Green MEP and Councillor respond to consultation on new lorry park in Kent

Martin Whybrow, Kent County Council member, and Keith Taylor, the Green MEP for South East England, have formally responded to Highways England’s consultation on their plan to build a new £250m lorry park in Kent.

The Green representatives believe that the plans do not stack up, either on economic or environmental grounds, and could create dangerous levels of pollution.

Question 1: Do you have any comments on the indicative layout of the lorry area?

It is a far too large, totally inappropriate site, on prime agricultural land, causing blight for a number of local communities, poor air quality, noise pollution and potential flooding. It is a massive, flawed, hugely costly proposal that was a knee-jerk reaction to an exceptional spell of disruption in summer 2015, failing to recognise that the building (including the bridge) and operation of the lorry park is likely to cause more disruption than the typically once a year event that it is meant to alleviate.

Moreover, the intended bifurcation of traffic into and out of Dover, between the M20/A20 and M2/A2 routes, as set out in Kent County Council’s recently published draft Local Transport Plan, further reduces the relevance of a single huge facility on just one of the two main arteries.

Question 2: Do you have any comments on the environmental impact of the proposals?

It is visible from an Area of Outstanding Natural Beauty, damages ancient woodland, and takes away good quality agricultural land.

At full capacity, 3600 HGVs spewing out fumes will have a huge impact on the health and well-being of local people. And yet air quality isn’t being taken seriously. There is no monitoring of the current levels at the site (to act as a benchmark) and no details of the expected air quality implications of a lorry park of this size.

The Planning Practice Guidance on Air Quality mentions explicitly lorry parks as an example whereby air quality considerations are relevant to a planning decision. Therefore this is an issue that must be more fully considered.

Awareness of the health implications of air pollution from vehicle emissions, including direct effects on mortality as well as on respiratory and cardiovascular diseases, is increasing all the time, with long term exposure to pollutants directly linked to 50,000 premature deaths a year in the UK, with short term exposure attributable to increases in hospital admissions. In early September 2016, air pollution was shown to ‘significantly increase’ the risk of Alzheimer’s disease. To gloss over the impact is a dereliction of duty.

Question 3: Do you have any comments on additional measures we could take to further mitigate the environmental impact of the proposals?

One major frustration has been the short-termism of the proposed solution. A glance at the estimates from the likes of the Port of Dover for HGV volume increases in the next decade show that any facility such as this will only scratch at the surface of the problem. It won’t go anywhere near to solving it.

That £250 million could be so much better spend on areas such as smart technology to head off HGVs at source when there is a problem, rather than allowing them to continue on their journeys and then trying to deal with the problem.

Road transport accounts for about one fifth of the EU’s total emissions of CO2 (cars and vans 15%, heavy duty vehicles 6%). Despite improvements in fuel consumption efficiency in recent years, emissions remain high mainly due to increasing road freight traffic. Hence, the investment to build the lorry park could instead also be used to identify alternatives to road freight, including moving far more by rail, in line with EU targets to shift 30% of long distance (over 300 km) road freight to other modes by 2030. Priority for investing in modal shift should be given to congested corridors, which the route from Dover clearly is. Other ports (such as Rotterdam and Gothenburg) have invested significantly in developing rail infrastructure to promote long term shift away from road-based freight.

Additional measures include building more resilient local economies to reduce the demand for imported goods, and moving goods much closer to their destination by sea before unloading, which would also reduce the systemic risk linked to having so much of the country’s traffic moving through a single corner of the country.

Question 4: Regarding the management of the site, do you have any comments on: a) traffic management, b) security, c) operation of overnight parking, d) management in general?

There are some highly pertinent questions about the operation of the site that don’t appear to have been answered (or, perhaps, even thought about). For instance:

How long would it take to activate the park if required, how are staff mobilized at short notice and what happens to lorries in the meantime?

When in use, does all HGV traffic go via the park? If Dover Port is closed but the tunnel is open, or vice versa, how could the lorries be identified for each route and directed accordingly?

It looks to have the potential for embarrassing chaos, replacing one form of gridlock with another, including stemming from the interim closure of Junction 11 when the lorry park is operational. It is no wonder that Port of Dover, Eurotunnel, the Transport Select Committee, MOTIS, DEFRA, CPRE and others all have reservations over elements of the project.

In terms of security, there are the implications of a lorry fire within the park, particularly when at full capacity, to be considered. How would emergency services access, in time, any such situation before it became a major incident?

Question 5: Do you have any comments on the facilities that should be provided at the site?

It makes no sense to consider its use for general overnight lorry parking but on the basis that the charges will be higher than local privately run lorry park facilities so as not to undercut the latter. And all the while some HGV drivers are not paid expenses, they will not use paid-for facilities unless there is a change in legislation so, as it stands, additional lorry parking will do nothing to reduce the parking of HGVs on Kent’s roads.

Question 6: Do you have any comments on how the operation of the site should be kept under review?

See comments in previous sections. As with any new development, it is important to put into place systemic review mechanisms, not just of the operation of the lorry park, but also the availability of alternatives. This requires that transparent and accountable monitoring and evaluation systems should be considered from the outset of the proposed development and that future stakeholder consultations with those affected should be more of a process than a one-off to ensure that the social, economic and environmental considerations of the park continue to be monitored and held to account.

Question 7: Do you have any other comments?

To state that the majority of local residents support the lorry park, as Highways England has done, is wholly misleading. This is reflected in the level of opposition from local parish councils and thousands of residents, including on social media, via petitions, and on demonstration marches. The health and well-being of local residents is being completely ignored and at no stage has there been a proper consultation about whether there should be a lorry facility such as this per se. To consult on two neighbouring sites, both hopelessly flawed, is not a consultation. There has been an appalling lack of transparency and democracy.

This response stems from one of the local Kent County Councillors, Martin Whybrow (Green Party), and the Green Party’s South-East MEP, Keith Taylor.


Highways England is consulting on its plans until 23 September 2016.