Gemini Trains response – comments on submissions from Eurostar and interested persons/parties
| Section | Depot access applications and decisions |
Gemini TOC Ltd Registered in England
3rd oor, Great Titcheld House Company number 14783093
14-18 Great Titcheld Street
London, W1W 8BD, UK
Ian Biggar
Access Policy Advisor
Oice of Rail and Road
25 Cabot Square,
London,
E14 4QZ
18 September 2025
Dear Ian
Comments by Gemini Trains on submissions by Eurostar, DfT and Kent County Council
Gemini Trains welcomes the opportunity to provide the ORR with its response to the submissions
made by Eurostar and by other S17 applicants. It also welcomes the opportunity to provide
comments on the submissions from both DfT and KCC.
In summary, the submissions from each of these participants provides compelling evidence that
the sector urgently needs competition and, rather than such competition providing simply a
copycat service akin to the incumbent, it is crucial that the focus should be on growing the
market, making the most of existing national infrastructure and providing a high-quality
complementary service.
Gemini’s core objective is to make international rail travel more accessible to more people by
providing high quality, value for money services, serving stations not currently part of the
incumbent’s network. Gemini will therefore be oering a dierentiated service under the Uber
brand.
Moreover, Gemini will bring additional value to the sector by opening a new international
passenger facility at Stratford International and reinstating services at Ebbseet. This will provide
instant resilience and redundancy on what is a crucial economic link between the UK and the EU.
The ORR should take this into account when awarding depot capacity – a granting of depot access
to an operator that simply mirrors the existing service not only adds risk to the sector, but it also
threatens to continue to constrain growth – as has been the case for the past 30 years of single
operator, monopoly operation.
Gemini’s positioning as a complementary provider also makes greater use of existing UK
taxpayer-funded infrastructure and assets.
- Temple Mills Maintenance Depot (TMI) – According to the KCC response £400m1 was spent
by the UK government to develop the international maintenance depot. Eurostar is naturally
the only current user of the facility, but Gemini’s request for capacity at TMI dovetails perfectly
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