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Opinion N ° 2013 - 0865 July 2, 2013, On A Draft Decree To The Objectives Of Quality Of Service Attached To The Post Office For 2013 In Respect Of The Supply Of Universal Service That La Poste Is Required To Provide Pursuant To Article 2 Of The Code...

Original Language Title: Avis n° 2013-0865 du 2 juillet 2013 sur un projet d'arrêté relatif aux objectifs de qualité de service fixés à La Poste pour 2013 au titre de l'offre de service universel que La Poste est tenue d'assurer en application de l'article L. 2 du code...

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JORF n ° 0188 August 14, 2013
Text N ° 69




Opinion n ° 2013-0865 of 2 July 2013 on a project d 'decree relating to the quality of service objectives set at La Poste for 2013 under the heading of the#039service that La Poste is held d ' ensure in application of L 'article L. 2 of the postal code and electronic communications

NOR: ARTR1321053V ELI: Not available


The Electronic Communications and Regulatory Authority Posts (hereinafter " The Authority),
Having regard to Directive 97 /67/EC of the European Parliament and of the Council of 15 December 1997 as amended concerning common rules for the development of the internal market in Community postal services and the improvement of the quality of service (hereinafter " Postal Directive);
In the light of the postal code and electronic communications (hereinafter " CPCE "), and in particular its articles L. 2, L. 5-2 (4 °), R. 1-1-8;
Seen the Law n ° 2010-123 of 9 February 2010 on the public company La Poste and the postal activities;
In view of the decree of 22 July 2008 on the quality of service objectives set at La Poste for the year 2008 in respect of the universal service offer that La Poste is required to provide pursuant to Article L. 2 of the Postal Code and the Electronic communications;
Seen the Order of 8 June 2009 concerning the objectives of Quality of service set at La Poste for the year 2009 in respect of the universal service offer that La Poste is required to provide pursuant to Article L. 2 of the code of posts and electronic communications;
In view of the decree of 30 January 2012 Relating to the quality of service objectives set at La Poste for 2011 and 2012 in respect of the universal service offering which La Poste is required to provide pursuant to Article L. 2 of the code of posts and electronic communications;
Opinion No. 2008-0216 of the Electronic Communications and Postal Regulatory Authority As of 11 March 2008 on a draft decree relating to the quality of service objectives fixed at La Poste under the universal service provision which La Poste is required to provide pursuant to Article L. 2 of the Postal Code and of the Electronic communications;
In view of Opinion n ° 2009-0243 of the Electronic Communications Regulatory Authority and of posts dated 2 April 2009 on a draft decree on the quality of service objectives set at La Poste under The provision of universal service which La Poste is required to provide pursuant to Article L. 2 of the Code of Posts and electronic communications;
In view of Opinion n ° 2010-0847 of the Electronic Communications Regulatory Authority and of the posts of 20 July 2010 on a draft decree on the quality of service objectives set out in La Position, for the year 2010, in respect of the universal service offer which La Poste is required to provide pursuant to Article L. 2 of the Code of Postal and Electronic Communications;
In view of Opinion No. 2011-0416 of the Regulatory Authority Electronic communications and posts as of 7 April 2011 relating to a Modification of the universal postal service provision catalogue;
In view of Opinion No. 2011-1509 of the Electronic Communications Regulatory Authority and of the posts of 22 December 2011 on a draft decree on the objectives of Quality of service set at La Poste, for the years 2011 and 2012, in respect of the universal service offer which La Poste is required to provide pursuant to Article L. 2 of the code of posts and electronic communications;
In view of the opinion No. 2012-1352 of the Electronic Communications and Communications Regulatory Authority 11 December 2012 on a modification of the universal postal service catalog;
Seen the catalogue of commercial offers from La Poste of the universal postal service as of 1 July 2013;
Given the conditions Specific sales of La Poste relating to the forwarding of mail;
In view of the request for an opinion of the Minister responsible for posts transmitted to the Authority on 19 June 2013 and completed on 24 June 2013;
After deliberation on 2 July 2013,



I. -The Legal Framework


CPCE Article R. 1-1-8 provides that " The Minister responsible for posts, after having placed the universal service provider in a position to submit his observations and having obtained the opinions of the Electronic Communications Regulatory Authority and the posts and the committee Of the public postal service and electronic communications, shall establish quality objectives applicable to the benefits of the universal service which it determines. These objectives relate to the timeliness and reliability with which these benefits are provided. "
In application of these provisions, the Minister responsible for posts seized the Authority on 19 June 2013 for an opinion on a draft decree" Relating to the quality of service objectives set at La Poste, for 2013, in respect of the universal service offering which La Poste is required to provide pursuant to Article L. 2 of the Code of Postal and Electronic Communications
. Has previously issued the following opinions on the objectives relating to the speed and reliability of the universal service:
- opinion n ° 2008-0216 of 11 March 2008 on a draft decree on the quality of service objectives set at La Poste, for 2008, for the service offering Universal;
-Opinion n ° 2009-0243 of 4 March 2009 on a draft decree setting targets for 2009;
-Opinion n ° 2010-0847 of 20 July 2010 on a draft decree setting targets for 2010, but this order has never been published ;
- notice n ° 2011-1509 of December 22, 2011 on a draft decree setting targets for 2011 and 2012.


II. -The draft decree
Regarding the quality of service measuring device


The draft order transmitted to the Authority provides, concerning the applicable quality of service measurement methodology, that:
- " The quality of service measures of the priority letter, the letter Verte and Community cross-border mail must be carried out in accordance with the European standard EN 13850. ' ;
- " The measurement of the quality of service of the recommended letter should be carried out on the basis of the methodology laid down in the EN 14137 standard. ;
- " The measurement of the quality of service of the Colissimo window must be carried out according to a method which must be computerized, explained and auditable " ;
- " The method of measuring the processing of claims must comply with the principles advocated in the European standard EN 14012 " ;
- " The measurement of the rate of repair of the reported malfunctions relating to the re-shipment service must be carried out according to a method which must be computerized, explained and auditable ".


For quality indicators Service


The draft order transmitted to the Authority includes, on the whole, the quality of service indicators retained in the previous order of 30 January 2012.
Two developments are however foreseen in this draft decree:
-a new quality indicator for the post office reorder service has been created: " The measurement of the rate of repair of the reported malfunctions relating to the re-shipment service shall be carried out in accordance with a method which must be computerised, explained and auditable " ;
-the indicator for the measurement of the rate of loss of recommended letters, as set out in the previous decree, no longer appears in the draft decree submitted to the Authority.
The following table outlines the objectives set or proposed by the Minister responsible for posts and the quality of service achieved.



You can view the table in
JOn ° 188 of the 14/08/2013 text number 69



III. -On the measuring devices of the quality of service
Concerning the letter Verte


As regards the method of measurement applicable to the letter Verte, the Authority approves the fact that the draft decree provides for the application of the EN standard 13850, as it had proposed in its Opinion n ° 2011-1509 of 22 December 2011. Although applicable, in principle, to the quality of service of priority consignments, this standard adopts a methodology adapted to non-priority shipments and has also been revised in 2013.
In addition, The application of the EN 13850 standard to the Verte letter makes it possible to organise jointly the measure of the quality of the priority letter and that of the letter Verte and the audit of control of these measures.


Concerning the letter Recommended


The draft order states that the measurement of the rate of distribution in J + 2 shall be Be carried out according to the methodology laid down in the EN 14137 standard. This standard normally applies to the measurement of the rate of excessive loss and delay of recommended shipments. However, the methodology which it provides and which is based on the generalization of a flashing system for the input and output of the postal network, appears to be perfectly adapted to also measure a delivery time in J + 2.
The Position has undertaken significant work to put in place a quality measure of the recommended letter in accordance with the EN 14137 standard. It therefore appears appropriate that the draft decree provides for the use of the standard EN 14137 for the measurement of the quality of service of the recommended letter.
However, the Authority considers that compliance with the EN 14137 standard should cover not only The measurement of the delivery times in J + 2 of the recommended letter but also the measurement of the rate of loss and the excessive delays in distribution of it.
Thus, the Authority considers that, like the decree on quality objectives Service of La Poste for 2011 and 2012, the draft decree for 2013 must provide for Expressly that the rate of loss and undue delay of the recommended letters of La Poste be measured, in accordance with the EN 14137 standard.


Colissimo


There is currently no European standard for The measurement of the quality of service of packages. In this context, the Authority agrees with the Minister's proposal that this measure should be carried out in accordance with a method " Computerised, explained and auditable ".
The measure of the quality of service of the packages of the universal service is now carried out by La Poste on the basis of a flashing of the input and output of the network. The delivery time of each package is thus measured by difference between the dates of the flashage at the entry and exit of the postal network.
The methodology put in place by La Poste was the subject of a study commissioned by the Authority in 2009. From ETDE LS. The results of this study have shown that the reliability of the measure is generally satisfactory.


Re-shipment service


The Authority considers it appropriate to introduce a new indicator as well as a Associated objective regarding the quality of the La Poste re-shipment service. This service, which is of great use to users, in particular during a change of address, is the subject of a relatively large number of complaints with the services of La Poste and the group's Ombudsman. It is therefore essential to be able to assess the level of quality of the re-shipment service provided by La Poste to users and the introduction of an objective set by the Minister should have an incentive effect to the improvement of the Service.
However, the language used, which refers to " Rate of repair of reported malfunctions relating to the re-shipment service ", is incomprehensible. The formulation " Recovery rate of service as a result of reported malfunctions related to the reshipping service " Appears preferable.


IV. -On the level of quality of service objectives


In general, the Authority welcomes the significant and continuous improvement in the quality of service of La Poste observed in recent years. In order to assess the scope of the quality of service objectives envisaged in the draft decree transmitted to it, the Authority analysed the progress of the quality of service results recorded by La Poste, in particular with regard to the latter
For the Verte letter, the quality of service results obtained in 2012 and the first quarter of 2013 seem to reflect a stagnation in service quality, or even a slight decline, with regard to the first quarter results 2013, which can be due to climate events. On the other hand, the quality of service of the priority letter has continued to increase since 2010, recording an increase of 4.5 points in three years. The improvement in quality of service is even more significant with regard to the recommended letter, which increased by nearly 9 points between 2010 and 2012 and made further progress in the first quarter of 2013.
Such progress achieved by La A position concerning the quality of service of the universal service is likely to encourage the setting of relatively ambitious objectives in this improvement path.


As regards the priority letter


For the priority letter, the draft order provides that the Distribution in J + 1 must be greater than 85 %. As pointed out by the Authority on several occasions, notably as part of its Opinion n ° 2011-1509 of 22 December 2011, and most recently, in its opinion No. March 26, 2013 on the draft company contract, a target of 85 % does not appear in line with the trajectory of progress of La Poste, in particular with regard to the results achieved by La Poste in 2011 and 2012 (87.3 % and 87.9 % respectively) Distribution in J + 1).


Verte letter


The quality of service objective for the Verte letter is a rate of 93 % in J + 2 distribution. The Authority recalls that, as announced by La Poste during the creation of this new offer, the quality of service of the letter Verte must, in the long term, reach a level of 95 % distribution in J + 2.
However, despite Relatively good results in 2012, with a rate of 92.8 % distribution in J + 2, the quality of service of the letter Verte marks a slight decline in the first quarter of 2013, reaching 91.7 % of J + 2 compared to 91.9 % in the first quarter of 2012. This decline, the scope of which must be put into perspective because it only corresponds to a single quarter and a difficult period at the climate level, does, however, reflect the need to monitor the progress of the quality of service of the letter Verte au In the coming quarters. In this context, a target of 93 % J + 2 appears acceptable for 2013, knowing that this rate is expected to increase to 94 % in 2014 and 95 % in 2015, in accordance with the 2013-2017 company contract.


About the recommended letter


The draft decree envisages a target of 93 % of J + 2 for the letter recommended in 2013. In view of the important progress made by La Poste concerning the quality of service of the recommended letter, this objective could be more ambitious. Indeed, in the last four quarters (1), the average quality of service achieved by La Poste was more than 94.9 % of the J + 2 distribution; it was 95.5 % in the first quarter of 2013, compared with 94.7 % in the first quarter of 2012. The
also recalls, as it pointed out in its Opinion n ° 2012-1352 of 11 December 2012, that the setting of a quality of service objective in J + 2 for the recommended letter should not result in a Degradation of its quality in J + 1. On this point, the Authority notes with satisfaction that the rate of distribution of the letters recommended in J + 1 did not decrease, but instead increased from 77.6 % in the first quarter of 2012 to 80.5 % in the first quarter of 2013.

(1) Average quality of service level reached in the last three quarters of 2012 and the first quarter of 2013.



Re-shipment service


The order fixed at La Poste is a 95 % repair target for the Malfunctions reported within 48 hours of the reorder service. The Authority notes that, in its specific conditions of sale relating to the re-shipment, " La Poste undertakes to remedy the malfunction within one working day from the request of the Customer ".
It therefore seems necessary to set an objective corresponding to the contractual commitment of La Poste concerning the time limit for Management of malfunctions, that is, an objective relating to the rate of resolution of malfunctions within 24 hours, not in 48 hours.
This notice will be sent to the Minister responsible for posts and published in the Journal Official of the French Republic.
Done at Paris, 2 July 2013.

  • Appendix



    A N N E X E




    SUBMISSION TEXT FOR NOTICE TO
    PROPOSALS FOR THE AUTHORITY (IN GRAS)

    Article 1
    The days of filing and distribution on working days, the quality of service indicators and objectives assigned to La Poste are defined in the table. Annex.
    The quality of service measures corresponding to these indicators and Objectives must comply with the following rules:
    1 ° The quality of service measures of the priority letter, the letter Verte and Community cross-border mail must be carried out in accordance with the European standard EN 13850.
    2 ° Measurement of the quality of service of the letter Recommended by the standard EN 14137.
    3 ° The measurement of the quality of service of the Colissimo desk must be performed according to a method which must be computerised, explained and auditable.

    Article 1
    Filing and Distribution Days In working days, the quality of service indicators and objectives assigned to La Poste are defined in the table in the Annex.
    The quality of service measures corresponding to these indicators and objectives must respect the The following rules:
    1 ° The quality of service measures of the priority letter, the letter Verte and Community cross-border mail must be carried out in accordance with the European standard EN 13850.
    2 ° Measurement of the quality of service of the letter Recommended by the standard EN 14137.
    3 ° The measurement of the quality of service of the Colissimo desk must be carried out according to a method which must be computerized, explained and auditable.


    Item 2
    The Position must measure the rate of loss and undue delay of the Letters recommended in accordance with the European standard EN 14137.

    Article 2
    The method of measuring the processing of claims must be In accordance with the principles advocated in the European standard EN 14012.
    The rate of response to complaints within 21 days of domestic mail is set at 95 % for 2013.
    The response rate to complaints within a period of 21 Days on the package is set at 95 % for 2013.

    Article 3

    Article 3
    The measurement of the rate of repair of reported malfunctions relating to the reshipping service shall be carried out according to a method which must be computerized, explained and Auditable.
    The rate of repair of reported malfunctions for the reshipping service is set at 95 % in 48 hours for 2013.

    Article 4
    The rate of recovery of the service as a result of Reported malfunctions for the reorder service must be Performed according to a method that must be computerized, explained and auditable.
    The rate of service recovery following reported malfunctions in the 24-hour reshipping service is set at 95 % for 2013.

    Article 4
    The Director General of Competitiveness, Industry and Services is responsible for the execution of this Order, which will be published in the Official Journal of the French Republic.

    Item 4



The President,

J.-L. Silicani


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