12 JAN 2016

Consultation Response to Highways England: Managing Freight Vehicles through Kent

This is a response to Highways England's Managing Freight Vehicles through Kent consultation paper. I have studied the consultation document and set out my response and recommendations.

The problem

For too long congestion problems surrounding the Channel crossing at Dover have adversely affected residents and businesses.

The high volume of freight traffic crossing to and from Dover and the Channel Tunnel results in a high volume of rubbish and human waste being dumped into roadside verges and causes visual pollution.

This is exacerbated by the lack of cleaning and waste facilities. Congestion - whether due to weather, operational problems, security problems or industrial action – frequently leaves Dover in gridlock and stretches of the M20 out of action for days on end due to Operation Stack.

This has a negative impact on residents and the local economy. During the migrant crisis last summer, it was estimated that the Kent economy lost £1.5m for each day Operation Stack was in action. The UK economy as a whole was said to have lost £1 billion.

This problem is set to worsen. 2015 saw Operation Stack invoked for a record breaking 35 days. The volume of freight vehicles crossing the English Channel is increasing and the migrant crisis continues to put pressure on The UK's borders. Forecasts predict that the number of lorries will continue to climb.

Traffic volumes

Currently, 10,800 freight vehicles cross the Dover Straights every day. This figure is rising rapidly, with a 6% increase in volume recorded from Q3 2014-Q3 2015. Forecasts predict that freight volume in the area could double over the next decade. That would mean over 20,000 freight vehicles a day and the local infrastructure will struggle as it is not adequate for this volume of traffic.

Increased traffic already overwhelms lay-bys and other local resting areas for vehicles. This will inevitably see a rise in waste, inconvenience and damaged infrastructure where lorries are parked inappropriately. Such activity further demonstrates the need for a permanent area to house these freight vehicles.


In the 2015 Autumn Statement, the Chancellor announced £250 million funding to address the problems caused by Operation Stack.

The funding is intended for a lorry park to provide a permanent alternative to Operation Stack, seeing an end to the sporadic closure of the M20.

The Solution

Basic Needs

From the problems seen this summer to the forecasts set out, it is clear that a wide ranging solution is needed to address the problem of freight vehicles crossing the English Channel.

The Highways England consultation sets out four possible solutions to this problem at two possible locations.

These solutions seek to tackle the problem of Operation Stack on the M20, providing a permanent holding station and basic facilities for lorry drivers whilst they are stationed there. The proposed area could host lorries affected by Operation Stack, TAP congestion or general disruption whilst providing chargeable overnight parking and Truckstop services.

Suggested Proposals

Option 1: Emergency only

As its name suggests, Option 1 would see the new development in use solely during times when Operation Stack would be deployed. Lorries would not incur any upfront charges to use the area, but may be fined if they did not move on at the agreed time.

Basic welfare facilities (toilets, handwashing, water and waste disposal) would be complimentary and on site.

This should see infrequent (if rising) use of the area, but it should free up the entirety of the M20, unless under exceptional circumstances.

Option 2: General Disruption

Option 2 would accommodate vehicles in a variety of circumstances that would remove or reduce the need for the area's main disruptive traffic management systems: Operation Stack, TAP and/or any Eurotunnel queue management system.

This proposal includes all measures laid out in Option 1 and should see the freeing up of the M20 and other key local roads. Again, the lorries would incur no upfront costs.

Option 3: General Disruption and overnight Parking

The proposal of overnight parking is the first of two revenue generating ideas. Option 3 includes all measures laid out in Option 2, but also provides overnight space (outside times of emergency/disruption) for c.500 lorries.

Overnight parking seeks to address the growing problem of lorries parking inappropriately or 'fly-parking' in the surrounding area. However making it chargeable will mean that few will use it due to the cut-throat cost nature of the lorry freight drivers.

Option 4: General disruption and Truckstop

Option 4 encompasses all measures laid out in Options 1-3, but also includes a motorway service station, aimed at lorry drivers.

The service station, or "Truckstop", would function 24/7, 365 days a year and include basic welfare facilities alongside:

shower and washing facilities for lorry drivers;

hot drinks and food available for purchase and on-site consumption

Fuel would be provided on the (proposed) Stanford West site and possibly on the Junction 11 North site

Parking would be free for the first two hours and chargeable thereafter. This option should relieve pressure on the M20, cut the growing problem of ill-parked lorries and provide a useful service branch for lorry drivers.

Option 4 Plus: Mandatory parking

Option 4 is my preferred option. However, I believe it would be better if all lorries were required to stop at the park for advance check-in and sorting for travel by the Tunnel or the Port. The Tunnel/Port would then pay for the facility maintenance costs of the lorry park. This would ensure that vehicles could be sorted to avoid congestion at the M20/A20.

Proposed locations

In their consultation, Highways England have suggested two locations on either side of Junction 11 on the M20: Stanford West and Junction 11 North.

My preference is for the Stanford West site. Its location minimises the use and therefore disruption of local roads. It would have less of an environmental and visual impact on the local surroundings and it is equipped to deliver any/all of the functions proposed in Options 1–4.


It is my belief that Option 4 provides the highest value to lorry drivers and local residents, whilst combatting the issues caused by Operation Stack. I would add that Option 4 Plus should be considered.

Whilst consideration must be given to the impact this construction could have on neighbouring parks or service stations, I believe that getting the most for money is a good use of public funds. It is clear that Option 4 (and ideally 4 Plus) is the proposal that best offers this.

For the reasons stated above, should conclusions on economic and environmental sustainability come back positive, I support construction of Option 4's development on the Stanford West site, but believe Option 4 Plus should be considered as the most efficient method of cross-channel traffic management.


very interested in your views, I to think option 4, and 4 plus are the only way forward, as some return has to to sought, I also believe that with the expected increase in freight crossing the channel, TAP has to become a perminent fixture, otherwise we would be back to square one. totally support your recommendations.
- ray williams

Its not only the operation stack that causes lorry problems we get them parking in Coombe valley Rd Dover every night and weekends causing us problems with rubbish and human waste , parking on pavements and being a nuisance with the speed they travel and the noise and times they pass our houses . I thought it was illegal to park overnight in residential streets ?????
- smurphy

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Charlie Elphicke

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