Memorandum submitted by the National Consumer
Council (POS 30)
INTRODUCTION
The National Consumer Council (NCC) is an independent
consumer expert, championing the consumer interest to bring about
change for the benefit of all consumers. We do this by working
with people and organisations that can make change happen—governments,
regulators, business and those who speak on behalf of consumers.
In October 2008, NCC will merge with Postwatch
and energywatch to form a new consumer advocacy body that will
operate on a statutory footing with enhanced powers. While Postwatch
is examining this round of post office closures, future changes
to the network will be charged to the new organisation as stipulated
in the Consumers, Estate Agents and Redress Act 2007. The merger
will enable the new body to examine postal services in the wider
context of access to essential services, especially in deprived
and remote areas.
In September 2007 NCC published a report Post
Office Closures 2002 to 2006: lessons for 2007 to 2009 in
conjunction with Dr Foster research consultancy. The findings
from that report, which have been used as a basis for this memorandum,
were used by NCC to urge Post Office Ltd to learn the lessons
of previous closures to ensure that communities with the greatest
need for Post Office services—whether in urban or rural
areas—are targeted for protection on social grounds in future.
The findings were also intended to assist Postwatch (and its successor
organisation) and local stakeholders in promoting the consumer
interest.
A full copy of the report can be viewed here:
http://www.ncc.org.uk/nccpdf/poldocs/NCC172rr_post_office_closures.pdf
THE EXPERIENCE
OF THE
LOCAL CONSULTATION
PROCESS SO
FAR
In our joint report with Dr Foster research
consultancy, Post Office closures 2002-06: Lessons for 2007 to
2009, NCC set out a number of recommendations that should be taken
into account as part of the local area consultation process. These
included:
1. The demographics which should be used
to help identify social need for Post Office services;
2. The need for sensitive and a responsive
consultation process to engage communities most in need of post
office services, but lease likely to state their case for them.
3. To be transparent with plans for local
consultations to allow communities time to prepare; and
4. Establishing a baseline of service provision
to take into account the effect of past closure programmes that
were not based on consumer need;
IDENTIFYING SOCIAL
NEED AND
SENSITIVITY OF
LOCAL CONSULTATION
Postwatch has been the primary consumer advocate
in local area plan consultations. Therefore colleagues there will
be able to give a more detailed picture of how the process has
been conducted to date. Issue of particular importance include
identifying social need and efforts to engage hard to reach groups
who are often most in need of post office services.
Our report found:
— The demographics of the communities
hard hit by the 2002-06 closures that translate into high social
need and dependency on Post Office services are:
— poor physical mobility—because
of age, no access to a car, infrequent public transport;
— high dependency on state benefits,
for example, unemployed, sick, lone parents;
— living in social housing in poorer
areas with low Post Office provision (per household);
— suffering social and financial exclusion—Post
Office Account holders and others with low access to mainstream
credit, banking and other key services.
— People who most rely on Post Office
services, such as single parents or elderly people, are often
less well-equipped to build and articulate the social case for
retaining their local Post Office service. An effective and sensitive
consultation process would need to engage these service users
and make it easy for them to give their views.
Elements of success and scope for learning from
Post Office Limited's work in these areas have the potential to
create improvements in the remaining of local consultations.
CONSUMER ADVOCACY
AND ENGAGEMENT
WITH POST
OFFICE LTD
NCC welcomes what we understand to be effective
co-operation between Postwatch and Post Office Ltd, both before
and after the publication of local area plans. This is particularly
important given the limited six week period for local consultation.
It is worth noting that the positive impact of Postwatch's consumer
advocacy before local area plans are published, and the work that
Post Office Ltd have done with them, may not be apparent to many
stakeholders.
We understand that apart from Postwatch consumer
representation in some areas has been limited. There is the need
for greater engagement from local representatives and decision-makers,
particularly in areas of high social need.
TRANSPARENCY
NCC also welcomes Post Office Limited's publication
of the timetable for local area consultations, which provides
local stakeholders with the opportunity to prepare their case.
BASELINE OF
SERVICE PROVISION
Our report concluded that Post Office Ltd should
have taken a baseline of provision and cross-matched it with consumer
need before the start of this closure programme. Historically,
closures have not been based on consumer need but rather sub-postmaster
preference, and this first strategic reshaping looking at need
should not have ignored this. The Government's rule that one place
would not be more disadvantaged than another by closures failed
to take account of the mistakes of the past and has meant that
the current closure programme could not address previous low provision.
This was a missed opportunity.
THE ROLE
OF POSTWATCH
IN THE
CURRENT PROGRAMME
AND IN
THE FUTURE
It is critically important that there is effective
consumer involvement in issues surrounding the future of the post
office network. We know from many years of research that post
offices provide essential services in many communities, not least
to vulnerable people. Communities must be able—and where
necessary assisted—to engage in discussions about the future
of these important local resources.
Postwatch's role in this process to date has
been important, and clearly this must continue until the end of
the current closure programme. We share its view that the leadership
of the new consumer organisation should work with Postwatch and
BERR to ensure that the right resources remain in place to perform
this function, against the backdrop of the transition to the new
body.
NCC, like Postwatch, will cease to exist at
the end of September 2008. Looking to the future, it is a matter
for the Board and leadership of the new organisation to decide
the nature of its involvement in issues around post offices.
We consider that one of the merits of the creation
of the new organisation is that it will have the ability to direct
resources to where the most substantial consumer detriment lies;
another is that it will be able to consider issues from a broader
perspective.
In the case of the Post Office network, any
future reduction in the network must inevitably raise issues of
real consumer detriment, given the range of essential services
that it provides.
Previous approaches to Post Office network coverage
have been one dimensional. Any further reduction will need to
be considered in the wider context of social exclusion and access
to services—particularly in outer suburbs and rural areas.
Post Office coverage needs, therefore, to be
seen as a key part of wider social urban and rural policies. The
new consumer organisation should be in a strong position to take
into account this wider perspective. We would expect the new organisation
to consider the role of the post office network in the context
of issues such as financial inclusion and access to payment systems,
particularly focusing on cross-cutting issues around the needs
of vulnerable consumers.
28 January 2008
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