Eurostar response – comments on submissions from applicants and interested persons/parties (Redacted)

SectionDepot access applications and decisions
Eurostar International Ltd
6th Floor Kings Place
90 York Way
London N1 9AG
eurostar.com
Eurostar International Ltd registered in England and Wales No. 2462001
6th Floor Kings Place, 90 York Way, London N1 9AG VAT Registration No. GB 991 2920 01
Ian Biggar
Access Policy Advisor
Office of Rail and Road (ORR)
25 Cabot Square
London E14 4QY
Sent by email to: stationsanddepots@or r.gov.uk
18 September 2025
Dear Ian,
Eurostar response to the ORR’s letter dated 15 August 2025 regarding applications for directions under
section 17 of the Railways Act 1993 fo r access to Temple Mills Internatio nal Depot
Thank you for your letter of 15 August 2025, invi ting Eurostar to reply to the submiss ions from Evolyn, VTE, Gemini
and Trenitalia. We set out our respons e in the attachment to this letter.
We look forward to our further engag ement.
[ ]
Gareth Williams
Eurostar General Secretary
Attachment: Eurostar’s submissions in r esponse to applicants’ and other stakehol ders’ submissions
2
Eurostar’s submissions in response to applicants’ and other stakeholders’
submissions
1 INTRODUCTION
1.1 The processes that the ORR has been conducting under s.17 have co nfirmed that there is broad commercial
interest in international passenger ra il services to and from the UK and with investable busin ess cases (or
potentially investable business cases ) if the right railway infrastructure is in place. Eur ostar welcomes that
interest.
1.2 Eurostar has been, and remains , a committed advocate of the ben efits of international passenger r ail
services, which deliver broad econom ic, social and environmental benefits . That is underlined by Eurostar’s
plans to purchase and introduce a new fleet of up to fifty new trains.
1.3 The submissions to the ORR in the context of the s .17 processes provide a glimps e into exciting ideas for
the long-term future of the internationa l passenger rail market.
1.4 There is a clear opportunit y for the UK to capitalise a nd become the leader in cros s-Channel rail services
and operations. That should be gr asped through system-wide support and investment in all as pects required
for the operation of international passenger r ail services, from terminals and sta tions to depots.
1.5 As things stand, there are no firm conclusions on availa ble capacity at TMI, but, even if the availability of
some relevant limited capacity can be esta blished at TMI, each of the applicants ’ and Eurostar’s plans set
out ambitions that ultimately seek to go far beyond what any residual capac ity at TMI can provide.
1.6 These s.17 applications can only be focussed on whether there should be a direction to enter an access
contract in relation to TMI; that is an inherent constraint of the s.17 proc ess which ORR is now conducti ng.
However, the vote of confidence in t he existence of significant and grow ing demand for international trav el
by rail calls for coordinated, sy stem-wide action by Government and th e ORR and all other stakeho lders to
plan and invest in infrastructure that s upports the true potential for internati onal rail services and the
associated jobs and investment. There is n o reason the necessary decisions to facil itate that wider growth
cannot be taken nowboth Eurostar and its potential competitors are as king for this. Eurostar calls f or swift
action taken in parallel with business and oper ational planning to deliver expanded infr astructure capacity
beyond TMI.
1.7 It is an error for the ORR to view the broad issue of international passenger rail market growth and
development as a dilemma about which operator gets what spare capacity can be found at TMI today. T hat
cannot, by any measure, be considered the approach best calculated to furt her the ORR’s duties under s.4.
It will deprive the UK and railway users of the environmental, economic and soci al benefits that are there to
be grasped.
1.8 In France and elsewhere in cont inental Europe there is also increas ing, sustained demand for high-speed
passenger rail travel. Like in the UK, that would be potentially constr ained by available depot capac ity, but
public and private sector stakeholders have not stood still on that issue. The ORR and G overnment will no
doubt be aware of the plans of the l ikes of Velvet (previously named Prox ima Rail) in France to launch new
high-speed services with new ro lling stock in 2028, but as the first us er of a purpose-built new ma intenance
depot, Marcheprime, which is being built an d will be operated by a private concessionaire, Liséa. Similar
avenues for c omplementary development of infrastru cture alongside new services could be exp lored and
facilitated in the UK.
1.9 Eurostar calls for all involved and all stakeholders to look beyond the par ameters of these s.17 processes to
adopt and encourage a similarly proact ive strategy to facilitate the ability of operators to service the demand
3
for international passenger rail travel from a U K base and to secure the associated social, environmental and
economic benefits for the UK. At present, despite the narrow parameters of the s .17 processes, it is evident
that applicants and stakeholders have asp irations that are irreconcilable with c urrent practical and
operational realities.
1.10 If the UK can deliver new depot ca pacity, it can capitalise on the furt her significant benefits of:
(a) economic growth;
(b) industrial development;
(c) creation of highly-skilled jobs;
(d) making the UK a hub for the maintenance of high-speed trains o n a grand scale (e.g. utilising
synergies with TMI and the HS2 depot i n Calvert); and
(e) strengthening the UK’s ties to cont inental Europe.
1.11 Ready-made opportunities for major infrastructure investment s where there are already cus tomers eager to
use it in the long-term to meet growing mar ket demand are rare opportu nities to be seized. A new d epot
could be designed from the outset for multi-occupancy use and otherwise tailored to the needs of thos e who
want to use it. If things move at pace, i t will deliver far greater benefits t o users than a new entrant to TMI
ever could, if synchronised with anticipated del ivery of new rolling stock. Eurostar believes such an approach
is cleaner and likely to prove as q uick to deliver as the complexities of trying to adapt existing infrastruc ture
whilst this continues in daily operat ion.
1.12 This investment outlook and th e opportunities for investment identified mirror many of the pr inciples of the
ORR’s Rail Network Investment Framework for the mainline net work and the ORR’s recent Par t 1 “Deep
Dive” review of that framework in J une 2025 (following a request fro m the Chancellor of the Exchequ er in
March 2025). That “Deep Dive” r eview identified pent up dema nd in the UK to invest in ra il infrastructure
given enough certainty and the ex istence of ready business cases to support investment. Th is opportunity
plainly now exists on the international c orridor. This is especially the case now the UK Government has taken
the major and positive step of ent ering into inter-governmental agree ments with France, Switzerland and
Germany to facilitate internationa l rail development across the Channel and with multipl e parties now making
the case for rail services and rolling stoc k procurements. We urge the ORR an d the Government to look
beyond s.17 and apply the lessons of i ts own review.
1.13 Notwithstanding Eurostar’s ov erarching position on the opport unities for growth of the intern ational
passenger rail market, the rema inder of this response focuses only on matters within the s trict scope of the
ORR’s remit under s.17 and of these s .17 processes.

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