VTE Holdings Limited response – comments on submissions from Eurostar and interested persons/parties (Redacted)

SectionDepot access applications and decisions
VTE Holdings Limited Registered in England & Wales No. 15124108
Whiield Studios, 50a Charloe Street, London, United Kingdom, W1T 2NS
1
BY EMAIL ONLY
Ian Biggar
Access Policy Advisor
Oce of Rail and Road
25 Cabot Square
London
E14 4QZ
4 September 2025
Dear Mr. Biggar,
VTE HOLDINGS LIMITED’S (“VTE”) APPLICATION FOR DIRECTIONS UNDER SECTION 17 OF THE
RAILWAYS ACT 1993 FOR ACCESS TO TEMPLE MILLS INTERNATIONAL DEPOT (“TMI”)
Thank you for your leers of 15 August – this leer replies to the rst of those, which invited VTE to
comment on submissions by Eurostar, the Department for Transport (“DfT”) and Kent County Council
(“KCC”) by 4 September.
VTE notes the subsequent two-week extension to that deadline, as communicated in the ORR’s leer
of 29 August, and VTE’s own wrien objecon sent on the same day. VTE considers it of paramount
importance that the overall meline for ORR’s Secon 17 process is not allowed to slip, and that a
decision is sll issued by 31 October. Therefore, notwithstanding the extension, VTE has chosen to
submit this leer in line with the original deadline of 4 September to assist the ORR as much as it can
in remaining on track with its proposed meline. VTE trusts that this leer, together with its
comprehensive submission of 18 July, will support the ORR in achieving that outcome. More detail on
VTE’s posion on this maer is provided in Secon 1 of this leer.
The primary focus of this leer, covered in Secons 2, 3 and 4, is to set out VTE’s comments on those
submissions from Eurostar, the DfT and KCC, as invited by the ORR.
VTE notes that the ORR leaves it to the discreon of each applicant if they wish to comment on other
applicants’ submissions, and that this is not a formal part of the ORR’s assessment process. In this light,
VTE has included high-level observaons on other applicants’ submissions within Secon 5.
1. VTE’s posion on the deadline extension
1.1 VTE is both surprised and disappointed by the decision to extend the deadline for this
submission, parcularly given the ORR’s own recognion that such an extension may impact its
ability to reach a nal decision by 31 October.
1.2 Unlike the two prior deadline extensions granted in June, which were disappoinng but
somewhat understandable given the volume and complexity of material required from
applicants at that stage, the nature of this submission is signicantly less onerous. It is dicult
to see why three weeks would not have been sucient me for all pares to comment on the
relevant materials. In this context, the decision to grant a two-week extension also feels
disproporonate. The extensions granted in June were limited to one week each despite that
submission requiring signicantly more substanve input.

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