Representation by Royal Mail Group Limited (Royal Mail Group Limited)
- Date submitted
- 15 November 2022
- Submitted by
- Other statutory consultees
Royal Mail Group Limited (RM) supports this proposed Energy from Waste CHP facility, but is seeking to secure mitigations to protect its road based operations during the construction phase. Under section 35 of the Postal Services Act 2011 (the “Act”), RM has been designated by Ofcom as a provider of the Universal Postal Service. RM 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 RM, 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. RM 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 affected detrimentally by any statutorily authorised project. RM’s postal sorting and delivery operations rely heavily on road communications. RM’s ability to provide efficient mail collection, sorting and delivery to the public is sensitive to changes in the capacity of the highway network. RM is a major road user nationally. Disruption to the highway network and traffic delays can have direct consequences on RM’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 RM’s business. Wisbech Delivery Office is approximately 500 metres to the north of the DCO application site. The proposed CHP connection corridor runs less than 100m to the east of Wisbech Delivery Office. In exercising its statutory duties, RM vehicles use the A47, the A1101 and all of the adjacent local roads on a daily basis. New Bridge Lane, Enterprise Way, Salters Way, Cromwell Road, Algores Way, Weasingham Lane and Churchill Road / Elm High Road are all used daily by RM and are important to access in to and out from Wisbech Delivery Office to from the A road network and for deliveries. Any congestion on these roads has potential to adversely affect RM operations. The nearby section of the A47, particularly between Wisbech and Ring’s End is a strategically important distribution route for RM services. Following submission of RM’s section 46 consultation response in August 2021, RM has had helpful contact with MVV UK as a result of which wording has been included within the applicant’s Environmental Statement Appendix 6A Outline CTMP paragraphs 7.4.29 and 7.4.30 which is in line with RM’s section 46 consultation requests. The applicant has accepted this wording as a commitment, which if fully implemented, will provide RM with satisfactory advance consultation, liaison and information on works that affect the highway network. However, RM is registering be an Interested Party to the Examination in order to protect its position and ensure that Outline CTMP paragraphs 7.4.29 and 7.4.30 remain unchanged during the Examination and take effect during the construction phase.