0.1.1 Postal reform
The move towards postal service reform commenced with the publication of a Green Paper opening a public consultation on the development of a single market for postal services (COM(91) 476 final)1. The process culminated in directive 97/67/EC2 of the European Parliament and Council of 15 December 1997. The directive established common rules for the development of the internal market of Community postal services and improvement of quality of service. Directive 97/67/EC “put in place a harmonised regulatory framework for the Community postal sector and defined the decision making process regarding further opening of the postal market to competition.” Director of Telecommunications Regulation (2001).It took until 2000 for directive 97/67/EC to be transposed into Irish law under the “European Communities (Postal Services) Regulations 2000”3. The following year Ireland’s Office of the Director of Telecommunications Regulation (OTDR) established a public protocol and procedure for taking account of the views of parties interested in the sectors under her control. A particular responsibility of the OTDR was to manage the definition of Ireland’s interpretation of the Universal Service Obligation (USO) and to monitor and regulate the performance of mandated universal postal service providers4. The USO applied to the public collection and delivery of mail.
Universal service providers must guarantee one clearance, and subject to derogation, one delivery to the address of every natural or legal person in the State five days a week.(Director of Telecommunications Regulation, 2001, pp. 3)
The USO defined a ”Reserved Area”, a designated legal monopoly in which mail services were supplied as a type of public good, albeit one that should be paid for by its users. However close regulation of the reserved monopoly was required by law to ensure that price setting was fair and that designated Universal Service Providers would not subsidise operations from a competitive area with profits from a Reserved Area activity or vice versa, thereby gaining unfair competitive advantage.
0.1.2 Problematising the absence of a postcode
The Irish postal service had heretofore operated according to a simple, perhaps elegant, balancing rule based on population density, collection point location and delivery frequency. Each collection point (postbox) is maintained and monitored according to the anticipated volume of items posted balanced against distance between collection points rather than according to predesignated Postcode areas. Similarly delivery routes, while relatively stable and based around the concept of post towns, may change in coverage, breadth, depth and frequency according to season, use, and social concentration. The policy as operated by An Post has allowed for responsive adaptation to demographics, changing volumes and composition of mail. And although the very idea of a postcode is ubiquitous and is an implicit understanding of what constitutes a post service in the vast majority of countries, somehow Ireland, contrary to the experience of the rest of the World, has achieved all this without using a national postcode system. Ireland’s An Post achieves this using OCR (optical character recognition), a comprehensive and accurate address database, automated sorting machinery, internal routing, planning and logistics systems hidden within its delivery apparatus.
0.1.3 Consultation, using postcodes as a lever to enable competition
Against this backdrop, directive 97/67/EC was introduced, aiming to address two potentially contradictory principles: the continuing provision of an affordable high quality universal postal service for society in each member state, but to also open postal services to competition through liberalisation of the postal market. In 2002 the Director of Telecommunications Regulation opened a consultation process into the status of Postcodes in Ireland. (Office of the Director of Telecommunications Regulation, 2002) The Director opened the consultation with the following statement...
“The paper also raises the very interesting question of why Ireland is only one of two countries in the EU without a proper Postcode system.” [emphasis added]
...and that “Apart from Greece, Ireland is the only European member state that does not use a postal coding system.”
Office of the Director of Telecommunications Regulation (2002, pp. 6)
The consultation paper went on to pose the following questions to stakeholders “What do you see as the advantages and disadvantages of introducing Postcodes in Ireland? Which would be the most appropriate organisation to allocate them, and how should it be funded?” Office of the Director of Telecommunications Regulation (2002, pp. 21) It dealt specifically with the problem of correct addressing and focused on the use of postcodes to improve this issue. Four examples of confusing addresses were provided (no personal detail, simply village or town name and two or three alternate county locations). The argument drew on the Universal Postal Union’s belief that a postcode is a fundamental, essential element of an address and that of 105 UPU members, only Ireland and Greece, within the EU, do not use a postcode. The regulator also referred to bulk mail providers (then An Post’s own customers) seeking the introduction of an agreed Postcode system and barcoding in order to pre-code and pre-sort mail, in order to pay lower fees. Mention was also made of Utility and Emergency services desiring to use a National Postcode system to improve location identification. The final case was of the benefit to firms using Postcodes in other countries for credit scoring consumers and customer relationship management systems.
0.1.4 ComReg and a postcode in its sights
In December 2002 the Commission for Communications Regulation (ComReg) was founded and replaced the Office of the Director of Telecommunications Regulator (ODTR). Etain Doyle, the previous Director of Telecommunications Regulation was appointed the first chairperson of the Commission.
On the 18th of December 2002 ComReg extended the deadline for submissions on the consultation started by the OTDR. The announcement stated
“it appears that there is a significant case for the introduction of Postcodes in Ireland”, then continued; “While An Post do not currently see the need for such a system there are many other players in the Postal Sector and wider who say they would like to see Ireland using the same system as most other countries.” Commission for Communications Regulation (2002)
On 13 May 2003 ComReg released its decision notice and response to the consultation process. In introducing this report Etain Doyle restated the key motivations for the consultation, in particular addressing “the very interesting question of why Ireland is one of the few countries without a proper Postcode system.” (Commission for Communications Regulation, 2003)
The consultation had unexpectedly attracted over one thousand responses, private citizens had reacted to a proposal to mandate the introduction of rural roadside letter boxes for delivery rather than delivery to addresses. On the proposal for a national postcode system it seemed “...that the case for postcodes is even stronger than we believed.” (Commission for Communications Regulation, 2003, pp. 6).
There was broad support from industry, from bulk mailer business, utilities and emergency services. It was noted that such a postcode system would help “facilitate credit scoring by financial institutions, health risk analysis by the Health Boards and other bodies who depend on statistical information in the compilation of various studies of general interest.” (Commission for Communications Regulation, 2003, pp. 42). The Central Statistics Office (CSO) stated “there would be major benefits to the overall statistical system.” Some respondents went so far as to propose Postcode designs and drafts of systems. In contrast An Post did not support the idea of introducing a National postcode, arguing that it was unnecessary given the proven effectiveness of its OCR, address database and automated sorting facility. An Post also pointed out that eventual user adoption and compliance could be problematic and likely result in problems and confusion.
0.1.5 Identification with place
However many rural respondents voiced opposition to the introduction of Postcodes. ComReg observed that:
“the basis for opposition was primarily in relation to the loss of townland names and the strong local history which was part and parcel of those names. Others objected stating that it would only create another layer on the address, that the knowledge of the local post person was sufficient to ensure delivery to the correct address.” (Commission for Communications Regulation, 2003)
ComReg determined however that there was an...
“overwhelming case for investigating the issue of introducing a postcode system in Ireland particularly when the An Post postman is no longer the only person making deliveries. ” (Commission for Communications Regulation, 2003, pp. 43)
ComReg’s position was clearly informed by the intent of Directive 97/67/EC in which it was envisaged that multiple Universal Service Providers could operate the USO under license by the Government. A public National Postcode system facilitating address disambiguation would facilitate this strategy. ComReg concluded however by stating that further investigation was necessary and proposed to convene a National conference to gather all stakeholders to further consider the issue of introducing a postcode system into Ireland.
0.1.6 The Symposium on Postcodes
At the Symposium on Postcodes in 24 November 2003 the chairperson of ComReg, Etain Doyle, set out the case for introducing a Postcode system. In spite of An Post’s achievement in applying OCR, their address database and automated sorting technology so that, for An Post at least, a Postcode for address disambiguation was unnecessary, Doyle stated that “postal services are no longer the preserve of national state-owned Post Offices”. (Doyle, 2003) Doyle concluded by stating that a publically available Postcode was necessary for service providers both within the postal sector and beyond. Further, by virtue of being publically available, simple and intuitive, that a National Postcode may even replace map references or Geo codes for location finding. Discussing public concerns of the possible loss of townland names and the cultural connections between place names, people and local history, she called the issue a “red herring”, stating that “You can have codes for the existing names right down to individual houses.” Doyle posited the case of a woman attending a clinic to screen for breast cancer and the possible ways her address (Ballylanders) may become disconnected from the actual location (in Limerick or Cork?). She offered other examples highlighting the value of postcodes to facilitate internet and telesales, enable direct mail marketing, simplify the centralisation or outsourcing of services so that local knowledge would no be longer required, and its use to utility companies and emergency services to quickly identify address locations. In terms of other benefits, a public alternative to An Post’s internal address identification system would reduce An Post’s unintended competitive advantage and act as an enabler for competition in the Irish market for Postal services.
“The volume of mail delivered to each household in Ireland is among the lowest in Europe, largely because the Direct Mail market is so underdeveloped. If postcodes had been introduced 10 or 20 years ago, when they were being introduced in other countries, would this most important part of the postal sector have developed differently? Would the introduction of a postcode now help to address this deficit?” (Doyle, 2003)
0.1.7 Yet another consultation
Four days after the Symposium on Postcodes ComReg launched a new public consultation specifically on Postcodes. The consultation document set out and explained the drivers for a public Postcode system and asked 13 new consultation questions related to the Postcode issue. The arguments put forward for a public National Postcode system included:
1. An Post’s own system was costly and difficult to port into other organisations and it had no user facing element.
2. A new postcode would take advantage of the most modern current technology.
3. It would assist emergency and utility services.
4. Facilitate electronic commerce and Internet services that require postcode information for user/address validation.
5. Reduce the potential for post delivery errors due to address ambiguity.
6. To facilitate direct mail marketing industry.
7. Simple intuitive postcodes could help people reach destinations.
8. It could help spatial epidemiological (medical) research.
9. It would help spatial research of social and economic programmes.
On 26 January 2005, ComReg released its report on the Postcode debate spanning its development over 2001-2003 and ComReg’s own subsequent research (Commission for Communications Regulation, 2005d). The report stated that there was broad support for the introduction of a public Postcode, detailing the benefits of the proposed change and introducing a principles based approach for how the Postcode and associated systems would be realised. It also took great care to address the concerns that had been expressed by the general public around the loss of placenames in addresses and their links with local culture and heritage. The report also organised the benefits of a public National Postcode under three broad themes rather than as a lists of benefits/benefactors.
The three thematic principles/goals were:
1. Providing a unique address without loss of local identity.
2. innovation, efficiency and competitiveness.
3. Government sector desire for a Small Area Spatial Code.
A crucial issue was to overcome how post delivery currently relied on personal ’local knowledge’. Isolde Goggin, the new Chairperson of ComReg, explained that the need for a unique address could be achieved without any loss of local identity.
“An Post had traditionally relied on the local knowledge of the postman and his/her familiarity with the addresses served, in order to effect correct delivery.” (Commission for Communications Regulation, 2005d)
Deep local knowledge is implicitly valued in Irish society. However commercial enterprises, in this case other Postal Service providers, encounter barriers to entry to the postal market because this local, contextual knowledge is not codified. An Post inadvertently benefits from its long term social and technological investment in learning and sustaining local knowledge, obviating the need for public spatial codes in addresses in order to facilitate postal sorting. Whereas other suppliers and stakeholders insist that the “availability of a public postcode is a vital aspect of the national economic infrastructure.” If instead there was a freely accessible public national postcode system it would lower the barriers to spatial address data for all stakeholders. A public postcode would also allow International companies to achieve the correct routing of addresses that may also, by right, be written in Irish. A postcode could overcome the need for Irish language translation and local knowledge.
0.1.8 Next steps toward a National Postcode Project
On January 26 2005 The Chairperson of ComReg announced that...
“Having considered all the submissions and arguments for and against, ComReg believes that there is broad support for the introduction of postcodes to Ireland. The evidence from other countries demonstrates that the use of postcodes can contribute to competitiveness and national development. ComReg also believes that it is possible to introduce a system of postcodes that will not affect historical and traditional townland names, particularly in rural areas. ” (Commission for Communications Regulation, 2005a)
This report adopted a more conciliatory note on the relationship with An Post than previously and stated that “a postcode system in Ireland should therefore be developed by all postal service providers for the benefit of that sector as a whole.” (Commission for Communications Regulation, 2005d). It highlighted An Post’s stated preparedness to work with a public postcode although it had neither the finances or resources to develop the system independently.
ComReg then proposed the formation of a new working group involving all key actors in the postal services industry and tasked with producing an outline business case and implementation plan for a new national postcode. ComReg set out additional specific and general requirements or issues to be addressed by the working group and referred to the Government decision in favour of a public postcode. The working group returned with its report of April 2005 recommending the following \citep{The2005aa}
1. A postcode system would have national benefits and should be commenced immediately.
2. Project managers should be appointed post haste (est charge 200-300k).
3. Project managers should be assisted by a National Postcode Project Board.
4. Project managers and proposed NPPB should conclude cost/benefit analysis for Dec 31 2005.
5. Subject to caveats the target date for implementing a postcode should be no later than 1st January 2008.
The initiative was also linked to the Cabinet decision supporting the report of the Steering Group on Social and Equality Statistics (SGSES) which proposed a national system of spatial classification to facilitate the Government and other public agencies.
The Small Area Spatial Code initiative incorporated the specific spatial coding requirements of the National Statistics Boar (NSB), Senior Officials Group on Social Inclusion (SOGSI), Central Statistics Office (CSO), National Economic and Social Council (NESC), and the Steering Group on Social and Equality Statistics (SGSES).
7 principles were proposed that the Postcode proposal should satisfy (Commission for Communications Regulation, 2005d)...:
1. It must be a public code.
2. Depth of coding to be structured to the level of specific spatial areas.
3. It must be easily memorised.
4. It must not require changes in the names of peoples’ townland, parish or county.
5. It must be competitively and socially neutral.
6. It must be self financing and/or of minimal cost to use.
7. And an appropriate public ownership structure (IPR) must be agreed.
The National Postcode Project Board (NPPB) was appointed and its first meeting took place on May 1 2005. Tasked by Noel Dempsey, Minister for Communications, Marine and Natural Resources, it was to represent stakeholders and govern the Postcode project. Soon after (23 May), on the instruction of the minister, ComReg announced its intention to hold a tender process for the design of the public postcode system (Commission for Communications Regulation, 2005b) for implementation and roll-out on January 1, 2008 (2005_Update31May-3June2005.doc).
References
- Commission for Communications Regulation (2002), ‘New postal proposals require public input’, Media release.
- Commission for Communications Regulation (2003), ‘Postal services - universal service obligation, tariff principles and miscellaneous issues’, Decision Notice & Response to Consultation.
- Commission for Communications Regulation (2005a), ‘Comreg report shows broad support for the introduction of postcodes to ireland’, Press release.
- Commission for Communications Regulation (2005b), ‘Comreg to hold a tender process for design of postcode system’, Press release.
- Commission for Communications Regulation (2005c), ‘Contract for the format of the proposed irish postcode system awarded’, Press release.
- Commission for Communications Regulation (2005d), ‘Postcodes’, Report.
- Communication from the Commission (1991), ‘Green paper on the development of the single market for postal services’. (COM(91) 476 final).
- Director of Telecommunications Regulation (2001), ‘Regulation of postal services – procedures for seeking the views of interested parties’.
- Doyle, E. (2003), ‘Comreg’s symposium on postcodes: Introduction by chairperson’, Speech.
- European Commission (1997), ‘Directive 97/67/ec of the european parliament and of the council’.
- Minister for Public Enterprise (2000), ‘S.i. no. 310/2000 - european communities (postal services) regulations, 2000’.
- Office of the Director of Telecommunications Regulation (2002), ‘Regulation of postal services - universal service obligation, tariff principles and miscellaneous issues’.
