Memorandum submitted by Postwatch (POS
3)
The first part of this report gives an overview
of the Post Office closure programme so far. In particular it
looks at those area plans that, by early January, had passed through
the pre-consultation and public consultation stages. The latter
part of the report outlines current areas of concern.
Many of the programme's processes are either
operating satisfactorily or improving; and most represent a clear
improvement on the processes during the previous closure programme.
But as the report makes clear, there is a clear need for swift
improvement in some areas, particularly those relating to Post
Office Ltd's (POL) communication with its customers, both about
the processes and the programme as a whole and its aims. In general,
POL is stronger on the mechanics of the process than on issues
of communication.
1. REVIEW OF
FIRST SIX
AREA PLANS
1.1 By 9 January, POL had started 13 public
consultations. Six of these—Kent; East Midlands; East Yorkshire
with Bassetlaw and North Lincolnshire; East Essex and Suffolk;
Glasgow, Central Scotland and Argyll and Bute; and Hampshire and
the Isle of Wight—had completed the consultation process.
This section will focus on Postwatch's experiences and activities
during these completed area plan consultations.
STATISTICAL OVERVIEW
1.2 These are the key points from the first
six area plans that entered public consultation:
— They involved 400 closure proposals
in 99 parliamentary constituencies.
— Of these, POL proposed to replace
63 closing branches with outreach services, thereby resulting
in a proposed total net loss of 337 post offices.
— Following Postwatch feedback, POL
withdrew 33 proposals during the pre-consultation period.
— Following public consultations, POL
withdrew 16 proposals from the closure programme and changed one
proposed closure to a proposed outreach.
— For each proposal withdrawn, POL
proposed a replacement closure within the same area plan. Substitute
proposals are also subject to six weeks' consultation.
— Postwatch agrees with POL's assertion
that the proposed remaining network would continue to meet the
access criteria set by the Government.
1.3 In our first progress report to the
Business, Enterprise and Regulatory Reform Committee (the Committee),
Postwatch described the different stages of the programme and
Postwatch's activities during each stage. A diagram outlining
the process is attached as Appendix One. The following
sections outline these different activities for the first area
plans.
SCRUTINY
1.4 Postwatch's principal activity during
pre-consultation is scrutinising POL's proposals. This work also
continues throughout public consultation. For the first six area
plans, this has involved both fieldwork, through 331 visits to
affected post offices, and desk analysis.
1.5 Our Geographic Information System (GIS)
helps inform our analysis of POL's plans. This tool enables us
to review independently POL's adherence (or otherwise) to the
access criteria set by the Government, and to plot the proposed
closures against relevant factors such as local demographics.
Examples of GIS maps are attached at Appendix Two.
1.6 Attached at Appendix Three is
our scrutiny checklist, which sets out the factors Postwatch takes
into account when considering whether POL has given sufficient
consideration to local community needs.
1.7 For each of the first six area plans,
POL stated that the proposed remaining network would meet the
distance access criteria set by the Government. Postwatch's independent
scrutiny confirmed this. Given this, our concerns on proposals
in these area plans focused on more qualitative issues, for instance
whether POL had demonstrably taken account of relevant local factors.
Of the 49 proposals withdrawn either in pre-consultation or consultation,
the key relevant local factors involved public transport, impact
closure would have on the local economy, effect on elderly customers,
distance to nearest alternative branch, and the ability of alternative
branches to cope with increased customer numbers were closures
to go ahead.
COMMUNICATIONS
Awareness-raising
1.8 During the six-week public consultation
period, Postwatch contacts stakeholders and uses the media to
raise awareness of the proposals and give our initial views. In
total, during the first six public consultations, Postwatch contacted
1,063 local stakeholders.
1.9 We also attend public forums, local
authority scrutiny committees, and meetings with MPs. For the
first six area plan consultations, we attended numerous meetings,
as well as organising a series of joint events with POL for stakeholders
in advance of the closure programme.
Research
1.10 Postwatch commissioned Ipsos MORI to
undertake research into customers' awareness of, and participation
in, closure programme consultations. Fieldwork was undertaken
by telephone interview in late November and early December, and
involved 602 interviews with customers in five area plans in public
consultation. The main findings were:
— 90% of respondents stated they had
used a post office within the past month.
— 64% of respondents stated they were
aware of closures, but only 18% said they were aware of a consultation
taking place.
— 42% stated they intended to participate
in the consultation; 3% stated they had done so.
— The media was the most common way
in which people had heard about the planned closures and consultation
process.
— Of those who stated they intended
to participate in a consultation, the most common routes for doing
so were to sign a petition or contact their local MP or councillor.
Contacting POL was third.
— One in five respondents who said
they would not participate in the consultation stated this was
because they either were not aware of the consultation or felt
it was too difficult to take part.
— 88% of those who had responded to
the consultation stated they found it easy or very easy to do
so.
1.11 We have shared the results with POL
and will meet in mid-January to discuss ways forward. Postwatch
is considering further research in this area to understand whether
public knowledge and levels of participation increase as the programme
continues.
POL's communications
1.12 POL's communications are certainly
better than they were in the previous closure programme. However,
our research illustrates the need for them to be better still.
It is particularly important that POL works harder to gain coverage
in the local media throughout consultations.
1.13 It should be a matter of great concern
to POL that less than one in five respondents is aware of a local
consultation. While it is welcome that POL issues press releases
at the start and end of consultations, more activity during the
six-week period is needed to drive up awareness and understanding.
This should also help increase the likelihood of customers responding
directly to POL. While it is of course welcome that customers
inform MPs and councillors of their views, it is important that
submissions are also made directly to POL.
1.14 It is also important that customers
understand that the decision to close 2,500 post offices comes
from the Government, not from POL, and that POL's role is to determine
the location of these closures. One consequence of this is that
when one proposal is withdrawn from the programme, a substitute
proposal is likely to be introduced.
1.15 POL's communication activities on this
point must be clear and direct. Postwatch is therefore particularly
disappointed that POL has not yet issued any press releases at
the start of consultations for substitute post offices. Failing
to do so may lead to increased customer confusion. Furthermore,
it is unfair and inconsistent—POL's approach to substitute
proposals should be no different from their approach to an area
plan's initial consultation. Postwatch has requested that POL
addresses this as a matter of urgency.
1.16 We welcome POL's proposal and decision
documents. Both provide useful background to the programme, a
narrative on the local changes, and information on individual
branches within the area plan. Furthermore, the decision document
is useful in setting out the main points of customer concern for
proposed closures, and POL's response. POL's documents are available
on its website
www.postoffice.co.uk/networkchange, and can also
be provided in paper format on request.
1.17 There have, however, been problems
with POL failing to update its website—for example, consultations
continuing to be listed as open when they have finished. We have
requested that POL rectify this problem. Similarly, we have requested
that POL include its press releases on these webpages (they are
currently located at www.royalmailgroup.com).
MONITORING
1.18 In accordance with the role which the
Government has set out for Postwatch, we monitor POL's activities
to ensure that it both consults the appropriate individuals and
organisations, and carries out the consultation process properly.
1.19 During the first public consultations,
we undertook 138 checks to determine whether POL was sending out
the necessary information in a timely fashion. We found:
— 82 stakeholders stated they had received
POL's information.
— 13 stakeholders stated they had not
received POL's information.
— 43 did not know whether they had
received the data.
1.20 It undermines the consultation process
if local stakeholders do not receive the necessary information.
When stakeholders tell us they have not received POL's information,
we let them know where they can locate this and also offer to
request POL to send the documents to them. We continue to communicate
our findings to POL, to ensure that stakeholders are receiving
the information they require.
Summary of responses
1.21 A crucial part of monitoring the consultation
process is ensuring POL has demonstrably taken account of feedback
they have received. To that end, both during and at the end of
public consultations, POL provides Postwatch with a summary of
responses received from stakeholders and customers.
1.22 The timeliness, format and content
of the summary of responses have been problematic, with variations
in when Postwatch has received these documents, their presentation,
and the amount of meaningful data they contain. This has meant
that at times it has been difficult to carry out our role of independent
scrutiny. We have pressed POL both for improved data on both these
early public consultations and for a more robust process for future
plans. POL has taken steps to address these early difficulties
and we believe an improved process and product are now in place.
2. OUTREACH
2.1 In our first progress report to the
Committee, we stated our concern about POL's failure to set out
details of proposed outreaches during public consultations. None
of the 63 proposed outreach services in the first six public consultations
contained proposed operational details. Instead, customers in
the affected areas were informed that an outreach service was
proposed, but were given little or no detail on what this proposed
service would involve—for example operating hours, location,
service type and range of services.
2.2 This is unsatisfactory, as consultations
are not on the principle of closure, but on what proposed changes
mean for a particular area. Customers need to be able to respond
to specific proposals.
2.3 We therefore welcome POL's efforts to
address this. POL has agreed that from January 2008 all outreach
proposals entering public consultation will include proposed operational
details. Postwatch will continue to monitor this. Additionally,
we welcome POL's commitment that for those outreach proposals
that have already moved through public consultation and where
POL continues to be unable to provide Postwatch with operational
service details at our post-consultation review discussion, POL
will undertake a further six-week local consultation on the proposed
outreach service, once details have been worked up.
Minimum service standards
2.4 As also mentioned in our first progress
report, Postwatch is disappointed that the Government chose not
to specify minimum opening hours or services that outreaches should
provide. We accept that POL should be able to act flexibly. However,
outreaches are needed in some locations to ensure that POL meets
the distance access criteria set by the Government. In such cases,
we believe that POL should be required by the Government both
to operate these services for a specified minimum number of hours
and to provide a specified minimum range of services. In our consultation
response, we recommended that outreach services should be available
for a minimum of two consecutive hours, three times per week.
2.5 We also believe it is important for
POL to ensure outreach services are regularly checked. This should
help ensure these services are tailored to meets the needs of
local communities.
3. REVIEW PROCESS
3.1 The review process is potentially a
four-stage process that deals with proposals where in Postwatch's
view POL has not given due consideration to material evidence
received during the public consultation, or where there is evidence
that a proposal does not meet the Government's policy requirements.
3.2 In the first six area plans, Postwatch
opted to review each outreach proposal that entered public consultation
without proposed operational details.
3.3 By January 2008, Postwatch had taken
two cases to the second stage of review. We opted to review the
decision to open a new post office in Otterferry, Argyll and Bute.
This opening was proposed to meet the requirement that 95% of
the population in the PA22 postcode district should be within
six miles of a post office. The review process was initiated as
we were not convinced that POL had sufficiently taken account
of local topography when it opted to open the new post office
in Otterferry, rather than elsewhere in the area.
3.4 The review process enabled us to assure
ourselves that POL had given due consideration to topographical
features in this area to feedback received during consultation.
Postwatch is now satisfied that customers will be reasonably served
by the post office network in this area.
3.5 Postwatch has also taken the proposed
closure of the post office in Kirn, Argyll and Bute to the second
review stage. This is because we felt that POL had failed to take
account of an expression of interest from a local community enterprise
to operate a post office in the area.
3.6 As a result of Postwatch's taking this
case to review, POL decided to delay the closure of this post
office for three months. This will allow the community group to
develop their proposal, with support from POL and Postwatch.
3.7 No cases have been taken beyond the
second stage of the review process.
4. SELECTION
CRITERIA
4.1 POL's rationale for selecting branches
to close is based on four criteria: size of branch (regular customer
usage), proximity to other branches, relative size (compared to
other branches in the area), and financial benefit to POL.
4.2 POL has recently agreed to give communities
information on customer usage of branches. We welcome this. However,
POL needs to do more publicly to explain the other criteria.
4.3 As we mentioned in our progress report
to the Committee, Postwatch is concerned about the long-term consequences
of the critierion relating to the financial benefit to POL.
4.4 There were instances in the early part
of the programme of POL's proposing for closure branches with
relatively high customer usage, but which it wishes to close because
of their high operational costs. It is hard to justify publicly
the closure of such post offices while lesser-used branches remain
open.
4.5 We welcome the Minister's comments to
Postwatch's Counters Advisory Group (which consists of statutory
and charity bodies, including Age Concern, ViRSA, Postcomm, and
the Local Government Association) in December 2007, that POL should
seek to be more open about the economic rationale for individual
closures within the confines of the need to respect confidentiality.
We also welcome that the Minister has spoken to POL about the
need for transparency (Hansard, 29 November 2007, column 186WH)
and we look forward to a positive outcome of this discussion.
Post-programme network
4.6 Both the Government and POL need to
take steps to build confidence in the sustainability of the post
office network once the closure programme is over. For the Government,
this should involve clear pronouncements that they are committed
to a post office network of 12,200 (including the new 500 outreach
services). This is particularly important given the recent Government
statement (HC 18 December 2007 cc1472W-1473W) that a network of
just 7,500 branches could satisfy the Government's access criteria.
The Government should also clarify the steps it will take to provide
its services through branches, and to help community-owned post
offices.
4.7 As part of its routine communication
activities, POL should assure communities that should any closures
take place following the end of the current closure programme,
they will endeavour—and expect—to put in place a local
replacement service.
5. POL CALL CENTRE
5.1 POL should take all necessary steps
to ensure that participation in local consultations is straightforward,
and that the consultation process is as inclusive as possible.
We therefore believe that POL should, as a matter of priority,
reverse its decision not to accept responses to consultations
via its call centre, except in instances where individuals are
unable to write or email. All customers should be able to submit
comments by telephone. Postwatch has written to POL on this issue.
5.2 Currently, POL provides only general
information (consultation dates, address details etc) to callers.
Postwatch undertook in-house research on POL's call centre throughout
November. 106 calls to POL call centre were undertaken, which
aimed to test POL's effectiveness in giving customers correct
contact details, as well as the ease in callers using the service.
The results were disappointing. We found:
— 56% of people stated that navigating
through POL's Interactive Voice Response system is not straightforward.
The route to speak to a call centre staff member takes three steps,
and there is not an explicit option to speak to a call handler
about post office closures.
— Various contact addresses were given
to customers. In fact, customers responding to consultations are
meant to contact POL via its freepost consultation address. It
was therefore of particular concern that on more than one occasion
POL call centre staff gave out an address that was not freepost.
— POL provided callers with three different
email addresses—two of which were valid and one that did
not work. We believe it would benefit customers if they were directed
to use one email address.
5.3 Providing correct contact information
is a fundamental communication need for a successful programme.
POL must get this right. We wrote to POL on 8 January to express
our concerns on this matter, and to request they review their
call centre processes and training as a matter of urgency.
6. CROWN OFFICES
6.1 The current crown office network consists
of 441 branches. POL has reported that crown offices, directly
managed by Post Office Ltd, lost £70 million in 2006-07.
In an effort to reduce losses and avoid closures, POL announced
its intention to franchise 70 crown offices into WHSmith stores.
By January 2008, 13 of these 70 post offices had opened, with
the remaining conversions scheduled to take effect by summer 2008.
6.2 Postwatch is scrutinising proposals
to close several sub-post offices in locations where, if the closures
go ahead, crown offices or newly converted franchised offices
will be expected to receive large numbers of additional customers
moving from closed branches. Where we have concerns, we will press
POL to make improvements, for example adding additional counter
positions. In certain cases, it may be necessary to oppose the
closure of nearby branches because of these concerns. We will
continue to monitor this situation closely in the coming months
and keep the Committee up to date.
6.3 Postwatch investigates every franchise
proposal to ensure that the quality and accessibility of post
office services will not be harmed by a change in service. We
continue to monitor existing conversions and are generally satisfied
with the quality of customer experience at these post offices.
Research undertaken for Postwatch by Ipsos MORI suggests that
the quality of service in six initial WHSmith franchises is good.
While the sample for this research was small, it supports our
in-house monitoring, which suggests customers in these post offices
receive a high standard of service.
6.4 Postwatch is also pleased that POL has
agreed to additional accessibility measures where post office
services will be located on the basement or first floor—for
example, alternative ground floor service points for customers
who may not be able to reach the first floor, and maximum call-out
times in the event of lift breakdown.
6.5 We strongly support POL's investment
in the remaining crown office network, with the aim of modernising
and refurbishing branches, and introducing new technology, including
self-service kiosks, to reduce queuing times in the busiest branches.
Research undertaken for Postwatch by Ipsos MORI found that average
queue times in crown offices are currently six minutes, underlining
the need for further investment in the crown office network.
7. POST-SEPTEMBER
ARRANGEMENTS
7.1 Postwatch will not exist after 30 September,
but the closure programme will continue beyond this (the final
public consultation finishes on 7 October, with the possibility
of the review process and/or substitute consultations after this
date). The Minister has reassured the House that while Postwatch's
current activities will become part of the new National Consumer
Council in October 2008, the team working on Network programme
will carry through to the end of the process (Hansard, 29 Nov
2007, column 183WH). But it is not yet agreed how this will work
in practice. It is essential to get the right arrangements in
place if we are not to increase the risks of losing key personnel
during a very uncertain time for Postwatch.
Appendix Two: Geographic Information System
samples (not printed)
Appendix Three: Scrutiny checklist
The table below shows the issues which Postwatch
examines for every closure and outreach proposal. This is not
an exhaustive list—there are often numerous additional local
factors that we look at and ask POL to take into consideration,
as well as scrutinising adherence to the distance access criteria.
For each category, Postwatch gives a red/amber/green
classification, which indicates our level of concern about the
issue for the branch in question. This is arrived at through fieldwork,
stakeholder and customer contact, and our own desk analysis. These
classifications then inform our final position on an individual
proposal.
| Red | Amber
| Green |
| Capacity | |
| |
| Opening Hours | |
| |
| Product Transfer | |
| |
| Demographics | |
| |
| Migration | |
| |
| State of branch | |
| |
| DDA complaint & access |
| | |
| Terrain / Geography | |
| |
| Distance | |
| |
| Parking | |
| |
| Public transport | |
| |
| | |
|
| Deprivation | |
| |
| ATM or cash available | |
| |
| Local economy | |
| |
| Posting facilities at closing branch |
| | |
| | |
|
| Fit with any local/ local authority plan |
| | |
| Vulnerable groups | |
| |
| Closure information available |
| | |
| Other Local factors | |
| |
January 2008
|
| | |
| 
