A supporter’s letter to HE

Here is what a friend and supporter of SOS Kent wrote to HE.

The Stanford Lorry Park Proposals

As a resident of Folkestone for over 50 years, I am concerned that this proposed development is out of character with the area, mis-conceived, unlikely to be effective in its declared aims and likely to prove a lasting environmental detriment to the region.
Hence, a failed attempt to solve the wrong problem is going to provide an enduring shameful legacy.

Firstly, if as the consultation document accepts, road freight traffic is likely to double within the planning horizon, the need is for a radical scheme to deal with the problems of tomorrow rather than those of yesterday.
The envisaged future flows, over 10,000 trucks per day outbound, would overwhelm any 3,600 truck park.
A 3,600 truck capacity park is tragi-comically inadequate to deal with multi-day disruption of a 10,000+ daily flow.
This rushed ‘sticking plaster solution’ is an inadequate response to the scale of future problems.

The aim must be to manage traffic flow through the general port region rather than to try to locally buffer the consequences of totally uncontrolled flows which are subject to major disruptions.
Indeed, I recall that one of the promises of the building of the Channel Tunnel was that it would encourage freight to and from Europe off the roads and onto the rail. Strategically, that ought to be revisited – including consideration of better and more diverse road/rail interchange facilities away from the coast.
Similarly, focussing ever more road freight through Dover and the tunnel terminal creates the situation where any disruption to either produces massive consequences.
Strategically de-focussing the flows, making more use of other ports, would provide better resilience. and lessen the consequences of any disruptions on a single route.

The problem of informal and illegal parking of trucks is not limited to the port hinterland. It is concentrated there because of the lack of facilities elsewhere and haphazard enforcement of existing regulations, combined with safety in numbers for the transgressors. More truckstop facilities are needed throughout the country, not simply this county. This unintended consequence of working hours restrictions needs to be dealt with nationally – rather than regionally where the symptom may be most manifest.
Multiple modest developments, particularly expansions where better use can be made of existing infrastructure facilities such as at Motorway Services, and plural smaller new developments on brownfield sites close to motorways, would serve the country as a whole better than this single new honeypot, as I fear that the existence of the facility would make it a route-planning target for hauliers. I don’t doubt that the facility could become busy – my concern is that it would simply create more concentrated demand, rather than defocussing and spreading the traffic.
Far better to have a network of multiple convenient stopping places, so that there could be facilities close to wherever drivers’ hours should happen to run out, rather than a massive ‘target’ that is too far for some, and a distance too short for others.

I don’t see any exit strategy. Such a facility would become essentially permanent, changing the character of its surroundings every bit as much as say a power station or an airport – and deserves similarly detailed consideration, and being planned as a fully-justified part of national infrastructure.

I wonder where in Europe a similar facility could be found?
Benchmarking the proposals against the realities of an existing facility would allow proponents and opponents to have a truly concrete basis to their arguments.
No such facility leaps immediately to my mind, which strengthens my feeling that such a facility is not a necessary adjunct to a transport bottleneck.
Cleverer solutions surely exist.

I am sceptical about the placating assurance given as to rainwater runoff. Shortly after the tunnel terminal development was completed, Folkestone suffered flooding resulting in part from the inadequacy of the drainage (including the underground portion of the Pent Stream) to cope with unexpectedly fast runoff. Despite planning and assurances, the existing infrastructure needed upgrading – and, to cope with a newly instant runoff from something the area of Manston’s runway, I fear will need a further radical upgrade.

I simply don’t accept the bland assurances that entry to such a facility would not disrupt local traffic flows and would not produce queuing back onto the M20. I have seen the queues back to the motorway from the Eurotunnel tollbooths, and the queues that STILL plague the Dartford Crossing even after the removal of the tollbooths that was ALSO promised to result in no queues, and the peak hour queues back onto the M20 at J4 even after the improvement works.
And of course I’m familiar with the tailbacks from the ENTRY to the ‘stack’ schemes.
All of which is why I’m not convinced that entry processing to a proposed ‘stack park’ could be quick enough to prevent backing up onto the main carriageway.
The evidence suggests that the assurance of keeping the main carriageway running safely is unachievable, and certainly unachievable within the realms of likely investment and staffing.

I note that the consultation document accepts the need for “screening” this creation, which implicitly rather than explicitly admits that this proposed development will despoil the AONB and needs to be hidden. Res Ipsa Loquitur.

The fundamental flaw is that this carbuncle doesn’t address the problems causing the disruption.
It merely tries to apply a sticking plaster to the symptoms rather than tackling the disease – which unattended will simply get worse with passing time and increasing concentrated traffic flows.
Vague and implausible assurances have been given about minimising the massive environmental impact of this scheme.
Adding to the implausibility, the consultation document even includes the obvious fallacy that Manston “cannot serve Eurotunnel”. “Cannot?” Really? It may be slightly out of the way (a trivial extra distance in the context of international haulage), but it has the colossal benefit of already existing. Dover Docks is held to be serviceable from Manston – and from Dover Docks, Eurotunnel is easily reached via the A20, the M20 to J11 and a mile or so back on the M20 to J11A for the tunnel complex.
There is simply no need to build a new Manston-size facility elsewhere in Kent.
A “stack park” exists!
What is needed is effort to add robustness, and even some redundant back-up, to the underlying infrastructure – planning to prevent the problems rather than ineffectually deal with their consequences.

Overall, the scheme gives the impression of just trying to show that something is being done about a problem.
But it is only tackling a symptom, not the real problems!
And when the proposal is fundamentally the wrong thing in the wrong place, it isn’t going to achieve its stated aims, and thus represents a waste of effort, money and precious environmental capital that will never be repaid.
All just to look as though something is being done, when what is needed is a smarter approach to the underlying strategic difficulties.

I am against both proposed Stanford developments.

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