Written evidence submitted by SOS Kent (OPP0062)

Challenge to evidence published 9-5-16

Following the evidence published yesterday, 9-5-16, from Highways England and Damian Collins, on behalf of SOS Kent (Smarter Options than Stanford, Kent) I wish to challenge information included.

Extracts from HE evidence:

The cost of widening a portion of motorway which could accommodate 3,600 lorries, avoiding the need to implement Stages 3 and 4 of Operation Stack and in most cases Operation Stack Stages 1 and 2, (effectively another 72 kms of network), would be approximately £500 million-750million. 

This was discounted as an option at an early stage due to its high cost and it does not take into account the need for major junction reconfigurations or the purchase and placement of movable barriers which would be required during the implementation of Operation Stack for non-port and tourist traffic to pass safely by parked lorries.

There would also be a need to replace the surface of the M20 for the section which is widened as it is of the older concrete type which would significantly add to these costs.  During construction a widening scheme would also require traffic management for safety reasons which would restrict access to what is currently the hard shoulder, raising the question of where lorries, which are currently queued during implementation of Operation Stack, would be placed.

Challenge: It should be the A2 to be upgraded as a priority over the M20, to provide a second continuous motorway route to Port of Dover (and Eurotunnel as necessary). HE evidence shows no joined thinking for future strategy with the proposed Lower Thames Crossing. Having all freight diverted to M20 (or any single route or lorry park) in an Op Stack situation makes it too vulnerable in the event of incidents upstream or on route.

Any spend on road improvements will result in 24/7 use and benefit unlike a single lorry park which may never be needed and be a total waste of public money.

Also, to add to my earlier answer on what previous Highways England work had been done in looking into various options, before settling on the idea of a single lorry area, and you might also want to be aware that as well as the tactical meetings which were held during Operation Stack, the following reports were also considered, all of which are in the public domain.

Challenge: When both cross Channel operators Eurotunnel and Port of Dover say that a single lorry park will not fix Stack, why are they being ignored?

 

 

Extracts from Damian Collins evidence:

First, the scale of the problem is not to be underestimated. Operation Stack was implemented 32 times last year costing the Kent economy £46million and the UK economy £8billion.

Challenge: These figures could have been plucked from mid-air. Where is the evidence to substantiate them?

It was implanted for 5 days in January and then almost continuously in late June and throughout July. At its peak there were 7,000 Heavy Goods Vehicles taking 36 hours to work through the queue.

Challenge: There would still be a queue with a lorry park

Research by Kent County Council estimates a cost to the Kent and Medway economy of around £1.45 million per day, based on delays to passenger journey times (£980,000 per day), reduced visitor numbers (£285,000 per day) and costs to the road haulage industry (£180,000 per day cost to the Kent-based industry)- over 32 days of disruption last year, Operation Stack cost Kent approximately £46 million. However, it is likely that this figure is a substantial under-estimate. The Freight Transport Association (FTA) estimates a wider cost to the TJK economy from Operation Stack of £250 million per day.

 Challenge: A lorry park won’t add any more channel crossings, HGVs will still have to wait for an available slot, they will not get to their destination any quicker. Overseas tourists will still not be able to get here if there are no channel crossings – a lorry park will have no effect on these figures.

 

It is possible that future disruption from implementations of Operation Stack could become even more frequent.

Challenge: It is also possible it may never happen again.

Freight traffic through Kent to the Port of Dover and the Channel Tunnel set to grow from 10,000 per day to 16,000 per day over the next decade. So doing nothing is not an option. The solution is off road lorry parking at Junction 11 of the M20. The estimated cost of this by Highways England is £160million.

Challenge: The solution is to have a proper strategy for the forecast increase in freight traffic and adopt the smarter solutions, ie, continue to address the causes of stack; upgrade the A2; adopt smart technology for better freight management on highways; create multiple smaller nationwide lorry parking areas to address the shortage of overnight parking; invest in rail to get freight off the overburdened road network.

 

 The proposals brought forward by Highways England are the result of a considerable amount of work by Kent County Council, the Department for Transport and Highways England themselves. Two sites have been brought forward for consideration to create a new off road lorry parking facility, although many more have been examined and discounted. Since the site is intended to manage HGV traffic heading towards the Channel crossing, it needs to be on the coast bound carriageway of the M20. It needs to be to the west of the Channel Tunnel entrance, but as close to it as possible to make sure we have proper enforcement. As Matthew Balfour, Cabinet Member for Environment and Transport, Kent County Council told your Committee on Monday, "You can't make drivers always do what they're meant to do" and only an estimated 30 per cent of drivers follow instructions such as diversions.

Challenge: are we unable to enforce law in the UK now? If not, how would you to force 3600 lorries to go to a single lorry park.

 

For this reason I do not think a series of smaller lorry parks dotted around the country's motorway network would be effective; the site needs to be as unavoidable as possible for HGVs bound for the Channel crossings, and that means locating it near to the crossings.

Challenge: Where will the 30% disobedient HGVs go? Carnage on the local roads of Shepway.

 

 

Of the two sites, one to the west and the other to the north east of Stanford North, I believe only one could be acceptable. The site to the west of Stanford requires the smallest amount of land to be lost, would be integrated into the motorway network and would be linked by a new bridge to the Stop24 services at junction 11 of the M20. Lorries would access and exit the lorry park directly from the motorway without using local roads.

Challenge: correction – 70% may do

Both I and Shepway District Council are committed to pressing Highways England to ensure that property screening is provided to ensure that the site's impact is mitigated as much as possible.

Challenge: previous track record with M20 and Stop 24 does nothing to reassure

 

I was interested to note the remarks of witnesses in relation to fly-parking by HGVs, especially but not only during the implementation of Operation Stack. This was a matter identified in the evidence you heard on Monday, with broad agreement amongst witnesses that a lorry holding area would solve the problem of fly-parking. This is a matter of great concern to a very large number of my constituents. They are rightly very unhappy about lorries parked in inappropriate or illegal locations. They cause damage to curbs and verges, and waste (including human waste) is often left by lorry drivers. Alongside tougher enforcement measures such as clamping, an extension of the parking available at Stop24 with the facilities of a lorry park available as needed can help bring an end to fly-parking across Kent.

Challenge: We welcome any move to reduce fly parking, but these are usually foreign drivers, unaccustomed to paying for parking on mainland Europe, who have no intention of paying to park. Does this mean that more thought has been given to permanent use of any single lorry park?

 

A pilot scheme in Ashford has shown that this works. Challenge: Which pilot scheme?

The lorry park could also be used to regulate the flow ofdata:image/png;base64,iVBORw0KGgoAAAANSUhEUgAAAAEAAABeCAYAAADizX6rAAAAAXNSR0IArs4c6QAAAARnQU1BAACxjwv8YQUAAAAJcEhZcwAADsMAAA7DAcdvqGQAAAAPSURBVChTYxgFww4wMAAAAdYAAdrpLkkAAAAASUVORK5CYII= traffic to the Port of Dover, ending the need for the current speed restrictions on the A20 which are a great frustration to motorists.

Challenge: Port of Dover has already advocated the retention of TAP as it currently works

 

 

Fundamentally, no mention has been made about the deadly emissions of 2.5 particulate concentrated in one area. When pollutants have been cited to cause so many deaths in the UK and it is being rectified in city centres, why is it ok to kill the rural residents adjoining the proposed lorry park?

10 May 2016