Eurostar’s further written representations
| Date | 17 December 2024 |
| Section | Depot 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
6thFloor Kings Place, 90 York Way, LondonN1 9AGVAT Registration No. GB 991 2920 01
Office of Rail and Road
25 Cabot Square
London E14 4QZ
By email: StationsandDepots@orr.gov.uk
17 December2024
Dear Office of Rail and Road
Application by VTE Holdings Limited (VTE) for Directions Under Section 17 of the Railways Act 1993
1 Eurostar refers to Office of Rail and Road’s (ORR) letter dated 5 December 2024 in relation to VTE’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 13 November2024 containing
Eurostar’s initial written representations in respect of VTE’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 VTE’s updated applicated form, which ORR provided to Eurostar enclosed with its
letter of 5 December. Eurostar stands by and maintains its position in relation to VTE’s original
application form, as set out in its letter of 13 November, which, except insofar as expressly stated in this
letter, remains apposite in its entirety notwithstanding the small amount of additional material that VTE
has since provided in its updated application form.
3 Eurostar has writtenseparatelytodayin relation to certain points in ORR’s covering letter of 5 December
and does not, therefore, otherwise address those points in this letter.
Overview
4 Even after being given the opportunity to provide further information, clarifications or representations,
VTE’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.
5 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 VTE back to the process for
considering access to TMI in Eurostar’sService Facility Descriptionfor TMI (the Access Process) for
further constructive engagement between the parties.
6 Considerable progress can be made through the Access Process, which iswholly rooted in the terms
and requirements ofthe Railways (Access, Management andLicensing of Railway Undertakings)
Regulations 2016.
7 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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