Mr. Gary Delaney:

I thank the Chairman and members for inviting me here today. What I have to say is of particular relevance to the matter of the national postcodes, particularly the chosen system, Eircode. I have spent many years in the positioning and navigation industries. I worked for 35 years as a navigator and land surveyor, have relevant experience and qualifications in the field and am a fellow of the Royal Institute of Navigation. The whole idea of a postcode and how it may be used is, in effect, a navigation technology exercise. The conduct of a service, product or person from A to B is about navigation.

Way back in 1997 and 1998, I developed a specific interest and completed a master's degree in co-ordinates systems and geo-coding systems. I went on to consider how those could be applied to mapping and navigation systems in Ireland and abroad and, in 2005, began developing what I believed was an address code system for Ireland, Loc8Code. I did not necessarily view it as a national postcode as that had never been delivered. Since Loc8Code was delivered to the market in 2010, I have amassed a lot of experience in a coding system for addresses in Ireland. This experience is also relevant to the committee's deliberations today.

I have prepared a very detailed analysis of Eircode, which members have in soft copy and which is also available to them in hard copy format. It is a very technical document. The subject merits this level of technicality; we are not just introducing a series of characters to define or identify properties, but are introducing a piece of national infrastructure, which needs careful attention.

Much has been made of the fact that An Post may use Eircode. It is my opinion that An Post will not use it much, although it may tolerate it, because Eircode does not fit with An Post's operations. If that is the case, we must focus on the other users, namely, the transport and logistics industries, emergency services and, particularly, the ordinary people, who have not been mentioned much. If the people in the street do not use this coding system, it is not a postcode and will be relegated to history along with other technical projects with which Ireland has been involved over the years.

As it stands, Eircode gives the user no intelligence about the location of the property to be travelled to. In fact, it has less capability than latitude and longitude, which have been around for hundreds of years and with which most people are now getting familiar.

People migh

t suggest that I am coming to this issue with a vested interest.

It is important that I draw the committee's attention to a report by the Global Address Data Association, GADA, in the US, which was circulated to members during the week. I will not go into its detail but, effectively, it says that Eircode is not a postcode. The detail of the discussion is an indictment of Eircode in terms of what it is supposed to do and can do, and the fact that it is not the technical new generation solution for a postcode that people have claimed it to be.

We must not forget that when we talk about the history of a national postcode, it dates back many years. Essentially, the national postcode was about levelling the playing field in Ireland with postal liberalisation. The postal market should not be referred to or thought of as just mail, because the front line in the postal market nowadays is parcels and other companies, including couriers, deliver parcels. If it is the case that the postal market is liberalised, everybody should be able to equally and easily find addresses in Ireland. Eircode was supposed to be about that. If it is the case that people from various industries have stated, before this committee or in other interviews, that it does not do that, perhaps the field is not levelled. In my opinion, if we have spent 13 years talking about this, there must be significant reasons that it did not happen. It is quoted that, perhaps, An Post did not want it to happen. That is on the public record. A postcode has not been designed for 13 years; it has been designed only since January 2014 when the winning bidder, Capita, engaged directly with An Post to design the code. The document which covers that is in the public domain. It is the postcode design document which runs from January 2014 to May 2014, when it was published. That consists of a consultation only with An Post. There is no record in that document of consultation with other people.

That is the basis. I will deal first with the issue of whether Eircode has legitimacy. I will not go into all of the detail. I have raised some topics in the analysis as to why Eircode might not have legitimacy, but one of the most significant is that Eircode does not conform with, or deliver, the definition of a postcode that is in the legislation, the Communications Regulation (Postal Services) Act 2011. I realise the Oireachtas is dealing with an amendment to that legislation at present, but we already have an Act which defines what a postcode in Ireland should be and Eircode does not fulfil that. The definition requires the postcode to define a locality. In other words, if I look at the code and I wish to go somewhere, that code automatically delivers to me the idea of where I am going. When we are going somewhere, none of us visualises the exact destination. We always visualise how we are going to get there and the areas we will pass through to get there. That is navigation and it is how people operate. That is the reason the definition says that the postcode should define a locality. The design document for Eircode states very specifically that it will not define a locality. An Post has requested that it would not define a locality because there would be unreasonable expectations about where people live and so forth.

I have documented in the analysis other reasons that Eircode may not have the legitimacy it should have, but in that regard alone it does not. In fact, if one reads the definition, it becomes very clear that the method An Post uses for sorting at present, which is the post town model and which the High Court gave sanction for An Post to operate and use in 2012, better conforms with the legislation and the requirement. In fact, if we go ahead with Eircode there might well be the possibility of two postcodes operating in Ireland, one which has legitimacy and High Court sanction and another that has no legitimacy. If Eircode is to be used as a property identifier for property related taxes and so forth, it could easily be challenged.

Effectively, Eircode does not comply with the legislation, nor does it comply with all of the recommendations of the last national postcode board since 2006.

It does not conform with the tender documents. It does not deliver something required by the ordinary Joe Soap user. Citizens of Ireland and visitors to Ireland need to be able to look at a postcode and use it in a useful way. Eircode has ignored all the prior knowledge about postcodes that existed in the world. If I was going to design something, as I have done, the first thing I would do is look at what is there, take what is good from it and enhance it as necessary. Any designer or anyone in business globally would do likewise.

In the document I have furnished to the joint committee, I refer specifically to the Northern Ireland postcode, which is part of the UK postcode. If one looks at the two examples I have included in my submission - BT4 1PW and BT4 1PY - one might not know exactly where those locations are, but one will see immediately that they are close together. One cannot make the same judgment when one looks at an Eircode because there is no indication of whether two postcode locations are close together. This is a critical issue for ordinary users. It is important that there is some intelligence in the code that tells us we were there before, or we will not have to go far from where we were previously. Above all else, one should be able to use the free Excel spreadsheet software that is readily available to order postcodes in a rational sequence for delivery.