Operation Stack Contents

2Background

Brief history of Operation Stack

15.Operation Stack was first deployed in 1988 (during industrial action on the UK side of the English Channel)12 and has been in use at varying intervals ever since. Over time, complex and extensive iterations of Operation Stack have been developed—latterly including the use of the London-bound carriageway of the M20, once closed sections of the coast-bound carriageway are full.

16.In 2005 a coned contraflow element to Operation Stack (to allow other traffic to continue using the M20) was trialled, but the time required for set-up and removal made it impractical.13 In 2008 the Highways Agency leased a Quick (or Quick-change) Moveable Barrier system for use in setting up a mobile concrete contraflow barrier during Operation Stack. However, the device (bespoke machinery which was leased at a cost of £627,849 a year) was used only twice in the following four years and its lease was ended in April 2012, apparently on the grounds that it was not cost-effective.14

17.Despite the development of plans for the implementation of Operation Stack on an extensive scale, in practice it has mostly been deployed only for short periods using limited capacity. (The longer the time that Operation Stack is deployed, the greater the capacity required, due to the lengthening of the queue.) The DfT stated in evidence to us that Operation Stack has been deployed “typically for a few days a year and only for a few days at a time and accommodating up to about 2,000 lorries”.15 Kent County Council (KCC), meanwhile, told us that Operation Stack had been “implemented 48 times between 1997 and January 2015 with an average duration of 5–6 days a year”;16 it has been called on average “more than twice every year “.17

18.There have been rare occasions when Operation Stack has been deployed more extensively, as shown by analysis of data that was supplied to us by Highways England (see Figure 2). As can be seen, 2015 saw a significant spike in the deployment of Operation Stack. Reasons for the deployment of Operation Stack in peak years are set out in Table 1.

Figure 2: Annual rate of deployment of Operation Stack, 1998–2015

Figure showing on how many days Operation Stack has been deployed in each year

- The annual totals have been arrived at by counting the total number of dates in each month when Operation Stack was in operation and then combining the monthly totals for each year.

- There are other ways of arriving at annual totals, which produce slightly different figures. However, the trends remain the same regardless of which methodology is used.

Source: Highways England

Table 1: Reasons for the deployment of Operation Stack in peak years

Year

Days

Reasons

2000

25

Industrial action and demonstrations in Calais (port, ferries and Eurotunnel)

Congestion at Port of Dover and Eurotunnel

Technical problems at Eurotunnel

Adverse weather

2005

27

Adverse weather

Industrial action and demonstrations in Calais (port, ferries and Eurotunnel)

Berth damage at Port of Calais

Technical problems at Eurotunnel

2008

39

Adverse weather

Industrial action and demonstrations in Calais (port and ferries)

Fire at Eurotunnel

Congestion at Port of Dover and Eurotunnel

2015

31

Fire at Eurotunnel

Industrial action and demonstrations in Calais (port, ferries and Eurotunnel)

Migrant action in Calais (Eurotunnel)

Sources: Kent County Council (2000); media reports (2005 and 2015); Kent Police (2008)

Operation Stack in summer 2015

19.The summer of 2015 saw prolonged industrial action by French ferry staff, who were protesting at the consequences of restructuring cross-Channel ferry operators following a ruling of the UK Competition and Markets Authority.18 At the same time, sustained attempts by migrants to breach security provisions at Eurotunnel in Calais (Coquelles), in order to come illicitly to the UK, led repeatedly to the disruption of services.

20.This unprecedented combination of circumstances meant that Operation Stack was deployed almost continuously between 23 June and 1 August 2015—on seven occasions for a total of 26 days.19 The constant deployment of Operation Stack in this way had not previously been seen—not even in previous peak years of deployment. The consequence was that large numbers of vehicles built up in the queue, necessitating the use for the first time of the London-bound carriageway, with the implementation of Stage Three of the then current iteration of Operation Stack (see Table 2), on two occasions, for a total of four days.20 At the peak, 7,000 Heavy Goods Vehicles (HGVs) were queued on the M20, taking 36 hours to work their way through.21 This disruption had significant national and local consequences.

Table 2: Operation Stack from spring 2015 to 4 August 2015

Stage

Extent

Vehicle capacity

Total vehicle capacity

One

Junction 8 (Leeds Castle) to Junction 9 (Ashford West), M20 coast-bound carriageway—two lanes

2,100

2,100

Two

Junction 9 (Ashford West) to Junction 11 (Hythe), M20 coast-bound carriageway

1,500

3,600

Three

Junction 9 (Ashford West) to Junction 8 (Leeds Castle), M20 London-bound carriageway

2,100

5,700

Four

Junction 11 (Hythe) to Junction 9 (Ashford West), M20 London-bound carriageway*

1,500

7,200

* Stage Four was never implemented.

Source: Highways England

21.Natalie Chapman, of the Freight Transport Association (FTA), told us about the impact on the haulage industry of the sustained deployment of Operation Stack in 2015:

At its worst, vehicles were queueing for over 24 hours, so there were some products that did not make it to market because they went off in the queue. There were others that arrived so late that there were late penalties. There were particular issues around things like express courier deliveries that are very time-sensitive. Again, they did not make it to market in time.22

22.We were, though, told by the Chief Executive of Highways England, Jim O’Sullivan, that the average delay, even with Operation Stack “at its worst”, had been “about four to six hours; in the way it worked out last summer, an individual truck was only held for that period of time”.23

Short-term measures introduced in 2015

Leasing of the former Manston Airport site

23.From 4 August 2015 arrangements for Operation Stack were amended to include the use of the former Manston Airport24 site (now known as “Stone Hill Park”), in the district of Thanet, as an interim lorry park for Dover-bound traffic. These vehicles would be “drained” from the queue on the M20 carriageway, “leaving only Eurotunnel HGVs on the M20”.25 Separating Port traffic from Tunnel traffic in this way would avoid the deployment of Stages Three and Four of Operation Stack, meaning that the London-bound carriageway could continue to take traffic (see Table 3 and Figure 3).26

Table 3: Operation Stack from 4 August 2015 (not yet implemented)

Stage

Extent

Vehicle capacity

Total vehicle capacity

One

Junction 8 (Leeds Castle) to Junction 9 (Ashford West), M20 coast-bound carriageway

2,100

2,100

Two

Junction 9 (Ashford West) to Junction 11 (Hythe), M20 coast-bound carriageway

1,500

3,600

Three

Stone Hill Park (Manston)

3,500 to 4,000*

7,100 to 7,600*

* Operational capacity of Manston depends on traffic conditions and may be less than the maximum parking capacity of the site.

Source: Highways England

24.This was facilitated by a lease agreed with the owners of Manston by the DfT. The arrangement was initially to be for three months but was subsequently extended until June 2016. A Statutory Instrument granting temporary planning permission for nine months was passed on 1 September 2015.27 In addition, the statutory powers of Highways England’s Traffic Officers have apparently been extended to allow them to direct traffic to the site (since there are no statutory powers that would allow Kent Police to direct a particular class of traffic onto private land in this way).28

25.David Brewer, Network Delivery and Development Director for Highways England, said that the members of the Strategic Coordinating Group had agreed that Manston “was the best available solution”.29 We detected little enthusiasm for the Manston option, though. Ms Chapman, of the FTA, told us that: “Manston is only a short-term measure—very short term, we hope. It is far from ideal. I suppose it is the best of a bad bunch of options”.30

Figure 3: Manston diversion route

Map of diversion routes at Manston Route for freight: As Operation Stack fills, freight traffic heading to the Port of Dover will be diverted to Manston Airfield, before being sent onto the port. For Dover-bound freight travelling southbound from the Dartford-Thurrock Crossing, Variable Message Signs (VMS) will divert traffic onto the A2/M2. For Dover-bound freight travelling eastbound along the M20 from the M25, VMS and hard signage will divert traffic to the M2/A2 using junction 7 of the M20 and A249. Traffic will be directed by hard signage at junctions along the route to junction 7 (Brenley Corner). At this point freight traffic will be separated from tourist traffic by way of hard signage. Dover freight will be directed along the A299 with hard signage at all key junctions. Once Manston is active as a Dover-bound freight holding area, any traffic which ignores the signage at M20 junction 7 will be turned around at junction 8 to return to the diversion route at M20 junction 7. If you are using Port of Dover during Operation Stack and you do not use Manston, you will be turned back, costing you time and money.

Source: Highways England

Feasibility of using Manston

26.When we asked Paul Watkins, the Leader of Dover District Council, about the likely effect of rerouting traffic from Manston to Dover, he told us the impact on traffic would be “horrendous”. He referred to the lack of dualling along stretches of the A256 (which connects Thanet and Dover) and the “log-jam” that would occur. Mr Watkins also thought there were “policing issues”, such as preventing “rat-running through the local villages”.31

27.Kent Police themselves have also expressed concerns about the plan to use Manston. Information released in response to a Freedom of Information request shows that on 9 July 2015 the Chief Constable of Kent, Alan Pughsley, texted the Leader of KCC, Paul Carter, to say regarding the possible use of Manston that “the challenging logistics of this venue would probably make it a non-starter unfortunately”.32 Shortly afterwards, on 14 July 2015, Mr Pughsley told the Home Affairs Committee that if Manston were used:

My team would say, “We cannot logistically do that because you would have to escort the lorries from the M20 all the way over to [ … ] Manston Airport”. If the Highways Agency or Highways England decided they could escort that there may be another conversation around that.33

28.A letter from the Chief Constable to the Leader of KCC, dated 30 July 2015 (also later released in response to a Freedom of Information request), identified the following drawbacks to using Manston:

The Chief Constable concluded that: “These points indicate that Stone Hill Park would not be a viable solution, but the decision to progress any further work would sit with Highways England as the primary agency.”34

29.Just four days later, on 4 August 2015, the DfT and Highways England announced that Manston would be used and quoted the Deputy Chief Constable of Kent, Paul Brandon, as follows:

Following work by the Department for Transport and Highways England, the option to divert freight bound for Europe to Manston Airfield, whilst very challenging, has become more feasible in terms of resourcing and logistics. Working with more resources than ever, including mutual aid from other police forces, Highways England and other agencies we are all committed to making the plan from the Department for Transport work [ … ]35

30.When we asked Assistant Chief Constable Jo Shiner in October 2015 about Mr Pughsley’s comments to the Home Affairs Committee, she told us:

The Manston option has not been tested; it cannot be tested until the criteria are there. It is quite a serious step to actually invoke the Civil Contingencies Act, with all the risks around doing that. It cannot be fully stress-tested until those conditions are there. Yes, we do have concerns, which we have articulated throughout, about the Manston option. Having said that [ … ] it is the best of a number of bad options, to be frank.36

31.At the same hearing, Mr Brewer, of Highways England, told us:

We agreed the diversion routes to and from Manston. We worked with Kent County Council to understand how we would direct traffic to and from, and we worked with the police and others to figure out how we would manage that operation.37

Mr Carter, of KCC, told us:

I am not as pessimistic about the Manston solution as others. I genuinely believe it will be good to see it tried and tested. If additional policing is put in through reciprocal arrangements with Essex Police, and there is a real will to keep the M20 and the Queen’s highway open in both directions, I believe that that is doable.38

32.When we heard from Mr O’Sullivan, of Highways England, in April 2016, he was adamant that all appropriate preparations had been made:

Last year, we checked all the routes to and from Manston. We carried out truck manoeuvring on Manston. We tested the queueing and the marshalling of trucks within the arrangements that we had put in place. We put the signage up. We tested the routes between Manston using our own HGV vehicles—impact protection vehicles and the like; we did testing with those vehicles to make sure that the routes were suitable for large vehicles and that they could see traffic signals and signs [ … ] By the time we entered September, the thing had been rigorously and thoroughly tested for its suitability.39

33.When we asked the Minister, at the same evidence session, about the Chief Constable’s comments to the Home Affairs Committee, Mr Jones stated that the police had not questioned the arrangements regarding Manston since the signing of the deal.40 In subsequent correspondence, he told us that a “new operational protocol” had been “agreed by a multi-agency group including Kent Police, Kent County Council, Highways England and Department for Transport officials on 6 August 2015”; it had also been agreed on the same day by the Kent Strategic Coordinating Group. However, this document could not be made public, “given its security sensitive contents”.41

Cost of using Manston

34.Another point of contention regarding the use of Manston is how much it will cost. On 4 August 2015 a Freedom of Information request was submitted to the DfT, asking about the cost of the Manston lease, as well as the cost of additional signage, policing and other arrangements in connection with using Manston as part of Operation Stack. In its response, dated 3 September 2015, the Department cited an exemption under section 43 of the Freedom of Information Act 2000 (that the release of the information would prejudice the commercial interests of any person) in respect of the cost of the lease. Regarding the second question, the Department responded that it “does not hold any information relating to the additional costs of policing and signage in relation to the use of Manston within Operation Stack”.42

35.When our Chair wrote to the Secretary of State in October 2015, she made a point of asking for detailed information on the Manston deal, in order to allow us “to take a fully informed view on whether this arrangement represents value for money”. However, Mr McLoughlin stated in his reply that the cost “cannot be disclosed to the public at this stage as this is commercially sensitive information”.43

36.We had no more success when we asked the junior minister responsible, Mr Jones, about this in April 2016. He told us that it would not be appropriate to talk about cost details, as the DfT was looking to further extend the lease on Manston and that “further negotiations are potentially compromised if we do them in public”.44 (The Minister and Mr O’Sullivan indicated that Manston would continue to be maintained as a “back-up” facility for Operation Stack, pending the completion of the lorry park.)45 The Minister did, though, hold out the possibility of releasing some information, in the interests of transparency, once any new deal had been concluded.46

37.It has since been reported, although not confirmed, that the lease is to be extended to the end of 2017.47

Other short-term measures

38.On 4 August 2015 the DfT announced that a filter system for “quick-to-market” goods would be trialled in the event that Operation Stack was again deployed. Under this scheme, hauliers producing a CMR48 note detailing that they were carrying various kinds of urgent, hazardous or perishable freight would not enter Operation Stack on the M20 or at Manston, but would instead be routed directly to the Port of Dover or the Channel Tunnel.49 The FTA anticipated that no more than 200 lorries per day would be given priority under this provision.50

39.In addition, from 30 July 2015 until 28 August 2015 the DfT applied a temporary relaxation of rules governing drivers’ hours in the event that Operation Stack was necessary.51

40.We heard that consideration had also been given to the reintroduction of a contraflow element to Operation Stack, but that this had been ruled out. Mr Brewer, of Highways England, told us it had been concluded that neither of the available options (the use of cones and the setting up of a fixed barrier) was practical or safe.52

The off-road solution: a permanent lorry park

41.The events of 2015 gave new impetus to the idea of building an off-road lorry park as a permanent solution to the problems posed by Operation Stack. This had been in circulation for some time and certain stakeholders, notably KCC, had long been indicating their support for it.

42.The Cabinet’s Civil Contingencies Committee (often referred to as “COBR”)53 requested that a preferred solution to the problems caused by Operation Stack be brought to its meeting on 21 August 2015. Highways England and KCC commissioned further work for this purpose from the European Gateway Strategic Delivery Group—a multi-agency taskforce that had been set up earlier in the year to develop short-term solutions to freight congestion around Dover and long-term changes to Operation Stack.

43.On the basis of further work by the Group, an “optimum package of measures” (with a preliminary costing of £468 million) was presented to COBR. The package included the construction of a lorry park capable of accommodating approximately 4,000 HGVs in a location close to the M20—although no specific site was mentioned.54

44.By October 2015, Highways England was “leading on the land acquisition, planning and delivery of a Lorry Holding Area with Permitted Development rights as the Highway Authority under Section 115 of the Highways Act 1980”.55 This statute allows Highways England to build a “lorry area” without the obligation to follow any of the normal planning procedures that would otherwise apply.56

45.When we held our evidence session in October 2015, we heard a number of arguments in favour of building an off-road lorry park as the best solution to the problems caused by Operation Stack.

Arguments for a lorry park

Keeping the M20 open

46.There are clearly serious consequences for the local community and the local economy when the M20 is closed; major inconvenience and cost are caused to individuals, public bodies and private businesses. A particular burden is borne by the A20, which becomes heavily congested with traffic diverted from the M20. Delays to freight traffic also have implications for the economy as a whole.

47.Jennifer Hollingsbee, Deputy Leader and Cabinet Member for Communities at Shepway District Council, told us of the impact on her village of Sellindge, through which the A20 passes:

Children cannot get into the primary school [ … ] People cannot get to the doctor’s surgery [ … ] I cannot get out of my road on to the A20. There is a snarl-up the whole time. People want to go to the toilet. Even residents along the road, because cars have stopped waiting for the traffic lights to change, have been out and allowed people to go in and use their facilities [ … ] Local schools have coach trips for students. Some of them have not been able to go. Westenhanger Castle is very near junction 11. It had to cancel a number of weddings. The person who actually owns Westenhanger Castle was in tears and the bride was in tears because people were not able to get there. In Shepway as a whole, 15,000 people a day travel out of Shepway. They are held up by Operation Stack. They cannot get to their offices. Some of the shops are not able to open. We have 11,000 people coming into Shepway and it is the same kind of thing. The movement of traffic is absolutely gridlocked.57

48.As well as the immediate financial costs to the local community (which are discussed further below), we heard there is also “collateral damage to Kent’s brand as the ‘Garden of England’”, discouraging tourists from visiting; and a deterring of inward investment, due to the “negative image” of the county that is conveyed.58

49.There was widespread agreement in the evidence we received that it is unacceptable for the M20, which is “a key part of our strategic road network”,59 to be completely closed for any length of time.

Driver welfare

50.Ms Chapman, of the FTA, explained that an important reason for favouring an off-road form of Operation Stack was the need to provide better facilities for drivers. She told us that in Operation Stack at present: “There are some portaloos along the roadside but there is not a lot in the way of facilities.”60 KCC told us:

Drivers are stuck in their vehicles for many hours without heating or cooling, food and water, and toilet and washing facilities; therefore during Operation Stack emergency temporary welfare facilities are provided by KCC at a cost to the taxpayer.61

Mr Carter said:

When you have lorry drivers held by the side of a road for 36 hours, it is unacceptable. You have to have the 4,000 spaces where you can provide the proper and appropriate facilities to support that number of drivers who are held up for that length of time. Four or five hours sitting on the hard shoulder of a motorway is acceptable, with the toilets we have put in and this, that and the other, but any longer than that and you have to have a movement and flow rate to allow people to progress off the carriageway into the lorry park where they can have the appropriate facilities [ … ]62

51.Another consideration related to drivers’ welfare is the need to allow them to take proper rest breaks, which Operation Stack currently tends not to do. Ms Chapman told us:

Most of the time while the vehicles are in Stack they are stationary, but of course it is a queue and the queue does move forward. That is part of the problem for drivers in the queue, because it causes havoc with the drivers’ hours rules. They are probably not stationary long enough to take their statutory breaks [ … ]63

An “off-carriageway solution” would “allow them to sit for long enough to take their breaks so that they are not constantly moving forward”.64

Maintaining freight fluidity

52.Another argument that we heard in favour of an off-road solution concerned the necessity of maintaining the fluidity of freight traffic—so that when cross-Channel services do resume, the available capacity can be filled quickly and efficiently.65 Peter Cullum, of the Road Haulage Association (RHA), told us:

One of the key factors is that you must be close to the ports to be able to call them forward. The major inefficiency is if the carriers across the channel are not full. Therefore they have to be accessible to that. Ideally, they have to be off-road.66

Ms Chapman told us:

The worst crime during Operation Stack is to see trains or ferries leaving half empty. We need to make sure that they are full to capacity, so that we can release those vehicles, get them going and keep the supply chain running.67

53.Tim Waggott, Chief Executive of the Port of Dover, stated that ferries operating out of the Port of Dover have an “uplift capacity of 300 [lorries] an hour”. Accordingly, in order to operate at maximum efficiency, the Port needed vehicles to be released from any queueing arrangement at that rate.68

Government funding commitment

54.In our Chair’s letter to the Secretary of State in October 2015 she informed him we had heard in evidence that:

there was a consensus that an off-road lorry park offers the best solution, as this would potentially eliminate the need to close parts of the M20 and would improve the situation for local communities [ … ] As this solution has been recommended from numerous quarters, and any solution that keeps the M20 open would be of national benefit, I would like you to make clear what the Government intends to commit to the development of an off-road solution, how quickly you expect one to be put in place, and what other steps your Department might take to mitigate the effects of Operation Stack until an off-road solution can be put in place.69

55.In November 2015 came the Government’s announcement that it was committed to “providing up to £250 million for a major new permanent lorry park to increase resilience in Kent, by taking pressure off the roads in the event of Operation Stack” and would “consult on a preferred site at Stanford and other alternatives shortly”.70 The Chancellor of the Exchequer indicated that this decision had been taken following representations made to him by Kent MPs.71

Highways England consultation, 2015–16

56.The consultation undertaken by Highways England during December 2015 and January 2016 (which was non-statutory in character) sought views on which of two locations at Stanford should be used for the planned lorry park; and how exactly the lorry park should be used. The consultation envisaged a number of different ways of using the lorry park:

Use only as a holding area (with basic driver welfare facilities) to accommodate lorries in lieu of deploying Operation Stack on the M20.

Use as above—and also to alleviate queues developing at the freight terminals at other times.

Use as above—and also to provide basic overnight parking facilities (for a fee) during times of normal operation of cross-Channel services.

Use as above—and also to provide truckstop facilities (a motorway service area focussed on providing facilities for lorries) during times of normal operation of cross-Channel services (with parking charges levied after the first two hours).

57.In correspondence from November 2015, which has been forwarded to us by the recipient, Highways England states that “Our study of other sites suggests an area of about 65 hectares will be needed.”72 In December 2015, in its consultation document, Highways England referred to the need for the lorry park to cover an area equivalent to the Manston site (61 hectares), in order to accommodate the same number of vehicles envisaged for Manston (3,600 to 4,000).73

Construction timetable

58.We heard from the Minister that, in keeping with the DfT’s desire to proceed “at pace”, the lorry park would be built “as quickly as possible”. Mr O’Sullivan added that Highways England:

would very much like to enter summer 2017 with some part of this scheme available [ … ] [W]e would like to have it available for 500, 1,000 or 1,500 trucks—whatever we could manage next summer—and then finish it as quickly as the construction will allow.74

59.This, of course, entails a quick decision by the Minister on where to build the lorry park and how exactly it will be used, based on Highways England’s recommendations following the public consultation. Mr Jones told us that he would be making his decision with the involvement of the Secretary of State, as well as local councils and others in Kent.75


13 BBC News, “Changes to Operation Stack system”, 24 March 2005

15 Department for Transport (OPP 019)

16 Kent County Council (OPP 055)

17 Q47

18 Eurotunnel’s ownership of ferries leased to a cross-Channel operator was held to be contrary to competition rules.

19 Department for Transport (OPP 063)

20 Qq178, 203 [Jon Griffiths], 204

21 Kent County Council (OPP 055); Qq2, 5, 51

22 Q2

23 Q195

24 Our predecessor committee examined Manston as a case study of a small airport: Transport Committee, Ninth Report of Session 2014–15, Smaller airports, HC713.

25 Kent County Council (OPP 055)

26 Qq 26, 67

27 The Town and Country Planning (Operation Stack) Special Development Order 2015 (SI 2015/1635)

28 WhatDoTheyKnow, Kent Police and Operation Stack, 21 September 2015. Traffic Officers hold powers under the Traffic Management Act 2004.

29 Q66

30 Q26

31 Q85

32 WhatDoTheyKnow, Kent Police and Operation Stack, 21 September 2015

33 Oral evidence taken before the Home Affairs Committee on 14 July 2015, HC (2014–15) 318, Q14

35 Department for Transport, Highways England and Lord Ahmad of Wimbledon, New measures to relieve pressure on Operation Stack, 4 August 2015

36 Q76

37 Q70

38 Q75

39 Q245

40 Qq246–9

41 Department for Transport (OPP 063)

44 Q240

45 Qq237–8, 243–5

46 Qq241–2

48 Convention relative au contrat de transport international de marchandises par route (Convention on the Contract for the International Carriage of Goods by Road)

51 DfT, “Notification—Port of Calais industrial action: temporary relaxation of the enforcement of drivers’ hours rules”, 29 July 2015. A similar relaxation has been applied in Scotland, for drivers affected by the closure of the Forth Road Bridge – trg logistics, Relaxed drivers hours rules due to Forth Road Bridge, 14 January 2016

52 Q59

53 “COBR” (or “COBRA”) is an acronym for the Cabinet Office Briefing Rooms, where the Civil Contingencies Committee meets.

54 Paper for KCC Environment and Transport Cabinet Committee, “Solutions to Operation Stack: Freight Fluidity for the UK’s Gateway to Europe”, 16 September 2015

55 Kent County Council (OPP 055)

56 Highways Act 1980, section 115

57 Q84

58 Kent County Council (OPP 021)

59 Q11

60 Q2

61 Kent County Council (OPP 021)

62 Q51

63 Q6

64 Q11. See also Q13 [Peter Cullum].

65 Qq11, 13 [Peter Cullum], 26 [Peter Cullum], 33 [Natalie Chapman], 39, 51, 85, 184

66 Q13

67 Q33

68 Q33. See also Q85. This equates to the Port’s peak capacity of “between 60 and 70 sailings a day, all of which uplift 100 freight vehicles” – Q17.

70 HM Treasury, Spending Review and Autumn Statement 2015, Cm 9162, November 2015, para 1.269

71 HC Deb, 25 November 2015, cols 1366 and 1391–2 [Commons Chamber]. See also HC Deb, 27 October 2015, col 192 [Commons Chamber]

72 Letter from Highways England, 30 November 2015

74 Q222

75 Q224





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25 May 2016