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November 2007
Post office closure programme
First Postwatch report to The Business,
Page
1. Introduction 2
2. Programme set-up 3
3. The consultation process 5
4. The programme so far 6
5. Other issues 11
Appendix 12
1 Introduction
1.1 This report aims to give an overview of Postwatch's actions and views on the current post office closure programme. Postwatch will continue to provide the Committee with progress reports. In addition, in this document we include details of the pre-programme set-up period.
Background
1.2 Following the Government's
decision that up to 2,500 post office closures should take place, Post Office
Ltd (POL) is proposing which branches are to close through 41 local six-week
public consultations throughout the
1.3 Because of the Government's decision, our acceptance that managed change is needed for the network to be sustainable for the long-term, and the role specified for Postwatch by the Government, Postwatch does not have the aim of trying to reduce the 2,500 closure figure to as low a number as possible.
1.4 Rather, Postwatch's focus is on ensuring that proposed branches to close are selected on the basis that, should the proposals go ahead, they would be such that they kept customer inconvenience to a minimum and also allowed POL to meet the distance access criteria put in place by the Government.
1.5 Our role can be summarised as follows:
· Scrutiny: every proposal of every area plan investigated.
· Feedback: early and ongoing discussions with POL on proposals. Aim to negotiate change where desirable.
· Awareness-raising: co-ordinated approach with POL on public consultation activities.
· Monitor and audit: Postwatch check that the right people are consulted, their views gathered and taken into account.
1.6 Closures will take place throughout 2008. After the programme, there will still be over 11,700 post offices, plus the additional 500 outreach services (typically part-time services offered from a van or from within a local facility like a village hall). 2
2.1 Postwatch had several concerns about closure programme as set out in the Government's decision document, for example the short duration of the programme, and that public consultations would only last six weeks. We set out our concerns in our response to the Government's decision document, available on our website www.postwatch.co.uk.
2.2 We also recognised that we nonetheless needed to work constructively with POL to ensure the closure programme worked effectively for customers.
Postwatch preparations
2.3 Postwatch has taken steps to ensure we can effectively scrutinise whether POL's proposals both take into account relevant local factors and, should they go ahead, would leave a network that continues to meet the minimum access criteria set out by Government:
· Our staff and committees in English regions, and other nations within
the
· Postwatch central office coordinates and supports our regional work, ensuring consistency of approach across the organisation
· We use a geographic information system, which enables us to plot POL's proposals against pertinent factors, such as topographical information and community demographics. This also allows us to independently assess where POL is meeting access criteria.
· Production of leaflets, letters and other materials to inform customers and their representatives about the closure programme and how to participate.
Memorandum of Understanding
2.4 Postwatch and POL have agreed a Memorandum of Understanding (MoU) which aims to ensure consistency across public consultations and provide customers with a set of safeguards and actions they can expect throughout the closure programme. The MoU sets out each organisation's respective roles and responsibilities during the closure programme, the timeframe for consultation phases, and agreed communication activities. A copy of the MoU can be found on our website.
Pre-programme public events
2.5 Before the programme's start, Postwatch and POL
undertook a series of joint events throughout the
2.6 16 joint meetings were held throughout the
2.7 Postwatch Counters Advisory Group (whose membership consists of voluntary and statutory organisations such as Age Concern, Citizens Advice, Postcomm, and ViRSA) has been regularly briefed. For more information on the Counter's Advisory Group visit our website.
2.8 Additionally, Postwatch and POL have both contributed to three Local Government Association events: the annual Rural and Urban Conferences, as well as a specially arranged event for councillors and local government officials, at which the Minister with responsibility for postal services also contributed.
Differences to Urban Reinvention
2.9 There are several important and welcome differences to Urban Reinvention, POL's previous closure programme:
· The current programme involves compulsory closures. Subpostmaster-preference dictated closure locations in Urban Reinvention.
· The current programme allows for greater consideration of POL's proposals by both Postwatch and other interested parties. Postwatch has eleven weeks, rather than two, in advance of public consultation to scrutinise and provide feedback on proposals. Additionally, POL is engaging with local authorities during the pre-consultation period both by requesting local information and through attending meetings on request.
· Unlike Urban Reinvention, all parties recognised before the programme's start for the need for area plans, rather than proposing individual closures.
· Including provision for 500 outreaches should help ensure a more flexible approach to restructuring than was the case in Urban Reinvention.
· Improved consultation processes and materials.
· Most importantly, the Government has given a clear decision in advance
of this programme that 2,500 branches need to close, proportionately across the
4
4.1 Eleven of the 41 public consultations have started. These consultations contained 666 closures, of which 101 were proposed to be replaced by outreach services. Four consultations have finished and are currently in the post-consultation period.
4.2 Postwatch has studied each of Post Office Ltd's closure proposals to ensure compliance to the national access criteria. At this stage, we are satisfied that the proposals put forward by POL have met the access criteria.
4.3 Given that distance criteria have been met, Postwatch has focussed on whether POL's proposals demonstrably take account of relevant local factors: public transport, terrain, demographics and impact on the local economy.
4.4 The following sections give details of issues that have arisen through the early stages of the programme.
Pre-consultation
4.5 During pre-consultation, Postwatch investigates and gives feedback on POL's proposals, POL starts discussions with subpostmasters in the affected area, and local authorities are invited to provide local information and offered a meeting to discuss the development of the area plan.
4.6 By the end of November, 24 area plans had started pre-consultation (including those which have moved into, or finished, public consultation).
4.7 Generally, we have found working with POL during the pre-consultation process to be productive. POL has made numerous changes following Postwatch feedback, resulting in significantly improved plans for the public consultation phase.
4.8 Neither POL nor Postwatch publicises details of these changes, as the details are commercially sensitive and involve private businesses.
Public consultation
4.9 At the start of public consultation Postwatch writes to local authorities, MPs and other local stakeholders, as well as using the media, to state our preliminary views and encourage participation in the consultation.
4.10 During consultation we contact those organisations and individuals who POL must write to, to check they have received information on the consultations. For the first eight public consultations, Postwatch made a total of 174 checks on whether stakeholders had received POL's consultation information pack:
- 59 percent (103) had received the information - 7 percent (12) had not - 34 percent (59) did not know whether they had received the information
4.11 When we find stakeholders have not received the information, or are unsure if they have, we inform them of the proposals and encourage them to contact POL. We are currently examining why a large percentage of stakeholders do not know if they have received the information.
4.12 We analyse responses sent directly to us or those that emerge from the response summary produced for us by POL. We may conduct further visits and investigations based on new evidence.
4.13 We also attend local meetings throughout the consultation period.
Review process
4.14 This process deals with those proposals where in Postwatch's view, Post Office Ltd has not given due consideration to material evidence received during the public consultation, or where evidence emerges that a proposal does not meet the Government's policy requirements.
4.15 As the diagram on page 5 sets out, this is potentially a four-stage process. The first three of these involve both organisations at regional and national level. The fourth and final stage is a review by Royal Mail's Chairman.
4.16 The process can be initiated following the post-consultation meeting, when POL shares its preliminary decisions with Postwatch. So far, the review process had not been taken beyond Stage 1. This is because:
· All proposals so far meet the distance access criteria.
· POL has agreed to amend their area plans in response to concerns Postwatch has raised on particular proposals.
· When disagreements have occurred, POL has been able to demonstrate that it has considered both responses made during public consultation and the impact of local factors on the proposal.
4.17 POL has not yet published any decisions on closures. We are therefore unable to provide details in this first report.
Outreach services
4.18 Outreach services are an important part of the current programme - on average, for every five closures, one outreach facility will be created. POL has been trialling delivery methods over the past couple of years, and we understand that four different operating models will be used:
· Mobile service - a van with incorporated post office counter, stopping at a specified location at a designated time for a set duration.
· Hosted service - a subpostmaster from a nearby post office visits a community at a designated time and runs a service from a 'hosted' location, for example a village hall or local shop.
· Partner service - a local businessperson runs a post office service from their business.
· Home service - a subpostmaster of a nearby post office offers a door-to-door visiting service on set days.
Consultation process and outreach
4.19 POL's consultations are not on the principle of closure, but on proposed changes for a particular area. Proposals must therefore be specific and clearly communicated, to ensure customers understand the changes POL intends to undertake. This is an essential part of meaningful consultation.
4.20 We are therefore concerned that, on numerous occasions at the start of public consultations, POL has failed to set out details of proposed outreaches. Instead, customers in the affected area have been informed that an outreach service is proposed, but have been given little or no detail on what this service is proposed to involve - for example operating hours, location, range of services.
4.21 Postwatch has raised this concern with POL. We have been informed that the number of occasions when this will happen has now been reduced. However, it should not happen at all. We are discussing with POL changes to their procedures to ensure that there is a minimum set of information for all outreach proposals. We have also obtained assurances from POL that no post office branch will close until its outreach replacement is operational.
Minimum service standards and outreach
4.22 In its decision document, the Government did not specify a minimum duration of opening hours or set of services that outreach services should provide. Whilst it is understandable that POL should be able to act flexibly, outreaches are needed in some locations to ensure that POL adheres to the minimum distance access criteria set by Government. Postwatch believes for such instances, the Government should require outreach services to both operate for a minimum duration and provide a 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.
Urban areas
4.23 POL has informed Postwatch that outreach services can be introduced to urban and rural areas. All proposals so far have been located in rural areas. Outreach services should be equally useful in urban areas. We therefore look forward to POL bringing forward proposals for urban outreaches.
New openings
4.24 In a number of postcode districts, POL currently fails to meet the requirement that 95 percent of the population in each postcode district should be within six miles of a post office. POL will therefore be required to open a number of new post offices, which will most likely be outreach services. When assessing whether additional branches are needed POL must take account of terrain and road distance, as well as straight line distance. Postwatch is looking at plans in affected areas to assess if POL is complying with this requirement.
4.25 POL has also stated that it will consider opening additional post offices if, while reviewing coverage in a particular area, it identifies gaps in its current network. We look forward to POL bringing forward such proposals.
Financial viability of proposed closures
4.26 POL uses four criteria for initial identification of branches to propose for closure:
· Size of branch - based on the number of customer sessions.
· Proximity - based on road distance between branches
· Relative size - compared to branches in the surrounding area
· Financial benefit to POL - net subpostmaster pay costs saved, taking into account any business predicted to be lost
4.27 Postwatch understands that one of the success factors of the programme is that POL becomes more financially stable. However, we have some concerns about the long-term consequences of the last of the above criteria.
4.28 There have been instances in the early part of the programme of POL proposing branches to close that receive a relatively high number of customers, but which are nonetheless undesirable to retain from POL's perspective because of their high operational costs.
4.29 Well-used and valued post offices closing, whilst lesser used branches remaining open, in part because they operate at a lower cost to POL, may result in longer-term difficulties. Some lesser-used branches may pick up additional business as a result of closures, but doubtless many will continue to run at a loss. We have raised our concerns on this issue with POL.
Proportionality
4.30 In its decision document, the Government stated then 'when developing detailed area plans, Post Office Ltd will reflect 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'.
4.31 Post Office Ltd interprets this to mean that there should be a roughly equal proportion of closures in each consultation. We have written to the Government, which has supported POL's interpretation.
4.32 It is of course right that
steps should be taken to ensure equity throughout the
POL's documents
4.33 For every public consultation, POL makes available various documents which aim to assist customer understanding. There are leaflets and posters (both placed in affected branches), and an area plan information pack, which is sent to local stakeholders and placed on POL's website. The information pack consists of details on each closure and outreach proposal, maps showing location of both closing and remaining branches, and a summary of the proposed changes.
4.34 These documents are an improvement on those produced by POL during Urban Reinvention. Likewise, POL's website www.postoffice.co.uk/networkchange is more ergonomic and comprehensive than the one for the previous closure programme.
4.35 There are nonetheless shortcomings in POL's literature. We would, for example, welcome a more succinct approach to informing stakeholders of proposed changes than the current area plan information pack provides. However, Postwatch and POL have agreed to review respective communication strategies and materials shortly, and we expect both organisations will find improvements can be made.
4.36 Additionally, during the fourth week and at the end of public consultations, POL also provides Postwatch with a summary of responses they have received from stakeholders and customers. This, and our own analysis and customer contact, is important in informing our final position on an area plan
POL call centre
4.37 POL does not currently accept responses to consultations via its call centre, except in instances where individuals are unable to write or email. This is disappointing - local consultations should be as inclusive as possible. An important part of this is ensuring customers can submit their comments by telephone. Whilst we understand there may be concerns over various practical difficulties of receiving submissions by telephone, nonetheless these are not insurmountable. We have raised this issue with POL and hope they will be able to address the matter.
Local authority involvement
4.38 POL has contacted local authorities on several occasions to request information that may be relevant when POL draws up area plans, for example local regeneration projects. We understand that most local authorities have responded, and that for those that have not done so, POL has re-contacted them to encourage input. We welcome this willingness to engage on both sides - information from councils is essential in helping to ensure area plans take account of pertinent local factors.
5 Other issues
Local and mayoral elections
5.1 POL has announced that public consultations will be suspended for the three weeks before the May 2008 local elections. In addition, POL has brought forward the date for public consultation on London post office closures to February, to ensure it does not occur the mayoral election campaigning period.
5.2 The three week suspension will have a knock-on effect for the start date of subsequent public consultations. The final public consultation will now start on 27th August - five weeks later than originally anticipated.
5.3 Postwatch had requested to both Government and POL that changes to the timetable were made to take into account local elections. We therefore welcome this decision, although the public consultation timetable should have taken the elections into account from the outset.
5.4 It is now important that post-September customer representation is considered carefully by Government, and a decision reached swiftly. Postwatch will not exist after 30 September, yet because of these changes to the closure programme's duration, public consultation will not only continue beyond this date for one area plan, but numerous additional plans will doubtless still be under discussion in the post-consultation period.
5.5 We are liaising with Government and other interested parties on this point, and have stressed the needed for clarity at the earliest possible opportunity.
Postwatch planned research
5.6 We understand that POL has received over 35,000 responses to its first three public consultations. POL estimates that levels of response are over 350 percent higher than during Urban Reinvention. We believe that response levels are higher, at least in part, because POL and Postwatch are both doing more to encourage participation in the process.
5.7 Postwatch has commissioned Ipsos MORI to undertake independent research to assess the public's awareness of current public consultations, and to see how easy customers have found it to contribute their views on proposals. We intend to use the findings to highlight any weaknesses in the public consultation process and to seek improvements from POL accordingly. We expect to publish results on 7 January 2008. |