Eurostar's further written representations
| Date | 21 November 2024 |
| Section | Depot access applications and decisions |
Eurostar International Ltd
6
th
Floor Kings Place
90 York Way
London N1 9AG
eurostar.com
Eurostar International Ltd registered in England and Wales No. 2462001
6
th
Floor Kings Place, 90 York Way, London N1 9AG VAT Registration No. GB 991 2920 01
Office of Rail and Road
25 Cabot Square
London E14 4QZ
By email: StationsandDepots@orr.gov.uk
21 November 2024
Dear Office of Rail and Road
Application by Evolyn for Directions Under Section 17 of the Railways Act 1993
1 Eurostar refers to Office of Rail and Road’s (ORR) letter dated 8 November 2024 in relation to Evolyn’s
Application to ORR for a Depot Access Contract relating to Temple Mills International Depot (TMI) under
section 17 of the Railways Act 1993 (the Act) and Eurostar’s letter dated 25 September 2024 containing
Eurostar’s initial written representations in respect of Evolyn’s original application form
2 Eurostar sets out in this letter its further initial written representations solely in respect of the new
material contained in Evolyn’s updated application form. Eurostar stands by and maintains its position
in relation to Evolyn’s original application form, as set out in its letter of 25 September, which remains
apposite in its entirety notwithstanding the small amount of additional material that Evolyn has since
provided in its updated application form.
Overview
3 Even after being given the opportunity to provide further information, clarifications or representations,
Evolyn’s application remains:
(a) strikingly lacking in detail;
(b) entirely unsupported by evidence;
(c) significantly premature and reflective of an under-developed service proposition; and
(d) not a valid s17 application.
4 Eurostar’s primary position remains that ORR should not take forward its consultation process but
should remit the initial decision about the depot access contract sought by Evolyn back to the process
for considering access to TMI in Eurostar’s Service Facility Description for TMI (the Access Process)
for further constructive engagement between the parties.
5 Considerable progress can be made through the Access Process, which is wholly rooted in the terms
and requirements of the Railways (Access, Management and Licensing of Railway Undertakings)
Regulations 2016. It is apparent to Eurostar (as discussed below) from Evolyn’s updated application
form that, in fact, Evolyn agrees with that.
6 Eurostar considers that ORR should not make a direction pursuant to s17 and still is not in a position in
practice or under the Act to do so, including for the reasons set out in this letter and Eurostar’s previous
correspondence.
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