Memorandum submitted by Postwatch Wales
POST OFFICE CLOSURES IN WALES
The information regarding the number of closures, objections etc needs to be seen in context. Each closure notification will have been dealt with by one of my committee members often by way of a site visit and liaison with the local community. Where it was apparent that (1) Post Office Ltd were doing their best to secure alternative facilities in the locality or (2) where there was local acceptance of the situation or (3) where protocols had been followed to the letter and clearly a determined but unsuccessful effort made to avoid closure or relocate albeit with amended hours; formal objection was not seen as a valid response in such circumstances.
Committee members are encouraged to discuss closure issues with Post Office Ltd and to make suggestions about improved viability and other issues such as access. I also think that you need to be aware of the fact that there have been occasions when I have written to Post Office Ltd congratulating them for their efforts in maintaining services in an area where closure was a possibility.
17 April 2002
POST OFFICE CLOSURES IN WALES AND THE WORK OF CONSIGNIA/POST OFFICE LTD
Since January 2001, Postwatch Wales has been involved in consultations regarding 41 post office closures in Wales. Postwatch Wales objected to closures in seven of these cases, resulting in one case where our involvement had a positive influence on the outcome.
Postwatch Wales is naturally very concerned about the adverse social consequences of any closures but recognises the difficulty of maintaining what are sometimes non-viable private businesses. Lack of customer loyalty is sometimes an issue with "anecdotal evidence" showing that in some circumstances rural offices are bypassed in order to use urban shopping facilities.
As a consumer body the interests of the consumer are paramount and problems need to be addressed honestly and objectively free of bias and dogma. Consignia have improved their performance in respect of the network for example through using Rural Transfer Advisers but there is a lot more they can do through encouragement, innovation and investment. They also need to make explicit that closure is a last resort after everything else has failed. In respect of the "social service" which post offices provide in the rural areas and indeed in the deprived urban areas the question of "who picks up the bill" cannot be avoided. Consignia operates in a commercial environment and as has been said earlier sub-post offices are private businesses; is it therefore fair or reasonable for them to bear the social costs or should financial assistance come from elsewhere? In fact a precedent has already been established with local authorities able to abate council tax and with central government making some money, at least, available for both the rural and the urban networks. (Notethe Select Committee should be aware that money to assist with the urban deprived network under s 103 of the Postal Services Act has been ringfenced in England for this specific purpose but that is not the case in Wales and Postwatch has taken up the issues with the Assembly as the money was transferred to the devolved administrations.)
In our view the best case scenario is for Consignia to effectively and proactively manage the network with the express intention of avoiding closures but with some element of systematic subsidy from either local or central government or both to support the "social service" dimension referred to above.
1. POST OFFICE CLOSURES PROCEDURES
(a) Notification period
The Code of Practice on Post Office branch relocation, closure and conversion agreed between Consignia plc and Postwatch (the Consumer Council for Postal Services)November 2001, states that the Territory General Manager must give Postwatch Wales at least one month's notice when closures are proposed. This requirement is usually adhered to, but this is not always the case.
(b) Evidence Provided by Consignia/Post Office Ltd
The Territory General Manager must provide evidence to show that he/she has considered a number of factors when proposing a post office closure. The distance customers will have to travel to other post office branches and the trading hours of those branches are sometimes mentioned in the letters of notification sent by Consignia to Postwatch.
The convenience of other branches as regards proximity to parking, public transport, pedestrian access, whether the terrain is hilly or flat etc is usually addressed in the notification letters.
Issues that are never mentioned in the notification letters that would benefit the consumer include:
facilities and access for the disabled at other branches;
the ability of other branches to absorb the work without detriment to service;
where a reduction in service will result, proximity of the nearest branch offering the service concerned;
effect on mailwork; and
any known plans to develop the area.
(c) Announcements of Closures
The Code of Practice requires the Territory General Manager to inform Postwatch Wales of any final decision as regards a closure before it is made public. This sometimes happens.
(d) Quality of Feedback
Post Office Ltd does not give answers in response to representations made by Postwatch Wales and other bodies as to whether their representations have any bearing on the outcome of a closure. Postwatch Wales is not satisfied with this state of affairs.
(e) Information Exchange
Postwatch Wales feels that the consultation process seems to delay the inevitable ie closures. Consultation does take place, but it is very difficult indeed for us to influence the final decision.
We would like Post Office Ltd to reply in writing to all correspondence with detailed response to suggestions of recommendations made by Postwatch Wales, or on Postwatch Wales' behalf.
Postwatch Wales feels there should be a requirement to give public notice of closure once the consultation process has ended in a negative result.
2. THE CONSULTATION PROCESS
(a) The Consultation Period
Postwatch Wales feels that the current consultation period, as defined by the Code of Practice is adequate, provided that Post Office Ltd acts promptly. Postwatch Wales also feels that in order to allow it to prepare an adequate response to a proposed closure, the clock should start on the day Postwatch Wales is notified, as opposed to the date of public consultation.
(b) Opposition to Closures
Committee members, (of which Postwatch Wales has 10, representing different areas of Wales) assisted by their focus groups, liaise with a wide spectrum of individuals and groups when investigating closures. Community councils, Citizens' Advice Bureaux, local authorities, local businesses along with any individuals who may be affected are consulted. Whenever possible, representations are made with a view to closure being avoided by producing evidence of need, etc, and sometimes making suggestions about increased viability.
Local MPs and AMs do become involved in closures. They are notified in accordance with the Code and will sometimes make their views known to Postwatch Wales as well as directly to Consignia.
Postwatch Wales feels that as the consumer watchdog for postal services, it should play a leading role in co-ordinating responses from MPs, AMs and other organisations. This would help convey a united front and cohesive front and avoid fragmentation.
3. PREVENTING CLOSURES
Postwatch Wales has noted that the vast majority of closures involve small sub-offices that cease to be viable for a number of reasons. In such circumstances and without the ability to give financial assistance, Postwatch Wales finds it difficult to envisage a suitable course of action. Comment has been made previously about the importance of customer loyalty.
Postwatch Wales feels it should be able to make a real impact on closure decisions, but in the absence of financial inducements and/or legislative powers, its actions are severely restricted.
Postwatch Wales has identified the following factors as a hindrance to our opposition to post office closures:
the absence of financial subsidies and incentives;
depopulation in rural areas that affects other services and institutions such as transport, shops, schools etc;
lack of customer loyalty which often means that people living in rural areas do their shopping in the nearest town and use post office facilities whilst there;
insufficient support to sub-postmasters, including lack of business advice, investment monies and general support; and
public money subsidy to support businesses which would not otherwise be viable, but which are vital to the local community.
16 April 2002