Representation by Royal Mail Group Limited
- Date submitted
- 10 January 2019
- Submitted by
- Members of the public/businesses
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.
The A303 is a strategically important distribution route for Royal Mail. Any construction phase delays can be expected to have direct impact on all local and regional Royal Mail vehicle movements using the affected section of the A303.
In addition, Royal Mail’s has two operational Delivery Offices both within 0.5 km of the proposed DCO boundary near Amesbury (Amesbury Delivery Office SP4 7EW and Bulford Barracks Delivery Office SP4 9JB).
Therefore Royal Mail is concerned that its future ability to provide an efficient mail sorting and delivery service to the public in accordance with its statutory obligations may be adversely affected by the construction of this extensive A road improvement as proposed in the DCO application.
Royal Mail submitted a s42 consultation response in April 2018 which made two requests of Highways England for inclusion in the draft DCO. These requests have not been satisfactorily addressed in the draft DCO, so Royal Mail wishes to further protect its interests through submission of this relevant representation.
Royal Mail requests that the final DCO includes requirements that:
1. Royal Mail is pre-consulted by Highways England on any proposed road closures/ diversions/ alternative access arrangements, hours of working and the content of the final Construction Traffic Management Plan (CTMP).
- The final CTMP includes provision for a mechanism to inform major road users about works affecting the local network (with particular regard to Royal Mail’s distribution facilities in the vicinity of the DCO application site). Contacts for Royal Mail: Holly Trotman (holly.trotman@royalmail.com) of Royal Mail’s Legal Services Team Daniel Parry-Jones (daniel.parry-jones@bnpparibas.com) of BNP Paribas Real Estate.