Representation by Royal Mail Group (Royal Mail Group )
- Date submitted
- 30 March 2021
- Submitted by
- Other statutory consultees
BNPPRE acts on behalf of Royal Mail and whilst our clients do not have an in principle objection to the proposed scheme we are seeking to secure mitigations to protect Royal Mail’s road based operations within its vicinity. Under section 35 of the Postal Services Act 2011 (the “Act”), Royal Mail has been designated by Ofcom as a provider of the Universal Postal Service. Royal Mail is the only such provider in the United Kingdom. The Act provides that Ofcom’s primary regulatory duty is to secure the provision of the Universal Postal Service. Ofcom discharges this duty by imposing regulatory conditions on Royal Mail, requiring it to provide the Universal Postal Service. The Act includes a set of minimum standards for Universal Service Providers, which Ofcom must secure. The conditions imposed by Ofcom reflect those standards. Royal Mail is under some of the highest specification performance obligations for quality of service in Europe. Its performance of the Universal Service Provider obligations is in the public interest and should not be detrimentally affected by any statutorily authorised project. Royal Mail’s postal sorting and delivery operations rely heavily on road communications. Royal Mail’s ability to provide efficient mail collection, sorting and delivery to the public is sensitive to changes in the capacity of the highway network. Royal Mail is a major road user nationally. Disruption to the highway network and traffic delays can have direct consequences on Royal Mail’s operations, its ability to meet the Universal Service Obligation and comply with the regulatory regime for postal services thereby presenting a significant risk to Royal Mail’s business. There are 10 operational facilities within 12 miles of this scheme. The additional vehicle movements during the construction and operational phase (approximately 12.5 million visitors per year with Gates 1 and 2 in operation) of the Scheme would have significant potential to be disruptive to Royal Mail’s local road operations. The key arterial routes identified by operational teams as being sensitive are the Dartford Tunnel (all drivers delivering in DA and ME postcodes use this route), A2, A296, M20 J3-6, M26 and M25 J2. Royal Mail wishes to ensure the protection of its future ability to provide an efficient mail sorting and delivering service. Royal Mail requests that: 1. the DCO includes specific requirements that during the construction phase Royal Mail is consulted by London Resort Company Holding or its contractors at least one month in advance on any proposed road closures / diversions / alternative access arrangements, hours of working, and the content of the final CTMP, and 2. The final CTMP includes a mechanism to inform major road users (including Royal Mail) about works affecting the local highways network (with particular regard to Royal Mail’s distribution facilities near the DCO application boundary as identified above). Royal Mail reserves its position to object to the DCO application if the above requests are not adequately addressed. Contacts: () of Royal Mail’s Legal Services Team () of BNP Paribas Real Estate.