Representation by Royal Mail Group Ltd (Royal Mail Group Ltd)
- Date submitted
- 5 September 2019
- Submitted by
- Other statutory consultees
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 proposed M25 Junction 10/A3 Wisley Interchange Improvements will, once constructed, reduce congestion which will have benefits for Royal Mail operational traffic movements. However, Royal Mail is concerned about the potential for disruption to its operations during the construction phase. Royal Mail’s has nine operational properties within approximately 10 miles of the proposed DCO boundary, the nearest being Cobham Delivery Office 1 High Street, Cobham KT11 3E which is 2.4 miles distant. The M25 and A3 are strategically important distribution routes for Royal Mail operational traffic. Any periods of road disruption/closure, night or day, have the potential to impact operations. Also, in exercising its statutory duties Royal Mail vehicles use on a daily basis all of the local roads that may potentially be affected by additional traffic arising from the construction of the proposed junction improvements. Royal Mail therefore wishes to ensure the protection of its future ability to provide an efficient mail sorting and delivery service to the public in accordance with its statutory obligations which may be adversely affected by the construction of this proposed scheme. In order to address the above concerns Royal Mail requests that: 1. The DCO includes requirements that Royal Mail will pre-consulted by Highways England or its contractors on any proposed road closures/ diversions/ alternative access arrangements, hours of working and the content of the final Construction Traffic Management Plan. 2. The final Construction Traffic Management Plan 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 area surrounding the DCO application boundary).