Representation by Royal Mail Group Limited (Royal Mail Group Limited)
- Date submitted
- 22 June 2023
- Submitted by
- Other statutory consultees
Royal Mail Group Limited (Royal Mail) supports London Luton Airport Expansion, but is seeking to secure mitigations to protect its road based operations during the scheme’s construction and operational phases. 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. Its 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 significant risk to Royal Mail’s business. Royal Mail has six operational sites within twelve miles of Luton Airport. 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 the Airport Expansion. Any congestion on these roads has potential to adversely affect Royal Mail operations. Royal Mail does not wish to stop or delay this scheme from being constructed, but does wish to protect its future ability to provide efficient mail sorting and delivering services. 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 LLAL 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 Royal Mail) about works affecting the local highways network (with particular regard to Royal Mail’s distribution facilities near the DCO application boundary), and 3. Royal Mail is invited to join any stakeholder traffic management consultation group that is set up during the operational phase. Discussions between Royal Mail and LLAL are ongoing. Royal Mail has been advised by the applicant that a draft legal agreement to address the above requests is being prepared for Royal Mail’s consideration.