As a campaigning organisation of blind and partially sighted people, we fight for the rights of people with sight loss in each of the UK’s countries. Our priorities are to:
We also provide expert knowledge to business and the public sector through consultancy on improving the accessibility of the built environment, technology, products and services.
RNIB is making this short response to the inquiry to highlight the importance of the UK’s postal service to blind and partially sighted people, and in particular the need to maintain the Universal Service Obligation (USO).
Royal Mail provides a free service, “Articles for the Blind”, which helps to lessen the barriers blind and partially sighted people face when trying to access goods and information. For instance, the service is used to distribute books in Braille or audio formats from specialist libraries which, being few in number, are likely to be far from a blind individual’s home.
We do not oppose competition in the postal market. However, we express some concerns that the advent of competition and “cherry-picking” by competitors to Royal Mail might jeopardise the delivery of the universal service, by eroding its capacity to raise the funds required.
We feel that Ofcom must continue to make certain that where there is competition, it is regulated and monitored to ensure that the USO can continue to be fully met.
Specifically, as competition increases, we believe Ofcom should vigilantly safeguard the provisions in the Postal Services Act- particularly requirement 6 of Section 31 of that Act.
Blind and partially sighted people face many barriers to accessing information and to inclusion in society. To overcome these in the field of reading, they need information in “accessible formats” such as Braille.
Braille is bulky. A short novel, such as Oliver Twist by Charles Dickens, takes up four Braille volumes, each A4 size, and about 2cms thick.
Producing Braille is expensive and the quantity produced is limited. The provision of free reading material for blind students, professionals or ordinary individuals wanting access to information or leisure reading became and has continued to be largely the responsibility of non-profit organisations. The dispersal of blind people over wide geographic areas meant that standards of access to information and library services set for the general population could not be easily and cheaply extended to blind people.
Recognising these inherent inequities, Royal Mail has long provided an exemption from postal charges for "Articles for the Blind" to permit access to literacy and learning which would otherwise be too expensive.
These days, Articles for the Blind include newer formats such as sound recordings and CDs, since the same problems relating to distribution and access continue to apply regardless of format. Royal Mail’s modern Articles for the Blind service therefore now applies to a wide variety of items which are specifically designed to ensure that blind and partially sighted people can access information and overcome other barriers in society.
Blind and partially sighted people continue to value highly the Articles for the Blind service. RNIB is therefore concerned to ensure that it continues to be provided to its current high standards.
In recent years we have witnessed attempts in various countries to remove or scale down their own versions of the Articles for the Blind service, often in the face of cost concerns arising from plans for privatisation or market opening. Indeed, at the start of this century, at the Universal Postal Union, it was proposed that the exemption from postal charges for blind and partially sighted people should be removed from the UPU Convention, the international agreement which governs the exchange of post between countries. Though this proposal was defeated, these challenges reflect the need to actively provide regulatory protection to the service in order for it to survive.
RNIB understands that Royal Mail has lost hundreds of millions of pounds in the last few years due to market liberalization, substitution and the requirement upon it to continue to provide the USO. However, it certainly appears to us that as things stand, Royal Mail is the only postal operator capable of providing the universal service.
We have previously expressed concern to Ofcom that privatization of Royal Mail might create further pressure on the provision of the USO as private shareholders look to maximize profit through cost reduction. We feared that in turn, privatization might put pressure on the continued provision of the “Articles for the Blind” service, and might also bring into question the continuation of the 6 day a week delivery of mail.
Any reduction in delivery frequency would disproportionately affect blind and partially sighted people, who rely more than most on the postal service due to the greater costs they incur in getting around and accessing information.
We understand that Royal Mail fears that end-to-end competition could jeopardize the provision of the universal service. We are concerned that if Royal Mail is left to bear the burdens of unprofitable parts of the universal service, and competition is allowed to cherry- pick the profitable parts, without competitors bearing the burden of the universal service, this could further undermine Royal Mail’s ability to provide the universal service.
We believe that Royal Mail needs to have the regulatory freedom to compete effectively so as to cover the costs of the universal service, such as through reasonable and appropriate price rises.
RNIB suggested in a response to the 2011Ofcom consultation “Securing the Universal Postal Service, proposals for the future framework for economic regulation” that Ofcom would need to very carefully monitor the effectiveness of regulation in helping ensure that the universal service is delivered fully, so as to ensure that regulation works in practice and does not cause unintended harm.
In that response, we agreed with Ofcom that any new entry to the market needs to be assessed carefully and on a case-by-case basis.
We believe that the regulation of competition in the postal market should continue to hold maintenance of the USO as a key objective. In particular, from our perspective, regulation of postal services should ensure the ongoing viability of funding for requirement 6 of Section 31 of the Postal Services Act.
Given these factors, RNIB believes that it is very helpful that the Postal Services Act 2011 protects the provision of “services to blind or partially sighted” as part of the universal service obligation in section 31, minimum requirements, of the act. [1]
RNIB will of course continue to work with Royal Mail to ensure the effective provision of the Articles for the Blind Service, and with other stakeholders to support a strong universal service.
Dan Pescod
Campaigns Manager, Europe, International and Accessibility
Royal National Institute of Blind People (RNIB)
16 October 2014
[1] “ Section 31 – Minimum Requirements:
Requirement 6: services to blind or partially sighted
The provision free of charge of such postal services as are specified in the universal postal service order to such descriptions of blind or partially sighted persons as are so specified.”