Title Meeting the Welfare and Parking Needs of Goods Vehicle Drivers and Riders, Briefing Report Authors Julian Allen, Maja Piecyk Number (ENG-TR) ENG-TR.036 Date June 2023 ISSN 2633-6839 MEETING THE WELFARE AND PARKING NEEDS OF GOODS VEHICLE DRIVERS AND RIDERS Briefing Report Technical Report ENG-TR.036 June 2023 Julian Allen and Maja Piecyk University of Westminster This briefing report has been produced as part of the Centre for Sustainable Road Freight (SRF – EPSRC grant number EP/R035148/1). Further details about the SRF project are available at: http://www.csrf.ac.uk/ Centre for Sustainable Road Freight http://www.csrf.ac.uk/ Allen J., M. Piecyk † Meeting the Welfare and Parking Needs of Goods Vehicle Drivers and Riders – Briefing Report Technical Report: ENG-TR.036 June 2023 ISSN Number: 2633-6839 Centre for Sustainable Road Freight Department of Engineering University of Cambridge Trumpington Street Cambridge CB2 1PZ Heriot-Watt University Edinburgh Campus Edinburgh EH14 4AS University of Westminster † 309 Regent Street London W1B 2HW www.sustainableroadfreight.org.uk © Copyright Centre for Sustainable Road Freight, 2023. Table of Contents Page no. 1. Introduction 1 2. Goods vehicle parking and other driver welfare considerations 3 2.1 Parking and welfare requirements of goods vehicle drivers and riders 3 2.2 HGV on-street parking regulations 6 2.3 Drivers’ hours regulations - breaks and rest periods 7 2.4 Definition and etymology of lorry parks and truckstops 8 3. History of transport cafes and lorry parks 10 3.1 Transport cafes and hostels 10 3.2 The emergence of lorry parks 11 3.3 Lorry parks serving the emerging motorway network 15 3.4 Summary 17 4. Types of HGV parking and lorry parks 19 5. Challenges and pressures faced by lorry park operators 24 6. Views on and responsibility for providing lorry parks 26 6.1 Views of local authorities and UK Government 26 6.2 UK Government approach 27 6.3 The situation in Kent and response of national and local government 30 7. The system for providing lorry parks and other HGV parking facilities 34 8. Government-commissioned audits of HGV overnight parking in England 39 8.1 Overnight HGV parking capacity, prices and ratings in lorry parks 39 8.2 Utilisation of lorry parks for overnight HGV parking 40 8.3 HGV overnight parking in all locations 43 8.4 Overnight HGV parking audit in England in 2022 47 8.5 Overnight parking by UK and non-UK registered HGVs 49 9. User opinion surveys of overnight lorry park facilities 53 10. Lorry park actions and research in other countries 57 10.1 Situation and actions in the European Union 57 10.2 Situation in the United States of America 60 11. Views on lorry park of those in the UK freight industry in 2020/21 63 11.1 Engagement and progress on HGV parking by UK Government and others 63 11.2 Planning issues 63 11.3 Financial viability of lorry parks and future funding options 64 11.4 Facilities and standards required at lorry parks 65 11.5 Future HGV refuelling at lorry parks 66 11.6 Government views on overnight parking in lay-bys and on-street in industrial estates 66 12. Actions announced by UK Government concerning lorry parks in 2021 and 2022 67 13. Recommendations made by the Transport Select Committee concerning lorry parks and the UK Government response 69 14. The provision of other driver welfare facilities in the course of work 74 14.1 Driver welfare needs and facilities for HGV drivers at warehouses, distribution centres and other sites they visit 74 14.2 Driver/rider welfare needs and facilities for other workers making deliveries/collection and providing services 77 15. People living in LGVs 76 16. Conclusions about HGV parking and driver welfare issues 81 16.1 HGV overnight parking – current situation 81 16.2 Research needs and considerations for HGV overnight parking 83 16.3 Daytime rest and welfare needs of all freight transport drivers and service providers 85 17. Recommendations for HGV parking capacity and other driver/rider welfare issues 86 17.1 Reforms to the planning system 86 17.2 Methods of funding greater lorry park capacity 88 17.3 Lorry park supply and demand data and research requirements 90 17.4 Provision of HGV parking availability information 90 17.5 Greater use of collaborative overnight HGV parking facilities 91 17.6 Using two-person crews for long distance HGV journeys 91 17.7 Drop trailer operations 92 17.8 Unaccompanied Roll-on Roll-off trailer operations 92 17.9 Wider driver and rider welfare issues 93 17.10 Connected autonomous vehicles (CAVs) 93 References 96 1 1. Introduction This briefing report investigates the parking and welfare needs of goods vehicle drivers and riders in the UK freight transport industry. It investigates the overnight parking requirements of long-distance drivers and how, for a long period of time, these have not been adequately met and provided for by the public and private sectors. Despite the fact that policymakers have increasingly legislated against HGV overnight parking on-street since the 1970s on grounds of impacts on traffic, road safety and nuisance and disturbance to residents they have failed to ensure that sufficient overnight parking space, and which is of a suitable quality and price, has been provided for HGV drivers. This problem is becoming increasingly acute over time and is likely to be an important factor in the shortage of long-distance drivers. The report also examines the day-time parking needs of goods vehicle drivers in order to comply with mandatory rest break legislation. It discusses the access to toilets and handwashing facilities required by all those delivering and collecting goods and providing services but which are unfortunately often not made available to them. It also investigates the welfare needs of those providing goods collection and deliveries as part of the growth in online shopping (especially for parcels, groceries and meals) the vast majority of whom work in urban areas with some using motorbikes, mopeds, bicycles and cargo bikes as well as working on-foot in addition to those using vans and HGVS. This includes consideration of their needs for rest areas and safe, secure vehicle parking facilities. Those without enclosed vehicles require covered rest areas when waiting between job allocations and when taking breaks as well as safe, secure vehicle storage locations while they obtain food and drink in cafes and shops and when making deliveries. In helping the reader to understand these issues, the report begins with an explanation of these parking and welfare needs of the various types of workers delivering and collecting goods and providing services. It also provides a history of the provision of overnight parking facilities for long-distance HGV drivers on motorways and other roads, explaining the views of successive UK Governments as well as the provision (or lack of) these facilities by local authorities and private sector operators. Section 2 discusses the parking and welfare needs of goods vehicle drivers and riders, on- street parking regulations, drivers’ hours regulations and the etymology of terminology used in the report including lorry parks and truckstops. Section 3 provides a history of transport cafes and lorry parks in the UK. Section 4 discusses the various types of lorry park to be found in the UK. Section 5 discuss the economic, planning and other challenges and issues facing lorry park operators. Section 6 provides insight into national government and local authority views on and responsibility for lorry parks. It includes a case study of the situation in Kent, where the overnight lorry park issues are most severe and actions taken by different levels of Government. Section 7 explains the current system for providing lorry parks and other HGV parking facilities. Section 8 discusses the findings of UK Government-commissioned audits of HGV overnight parking in England. 2 Section 9 presents the findings of surveys of users of overnight lorry park users concerning their suitability and quality. Section 10 discusses the lorry park situation and actions taken in the European Union and the United States of America. Section 11 provides views expressed by politicians and industry on lorry parks and Government policy concerning them since the severe worsening of the HGV driver shortage in 2020. Section 12 presents the lorry park actions that the UK Government committed to taking in 2021. Section 13 discusses the recommendations made by the House of Commons Transport Select Committee in 2021 concerning lorry parks in its inquiry into Freight Supply Chain, and the UK Government response to these recommendations in 2022. Section 14 discusses other driver and rider welfare needs in the course of their work beyond overnight HGV parking. Section 15 discusses the growing incidence of people living in LGVs (i.e. vans) and its potential impacts on public perception of road freight transport and on-street parking regulation. Section 16 provides conclusions including the inadequacies and gaps in current provision of facilities for goods vehicle drivers and riders. Section 17 provides recommendations about actions that can be taken by national and local government and industry to address deficiencies in overnight HGV parking and other driver/rider welfare needs. In this report, dedicated facilities where HGV drivers can park their vehicles and rest in the course of their work are referred to as either ‘lorry parks’ or ‘truckstops’ depending on the source. The term ‘lorry park’ was being used in the UK by the late 1950s when these facilities first emerged. This term has the same meaning as ‘truckstop’ which is now also commonly used in the UK as a result of the proliferation of American culture (see section 2.4 for further discussion of the derivation of the terms ‘lorry’ and ‘truck’). The term ‘HGV’ is used in the report to refer to goods vehicles over 3.5 tonnes gross mass that make use of lorry parks, while ‘LGV’ is used to refer to light goods vehicles up to and including 3.5 tonnes (often commonly referred to as vans). The term HGV is more commonly used in UK industry and research to refer to these vehicles than lorry or truck. This report has been produced as part of the Centre for Sustainable Road Freight (SRF – EPSRC grant number: EP/R035148/1). A slide set and summary report are also available from the SRF website that accompany this report. Further details about the SRF project are available at: http://www.csrf.ac.uk/ http://www.csrf.ac.uk/ 3 2. Goods vehicle parking and other driver welfare considerations 2.1 Parking and welfare needs of goods vehicle drivers and riders Drivers of goods vehicles (both heavy and light goods vehicles - HGVs and LGVs), riders (using bicycles, cargo, bikes, mopeds and motorcycles) and on-foot goods and service providers (such as parcel porters and engineers) require various facilities and amenities as part of their working day. These facilities vary depending on the type of work that the driver/rider/on-foot provider is involved in. Whereas some operations involve driving long distances and being away from home for a night or more, others involve working near where the driver lives and them going home every night. Those drivers that spend nights away from home, by definition, require additional facilities than those who do not (including somewhere to park the vehicle, obtain food and drink, and toilet and washing facilities). The law requires that goods vehicle drivers take rest breaks if they exceed specified hours of driving per day (which apply to most of those involved in goods delivery and collection work). Delivery personnel not using LGVs and HGVs will also require rest during the course of a working day. HGVs are fitted with tachographs to ensure that this happens regularly, while drivers of LGVs (often referred to as vans) are limited only to maximum working/driving hours, with no legal requirement or means of independently verifying any rest breaks (see section 2.3 for further discussion of drivers’ hours regulations). Goods vehicle drivers can also require stopping facilities when they are delayed by transport disruptions (such as traffic accidents, incidents causing road/route closures, and ferry service disruption). All personnel using vehicles to provide goods or services also require places to park their vehicles during the course of their work. All drivers and riders need access to food and drink, and the use of toilet and hand washing facilities during the working day. Drivers and riders engaged in making instant deliveries of groceries and meals in urban areas that have been purchased online, as well as same-day parcel couriers, often have to wait between deliveries for their job to be allocated, and therefore require suitable waiting locations. Those driving LGVs in order to primarily provide a service rather than to collect or deliver goods (such as plumbers, electricians, utility engineers and builders) will visit fewer addresses per working day than those delivering or collecting goods, and therefore require fewer parking spaces but have longer vehicle dwell times at the parking locations they use. Despite the fact that goods vehicle drivers, riders (of bicycles, cargo bikes, motorbikes, and mopeds) and on-foot personnel) delivering and collecting goods and providing services require stopping, resting and welfare facilities this does not mean that are necessarily provided in the locations in which they work by the businesses they work for, the businesses they collect to and deliver from, by private providers or by local authorities. In fact, many of these requirements of drivers, riders and on-foot personnel are currently not well provided for by either the private or public sector. The key facilities and amenities required in the course of their work by those providing goods delivery/collection and servicing tasks are: • Vehicle stopping space to carry out goods deliveries/collections or servicing work (either loading/unloading or parking depending on nature of work), • Vehicle stopping places to take mandatory and other daytime rest breaks from work, • Eating and drinking facilities, • Toileting and washing facilities, • Overnight vehicle stopping facilities. 4 These stopping, comfort and resting requirements can occur in a range of different instances as part of a driver’s daily work: • On the journey while driving the vehicle, • Where deliveries/collections and servicing tasks are made, • While waiting between job allocation / deliveries and collections, • Overnight (if working but not driving – mostly required by long-distance HGV drivers). Figure 1.1 shows the facilities required drivers, riders and on-foot personnel for stopping locations and welfare provision in various types of goods delivery/collection and servicing work. Figure 1.1: Facilities required for vehicle stopping and welfare provision by drivers, riders and on-foot personnel in goods and servicing work These vehicle stopping, resting and welfare requirements can be provided for at official, dedicated locations specifically equipped to provide for these facilities or in unofficial, non- specific locations. Non-specific vehicle stopping locations (whether official or not - such as in lay-bys and at kerbsides in industrial estates) are often less safe and more likely to be associated with crime against the driver and their vehicle/goods carried. Secure parking locations (especially for overnight stops) helps to prevent theft of vehicles and cargo, as well as providing suitable and safe working conditions for drivers. The lack of access to toilet facilities for drivers, riders and on-foot personnel in the course of their work can result in them having to illegally relieve themselves in public places or use bottles for this purpose in their vehicles. Riders and on-foot personnel who have to wait in public places between job allocations (such as on streets or in public parks etc.) are subject to greater risk of crime (to them, their vehicles and loads) as well as having no protection from the weather (such as rain, wind and excessive sun). The various vehicle stopping locations that may be used by a driver for daytime rest and overnight stops include: 5 • At a lorry park (either a Motorway Services Area, a Trunk Road Services area, an independent lorry park or a local authority lorry park), • At a warehouse/distribution centre operated by the employer/hirer of the worker • At a building occupied by shippers/receivers that deliveries / collections are made to and from or at which services are provided, • At a distribution centre / operating centre provided by a freight transport operator that makes this available commercially or via a collaborative arrangement with others, • On-street on the public road network (especially in a lay-by or at the kerbside on an industrial estate in the case of HGVs), • In a public place (e.g. bench, park etc. for a cycle courier). Some operators use independent lorry parks close to the area in which they live and/or work as an operational base, listing this as their home base on their Operator’s Licence. The locations at which refreshment and comfort (toilet and handwashing) facilities can be provided to drivers during their daily work include: • At a lorry park, • At a warehouse/distribution centre operated by the employer/hirer of the worker, • At a building occupied by shippers/receivers that deliveries / collections are made to and from or at which services are provided, • At a distribution centre / operating centre provided by a freight transport operator or other business with suitable off-street space that makes this available commercially or via a collaborative arrangement with others, • In a private café, restaurant, shop or other private facility not connected to the driver’s work (e.g. shopping centre etc.), • At public toilets. The greater the duration of stay of a goods vehicle, the more facilities that are ideally provided in a location (such as toilets, showers, food availability and driver/vehicle security). However this is not always the case, with even many lorry parks offering only basic facilities. In general, the shorter the vehicle stopping time, the shorter the distance that a driver will be able or willing to drive to access it. Some HGV operators inform the driver about where they should stop for daytime or overnight stops for reasons of cost, security, vehicle insurance requirements and route deviation, while others leave this to the discretion of the driver. For some drivers, the costs of using parking facilities and obtaining refreshments are paid for by those they are working for, while for other drivers they have to pay for these facilities themselves. This is likely to have an important bearing on the driver’s parking location choices for breaks. Even if these driver expenses are paid for by those they are working for, if this takes the form of drivers having to pay these costs themselves and receiving fixed rates of expenses regardless of whether or not they were incurred, this can result in drivers choosing not to purchase these services and instead treat these expenses as income. Suitable HGV parking facilities should exhibit the following criteria (British Parking Association, 2005): • Must not obstruct the highway, • Must have safe exit from and access to the highway, • Surface must bear the axle, steering and braking loads, • Area must be of shape and size to minimise manoeuvring to park, • Cause minimum nuisance or hazard to third parties, • Must be sufficient parking space when required, • Must be on or close to arterial route (to minimise transit times, fuel consumption and environmental impact), 6 • Provide for drivers’ personal needs (food quality/quantity, toilet, showers), • Provide for operators’ needs (security, fuel and basic service needs and cost), • Be economically viable for private operation (or subsidised from public funds if benefits so justify, • Provide a segregated area for hazardous vehicles, • Offer simple payment method (so as to avoid exorbitant fines/clamping). 2.2 HGV on-street parking regulations Control of parking on local roads is a matter for local highway authorities. It is not necessarily an offence for heavy goods vehicles (HGVs) to park on local roads including residential streets depending on the circumstances. It is deemed to be an offence for a goods vehicles (and any vehicle) to cause an obstruction while parked (with this decision depending on the size and type of the vehicle and the type and width of the road). An HGV over 7.5 tonnes gross weight can be parked on-street while loading and unloading as long as it is not parked on a verge, pavement or on land separating carriageways (unless given permission to do so by the police or if someone stays with the vehicle at all times.). For overnight on-street parking, the side and rear parking lights on an HGV over 7.5 tonnes must be left on during hours of darkness. Local highway authorities can use Traffic Regulation Orders (TROs) to control the parking of HGVs over 7.5 tonnes on specified roads and lay-bys in their areas, and many have done so in relation to overnight parking on specific streets or areas since the 1970s, often as a result of complaints from the general public, due to obstruction and impacts on safety and traffic flow that they can cause, and also because of the negative effect they can have on the amenity (caused by noise impacts and visual intrusion, damage to carriageways kerbsides and footways, as well as loss of parking space for residents). Such overnight parking restrictions require the placing of signage on roads subject to these restrictions to inform drivers of the controlled vehicles and time of operation. In addition, the operator of a goods vehicle over 3.5 tonnes requires an Operator’s Licence. This licence has to specify the operating centre for the vehicle which must be deemed a suitable place by the licensing authority. If the operating centre proposed by the operator is on-street near their home, if this location is deemed unsuitable by the licensing authority, the police or those living close to the named address due to the safety or environmental impacts it will cause, then the licence can be refused or revoked. Although many local highway authorities have imposed HGV parking restrictions on the streets under their control local, many have not ensured the alternative provision of off-street parking facilities. There are few local authority parking facilities (only 16 out of a total of 328 lorry parks in England in 2022) and even where these do exist they tend to provide only basic facilities (with 50% having offering only parking, and 25% having only parking and toilets in England in 2022). Local highway authorities are not legally required to provide such off-street parking facilities for goods vehicles. Even taking account of lorry parks operated by the private sector, there is a substantial undersupply of HGV overnight parking spaces in England. This is likely to be due to high cost of suitable land, the investment required to develop and operate a lorry park, and the amount spent by HGV drivers when using these facilities. These factors make public and private sector provision of overnight parking in lorry parks commercially unattractive (see section 5 for further discussion). 7 2.3 Drivers’ hours regulations - breaks and rest periods Goods vehicle drivers are subject to drivers’ hours regulations. Drivers of HGVs (i.e. goods vehicles over 3.5 tonnes gross mass) must only drive for (Driver and Vehicle Standards Agency, 2022): • 9 hours in a day (which can be extended to 10 hours twice per week), • 56 hours in a week, • 90 hours in any 2 consecutive weeks. In terms of taking breaks and rests, the drivers of these HGVs must take (Driver and Vehicle Standards Agency, 2022): • at least 11 hours rest every day (which can be reduced to 9 hours rest 3 times between any 2 weekly rest periods), • an unbroken rest period of 45 hours every week (which can be reduced to 24 hours every other week), • a break or breaks totalling at least 45 minutes after no more than 4 hours 30 minutes driving, • a weekly rest after 6 consecutive 24-hour periods of working, starting from the end of the last weekly rest period taken. All the driving of those using HGVs must be recorded on a tachograph. A break may be taken in a moving or stationary HGV, provided no other work is undertaken. Daily rest periods (i.e. of at least 11 hours every day) and reduced weekly rest periods (i.e. of 24 hours every other week) may also be taken in a HGV. However, the vehicle should have suitable sleeping facilities (either a bed or a bunk designed for sleeping on) and the vehicle should be stationary. If the HGV has no suitable sleeping facilities the driver should make other arrangements such as a hostel, hotel or boarding house. Regular weekly rest periods and any weekly rest of more than 45 hours are not permitted to be taken in a HGV and should be taken elsewhere such as in a hostel, hotel or boarding house. Cost for accommodation outside the HGV must be met by the employer (Driver and Vehicle Standards Agency, 2022). ‘Multi-manning’ is also permitted in which there are at least two drivers in the vehicle to do the driving. Regulations state that each driver must have a daily rest period of at least 9 consecutive hours but they may do so within the 30-hour period that starts at the end of the last daily or weekly rest period (rather than the normal 24 hour period). Organising drivers’ duties in such a fashion enables a crew’s duties to be spread over 21 hours. The maximum driving time for a two-person crew is 20 hours before a daily rest is required (although only if both drivers are entitled to drive 10 hours) (Driver and Vehicle Standards Agency, 2022). HGVs used for longer journeys are often fitted with sleeper cabs or sleeper berths to provide accessible resting and sleeping space for the driver and prevent them from having to find and pay for bedroom accommodation at overnight stopping locations. Sleeper berths were first introduced in the United States in the 1920s and were located on the top or side of HGVs and were usually small and uncomfortable (National Transportation Safety Board, 2000). Sleeper cabs have improved greatly over time. Today, they are typically located behind the driver’s cab and vary in terms of equipment and luxury from a space only just wide enough for a bed to a king-size single bed or bunk beds, and with equipment including TV, refrigerator, microwave, and games console. Although LGVs (i.e. goods vehicle up to and including 3.5 tonnes gross mass) are not typically fitted with tachographs (unless driving overseas) professional drivers of these vehicles in the UK are also subject to drivers hours’ rules. These stipulate that the daily driving limit is 10 8 hours per day and the driver must not be on duty (i.e. including not driving) for more than 11 hours in any working day on which they have driven). These LGV drivers/operators must record their hours as their vehicle are not typically fitted with tachographs (unless driving overseas) (Driver and Vehicle Standards Agency, 2022). 2.4 Definition and etymology of lorry parks and truckstops As previously mentioned, dedicated facilities where goods vehicle drivers can park their vehicles and rest in the course of their work are referred to interchangeably as ‘lorry parks’ or ‘truckstops’ (or also ‘truck stops’ or ‘truck-stops’) in the UK. This is due to the common usage of both ‘lorry’ and ‘truck’ to refer to heavy goods vehicles (HGVs). The term ‘lorry’ is thought to either derive from the verb ‘lurry’ (meaning ‘to pull, tug’ and of unknown origin) which first appeared in the 1570s or, as cited in notes dating to 1834, from a railway inventor in the early 19th century called Laurie. A lorry is defined as ‘a long flat wagon without sides running on four low wheels. Also, a truck or wagon used on railways or tramways’ (Oxford English Dictionary, 2022). The term is first recorded in 1838 in relation to moving luggage by rail: ‘a luggage train was perceived....with three lurries attached to it’ (Oxford English Dictionary, 2022). The first known usage of the word ‘lorry’ to refer to a large motor vehicle for carrying goods by road appeared in 1911. ‘Lorry’ became the preferred term for a large goods vehicle in Britain as well as in countries in the British Empire including India, Malaysia, Singapore, Hong Kong, as well as in Ireland. The term ‘truck’ first appeared in English in the early 1600s referring to a small-wheeled roller on which naval guns were transported. By the late 18th century it was also used to refer to a wheeled vehicle used for carrying heavy loads, with the same meaning in this sense as a lorry. The word is derived from the word ‘truckle’ (meaning ‘wheel, roller or pulley) which is derived from the Latin ‘trochus’ (meaning ‘iron hoop’), from the Greek ‘trokhos’ (meaning ‘wheel’), and from the Greek ‘trekhein’ (meaning ‘to run’) (The Word Detective, 2009). It is first used in reference to a motor vehicle for carrying goods by road in America in the 1910s, which was a shortened form of ‘motor truck’ (which first appeared in American English in 1901) (Online Etymology Dictionary, 2022). ‘Truck’ is the preferred term for a heavy goods vehicles in Canada, Australia, New Zealand, Pakistan and South Africa, as well as in America. Although the word ‘truck’ was originally used in the UK as an alternative to ‘lorry’ it was far less commonly used than the latter until the mid-20th century. The term ‘truck’ would appear to have entered more common usage after the Second World War, with it being the term used by combined US and UK military forces (as noted by Winston Churchill in 1943 - Online Etymology Dictionary, 2022). Today, the terms ‘lorry’ and ‘truck’ are used interchangeably in the UK as well as in other countries that formerly used ‘lorry’. This has been achieved through its usage in American culture (including films, books and songs), as well as by the vehicle manufacturing industry. Drivers of HGVs were originally referred to as ‘lorry drivers’ in the UK (first recorded use in the UK in 1926 (Oxford English Dictionary, 2022) and other countries that used the term ‘lorry’, while they were referred to as ‘truck drivers’ or ‘truckers’ in America and other countries using the term ‘truck’ (there is a record of the term ‘truck driver’ being used in a British newspaper in 1907 but it was uncommon). Today, again as a result of American culture, both ‘lorry driver’ and ‘truck driver’ are used interchangeably in the UK. The first recorded use of the term ‘lorry park’ (meaning ‘an open space or lot reserved for the parking of lorries’) was being used in the UK by the late 1950s (Commercial Motor, 1957). ‘Truck stop’ (also written as ‘truckstop’ and ‘truck-stop’) has its first known recorded use in American in 1961, with its first common usage in the UK not appearing until the mid-1980s (Oxford English Dictionary, 2022; Commercial Motor, 1984). 9 In this report, the term ‘heavy goods vehicle’ (HGV) is used in preference to ‘lorry’ or ‘truck’ to refer to goods vehicles with a gross weight of over 3.5 tonnes, and ‘light goods vehicle’ (LGV) is used to refer to those up to and including 3.5 tonnes. These terms are more commonly used in UK industry and research to refer to these vehicles. Both ‘lorry park’ and ‘truckstop’ are used in the report to refer to these HGV parking facilities. 10 3. History of transport cafes and lorry parks 3.1 Transport cafes and hostels In the early days of horse-drawn road freight, carriers used inns and taverns in towns as staging posts and using stabling, and eating, drinking and sleeping there. With the development and uptake of motorised goods vehicles, by the 1920s, drivers of these vehicles travelled the country’s A-roads along which commercial proprietors provided transport cafes. Offering basic food and drink, these establishments came to be commonly known as ‘caffs’ and ‘greasy spoons’, some were brick buildings, some cabins, while others were made from converted vehicle bodies. The better equipped cafés provided on-site parking, toilets and washrooms with some also offering overnight accommodation. These were important facilities for the long-distance HGV driver, especially given the slow vehicle speeds (with maximum speeds of 20 miles per hour until 1957 and 30 miles per hour thereafter for HGVs with unladen weights over 3.5 tonnes), the long journeys they had to undertake, the physical effort of driving these vehicles and the lack of protection they provided from hot and cold weather. Strong tea and platefuls of carbohydrates and protein were standard fare (Armstrong, 2003). In the initial decades of long-distance HGV driving, drivers were often accompanied by mates who helped the driver and provided them with company. When mates became less common in the 1950s and 1960s, the transport café became an important place of contact with others for HGV drivers given the lonely nature of the work. These cafes were also frequently used as change- over points for drivers, with trailers swapped between vehicles to reduce each drivers’ time spent on the road. A 1950s study noted the welfare importance of these cafes to goods vehicle drivers and, given this and their relatively poor health and hygiene standards, suggested that these cafes should be approved and preferably regulated by the Ministry of Transport (Solomon, 1954). By the 1960s more than 1000 transport cafes were identified throughout the country in surveyed work. A 1960s study found that these cafes had generally become larger, more impersonal, cleaner and more expensive over the intervening decade. It divided cafes in two types: i) traditional ones that typically provided large helpings of meals of meat, potatoes and two vegetables, apple tart and custard and bacon sandwiches; and ii) newer ones that provided less generous portion sizes and focused more on fatty fried food (such as egg, bacon and chips). Early motorway service station cafes had begun to appear by this time, but some goods vehicle drivers reported avoiding them due to the higher prices and “lack of life”. This 1960s study of road freight transport drivers in Britain found that they commonly stopped at transport cafes three times during each shift: the first after two to three hours of driving, the second in accordance with the legally required break after five and a half hours and the third later in the shift. Such common café stops were related to drivers making little provision for making hot drinks in their vehicles at this period. The study found younger drivers were most likely to use cafes, while older drivers were often prone to stop in lay-bys to consume pre-prepared sandwiches and tea from a flask (Hallowell, 1968). This 1960s study also discusses overnight stopping facilities for long-distance goods vehicle drivers, explaining that these ranged from small houses where drivers slept in dormitories with several beds, to large transport hostels with small, individual ‘cubicle’ bedrooms also providing hot running water, showers and a television lounge. It describes the latter as “the height of luxury” for long-distance drivers. It explains that many drivers interviewed felt that most proprietors did what they could to make drivers feel comfortable and welcome, but that some ran poor, scruffy, dirty establishments. The author reflects that overnight accommodation in the late 1960s was generally better than what had preceded it but speculates that the profit margins for proprietors of these establishments must have been limited given what drivers were able and willing to pay for food, bed and breakfast (Hallowell, 1968). Employed long- distance drivers often received allowances for food, drink and overnight accommodation but these were limited in value and would not afford the better services on offer. It is also long 11 recognised that some overnight facilities provided prostitution services as well (Armstrong, 2003). 3.2 The emergence of lorry parks Several factors led to changes in the management of HGV on-street parking and the provision of lorry parks. These include the growth in long-distance HGV journeys, the inadequacy of facilities offered and off-street parking space at many transport cafes and hostels, the rising number of complaints from the general public about the impacts of HGV parking in the vicinity of their homes, and the rising crime against HGVs and their loads when parked in insecure on-street locations. The existing network of transport cafes and the facilities they offered in both urban and non- urban locations did not adequately provide for the needs of the growing number of long- distance HGV drivers who needed overnight stopping facilities. This resulted in a substantial growth in the number of long-distance HGV drivers parking on-street. These issues are discussed below. Figure 3.1: Markham Moor lorry park and diner on the A1 Source: Ian S, 2012, https://commons.wikimedia.org/wiki/File:Markham_Moor_lorry_park_and_diner_-_geograph.org.uk_- _3049901.jpg Increases in HGV carrying capacity (both in terms of weight and volume) as well as in vehicle maximum speeds, which reflected developments in vehicle engineering, reduced the costs of freight transport per unit of product moved. Maximum permissible vehicle lengths for articulated HGVs were increased by 6% in 1955, by a further 21% in 1964, and by a further 15% in 1968. Maximum permissible vehicle widths for articulated HGVs were increased by 7% in 1955, and by a further 3% in 1964. At the same time vehicle manufacturers were also producing vehicle trailers with greater height, for which there were no regulations other than the need for a stable vehicle and to be able to pass safely under road bridges. Therefore, both the area and volume of the carrying space in HGVs increased substantially. The maximum permissible gross weight of articulated HGVs increased by 9% in 1955 and by a further 33% in 1964. The maximum speed limit for articulated HGVs increased by 50% in 1957 (from 20 to 30 miles per hour) and was then increased by a further 33% on A-roads (to 40 miles per hour) and by 133% on the new motorways (to 70 miles per hour). These changes in vehicle 12 dimensions and speeds meant that, over time, it became possible for vehicles to carry greater loads and to cover journeys in less time, thereby reducing road freight transport operating costs. This reduction in the cost of HGV operations led to an increase in the average distance over which goods were transported by road freight transport since the 1950s and a growth in long-distance journeys requiring overnight stops. Figure 3.2 shows the average length of haul (a proxy for the average journey distance over which goods are transported) since 1953. Figure 3.2: Road freight transport average length of haul in Britain, 1953-2020 Source: calculated from data in Department for Transport, 2021a. These reductions in road freight transport costs, together with its end-to-end service and flexibility also led to road freight winning substantial volumes of long distance traffic from the railways. It also facilitated businesses to restructure their supply chains, relying on fewer but larger warehouses with the economies of scale this offers, served by HGVs travelling further between delivery and collection points. Figure 3.3 shows the freight tonne-kilometres by road and rail since the 1950s reflecting these developments. Road tonne-kilometres surpassed those of rail in 1955 and have increased considerably since, whereas rail tonne-kilometres were lower in 2020 than in 1953. By 2020, the road and rail split of tonne-kilometres in Britain was 90% and 10%, respectively. 13 Figure 3.2: Goods moved by road and rail freight in Britain, 1953-2020 (tonne- kilometres) Source: calculated from data in Department for Transport, 2021a. The existing network of transport cafes and hostels serving long-distance HGV drivers and the facilities they offered did not provide for the needs of the growing number of long-distance drivers who needed reasonably priced overnight parking, sleeping and catering facilities. There was a shortage of such facilities and the number of beds required and the standards of many were not high, given what drivers could afford. Some transport cafes offered off-street HGV parking, while others especially those in urban areas did not, with drivers instead using on-street parking. In addition, HGVs were commonly parked on-street overnight both by drivers on long-distance journeys as well by drivers and owner-operators who parked them near their homes. From the 1950s, some local authorities, acting on complaints about nuisance and other vehicle related impacts from residents about on-street parking of HGVs by drivers while they were using transport cafes, began to try to impose on-street parking restrictions on HGVs. For example, Catterick and Richmond councils attempted to introduce on-street parking restrictions for this reason in 1954. However, the Minister of Transport rejected the proposal stating that the reported nuisance did not warrant the proposed restrictions and would not in any case ameliorate it (Commercial Motor, 1954). Concerns and complaints from members of the general public about the visual and noise impacts of HGVs parked on-street in urban and rural areas escalated through the rest of the 1950s and 1960s. However, until 1969, on-street parking restrictions could only be introduced by local traffic authorities on grounds of safety or traffic disruption, not on grounds of amenity. In 1964, Derbyshire County Council urged the police to address the problem of HGVs parked on-street and to prosecute if necessary (Commercial Motor, 1964). From the early 1960s on, as the number of HGVs grew, an increased rate of HGV cargo and vehicle thefts took place. This was most common when vehicles were parked, especially overnight. This caused freight transport operators to become increasingly concerned about the security of their vehicles and the goods they carried for their customers. This led to calls from some operators for secure lorry parks. Jointly, these issues led to the need for national government to consider on-street overnight HGV parking, and for national and local government as well as businesses to consider the 14 provision of stopping facilities for HGV drivers with off-street parking, sleeping and catering facilities. This led to the emergence of facilities referred to as lorry parks from late 1950s. Some were established by private businesses, some by local authorities and some with both acting together. In 1957, Liverpool Corporation considered establishing fenced lorry parks with night watchmen in three areas of the city as a response to HGV cargo theft (Commercial Motor, 1957). In 1962, a lorry park was opened by a hotel owner with National Car Parks. The lorry park with security guards was located in Camden with the hotel operating a shuttle bus for drivers to take them to the hotel in Islington for overnight accommodation. The RHA advised on and publicised the park, stating its benefits in improving security as well as reducing the impacts of on-street parking (Commercial Motor, 1962). In 1966, Birmingham City Council commissioned work for a lorry park with security guards, drivers’ motel and restaurant (Commercial Motor, 1966a). Also in 1966, freight transport businesses in Stockport that were members of the Road Haulage Association (RHA) established a limited company to provide an experimental, temporary high-security, low-cost lorry park for 30 HGVs in conjunction with support from the local authority who were keen to reduce the impacts of on- street HGV parking. The leased site was securely fenced with café and sleeping facilities (Commercial Motor, 1966b, 1967a). However, these early lorry parks proved unpopular with freight transport operators. This resulted in the RHA rejecting a 1967 resolution from the Metropolitan and South Eastern Traffic area (i.e. London and the South East) urging it to sponsor lorry parks (preferably with security guards) in all major UK urban areas for overnight parking by long-distance HGV drivers. The RHA chose not to support such an approach as local authorities were said to be reluctant to provide space or resources for lorry parks due to a reported lack of use of those in existence by HGV drivers (Commercial Motor, 1967b). The Greater London Council (GLC) began considering overnight parking provision for HGVs in 1966, working with London boroughs to identify solutions. This was in the aftermath of the London Borough of Barnet’s application for the development of a lorry park being turned down by the UK Government. In 1967, the GLC unveiled a plan in which it would provide lorry parks with overnight accommodation and catering facilities throughout London and on trunk roads leading to London, together with new, strict HGV on-street parking controls throughout inner London, especially focusing on preventing HGV on-street parking generated by existing transport cafes, with applications for new cafes without off-street parking to be refused. GLC lorry park trials commenced in 1968 in conjunction with National Car Parks, which had been commercially operating six lorry parks in London since the mid-1960s (Commercial Motor, 1966c, 1967c, 1968). The implementation of traffic legislation by the UK Government in 1969 permitted local authorities to apply to national Government to restrict on-street parking on amenity grounds (i.e. their visual and noise impacts in addition to the existing grounds of safety and traffic disruption). This led to local authorities, especially those in urban areas, introducing restrictions on HGV on-street parking on these grounds, gradually removing much former overnight parking space over the next few years. However, despite introducing night bans on HGVs parking on-street, relatively few local authorities introduced lorry parks to compensate for lost on-street parking space. The main recommendation of the 1971 UK Government report of the Working Party on the Parking of Lorries was that a national network of lorry parks should be established for overnight and daytime use by long-distance HGVs, paying particular attention to security and to drivers' needs for a good standard of overnight accommodation. Also in 1971, the circular ‘Roads 53/71’ was issued by the UK Government which drew the report and its recommendations to the attention of local authorities. As part of the 1971 Highway Act, the Government announced that it would locate and buy sites to establish a national network of approximately 50-60 large secure lorry parks in England (outside of London), which would be leased to and operated by companies on its behalf, similar to Motorway Service Areas, with a view to selling these leases to operators in the longer term. It was expected that this national 15 network would have to provide capacity for 15,000 HGVs. Various companies and consortia expressed interest in winning these sites. The Government also announced that in addition to this national network of lorry parks provided by central Government, local authorities would be expected to provide smaller lorry parks (Commercial Motor, 1971; Department of the Environment, 1971; Speed, 1973). However, in 1974, the UK Government announced that it was scaling back the ambition of this national network of lorry parks and then stated that it had no statutory powers to finance lorry parks which were, it said, entirely the responsibility of local authorities. Later in the same year, the Government stated that although lorry parks were much needed, few were being developed due to their commercial unattractiveness, as well as difficulty in obtaining suitable sites (Commercial Motor, 1974a, 1974b, 1974c). By 1975, the UK Government said that the plans for lorry parks in the 1971 report were unlikely to be realised, with the Under-Secretary in the Department for the Environment telling the House of Commons, “We must look for other and perhaps slightly more modest ways of tackling the problem”. The Government had previously refused to grant planning permission for the development of a lorry park at the Port of Harwich, again stating that local authorities rather than national Government was responsible for meeting the demand for local HGV parking with some national Government grant money available (Commercial Motor, 1975). By 1977, it was reported that the number of HGVs parking on-street in London had been reduced by three-quarters through the implementation of night-time parking restrictions. A similar situation occurred in urban areas across the rest of the country but with little off-street lorry park space provided by local authorities. In addition to government’s plans and policies concerning lorry parks, commercial operators set up independent lorry parks in or near urban areas and in close proximity to the trunk road network if these were deemed to be commercially viable. 3.3 Lorry parks serving the emerging motorway network The gradual development of the motorway network in the UK from the late 1950s together with the provision of motorway services proved attractive to HGV drivers given the faster permitted vehicle speeds (70 compared with 40 miles per hour). However, when construction began on the first motorway, the M1, in 1958 no land or plans had been put in place to provide stopping locations with facilities to meet the needs of HGV drivers or other road users. Road freight operators and trade associations stated that they would have to avoid using the M1 due to its lack of stopping facilities and raised concerns about the assistance required by drivers whose vehicles had broken down. To prevent there being insufficient facilities for HGV drivers on this first motorway for their daytime and overnight stops that would require them to deviate off this road to independent, family-run transport cafes and lorry parks on A-roads, the UK Government had to take action. This led to the Government acquiring several small plots of land for potential service stations and surveying businesses about their preferred locations and their plans for such sites. The Government encountered difficulties obtaining planning permission for the development of these service stations due to objections by locals. Businesses were surveyed again, with the Government explaining it would only pay for the landscaping and parking areas, and asking respondents to suggest a site design and a rental price formula for the sites they were interested. 16 Figure 3.4: Lorry park at Hilton Park services on the M6 Source: Steve Daniels, 2009, https://upload.wikimedia.org/wikipedia/commons/e/e7/The_lorry_park_at_Hilton_Park_services_- _geograph.org.uk_-_1576256.jpg The Government subsequently decided that the two selected sites on the M1 would have facilities to refuel and repair vehicles, toilets, two transport cafés and a café or restaurant for the general public. Unlike the family-run transport cafes and lorry parks on A-roads, these plots of land for motorway services were operated by large businesses (who leased the land from the Government and then went about constructing buildings and parking areas to provide these services). These Motorway Service Areas provided services for both cars and HGVs. No motorway service stations were developed specifically for HGVs as these were known to generate less revenue than car and coach users. When motorway services opened on the initial motorways (M1, M2, M5 and M6) they were found to be far too small in size for the number of vehicles choosing to stop at them. The Department for Transport compulsorily purchased 21 parcels of land adjoining these new motorways with the intention that they would be used to provide motorway welfare facilities for drivers. After a review of these facilities in 1978, the private sector bodies operating them were provided with 50-year leases for these sites by the Department for Transport at a peppercorn rent (Moto Hospitality, 2021a). Motorway Service Area operators became increasingly frustrated by the amount of space taken by HGVs, with some drivers remaining parked for long periods of time. By 1978, an inquiry by the UK Government into Motorway Service Areas led to the right for the first time for Motorway Service Area operators to charge for parking (known as the Prior Report). As a result, from 1979, the Government introduced an arrangement whereby Motorway Service Areas only had to provide two hours of free parking to all drivers (so they could have a break for road safety purposes) but could be charged for staying beyond two hours. In the initial period of Motorway Service Areas, the demand for overnight parking at them from HGV drivers was low as they offered no sleeping accommodation and instead drivers visited cafes and hostels for rooms. However, with the introduction of the sleeper cab, demand for overnight HGV parking increased, with drivers able to sleep in their vehicles. The Prior Report also called for more lorry parks to meet the demand. Some operators developed separate parking areas within motorway service areas for HGVs, together with separate overnight accommodation services for car and HGV drivers. Shortly after the Prior Report was published, a new Government announced that it was no longer keen on its involvement in acquiring land and planning permission for these services 17 and its continued ownership of them. During the 1980s, the problem of lack of overnight parking space for HGVs worsened, with many Motorway Service Areas reaching their HGV capacity on a regular basis. In 1992, the UK Government deregulated the provision of motorways services, meaning that private businesses could own these sites and apply to open new ones, despite their planning and operating requirements remaining subject to government control. Motorway Service Area operators began to acquire both freehold sites and sites leased from commercial landlords rather than from the Government. Since 2008 it has been permitted for businesses to develop dedicated motorway lorry parks, but none have been established to date. Today there are almost 80 Motorway Service Areas in the UK, with the majority owned by private businesses. However, the leases on the 21 sites still owned by Government and leased to operators are coming up for renewal. 3.4 Summary The rise of the motorways and the service stations along their entire length resulted in the gradual decline of transport cafés and some lorry parks along the A-road network. As they increasingly used motorways, HGV drivers became reluctant to travel far off the network to A- road facilities they used to frequent. However, some drivers have continued to prefer to use independent lorry parks on A-roads and in other non-motorway locations or the remaining local authority lorry parks, for reasons including their perceived service level, their lower prices and their convenience given the route being taken by the driver. Ever-more spacious and luxurious in-cab and onboard sleeper facilities for drivers have also resulted in far greater driver willingness to spend more rest time and overnight stops in their vehicles, at lorry parks or Motorway Service Areas, so even if using these places to park potentially not requiring a bedroom in a hotel or hostel. Many former A-road transport cafes were converted to chain restaurants marketed for car travellers, including ‘Little Chef’ and ‘Happy Eater’ chains, which could serve four meals to a family with only a car parking space required, thereby proving far more lucrative proposition than aiming for individual HGV drivers whose vehicles took far more parking space. Today, most of the traditional transport cafes have disappeared. For refreshments, daytime and overnight stops, HGV drivers can choose between motorway services alongside the motorway network with direct access roads, lorry parks located on other major trunk roads, those lorry parks and remaining transport cafes located within a few miles of the Strategic Route Network (SRN)1, local authority lorry parks (of which a few remain but which often provide only daytime refreshments if at all), and refreshment trailers in lay-bys. Successive UK Governments over several decades have stated that they want no involvement in subsidising, providing land for, or operating lorry parks (either in Motorway Service Areas or other types), instead viewing them as a facility run by the private sector as profitable businesses. Local authority lorry parks have also declined in number, with them often not viewing it as a priority, concerned about the operational costs, and keen to realise the financial returns from development for other uses. Given the relative spending of car and HGV drivers and the space both types of vehicle require, Motorway Services Area operators are inevitably far more interested in providing space and services for the former rather than the latter. The cost of operating dedicated lorry parks on trunk and other A-roads together with the revenue they generate has led to some struggling to survive or closing and the land being developed for other uses, with relatively few new ones opening. Although the total HGV space available at all types of lorry park has risen in the last decade it continues to fail to provide sufficient space to accommodate all HGVs requiring overnight parking. In an audit of overnight HGV 1 Strategic Road Network (SRN) - the road network in England maintained and operated by National Highways - formerly known as the Highways Agency. It includes all motorways and major trunk roads. 18 parking in England in 2022, 34% of HGVs were found to be parked in lay-bys and on-street in industrial estates rather than in lorry parks of any type. In 2021/2, UK-registered articulated HGVs were responsible for 62% of tonnes lifted and 79% of tonne kilometres performed by all UK-registered HGVs on domestic journeys in Britain. The average length of haul for these articulated HGVs was 138 km compared with only 60 km for rigid HGVs (calculated from data in Department for Transport, 2023a). Table 3.1 shows the breakdown of tonnes lifted and tonne kilometres performed by these UK-registered articulated HGVs in 2021/22. In 2020/21 50% of the tonne kilometres performed by these articulated HGVs had lengths of haul in excess of 200 km and 23% in excess of 300 km. By comparison, only 1% of tonnes lifted and 5% of tonnes moved by rigid HGVs had haul lengths in excess of 300 km in 2021/2. Overall, these articulated HGVs accounted for 93% of tonnes lifted and 93% of tonne kilometres of all UK-registered HGVs on journeys with haul lengths over 200 km in 2021/22 (calculated from data in Department for Transport, 2023a). It is articulated HGVs making these longer journeys that are most likely to make use of overnight parking facilities. Table 3.1: Length of haul for UK-registered articulated HGVs on domestic journeys in Britain, 2021/2 Length of haul (kilometres) Up to 50km Over 50km to 100km Over 100km to 150km Over 150km to 200km Over 200km to 300km Over 300km All lengths Tonnes lifted 22% 23% 18% 13% 15% 8% 100% Tonne kilometres 4% 12% 16% 17% 27% 23% 100% Calculated from data in Department for Transport, 2023a. 19 4. Types of HGV parking and lorry parks Lorry parks are required to provide HGV drivers with safe parking facilities off the public road network. This has become increasingly important since the restrictions placed on overnight parking on many public roads since the 1970s (see section 3.2). Depending on the type of lorry park, it may also provide high levels of security and lighting (to help protect the driver and vehicle from theft or attack), together with personal hygiene (toilets and showers) and catering/shop facilities. As in-cab facilities and space have been designed into HGVs many drivers choose to sleep in their vehicles. Therefore, relatively few lorry parks provide accommodation. The most recent survey of lorry parks in England commissioned by the Department for Transport categorises four types of lorry park: i) independent truckstop, ii) local authority truckstop, iii) Motorway Service Area, and iv) Trunk road service area (AECOM, 2022). A description of each of these types of lorry park is provided in Table 4.1. Table 4.1: Description of types of lorry parks in England Type Description Independent truckstop Sites providing daytime and overnight HGV parking facilities that are usually independently owned and operated (or may be part of a specialist chain of sites). They are available to any freight driver (irrespective of company) and are typically exclusively for the use of freight vehicles but some may provide daytime rest and refreshment facilities for passenger traffic (car and coach). (Also includes cafes with parking for lorries – which may not have any facilities opened at night). Local authority truckstop Sites providing daytime and overnight HGV parking facilities that are under the control of a local authority. Typically basic toilet block amenities are provided and often an independently run café is co- located on the site. Sometimes a car park that is used for HGV parking at night, typically without any facilities. Motorway services area (MSA) Sites signed off the Motorway network providing daytime and overnight HGV parking facilities, typically but not exclusively operated by road-side facility chains. Separate HGV parking areas are provided but welfare facilities are common to all MSA traffic. Trunk road services area (TRA) Sites along the strategic road network (SRN) providing daytime and overnight HGV parking facilities. Separate HGV parking areas are provided but welfare facilities are common to all service area users. Whilst some sites are large, many are small with limited HGV parking and facilities limited to the forecourt shop and toilets. Source: AECOM, 2022. A 2009 report provides further insight into the typical differences between Motorway Service Areas, independent lorry parks (located on trunk and non-trunk A-roads and elsewhere) and local authority lorry parks (see Table 4.2). 20 Table 4.2: Description of types of lorry park in England Facilities Types of lorry park Motorway Service Area (MSA) Independent Lorry Park Local Authority Lorry Park Location Located on the strategic road network (SRN) of motorways throughout the UK, therefore they are linked to the Highways Agency* remit Normally located on the trunk road network of A roads throughout the UK Normally located on the trunk road network of A roads throughout the UK. There are very few of these facilities in England. There are also a number of other local authority parking sites in urban areas that may operate as car parks during the day and cater for lorries at night. However, these are not usually formally designated and have small capacities Dedicated or shared Although parking bays are segregated they share facilities with other road users. Very few have dedicated lorry driver facilities. These are normally dedicated to HGV parking, however sites that have a café may open up to other motorists depending on the level of security the site is aiming to achieve. These are normally dedicated to HGV parking, however sites that have a café may open up to other motorists depending on the level of security the site is aiming to achieve. Vehicle capacity MSA will usually hold at least 40 vehicles. The size will vary from 5 lorries up to 250. This shows the varying nature of independent lorry parks. The size will vary from 5 lorries up to 250. Pricing Normally expensive to park. They have the highest variance in price and in the standards that are provided. They have the highest variance in price and in the standards that are provided. Facilities Normally has good security, CCTV, patrols etc although not normally a fence due to planning policy. This means people are free to move around who are not drivers. Some independent sites will only have ‘basic’ facilities, the one constant factor is that they must provide overnight parking and have toilets to make it appropriate. Some local authority run sites will only have ‘basic’ facilities, the one constant factor is that they must provide overnight parking and have toilets to make it appropriate. Ownership Normally form part of a large chain of private investors e.g. MOTO, Welcome Break, or Road Chef. Normally they are privately owned and family run businesses. These sites can be leased by the local authority and privately run. There are very few sites that are owned and also run by local authority. Other points Not all MSA cater for lorries. These are not always associated with the Highways Agency* and may fall under the responsibility of the Local Authority. These will fall under the responsibility of the Local Authority. Note: Highways Agency now called National Highways. Source: AECOM, 2009. 21 Figure 4.1: Lorry park at South Mimms Services on the A1M Source: Antony, Dixon, 2011 https://commons.wikimedia.org/wiki/File:Lorry_park_at_South_Mimms_Services_-_geograph.org.uk_- _2698750.jpg Figure 4.2: Lincoln Farm Lorry Park on the A452 Source: Robin Stott, 2011 https://commons.wikimedia.org/wiki/File:Lorry_park_adjoining_Lincoln_Farm_Caf%C3%A9_- _geograph.org.uk_-_2587354.jpg 22 A rating system based on facilities available at lorry parks was devised in 2017 to rate those audited for the Department for Transport (see Table 4.3). This rating system is based on a five-point scale which is broadly in line with the European Truck Park Area Certification system (called LABEL) (AECOM, 2022). Table 4.3: Rating system used for lorry parks in audits for the Department for Transport Site rating Facilities Description 0 No facilities Basic rest area with no facilities. 1 Toilets Basic rest area offering lorry drivers a place to park and access to toilets. 2 Toilets and café Basic/medium rest area offering lorry drivers a place to park and access basic amenities. 3 Toilets, showers, and café Medium level facility offering lorry drivers a place to park with basic amenities including wash facilities. 4 Toilets, shower, café, lighting, and security fence Medium/high level facility offering a degree of secure and safe HGV parking whilst also offering reasonable facilities for lorry drivers. 5 Toilets, shower, café, lighting, security fence, accommodation, and CCTV High end HGV parking facility offering lorry drivers a place to park security and safely whilst also enjoying extensive facilities. Source: AECOM, 2022. The earliest Motorway Service Areas (MSAs) were built by private operators on land leased to them for 50 years at a peppercorn rent by the Department for Transport. In 1992, the UK Government deregulated the provision of motorways services, meaning that private businesses could own these sites and apply to open new ones, despite their planning and operating requirements remaining subject to government control. Since this date, MSAs have been identified and acquired by operators in the same way as are other commercial developments but remain subject to planning approval (as for any other commercial development) and certain rules concerning minimum standards their location and impacts. These post-1992 MSAs have been both acquired on a freehold basis by operators as well as sites being leased from commercial landlords rather than from the Government. Although MSAs contain facilities for HGVs, the drivers of these vehicles also make use of lorry parks on other roads. These have always been privately operated facilities. Government regulations in 2010 designated two types of lorry park that serves the SRN: (i) a lorry park on the motorway (which is signposted from a motorway) and a trunk road lorry park (which is signposted from a non-motorway trunk road). Although not designated by these regulations, there are also lorry parks which provides the necessary facilities but (either due to regulations or choice) is not signposted from the SRN which may be independently operated or run by a local authority. The 50-year leases on the early MSA sites owned by the UK Government will begin to expire soon. The operators of these MSA have been discussing the extension of these leases with 23 the Department for Transport for several years. However, these discussions have not led to lease extensions to date. In late 2021, the Department for Transport told these MSA operators that they were commencing the valuation of these sites so that Ministers could then decide in 2022 whether to: i) leave as is (i.e. do nothing and leave the Leases to expire), ii) re gear (i.e. provide lease extensions for a further 50 years), iii) exit (i.e. sell the sites on the open market), or iv) income strip/fixed income (i.e. provide new leases with premium payment / rental income rather than peppercorn rents). Until they have certainty about lease extensions, these operators have been reluctant to further invest in these sites as, if these leases are not extended or not extended on the same terms, it would not be possible for them to recoup their investments. This under-investment has led to them often not being sufficiently large to cope with current traffic levels and the number of passengers requiring use of the facilities (Moto Hospitality, 2021a). 24 5. Challenges and pressures faced by lorry park operators Private developers make the decision to develop Motorway Service Areas (MSAs) and other types of private parking facilities for HGVs (with the exception of local authority lorry parks of which there are few, and none of which has opened recently). These private developers make the decision about the location and size of the site, and, beyond the minimum Government standards, the facilities that will be provided, the level of security offered, and the method of privately funding it. The developer has to apply to the local planning authority for planning permission to carry out such a development. There is a substantial cost associated with preparing such planning applications. Many such applications are rejected due to unfavourable views from local residents about such prospective developments, and the cost of resubmissions and alterations required to proposed schemes in order to attempt to gain permission is often also considerable. In addition, substantial time is usually involved from the submission of a planning application to the announcement of the final decision by the local planning authority (see sections 6 and 7 for further discussion of the planning system for lorry parks). Given the attributes of modern lorry parks, they often require considerable land, which is expensive to acquire. The construction and infrastructure costs are also substantial given their power, water, sewerage, building and parking requirements. Operating costs can also be considerable given the staffing requirements and business rates for such sites. In addition, the financial returns to be made from operating MSAs and especially dedicated lorry parks is relatively low, given the profitability of the road freight transport sector together the space required per HGV parking space and the relatively low spend per driver/parked vehicle (given that these drivers are seasoned travellers who often prepare for their time away from home and are not especially well paid). MSAs and other roadside facilities catering to car users are typically more profitable than services provided to HGV drivers, as the latter usually travel with all their belongings, sometimes including food and drink, and therefore make fewer purchases of products and services when stopping either overnight or during the daytime. The main source of revenue from HGV drivers using lorry parks is usually the parking charge. Therefore, such HGV sites are often not deemed particularly financially attractive by private sector investors. New lorry parks are estimated to have at least a twelve to fifteen year payback period which discourages developers (AECOM, 2022). Land that could be used for lorry parks is instead often used for other purposes, given the relative rates of financial return for other land uses. In addition, some lorry parks operators are encouraged to sell by developers who wish to acquire the site for other, more profitable development uses. For instance, the Orwell Crossing Lorry Park, located 12 miles from Felixstowe on the A14, closed in 2021 and is being developed as a 60 acre logistics park which is expected to create 1100 jobs. Some local authorities that ran lorry parks have closed these for redevelopment as more financially attractive uses. Such alternative land use development potential for prospective or existing lorry parks is often heightened by their proximity to the Strategic Route Network (SRN) and the quantity of passing traffic attracted by these major traffic routes with hotel, office, business park and retail park development options. Such development pressure has been greatest in the South East in close proximity to London and its surrounding home counties. These same commercial issues (high land purchase prices, investment and operating cost requirements, and lack of sufficient expenditure by HGV drivers using them) also explain why there are so few local authority lorry parks (only 16 out of 328 lorry parks in England in 2022) and that even where these do exist they tend to provide only basic facilities (with 50% having offering only parking, and 25% having only parking and toilets in England in 2022). The number of these local authority lorry parks has reduced over time, with the authority selling the site and/or allowing a change of use on the site for its development for other more financially attractive purposes. This is due to local highway authorities not being legally 25 required to provide such off-street parking facilities for goods vehicles even if they have restricted on-street overnight HGV parking, together their lack of available funding and lack of prioritisation of their importance. As a result, few local authorities are considering developing lorry parks. As mentioned above, local authorities have also rejected many planning applications for new lorry parks by private developers and taken substantial periods of time to reach decisions for those they have eventually approved (often with expensive changes to proposals required). 26 6. Views on and responsibility for providing lorry parks 6.1 Views of local authorities and UK Government A consultation exercise was carried out by AECOM in May 2008 on behalf of the Highways Agency to investigate opinions and experiences of English local authorities with regards to HGV parking. The work found that some local authorities did not research or maintain an understanding of the lorry park situation in their area, and that “many local authorities were not taking a very proactive role towards the management of their road network in regard to lorry parking”. The consultation work found that 20 out the 37 responding local authorities were experiencing problems with unauthorised parking of HGVs on the Strategic Road Network (SRN). Thirteen responding local authorities stated that more lorry park provision was needed, and only 8 of the 37 local authorities were happy with the current level of HGV parking provided in their areas. The vast majority of Local Authorities (33 of the 37) believed the Highways Agency were at least partly responsible for lorry park provision in their jurisdictions, with five of them believing that the Highways Agency was wholly responsible for this. Only 11 of the 37 responding local authorities were involved in monitoring the lorry parks that operated in their areas. Twenty three of the 37 local authorities had a freight strategy but this did not necessarily cover HGV parking (AECOM, 2008a reported in AECOM, 2009). A report carried out for the Department of Transport in 2009 noted that, “Several local authorities have reported problems with HGV parking in their jurisdictions, however many of these do not have strategies for managing HGV movements and parking. Most also believe that highways authorities and central government should be at least partially responsible for the provision of such facilities” (AECOM, 2009). In 2008, the UK Government published a report that it described as “the first detailed analysis by the Department (of Transport) of the movement of major freight commodities on our national transport corridors. It sets out our understanding of the issues across freight modes and considers how government and industry can work together to facilitate effective freight movement and to mitigate its impacts” (Department for Transport, 2008, p.4). This report included consideration of HGV parking, noting that, “The Department is undertaking a research project on the provision of HGV parking in England. The project is being undertaken to consolidate existing research, which will lead to the clarification of roles and responsibilities across the public and private sectors. It is anticipated that it will feed into an action plan or strategy on lorry parking for implementation from 2009/10” (Department for Transport, 2008, p.4). The report also explained that “The attitude of a local authority to…..lorry parking provision can have impacts on the ability of an entire supply chain to deliver at the most effective and efficient time (Department for Transport, 2008, p.85) Prosaically, in the light of what has happened in Kent since its publication (see section 6.3), the report noted, “…..it was felt that Ro-Ro port capacity (particularly through Dover) could be full by 2018. Some stakeholders also expressed a view that port capacity needed to be matched by the capacity of associated infrastructure, including the key corridors to and from ports and secure waiting and lorry parking facilities close to ports” (Department for Transport, 2008, p.87) The research project into HGV overnight parking referred to in the above Department for Transport report was commissioned from AECOM and published in 2009. It notes that, “The DfT are conscious that the provision of HGV parking facilities in England is often considered inadequate, by a variety of stakeholders, including lorry drivers themselves, their managers, other road users, associations, councils and residents of areas where lorries frequently park” (AECOM, 2009). 27 6.2 UK Government approach Later in 2009, the Department for Transport published its ‘Strategy for Lorry Parking Provision in England’. This strategy commended by stating “DfT understands that the provision of HGV parking facilities is a vital service that supports the national and international road freight operations which help facilitate the UK economy and its growth. Lorry parks help to ensure road safety, preserve local amenity, reduce opportunities for crime and address the general needs of HGV driver working conditions. It is therefore important such services have support on a national level that helps create an environment which reduces the current barriers hampering development, financial stability and adequate standards. To work towards this better environment for HGV parking a clear plan has to be in place that can be realistically and practically delivered. Creating this strategy for HGV parking is the first step towards a long- term solution. The strategy is also a response to the call from industry for a co-ordinated approach to policy” (Department for Transport, 2009). Following this strong and supportive opening statement about the importance of HGV parking and the need for plan to deliver the parking facilities needed, the strategy went on to commit to six strategic objectives and related aims (see Table 6.1). Whilst the strategy did not foresee the national Government owning or operating lorry parks or pledge any specific level of Government funding to meet the objectives outlined in the strategy, it did commit the Government to far a greater level of planning and monitoring of the demand and supply for HGV parking; working with local authorities to emphasise their importance, ensuring that HGV parking requirements were prominently reflected in associated planning legislation, regional spatial strategies and local development plans; working with business to develop a more viable financial model for lorry parks that led to new sites opening and fewer closing; carrying out disseminating information to freight businesses and HGV drivers about the location of and facilities provided by lorry parks; and learning from European experience which in the case of several countries involves the provision of far higher driver welfare and safety features. A general election in 2010 resulted in a change in UK Government. In June 2011, the Roads Minister, Mike Penning, announced that the new Government had introduced, “a change to the policy to permit the development of truckstops on the motorway network…..Proposals for dedicated truckstop facilities will now be considered in the context of existing and proposed rest facilities on the strategic road network (SRN), and will be determined on their individual merit. This will include truckstop facilities that can be accessed direct from motorways - motorway truckstops - which are a type of facility not permitted until now. Where there is evidence to demonstrate that demand for lorry parking exceeds supply, the development of truckstop facilities at existing service areas would be viewed favourably.” (This was incorporated into DfT circular 01/2008 (April 2008) and subsequently incorporated, in a revised form, into DfT circular 02/2013 ‘The Strategic road network and the delivery of sustainable development’ - Department for Transport, 2013). The Roads Minister went on, “I am currently considering ways to reduce regulation, increase competition and improve still further the quality of Motorway Service Areas. To this end, I have instructed officials in my department to identify those elements of the policy that might instead be better determined at a local level through the current planning system. I have also instructed my officials to work with the Department for Communities and Local Government to consider how best to take these issues forward in the context of the national planning policy framework. Separately, we will produce an associated DfT technical note, setting out requirements in respect of road safety and operational issues. This approach accords with the government’s twin aims of decentralisation and localism, reducing the burden of bureaucracy and strengthening local accountability. It will encourage competition and, through this, improve service for users” (Department for Transport, 2011b). 28 Table 6.1: Strategic objectives and related aims of the DfT’s Strategy, 2009 No. Strategic Objective Aim 1. Build on the current understanding of HGV parking provision and investigate the demand requirements up to 2014 – 2019 and beyond if necessary. Develop a lorry parking model to establish an evidence based approach that can target specific problem areas and inform decision making at national, regional and local levels. This would help to map parking hotspots associated with demand and capacity issues up to 2014 – 2019 and beyond if necessary. This research would underpin many elements of the strategy / action plan. 2. Define the position of lorry parking policy at national, regional and local levels where required. Encourage Councils to consider and support the need of lorry parking where it is required. Help to understand the position of lorry parking in the policy suite of documents including National Planning Statements (NPS), Policy Planning Guidance 13 (PPG13), Regional Spatial Strategies (RSS), Local Development Frameworks (LDF), Local Transport Plans (LTP), and 01/2008 ‘Policy on Service Areas and Road Side Facilities on Motorways and All- purpose Trunk Roads in England’. 3. Support Industry by providing Best Practice Guidance and further information to help stabilise business. The production of best practice guidance to increase the appropriate use of lorry parking and clearly define operator and driver responsibilities such as forward planning and expense payment structures. Improve service levels and working conditions for drivers. Improve financial return of lorry parks and to stimulate future investment. 4. Create an environment where lorry parking schemes can be brought forward by the private sector as more feasible investment opportunities. To help to make lorry parking businesses more sustainable and competitive. Improve the stability of lorry parking businesses. To encourage new developments and to reduce closures across the network. Review of lorry parking operating costs. To make lorry parking businesses more competitive and viable as investment opportunities. 5. Increase awareness of existing lorry parking locations and encourage their appropriate usage. Increase the awareness of areas in need of lorry parking. Reduce inappropriate parking and associated environmental and safety implications. Indirectly increase compliance to the driving time regulations. Encourage journey and contingency planning. Highlight the areas in greatest need of lorry parking provision, including locations that currently have no facilities. 6. Encourage the development and use of secure lorry parking locations with an added intention of improving working conditions for drivers. Reduce crime and terrorist opportunities and improve safety of drivers and lorry parking site staff. Utilise existing information from SETPOS and LABEL to encourage private investment in new developments and upgrades to increase security across the network. Provide guidance and information on available standards and how to achieve them. Source: Department for Transport, 2009. In November 2011, the UK Government published a more detailed HGV parking audit of the SRN in England (AECOM, 2011) than the work commissioned in 2009. In publishing this study, Roads Minister stated that: “Making this information available to drivers and operators will make it easier for them to know where facilities are available. It will also help developers and local councils who want to plug gaps in the market helping to boost growth in the sector. I hope that by providing better information we will see more high quality HGV parking facilities 29 in the places where they are most needed. This will improve safety for drivers and reduce disruption for local residents” (Department for Transport, 2011a). After 2011, Government outputs concerning HGV parking in England come to a seeming halt until the Transport Select Committee 2015/16 inquiry into the road haulage industry (House of Commons Transport Select Committee, 2016a). In written evidence to that inquiry, the Department for Transport reiterated the view of the Roads Minister in 2011 (above) stating that, “The provision of roadside facilities is primarily a matter for the private sector and local authorities, who are best placed to judge local traffic conditions and needs. There is no specific disaggregated information available on Government spend on roadside facilities, although it is likely to be limited” (Department for Transport, 2016a). During the inquiry the Government was criticised for its (lack of) management of HGV parking. Lack of provision of facilities for goods vehicle drivers is commonly cited by drivers and others as an important factor in the HGV driver shortage that has existed for many years.. In the 2015 Chartered Institute of Logistics and Transport (CILT) driver shortage survey, approximately 40% of respondents cited driver facilities as an important issue (Chartered Institute of Logistics and Transport, 2015a). In written evidence to the inquiry into the road freight transport sector in the UK by the House of Commons Transport Committee in 2015/16 (House of Commons Transport Select Committee, 2016a), the CILT noted, “at a UK level the lack of provision of secure parking with drivers’ rest facilities on key trunk routes”, explaining that unless improvements were made would affect road safety and result in the industry continuing to fail to recruit drivers (Chartered Institute of Logistics and Transport, 2015). In 2017, Logistics UK published a ‘Commercial Vehicle Driver’s Rest Facilities Charter’ in which it urged central Government to ensure that sufficient investment was made in in the road network for HGV driver facilities, and National Highways and local authorities to ensure that central Government guidance was adhered to when new road infrastructure is planned and developed thereby avoiding loss of lay-by provision or rest facilities. The charter argued that there must be “no further loss of overall (HGV parking) capacity and then progressively a gain as roads develop” (Logistics UK, 2017). In its written evidence responding to the Transport Select Committee’s questions about lorry parks, the UK Government said that “The provision of roadside facilities primarily a matter for the private sector and local authorities, who are best placed to judge local traffic conditions and needs. There is no specific disaggregated information available on Government spend on roadside facilities, although it is likely to be limited.” It did, however, say that “ministers will be examining further what support the Government and Highways England can provide in relation to encouraging changes to Motorway Service Area operations and future investment in lay- bys and other HGV parking (Department for Transport, 2016a, 2016b). The Transport Select Committee’s inquiry also led to the Department for Transport commissioning another audit of HGV parking (AECOM, 2017). It can only be assumed that the new Government elected in 2010 was rather less keen than its predecessor on the strategy for HGV parking provision that it inherited. Rather than delivering on the strategic objectives in Table 6.1, from the tone of the Road Minister’s statement in 2011 and the DfT’s written evidence to the Transport Select Committee in 2016 (see above) instead the Government decided that it did not see its role as taking charge of HGV parking issues and instead sought to devolve this responsibility to local authorities, who did not rise to the challenge. There has been little change in terms of the approach taken by UK national Government or local authorities in addressing HGV parking facilities in recent years with the freight industry expressing concerns and disquiet about it (see section 11). Factors including amenity problems and other impacts caused by HGV parking in lay-bys and at kerbsides in industrial estates and lorry-related crime/theft have though led to HGV parking studies being 30 commissioned by some local authorities. An update on the most recent announcements and actions concerning lorry parks by the UK Government is provided in sections 12 and 13. 6.3 The situation in Kent and response of national and local government Although overnight HGV parking shortages exist in many regions of the country, pressures have been greatest in Kent, due to a lack of lorry park space to meet demand which is driven by the number of HGVs coming into and out of the UK via the Port of Dover and the Eurotunnel in Folkstone to make deliveries (5,000-10,000 HGVs daily) and the delays they face at these intermodal crossing points on their return journeys. The South East region in which Kent is situated has the greatest number of lorry park spaces on or within 5 km of the SRN of all regions in England (3,729 spaces in 2022). Lorry parks in the South East were found to have an overnight utilisation rate of 94% in a 2022 audit (i.e. 94% of lorry park spaces were observed to be in use when the audit took place). This was a substantial increase on the 84% utilisation rate observed in the 2017 audit. Given that it is assumed in these audits for the Department for Transport that lorry parks become full at a utilisation rate of 85% this indicates the demand for lorry park space. Of all HGVs parking overnight in the South East in the 2022 audit, 28% of them were observed to be parking in lay-bys and at kerbsides in industrial estates rather than in lorry parks, providing further indication of the lack of lorry park capacity. If all of these HGVs were to be accommodated in lorry parks, the South East would have required an additional 1,700 lorry park spaces in 2022, more than any other region of England, with the majority of these required in Kent (analysis of data in AECOM, 2022 - see section 8 for further details of this overnight HGV parking audit). Even as far back as 2014, modelling of the future lorry park capacity required in Kent indicated that, “with the ongoing increase in international freight traffic…there would need to be a huge uplift in parking provision to cope with all truck parking” (AECOM, 2014). This lack of lorry park capacity in Kent has existed for many years. In 1988, ‘Operation Stack’, a contraflow traffic arrangement on the Dover-bound side of the M20 to cope with the build- up of HGV Channel crossing road traffic when delays occurred at the port and/or the Eurotunnel, was introduced. It was implemented on numerous occasions during its life. In 2015, the UK Government announced that proposal to provide a lorry park at Stamford West in Kent to replace Operation Stack. This was to cost £250 million and provide off-motorway parking for 3,600 HGVs including driver facilities. However, the proposal received many objections for local residents. In 2017 it was subject to a judicial review which ruled that it could not go ahead due to the lack of an environmental assessment prior to the review. This resulted in the Government dropping the plans. The proposed scheme also faced much objection from residents living near the site. In 2018, in a speech updating Parliament on Operation Stack and HGV traffic in Kent, the Under-Secretary of State for Transport, Jesse Norman, told the House of Commons that the Government was announcing measures to lay-by and on-road parking by HGVs in Kent and elsewhere the country (see an explanation of the Kent TRO scheme below). As part of this speech, he also announced plans “increase overnight HGV parking capacity which could potentially add an additional 1,500 spaces” which, he hoped, would be delivered by the private sector. He set out three steps the Government would be taking to assist in this goal: (i) National Highways would analyse its landholdings in order to identify sites with the potential to be developed into lorry parks, and would give increased priority to the provision of HGV parking across the SRN (it had proposed funding needs for better HGV parking facilities to the Department for Transport which were being considered), (ii) that Jesse Norman and the Planning Minister Dominic Raab had written to local planning authorities to “draw their attention to the survey results, which show a strategic national need for more HGV parking and highlight shortages in specific areas”, and that Department for Transport was asking National Highways to “assist local authorities in actively identifying areas of HGV parking need and potential solutions, including in the context of specific planning applications where these 31 might help alleviate the situation”, and (iii) Department for Transport would “consider further steps to make it easier for local authorities to take enforcement action against hauliers who park inappropriately” and promote the trial approach on the A20 in Kent in other regions facing this problem (Department for Transport, 2018). The HGV parking problem in Kent has become increasingly severe over time as goods importation levels increase, resulting in increases in HGV movement to and from mainland Europe and the pressure this places on the Ports of Dover, Ramsgate and Folkestone and the Eurotunnel and, more recently, since 2020 with problems caused by Covid and Brexit and the P&O ferry crisis in 2022. These sea ports and the Eurotunnel were responsible for handling 1.6 million powered HGVs leaving the UK for the EU in 2021. This represented 84% of all powered HGV crossings departing the UK (calculated from data in Department for Transport, 2021b, 2021c). As mentioned above, in 2017 Kent County Council, Ashford Borough Council and the Department for Transport put in place an 18-month Experimental TRO to trial an overnight HGV parking ban between 20:00 and 07:00 covering the A20 between Charing and Ashford and four industrial estates in the borough. The trial permitted clamping of vehicles that contravened restrictions and a Penalty Charge Notices (PCN) that includes a £150 clamp release fee. The trial resulted in 2,754 HGVs being clamped, with HGV parking in the area falling by “61% with little displacement to neighbouring districts.” In 2019, the scheme became permanent (Ashford Borough Council, 2019). Brexit-related concerns about delays due to document, vehicles and goods checks at the Dover Straits seaports and the Channel Tunnel led to the UK Government having to introduce the ‘Heavy Commercial Vehicles in Kent Order 2019’ as a multi-agency response plan managed by the Kent