Don’t sell our postcodes! Why we should have Open Addressing in the UK
Open Data User Group Response to the Ofcom Postcode Address File (PAF) Consultation
ODUG’s response to the Ofcom PAF Consultation is published here. Our primary feedback is that this consultation simply considers Business–as-usual for the Postcode Address File (PAF) – and therefore assumes that increased revenues should be derived from the Royal Mail‘s current monopoly position – to increase Royal Mail’s profits. Please read the full response for more detail.
What we are saying here is don’t sell our postcodes. This has nothing to do with how much junk mail you get through your letterbox and the data does not include people’s names. It’s about whether we have a central, high quality, publicly available set of address data for the country – which is owned by the public, not by private organisations and available to anyone as Open Data for use and re-use.
We would welcome your views in comments below and, if you are interested in the detail, please read on …..
Some eyebrows have been raised at the Open Data User Group’s decision to highlight the need for an Open National Address Dataset as their first target. Surely addresses aren’t a problem? Write one on an envelope, it usually gets there. Pop a postcode in a sat-nav and it guides you to a place near your destination (except when it doesn’t and you end up in a field). What is the problem?
The Open Data White Paper which announced the setting up of ODUG specifically mentioned a national address dataset as one of the matters that government wants to resolve. This is because addresses and addressing have been a contentious area in the data world for more than a decade.
So what is there to argue about? As is usually the case it is mainly money; who is entitled to make money from addresses and how much. Who owns addresses and therefore the revenue? These are all publicly owned organisations in play here by the way – your taxes are funding them, public assets are being traded and there is a capped return going back into the Treasury (who appear to discount the wider economic case which they should consider if they were to refer to the ‘Green Book’ which is the economic ‘bible’ they should use to make public spending decisions for the good of the nation).
The real issue here is that as publicly funded organisations struggle to balance budgets, access to a nice little natural monopoly (theoretically there can only be ONE correct set of addresses and their locations) in the provision of data that everyone needs, particularly if it is lightly regulated, can lead to a permanent highly lucrative revenue stream.
This is good, easy, business ….. Imagine if every time someone purchased something on the internet and entered their address, or used a sat-nav, or needed to verify an address list you could charge a toll, which doesn’t need to be related tightly to your costs, that’s a real ‘nice little earner’. For this reason a long standing set of fierce arguments, colloquially known as the ‘address wars’ have raged for years between Local Authorities, who legally ‘create’ addresses, Royal Mail, who add a postcode and modify addresses to reflect the delivery network and Ordnance Survey who map where the address is; constant squabbles have persisted over who can leverage the Intellectual Property Rights (even though this is all publicly funded Crown Copyright data) and hence the revenue from addresses .
Royal Mail, because they compiled the first comprehensive list of postal delivery addresses, the PAF, and started selling it in the 1980s, claim first mover advantage and demand payment from anyone who uses or sells data that includes addresses with postcodes. Local Government have tried to assert their moral ownership of addresses, based on their statutory addressing powers and Ordnance Survey, who were first to map all postal addresses, want their slice of the cash whenever an address is placed on the map, not just their own maps – any map!
So there is an unseemly tussle over which of these organisations can put up metaphorical “toll gates” on the physical information highway and claim a payment every time an address is used.
A contrary view, which ODUG and others hold, is that definitive addresses are a natural monopoly; a core-reference dataset which is lubricant to ensuring efficiency and accuracy in record keeping, location and deliveries. We believe addresses are a true, non-rivalrous (anyone can use it without limiting other users), non-excludable (anyone can get hold of it) public good. It is in the public interest that as many organisations and individuals use correct addresses as easily as possible and the best way to ensure that is not to charge for an address at the point of use.
The internet would grind to a halt if everyone had to pay a lookup charge every time a web site address or an email address was converted to the numeric address used internally on the internet. For this reason internet addressing databases are freely shared, in real time and free at the point of use. Those who register an address pay, as do those using an internet service, but not for looking up an address.
All internet users have free access to the address data under the Domain Naming System (DNS). We believe that the same should be the case for postal and geographical addresses.
The reason this is so important now is that Royal Mail may soon be put up for sale, in full or in part, and ministers will need to decide whether to allow them to take the national Postcode Address File (PAF) into private ownership. When the Dutch government sold their postal address file with their equivalent of Royal Mail to a private owner they soon came to regret their decision and had to fight in the courts to buy their national address file back at a reasonable price. We do not want the same error to be made here in the U.K.
It looks very likely that ministers will take a final decision on the future of the Postcode Address File before the Summer Recess.
ODUG believes that the decision will come down to one of three choices:
Option 1 -‘Business-as-usual’
PAF ownership is rolled in with the sale of Royal Mail and becomes a private asset lightly regulated, as at present, by Ofcom (the regulator for Royal Mail). The current Ofcom review assumes Business as usual and proposes that in this case PAF licensing restrictions should be made simpler – we think they should be removed. Looking at the business-as-usual scenario Ofcom also thinks that the cap on the profits Royal Mail is allowed to make on PAF should be lifted. This is because their current remit is to allow Royal Mail to make as much (short-term) profit as possible – regardless of the wider economic benefits, or dis-benefits of this approach in the medium to long term. Ofcom views Royal Mail through a lens which does not acknowledge privately or publicly that the relatively small profit Royal Mail currently gets from PAF should not be material to the returns one might expect from a huge organisation whose core business is in delivering post! This option will give Royal Mail a permanent (or, at least, difficult to reverse) right to toll all transactions that involve an address and essentially privatises a natural, publicly funded, monopoly dataset to the detriment of us all.
Option 2 - ‘Monopoly rents elsewhere’
The PAF maintenance monopoly could somehow be transferred to GeoPlace LLP (the commercial partnership between the Local Government Association and Ordnance Survey), creating a consolidated monopoly for commercial exploitation by a body/bodies which, at present, are not fully publicly accountable and which could follow Royal Mail into private hands (although we believe this is less likely).
Option 3 - An Open National Address Dataset
PAF maintenance gets rolled into the GeoPlace National Address Gazetteer (Royal Mail) contributing as a regulatory obligation in support of it Universal Postal Service provision or, put more simply, the requirement it has to deliver post to us all. A new business model is produced for GeoPlace (or, following a public procurement, another contractor) to maintain the National Address Gazetteer including PAF as a free at the point of use. An Open Data product is delivered under the Open Government License. This can be funded out of the government’s existing financial commitments to addressing from funds currently committed, long-term, via the Public Sector Mapping Agreement and the very recently announced Public Sector PAF Licence. These funds could be made up with a small charge on address registration fees which are already levied by many individual Local Authorities for naming and numbering.
ODUG believes that Option 3 best serves the national interest and understands that this view is shared by the Open Data Institute, the Demographics User Group and many others. ODUG is concerned that the Shareholder Executive (the agency that holds Royal Mail shares on behalf of the public) and the Treasury, appear to be lobbying hard for Option 1 because they see this as giving immediate shareholder return in the price paid for Royal Mail. Reversing Option 1 – if this was the government’s decision would be extremely hard. The Public Data Group (which groups together Trading Funds including Ordnance Survey) is likely to favour Option 2.
We strongly believe that Option 3 is in the national interest and consistent with the National Information Framework produced by another government advisory body, APPSI (the Advisory Panel on Public Sector Information) and the overriding principles set out for the re-use of Public Sector Information.
We also do not believe that bundling in ownership of PAF with Royal Mail will make a material difference to the sale price of the business. On the contrary, a potential investor is likely to view the persistent debate about the ownership and future of PAF as a risk factor which will deter them from investing in the Royal Mail. Offering PAF as part of the deal will not solve their concerns if they fully understand the wider issues at stake.
This is why our response to Ofcom asks them to evaluate and consider our preferred option, which is for PAF to be turned into Open Data now. This can be followed by consolidating address management so that the nation has a single, properly maintained, fit for purpose, definitive Open National Address dataset in the future which is free for all to use to promote the growth of the economy and to support national efficiency.
The Ofcom consultation remains open until 21st of March so there is an opportunity to express your views there as well. (http://stakeholders.ofcom.org.uk/consultations/postcode-address-file/)