articles

Privatising the Post: Too Much, Too Late

By Rebecca Gordon-Nesbitt, 23 July 2009

 

While the government may have shelved plans to privatise the Royal Mail, the self-affirming logic of neoliberalism that informed the plans persists. Rebecca Gordon-Nesbitt details the turbulent history of government attempts to sell off the postal service and how consultants conspired to present public sector looting as sheer imperative

 

Of all institutions of modern times, there is, perhaps, none so pre-eminently a people's institution as is the Post Office [...] Its services are claimed exclusively by no one class; the rich, the poor, the educated, and the illiterate, and, indeed, the young as well as the old,-all have dealings with the Post Office.

– J.W. Hyde, The Royal Mail: its curiosities and romance, 1885, p. ix.

 

 

On 1 July 2009, Gordon Brown's government announced it was abandoning plans to part-privatise the Royal Mail before the next election, claiming that a high enough bid had not been received and that passage of the necessary legislation through parliament would detract from other core business at a crucial time. At stake was a 30% share in the UK postal service, which, for just £2 billion, was to include a recent £1.2 billion injection of public funds into the sorting network and a pledge from government that it would assume responsibility for the majority of the pension deficit (estimated to be approaching £10 billion at the time of writing). In a classic, if belated, example of PFI, the government thus proposed to mitigate the risk of investing, leaving the potential investor free to reap the rewards of acting as an accomplice in driving down public sector spending. The Dutch postal operator, TNT - hitherto the Royal Mail's greatest rival in the newly competitive market, with a reputation for bullying its workforce to accept pay cuts - was thought to be the only interested party,1 a prospect decried as ‘letting the fox into the hen house' by MP, Geraldine Smith, who led a significant parliamentary opposition to the proposed privatisation.2

 

Image: Victorian Postman

With the coal and steel industries having been decimated and the related automotive and ship-building industries falling into terminal decline, the provision of gas, oil, electricity and water being handed over to unregulated speculators and the peddling of rail and telecommunications networks paving the way for the maximum extraction of profit from the digital revolution, the postal service stands as the last bastion in the ongoing march of neoliberalisation in the UK. Intended as a ‘political project to re-establish conditions for capital accumulation and to restore the power of economic elites', neoliberalism has been discredited according to a range of social and economic indicators, yet its pervasive ideology has infiltrated the public sector.3 The legislative hiatus around the Royal Mail provides a moment to reflect on how this ideological climate has been constructed and reinforced, and to consider other ways in which this vital debate might be framed.

Nowadays, privatisation of the post is often presented as something of an inevitability, based on European Commission edicts and sound economic reasoning, but, as we shall see, this perception is predicated on value-laden research, commissioned from right-wing think-tanks and market-friendly management consultants, which in turn relies on skewed economic modelling and politicised appointments at the highest levels. And, while the continued provision of a state-run postal service has been hotly debated in recent months, the post has been the subject of a deliberate and sustained campaign to manufacture consent around privatisation dating back forty years.

The roots of the Royal Mail's current precarity can be traced to 1969, when the Post Office first achieved quasi-autonomy from government. Having operated under the auspices of the state since early in the reign of Henry VIII, the decision was taken that a government department was ill-equipped to run such a large organisation. At the instigation of two Postmasters General - Clement Attlee and Tony Benn - the Post Office became a public corporation, with the government as its sole shareholder, employees relinquishing their civil servant status and a Minister for Posts and Telecommunications being appointed - a short-lived role that soon devolved to the Department of Trade and Industry (DTI). In the process, the Post Office maintained an obligation to undertake daily collections and to deliver mail to every address in the United Kingdom, however remote, for the same price. In order to fulfil this universal service obligation (USO), the Post Office retained the exclusive privilege of delivering letters. As we shall see, the letter monopoly has historically been highly contested territory, with threats of its temporary removal being made in an attempt to break the postal strikes of 1996.

Over the next three decades, the Post Office continued its operation on this basis, with targets being set by Westminster and profits being skimmed off until well into the 1990s. This period in the UK closely corresponds with the rise of neoliberalism, which, as we have witnessed countless times, translates into ‘tactics or policies that result in diminishing the authority of the state or public sector in society, especially in the market, and placing large, private corporations at the top of organised society. This implies, firstly, that corporate leaders make a pact with certain political figures and/or organisations in governmental and international bodies, in order to lay the legal basis for this movement or transition.'4 And so it came to pass that, in 1997, the European Commission issued a Directive to establish a single market for postal services in Europe. This specified that all European Community residents were entitled to access a universal service at an affordable price reflecting costs. On an interim basis, as part of a ‘gradual and controlled liberalisation of the market', the Directive allocated an area to providers of the universal service, below which weight and price postal competitors could not operate.5

In the UK, a White Paper was published in response, outlining the many benefits of competition, and detailing changes aimed at protecting the universal service without direct public subsidy.6 While reducing the percentage of profits withdrawn by the Exchequer, the White Paper proposed halving the letter monopoly, significantly reducing the reserved area proposed by the European Commission. This document also proposed transforming the public corporation into a public limited company with all shares owned by the Crown - a change in structure which was implemented in the Postal Services Act (2000) and would facilitate future privatisation.

In November 2000, Royal Mail chief executive, John Roberts, appealed to the European Parliament not to allow the reserved area to drop any further but his protest fell on deaf ears and Roberts was replaced by the more ‘on-message' Adam Crozier, former Saatchi and Saatchi Joint Chief Executive, who became the highest paid public sector employee and fully endorsed Royal Mail's commitment to a competitive marketplace.7 Considering other key personnel, the main protagonist responsible for postal reform in Europe is Charles McCreevy, Commissioner for the Internal Market and Services portfolio since 2004, who is widely known as a free-marketeer.8 Giving a speech in London in 2006, then-Chancellor of the Exchequer, Gordon Brown, heralded a new wave of liberalisation across Europe and announced that the Treasury was working with McCreevy to achieve this.9 The pro-market stance evinced by McCreevy in Europe and Brown in the UK is consolidated at the government department formerly known as Trade and Industry (which, in 2007, was tellingly renamed the Department of Business, Enterprise and Regulatory Reform), where the Select Committee is chaired by Conservative MP, Peter Luff, who has links to PR and lobbying company, Bell Pottinger (advisors to biotech giants Monsanto).10

Under the provision of the Postal Services Act (2000), a new Postal Services Commission, Postcomm, was set up to maintain the universal service and to issue licenses to entrants to the market. This delegation of powers by government is akin to the Bank of England being charged with determining interest rates, but the DTI retained jurisdiction over appointments to the boards of both Royal Mail Group and Postcomm and to the Chair of Postwatch, the postal watchdog. In 2002, at a time of strained relations between Royal Mail and Postcomm, leading labour donor, Allan Leighton, was appointed Royal Mail Group Chairman by Tony Blair. Responsible for making the post profitable, while borrowing money from the government on commercial terms to improve the fortunes of the ailing service, Leighton reportedly secured a secret deal to privatise the Royal Mail as a condition of his reappointment and is on record proposing various management and staff buyouts of the postal service.11 And, while Leighton was replaced by banker, Donald Brydon, in March 2009, the Royal Mail Group board continues to be wholly comprised of notables from the business world, which goes some way towards explaining the overall complicity of postal executives when confront

ed with liberalisation proposals.

The picture at Postcomm is markedly similar, with pronounced business interests within its constituents. Its Chair, Nigel Stapleton, is Non-Executive Director of both the London Stock Exchange and Reliance Security Group. Beneath him sits, amongst others, Stephen Littlechild, described as ‘an international consultant on regulation and privatisation' who declares no potential conflicts of interest on the Postcomm website.12 However, in 1981, Littlechild was commissioned to write an article for the in-house journal of the Institute of Economic Affairs (IEA), entitled ‘Ten Steps to Denationalisation'. Unequivocal about the need to introduce competition into nationalised industries, Littlechild tempers Enoch Powell and Milton Friedman's calls for ‘immediate and wholesale denationalisation' to suggest a significant movement towards it.13 The postal service forms the tenth step in his proposed denationalisation programme, beginning with a sale of the profitable (non-rural) parts of the business. In what would appear to be a self-fulfilling prophecy, this man now oversees the introduction of competition into the postal sector.

Image: 1950s postal deposit

The highly politicised nature of these appointments consolidated the Royal Mail as a major battleground for neoliberal ideologues, with the London-based Institute of Economic Affairs (for which Littlechild penned his pamphlet) being paramount. Founded in 1955 as an offshoot of Friedrich von Hayek and Milton Friedman's Mont Pelerin Society, the IEA nurtured Keith Joseph, who became one of Margaret Thatcher's key advisers. David Miller and William Dinan outline three waves of pro-corporate spin in the UK - the first (1911 - 30) centred on National Propaganda, the main industry-funded corporate propaganda organisation of the inter-war years; the second (1936 - 50), beginning in the US in the wake of the Wall Street Crash, prompted by the loss of faith in big business exemplified by the New Deal; the third taking us up to the 1980s, during which period the Mont Pelerin Society recruited Times editor, William Rees Mogg, to the cause of market fundamentalism and the IEA gained in influence.14

In considering more closely some of the attempts to manufacture consent around postal privatisation, a consistent voice - becoming increasingly shrill over the decades - is that of Ian Senior, who began his career as a civil servant with four and a half years at Post Office HQ, latterly as private secretary to the last Assistant Postmaster General. In a background memorandum, published by the IEA a year after the 1969 devolution of the Post Office from government, Senior concluded that ‘what is needed is the creation of an environment which gives to PO managers not only the freedom to manage with more efficiency, but also the incentive to do so [...] for it is widely accepted that competition coupled with free consumer choice creates the best environment for productive enterprise.'15 This led Senior to argue that the letter monopoly - which had been subsidising less profitable areas of the corporation, including the collection from/delivery to rural areas as part of the USO - was unjustifiable and should be removed, and that the uniform tariff for letter delivery should be revised.

Writing in 1983, again for the IEA, Senior's calls for the abolition of the letter monopoly and an end to the practice of cross-subsidisation were subordinated to a consideration of dividing the Post Office into its component parts and selling them off to the public.16 Three years later, under the umbrella of the Royal Mail Group, three separate companies - Post Office Counters, Royal Mail and Parcelforce - were created, which was viewed by some as a prelude to privatisation (as the separation of telecoms from posts had been under the British Telecommunication Act of 1981). But Michael Heseltine, President of the Board of Trade under John Major, was urged to drop his controversial privatisation plans and duly did so in 1994.17

The essence of Senior's position - that competition necessarily yields efficiency and customer satisfaction, and that the postal market should be opened up to such positive forces - has been sustained throughout his extensive commentary on the subject, and is strongly echoed in recent policy on postal reform. Having countered privatisation while in opposition, by 1999 the New Labour government believed that ‘competition encourages innovation, productivity and growth. Where there is competition in postal markets, and where it is anticipated, here and abroad, it is already leading to a diversity of products, tailored to meet consumer needs'.18 By the turn of the millennium, the postal service had become a key part of New Labour's PPP strategy.19

 

Image: Communication Workers Union banner

This dovetailing of the views of Thatcherite ideologues with those of more recent policy-makers becomes clearer if some of the research commissioned into the economics of liberalisation is examined. In 1998, in the wake of its first Directive on postal services, the European Commission approached National Economic Research Associates (NERA) to undertake an analysis of the cost to each of its Member States of the USO. It was understood that the results of this study would assist the Commission in determining how much (if any) compensation would be needed by universal service providers, and whether cross-subsidy from a reserved area or compensation from an independent fund would be the most appropriate way of securing continued provision in a competitive marketplace. By subtracting the losses made in unprofitable parts of the business from the net profits, NERA concluded that the cost of providing the USO is negligible (£22.6m) and that, rather than offering compensation to providers, the imposition of universal service should be reconsidered in a liberalised environment. It should come as no surprise that the published report cites as part of its project team none other than Ian Senior, self-declared ‘special adviser in the London office of NERA', who subsequently re-iterated their flawed findings to justify market liberalisation in yet another IEA missive.20

The Royal Mail refuted NERA's methodology - on the basis that, in considering a stable market, it fails to take account of competition - and responded with an alternative approach, developed by PricewaterhouseCoopers, which aims to take account of the liberalised environment and the reduced monopoly this implies. Mapping different scenarios, this report concluded that between 24% and 90% of normalised profits (approx. £200-750 million a year) could be lost. Researchers at the University of Zurich compared these two methods of evaluating USO and dismissed the NERA method as having little relevance to a competitive situation. By contrast, they concluded that the PricewaterhouseCoopers method seems to produce a more reliable model of the cost of USO in a competitive environment, assuming that the universal service provider has already maximised efficiency; otherwise, the cost of modernising the service in order to compete diminishes overall profits and increases the relative cost of USO.

Since full liberalisation came into effect in 2006, competition has grown more rapidly than anticipated in the areas of collection and sorting, with Royal Mail being left with the unprofitable final mile of deliveries and any forecast growth in the postal sector failing to materialise sufficiently to compensate for the market share lost to its competitors, invalidating Postcomm's confident claims that Royal Mail would maintain a 90% market share by 2010.21 For the fiscal year ending in March 2009, Adam Crozier acknowledged that external revenue in the letters market ‘fell by £123 million - nearly 2% - despite postage price rises in April 2008 averaging around 5%.'22 This is compared to an increase of £157 million in the financial year 2001-2, when the post was blighted by anthrax scares and the 11 September attacks. This exposes the method of calculating the USO favoured by the European Commission/NERA as farcical and shows that, at the lower end of its forecast, the Royal Mail underestimated the losses that would be incurred in a competitive environment.

 

Image: Rural postal worker

Before considering how the ideological impetus underlying this dubious economic modelling has continued into more recent research in the postal sector, it is worth mentioning that, in 1998, Royal Mail, together with several other national postal operators, sponsored a piece of research by the Institute for the Future. The subsequent report presents liberalisation as a foregone conclusion, and considers strategies of survival rather than reversal. Tracing contemporary emphasis on efficiency to the Chicago School of Economics and IEA, it offers a laudatory account of the history of deregulation in the US, the UK and Chile. Projecting ahead to 2010, the report finds that ‘posts are privatized; the monopoly is ended; more prices are determined by market forces; regulators ensure the interconnection of all players; universal service is achieved by the whole sector'.23 Little wonder, then, that the Royal Mail offered little resistance to liberalisation when the businessmen on its board were confronted with a near-reality formulated by serious researchers; little wonder, also, that these were the conclusions drawn by the Institute for the Future, founded as it was by a group of former RAND Corporation researchers with a grant from the Ford Foundation, an association with demonstrable links to covert foreign policy.24

And what of the regulators invoked by the Institute for the Future? In the nine years of its operation to date, Postcomm has been the major commissioner of research into the postal sector, allocating over £20 million to ‘outside consultants, lawyers etc.'25 Early in its history, Postcomm received the results of research it had commissioned from Frontier Economics - a consultancy firm with a proven pro-privatisation agenda - into the relationship between liberalisation and efficiency.26 The findings asserted that ‘the proposition that competition leads to improvements in efficiency can be supported empirically. Numerous studies point to the efficiency benefits of liberalised competitive markets'.27 At the same time, the National Audit Office published a report into postal operations, portraying an obstinate universal service provider unwilling to increase efficiency without the incentive of private shareholders and adopting Postcomm's conviction that ‘competition delivers greater benefits than regulation in terms of the price, quality and innovation'.28 This tacit confirmation that increased efficiency would be certain to guarantee the Royal Mail protection from liberalisation set the tone for ongoing research initiatives. And, while Royal Mail vehemently refuted that a connection between liberalisation and improved performance had been demonstrated by Frontier Economics, by neglecting to commission counter research it became complicit in the policies determining its fate.29

Whereas ‘neoliberal politicians might argue that a service or public industry would become more efficient if it were free from governmental bureaucracy', it is suggested that ‘those myths have been widely contested by people who have actually experienced the privatisation of industry or services, as efficiency issues after privatisation are often neglected.'30 And, while the Royal Mail has succumbed to the logic of efficiency in anticipation of potential privatisation, in the absence of investment this has simply been translated into a loss of tens of thousands of jobs. At the time of writing, postal workers are involved in a series of strike actions intended to bring the executive and government to the table for reneging on its modernisation plans, and the Communication Workers Union (CWU) - which has consistently opposed the liberalisation agenda advocated by the Royal Mail and Postcomm31 - is accusing the Royal Mail of failing to re-design deliveries and to provide the necessary machinery.32

In May 2002, Postcomm pre-empted the European Commission's call for Member States to provide a timetable for the opening of their postal markets.33 Placating anxieties about rushing the competitive process, Postcomm announced that liberalisation would be an elongated three-phase process.34 Despite the Treasury expressing concern about threats to the USO in a competitive environment, scepticism about Postcomm's economic modelling and disapproval that ‘Postcomm have made use of expert consultants, but these are no substitute for in-house expertise', the regulator continued in its trajectory.35 Two years later, concerned that competition was not forthcoming at the rate and intensity desired, Postcomm undertook a competitive market review to propose that cross-subsidy be eradicated and Royal Mail be stripped of its VAT-free status, further handicapping the universal service provider in the face of competition.36 In a direct example of the bilateralism between ‘research' and policy, Postcomm also followed the advice of Frontier Economics to launch a consultation into a revised market opening timetable,37 which led to full market opening being brought forward by fifteen months and the intermediate step being eradicated, a move that was later condemned as untimely by the Trade and Industry Select Committee.38 As banks and other major companies and government departments - spurred on by Rupert Murdoch - fled Royal Mail in favour of its two main rivals - Deutsche Post and TNT - Postcomm did all it could to help entrants to the market, preventing Royal Mail from triggering price reviews to generate much-needed funds and imposing hefty performance-related fines that were greeted with glee by its competitors.39

In UK academia, research generally consolidates the neoliberal consensus outlined above. In a 2004 dissertation for the University of Durham, for example, Nick Steven-Jones relies heavily on Ian Senior's arguments to summarise ‘it can be seen that with effective introduction and regulation a market is almost always vastly improved by the introduction of competition and subsequently most problems relating to the requirement for a the [sic] universal service become insignificant'.40 Research conducted at the ‘independent and politically neutral' Centre for the Study of Regulated Industries - based at the University of Bath School of Management, which lists NERA as one of its sponsors - offers an overview of the various roles and responsibilities of the relevant parties to the postal debate without critical commentary.41 Similarly, research commissioned at the University of Warwick by the National Audit Office attempts an empirical analysis of the economic models used to cost USO by the European Commission, Postcomm and Royal Mail but fails to add anything significant to the discussion.42 In short, the skewed research commissioned by the European Commission and Postcomm in the wake of IEA pro-privatisation propaganda has created a rhetorical climate in which efficiency is everything, aimed at maximising the profits that this beleaguered public sector institution is now consistently expected to make.

In December 2007, the Secretary of State for Business, Enterprise and Regulatory Reform, John Hutton, appointed businessman, Richard Hooper, to undertake a review of the liberalised postal services sector, aimed at preserving the universal service. Deputy Chairman of Ofcom (the telecoms equivalent of Postcomm) between 2002 and 2005, Hooper was advised in this process by Taylor Woodrow's Ian Smith and by Dame Deirdre Hutton, a shareholder in some of the UK's major companies and advisor to pro-market think-tank, the Social Market Foundation. The review team's interim report, published in May 2008, acknowledges the threat to the universal service under the current conditions, but ruled out a return to statutory monopoly under EU rules to broadly consolidate the benefits of market opening.43 Postcomm, which will have the task of devising the regulatory framework that will take effect when the last remaining price controls are lifted in April 2010, seized upon the review's ethos to recommend the de-coupling of the letters business to facilitate the entry of outside capital.44

Building on the consensus that has been engineered around the postal service, Hooper's team took as its starting point the ostensibly undisputed inefficiencies within the mail network in the face of enforced modernisation from Europe, and the view that effective competition would bring about positive outcomes. Having already rejected a solution to the postal predicament which might have entailed future public funding, the conclusion made at the close of 2008 was that the Royal Mail should seek a strategic partner from the commercial sector.45 Inscribing Hooper's circular arguments into the Postal Services Bill (2009), Business Secretary, Peter Mandelson, obligingly made provision for the Royal Mail to be ‘publicly owned', which, with typical political sleight of hand, means that up to 49% of its shares may be bought by a body other than the Crown.

 

Image: Postal workers warming themselves during a strike

It is this Bill - underwritten by parliamentary rebellion, profound dissatisfaction amongst the Royal Mail workforce and widespread public opposition - that has now stalled. More than mere sentimental attachment to a postal network built up over five centuries, this signals deeper resistance to rule by the European trade federation and the neoliberal agenda underlying it. A generation that has lived through a period of irrevocable privatisation, and experienced the crippling costs that are its inevitable consequence, is in the process of developing arguments against the free market. And, while rebel ministers seem genuinely willing to consider a non-profit model for the postal service, one of the main ideological responses being put forward, by the ‘independent democratic left pressure group', Compass, persists in proposing reform on the basis of future profitability.

Meanwhile, the CWU has engaged Blue State Digital to assist in its campaign to ‘Keep the Post Public'.46 This next-generation lobby group was instrumental in Barack Obama's presidential campaign, deploying online tools to convince more than three million donors to contribute in excess of $500 million of funds.47 While the development of Web 2.0 under the aegis of corporate capitalism, at the expense of the genuine democratic potential of peer-to-peer networking, has been widely criticised in these pages, its deployment by spin doctors and lobby groups arguably represents a fourth wave of corporate spin.48

As the endgame of neoliberalism is played out at the postal frontier, those opposing the privatisation of public services ought to regard the inability of free-marketeers to construct consent around liberalisation as an inadvertent victory. The postal interregnum must be seized upon to reconsider the primacy that has hitherto been given to profit-making in the public sector; it precipitates a re-examination of the claims made for competition, and a deconstruction of the ethos of efficiency; it permits questions to be asked about the fate of a pension deficit that seemed easy to plug with public money when it benefited private interests; and, perhaps most of all, it offers space in which to reconsider tactics in light of the millions squandered to lobby groups and think tanks that were ultimately unable to influence what we think.

Having worked as a curator in London, Glasgow and the Nordic countries, Rebecca Gordon-Nesbitt <rebecca AT shiftyparadigms.org>receded from direct participation to concentrate on research into the infrastructure of the art world, its institutions and economies. Committed to the use of investigative research in exposing elites, she retains a belief in the radical potential of art

Footnotes

1 Tim Webb, ‘Dutch frontrunner for Royal Mail accused of bullying workforce', The Guardian, Tuesday 10 March, 2009, p. 27.

2 Holly Watt, ‘Post reformation', The Sunday Times, 1 March 2009, p. 20.

3 David Harvey, A Brief History of Neoliberalism, Oxford: Oxford University Press, 2005, p. 19 (italics in original).

4 Antonio Carmona Báez, State Resistance to Globalisation in Cuba, London: Pluto Press, 2004, p. 8.

5 Directive 97/67/EC of the European Parliament and of the Council of 15 December 1997 on common rules for the development of the internal market of Community postal services and the improvement of quality of service, p. 1.

6 Department of Trade and Industry, Post Office Reform: A World Class Service for the 21st Century, Cm 4340, Presented to Parliament by the Secretary of State for Trade and Industry, July 1999.

7 Anon, ‘Royal Mail hits back at EC plan', Precision Marketing, 6 November, 2000.

8 See Honor Mahony, ‘Free marketers in top commission posts', EU Observer, 13 August, 2004.

9 HM Treasury, ‘Check against delivery', Speech by the Chancellor of the Exchequer, the Rt Hon Gordon Brown MP at the Mansion House, London, 21 June, 2006.

10 Antony Barnett and Oliver Morgan, ‘Resign call over MP's link with GM food firm', The Observer, Sunday 11 July, 1999, http://www.guardian.co.uk/science/1999/jul/11/gm.food

11 Steve Schifferes, ‘Who's backing Labour?' BBC News Online, Monday, 14 May, 2001.

12 http://www.psc.gov.uk/about-postcomm/commissioners-and-directors/stephen-littlechild.html

13 Stephen Littlechild, ‘Ten Steps to Denationalisation', Economic Affairs, October 1981.

14 David Miller and William Dinan, A Century of Spin: How Public Relations became the Cutting Edge of Corporate Power, London: Pluto Press, 2008.

15 Ian Senior, The Postal Service: Competition or Monopoly? Background Memorandum 3, London: Institute of Economic Affairs, 1970, p. 30.

16 Ian Senior, Liberating the Letter: A proposal to privatise the Post Office, Research Monographs 38, London: Institute of Economic Affairs, 1983.

17 Colin Brown, ‘Tories seek to delay Royal Mail break-up', The Independent, 9 April 1993, p. 4.

18 Department of Trade and Industry, 1999, op. cit., p. 5.

19 HM Treasury, Public Private Partnerships: The Government's Approach, London: The Stationery Office, 2000.

20 Ian Senior, ‘A Penny on the Post: Too little, too late, too intrusive', London: Institute of Economic Affairs, 2003, p. 4. See, http://www.iea.org.uk/files/upld-book335pdf?.pdf

21 Anon, ‘Royal Mail "will still dominate market in 2010"', Precision Marketing, 4 November, 2005.

22 Adam Crozier, ‘Chief Executive's Report', Royal Mail Holdings plc, Report and Accounts Year ended 29 March 2009, 2009, p. 6.

23 Peter Hanley and Greg Schmid, ‘Surviving Deregulation: A Postal Scenario for 2010', Silicon Valley: Institute for the Future, 1998, p. 64.

24 Daniel Brandt, ‘Philanthropists at War', NameBase NewsLine, No. 15, October-December 1996. See, http://www.namebase.org/news15.html

25 These figures, found in Postcomm's annual accounts at http://www.psc.gov.uk/about-postcomm/annual-reports-and-plans/archived-reports-and-plans.html

26 For more on Frontier Economics, see http://spinprofiles.org/index.php/Frontier_Economics

27 Frontier Economics, ‘The Impact of Liberalisation on Efficiency: a survey: A report prepared for Postcomm', January 2002, p. 2.

28 Comptroller and Auditor General, ‘Opening the Post: Postcomm and postal services - the risks and opportunities', London: National Audit Office, HC 521, Session 2001-2002: 24 January 2002.

29 ‘Consignia's Comments on "The Impact of Liberalisation on Efficiency: A Survey - A report prepared for Postcomm by Frontier, January 2002"', April 2002, p. 1.

30 Carmona Báez, 2004, op. cit., p. 9.

31 See, for example, Communication Workers Union, ‘Postcomm's Competitive Market Review: CWU Submission', 2004, http://www.psc.gov.uk/postcomm/live/policy-and-consultations/consultations/competitive-market-review/CWUsresponsetoCMR.pdf

32 ‘Postal Strikes as Royal Mail Blocks Modernisation', http://www.cwu.org/news/archive/postal-strikes-as-royal-mail-blocks-modernisation.html

33 Directive 2002/39/EC of the European Parliament and of the Council of 10 June 2002 amending Directive 97/67/EC with regard to the further opening to competition of Community postal services, Paragraph 14.

34 ‘Promoting Effective Competition in UK Postal Services: A Decision Document', May 2002, http://www.psc.gov.uk/policy-and-consultations/documents-by-date/2002/FINAL_Decision_document_29_May.pdf

35 HM Treasury, ‘Treasury Minutes on the Thirty-first to the Thirty-fifth Reports from the Committee of Public Accounts 2001-2002', Presented to Parliament by the Financial Secretary to the Treasury by Command of Her Majesty, July 2002, p. 6.

36 Postcomm, ‘Competitive Market Review: Proposals for Consultation', September 2004.

37 Postcomm, ‘A Revised Market Opening Timetable: Proposals for Consultation', September 2004, http://www.psc.gov.uk/postcomm/live/policy-and-consultations/consultations/market-opening-timetable/ARevisedMOT2004.pdf

38 ‘The evidence that liberalisation delivers an improved service for customers is compelling but we regard Postcomm's choice of dates for the move to full liberalisation in the UK postal services market to be an untimely one.' House of Commons Trade and Industry Committee, Royal Mail after Liberalisation: Second Report of Session 2005-06 Volume I, HC 570-I, London: The Stationery Office, 2005.

39 Terry Macalister, ‘Pressure grows on Royal Mail as Sky opts for TNT, The Guardian, 19 January 2005, p. 18.

40 Nick Steven-Jones, ‘The Implications and Consequences of the Introduction of Competition into the Postal Monopoly in the UK', University of Durham, 2004, p. 2.

41 Constantina Bichta, ‘Regulation of UK Postal Services', Centre for the Study of Regulated Industries, University of Bath School of Management, 2002, p. ii.

42 Martin Cave, ‘Cost modelling requirements for Postcomm's regulatory purposes', University of Warwick, August, included as Appendix 6 in Comptroller and Auditor General, 2002, op. cit., pp. 57-66.

43 Richard Hooper, Deirdre Hutton and Ian R Smith, ‘The challenges and opportunities facing UK postal services: An initial response to evidence', May 2008, www.berr.gov.uk/files/file46075.pdf

44 Postcomm, ‘The independent review of the postal services sector: Second submission by Postcomm, the industry regulator', 2008, http://www.psc.gov.uk/postcomm/live/independent-review/Postcomm_Second_submission_to_the_Independent_review.p df

45 Richard Hooper, Deirdre Hutton and Ian R Smith, ‘Modernise or decline: Policies to maintain the universal postal service in the United Kingdom', London: The Stationery Office, 16 December, 2008.

46 See Nadia Ghani, Brand Republic, 2 March 2009, http://www.brandrepublic.com/News/886683/Obamas-digital-agency-hired-fight-against-Royal-Mail-privatisation/?DCMP=ILC-SEARCH

47 Obama for America on Blue State Digital, http://www.bluestatedigital.com/casestudies/client/obama_for_america_2008/

48 See, for example, Dmytri Kleiner and Brian Wyrick, ‘Info Enclosure 2.0', Mute, Vol 2, #4, Winter 2006, pp.10-19, http://www.metamute.org/en/InfoEnclosure-2.0