KCC Draft Freight Action Plan

Letter sent to
Transport Strategy Team,
Planning and Environment Division,
Kent County Council,
Invicta House,
County Hall,
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….



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.





A report of the meeting held on 07 October 2016 in the Assembly Rooms

The purpose of the meeting was to bring to the attention of our members the Kent County Council’s recently published Local Transport Plan LTP4 and to seek their views on transport problems in the Town as an aid to formulating the Society’s response to the Plan.  It was organised by members of the Environment Committee and chaired by Hilary Whelan.

Around 50 people attended the meeting, including the organisers and committee members.  All were invited to complete a questionnaire on their travel habits (the results have not yet been analysed).  The meeting began with a video showing an interview recorded in 2013 with Arthur Percival, in which he described how the Society had previously campaigned against the KCC plan to build a ring road in the Town.  There followed a break-out session in which attendees jotted down their concerns about transport in Faversham today on ‘post-it’ notes, and Brenda Chester read some of them out.  Then Chris Wright gave a presentation summarising the contents of the current plan and its implications for the Town.  The key points are set out in the Appendix to this report.  There followed a lively discussion.

An analysis of the post-it notes revealed two stark conclusions.  First, those who attended the meeting want to make life easier for the motorist.  I divided the subject matter into a handful of main categories (road improvements, parking, cycling & walking, environment, planning, and ‘other’) and it was striking how the largest number of responses (about a quarter) fell into the category of road improvements.  People were greatly exercised about Brenley Corner, the possibility of a new link to the M2, better parking facilities, and the conversion of busy streets into one-way working.

Second, our attendees were less concerned about environmental issues than I expected, in particular, how traffic growth might affect our medieval street frontage and the quality of the environment as a civilised place in which to walk about.  Only one post-it note mentioned architectural heritage.  It seems the Society will need to work hard to alert members to the dangers inherent in a Local Transport Plan that will do little to protect Faversham and towns like it for future generations.

In addition to the key points made during the presentation, the Appendix lists some suggestions that the Board might like to use as a starting point for the Society’s response to the KCC.

Chris Wright

14 October 2016



Key points in Chris Wright’s presentation

  1. The Plan is strategic rather than local, with the emphasis on the main transport corridors between London and the Channel ports together with pinch points on other parts of the County road network. The main ‘local’ areas are the Thames Gateway and East Kent.
  1. But Faversham isn’t mentioned, and residents in all areas want to see how the growth will affect them.
  1. Like many other towns, Faversham is under pressure to provide more land for housing in the surrounding area. During the last few months, the total number of housing units with outline planning permission has escalated to about 1800.  The consequences will be far-reaching.
  1. It is well known that peripheral housing development has a disproportionate effect on road traffic mileage. Residents in outlying areas must travel further to achieve their ends and are more likely to travel by car than those living near the centre.  Consequently, each peripheral housing development generates disproportionately more car mileage per household and puts disproportionately more pressure on the existing road network.


  1. Traffic growth is not a steady progression. When the flow along a street approaches capacity the queues start to grow rapidly and delays multiply, so that in a relatively short time, a small percentage increase can lead to unacceptable levels of congestion.  On some arterial streets such as West Street and The Mall, queues often tailback along the whole street during peak periods.


  1. But compared with many towns in Kent, Faversham’s traffic congestion is currently on a small scale. It’s not the delays that are the problem, it’s the fact that pedestrians view motorised traffic as intimidating and dangerous.  The perceived safety risk discourages walking and encourages more people to use their cars for short journeys, which in turn leads to a greater increase in the level of traffic – a vicious circle that during the less enlightened decades of the 1960s through to the 1990s damaged many other towns in Britain.  Road traffic can easily reduce a place to a non-place.


  1. The damage is usually irreversible. Faversham is a medieval market town whose backbone is formed from three conservation areas whose streets and housing frontage were not designed to cope with year-on-year increases in motor traffic at current levels. Vehicle queues are occurring on narrow streets with houses fronting the carriageway, many dating from the fifteenth century or earlier.  Congestion brings noise, vibration from heavy vehicles, dirt, and atmospheric pollution together with a significant risk to health.  In the longer term it can lead to schemes that are out of sympathy with their surroundings: an epidemic of traffic signs, road markings, pedestrian guard rails, and traffic signals in an attempt to ease traffic flow.  Ironically, one of the main aims of the KCC Plan is to protect the environment (see under Outcome 4: enhanced environment).  But it is weak on heritage.


  1. The Town needs a coherent plan for coping with traffic demand before matters get out of hand. This will call for solutions at the local level.  The Plan acknowledges that there is a problem.  For example, in relation to the Dartford area it admits that ‘a significant modal shift is needed to accommodate the projected growth’, meaning that people must switch from car to other forms of transport.  But it doesn’t say how they will be persuaded to do this.


Some suggested solutions


  1. The fundamental aim of the Plan, to deliver growth, is misguided, especially for heritage towns like Faversham. It is not the business of a transport plan to deliver growth per se.  It should be to deliver a quality of life for residents.
  1. In addition, the Plan could usefully feature conservation as an objective in its own right.
  1. To achieve quality-of-life and conservation objectives the Plan should list specific policies and schemes that manage levels of vehicular traffic through measures that naturally encourage people to shift from car usage to other modes of transport that are less damaging to the environment and more beneficial to public health and the local economy.
  1. Effective solutions start with a better knowledge base: a review of the traffic likely to arise from future housing development. The Plan should require housing developers, as a condition for planning permission, to assess the impact of their proposals cumulatively across all housing developments.  They should submit (a) systematic forecasts for traffic growth across the network as a whole, (b) an assessment of the resulting economic, environmental and health impact, and (c) alternative policies and plans for dealing with it.
  1. Practical measures for Faversham include:

– lower speed limits (Twenty’s Plenty) to reduce (unintended) intimidation by moving vehicles through noise and accident risk that creates an atmosphere hostile to walkers

– working with schools to promote walking to school

– environmentally friendly cycle routes and pedestrian routes that encourage people to walk and cycle from outlying estates into the Town, with special attention to the pedestrian routes over the railway yard

– more effective parking enforcement to protect the street environment and to ensure that the regulations don’t fall into disrepute

– higher parking tariffs

– Park-and-Walk, Park-and-Cycle.



Submission from the Faversham Society to the Public Realm Group of Faversham Town Council

There are concerns about parking around the Guildhall, and calls for yellow lines to be painted. The Faversham Society does not endorse the use of yellow lines anywhere in the town centre. In our view, they not only disfigure a heritage area, but are ineffective – people park on them regardless – and cause more problems than they solve.

The purpose of the yellow lines was to support the evening economy by allowing parking in the town centre. However, a lot of the space is being used for long-term and overnight parking, limiting the space available for customers of evening businesses – and, in particular, making it difficult for Blue Badge holders to find a space, especially in Preston Street.

It is questionable whether evening on-street parking is needed at all, except for Blue Badge holders, since the car parks are free in the evenings, have plenty of space, and are a very short distance away. Traders to whom we have spoken did not see the necessity for yellow lines, for this reason. The entire town centre could be made a no-parking zone, day and night.

However, there is a case for allowing brief parking during the daytime to enable quick shopping (eg, newsagents), visiting the bank, and dropping off and collecting bulky items. This would also benefit takeaways, daytime and evening. A reasonable period might be 20 minutes (this would tie in with a 20mph speed limit and be easy to remember). Those needing longer stays would be able to use the car parks, as now.

There is also a case for having reasonably-priced parking for business owners (eg, those who currently park around the Guildhall) in nearby car parks.

We ask the Town Council to vary the Traffic Order for the town centre (bounded by the Court Street and East Street entrances and the junction of Preston Street with Stone Street), such  that either:

  1. The entire area would be a no-parking zone at all times.


  1. Parking would be permitted at all times for a maximum of 20 minutes.

In either case, Blue Badge holders would still be permitted to park for a maximum of 3 hours.

Both of these options would need only signs at the entrances. All yellow lines could be removed, as the parking regulations would be consistent throughout the area.

We also ask the council to discuss with Swale Borough Council whether reduced-cost car park permits could be made available for town centre traders.


Yellow Lines around the Guildhall

The Council has been accused of dithering over yellow lines. The Faversham Society has previously expressed its concern about the painting of yellow lines around the Guildhall. The Society’s position was determined at our July 2015 Board Meeting

After some discussion over the merits of having/not having single/double lines the following proposal was put forward:- That the Faversham Society, does not endorse in heritage areas, the continued use of yellow lines and that a policy on this and street furniture be created.  A vote ensued with 10 votes for, 2 against and 2 abstentions and was duly carried.

We continue to urge the Council to undertake an urgent review of parking in the town centre.

The Faversham Society remains opposed to the painting of yellow lines in conservation areas and requests that a full review of parking and traffic management in the town centre is undertaken.

There are number of questions to be considered:

  • Is parking in the town centre after 18:00 desirable to support the evening economy?
  • Are yellow lines necessary in order to regulate where people park and for what period?
  • Enforcement is a major issue – will painting yellow lines achieve the changes in parking behaviour expected?

Yellow lines cause significant visual damage  in the historic core. A Traffic Order could be used to permit short term parking in the town centre after 18:00 to enable people to pick up takeaways in the town centre, and ensure that those parking for a longer period of time park in the car park.

It is also important that parking by the able bodied does not deny space for blue badge holders. Presently huge delivery vans regularly blocking Preston Street, forcing disabled drivers up on to the pavement, cyclists career the wrong way down the street scattering pedestrians who are forced to walk in the road.  It is frequently impossible for disabled drivers to park in Preston Street  after 18.00 hours, as the able bodied don’t use the  car parks, preferring to park in Preston Street denying space to those with disabilities.

Historic England provides relevant advice on yellow lines in historic area
Historic England (2008) Streets for All Parking Restrictions without yellow lines

Although the Society does not support yellow lines, we would point out that 50mm lines are all that is required in Conservation Areas.

In 2013 the Minister  Norman Baker said:
“No one wants to see unnecessary yellow lines blotting our towns and villages when there is an alternative. They are a clear eyesore that can be intrusive and can have a huge impact on the look and feel of our streets, particularly in historic town centres or conservation areas.
“I encourage local authorities to think about the use of restricted parking zones. They can be used to improve the visual impact of the street while providing clear information to motorists.”

Chapter 3 of the Government’s Traffic Signs Manual also provides relevant guidance on alternatives to yellow lines