We were gobsmacked by our honourable member’s tweet this week:
Clearly he’s forgotten the litany of lies he sent to the Transport Select Committee earlier this year, which we tried to put him straight on with the following letter. He has not replied. He was even misleading the House itself in the debate on 7 September when he repeated the £250m a day nonsense.
Mr Damian Collins, MP
House of Commons
11 May 2016
Dear Mr Collins
Operation Stack and Lorry Parks
I was very disappointed in your submission to the Transport Select Committee which they published this week. In summary, you have repeated information which was already available to the Committee from other sources (much of which is wrong or misleading) thus adding little to the debate, while saying nothing about the interests of your constituents than a passing reference to “screening”.
You emphasise the scale of the problem of Operation Stack (in 2015). This is not disputed and the Committee hardly needs reminding of it.
You then quote KCC’s estimates of the cost to the Kent economy of Operation Stack, again based only on the situation in 2015 which is acknowledged as exceptional. I have no idea whether these figures are accurate, but for a typical Stack event (which does not cause the multi-day disruption experienced last year) the daily costs must be lower. Even if we accept these figures as typical, given Phase 2 of Operation Stack is called on average only once a year, and it is very rare for a Stack event to last more than 24 hours, the average annual cost to Kent can only be of the order of £1-2m. Figures like £46m grab headlines but the costs in a typical year do not justify spending £250m or even £160m.
You go on to make the now well-worn error of saying Operation Stack costs £250m a day. If there is any truth in this figure it is the cost of disruption at the ports, not the cost of closing part of the M20. Lorry parks will not mitigate that cost. You also ascribe this figure to the FTA but Ms Chapman and Andrew Jones made it clear it came from Port of Dover’s estimate of the total value of goods passing through the Port. It is ridiculous to suggest that this value will be totally wiped out by even a 3-day delay in delivering goods to market. The figure is both wrong and irrelevant.
Next you claim that with increasing traffic, Operation Stack will be called more frequently. Not so. The port operators have invested millions over the years to ensure that they can handle the peaks in traffic arriving at their gates and continue to do so. It is external events which cause the congestion which prompts Operation Stack and there is no reason why these should become more frequent as traffic flows increase. In contrast to the port operators, and apart from the odd traffic light, Government has invested nothing at all in infrastructure that would ease the flow of traffic to the ports or reduce the blight of “fly-parking” in Kent and further afield. “Doing nothing” clearly has been Government’s preferred option since completion of the A20 upgrade Folkestone-Dover last century. It is ironic that politicians should now be saying doing nothing is not an option.
“The proposals brought forward are the result of a considerable amount of work by Highways England and Kent County Council”. Not true. Most of considerable work was to find suitable sites for overnight lorry parking, or smaller sites for Operation Stack events. When the goal-posts were moved in about October last year, Highways England had a different brief to follow and they have admitted to the Committee that they have not had adequate time to study it properly.
The many sites which you say were examined and discounted will have been rejected because they do not offer 4000 spaces close to the ports. Port of Dover say they can handle 400 trucks per hour at full tilt and Eurotunnel 300. Why is it necessary to have 5-6 hours’ supply of trucks parked up near the ports? Disperse them to smaller parks and many more sites become suitable and also available for overnight parking the other 360 days of the year.
“[The site] needs to be on the coast-bound carriageway of the M20”. The current proposal includes a bridge, so obviously a lorry park can be either side of the motorway.
“It needs to be ….. as close to [the Chunnel] as possible to ensure we have proper enforcement”. No. The reason for wanting it close to the port(s) is that port operators worry (in my opinion unnecessarily) that they will not have full ships and shuttles in the hours after full capacity is restored.
“… only an estimated 30% of drivers follow instructions such as diversions”. I think this figure is wrong. Mr O’Sullivan stated to the Committee “[compliance with Operation Stack last year] was very high”. Cllr Balfour is quoted in the transcript of the March hearing “There was 30% compliance at the beginning of Stack the last time round”. I was there, and believe he actually said “30% non-compliance” which matches figures I have heard from elsewhere, but the key thing is that it relates only to the beginning of Stack. Similar non-compliance is reported for the early days of TAP, but once drivers understand the system and recognise the penalty for non-compliance, they toe the line. There will always be cheats, but to say 70% of drivers don’t follow the rules is just scare-mongering.
You say “the site needs to be as unavoidable as possible”. The only way to make it unavoidable is to have a policeman standing on the motorway carriageway at Junction 11 (and another one somewhere on the A2). Otherwise, any driver can just turn up at the port gates. This has nothing to do with where a lorry park is or whether there is just one or many of them.
A lorry park will be no better at ensuring compliance than the existing Operation Stack and could easily be worse.
You state a preference for “Stanford West” on operational grounds but ignore the comparative impact of the two sites on your constituents.
I do not understand why having a site “split” from Stop24 is a disadvantage. Drivers wanting to eat can get there just as easily from Shrine Farm as from Stanford West (they won’t be taking their lorries with them).
“Property screening” will do nothing to mitgate air pollution and the impact on the landscape, including the setting of the AONB and heritage assets which feature strongly in Kent’s attraction to tourists.
“… broad agreement amongst witnesses that a lorry holding area would solve the problem of fly-parking”. Nobody has said that, in fact there is agreement that multiple sites are the answer for fly-parking. The proposals may have an impact on fly-parking in Shepway but only if it is used for overnight parking ie in competition with existing park operators which everyone has acknowledged is to be avoided. It would have less impact on the problem in Ashford and none at all further west and along the M2/A2 corridor which also suffers this blight. Multiple parks would have a much bigger positive impact. The Ashford experience is encouraging but such enforcement measures are like swatting flies unless there are legal places nearby to park.
“The lorry park could also be used to regulate the flow of traffic into Dover”. Indeed it could but it still would not be justifiable. You will be aware that Port of Dover and Dover District Council disagree and Port of Dover think Stanford is too far from the port for either TAP or Stack purposes.
In summary, Mr Collins, there are so many things wrong in your submission that I have felt compelled to write to you for the first time on this matter. Your submission serves only to bring extra truthiness to the misleading information put out by others which will not help the Committee at all to reach a sensible conclusion.
Your time would have been better spent explaining the plight of your constituents to the Committee and taking the trouble to understand why planting a few trees is going to do nothing to make this an acceptable project.