Operation Stack: the CPRE Kent view and the chance for you to have a say

A fresh round of consultation opens today (Monday, June 11) on tackling the congestion caused by freight traffic held up when trying to cross the English Channel.
Or, in other words, what can we all do about Operation Stack?
CPRE Kent has made regular contributions to the debate on Stack (the process used by police and the Port of Dover to park lorries on the M20 when ferry or Eurotunnel services are disrupted by industrial action or bad weather; the organisation’s view is summed up by director Dr Hilary Newport:
“We are pleased that the flawed plan for a single huge lorry park – the size of Disneyland – just off junction 11 of the M20 were dropped.
“We, along with the House of Commons Transport Select Committee, did not believe that this could be a viable solution to keeping the M20 flowing freely, and there is no doubt that it would have been a huge blight on Kent’s countryside.”
Some two years ago, when there was also a round of public consultation, Dr Newport said: “We do not think that a single huge lorry park, which may only be called into use for a few days – if at all – in any year is the answer.
“A better solution would offer real resilience to the logistics industry now and into the future and help not just Kent but the whole country cope with disruption, strikes or emergency, such as extreme weather, fire or security threats.”
Other problems that need addressing include roadside parking of HGVs with the associated litter and noise; noise and air pollution caused by engines running in slow-moving traffic jams or when stationary to keep refrigeration units running; and disproportionate wear and tear on Kent’s roads.
CPRE Kent contends that instead of the expensive and damaging construction of a single lorry park, investment should be made to:

• Support a network of dispersed, serviced truck stops that operate on a commercial basis and have some degree of overflow capacity in the event of disruption to Channel crossings. Many shippers prohibit trucks stopping within 120 kilometres of Calais. Similar measures should be employed to hold vehicles outside the Channel Corridor until called forward.
• Incentivise the use of alternative ports of entry and exit (such as Newhaven, Ramsgate, Sheerness, Dartford, Portsmouth and Purfleet), as well as modal shift away from road-based freight – this would also have the additional benefit of reducing reliance on the Dartford crossings.
• Incentivise shippers to return to unaccompanied trailer operations across the Channel, which would also boost UK employment of HGV drivers and reduce emissions.
• Work with the logistics industry, fleet operators and drivers to implement ‘smart queuing’ – smartphones, GPS and communications technology should remove the need for drivers to be nearest the front of any physical queue in Kent when they could be called forward from dispersed locations further afield and guaranteed timely passage across the Channel.
• Implement ‘quick wins’ – CPRE Kent supports expansion of the existing Stop24 truck facility south of the M20 at junction 11; this could quickly provide a partial solution.

Dr Newport said: “With modern technology and sophisticated international business operations, we are sure there is a better solution than allowing all the lorries to build up in Kent with no other way of reaching Europe than the Dover/Folkestone to Calais crossings.”

• To read CPRE Kent’s full position paper, click here
• If you would like to contribute to the consultation, click here

• A number of important documents have yet to emerge. For example, a rigorous transport plan and a finalised air-quality assessment. The latter is critical given that allocations at Teynham will feed extra traffic into AQMAs.
• There seems to be no coherent plan for infrastructure delivery – a key component of the plan given the allocations being proposed near the already crowded Junction 7.
• There seems to have been little or no cooperation with neighbouring boroughs or even parish councils within Swale itself.

The removal of a second consultation might have been understandable if this final version of the plan were similar to that being talked about at the beginning of the consultation process. It is, however, radically different in the following ways:

• There has been a major shift in the balance of housing allocations, away from the west of the borough over to the east, especially around the historic town of Faversham. This is a move that raises many concerns.
• A new large allocation, with accompanying A2 bypass, has appeared around Teynham and Lynsted, to which we are objecting.
• Housing allocations in the AONB around Neames Forstal that were judged “unsuitable” by the council’s own officers have now appeared as part of the housing numbers.
• Most of the housing allocations being proposed are on greenfield sites, many of them on Grade 1 agricultural land – a point to which we are strongly objecting.

Concerns about the rush to submit the plan

The haste with which the plan is being prepared is especially worrying given the concentration of housing in Faversham. If the town is to take a large amount of new housing, it is imperative that the policies concerning the area are carefully worked out to preserve, as far as possible, the unique nature of the town. The rush to submit the plan is likely to prove detrimental.

As Swale does not have a five-year land housing supply, it is open to speculative development proposals, many of which would run counter to the ideas contained in the current plan. Some are already appearing. This is a common situation, and one that, doubtless, is a reason behind Swale’s haste.

Our overriding fear, however, is that this emphasis on haste is ultimately going to prove counterproductive. This is because it is our view that the plan, in its current form, is unlikely to pass independent examination. We are urging Swale to listen to and act upon the comments being made about the plan and to return the plan to the council with appropriate modifications before submitting it to the Secretary of State.

Essentially, this means treating the current consultation not as the final one but as the ‘lost’ second consultation.

The consultation ends on Friday 30 April and we strongly urge residents to make their opinions known if they have not already done so.

Further information

• Read more on the Swale Local Plan
• Read CPRE Kent’s detailed comments on the plan
• View the council’s consultation document