The building blocks for a sustainable postal service

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1 The building blocks for a sustainable postal service Proposals to remove bulk products from the universal service and clarify the status of other universal service products a consultation February 2011

2 In this document, Postcomm consults on the removal of bulk products from the universal service. Postcomm also explains that it considers that Printed Postage Impression (PPI) is a payment channel like stamp and meter, and that PPI First and Second class single piece items should be considered to be part of the universal service. Finally, Postcomm clarifies the status of certain services within the universal service, as originally set out in its 2004 decision on the universal service. Key conclusions: Postcomm summarises research findings which confirm the importance of the universal postal service to customers today. Postcomm sets out evidence on bulk customers needs and changes in the market. This evidence seems to indicate that bulk products should be removed from the universal service. Postcomm considers that PPI and meter are payment channels, and that for single piece mail all payment channels should be clearly included within the universal service. Postcomm provisionally concludes that it is appropriate to clarify the composition of the universal service in Royal Mail s licence to include PPI single piece mail, and Recorded Signed For, Redirections (up to 12 months), Keepsafe, Poste Restante, Certificate of Posting, and Business Collections, as set out in its 2004 decision on the universal service.

3 Key proposals: Postcomm proposes a modification of Condition 2 of Royal Mail s licence to: remove the remaining bulk products from the universal service, Mailsort 1400 First and Second class and Cleanmail; include Printed Postage Impression (PPI) First and Second class single piece items; and include Recorded Signed For, Redirections (up to 12 months), Keepsafe, Poste Restante (free), Certificate of Posting (free), and Business Collections. Postcomm also proposes a definition of single piece items in relation to First and Second Class mail. Expected impact: We consider that removing bulk products from the universal service will benefit bulk customers by giving Royal Mail more commercial freedom to adapt these services to customers needs. It should also encourage a more level-playing field between operators in the provision of bulk services. Our evidence indicates that bulk mailers are more concerned with low prices than the key features of the universal service. In relation to the confirmation of universal service status for other specific services, Postcomm aims to replicate the generally understood regulatory position of these products, and has identified no likely material impacts arising as a result of the implementation of these proposals.

4 Consultation questions: Q1: Do you agree that references to bulk mail, and specifically Cleanmail and Mailsort 1400 (First and Second class), should be removed from Condition 2 of Royal Mail s licence and therefore from the universal service? Please explain your reasons to support or oppose the removal of bulk products from the universal service. Q2: Do you agree that stamps, meter and PPI are payment channels in relation to single piece items and therefore ought to be treated in the same way in terms of their universal service status? Q3: Do you agree with our proposed definition of single piece mail? If not, can you suggest an alternative? Q4: Do you agree that we should therefore modify Royal Mail s licence to include PPI First and Second class single piece mail in Condition 2? Q5: Do you agree that First and Second class single piece PPI mail should be subject to the same quality of service targets as stamped and metered mail and that we should modify Condition 4 accordingly? Q6: Do you agree that we should modify Royal Mail s licence to clarify that Recorded Signed For, Redirections (up to 12 months), Keepsafe, Poste Restante, Certificate of Posting, and/ or Business Collections should be provided as universal service products? Q7: Do you agree that the quality of service for single piece items that are sent via Recorded Signed For, Redirections (up to 12 months), Keepsafe, and Poste Restante, and the quality of service for Business Collections is already driven by Royal Mail s existing quality of service targets for First and Second class mail and collection points? Do you agree that there should be no additional quality of services targets specific to these services? Do you agree that the target for Certificate of Posting should be that all customers requesting a Certificate of Posting receive one?

5 Summary Summary S.1 In our Forward Work Plan and in our May 2010 consultation document on proposals for a new regulatory framework 2, we said we would review the universal service. This document follows from our workstrand on the universal service and reviews the option of removing bulk products from the universal service. It also clarifies, in other respects, the existing composition of the universal postal service that should form the basis of Royal Mail s licence under both the current regulatory framework and, in turn, the composition of the universal service under the new regulatory regime proposed by the Postal Services Bill 3 ( the Bill ), assuming the Bill is enacted in its present form. S.2 This document is accompanied by a formal proposal for a modification of Condition 2 of Royal Mail s licence ( Condition 2 ) Provision of universal postal service in the United Kingdom, and related changes to Condition 4 Services, standards of service and compensation 4 ( Condition 4 ), which begins the formal process necessary to make changes to Royal Mail s licence. We believe that it is prudent to commence the formal process so that, if appropriate, we are in a position to implement our decision before the Bill receives Royal Assent. The proposed licence modifications simply reflect what is set out in this document. However, we emphasise that this does not mean that we have prejudged the outcome of this consultation, merely that, if the outcome of the consultation is that we should make all or any of the changes suggested to the universal service, we are able to do so quickly. S.3 Following our Forward Work Plan and our May 2010 consultation document setting out that we would review the universal postal service, we published the findings of our extensive research on the needs of customers from the universal service, commissioned jointly with Consumer Focus, in November We have also published a report by Frontier Economics updating its 2008 findings 6 on the net cost of certain elements of the universal service 7, and our views on the affordability of the universal postal service 8, alongside this document. 1 Postcomm, Forward Work Plan , 2 Postcomm, Laying the foundations of a sustainable postal service, May 2010, 3 Introduced to Parliament in October The Postal Services Bill as introduced to the House of Lords is at 4 Postcomm, Licence granted to Royal Mail Group Limited, March 2001, as subsequently amended 5 TNS-BMRB, Customer needs from a sustainable universal postal service in the UK, November 2010, 6 Frontier Economics, Net costs of elements of the universal service, May 2008, 7 Frontier Economics, The net cost of elements of the universal service an update, February 2011, published on the same day as this consultation and available on our website, 8 Postcomm, Discussion paper on affordability, February 2011, published on the same day as this consultation and available on our website, i

6 Summary S.4 Our research shows that bulk mailers appear to value low prices rather than any specific features of the universal service, in particular uniform pricing. Due to changes in market conditions, there are now also alternatives to Royal Mail s bulk services. This evidence indicates that it may no longer be necessary to have bulk products in the universal service to meet the needs of bulk customers. Industry stakeholders have been discussing this issue for some time and, in light of the evidence we have gathered to date, we consider that it is appropriate to consult formally on this issue, in particular to gather further views from the users of bulk products. S.5 In line with our decision in 2004 about the composition of the universal service, we also aim to clarify the current composition of the universal service, as a basis for the initial conditions 9 which will be set by Ofcom. We consider that this will help a smooth transition to the new regulatory regime, in addressing some uncertainty about the status of these products. S.6 In Chapter 1 we discuss the objectives of, and the background to, this consultation. We outline our work on a new regulatory framework for 2012 in the context of the Postal Services Bill. Amongst other major proposals, the present provisions in the Bill retain the regulator s primary universal service duty, re-affirm the key features of the universal postal service, and transfer regulatory responsibility for postal services from Postcomm to Ofcom. S.7 The Bill also establishes an authorisation regime closely modelled on that in the electronic communications sector. It provides for a number of different forms of regulatory conditions to be imposed on the universal service provider and other operators. The Bill provides that Ofcom must ensure that initial regulatory conditions applicable to postal operators are similar to the licence conditions in place immediately before it assumes regulatory responsibility for postal services. This means, in effect, a transposition of the current licences into the general authorisation regime established by the Bill, as a starting point. S.8 With this in mind, Chapter 1 outlines how this consultation will assist in ensuring a smooth transition into the regulatory regime proposed by the Bill in relation to the composition of the universal service. S.9 In Chapter 2 we discuss the basis of the universal service. The key features of the universal service are set out in primary legislation, in essence: collection and delivery of post everywhere in the UK, at the same affordable uniform price, every working day 10. The Bill reflects the current essential features of the universal service when it describes the minimum requirements of the universal 9 Postal Services Bill, Schedule 9, as introduced to the House of Lords 10 Postal Services Act 2000, section 4, ii

7 Summary service 11. The products listed in Condition 2 of Royal Mail s licence at the moment, and which Royal Mail is obliged to provide in the discharge of its universal service obligation, are: First class stamped mail and First class metered Second class stamped mail and Second class metered Standard Parcels Airmail and Surface Mail Special Delivery Next Day Cleanmail (this does not include the new Cleanmail Advance Product) Mailsort 1400 (First and Second class only, not Third class) International Signed For, when sold with single piece air mail and surface mail services S.10 In Chapter 3 we provide the background to Postcomm s decision in 2005 to retain Cleanmail and Mailsort 1400 First and Second class in the universal service. We present evidence on relevant developments in the market since 2005, about recent usage of the universal service bulk products, bulk customers needs from the postal market, and the provision of bulk mail services by other postal operators. S.11 Our research into the needs of bulk mail users from the universal service shows that they prioritise the importance of low-price bulk products, but that they place less value on the key features of the universal service, in particular accepting the concept of zonal pricing. The provisional conclusions of our market study also shows that the bulk mail market is increasingly competitive, although Royal Mail retains market power in these markets. S.12 We also consider that it is unlikely that Royal Mail would stop providing bulk products, or indeed the current universal services on a universal basis, as long as there is demand for these products. This is because of the significant contribution that bulk products make to the financing of the universal service and the fact that Royal Mail continues to have to collect and deliver single piece mail on a universal basis. S.13 In Chapter 4 we provisionally conclude that stamps, including Smart Stamps, meter and Printed Postage Impression (PPI) are all payment channels used for the same postal product. Accordingly, Postcomm considers the First and Second class single piece postal products provided by Royal Mail to be part of 11 Postal Services Bill, clause 30. The Postal Services Bill as introduced to the House of Lords is at iii

8 Summary the universal service, irrespective of the payment channel used. We propose a modification to Condition 2 of Royal Mail s licence to clarify this, and we propose the following definition for the purposes of Condition 2 to clarify the meaning of single piece in relation to universal service products paid for by PPI, meter and stamps, as: the service of conveying postal packets 12, with no value added services or premium attributes, at a price which is not subject to any discounts related to volume of mail per mailing or presentation of mail, and regardless of payment channel used. S.14 In Chapter 5 we explain that, in 2004, Postcomm decided the following products should also be provided as part of the universal service: Recorded Signed For Redirections (up to 12 months) Keepsafe Poste Restante (free) Certificate of Posting (free) Business Collections S.15 These products are, however, not currently listed in Condition 2 of Royal Mail s licence. We therefore propose to include them in Condition 2 in order to clarify and confirm their universal service status. 12 The term postal packet is defined by section 25 of the Postal Services Act 2000 to include both letters and packets: postal packet means a letter, parcel, packet, or other article transmissible by post, iv

9 Contents Contents Summary... i Chapter 1: Introduction... 1 Building a new regulatory framework for This consultation... 2 Chapter 2: The universal service... 9 What is the universal service?... 9 Reviewing and clarifying the postal products which must be provided as part of the universal service.. 11 Research into the needs of customers from the universal service Customer Interest Forums Chapter 3: Removing bulk products from the universal service Background Evidence on changing customers needs Implications of removing bulk products from the universal service Chapter 4: Single piece products in the universal service Stamps, meter and PPI are payment channels Implications for the single item products and their associated payment channels Chapter 5: Support services and other services to be included in Condition Support services considered part of the universal service Resolving the status of these products Appendix A: Glossary Appendix B: Table showing products listed in our 2004 decision on the universal service as part of the universal service Appendix C: Draft Licence modification Appendix D: Impact assessment General Introduction to impact assessments Removal of Mailsort c/ 2c and Cleanmail from the universal service Equality Impact Assessment... 60

10 Chapter 1: Introduction Chapter 1: Introduction Building a new regulatory framework for This consultation is part of a series of documents to be published by Postcomm that set out initial views on the building blocks for a new regulatory framework to be in place from Our aim is to maintain the momentum for much needed change to the regulation of postal services, and to do what we can to help develop a stable regulatory environment that, in particular, safeguards the universal service and protects the interests of customers. 1.2 These proposals are being made while Postcomm retains regulatory responsibility for postal services under the Postal Services Act Since it is intended that regulatory responsibility will transfer to Ofcom under the system set out in the Postal Services Bill 2010 ( the Bill ), both Ofcom and Postcomm have agreed to work together as far as practicable to maintain regulatory stability. 1.3 In developing initial proposals consistent with our current statutory duties, therefore, Postcomm also considers it appropriate to take due account of the likely scope of regulation under the Bill. This means that Ofcom will be able to rely on our work after the transfer of regulatory functions to the extent relevant and appropriate given the new legislative framework under which it is expected to operate. 1.4 Following the publication of this document we will shortly publish consultations on our provisional conclusions on the retail market study for Letters and Large Letters and other products not yet considered in our market study work, and initial proposals for the regulation of access taking account of our review of the current regime. 1.5 In turn these consultations are expected to be followed in March 2011 by initial proposals for the new 2012 regulatory framework, including initial proposals for the regulation of access and, later in March, consideration of the form and structure of a price and quality of service control, including consideration of relevant price controls for access, and accompanying safeguards of product cost transparency and accounting separation. They will also be followed by a consultation on our initial views on the market for outbound international mail. 1.6 Final proposals about the new regulatory framework, informed by our ongoing research and the views of interested parties on all these consultations, are currently expected to be published in late summer We would expect a 1

11 Chapter 1: Introduction final decision to be made about the new regulatory framework in early 2012 and the new regulatory framework to take effect in spring As part of the transfer of regulatory responsibility, Ofcom will need to: consult as soon as practicable after Royal Assent on the initial authorisation conditions to apply to Royal Mail and other postal operators in light of the scope of the licences in place just before the regulatory provisions of the new Act come into force; and consider the scope of the first universal postal service order anticipated by the Bill. This consultation Background 1.8 Our primary duty is to ensure the provision of a universal service. We said in our Forward Work Plan that an objective of our work programme is to put in place a new regulatory framework for 2012 that ensures the provision of a sustainable, affordable universal service that meets customers needs. We explained that we would undertake work to identify what customers need from the universal service now and in the future, and what services it should include and how these ought to be provided. We also said that we would assess whether the universal service is affordable and how affordability should be assessed, and ensure that the interests of vulnerable groups will be fully taken into account in the discharge of our functions. 1.9 In Annex 1 of Postcomm s May 2010 consultation document on proposals for a new regulatory framework 14, we set out more details on how we would review the universal service. We explained that the review had three principal workstrands: Understanding what customers need from a universal service Understanding what affordability means to customers Assessing the net cost to Royal Mail of providing a universal service that meets the needs of customers and is affordable 1.10 Since publishing our Forward Work Plan and our May consultation, we have commissioned research on customers needs and considered further what 13 Postcomm, Forward Work Plan , 14 Postcomm, Laying the foundations of a sustainable postal service, Annex 1: Provision of a universal service, May 2010, 2

12 Chapter 1: Introduction affordability means for customers. In November 2010, we published research commissioned jointly with Consumer Focus, the consumer watchdog, on customers needs from the universal service 15. This extensive research shows that customers use of communication channels is changing, but that they continue to value the postal service. Our research also showed high levels of satisfaction with the current universal postal service In conjunction with this consultation we also publish: An update 16 of the report we commissioned in from Frontier Economics on the net cost of certain elements of the universal service Our views on the concept of affordability in relation to the universal postal service 18 The report from the second wave of Customer Interest Forum meetings The Postal Services Bill was introduced to Parliament in October Amongst other major proposals on postal services, the Postal Services Bill reaffirms the key features of the universal postal service and the minimum requirements set out in the current Postal Services Act. The Bill anticipates that Ofcom will have to specify by order ( a universal postal service order ) the description of services that it considers must be provided as a universal service. Prior to putting in place the first such order, Ofcom will not have to carry out an assessment of the extent to which the postal market is meeting the reasonable needs of users, although it will have to undertake such a review within 18 months of the new regulatory provisions coming into force While the precise legislative framework will not be certain until the Bill has completed its passage through Parliament, we have therefore concluded that, rather than undertake a fundamental review of the composition of the universal service, in the context of the transfer of our regulatory responsibilities to Ofcom, it would be appropriate to do the following: Consult on removing the remaining bulk products from the universal service Clarify the current composition of the universal service - we propose this clarification to ensure an orderly transition to the new regulatory regime once the new legislation is enacted 15 TNS-BMRB, Customer needs from a sustainable universal postal service in the UK, November Frontier Economics, The net cost of elements of the universal service an update, February 2011, published on the same day as this consultation and available on our website, 17 Frontier Economics, Net costs of elements of the universal service, May 2008, 18 Postcomm, Discussion paper on affordability, February 2011, published on the same day as this consultation and available on our website, 19 Synovate, Postcomm Customer Interest Forum, Wave Two- Report, February 2011, published on the same day as this consultation and available on our website, 20 The Postal Services Bill as introduced to the House of Lords 3

13 Chapter 1: Introduction Objectives of this consultation 1.14 This consultation document considers whether Postcomm should remove Cleanmail and Mailsort 1400 First and Second class, the two remaining bulk products in the universal service, from the universal service. We decided in 2005 to retain bulk services and these products in particular to ensure that bulk mailers, particularly smaller volume bulk mailers, continued to benefit from the safeguards of the universal service 21. We undertake this consultation to gather further evidence on whether the changes in the postal market since 2005 support the removal of bulk products from the universal service We think it is appropriate to undertake a consultation on removing bulk products from the universal service now, to ensure that Ofcom is able to rely on the most up-to-date and appropriate composition of the universal service when it rollsover the current regulatory regime during the transitional period This consultation document also clarifies the composition of the universal postal service. In accordance with our 2004 decision on the universal service 22, we confirm that we consider that: Stamps (including Smart Stamps), meter and Printed Postage Impression (PPI) are all payment channels rather than distinct products and Condition 2 of Royal Mail s licence should be clarified to confirm that all relevant single piece products should be included in the universal service. Consequently, the First and Second class single piece postal products provided by Royal Mail are part of the universal service, irrespective of the payment channel used. Some products which Postcomm decided in 2004 were part of the universal service, but which are not currently referred to in Condition 2 of Royal Mail s licence, are part of the universal service. Therefore, in the interests of reducing uncertainty, we propose that those products should be included in Condition Again we consider that this clarification should be helpful in the context of transition to a new regime This consultation document is accompanied by a formal proposal for a modification of Condition 2 of Royal Mail s licence ( Condition 2 ), Provision of universal postal service in the United Kingdom, and related changes to Condition 4, Services, standard of service and compensation 23. Condition 2 is important in defining the composition of the universal service because, in 21 Postcomm, The universal service for bulk mailers, June 2005, 22 Postcomm, Decision document: the UK s universal service, June 2004, 23 Postcomm, Licence granted to Royal Mail Group Limited, March 2001, as subsequently amended 4

14 Chapter 1: Introduction addition to providing a general description of the universal service, it lists the products Royal Mail must provide as part of the universal service. Condition 4 specifies the quality of service standards which certain products and features of the universal service must meet. Our impact assessment 1.19 Impact assessments are an important way of ensuring that we have considered the impacts of major policy proposals. Our decision to produce and publish an impact assessment is made on a case by case basis to ensure that they do not place an undue burden on interested parties and that they are not disproportionate We have included an impact assessment in this consultation about the option of removing bulk products from the universal service (see Appendix D). We have considered whether it would be appropriate to undertake a full cost-benefit analysis for this proposal but concluded that a qualitative impact assessment is sufficient. This is particularly the case because the nature of the impacts of our proposals is difficult to quantify robustly, given the wider market uncertainties and parallel changes proposed to regulation, both of which would need to be reflected in any assumptions we make about what may happen if there were no changes We have not included an impact assessment on the clarification of the composition of the universal service in relation to PPI single piece, Recorded Signed For, Redirections (up to 12 months), Keepsafe, Poste Restante (free), Certificate of Posting (free), and Business Collections. This is because our consultation merely seeks to confirm what we consider to be the current position on the composition of the universal service, rather than making proposals to change it. Structure of this document 1.22 The table below sets out the structure of this document. Chapter Title Description Objective Summary 1 Introduction Provides an outline of the purpose and structure of this document and a proposed timetable for next steps. 2 The universal service Sets out what the universal service is To provide background information in relation to 5

15 Chapter 1: Introduction 3 Removing bulk products from the universal service 4 The single piece product in the universal service 5 Support services and other services to be included in Condition 2 Lists the services to be provided as part of the universal service Explains that we are consulting on removing bulk products from the USO and clarifying the composition of the universal service, but that we are not otherwise undertaking a fundamental review of the universal service Outlines research findings showing that customers continue to value the postal service Presents evidence on usage of the universal service bulk products, bulk customers needs from the universal service, the provision of bulk mail services, and market changes since Postcomm s decision to retain Cleanmail and Mailsort 1400 First and Second class in the universal service Concludes that requiring bulk products in the universal service may no longer be necessary Discusses the implications of removing bulk mail from the universal service Confirms that Postcomm considers that stamps, meter and PPI are payment channels Confirms that Postcomm considers that the First and Second class single piece mail products are part of the universal service irrespective of the payment channel used Clarifies that Postcomm considers products it decided in 2004 were part of the universal service, but are not listed in Condition 2, should be provided as part of the universal service the universal service to support this consultation To invite views on whether Postcomm should remove bulk products from the universal service To discuss payment channels in relation to single piece products To consult on the proposed licence modification to include PPI First and Second class products in Condition 2 To consult on the definition of single piece mail. To consult on a licence modification to include these products in Condition 2 6

16 Chapter 1: Introduction Timetable 1.23 The figure below sets out our timetable to implement our proposals and decisions 24. Views invited 1.24 We welcome views on the issues set out in this document, including our impact assessment, from all interested parties. In particular, we welcome views on the consultation questions which can be found at the end of each chapter and which are summarised at the front of the consultation document Responses should be sent or ed to: Elisa Pruvost Postcomm Hercules House London SE1 7DB 1.26 The closing date for responses is Tuesday 31 May The Licence modification is subject to section 14 of the Postal Services Act 2000, 7

17 Chapter 1: Introduction 1.27 If you would like to discuss any points raised, please contact Elisa Pruvost by telephone or Postcomm will make public all responses to this discussion document, subject to individual requests for confidentiality. If you do not want all or part of your response to be read by anyone outside Postcomm, please ensure that you clearly indicate which part is confidential. If you are happy for your contribution to be made public, but do not want the name of the organisation or individual who signed it to be revealed, please indicate this by adding the following: Name of organisation/ sender NOT to be published. 8

18 Chapter 2: The universal service Chapter 2: The universal service 2.1 This chapter sets out what the universal service is and lists the services to be provided as part of the universal service. 2.2 This chapter also explains that while we are consulting on the removal of bulk products from the universal service, and clarifying the composition of the universal service, we are not otherwise undertaking a fundamental review of the universal service. Finally, we outline research findings showing that customers continue to value the postal service. 2.3 The Postal Services Bill sets out Ofcom s primary duty, and the minimum requirements of the universal service, in a way that is essentially consistent with Postcomm s current primary duty, and which largely replicates the current definition of the universal service under the Postal Services Act We consider that our proposals are consistent with the regulatory regime anticipated by the Bill 25. What is the universal service? 2.4 Postcomm s primary duty is to seek to ensure the provision of a universal service: section 3(1) of the Postal Services Act 2000 requires Postcomm to exercise its functions in the manner which it considers is best calculated to ensure the provision of a universal postal service 26. The importance of the universal service was endorsed by the Hooper review which concluded that the UK s national network strengthens social cohesion by ensuring that everyone, whether in urban, rural or remote areas, has an accessible, reliable means of communication and the capacity to send and receive physical goods 27. The Postal Services Bill 28 also requires Ofcom to secure the universal service: clause 28 states that Ofcom must carry out their functions in relation to postal services in a way that they consider will secure the provision of a universal postal service It is recognised that amendments may be introduced as the Bill passes through Parliament. 26 Postal Services Act 2000, 27 An independent review of the UK postal services sector led by Richard Hooper CBE, Modernise or decline, December 2008, Tthe report is referred to as the Hooper Report 28 The Postal Services Bill as introduced to the House of Lords 29 The relevant clause in the Bill goes on to refer to a number of matters to which the regulator must have regard, specifically the financial sustainability and efficient provision of a universal postal service. Clause 28, Postal Services Bill as introduced to the House of Lords, latest accessed on 20 January

19 Chapter 2: The universal service 2.5 The universal postal service itself is described in legislation. The underlying European Postal Services Directive 30 ( the Directive ) requires Member States to meet certain minimum requirements. The key requirements are: One collection and delivery to all addresses, five working days, in respect of postal items weighing up to 2 kilograms and postal packages weighing up to 10 kilograms 31 Services for registered and insured items Equivalent cross-border services All to be at affordable prices 2.6 These key features of the universal service are enshrined in the UK in the Postal Services Act 2000, along with an additional requirement for geographical uniformity of price, i.e. the one price goes anywhere requirement 32. The Postal Services Act 2000 also imposes a requirement to collect and deliver post every working day. In the UK, working day is defined as Monday through to Saturday in relation to letters, and as such the delivery and collection obligation for letters extends to six days a week. This is more than the EU minimum requirement of five days per week. The delivery and collection obligation for other postal packets is five days a week The Postal Services Bill also sets out the minimum requirements of the universal service and largely replicates the current definition. In particular the Bill requires one delivery and collection of mail every Monday to Saturday for letters and every Monday to Friday for packets, at affordable and uniform prices. 2.8 In essence the universal postal service can therefore be summarised as the collection and delivery of post everywhere in the UK, at an affordable uniform price, every working day. 2.9 Parliament has delegated to the regulator the task of identifying which specific services must be provided to meet the minimum requirements of the universal service. The Postal Services Bill anticipates that Ofcom will also be required to set out a description of the services which should be provided as universal postal services The Directive also requires quality of service standards to be set in relation to the universal service. In the UK, Postcomm has set quality of service targets in 30 Directive 97/67/EC as amended most recently by the Third Postal Directive 2008/6/EC, 31 Member States may increase this weight limit to 20kg and the UK did so 32 Postal Services Act 2000, 33 Section 125, Postal Services Act 2000, definition of working day, 10

20 Chapter 2: The universal service Condition 4 of Royal Mail s licence. The Bill anticipates that the universal postal service order will set out the standards with which those services must comply 34 and Ofcom may also impose performance targets in a designated Universal Service Provider (USP) Condition Currently, Condition 2 of Royal Mail s licence lists the following products which Royal Mail must provide to discharge its universal service obligation, and which must therefore meet the minimum requirements of the universal service 36 : First Class stamped mail and First Class mail metered Second Class stamped mail and Second Class mail metered Standard Parcels Airmail and Surface Mail Special Delivery Next Day Cleanmail (this does not include the new Cleanmail Advance Product) Mailsort 1400 (First and Second Class only, not Third class) International Signed For, when sold with single piece air mail and surface mail services 37 Reviewing and clarifying the postal products which must be provided as part of the universal service 2.12 As stated in the Directive, the universal postal service should evolve in the light of changing social, economic and technological conditions, and the changing needs of users Postcomm first determined the range of Royal Mail services to be provided as part of the universal service when it issued Royal Mail s licence in At that time the services chosen simply reflected the services offered by Royal Mail The services provided as part of the universal service were then the subject of reviews by Postcomm in In April 2003, Postcomm started to 34 Clause 29(1)(b), Postal Services Bill as introduced to the House of Lords 35 Clause 35(6), Postal Services Bill as introduced to the House of Lords 36 Postcomm, Licence granted to Royal Mail Group Limited, March 2001, as subsequently amended 37 Postcomm issued in January 2011 a decision to modify Royal Mail s Licence to include International Signed For in Condition 2, 38 Postcomm, The universal postal service in the UK: what services should be provided?, A consultation document, April

21 Chapter 2: The universal service consult on the services to be provided as part of the universal service 39, and published its proposals in November We published our decisions in relation to single piece mail in June , and in relation to bulk mail in June Postcomm specified the definition of the services to be provided as part of the universal service in Royal Mail s licence in the May 2006 licence modification for the price control Since the review, Postcomm has undertaken work on certain aspects of the universal service, for example annual customer surveys 44 to understand attitudes and behaviour towards postal services. In 2008 we also commissioned a study on the net costs of certain elements of the universal service 45. After the Postal Services Bill 2009 was withdrawn, we decided it was appropriate to undertake a review of the universal service, to contribute to the new price control which we aimed to implement for April We decided such a review was especially timely in view of customers changing communications patterns: the continuing decline of social mail, the growth in packets volumes and the widespread use of electronic communications In Annex 1 of our May 2010 consultation document 46, we invited views on the work we were undertaking to review the universal service, although we did not ask specific questions. We received a total of 13 responses. Overall, respondents recognised that a review of the universal service was needed. Two operators said that it was important for Postcomm to review the universal service because the scope of the universal service will have an impact on the wider regulatory regime Subsequently however, in October 2010, the Government introduced a new Postal Services Bill 47. The Postal Services Bill is currently progressing through Parliament. Amongst other major proposals on postal services, the Postal Services Bill re-affirms the key features of the universal postal service, and transfers regulatory responsibility for post from Postcomm to Ofcom. 39 Postcomm, The universal postal service in the UK: what services should be provided?, A consultation document, April Postcomm, Review of the universal postal service: Postcomm s proposals, November Postcomm, Decision document: the UK s universal service, June 2004, 42 Postcomm, The universal service for bulk mailers, June 2005, 43 Postcomm, Royal Mail s price and service quality review , Licence Modifications Proposals, March Frontier Economics, Net costs of elements of the universal service: A report prepared for Postcomm, May Postcomm, Laying the foundations of a sustainable postal service, Annex 1: Provision of a universal service, May 2010, 47 Postal Services Bill as introduced to the House of Lords 12

22 Chapter 2: The universal service 2.19 We have therefore concluded that in the context of the transfer of our regulatory responsibilities to Ofcom, it would be appropriate to clarify the current composition of the universal service. We propose this clarification to ensure an orderly transition of the regulatory regime once the new legislation is enacted However, we also think it is appropriate to undertake a consultation to test whether it would now be appropriate to remove bulk products from the universal service. Given the changes in the market, we want to ensure that Ofcom is able to rely on the most up-to-date and appropriate product composition of the universal service when the current regulatory regime is transposed into the new general authorisation regime and a new price control is set We would aim to implement any decision, if appropriate, before the Postal Services Bill receives Royal Assent. During the transitional period, Ofcom will have to set the initial conditions, in this context, essentially transposing licence Conditions 2 and 4. While this is not necessary when making the first universal postal service order, within 18 months of the new regulatory provisions under the Bill coming into force, Ofcom will have to review the extent to which the postal services market is meeting the reasonable needs of users of postal services. Research into the needs of customers from the universal service 2.22 As part of the universal service project, Postcomm has worked with Consumer Focus to commission joint research into the needs of postal customers, appointing TNS-BMRB in March 2010 to undertake the research work The research explored the needs of residential, business and bulk customers, as both senders and recipients of mail. It also covered the needs of special interest groups, described in the Postal Services Act 2000 as individuals who are disabled or chronically sick, individuals of pensionable age, individuals with low incomes, and individuals living in rural areas Our research on customer needs found that post is still an important method of communication and people recognise the importance of the postal service, including having a uniform price regardless of where mail is sent in the UK: 85% of residential customers agreed that they will always need to send some things by post. 48 TNS-BMRB, Customer needs from a sustainable universal postal service in the UK, November

23 Chapter 2: The universal service 66% of residential customers agreed that they like receiving post, with only 15% disagreeing. Around half of residential customers surveyed had used Standard Parcels in the last year, two-fifths had used Recorded Delivery and a quarter had used Special Delivery. Residential customers receive far more mail than they send: three-fifths receive six or more items a month. In contrast, around half of customers report typically sending fewer than two items a month. Customers who are sending more mail than three years ago are also sending more parcels, and customers sending less mail than three years ago are also sending more parcels overall. A quarter of customers say they receive parcels. Most residential customers say that the ability to send an item of mail for the same price to anywhere in the country is an important part of the universal service. Our research shows that 57% disagreed that they would be prepared to pay different prices depending on which part of the country they were sending their post to, compared with 28% who agreed they would be willing to pay different prices depending on which part of the country they were sending their post to (and 13% who did not know). In addition, 93% of businesses that send single piece mail agreed that they will always need to send some things by post Our research also found that the current service 49 is acceptable to nine out of 10 residential customers and nine out of 10 business customers. In relation to residential customers, there is little difference in acceptability across the subgroups. Compared with 91.3% of customers overall finding the current service acceptable, the groups who find it slightly less acceptable have a disability (89.9%), live in rural areas (88%), are of retirement age (86.8%) and are aged over 75 (83.6%). We know, however, that how acceptable a service is to customers is not necessarily synonymous with their needs from the service, and our reports explore customer needs in more detail. The full reports were published on 8 November 2010 and are available on our website 50. Customer Interest Forums 2.26 In 2010 Postcomm also created a network of Customer Interest Forums which meet on a quarterly basis across the UK, to enable Postcomm to ask customers for their views on a range of postal issues. There are five Forums (Glasgow, Cardiff, Belfast, Chesterfield and London), each consisting of approximately First and second class services, collection and delivery on six days a week, 93% target for first class stamped and metered mail and a guaranteed and insured next day product (Special Delivery Next Day) 50 TNS-BMRB, Customer needs from a sustainable universal postal service in the UK, November

24 Chapter 2: The universal service residential and micro-business customers, brought together to discuss their experiences and issues surrounding the postal market To date, two Forum sessions have been held in each location with the final meetings to take place in March The first sessions explored customer views about universal postal services and the role of the postal regulator, together with providing information to Forum members to help inform future discussions A full report of the findings from the first wave of Forums was published on 8 November 2010 and is available on our website 51. The main findings from the first wave of Forums were: Customers consider the universal service to be a fundamental part of society and whilst they may well sometimes experience frustration or dissatisfaction with the postal service, they firmly value its existence. On the importance of postal services, participants agreed that it is essential for Postcomm to ensure that the postal service is accessible to everyone in society and that special account is given to individuals who are disabled or chronically sick, of a pensionable age, with low income and those residing in rural areas. On the uniform tariff, customers think that being able to send post anywhere in the UK for the same price makes the postal service system convenient and straightforward. Customers appreciate the fact that they do not have to think about how much it will cost them to send their post to different locations throughout the UK The second sessions discussed the issue of affordability of postal services. The report from the second wave of Forums is published alongside this consultation 52. The findings in relation to the universal service from this second report confirmed the findings in the first report. In particular, on discussing the one-price goes anywhere uniform tariff: Most participants were very positive that it costs the same price to send mail anywhere in the UK. It makes the postal service system convenient and straightforward for all. Customers appreciate the fact that they do not have to think about how much it will cost them to send their post to different locations throughout the UK. 51 Synovate, Postcomm Customer Interest Forum, Wave One Report, October 2010, 52 Synovate, Postcomm Customer Interest Forum, Wave Two- Report, February 2011, published on the same day as this consultation and available on our website, 15

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