Heathrow Express Operating Company Limited – further representations – 26 November 2021
| Date | 26 November 2021 |
| Section | Appeals under The Access and Management Regulations |
Heathrow Express Operating Company Limited. Registered in England and W ales co. no. 3145133.
Registered office: The Compass Centre, Nelson Road, Hounslow, Middlesex, TW6 2GW
Classification: Confidential
Classification: Confidential
Sophie Chapman
Business Lead
Heathrow Express Operating Company Limited
The Compass Centre, Nelson Road
Hounslow, Middlesex
TW6 2GW
BY EMAIL AND COURIER
Office of Rail and Road (ORR)
25 Cabot Square
London
E14 4QZ
contact.cct@orr.gov.uk; james.osborn@orr.gov.uk
MOST URGENT
26 November 2021
Dear Sirs / Madams
APPEAL UNDER PART M OF THE HAL NETWORK CODE BY HEATHROW EXPRESS
OPERATING COM PANY ( “HEOC”) IN RESPECT OF DISPUTE REFERENCE
HAL/TTP003 DATED 27 OCTOBER 2021
We refer to your letter dated 19 November 2021, requesting written representations as to the
below, each of which is addressed in this letter as follows:
“(i) ORR’s legal power to act as an appeal body in this dispute and under which
statutory provision(s) (See Paragraph 1 below)
(ii) Which party/parties have a right to appeal to ORR and under which statutory and/or
contractual provisions, including:
a. The inter-relationship between a party’s right to appeal under the contractual
provisions of the HAL Network Code and any statutory right to appeal
b. The inter-relationship between Parts D and M of the HAL Network Code with
respect to a party’s right to appeal.”
(See Paragraph 2 - 4 below)
We also refer to the representations raised by MTR Corporation (Crossrail) Limited (“MTR”) in
their letter of 12 November 2021 to the Office of Rail and Road (“ORR”) (“MTR’s
Representations”). We do not respond exhaustively to MTR’s Representations herein, and
HEOC should not be taken, by the ORR, to accept any point within MTR’s Representations
that is not addressed in this letter, which focusses instead on providing the representations
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