1.1 Kent County Council (KCC), as the Local Transport Authority for Kent, welcomes the opportunity to submit written evidence to this inquiry into Operation Stack. We would be very happy to expand on any aspect either in writing or as oral evidence.
1.2 KCC’s concerns can be summarised as follows:
1.3 Kent County Council asks the Committee to seek assurances that action is taken by the Government to:
2.1 A new Lorry Area needs to consider the following planning, management and implementation issues in relation to Operation Stack:
2.2 Kent County Council (KCC) also urges that the Department for Transport (DfT) considers trunking parts of the local road network that the Lorry Area is dependent on for access and egress, in particular, Junction 11. Highways England will then have responsibility for maintenance of the roads that are essential for the operation of the Lorry Area.
3.1 The current arrangement with Operation Stack as the main response to disruption to cross Channel traffic is totally unacceptable to KCC, to our communities and to our businesses. It is essential that the motorway is kept open for two-way traffic flow at all times and is never closed for the queuing of freight vehicles, therefore KCC strongly supports a Permanent Lorry Area to reduce or remove the need for freight traffic to be queued on the M20.
3.2 A Lorry Area would benefit the local economy as the current arrangements for Operation Stack results in an estimated cost to the Kent and Medway economy of around £1.45 million for each day it is in operation. Scaling the Kent figure up to the 32 days’ disruption caused by Operation Stack in 2015 gives an approximate cost of £46 million. However, it is likely that this figure is a substantial under estimate.
3.3 The £46 million estimate relates to costs borne by the Kent and Medway economy only; i.e. costs accruing nationally or internationally (e.g. to the freight industry based outside or carrying goods from outside Kent) are not included, therefore the national costs are substantially greater. The Freight Transport Association (FTA) estimates a wider cost to the UK economy of £250 million per day. A Lorry Area would therefore also benefit the national economy.
3.4 Kent businesses are also negatively impacted by Operation Stack with 45% of tourism businesses reported cancellations; 59% considered that they had lost up to 20% of business as a result of Operation Stack. Let alone the collateral damage to Kent’s brand as the ‘Garden of England’.
3.5 The widespread traffic disruption due to Operation Stack not only prevents international freight fluidity with direct costs to business and national economies, but also affects local accessibility and business productivity; and undermines the perception of Kent as a place to do business and to visit. It creates a negative image of Kent, deterring inward investment by the private sector. The perception is that East Kent is the most severely affected and this is where inward investment is required the most in order to help tackle high unemployment rates and lower Gross Value Added (GVA) relative to the wider South East region.
3.6 Traffic disruption causes the loss of employee hours, delays to business deliveries and local service provider cancellations. It causes considerable journey time delays and journey time unreliability. There is a significant human cost of the effect of the congestion in the county caused by Operation Stack. This includes care workers not being able to get to those they look after, patients not being able to get to doctor's surgeries or hospital, appointments being missed, and people not being able to access the most basic services, including not being able to get to shops for food etc.
There is also a direct cost to Kent businesses that cannot carry out their daily work due to difficulties accessing the business itself or its customers. This is particularly so for businesses located on or close to the A20 diversion route.
3.7 Driver welfare is also a serious concern for both lorry cab drivers and car drivers caught in the congestion. Drivers are stuck in their vehicles for many hours without heating or cooling, food and water, and toilet and washing facilities; therefore during Operation Stack emergency temporary welfare facilities are provided by KCC at a cost to the taxpayer.
3.8 Operation Stack also impacts on the tourism industry both within Kent and delays to tourist traffic between the UK and France. Tourism is worth £3.4bn to the Kent economy and supports over 65,000 jobs.
4.1 A Lorry Area with the minimum 3,600 Heavy Goods Vehicle (HGV) spaces as proposed by Highways England would allow M20 to remain open in both directions for all traffic during most instances of disruption to cross Channel services, therefore mitigate the current negative impacts of Operation Stack.
4.2 3,600 HGVs and would replace Operation Stack Stages 1 and 2 (Junction 8 to 11 which also has capacity for 3,600 HGVs) in the first instance. Only in extreme circumstances (when the capacity of the Lorry Area is full) would Operation Stack Stages 1 and 2 (Junction 8 to 11) be used, which in combination with the Lorry Area, would provide total capacity for 7,200 HGVs. This would prevent the need to use the London-bound carriageway for Operation Stack (Stages 3 and 4) as was experienced in Summer 2015.
4.3 As previously stated, it is essential that the motorway is kept open for two-way traffic flow at all times and is never closed for the queuing of freight vehicles, therefore the Lorry Area should be future-proofed to deal with the growth in cross Channel freight traffic that is predicted for Eurotunnel and the Port of Dover. The current average daily demand at the Channel ports is over 10,000 HGVs (2 way flow) and this is forecast to increase to between 14,000 and 16,000 per day in the next decade (annual growth of between 2% and 4% at the Port of Dover and up to 30% over the next 5 years at Eurotunnel).
4.4 KCC supports the Lorry Area operating for both general disruption (in place of the current arrangements for Operation Stack) and for use for overnight lorry parking. Provision for overnight lorry parking will address the problem of illegal and inappropriate overnight lorry parking and complement the work of KCC, the Police and the Districts with enforcement. Despite a lack of capacity and high demand for overnight lorry parking, the private sector has not delivered sufficient provision to meet demand; therefore use of part of the Lorry Area for overnight parking is supported. The capacity for overnight parking should match demand and should not disadvantage commercial providers in the area, who have paused their own expansion plans pending the outcome of the proposal by Highways England for a Lorry Area. Therefore KCC urges that Highways England and the DfT provide clarity around the commercial overnight parking element of the Lorry Area proposal.
4.5 Use of the proposed Lorry Area for overnight parking should be part of a network of lorry parks across the country, which alongside enforcement measures, would address the severe problem of inappropriate lorry parking.
4.6 The proposed Lorry Area also provides the potential for a better means of managing excess traffic at Eurotunnel which currently creates an informal queue on the M20; and provides an opportunity to complement the Dover Traffic Assessment Project (TAP) so that local traffic congestion is reduced when Port of Dover traffic queues on the A20. However, the current arrangements with the Dover TAP should also be retained so that cross Channel freight traffic continues to queue outside of the town and thus reduces congestion in the urban area. The scheme needs to have a speedy resolution to installing a variable speed limit on the A20 as this will help to reduce the current impacts on the surrounding local road network caused by using one lane of the dual carriageway trunk road to queue HGVs.
5.1 During the June/July crisis, the DfT instructed Highways England, KCC, Kent Police and other partners to utilise the former Manston Airport site as a temporary lorry park for Operation Stack. Manston will be used when Stage 2 (Junctions 9 to 11) is half full, which allows approximately 3 hours’ notice to mobilise the former airport site. Stages 1 and 2 (Junctions 8 to 11) would then be drained of all Port of Dover traffic, leaving only Eurotunnel HGVs on the M20. Subsequent Dover bound HGVs will then be directed via the A249, M2 and A299 to Manston and released to the port via the A256 and A2.
5.2 Manston would hold approximately 3,500 HGVs and should prevent the closure of the London-bound carriageway Junctions 11 to 8 (Stages 3 and 4). Use of Manston is a temporary measure until June 2016 and so far it has not been implemented.
5.3 Other short term measures required as part of a package alongside the Lorry Area include:
6.4 As previously stated, KCC urges that the DfT considers trunking parts of the local road network that the Lorry Area is dependent on for access and egress, in particular, Junction 11. Highways England will then have responsibility for maintenance of the roads that are essential for the operation of the Lorry Area.
6.5 KCC also makes the case for a small proportion of the funding allocated by Government (for the Lorry Area) to repair the damage to KCC’s road network, including verges and highway assets, damaged by HGVs due to Operation Stack.
6.6 Should Operation Stack be implemented on the M20, either before or after a lorry park is in operation, the A20 between junctions 8 & 9 of the M20 will become the diversion route. To aid travellers on the diversion route there needs to be the increased use of traffic technology, such as Variable message signing, to communicate the diversion route and any information regarding the delays.
7.1 In conclusion, KCC’s concerns can be summarised as follows:
7.2 Kent County Council asks the Committee to seek assurances that action is taken by the Government to:
Matthew Balfour
Cabinet Member for Environment and Transport
Kent County Council
29 February 2016