Richard North, 08/01/2019  

Forced to decide whether a Secretary of State might be lying or is simply ignorant, I think I would prefer to choose the former. The idea of senior government members not knowing what they are doing is not one with which I am terribly comfortable.

When it comes to the Secretary of State for Transport, though, I would find it more difficult to accept that he is lying. It is the easiest thing in the world to believe that, in Chris Grayling, we have a man who would struggle to get to grips with the Ladybird book of motor cars. Tootles the Taxi might be more his level.

Thus, when yesterday he delivered a written statement to parliament, updating MPs on the government contracts with ferry operators, one has to give him the benefit of doubt on his more dubious claims, and assume that he doesn't realise the errors he is perpetrating.

What particularly sticks in the craw is the way the assertion that the Department for Transport has completed a procurement process to secure additional ferry capacity between the UK and the EU gets transformed into a process of providing additional freight capacity, as if they were the same things.

It is not pedantic to say in this context that, when it comes to ro-ro ferries, these ships do not carry freight, as such. They carry lorries and it is those that carry the freight – assuming they are loaded, which is not always the case. About a third of the lorries travelling on ferries from the UK to the continent are returning empty.

Measurement of capacity, though, is rather more complex, as we are not so much talking about individual ferries or lorries, but of the tonnage that can be delivered via the combination of the various routes to their final destinations in a given period.

Comparing lorries with a the same load-carrying capacities, if one group takes twice as long to deliver the goods via a specified route than by another, and if a similar number of ferries transporting them can only hold half the number of vehicles, that route capacity is only a quarter of its comparator.

Given that this will apply, to a greater or lesser extent to the routes chosen by Mr Grayling for his largesse, and his ferries are not carrying additional lorries but those displaced from the Dover corridor route, the net effect of his intervention will actually be to reduce the overall capacity. The lorries concerned will be engaged in the load delivery (and return) for that much longer. They and their drivers will not be available to carry fresh loads. To maintain the capacity, many more lorries will be needed.

Nor does it stop there. Mr Grayling tells us that, in addition to the Seaborne Ferries plying the Ostend route, Brittany Ferries and DFDS will run from the Ports of Immingham and Felixstowe (DFDS) and Poole, Plymouth and Portsmouth (Brittany) to destinations in Germany (Cuxhaven), the Netherlands (Vlaardingen) and France (Caen, Cherbourg, Le Havre, and Roscoff).

Yet, if one adds in Ostend, only two of the destinations (Cuxhaven and Le Havre) are serviced by Border Inspection Posts. Although Vlaardingen is close to Rotterdam, it is the wrong side of the river for traffic to access its inspection centres.

On that basis, the actual load-carrying capacity for these routes, in delivering foodstuffs, is nil. Even if temporary facilities were provided, one might expect the ports to become so congested that their load processing capabilities might be seriously limited, especially as there are low numbers of ramps, and very few of the double-deck type.

It is certainly the expectation of the French authorities that there will be congestion and delays, which suggests that, if there is any sense behind the Grayling scheme, it is not in providing additional capacity. Rather, it is a way of getting urgent goods into the UK, by-passing the blockages on the Dover corridor.

If that is the case, then it would be helpful if Mr Grayling would say so. For the very limited capacity afforded to be actually put into use, it would suggest that the Dover corridor had come almost to a complete halt, and there was a real danger of food and other essential supplies, such as medicines, running out.

Putting a little meat on the bone, we now have some UK academic research which is endeavouring to model more accurately the effect of delays at the ports. This is the UCL, which is assessing the impact of different processing times for outbound journeys using Dover's existing layout and traffic flows. It anticipates that extra customs checks of up to 40 seconds per vehicle would have no impact on the queuing time for outward journeys through Dover.

However, if delays reach 70 seconds per truck, a queue of between 1,200 and 2,724 heavy goods vehicles is expected, leading to tailbacks taking six days to clear. "[The queue] starts Monday evening and ends by Saturday noon", the UCL estimates. However, if the processing time goes up to 80 seconds the result would simply be "no recovery". The whole country would be gridlocked in a massive traffic jam.

This research was actually commissioned by the DfT, and if it is giving the right picture, the traffic from Ramsgate won't be able to get clear of the port, as it will be caught up in the Dover congestion.

This is especially the case if separate research by Imperial College London has got it right. It predicts "paralysis" on the M20 motorway and A20 trunk road if new customs delays are introduced. Nearly five hours of traffic delays in Kent is predicted at peak times, with an extra two minutes spent on each vehicle at the border tripling existing queues on the M20/A20 to 29 miles.

The worrying thing about this research, though, is that it is only one of "a number of documents commissioned" by the DfT since the 2016 referendum. The UCL work was presented to ministers in 2017 but never published.

Perhaps, though, one might have to change one's view of Grayling. On the basis of this, he undoubtedly knows far more than he has been letting on. One can see why he is so keen to get the extra ferries in place.

It also explains, to an extent, the otherwise inexplicable road tests from Manston yesterday, when a meagre 90 lorries were used to rehearse procedures in the event of disruption arising from a no-deal Brexit.

What is so frustrating about all of this, though, is that modelling all seems predicated on congestion on this side of the Channel, with very little understanding or information about conditions in the continental ports.

It is there where the longest delays might be. Forget 80 seconds. It can take 2-3 hours to process one load through a BIP and throughput is limited by the number of bays. More time still can be taken if multiple consignments of different foods are presented for inspection.

On top of this, one has to recall that, in the event of a no-deal, UK notified bodies are no longer recognised and, without a mutual recognition agreement on conformity assessment in place, their third party certification of regulatory conformity will no longer be valid.

Unless very stringent measures are imposed, UK exporters will doubtless be attempting to continue sending goods to the continent which, without the valid certification, will not be admitted. No doubt, French and other national customs and trading standards officials will be inspecting large number of vehicles in anticipation of intercepting these prohibited goods.

The food trade, therefore, is only part of the problem. Lorries used to ship a wide range of manufactured (non-food) goods, bearing CE marking, will also come under extra scrutiny. Full loads might take considerable time to inspect.

Here, there is the question not only of secure inspection bays, but the handling equipment and manpower needed for the labour-intensive processes of unloading and reloading vehicles. Then, if re-testing of goods is permitted, numbers of vehicles and/or trailers may have to be detained for several weeks, awaiting results.

Nothing of this seems to be factored in. UK media coverage of the problems is scant, and even French publications are taking the issue more seriously than one finds in the UK. Sometimes, I find myself having to do a double-take, wondering if these issues are somehow not real.

Sadly, though, just because the media ignore a problem does not mean it doesn't exist. The problems, if anything, have been massively understated. In the event of a no-deal Brexit, cross-Channel trade will be on the brink, with gridlock the inevitable consequence.

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