Memorandum submitted by Post Office Ltd
(POS 4)
INTRODUCTION
Post Office Ltd's Network Change programme represents
the implementation of the Government's policy on the UK's network
of Post Office branches. After a 12-week national consultation,
the Government decided in May 2007 to reduce the size of the network
by up to 2,500 branches while opening 500 new "Outreach"
outlets designed to provide services appropriate to usage levels
in a more efficient way than traditional branches. Detailed implementation
began in July 2007 and the first branch closure required by the
Government's policy took place in January 2008.
Post Office Ltd welcomes the opportunity created
by the Committee's investigation to explain how emerging thoughts
on future provision are formulated, how stakeholders are actively
involved in reviewing, validating and amending proposals prior
to public consultation, how local public consultation is carried
out and how final proposals are either confirmed or amended prior
to implementation.
1. CONTEXT
1.1 Post Office Ltd has consistently made
clear that the size and shape of the Post Office network, and
the level of funding available to pay for it, is a matter for
the Government. The impact of demographic change and new technologies
on the level of business at Post Office branches has been greatly
accelerated by the decisions made by Government departments and
public bodies including the Department of Work and Pensions which
has removed benefit business amounting to £400 million annual
income, the BBC which has awarded the TV Licensing work to a competitor
and DVLA which now receives more than one million payments online
every month. These decisions have contributed to a reduction in
customer numbers of more than four million people every week.
1.2 This decline in traditional business
means that the current network of more than 14,000 branches is
no longer sustainable. The underlying loss made by the business
last year increased to £174 million, more than £3 million
every week. The majority of individual branches are loss making
to Post Office Ltd, including 90% of rural branches. These branches
are only profitable to sub-postmasters because they are subsidised
by a loss-making Post Office Ltd. One in five rural branches serves
fewer than 70 customers each week.
The Government's decision in its response to
public consultation recognises this, and together with a funding
commitment amounting to £1.7 billion over five years to 2011,
offers an opportunity to make a smaller but still substantial
network more stable and secure for customers and sub-postmasters,
and to underpin it for the first time with minimum criteria on
accessibility.
1.3 Post Office Ltd knows that having to
implement change and closures will inconvenience some customers.
Nevertheless we are determined to manage change in such a way
as to leave behind the best possible network—which will
still be largest retail network in Europe—within the constraints
of the funding and decisions set out by the Government, and to
inform and seek the views of our customers and other stakeholders
in an inclusive, consistent and meaningful way.
1.4 We are also conscious that sub-postmasters,
who own and run the private businesses which are affected, require
certainty as to their future in as short a time frame as possible,
and, in many cases, will remain concerned at the value of their
businesses which remain within the network. Post Office Ltd has
mounted an extensive communication effort, including inviting
every sub-postmaster to one of around 250 Network Roadshow events,
to build an understanding of the broader programme and of how
individuals are affected and undertaking personal one-to-one meetings
with every affected sub-postmaster
1.5 Post Office Ltd has learned from previous
experience of planning and implementing managed closures in the
network. In contrast to the Urban Network Reinvention programme
which resulted from earlier Government decisions regarding the
number of branches in urban communities, Post Office Ltd has made
the current programme mandatory for sub-postmasters, rather than
seeking volunteers. Customers need to see a viable future network
based on accessibility and not one planned on the basis of which
sub-postmasters would prefer to close and take compensation. The
current programme is based on an area approach, to give a coherent
approach to future service provision, and to provide a once-over-the-ground
approach which gives customers and sub-postmasters clarity as
swiftly as possible.
2. EXPERIENCE
FROM LOCAL
CONSULTATION SO
FAR
Summary
Post Office Ltd has:
— Put in place a consistent and comprehensive
approach to formulating emerging thoughts on the basis of Government's
criteria and factors, and developing and reviewing proposals,
both before and as part of local public consultation, with active
involvement of stakeholders and customer representatives
— Sought to change initial thoughts
on the basis of stakeholder input before public consultation,
as well as making changes as a result of local public consultation
— Actively involved customers and communities
in developing proposals for Outreach outlets
— Made available more information than
ever before to contribute to proposals and to inform customers
and stakeholders
— Pro-actively communicated to the
media, to stakeholders, including MPs, and at public meetings
organised by customers or other organisations
2.1 Post Office Ltd, with Postwatch involvement,
has set clear objectives, or success factors, for the public consultation
process:
— Change is implemented in a way that
meets prescribed Government requirements as set out in the Government
Response to public consultation
— Consumers and those who represent
them are fully informed about the proposed change and have the
opportunity to contribute views on how it is to be implemented
in the area within the requirements of Government
— Change is introduced in a manner
that minimises disruption and avoids inconvenience to customers
(where this is within Post Office Ltd's and Postwatch's power)
— Change meets the Government's criteria
on accessibility and results in a more financially sustainable
network for the future
2.2 The local public consultation itself
is one part of a lengthy planning and consultation cycle, undertaken
in 47 areas across the UK, which:
— Plans the retention, closure or conversion
to Outreach of existing branches—on the basis of the size
of network and the criteria and factors set by Government, but
not on the basis of the preferences of individual sub-postmasters
— Involves customer representatives
and local stakeholders throughout a 125-day process to ensure
that the best possible proposals are developed and that the local
public consultation phase itself is supported by detailed, publicly
accessible information about each proposal
— Takes a consistent approach in each
of 47 areas across the UK, with the aim of completing the programme
in 12-18 months
2.3 The criteria and factors set by Government,
including the principle that no country within the UK and no group
of inhabitants at the area plan level should be significantly
more adversely affected than any other, are set and cannot be
amended by the planning and consultation process. Post Office
Ltd recognises that the planning and consultation process is a
tool to build the best possible future network, but is not an
opportunity for the company, or for customers or stakeholders,
to reopen or change the Government's decision to close up to 2,500
existing branches while providing around 500 new Outreach outlets.
2.4 The 125-day process comprises six discrete
stages, set out here:
| Blueprint and validation
| 2 weeks | Initial thoughts are modelled—based on application of Government's criteria to existing network. Initial thoughts reviewed and amended on the basis of Postwatch and Local Authority input and Post Office Ltd's on the ground activity—continuing through subsequent six week engagement with agents phase.
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| Engage with agents | 6 weeks
| Face to face conversations with all affected subpostmasters
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| Consultation and preparation, including MP advanced notification
| 3 weeks
(MP advance notification being the final week)
| Development of final proposals to form the basis of Local Public Consultation; shared with MPs one week before the start of consultation
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| Local Public Consultation
| 6 weeks | Detailed information available via branches, Consultation team and website to assist customers and other stakeholders.
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| Review and decision |
3 weeks (subject to review process), ending in publication of final decision
| All consultation representations reviewed and assessed by Post Office Ltd and a summary of issues raised in consultation is shared with Postwatch and an opportunity given to it to refer any decision to review before publication of firm decisions
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| Implementation | 4 weeks
| Preparation for closures and transfers to new Outreaches where appropriate. First changes may take place after this four week period
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The six-week local public consultation (the length of which
has been set by Government) is the fourth stage of the overall
process. Post Office Ltd's objective is to put into public consultation
the best possible proposals for the future provision of services
in the relevant area and, in practice, the initial thoughts based
on Government's criteria and factors will already have been reviewed
and changed as a result of the pre-consultation part of the process.
Public consultation brings the opportunity to test detailed proposals,
and the information on which they are based, and to give customers
and local stakeholders the opportunity to scrutinise their formulation.
2.5 Postwatch, the consumer body representing all Post
Office customers, was involved in the design of the overall planning
and consultation process, and plays an active role throughout
the 125-day process.
2.6 In July 2007 Post Office Ltd asked 468 UK Local Authorities
to provide information relevant to planning the future provision
of Post Office services, including information regarding regeneration
plans and their potential impact on usage and regarding public
transport. In total 283 Local Authorities have so far responded
with relevant information which has been used to formulate area
propositions. In addition, Post Office Ltd has met with more than
50 Local Authorities as part of the planning and consultation
process for the first 12 area plans.
2.7 The bulk of changes made to Post Office Ltd's initial
thoughts are made prior to local public consultation as part of
engagement with Postwatch, representing customers, and with Local
Authorities and with input from local Citizens Advice offices.
Between 2% and 26% of closures initially proposed—50 individual
branches—have been withdrawn by this dialogue before the
start of local public consultation in an area.
2.8 When initially identifying branches to be proposed
for closure, Post Office Ltd looks at the following information
it has on the branches in the relevant area relevant to the criteria
and factors set by Government, which are summarised at Annex
A (not printed here). In doing this we look at things
such as:
— Size of branch—particularly the number
of customer sessions (visits by individual customers)
— Proximity—to other Post Office branches
based on road distance between branches
— Financial benefit to Post Office Ltd—including
net sub-postmaster pay costs saved, and other costs to Post Office
Ltd, taking into account any business that is predicted to be
lost
— Relative size—based on size of branches
in the surrounding area
In addition to the input from Local Authorities and Postwatch,
Post Office Ltd always undertakes on the ground local research
to check and validate local information and to identify the likely
issues affecting customers. The final proposal, on which public
consultation takes place, is produced by a Network Development
Manager—a senior Post Office Ltd manager with direct knowledge
and experience of the affected area—and checked and approved
by the Programme Director.
2.9 In general, Post Office Ltd does not therefore expect
to make major changes after public consultation, but aims to ensure
that the published proposal is based on correct and comprehensive
local information and that the process has been properly and consistently
applied. We are conscious that the performance and value of individual
Post Office business can be adversely affected by even a withdrawn
closure proposal. The number of changes resulting from public
consultation alone is therefore not the right measure of the effectiveness
of the process.
2.10 A multi-stage review process has been agreed between
Post Office Ltd, Postwatch and the Government to ensure that decisions
are fully examined and can be reviewed if stakeholders believe
they do not follow the Government's criteria or that the agreed
planning and consultation process has not been followed.
2.11 Post Office Ltd is determined that the process is
as transparent as possible and that the right information is readily
accessible to customers and other individuals or organisations
wishing to participate in local public consultation. A substantial
quantity of detailed information supporting each individual branch
closure proposal, and setting out the alternatives is published
by Post Office Ltd as part of each Area Plan Proposal.
3. LOCAL VIEWS—EXTENT
TO WHICH
THEY HAVE
BEEN TAKEN
INTO ACCOUNT
Summary
— Customers and other stakeholders have contributed
strongly to the planning and consultation process through the
local public consultation
— In addition customers' views are represented by
Postwatch throughout the 125-day planning and consultation process
and local input is sought via Local Authorities throughout the
process
— Local Public Consultation has overturned closure
proposals in each of the first six plans completed
— Post Office Ltd is only permitted to act on local
views where those views provide information relevant to the criteria
and factors set by the Government
3.1 Input received during public consultation, particularly
that which provided additional information relevant to the criteria
and factors set by the Government, has helped Post Office Ltd
and Postwatch review and validate area propositions. In 14 instances
in the first six Area Plan Proposals, particular closure proposals
have been withdrawn as a result of this information. Withdrawn
proposals are summarised at Annex B (not printed here).
3.2 In other instances Post Office Ltd has been able
to respond to customers' concerns by committing to improvements
to branches, for example by improving access for customers with
disabilities, extending opening hours, making additional services
available or, in some instances, by adding additional counter
positions. Investment grants are made available by Post Office
Ltd to support this activity. Improvements are planned in 59 branches
in the first six plans completed and the product range has been
extended in a further 289.
3.3 Certain concerns raised during public consultation
have not led to changes in Post Office Ltd's proposals, because
they relate to the broader policy or to the magnitude of the changes,
both of which have already been determined by Government following
a 12 week national consultation. In addition, Post Office Ltd
is not allowed to take certain factors into account in reaching
proposals or decisions, including strength of feeling among customers
regarding the popularity and ability of a particular sub-postmaster,
or the wishes of a sub-postmaster, either to remain in the network
or to accept the compensation package.
3.4 To date, more than 44,000 individual pieces of correspondence
have been received as part of the 12 area public consultations
completed or currently underway. In addition, Post Office Ltd
has attended more than 45 public meetings, briefed more than 120
MPs and, additionally, briefed members of devolved legislatures.
Our policy is to attend every such meeting subject to logistical
issues, and fewer than 5% of invitations have not been accepted.
The Network Change area of the Post Office Ltd website, which
provides easy access to all information and consultation materials
is receiving around 2,000 visits each week.
Every piece of correspondence received during the area public
consultation period must be acknowledged, read and considered
by the Network Development Manager responsible for making both
proposals and decisions on individual branches. Postwatch also
receive copies of correspondence received during public consultation
to inform their participation in the decision making process.
3.5 The scale of consultation activity undertaken to
date is summarised here (and broken down by area at Annex C)
(not printed here)
| Number of Parliamentary constituencies covered by first 12 plans
| 188 |
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| Number of meetings undertaken with MPs affected by first 12 plans
| 126—meetings offered to all MPs. Principal reason for not taking up offer was lack of change planned in constituency
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| Number of Local Authorities affected by first 12 plans
| 161 |
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| Number of Local Authorities engaged in planning
| 111 |
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| Number of meetings undertaken with affected Local Authorities
| 52 |
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| Number of representations received during first 12 plans
| 44,270 |
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| Number of public meetings attended during first 12 plans
| 47 |
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| % of customers unaffected by proposals put into public consultation
| 91% |
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| % of customers either seeing no change or remaining within one mile, by road, of nearest alternative branch
| More than 99% |
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| Number of closure proposals within first 12 plans
| 605 |
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| Number of Outreach proposals within first 12 plans
| 89 |
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| Number of closure proposals withdrawn prior to start of public consultation
| 50 |
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| Number of closure proposals withdrawn as a result of public consultation (for six plans where decisions have been made)
| 15 |
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| Number of branches with improvements planned as a result of public consultation (for six plans where decisions have been made)
| 59 |
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| Number of branches where product range has been extended following public consultation (for six plans where decisions have been made)
| 289 |
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4. NATURE OF
OUTREACH PROJECTS
Summary
— The Outreach model is already a working part of
our way of providing services and will increase in significance
as a result of the Government's decision to create around 500
further Outreach branches
— 89 Outreach outlets have been proposed within
the first 12 area propositions developed by Post Office Ltd and
put into local public consultation
— Developing Outreach proposals as an integral part
of the area planning and consultation process presents some challenges
but is the right way to proceed, informed by the ongoing involvement
of Postwatch representing customers
— Crucially, experience shows that customers continue
to use Outreach outlets and Outreach outlets continue to provide
the face to face advice and support that is crucial to the social
value of the overall Post Office network
4.1 In 2004 Government asked Post Office Ltd to develop
trials of innovative and efficient ways of providing Post Office
services in communities where a traditional full branch has closed
or was becoming clearly unsustainable for the sub-postmaster.
In response, Post Office Ltd developed and tested four models
for "Outreach" service provision—a mobile post
office service visiting small communities at set times, a hosted
service operated within third party premises for specific hours
each week, a partner service within the premises of a local partner
such as a shop or a home service whereby customers can contact
a sub-postmaster by phone for services. In around 70 on-the-ground
pilots, Post Office Ltd demonstrated the viability of the approach
and saw a positive response from customers, sub-postmasters and
other community stakeholders.
4.2 The "Outreach" concept supports both the
Government's emphasis on accessibility as set out in the criteria
it has set for the network in the future, and Post Office Ltd's
clear objective to maintain a sustainable network by providing
the core sub-postmaster with a stronger commercial opportunity
than that provided traditional branches. Outreach outlets are
regarded by Government, Post Office Ltd and Postwatch as a valid
means to fulfil national accessibility criteria in appropriate
locations and to provide services to customers.
4.3 The Government's final decision on the future shape
and size of the network explicitly required Post Office Ltd to
provide services through Outreach outlets in around 500 communities—partially
offsetting the overall reduction in traditional branch numbers
while contributing to a more sustainable network through reduced
overheads in communities with low numbers of current or potential
customers.
4.4 Developing proposals for Outreach outlets is an integral
part of the 125-day planning and consultation process in appropriate
areas. In the first 12 area propositions, Post Office Ltd has
proposed 89 Outreach outlets in rural communities. The local public
consultation process itself provides a valuable opportunity for
local communities to influence the nature of eventual outreach
solutions and for Post Office Ltd to seek assistance from within
communities to identify potential partners and locations.
4.5 Selecting the "core" outlet, which will
manage a cluster of Outreach locations is based on the size of
the prospective branch—in terms of the number of customer
sessions envisaged—and the proximity of the core and potential
Outreach locations to each other. Post Office Ltd cannot compulsorily
require an existing sub-postmaster to take on responsibilities
as a "core" branch, and must therefore attract volunteers
and remain flexible in how "core" and Outreach location
selection is undertaken.
4.6 In some areas where plans have been developed early
in the programme this process has taken longer than anticipated,
partly because, understandably, the focus of community representations
has been on preventing the loss of a traditional branch rather
than helping Post Office Ltd finalise details of an outreach replacement.
In these circumstances Post Office Ltd has agreed a review approach
with Postwatch to ensure that detailed proposals can be fully
scrutinised before final decisions to close existing branches
are implemented.
5. THE ROLE
OF POSTWATCH
Summary
— Postwatch is fully and actively engaged in the
programme, and is able to represent customers and influence decisions
at every stage in the 125-day planning and consultation process
5.1 Postwatch represents customers of Post Office branches
and is acting on their behalf throughout the planning and consultation
process—which Postwatch helped to design—both before
and after the six-week local public consultation period. Postwatch
carries out this role by scrutinising every individual proposal
and giving its views on customers' needs and concerns at a local
level and actively seeking to change those individual proposals
which it believes can be improved or should be altered. Both Postwatch
and Post Office Ltd aim to make as many of these changes before
the start of public consultation—only in instances where
new information is provided by the public consultation process
should it be necessary to make further changes to the proposals.
5.2 In addition has a responsibility to publicise and
raise awareness of the public consultation process, and to monitor
the way in which consultation is carried out.
5.3 Post Office Ltd and Postwatch have agreed a number
of formal points of engagement throughout the process to ensure
consistency and enable proper scrutiny of proposals and decisions.
In addition the two bodies have organised joint briefings for
stakeholders across the UK and brought respective teams together
on a number of occasions to ensure learning and best practice.
5.4 Postwatch is able to trigger a review process if
it believes that any individual proposal does not fit the approach
set by Government or the planning and consultation process established
by Post Office Ltd. A review may be triggered after the public
consultation process is completed, but before final decisions
are announced following the consideration of all responses to
public consultation, if agreement between Postwatch and Post Office
Ltd is not reached. There are four potential stages to this review—at
stage three, Postwatch and Post Office Ltd at Chair and Managing
Director level respectively will re-examine the decision and a
final review stage is allowed for in the event of continuing disagreement.
To date, no individual reviews beyond stage two have been requested
by Postwatch as a result of the six Area Plan Proposals to have
reached final decision stage.
5.5 Post Office Ltd and Postwatch agreed, prior to the
programme, a Memorandum of Understanding setting out their respective
roles and the way in which they interact at different stages of
the consultation process.
6. CROWN POST
OFFICES—HOW
THEY INTERACT
WITH THE
SUB POST
OFFICE NETWORK
Summary
— Post Office Ltd has now set out a clear and confirmed
strategy to maintain commercial high street flagship branches
without these branches acting as a financial drain on the less
commercially viable parts of the network
— Confirming plans for the Crown network before
starting the Network Change programme gives customers and other
stakeholders a clearer, more certain picture of alternatives to
branches which may now be proposed for closure
— The performance and capacity of all flagship branches
is actively managed to ensure a high quality of service
6.1 Post Office Ltd is committed, as part of both our
social purpose and our commercial strategy, to providing a high
quality network of flagship branches, located in convenient town
and city locations readily accessible to customers. At the same
time we cannot continue to sustain the losses of more than £1.4
million incurred each week in the traditional network of 460 directly
managed Crown branches. A loss making flagship network reduces
the financial support which can be given to branches in smaller
urban and rural communities.
6.2 In April 2007 we announced clear decisions on the
future of the existing Crown Office network, giving certainty
on the future of almost all branches—373 to be retained
by Post Office Ltd as directly managed branches and a further
70 to be run in partnership with WHSmith, following successful
initial partnerships at six branches. We have been reviewing options
for a remaining 15 branches—two of these branches have now
been franchised and we are consulting on the potential closure
of a further two. We are actively pursuing franchise arrangements
for the remaining 11 but believe we may be unable to find suitable
partners for two of these, which may then close. This decision
puts an end to the piecemeal approach to franchising taken in
the past which, while driven by financial necessity, led to uncertainty
and a fragmented approach to investment and improvement, and gives
as close as possible to a stable basis on which to plan the rest
of the network through the current change programme.
6.3 Post Office Ltd is now able to plan substantial refurbishment
in these branches to provide a modern retail environment, including
developing self service kiosks so that customers wanting to post
packets and parcels don't have to go to the counter and providing
dedicated counters for small business and online auction customers.
Our investment plan will encompass both the flagship branches
directly managed by Post Office Ltd and those managed by WHSmith.
In the same way, the performance standards required and the approach
to training and developing those colleagues serving the public
is identical in all these branches, regardless of the management
model.
6.4 Post Office Ltd is conducting public consultation
on each Crown Office to be moved to a new WHSmith branch, and
any other changes to the Crown network, in line with the code
of practice agreed with Postwatch and under the same internal
Governance as the remainder Network Change programmme. 61 of the
70 consultations regarding WHSmith were completed before the first
public consultation arising from the remaining Network Change
programme and a further four consultations have since been completed,
with five yet to commence.
6.5 Post Office Ltd has a single, integrated approach
to managing changes to Crown offices and the changes to the rest
of the network required by the Government—amounting to the
first full strategic review of the network ever undertaken. Any
proposal to close rather than replace an existing Crown branch
will be put into consultation prior to the start of the public
consultation on the relevant area proposition so that respondents
are as fully appraised as possible of Post Office Ltd's overall
plans and the overall provision of Post Office services for the
area can be considered in making the final decisions.
6.6 Post Office Ltd knows that flagship branches can
attract large numbers of customers from outside their immediate
geographical area, particularly when customers are seeking an
alternative if the branch nearest their home address closes. We
therefore continuously manage the capacity of these branches extremely
carefully, and have, for example, ensured that all new WHSmith
managed branches provide at least the same number of serving hours
as the Post Office managed branches they replace.
7. THE FUTURE
OF BOTH
CROWN AND
SUB POST
OFFICE NETWORKS
7.1 The Network Change programme will leave behind a
UK network of around 12,200 Post Office outlets of which 500 are
new Outreach outlets, with a level of accessibility guaranteed,
for the first time, by Government set criteria. The combination
of the approach to Network Change described in this submission,
and the broader commercial strategy of Post Office Ltd is intended
to put the network on a more secure and sustainable financial
footing, and crucially, to manage where branches are, and how
readily customers can reach them, rather than simply managing
the overall size of the network.
7.2 Post Office Ltd is, at the same time as transforming
the size and shape of the network, transforming the range of services
provided and products offered as the Government withdraws the
traditional business which has historically enabled sub-postmasters
to run viable small businesses based around the Post Office contract.
Government business will by 2010 make up less than 10% of the
average the sub-postmaster's Post Office business. The rest will
come from commercial services, including mail and parcel services,
bill payment and increasingly new streams of business developed
and marketed by Post Office Ltd, including foreign currency, telephone
and broadband services and financial services, including savings,
a range of personal insurances (for example home, motor and travel),
credit cards and mortgages. A fuller summary of what we are doing
to drive new business through the network is provided at Annex
D (not printed here).
7.3 The Government has decided to reduce the size of
the current network by up to 2,500 branches and is providing the
funds to compensate the affected sub-postmasters. Post Office
Ltd has no wish to see any reduction in branch numbers beyond
this level, providing that the overall network can be made sustainable.
Any instance of a branch closing in the future for reasons beyond
Post Office Ltd's control will result in a case by case examination
of the future provision of services across the relevant local
area and to meet the binding national accessibility criteria.
Nonetheless, it remains the case that the majority of Post
Office branches are not commercially viable for Post Office Ltd
and require support through the structure of the Post Office remuneration
to make them viable for sub-postmasters, which provides minimum
income levels regardless of low numbers of transactions in smaller
branches. Post Office Ltd's ability to provide remuneration at
a level which enables these branches to survive is dependent partly
on the success of the company in marketing new services, both
through branches and directly, and, crucially, through financial
payments from Government in recognition of the social value of
the network of branches. Changes to Government's position would
require Government to review its decision on the size and shape
of network it wished to see.
7.4 The Post Office Card Account, while a smaller income
stream than the benefit book which it replaced, is used by more
than 4 million customers and represents vital footfall for sub-postmasters,
usually benefiting the retail businesses which run alongside Post
Office business. The replacement for the current Card Account
contract, which runs until 2010, is currently the subject of a
tender process by the Department for Work and Pensions. Post Office
Ltd believes it remains the best and most accessible provider
of this service. Loss of this product and its associated footfall
would have a serious and immediate impact of the livelihood of
many of the 12,200 outlets which will remain following the completion
of the Network Change programme.
10 January 2008
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