Letter sent to
Transport Strategy Team,
Planning and Environment Division,
Kent County Council,
Invicta House,
County Hall,
Maidstone,
Kent ME14 1XX

We are responding to your invitation to comment on the draft Freight Action Plan.  What we want to say doesn't fit into the questionnaire format so would you please accept this letter as our response.

It is not easy for Counties to control lorry movements using the limited powers available to them within the existing legal framework. The KCC Freight Action Plan makes a fair stab at the problem, drawing together a number of measures that have already been implemented and suggesting a couple of new proposals. But they are not very specific: the document is vague on the details and gives no timescales for implementation. I suggest we confine our response to asking questions rather than questioning the aims or the policy as such.

The Society strongly supports the efforts of the KCC to control undesirable lorry movements together with inappropriate overnight lorry parking. The draft Freight Action Plan mentions several measures that are already in place. However, we would like the draft to be clearer on the new ones so we can comment sensibly on what is being proposed. Our main queries are as follows:

1. What is the total capacity of the proposed new network of lorry parks and how does it measure up against existing facilities? Could the Plan say where they are to be located, and what is the timescale for implementation?

2. The Freight Journey Planner will be useful for operators who don’t know the local road network, especially those based overseas. Could the Freight Action Plan please explain whether there is a strategy for promoting its use among operators and how it will work?

3. The Plan refers to a proposed connected/autonomous vehicle control corridor on the A2/M2 corridor. Could the Report please make clear who is implementing the plan and what is the timescale?

4. Could the Plan prioritise new areas for implementing Lorrywatch schemes?

5. Could the Plan please specify what options are available for Faversham, whose core network of medieval streets is particularly vulnerable to the environmental impact of heavy goods traffic?

We look forward to your reply….

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Background

The KCC Freight Action Plan Consultation Draft can be downloaded from the KCC web site at kent.gov.uk/freightactionplan. The Plan aims to reduce the impact of growing road freight traffic on local communities. It has been prepared by KCC staff under the direction of the Cabinet Member for Environment and Transport Matthew Balfour. The deadline for responses is 12 March 2017.

What the Plan proposes

There are five main actions, most of which are already taking place. Paraphrased, they are:

1. Tackling the problem of overnight lorry parking

2. Finding a long-term solution to Operation Stack

3. Confining HGV routeing where possible to the strategic road network

4. Protecting local communities by restricting access

5. Planning and development control of potentially harmful freight-generating land uses.

Overnight lorry parking

A survey in September 2016 showed that around 700 lorries are illegally parked overnight on principal roads in Kent. The greatest concentration occurs in Swale around the Port of Sheerness. Ashford Borough Council already issues warning notices and penalty charges for illegal lorry parking, and may clamp frequent offenders. Highways England is proposing an overnight lorry park with 500 spaces at its Operation Stack site.

The Action Plan says the KCC ‘is developing a strategy’ for a network of small lorry parks with suitable facilities for overnight stops. They will be priced so as not to compete unfairly with existing commercial sites. No numbers are quoted, there are no indications of where the sites might be, and there is no indication of the timescale for completion.

Operation Stack

Highways England has created the Operation Stack facility at Stanford West off the M20. It has 3600 spaces. Under extreme conditions this will not be enough and the police will still need to store another 3600 vehicles on the east-bound carriageway of the M20, but the west-bound carriageway will remain clear. In 2015 Dover introduced a smaller scheme on the A20 to protect the Town centre.

The KCC Action Plan supports these initiatives but seems not to propose any further action.

HGV routeing

The Department for Transport is promoting the use of new technology that connects vehicles electronically and allows autonomous (‘hands-off’) control.

The KCC Plan says that a scheme for the A2/M2 corridor is being developed, but does not make clear by whom, or by when.

But the KCC has adopted and developed a Freight Journey Planner on-line mapping tool that can be downloaded from freightgateway.co.uk/kent. It is said to feed into lorry satnavs. The map can be configured to show local height, width and weight restrictions, but not parking controls.

Local communities

In general, there are four ways of deterring lorries from entering sensitive areas unsuitable for heavy vehicles:

- width and height restrictions (on environmental grounds)
- height and weight restrictions (to protect bridges)
- advisory signs (flagging roads that are unsuitable for heavy vehicles – not legally enforceable)
- direction signs (encouraging lorries to use a particular route).

In 2012, KCC launched in collaboration with the police and local communities a Lorrywatch scheme in selected areas. Examples are Smarden, Sandwich and Westerham. Local residents are asked to report instances where lorries violate restrictions to the County’s Freight Officer. Repeated violations can lead to prosecution for UK-based vehicles but not those based overseas. Recently schemes have been added in which the Freight Officer contacts firms whose vehicles have been observed flouting the restrictions, but has no legal powers to enforce them. There is no mention of any scheme, mandatory or otherwise, in Swale.

The Freight Action Plan does not appear to recommend any new schemes under this heading.

Development control

A developer can be required by the KCC to produce a Transport Assessment that identifies potentially adverse impacts of freight movements associated with the scheme together with mitigation measures. KCC monitors applications for HGV operator licences and can object.

The Freight Action Plan does not propose any extension to these measures.