Representation by Royal Mail (Royal Mail)
- Date submitted
- 30 October 2020
- Submitted by
- Other statutory consultees
BNPPRE act on behalf of Royal Mail and whilst our clients do not have an in principle, objection to the proposed scheme we are seeking to secure mitigations to protect our operations within the location of the project. Under section 35 of the Postal Services Act 2011 (the “Act”), Royal Mail (RM) 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. The Government imposes financial penalties on Royal Mail if its Universal Service Obligation service delivery targets are not met. These penalties relate to time targets for collections, clearance through plant and delivery. 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. There are three operational facilities within 12 miles of this proposal, Alnwick Delivery Office (“DO”), Morpeth DO and Ashington DO. The location, nature and scale of the proposed improvements could present risk of construction phase impact / delays to Royal Mail’s road based operations on the surrounding road network. The key concerns to RM’s operations will be the impact to collection mail coming from Alnwick DO and Berwick DO (30 miles north of the Scheme), en route to Tyneside Mail Centre for processing. As well as causing impacts to inward mail deliveries from Tyneside to Alnwick DO. Every day, in exercising its statutory duties Royal Mail vehicles use of the A1 and other subsequent main road that may potentially be affected by additional traffic arising from the construction of the proposed upgrades. Any periods of road disruption / closure, night or day, have the potential to impact operations. Royal Mail does not wish to stop or delay the improvements from coming forward for development. However, Royal Mail does wish to ensure the protection of its future ability to provide an efficient mail sorting and delivering service. In order to do this, Royal Mail requests that: 1. The DCO includes specific requirements that during the construction phase Royal Mail is consulted by Highways England or its contractors at least one month in advance on any proposed road closures / diversions / alternative access arrangements, hours of working, and the content of the final CTMP, and 2. The final CTMP includes a mechanism to inform major road users (including Royal Mail) about works affecting the local highways network (with particular regard to Royal Mail’s distribution facilities near the DCO application boundary as identified above). Royal Mail reserves its position to object to the DCO application if the above requests are not adequately addressed.