Mr. Alex Chisholm:

I will respond to the comments made by Deputy Michael Moynihan. I thank him for his summary of the role that we try to perform. I agree generally that we try to be a watchdog for the consumer, to uphold the public interest and to ensure the development of the postal sector. We are not a watchdog for the taxpayer. We see that as a role for the Ministers for Communications, Energy and Natural Resources and Finance, who are the shareholders in An Post. It is also the role of the Comptroller and Auditor General and other such bodies. We do not represent the taxpayer but we certainly represent the consumer and the user of the postal sector. We were asked for our view of the sustainability of the postal services in rural areas. Our view is that the universal postal service must be maintained and that provides for the collection and delivery every day of the working week. It is essential. In order to make that economically viable, as I tried to indicate in my opening remarks, it is very dependent on postal volumes being maintained. It will depend on the postal service providers to provide a high quality, efficient and valuable service to their customers.

From our point of view we want to give encouragement and incentives to provide an efficient service that provides quality and choice. We will also undoubtedly work on the quality of written communication. I apologise to the Deputy that he finds some of our expressions gobbledegook and we will work harder at that. I totally agree that all interested parties, including ordinary members of the public, should be able to read, understand and comprehend what we produce. We endeavour to reach that standard. We will try harder in future.

Deputy Harrington also spoke on the postal matter at our hearing in January 2012. I will try to answer his questions directly. In response to his question on service providers, we have received five authorisation applications and notifications. The answer to his question on the number of disputes that have arisen is zero. I should, however, note that the procedures were only finalised in October 2012, which is a relatively short time for disputes to have arisen. The Deputy also asked about the price application. We expect to have a finalised application in the next few weeks if not days and we will publish a consultation on that before the end of the year. We expect to have our response in the first quarter of next year.

Deputy Harrington expressed some surprise at the different hierarchies that we have under the legislation. The legislation makes it very clear that the primary objective of ComReg is to preserve the universal postal service and that takes priority over the other two objectives. Deputy Harrington noted that we included in our presentation a chart that shows that the historic link between postal service revenues and overall activity in the economy appears to have been weakened, if not broken.

There is more information on letter volumes, and that information is included in the report published in October. I have made a note to send Deputies a copy of that so they will have all the information we have available in the public domain about trends in letter volumes.

With regard to quality of service, we are bound under the legislation to set quality standards, monitor and ensure compliance. We have not fined anybody and the level of a fine is a matter for a court, as well as all considerations and evidence for that. We were asked where are the blockages. Our role is to set targets for quality and this is done by reference to international standards. Deputy Keaveney asked about benchmarking and we do that by reference to international standards in all other European markets. The role of An Post as the universal service provider is to identify where are the blockages in order to be able to hit targets. We should be clear about the different roles and we do not seek to manage the business.

We were also asked about the level of transparency in our quality of service targets. We publish them quarterly and they come with relevant supporting detail about the different services available. For example, there is detail of services within Dublin as opposed to between Dublin and the country areas. Deputy Colreavy asked about the resources available, including how many people are employed. We have four dedicated staff in the postal area and we are able to support those people through the work of the technical staff in ComReg. He also asked about the amount spent on external advisers. The last available published accounts, for 2010, have that amount at €522,000, and much of that is accounted for by the quality of service monitor which we are required to commission and execute on an independent basis. It is necessarily done by an independent research agency. The total spend in that year was €1.3 million.

The Deputy asked if this represented value for money. The €1.3 million sum is considerable but not large compared to an industry with turnover approaching €1 billion. ComReg has experienced the pay cuts, pension levies and other economies, including restraints on employment numbers, which have applied across the public sector. We have been able to reduce our costs for each of the past two years.

With reference to international comparisons, a report was done for the European Commission by an agency called WIK-Consult, and it considered the appropriate level of resourcing for postal regulators across Europe. It recommended a minimum of nine to ten people, so in that regard four people is rather less than what is advisable at the European level. We also had dialogue on the matter in preparing our strategy, and we received a submission suggesting that we should compare ourselves with the UK. Postcomm was the regulator in the UK and it had a staff of over 50 people; Ofcom has now taken on the role and its budget last year was approximately £8 million, or over €9 million.

I have said what I wished to about the court cases but Deputy Keaveney also asked about the communications strategy and working out matters in a practical way. He quoted from the Irish Examinerwith regard to a case taken relating to an ordinary citizen. In trying to resolve matters, we spent many months trying to find resolution at a staff level and a practical working basis with An Post. The case was brought before the courts by An Post.

We will hold consultations on how the levy funds our costs. It is provided for under legislation but we will consult interested parties to gather their views. With regard to benchmarking our performance as regulators, we pay much attention to best practice across the EU's 27 members. We are members of the European regulators group for postal services. In examining aspects of our work like accounting, quality of service, price caps or universal service funding, there is much detailed work at the European level and we take all due account of the best practice guidance available through that forum.