Representation by Royal Mail
- Date submitted
- 10 March 2023
- Submitted by
- Non-statutory organisations
Royal Mail (RM) does not have an in principle objection to this proposed road scheme but is seeking to secure mitigations to protect its 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. Junction 9 of the M3 is a critical junction used by RM’s national and local collection, distribution and delivery operations. RM has four operational facilities within 10 miles, including Winchester Delivery Office c 0.75 miles distant. Highway works and Traffic Management for this scheme risk impact on and delays to RM’s operations. Every day, in exercising its statutory duties RM vehicles use all the main roads that may potentially be affected by additional traffic arising / delays during construction of this scheme. Any road disruption / closures, night or day, has potential to impact operations. RM does not wish to stop or delay this scheme from being constructed, but does wish to protect its future ability to provide an efficient mail sorting and delivering service. In order to do this, RM requests that: 1. the DCO includes specific requirements that during the construction phase RM is consulted by National Highways or its contractors at least one month in advance on any proposed road closures / diversions / alternative access arrangements, hours of working, and on the content of the final CTMP, 2. the final CTMP includes a mechanism to inform major road users (including RM) about works affecting the local highways network (with particular regard to RM’s distribution facilities near the DCO application boundary), and 3. RM is able to join National Highways’ consultation group with the Local Highways Authority and other major road users. RM reserves its position to object to the DCO application if the above requests are not adequately addressed.