Representation by Royal Mail Group (Royal Mail Group)
- Date submitted
- 13 February 2023
- Submitted by
- Members of the public/businesses
Royal Mail Group Limited (Royal Mail) supports National Grid’s Yorkshire Green scheme, but is seeking to secure mitigations to protect its road based operations during the scheme’s construction phase. 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 affected detrimentally 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. Royal Mail has two operational properties within approximately two miles of the DCO boundary. In exercising its statutory duties, Royal Mail vehicles use on a daily basis all of the roads that may be affected by any Traffic Management measures, partial or total road closures and /or any additional traffic during the construction phase of Yorkshire Green. Any congestion on these roads has potential to adversely affect Royal Mail operations. Following submission of Royal Mail’s section 42 consultation response in December 2021, Royal Mail has had very helpful contact with National Grid as a result of which wording has been included within the Construction Traffic Management Plan dated November 2022 (document reference is 5.3.3F Appendix 3F) paragraphs 8.2.5 and 8.2.6 which is in line with Royal Mail’s section 42 consultation requests. The applicant has accepted this wording as a commitment, which if fully implemented, will provide Royal Mail with satisfactory advance notification, liaison and information on works that affect the highway network. However, Royal Mail is registering be an Interested Party to the Examination in order to protect its position and seek to ensure that paragraphs 8.2.5 and 8.2.6 of the CTMP remain unchanged during the Examination and will take effect during the construction phase.