4.3. Minimum services provided

Current situation

Objectives currently in force as far as minimum services provided are concerned are presented in Table 7.

Table 7. Objectives of minimum services provided 

1.	Provision of a post service for the blind.
2.	Provision of the full range of concessionary services by at least one postal establishment in every municipality.
3.	The percentage of postal establishments providing the full range of concessionary services intended for the occasional segment*, in the total of postal establishments, shall be at least 75%.
4. a)	The maximum distance to a postal establishment providing the full range of concessionary services intended for the occasional segment* shall be 8500 meters for 97.5% of the population, at national level.
4. b)	The maximum distance to a postal establishment providing the full range of concessionary services intended for the occasional segment* shall be 5500 meters for 97.5% of the population, at the level of urban areas.
4. c)	The maximum distance to a postal establishment providing the full range of concessionary services intended for the occasional segment* shall be 15 000 meters for 97.5% of the population, at the level of rural areas.
5.	The maximum distance to a postal establishment providing the full range of concessionary services intended for the occasional segment* shall be 30 000 meters at the most, for the whole of the population.
6.	In rural areas, for population residing more than 10 000 meters away from nearest postal establishment, postmen shall also perform itinerant customer service operations, which specifically include sale of stamps and prepaid envelopes, acceptance of non-registered mail, acceptance of registered mail, home payment of postal orders.
7.	The percentage of postal establishments providing the legal summons and notifications service compared to all establishments shall be at least 50%.
8. a)	The number of postal establishments opened to the public less than 5 days and/or 15 hours a week shall not exceed 1.5% of all postal establishments.
8. b)	The number of postal establishments opened to the public less than 5 days and/or 15 hours a week shall not exceed 20% of postal establishments in each municipality.

* Postal establishments providing the full range of concessionary services intended for the occasional segment mean postal establishments providing the basket of services generally used by the occasional segment of users, which includes the following services: standard mail, priority mail, easy mail, registered mail, insured mail, books and parcels, postal orders (issue and payment) and collections.

Source: ANACOM Decision of 28.08.2014.

[Original] proposal submitted by CTT, on 09.03.2017:

CTT proposed to:

a) Revise (both) indicators of limited/ shorter opening hours (vide indicators 8a and 8b in Table 7), taking into account, according to CTT, the increasing difficulties in installing these postal establishments in villages;

b)  Maintain remaining indicators and respective objectives.

CTT specifically proposed the following changes to indicators of shorter opening hours:

“By virtue of the existence of shorter opening hours in some post offices operating in villages, which cannot operate at an alternative location, the operation of postal establishments for shorter opening hours shall be admitted. In this respect, the following is defined:

a) The number of postal establishments opened to the public less than 5 days and/or 15 hours a week must not exceed 1.5% of all postal establishments;

b) The number of postal establishments opened to the public less than 5 days and/or 15 hours a week mustshall not exceed 20% of postal establishments inof each municipality or one postal establishment in the case of municipalities with less than five establishments.”

It is highlighted that this proposal requires two conditions to be met simultaneously so that a postal establishment is considered to operate for shorter opening hours:

a) opening to the public for less than 5 working days; and

b) opening for less than 15 hours a week.

According to the current wording of this indicator, it is enough that one of the above-mentioned conditions is met so that a postal establishment is deemed to operate for shorter opening hours, thus making the current indicator more demanding than the one resulting from CTT’s proposal.
CTT also proposed the change of the methodology for assessing the urban typology of parishes, to take TIPAU 2014 into consideration. As referred above, this was accepted by ANACOM, reason for which this issue will not be referred again in the scope of this specific point.

ANACOM Decision of 05.06.2017:

ANACOM considered that the proposal submitted by CTT for indicators of shorter opening hours did not guarantee accessibility and quality in the provision of the universal postal service, failing also to take user needs into due account.

ANACOM took the view that CTT’s proposal should be revised, so as to:

a) consider that a postal establishment will only be deemed not¹ to operate for shorter opening hours where it observes, simultaneously, a criterion of opening all working days of the week (or in the alternative, at least five calendar week days²) and a criterion of minimum number of opening hours on each of those days, to make up a minimum number of opening hours a week; and

b) maintain at the same time a maximum objective value for the set of situations of postal establishments considered to operate for shorter opening hours, so as not to imply a deterioration of current conditions of accessibility.

As regards the limitation of postal establishments operating for shorter opening hours per municipality, ANACOM considered that CTT’s proposal would allow, in municipalities where a single postal establishment exists, that it operated for shorter opening hours, a situation which in the opinion of this Authority does not ensure, in such municipalities, the availability and accessibility required for the provision of the universal service, in view of the limited period of time available to access that service.

As such, this Authority took the view that:

a) CTT’s proposal should be revised, so as to safeguard, in municipalities where a single postal establishment exists, that it does not operate for shorter opening hours;

b) Furthermore, it would contribute to a better accessibility to the universal service and would better fulfil user needs if in all municipalities, in addition to the requirement for a postal establishment providing the full range of concessionary services (an objective which is currently in force and which CTT proposed to maintain), this postal establishment operated (at least) all working days of the week for a minimum of six hours a day.

With regard to CTT’s proposal to maintain remaining indicators and objectives of minimum services provided, ANACOM deems that this would ensure the availability and accessibility of services that integrate the universal postal service.

[Revised] proposal submitted by CTT, on 18.07.2017:

In this respect, CTT:

a) Presents a new revised proposal for indicators of shorter opening hours for post offices (indicators 8a and 8b);

b) Continues to propose the maintenance of remaining indicators and respective objectives.

CTT’s proposal, as regards indicators of shorter opening hours, is as follows:

“By virtue of the existence of shorter opening hours in some post offices operating in villages, which cannot operate at an alternative location, the operation of postal establishments for shorter opening hours shall be admitted.

Postal establishments operating for shorter opening hours shall be deemed to be those opened to the public less than 5 working days or 15 hours a week, excluding those opened to the public for a period of at least 5 calendar days and 20 hours a week or more.

In this respect, the following is defined:

a) The number of postal establishments with shorter opening hours opened to the public less than 5 days and/or 15 hours a week must not exceed 1.5% of all postal establishments;

b) The number of postal establishments with shorter opening hours opened to the public less than 5 days and/or 15 hours a week shall not exceed 20% of postal establishments inof each municipality or one postal establishment in the case of municipalities with less than five establishments. In the case of municipalities where a single postal establishment exists, it shall not operate for shorter opening hours and shall open every working day, with a minimum 15-hour weekly operating period”.

Position taken by ANACOM:

In line with ANACOM’s position, expressed in the decision of 05.06.2017, CTT amended its proposal on establishments with shorter opening hours, so as to consider that a postal establishment will not be deemed one where it fulfils, simultaneously:

a) A criterion of opening on a minimum number of working days, or calendar days, of the week;

b) A criterion of minimum number of opening hours a week.

As such, CTT proposes to maintain current criteria of minimum opening hours in five working days a week and 15 opening hours a week.

CTT also proposes that postal establishments that are not opened every working day of the week, but which are opened on weekends, may also not be considered as operating for shorter hours, insofar as they are opened 5 calendar days and for at least twenty hours a week, given, according to CTT, the convenience and proximity services provided to the population, which allow greater accessibility to postal services.

This revised proposal submitted by CTT is in line with ANACOM’s perspective, as it allows the identification of postal establishments operating for shorter hours to take into consideration the accessibility to postal services on weekends, given the convenience of this access to groups of users, namely residential users, who on working days may have greater difficulties in accessing postal services by virtue of being at work.

However, CTT fails to define a minimum number of opening hours on each day of the week (either working days or weekends) for postal establishments considered not to operate for shorter hours.

CTT takes the view that, for a postal establishment to be considered not to operate for shorter hours, it is enough to define a criterion of operation in terms of the minimum number of days and hours of weekly operation, given that:

a) This criterion already guarantees a smooth functioning of the postal establishment according to local needs, as well as the accessibility to postal services;

b) In view of constrains related to the installation of post offices in villages, the introduction of a minimum number of hours of daily operation would introduce  severe limitations to the functioning of these postal establishments, without any benefits to the population in terms of accessibility and quality in the provision of the service, as this could lead to situations where the establishment better equipped for the provision of the postal service would be disregarded for not complying on an operating day with the specific minimum hours of operation or where a postal establishment would not open in a specific location due to the fact that the single establishment prepared for this purpose would not be able to achieve the minimum number of hours on a weekday.

It must be clarified that it was not ANACOM’s intention to define a minimum daily operating period that resulted in the need to increase current opening hours of postal establishments considered to operate for shorter hours.

ANACOM seeks to guarantee, as CTT also refers, the minimum regular operation of postal establishments, to allow access thereto by users throughout the week.

In this context, it is deemed that CTT’s proposal as regards (weekly) operating periods of postal establishments with shorter hours, together with the maintenance of the limit of possible situations of shorter hours at national level³, continues to guarantee the access of both business and residential users to postal establishments throughout the week.

As regards the limit of postal establishments with shorter opening hours per municipality, CTT’s proposal is in line with ANACOM’s perspective, that is:

a) The number of postal establishments operating for shorter hours does not exceed 20% of establishments in every municipality or one postal establishment in the case of municipalities with less than five establishments;

b) In municipalities where only a single postal establishment exists, it must not operate for shorter hours.

As referred above, in its decision of 05.06.2017 ANACOM considered that it would contribute to a better accessibility to the universal service and would better fulfil user needs if in all municipalities, in addition to the requirement for a postal establishment providing the full range of concessionary services (an objective which CTT proposed to maintain), this postal establishment operated (at least) all working days of the week for a minimum number of hours a day, of six hours or more.

As far as this objective is concerned, CTT proposes that the postal establishment concerned operates every working day, with a minimum 15-hour weekly operating period.

CTT informed that there are currently 63 municipalities where a single postal establishment exists providing all concessionary services, out of which only one post station (store), in the island of Corvo, operates less than 6 hours a day (it operates 3h30m a day). Their opening hours have been operational since November 2010, taking into account the respective activity and the average daily demand of the post station, factors which, according to CTT, are also taken into account in the definition of opening hours of other postal establishments.

CTT believes that, given that opening hours are defined to better meet postal needs of the population taking into account the respective local demand, the safeguard proposed, according to which in municipalities where only a single postal establishment exists, it shall not operate for shorter hours, is enough to ensure the availability and accessibility of the universal service in these municipalities.

Bearing in mind:

a) That the objective intended by ANACOM with the definition of a minimum period of daily operation, for a postal establishment per municipality providing all concessionary services, is to ensure the accessibility of users (residential and business ⁴ to concessionary services in all working days of the week, in every municipality;

b) That shorter operating hours imply, ceteris paribus, a lower degree of accessibility;

c) That the proposal presented by CTT safeguards access for a minimum period a week to postal establishments that are the sole available establishments in the municipality where they are located (which, on account of being the sole available establishments, are required to provide all concessionary services), but fails to guarantee, however, in remaining municipalities where more than one postal establishment exists, a minimum period of access to at least one postal establishment providing all concessionary services;

d) That it is deemed appropriate to safeguard a minimum period of access every day, all working days of the week, to at least one postal establishment providing in each municipality all concessionary services, regardless of whether in that municipality there is only one or more postal establishments, a guarantee that does not exist today in current objectives of postal network density and minimum services provided;

e) That according to the study on the needs of users in accessing postal establishments and other points of access to the postal network, of May 2017, in addition to proximity, opening hours of postal establishments is one of the main criteria valued by (residential and business) users when choosing which postal establishment to use. The same study concludes also that most (residential and business) users are satisfied with the characteristics of the current postal network, and that there is strong resistance to its degradation [around only 20% of - residential and business - users could accept the reduction of opening hours of postal establishments (to operate exclusively in the morning or in the afternoon)];

f) The 2016 Survey also shows that opening hours is one of the most important aspects in the scope of the general quality of the postal service provided⁵, such users being satisfied with opening hours⁶;

g) That, according to available data for the end of March 2017, there are only two municipalities in the country that fail to have at least one postal establishment providing all concessionary services, with a daily operating period of less than 6 hours, one of which is referred by CTT, in the island of Corvo,

ANACOM considers that, as a safeguard measure and in order to guarantee the regular accessibility of concessionary services provided in each municipality, in addition to the requirement for (at least) one postal establishment providing the full range of concessionary services (an objective which is currently in force and which CTT proposed to maintain), that postal establishment is required to operate all working days of the week for a minimum of six hours a day, which corresponds to a minimum of 30 hours a week.

Nevertheless, ANACOM deems that specific situations where the operating period of postal establishments is at the moment already lower than that 6-hour period must be taken into account.

In the light of the above, ANACOM takes the view that indicators 8b) and 2 of CTT’s proposal must be amended to read as follows:

“2. In every municipality, at least one postal establishment shall provide the full range of concessionary services, operating:

a) 99% of the cases, all working days for a minimum daily period of 6 hours;
b) In remaining cases, all working days for a minimum daily period of 3 hours.”

“8. By virtue of the existence of shorter opening hours in some post offices operating in villages, which cannot operate at an alternative location, the operation of postal establishments for shorter opening hours shall be admitted.

Postal establishments operating for shorter opening hours shall be deemed to be those opened to the public less than 5 working days or 15 hours a week, excluding those opened to the public for a period of at least 5 calendar days and 20 hours a week or more.

In this respect, the following is defined:

a) At national level, the number of postal establishments operating for shorter opening hours shall not exceed 1.5% of all postal establishments;

b) In each municipality, the number of postal establishments operating for shorter opening hours shall not exceed 20% of postal establishments of each municipality or one postal establishment in the case of municipalities with less than five establishments.”

ANACOM agrees with the maintenance of remaining indicators of minimum services provided (indicators 1, 3, 4, 5, 6 and 7 - vide Table 7 above), as well as with the respective objective values, taking into consideration that, according to the study on the needs of users in accessing postal establishments and other points of access to the postal network, of May 2017, most (residential and business) users are satisfied with the characteristics of the postal network, this Authority taking the view that such indicators and objectives contribute to ensure the availability and accessibility to services that integrate the universal postal service.