Written evidence from the Department for
Business, Innovation and Skills
UNIVERSAL SERVICE
OBLIGATION FOR
REGISTERED LETTERS
AND PARCELS
Committee Members asked whether the provisions in
the Postal Services Bill for six-day collection and delivery of
letters applied to registered letters and hence whether this required
Post Offices to be open on Saturdays to accept registered letters.
Committee Members also asked whether Royal Mail's current six-day
parcel service was a commercial decision or whether it was a regulatory
requirement imposed by Postcomm.
Clause 30 of the Bill replicates the provisions required
of a universal service by the Postal Services Act 2000. Requirements
one and two require delivery and collection of letters every Monday
to Saturday, and parcels and packets every Monday to Friday.
Requirements four and five require a registered and insured items
service.
In response to the Committee's queries we can therefore
confirm that the definitions within the Bill are such that a registered
letters service must be provided from Monday to Saturday
and a registered service for other postal packets from Monday
to Friday. We can also confirm that there is no legal or contractual
requirement on Royal Mail to provide a six-day parcels service
- it is a purely commercial decision for the company.
The Bill replicates the current legislative requirements
under the PSA 2000 and the proposals by the last Government in
their 2009 Bill. In respect of letters (registered and not),
this gold-plates the European Directive which requires a minimum
of delivery on five working days a week.
Given the changes in the market identified by Richard
Hooper, and the potential threat these pose to the universal service,
we believe that now is not the time to hard-wire into legislation
any more onerous requirements on the universal service provider
than are already imposed. To do so could risk the provision of
the universal service.
It is possible for more onerous requirements to be
imposed by Ofcom through their Universal Postal Service Order,
if this was in line with the needs of users. We believe it is
vital that regulatory requirements are only imposed where there
is a genuine need, and hence that they are determined by Ofcom
in the light of evidence they gather from the market and from
users. They must also be in line with Ofcom's overarching duty
to secure the provision of the universal postal service. The
Committee may be particularly interested to note that in undertaking
all of their activities in relation to postal services,
Ofcom will be bound by their statutory general duties as set out
in the Communications Act 2003 (although should there be a conflict,
their duty to secure the universal postal service will take precedence).
Under this they must take into account the needs of a range of
users, including 'the different interests of people in different
parts of the UK, including those in rural and urban areas'.
Despite there being no legislative or licence requirement
for a six day a week service now, Royal Mail does deliver parcels
six days a week anyway - because to do so makes commercial sense.
This part of the market is highly competitive and so, in line
with regulatory best practice, we are keen to avoid unnecessary
regulation, particularly as Ofcom's duties will ensure the reasonable needs
of users, across all areas of the country, are met.
In terms of what a six day a week registered letters
service means for Post Office opening times, Ofcom are required
by clause 28(4) of the Bill to carry out their functions in a
way that believe will secure the provision of sufficient access
points to meet the reasonable needs of users of the universal
postal service. So Ofcom will have a statutory duty to ensure
that users are able to access the services that are part of the
universal postal service.
More broadly, the Government's recent policy statement
on the future of the Post Office network set out both its commitment
to no further programme of closures and its long-term strategy
for securing a sustainable future for the Post Office. Key to
this will be enabling the network to change in response to what
customers really want: greater convenience through longer opening
hours, quicker service and accessibility in well positioned locations.
During the session we touched on the Post Office
Local model, which is in its pilot stage with over 50 pilots across
the UK. The Post Office Local model is designed with the consumer
in mind and is able to offer longer opening hours and quicker
service. The Government believe that this model is particularly
appropriate for many smaller sub-post offices across suburban
and rural Britain. Initial findings from the pilot locations
show that, on average, post office services provided through a
'Local' branch have been available for more than six hours extra
per day than previously. However, this does not mean a significant
reduction in services offered: 86% of post office services are
available through Post Office Local, including all core products
such as posting letters and parcels, paying bills and collecting
pensions and pre-ordered travel money.
GUIDANCE ON
RE -OPENING
POST OFFICES
The Committee enquired about time taken to re-open
Post Offices.
The current approach to temporary closures (as set
out in the Code of Practice between Post Office Ltd and Consumer
Focus on Changes to the Network in April 2009) is that Post Office
Ltd will always work to get the branch re-opened. Post Office
Ltd do not put a time limit on this process, although it is realistic
to say that if the company have not been able to find a solution
within the first 12 months (for example, if no-one comes forward
to run the office), the likelihood of re-opening diminishes and
the company will prioritise its resources to try and find solutions
elsewhere. However, if an opportunity to re-open on a sustainable
basis in the locality does subsequently arise, Post Office Ltd
will actively consider this. Alternatively, if the company decide
that they no longer require a facility in that general location,
then they will put that matter to a public consultation in accordance
with the Code of Practice. If a closure results in Post Office
Ltd being in breach of the access criteria the company is of course
under a legal obligation to reopen the branch with no exceptions.
Changes to opening hours may also require a public
consultation under the terms of the Code of Practice. The Code
of Practice retains necessary flexibility about what constitutes
a 'minor' change and therefore does not require consultation,
but it is highly likely that a change as significant as the ending
of Saturday opening would require consultation. This would particularly
be the case if Saturday represented a major part of the opening
pattern of the branch concerned and/or where there were no very
close alternative facilities on Saturdays.
POST OFFICE
EQUALITY DUTIES
The Committee raised concerns about access to Post
Offices with stairs and we undertook to provide further information
on Post Office Ltd's duties under the Disability and Discrimination
Act 1995.
Post Office Limited is itself responsible for compliance
with the Act in respect of access for disabled people to its services
at Crown Post Offices and subpostmasters are similarly responsible
for DDA compliance for the post office services that they provide.
Post Office Limited works with subpostmasters to assist them in
identifying any problems at their branches and to support them
in making adjustments where possible to assist with DDA. Post
Office Limited has set up a fund that contributes towards improvements
in subpostmasters premises in terms of DDA. In some locations
there will however be space, planning or topographical constraints
on what can be done to facilitate disabled access.
Additionally, Post Office Limited has recently conducted
access audits across the whole of the Post Office branch network.
As part of the audit, information on accessibility and other facilities
such as low payment counters, induction loops and alternative
languages available at Post Offices was gathered.
The information on Post Offices can be found at www.directenquiries.com
and forms part of the national access register that they have
developed in conjunction with RADAR and the Employers Forum on
Disability. By selecting Post Offices as the featured location
and then a geographic area a customer can see the Post Offices
in that area and the facilities that are offered, enabling them
to make decisions on which Post Office to use.
A link to the information is also available through
the Post Office Limited website by clicking on accessibility at
www.postoffice.co.uk
MAILWORK CENTRES
The Committee requested a list of the Post Offices
that share space with Royal Mail (known as Mailwork centres) in
Scotland. The full list, as supplied by Post Office Ltd, is attached
to this letter.[41]
23 November 2010
41 Not printed. Back
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