Representation by London & South Eastern Railway Limited (London & South Eastern Railway Limited)
- Date submitted
- 31 March 2021
- Submitted by
- Non-statutory organisations
Relevant Representation by London & South Eastern Railway Limited in respect of an application by the London Resort Company Holdings Limited for a Development Consent Order 1. LONDON & SOUTH EASTERN RAILWAY LIMITED'S INTEREST IN THE MATTER 1.1. London & South Eastern Railway Limited ("Southeastern") operates passenger train services pursuant to a franchise agreement it entered into with the Secretary of State for Transport (the "SoS") dated 27 March 2020 (the "Franchise Agreement"). 1.2. The Franchise Agreement expires on 17 October 2021. Southeastern is submitting this Relevant Representation as if they were continuing to be the operator of the South Eastern Franchise past this date. Southeastern will be sharing this response with the SoS but the views of the SoS should also be sought out. 1.3. As the operator of train services on the South Eastern Franchise, Southeastern: 1.3.1. operates domestic passenger rail services on High Speed 1 which call at St Pancras International, Statford International and Ebbsfleet International Stations; 1.3.2. operates domestic passenger rail services on the National Rail network in the vicinity of the proposed London Resort (the "Project"). In particular, Southeastern operates domestic rail passenger services that call at Swanscombe station, Greenhithe station and Northfleet station (each being a station near to the Project); and 1.3.3. is the station facility owner at Swanscombe station, Greenhithe station and Northfleet station. 1.4. The Project, if it proceeds, would have a material impact on each of the above and, therefore, Southeastern is interested in the Project. 2. REPRESENTATION 2.1. Southeastern remains supportive of the Project in principle but has concerns about the application in its current form. 2.2. Specifically, Southeastern is not yet satisfied that the London Resort Development Consent Order proposed includes appropriate mitigation measures and safeguards to ensure the safe and efficient continued operation of the rail network. Southeastern considers that further studies and a wider analysis of industry interests and financial consequences will be required in order to demonstrate that the Project will not prejudice the safe and successful operation of domestic passenger services by Southeastern. 2.3. Further, Southeastern is concerned that there has been insufficient consideration about: 2.3.1. the impact of an increase in passenger numbers at relevant stations as a result of the Project; 2.3.2. the need for extra facilities and expansion at the relevant stations (e.g. the High Speed 1 stations as above, Swanscombe station, Greenhithe station and/or Northfleet station on NRIL) as a result of increased passenger demand due to the Project; 2.3.3. the potentially serious timetabling implications due to the increase in passenger demand (e.g. additional London to Ebbsfleet services may be required and additional station dwell time at each of the NRIL stations) as a result of the Project; 2.3.4. the potential requirement for extra capacity rolling stock (including additional depot/stabling space for rolling stock) as a result of the Project; 2.3.5. the impact of the Project on car parking capacity at Ebbsfleet International; 2.3.6. platform capacity at St Pancras International and Ebbsfleet International Stations and the extent to which this may constrain potential solutions to the increase in passenger numbers as a result of the Project; and 2.3.7. safety during both the construction and operation of the Project. 2.4. This list is not exhaustive. 2.5. Southeastern notes that some of the above issues are being discussed in a joint independent capacity study. Southeastern looks forward to the findings in this study and hopes that this deals with the some of the current uncertainties around the Project. 3. PARTICIPATION IN THE EXAMINATION 3.1. Southeastern is continuing to review the application material, with the intention that Southeastern will provide a full representation at the written representation stage. 3.2. Southeastern wishes to attend the preliminary meeting for this matter. 3.3. Please register Southeastern as an Interested Party so that it can be kept informed of relevant information and hearings that might affect its position. The contact at Southeastern is Mike Boden, Business Development Director. London & South Eastern Railway Limited 31 March 2021