PAF – Initial Postcomm response
A month ago I wrote to Ken Clarke and John Thurso asking them to add their support to Tom Watson's correspondence with the Royal Mail over the Postcode Address File and providing access at a reasonable cost. Ken Clarke passed me on to Jonathan Djanogly, Shadow Spokesperson on the Post Office. He has written to Postcomm on the matter and has replied to me with their response.
I think Jonathan has pretty much cut'n'pasted their response so I'm not clear on what are his views and what is the response from Postcomm.
The key sections are:
Postcomm also ring-fenced PAF within Royal Mail and limited the profit margin that Royal Mail can make on the provision of PAF to 8-10%.
I'm not sure the Royal Mail should be making a profit at all. No.10's petition response indicated that the terms were to protect IPR. They don't mention a profit however reasonable.
Postcomm also set up an independent Advisory Board to advise Royal Mail on various issues concerning PAF including licence fees, and data quality and Postcomm also monitor its accounts.
I had expected this to be part of RM's defence. However the Advisory Board consists of existing customers of the PAF. This is a group of people and organisations whose business interests are served by high barriers to entry rather than a small (to them) reduction in cost. £3,750 (the cost of a PAF Click-Use licence) is very insignificant to a million point turnover business but quite substantial to new entrant to the market trying to test a concept.
This next bit is critical:
The bulk of the costs of providing PAF arise through the maintaining and updating of information in the file which is done with the help of delivery staff all over the country via a service level agreement. Postcomm expect Royal Mail to charge fees sufficient to recover those costs provided they are reasonable.
If this is true it represents the crux of the matter. If I am reading this right then users of the PAF are paying to keep the Royal Mail efficient. This cross-subsidisation for a ring-fenced asset is wrong. It artificially increases the cost of the PAF and therefore raises barriers to entry to potential users of the PAF.
Finally there is the promise that it will all be sorted:
discussions are near an end and Postcomm understands that Royal Mail will publish its final plans before the end of this year with a suitable time frame for implementing the changes.
There is a danger that without sufficient pressure that PostComm will accept Royal Mail and their biased Advisory Board's recommendations. Unless we see a much more transparent, cheaper, and fairer route to using the PAF a large number of socially useful sites will not see the day of light. It will be a massive opportunity lost.
What can we do about it? More pressure from politicians. More pressure from us the public and industry on both the politicians and Postcomm. Write to Philip Groves at Postcomm [philip dot groves at psc.gov.uk] who is handling complaints about the PAF. Write to Lord Young of Norwood Green, the "post Office" minister, write to Jonathan Djanogly, the conservative Post Office spokesperson, write to John Thurso from the Lib Dems (actually I wouldn't bother he still hasn't responded to the first two emails on this.)