruption. Dualling of sections of the A2 on approach to Dover and around Lydden is needed as well as junction enhancements with the M2 at Junction 7 Brenley Corner.
Lower Thames Crossing
6.6 Government must commit to the Lower Thames Crossing without delay – events on the French side of the Channel last summer show what happens when there is a blockage in this strategic international freight corridor between Europe and the UK (including to the Midlands and the North). With the Dartford Crossing operating above its design capacity, new infrastructure is required for our transport networks and key freight corridors to remain free flowing and above all resilient.
7.1 There is a substantial risk that in investing a large sum of money creating a solution to Operation Stack, other elements are added on in order to ensure the area does not sit dormant. However, there is a real risk of trying to create a panacea, the effect of which creates more issues than it set out to solve.
7.2 We believe that Highways England should investigate the investment case for all options which deliver the Chancellor’s core strategic objective of relieving the pressure on roads in Kent from Operation Stack. This should include both on and off-highway solutions.
7.3 Consideration should also be given to the dynamic effects of any lorry holding area on the A2/M2 corridor, which would support the introduction of full dual carriageway status and greater resilience for the 5.5km of single carriageway remaining between Lydden and Dover.
7.4 Any solution to the management of freight vehicles through Kent must ensure that it does not impede the fluidity or efficiency of this key trade route which is so vital for the UK’s economic prosperity.