The post office closure programme

 

 

Progress report to The Business, Enterprise,

and Regulatory Reform Committee

 

 

 

Postwatch

 

 

 

 

 

 

 

 

 

 

May 2008

 

 

The post office closure programme

 

 

 

 

Postwatch May 2008 progress report

 

 

 

 

 

 

 

 

 

 

Page

 

1. Overview 3

 

2. Post-consultation review process 3

 

3. Outreaches 6

 

4. Local authority funding 7

 

5. Communications 8

 

6. Mow Cop Village 9

 

7. Code of Practice 9

 

Appendix One - the review process 10

 

 

1. Overview

 

 

By the start May, Post Office Ltd (POL) had proposed 1,261 closures and 284 outreaches. Below is a statistical update on completed area plans - those for which POL has both consulted and announced decisions.

 

By the start of May, POL had announced decisions for 16 area plans. The key points for these plans are as follows:

 

· They involved 751 closure proposals in 230 parliamentary constituencies.

 

· In addition, POL has proposed a further 133 branches for closure and replacement with outreach solutions.

 

· Following Postwatch feedback, POL has withdrawn 82 proposals during pre-consultation periods.

 

· Following public consultations, POL has withdrawn 30 proposals and changed one proposed closure to a proposed outreach.

 

· POL has consulted on 20 replacement branches following these withdrawals. One replacement branch has been withdrawn.

 

· There has not been a replacement branch proposed since the North Yorkshire with Yorkshire East and Keighley plan (the 11^th area plan to enter public consultation). The consultation period for this replacement closed on 9 April.

 

· Postwatch agrees with POL that the proposed remaining network would continue to meet the access criteria set by the Government.

 

· 29 proposals have been entered Stage Two of the review process, 16 of which were escalated to the third stage. One of these then went to the fourth and final stage.

 

 

2. Post-consultation review process

 

The review process allows for disputed proposals to be further examined and discussed by Postwatch and POL after public consultation.

 

Postwatch does not always initiate the review process with the purpose of persuading POL to withdraw a closure proposal. We have also requested reviews with the aim of addressing other concerns and to secure other outcomes, for example, in connection with proposed outreach services, and to achieve improvements to customer service at particular branches in the remaining network.

 

It is important that all customers and their representatives who wish to participate in the consultation process do so during the six week consultation period. This helps ensure both POL and Postwatch are aware of local concerns and community needs, which in turn influences our decisions on whether to initiate the review process for specific proposals.

 

 

 

 

 

Process changes

 

Following its use early in the closure programme's early stages, POL and Postwatch have agreed amendments to the review process.

 

Appendix One explains the different stages of the review process.

 

Stage One has been operating effectively since the programme's start. However, both POL and Postwatch felt that the later stages of the process could be improved to provide a more efficient and effective process for reviewing contentious proposals.

 

Postwatch and POL have agreed that Stage Two should be put back several days - these meetings now take place 15 working days after the end of consultation, rather than 12 as was previously the case. The longer duration between the first and second stages means the proposals in question are further discussed at a regional level, allowing for greater consideration of the issues by both organisations.

 

 

Action plans

 

In addition, POL is now also providing action plans to Postwatch for Crown Offices in areas where closures are proposed. These are useful in helping inform our decision-making, and provide a needed and welcome link with POL's ongoing work on the Crown Office network. Action plans contain various relevant local operational details, for example current customer service quality at the Crown Office, and plans to adjust staffing levels or deployment to meet the predicted increase in customers.

 

Action plans help ensure that the customer experience in the post-programme network is central to POL's planning. They provide information and an assurance that the programme is not just about closing post offices, but, more importantly, about putting in place a viable network that is able to provide a satisfactory service to communities.

 

We have, however, been disappointed with the time POL has taken to deliver these action plans, particularly for the Stage Three cases in the Sussex area plan, which were weeks late - unacceptable, given that decisions on closures of affected branches could not be announced until these plans were received, resulting in uncertainty for both subpostmasters and customers. We understand the need for the plans to be both comprehensive and accurate. However, the consistent failure of POL to meet self-imposed deadlines undoubtedly causes inconvenience for customers and subpostmasters.

 

 

Timing

 

We want to ensure that Postwatch is aware of affected communities' needs and views on every closure proposal. Several important factors help ensure this happens:

 

· Our own scrutiny of POL's proposals, including site visits and analysis from our Geographical Information System.

· Discussions with customers and their representatives, including public meetings

· Accurate and comprehensive summaries of consultation responses from POL

· Timely receipt of copies of submissions by key opinion formers

 

Postwatch writes to stakeholders - including MPs, local authorities, charities, and Regional Development Agencies - at the start of and during consultations. These letters have several aims: raising awareness and encouraging participation; outlining our initial position on POL's proposals; requesting that we are copied into stakeholders' submissions to POL; and alerting stakeholders to consultation timescales and the review process.

 

POL typically announces its decision on an area plan around four weeks after consultation ends. However, Postwatch is required to inform POL which proposals will enter the review process within ten working days of consultation finishing.

 

Postwatch has received a number of contacts from stakeholders after POL has announced decisions on closures, requesting that Postwatch initiates the review process for a particular closure proposal. By that point, however, it is too late for the review process to be triggered for proposals within the area plan in question.

 

POL's announcement effectively signals that an area plan is finished. Once a decision announcement has taken place, there is not the option of revisiting proposals contained within an area plan. It is therefore vital that both POL and Postwatch receive communications from stakeholders during the six-week consultation process. Postwatch will continue to work to ensure stakeholders are aware of the timescales of the different stages of the closure programme, and understand the role, purpose and timing of the review process.

 

 

Stage Four

 

Unlike earlier stages in the review process, Stage Four is not a bilateral discussion between POL and Postwatch of the proposal in question. Instead, both parties submit written evidence to Allan Leighton, Chairman of Royal Mail, who takes the final decision.

 

Postwatch has so far escalated one closure proposal to Stage Four of the review process - Micklegate Post Office in York. Our concerns in connection with POL's proposal to close this branch focussed on several local factors, principally that we considered POL's customer migration prediction to be low, and were the branch to close, that parts of the remaining local network would not be able to satisfactorily cope with the increased customer levels.

 

Following a review by Allan Leighton, we are pleased that POL announced on 2^nd May that Micklegate Post Office will not be closed as part of the programme.

 

 

Communicating decisions

 

Both POL and Postwatch issue press releases and use their websites to communicate consultation outcomes. If the review process is still underway at the time of POL's announcing its decision on the remainder of an area plan, POL and Postwatch issue additional press releases when the review process outcomes are known.

 

However, POL's decision document should be clearer on the review process. Further background information is needed on the process itself, customer feedback during consultation on those cases that subsequently enter the review process, and Postwatch's rationale for particular cases being subject to further review. Greater clarity and transparency would assist in strengthening understanding of, and confidence in, the process.

 

 

3. Outreach

 

Outreach services are an important part of the programme, with at least 500 being put in place by POL to help mitigate the effects of closures.

 

 

Range of services

 

There are four outreach service models: hosted, partner, mobile, and home delivery. Partner services are outreaches where a local businessperson runs a post office service from their business, for example in a local shop or pub.

 

Postwatch has raised concerns with POL about the restricted range of services offered at 'partner' outreaches. Specifically, it is unsatisfactory these outreach services are unable to accept postal packets weighing more than 2kg.

 

This is a significant issue, and one which Postwatch wants POL to address as a priority. Whereas customers are able to access elsewhere many services available at post offices, this is not the case for posting heavy packets. Non-availability of this service would therefore cause particular difficulties and inconvenience for customers.

 

We have written to POL on this matter. We accept that there may be occasions when a partner service is not able to accept packets weighing over 2kg, for example in premises with space and security constraints. However, such a restrictive arrangement should be the exception, not the norm, particularly in view of the fact that many partner services are located within the premises that previously housed the post office, where this service was available.

 

POL has sought to explain the restrictions on parcels as being due to practical difficulties - for example POL has explained that the scales used at outreach services have a maximum weight of 2kg - prohibit this service being offered. POL has also stated that they believe relatively few customers will be impacted, as their records indicate an average level of usage of this service at branches that have been, or are being, changed to outreach services.

 

We do not accept that these practical difficulties could not be overcome in most locations and do not accept that relatively low usage is grounds for not providing these services. Postwatch will continue to press the case for this service to be available at partner outreach services.

 

 

Trials of outreaches in urban areas

 

We welcome POL's announcement that it intends to trial outreach services in a number of urban areas. Postwatch has long pressed POL to introduce urban outreaches, and we will be discussing with POL the details of these pilots in the weeks ahead. Should the trials prove successful, we look forward to POL introducing outreach services into other urban locations.

 

Postwatch understands that the trial of urban outreaches will be handled as a separate exercise from the closure programme.

 

Additionally, we welcome POL's commitment to establishing an outreach service in Hastings, to replace the existing post office. Postwatch took the proposed closure of the existing post office to the third stage of the review process. We had stressed the importance of retaining post office services in this area because the adverse impact closure would have on the deprived local economy, and the ability of Hastings Crown Office to adequately serve additional customers.

 

POL's willingness to develop an urban outreach in this location is good news for customers. We look forward to POL providing further information on the criteria for selecting trial locations, the duration of trials, and arrangements should an outreach trial not continue.

 

We will continue to work with POL on this matter. In addition, as Postwatch will merge with the National Consumer Council and energywatch on 30^th September 2008, we are also liaising with the start-up team of the successor organisation on longer-term customer issues in connection with the urban outreach pilots.

 

 

Early outreach consultations

 

In previous reports, we welcomed POL's commitment to consult again on those outreach proposals that had moved through public consultation before January 2008, and where POL was unable to provide operational details of the service to Postwatch by our post-consultation review discussion.

 

Public consultation on this basis has now started in several locations, including Langworth, Lincolnshire. POL had originally proposed an unspecified outreach service in Langworth, but in response to Postwatch's concerns POL consulted again, the second time on a proposal to introduce a mobile service in the village. Postwatch welcomes POL's commitment to meaningful community engagement on proposed services. We are, however, disappointed that it took POL several months to develop this proposal, resulting in a protracted period of uncertainty for customers.

 

We are concerned that POL has yet to consult on detailed outreach proposals in three locations in Hampshire, despite announcing in early January that this would happen once POL had fully worked up proposals. POL originally consulted, failing to include operational details, on establishing outreaches in Hampshire in late 2007. We welcome that POL has now commenced a second consultation, with details, on five of these proposals. We continue to press POL to commence consultation on the remaining outreach proposals as soon as possible.

 

 

4. Local authority funding

 

Postwatch welcomes the ongoing discussions between local authorities and POL on local authorities providing financial support for particular post offices.

 

Where POL receives a serious approach to financially support a post office, POL has committed to engaging with the interested party on the costs that would need to be covered and the contractual terms and conditions that would apply. Postwatch is not privy to the discussions taking place between POL and local authorities, but we understand that these costs would include the provision of suitable premises, staff, initial set-up costs, and guaranteed funding until at least 2011.

 

Postwatch considers that it is right that local authorities should be expected to commit to funding on this long-term basis. Locally funded branches will not be eligible for any of the Government's £150 million financial support. We are concerned that without this commitment, local authorities, during periods of financial pressure, may not be able to find sufficient money to finance post offices against a backdrop of falling customer visits and financial losses.

 

It is important that such locally funded post offices do not undermine the viability of other branches in an area. Many post offices are expecting, and in numerous cases depending on, an increase in business as a result of nearby closures. It is therefore critical that POL works with local authorities to ensure that any local funding agreement contributes to the delivery of a stable post office network, and does not adversely impact upon the viability of other post offices in that area.

 

Postwatch will continue to liaise with the Local Government Association (GLA) to help ensure its members are aware of POL's commitment to engaging on local funding, and other practical solutions. As part of this engagement strategy, we are working closely with LGA officials to support a best practice event for local authorities in May.

 

 

5. Communications

 

Postwatch has previously reported to the Committee that, although an improvement on the previous closure programme, aspects of POL's customer and stakeholder communications should be improved.

 

 

MP liaison

 

Postwatch welcomes that, in response to the Committee's inquiry on post office closures, POL committed to earlier MP liaison before public consultation starts, with MPs receiving details of POL's proposals two weeks in advance of consultation. Postwatch routinely contacts individuals and organisations (including members of devolved administrations) who POL must write to, to check they have received consultation information. We will change the timing of our MP liaison to reflect POL's changes.

 

 

In-store literature

 

Postwatch has pressed POL to improve its customer literature. In particular, we want to see clearer information on posters and in leaflets on how customers can constructively participate in consultations. POL has informed us that its in-store literature is being changed, with amended documents being available from May. Postwatch has given POL comments on potential improvements, and we look forward to improved customer literature helping consultations.

 

 

Substitute consultations

 

Postwatch has continued to press POL to introduce consistency to its communication activities for 'substitute consultations' (those branches POL propose for closure as a result of other proposals being withdrawn from the programme). POL has thus far failed to issue press releases at the start of these consultations.

 

We therefore welcome POL's recent commitment that, from May, they will issue press releases for any consultations on substitute proposals.

 

 

Stakeholder monitoring

 

Postwatch continues to contact stakeholders who POL must write to at the start of consultations, to check that they have received POL's information packs. For the first 17 public consultations, Postwatch made a total of 270 checks:

 

· 183 (68 percent) stated they had received the information

· 16 (6 percent) had not received the information

· 71 (26 percent) were classified as 'unknown'

 

'Unknown' refers to those instances where a stakeholder could not confirm if the pack was received or not, or where Postwatch was unable to discuss the matter with a stakeholder (for example where our telephone call was not returned).

 

 

6. Mow Cop Village

 

Postwatch is disappointed that POL as part of its Shropshire and Staffordshire area plan included the proposal to close Mow Cop Post Office, in Cheshire. POL had already included this area in its Merseyside and Cheshire area plan, with two closures taking place in Congleton constituency (in which Mow Cop is situated).

 

POL's decision to consult on this particular proposal goes against its commitment that they would adopt a 'once over the ground' approach to all areas. This is the first, and we hope only, instance of POL revisiting an area to propose additional closures over and above those that it proposed earlier in the programme.

 

The Shropshire and Staffordshire consultation ends on 9 June. Postwatch will oppose the closure proposal.

 

 

7. Code of Practice

 

In its reply to the Committee's report on the closure programme, the Government requested POL works with Postwatch to develop a new Code of Practice covering 'business as usual' network changes.

 

Postwatch agrees that the current Code of Practice should be updated to include, for example, arrangements for outreach services and to reflect recent changes in Government policy. Given that the many functions agreed in the Code of Practice will be discharged by our successor organisation, the new National Consumer Council, we will be discussing how we take this forward with BERR, POL, and the new NCC in the coming weeks. We will update the Committee on developments in our next progress report.