Royal Mail and the Postcode Address File – epetition response

Number Ten Downing Street wrote a response to the petition

“We the undersigned petition the Prime Minister to release the address
and postal code data held within the Royal Mail’s PAF to the public.”

In short they are saying, "not our problem, talk to Postcomm".  Some feel this is a cop-out, but nevertheless it is their policy to pass on the issue to the regulator.  After all:

Under Section 116 of the Postal Services Act 2000,
Royal Mail must maintain the PAF and make it available to any person
who wishes to use it on “such terms as are reasonable”.  This
requirement is replicated as a condition of Royal Mail’s licence.

If the Royal Mail are not abiding by the terms of their licence then their regulator should be asked to make sure they do.

Provision exists for Royal Mail to recover a reasonable
charge for the supply of PAF.  However it must not impose any term or
condition other than reasonable restrictions to safeguard its
intellectual property rights (IPR), and to ensure that the PAF and its
updates are used to support effective addressing.

So the question is whether £3,750 for a click-per-use licence is a reasonable charge or not.  Does this mean the Royal Mail is permitted to make a profit on the sale of licences for the PAF? Are they able to recoup the cost of creating and maintaining the database or should that cost be accounted for with the efficiencies they gain from accurate addressing on their delivery operation?

It isn't going to be easy to win this battle.  The Royal Mail won't want to give up the licence fees; many of their existing customers won't because it may lower the barriers to entry into their market.

No. 10 seem to have passed the buck and therefore it may be time to write to Postcomm.  But what will make them take action?  Pressure from politicians of course (although Messers Clarke and Thurso have yet to acknowledge reciept of an email). Pressure from the press, possibly.  Pressure from the public, it can't hurt.  Clear evidence that Royal Mail are in the wrong, perhaps?

Even with the right strategy, the basics won't be easy.  Postcomm don't make it easy to contact them.  They mostly try to get you to contact the Royal Mail and then offer a single info@psc.gov.uk address.  Which of course auto-responds "Out of Office" telling you to complain about the Royal Mail to the Royal Mail and promising a response within 7 days "If your query relates directly to Postcomm or our policies"

Ho-hum.  Let's keep trying.

UPDATE:  Philip Groves from Postcomm has responded and asked that I send  my complaint to him.  His email is firstname.lastname@psc.gov.uk