From Charles Webb, executive director.
I WRITE in response to the editorial entitled ‘Common sense or dogma?’ (JEP, 27 May).

That editorial criticised the JCRA with respect to its current consideration of the potential granting of postal licenses to Hub Europe Ltd and Citipost DSA Ltd. As the Jersey Competition Regulatory Authority’s executive director, I provide the following response.

First, the JEP’s editorial appears to assume that the JCRA has already made its final decision to grant postal licences to Hub and Citipost. It has not. As explained in detail in my previous letter to the JEP, published on the 27th April, the JCRA has proposed to issue postal licences to Hub and Citipost.

These proposals were both subject to a month-long public consultation process, which ended on the 30th April. We received 17 responses to this consultation, 14 of which are published on the JCRA’s website (JP and two other respondents did not authorise us to publish their responses).

Jersey’s Postal Law now requires the JCRA to consider the issues raised in the consultation before reaching a final decision, which takes the form of another document called the Final Notice. In the Final Notice, we state whether or not we still intend to proceed with the proposed licences, and if so, on what conditions.

We have stated publicly that we hope to be in a position to reach our final decisions and issue Final Notices at the end of July, but this is not a hard deadline set by law. What is more important than any particular estimated date is that the JCRA take into account all relevant considerations in reaching its final decision under Jersey’s Postal Law. This is the process in which we are currently engaged.

Second, the editorial accuses the JCRA of taking a ‘dogmatic’ approach to potentially increased competition in the postal sector. This is simply not accurate. One need only review the responses to the JCRA’s consultation from Jersey Post’s own bulk mailing customers, which express sentiments like:

‘Without the introduction of competition and with the continual and unnecessary price increases by Jersey Post, it is only a matter of time until fulfilment businesses will relocate outside of Jersey.’

‘In summary we believe strongly that if this application does not proceed many dozens, perhaps even hundreds, of jobs will be lost in the growing online retail and fulfilment industry in Jersey and (we) for one will be forced to re-evaluate Jersey as our base of operations.’

The full text of these and other similar responses are available on our website. These are real concerns expressed by real Jersey businesses in a sector that currently employs over 1,000 people in this Island. While the JCRA has not reached a final decision with regard to the potential award of new postal licences, labelling our approach as ‘dogmatic’ does not give due respect to the real concerns that have been expressed to us.

Third and finally, notwithstanding the JCRA’s final decision on new licences, the postal industry is changing, and will continue to change, in Jersey and abroad. Mail volumes are falling by five to seven per cent per year as consumers communicate more by electronic means – for example, this letter to the JEP was sent via email – and companies more often encourage practices like online billing. (For our children, the old saying ‘the cheque is in the post’ likely will have very little meaning).

These changes are having, and will continue to have, profound effects on the postal industry and postal operators. To this end, we welcome the Economic Development Minister’s recent announcement of a public consultation to review Jersey’s postal universal service obligation, and what can be realistically expected, given the costs.