Letter from VTE Holdings Limited
| Date | 17 January 2025 |
| Section | Depot access applications and decisions |
VTE Ho ldings Limited Regis tered in England & Wale s No. 15124108
Whitfi eld Stud ios, 50 a Charlo tte Str eet, Lon don, Uni ted Kin gdom, W 1T 2NS
Victoria Procter
Executive, Access & Licencing
Office of Rail and Road
25 Cabot Square
London
E14 4QZ
17 January 2025
BY EMAIL ONLY
Dear Victoria
VTE HOLDINGS LIMITED’S APPLICATION FOR DIRECTIONS UNDER SECTION 17 OF
THE RAILWAYS ACT 1993
VTE Holdings refers to Office of Rail and Road’s (ORR) letter dated 5th December 2024 in
relation to the above and Eurostar’s letters dated 13thNovember 2024 and 17th December
2024 in relation to their initial representations regarding our application.
VTE Holdings is grateful for the opportunity to make these representations. As an initial
observation, Eurostar’s responses do seem to mirror a remark by ORR’s CEO who was
reported in the press as stating that Eurostar “…has some vested interest in making the
process complicated”. Similarly, in our view, the responses illustrate that “Eurostar are
protecting their business, which is to be expected”just as Getlink’s CEO remarked to the
media. Notably, Getlink’s CEO was alsoreported as saying regulations were “clear” that the
depot [Temple Mills] was part of an “open access” network that should be open to other
companies.
VTE Holdings believes that competition on this vital link to Europe is firmly in the public
interest and essential to promote sustainable change in travel habits, giving customers
choice and driving excellent customer experience and value for money. We would note that
after 30 years of operation, Eurostar still only operates one significant regular new route (to
Amsterdam) and only now that competition is on the horizon is Eurostar discussing new
opportunities (but simultaneously noting that capacity at stations and depots is constrained).
Only by having a strong and agile competitor with a recognised and trusted brand for looking
after its customers will there be a change in this dynamic – and so it is now time for the route
to reach its potential.
VTE Holdings would like to note that the process set out in Eurostar’s Service Facility
Description for gaining access to the depot seems, on the face of it, not to have been
followed by Eurostar with respect to the introduction of the Class 374 train. Section 5 first
bullet point suggests that “To access TMI…relevant licence and safety certification to
operate services on the railway network” must be in place. When the first train was delivered
to Temple Mills on 30th January 2014 the Class 374 was not authorised to operate on HS1
which came some considerable time later.
The two letters of representations from Eurostar can be distilled into a number of themes.
These themes and our comments thereon are:
1.Representations on the suitability of ORR processes, ORR's jurisdiction and how ORR
should proceed with the various S17 applications
ORR will, of course, make its own determination of these issues. We would note,
however, that we do believe ORR has the relevant powers and oversight of the depot,
and at a meeting held on 18th June 2024 these powers were made clear, which included
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