Eircode and Loc8 Code Report
Introduction
What is Eircode?
Eircode is a new post code system that is intended to be introduced this year under direction of Labour Minister for Communications, Energy and Natural Resources, Alex White (formerly Pat Rabbitte when he held the position of Minister). A unique 7-digit alpha-numeric code will be applied to every postal address in Ireland under this system. The first part of the code is called a ‘routing key’, consists of three characters and defines a principal post town span of delivery. The second part of the code, called a ‘unique identifier’, is different for every address and distinguishes one postal address from another. E.g. A65 F4E2. At present, Eircode has not been tested for use by any of the companies it has been designed for (An Post, freight/delivery companies and other businesses). Implementation of the Eircode system will also cost the State €27million. Businesses who avail of Eircode will have to pay data access and usage fees in order to access vital information under the scheme.
What is Loc8 Code?
Loc8 Code was developed by Gary Delaney within GPS Ireland which is a small Irish GPS Services and innovation company, based in the village of Crosshaven in Cork. These codes were developed in response to a demand from GPS Ireland’s clients, particularly utility companies, who needed to make more efficient use of GPS technology without the limitations of poor Irish addressing. The demand for Loc8 Codes grew in 2006 when detailed digital mapping first became available in Satnavs for Ireland. Since 2008, Loc8 has been updated, refined and used with smartphones, Garmin, satellite navigation systems and computers. It is a smart code with an integrated GPS algorithm that allows identification of an area within a 6-metre range regardless of the presence of a postal address. Loc8 codes have been offered as the country’s answer to a post code free of charge, but they were excluded from the tendering process in 2011 (the process of making an offer or proposal to implement a new postcode system) because there was a stipulation requiring them to have a €40 million turnover in order to participate. Loc8 codes are free for all to use and can be obtained using PC internet and smartphone apps.
Why do we need a postcode?
A postcode should be able to assist and improve the mail delivery service. Whilst An Post are currently 98% efficient with their service and next day delivery, smart coding systems can help in other areas. Location codes are very important for: freight companies, delivery companies, tourists and emergency services to be able to pinpoint exact locations where necessary.
Main body of report
Eircode vs Loc8 Code (and why the latter is the only way forward)
There are many reasons why Loc8 Code is a better option than Eircode for implementation as the country’s postcode service. For the purpose of this report, I will explain the main points under the following headings, in as concise a manner as possible, in order to convey how Eircode is not Ireland’s answer to a postcode or any other modern location system. The majority of the arguments supporting Loc8 codes have been cited in Gary Delaney’s in-depth report ‘Presentation on Eircode & a National Postcode produced on the 30th of June 2015.
The tendering process excluded Loc8. Participants in tender required a €40 million turnover which essentially excluded small businesses from taking part. Mr. Delaney explains that the original tender was found by European Commission to have breached government guidelines on public tenders by excluding small business. It was due to this that Loc8 code could not be a candidate for the new post code system despite the fact that it had been developed by GPS experts and had been used successfully for a number of years.
Loc8 Code offered to State for free! In the Irish Independent of Friday May 17th 2013, Loc8 Code offered its Digital Address Code to Minister Pat Rabbitte as a free gift to be used for the purpose of a National Address and postcode. Plans to continue with Eircode still went ahead and, to reiterate, it will cost the State €27million. Mr. Delaney explains with reference to the implementation of Eircode: “Eircode bears no resemblance to NPPB or consultants recommendations, it does not satisfy the terms laid down in the postcode procurement tender PQQ of Jan 2011 and rather than being designed since 2003, it was clearly designed in a collaboration between Capita & An Post (the winner and runner up in the postcode tender) in a few months ending May 2014 after the €27m contract had been awarded to Capita and its consortium bid members in December 2013”. It is clear that the most financially well-off businesses had direct input in the design of Eircode and did not deem it necessary to consult or collaborate with experts of GPS in order to modernise and perfect the new national postcode. Loc8 Code provides free codes to everyone whilst Eircode will charge customers data access and usage fees as well as annual fees to avail of its information.
Poor code design by non-experts. Gary Delaney explains that “the design was argued and justified without reference to other postcodes in use worldwide, a needs assessment, international postcode expertise or recognised expertise in navigation, coordinate, positioning or GPS technologies”.
Mistakes are easy to make! Unlike the logical UK postcode system, the 7-digit code that Eircode has designed will consist of randomly generated and assigned letters and numbers. This means that while two codes may appear similar (example one digit difference), it does not necessarily mean that the two areas are close by. In this way, it has no public usability because it is impossible to gauge location or spatial distances between locations reading the 7-digit Eircode alone. By looking at two Loc8 Codes side by side the user can visualise how close to each other they are, but the random structure of Eircode does not allow this and therefore makes it limited and complicated for the general population to use It is very easy to make mistakes and input the wrong details using Eircode while Loc8 Code has a ‘checker’ function to prevent these mistakes occurring.
Eircode has sole dependence on technology. Eircode has no ‘visual intelligence’ built in. It cannot be deciphered merely by looking at the code due to the random assignation of letters and numbers whereas Loc8 works on a longitude and latitude co-ordinate system. This means that Loc8 works on basic functionalities combined with technology to produce a code that makes sense with or without the use of GPS or internet.
Updated databases are vital. In a nutshell, Eircode cannot be used at any level without GPS or app technology because it is a random code with no integrated GPS data – making it useless without an up-to-date database to look it up. Databases will warrant constant updating in order to make the system effective so Eircode users will face ongoing expenses to download and install these updates. Loc8 does not require any updates or databases due to how technologically advanced the system is. To date, no GPS or SatNav manufacturer have indicated support for Eircode and have expressed that a database so large will not fit on many SatNav systems currently in use. As an experienced supporter of SatNav Technology, Gary Delaney acknowledges that the majority of SatNav users never update them and therefore if Eircode was ever delivered on SatNavs, it would quickly become less than useful once the on-board database becomes out of date and not updated. This is one of the reasons why Eircode does not have the support of major players in the Navigation industry like Garmin and TomTom who already support the Loc8 type of solution.
Will it even work? Eircode has never been tested with ordinary users and has never been made to work on navigation devices. There have been investigations and concerns from: The Data Protection Commissioner, EC Procurement Investigation Unit, Joint Oireachtas Transport & Communications Committee, and Comptroller and Auditor General. We know that Loc8 works, it is extremely user friendly, free and requires little maintenance and no updates. Loc8 is now also a standard pre-installed and FREE feature on all new Garmin SatNavs purchased and can also be used via a smartphone App called point8. The App works with Garmin, TomTom, Waze, Google and other well know navigation systems. It seems ludicrous that the government will invest €27 million into a project that has not been tried and tested amongst those who Eircode has been designed for.
They do not require Eircode. A postcode is designed to assist the mailing service but An Post will have very little use for Eircode. As is stands, An Post have a 98% efficiency rate and have explicated that they do not require the use of a postcode for sorting mail or to improve efficiency. An Post have insisted that the postal address continue to be in use due to the fact that Eircode would present additional manual sorting challenges rather than minimising them. Considering this, the modern postcode should reflect the needs of emergency services, tourism services, freight and delivery companies etc. rather than those of An Post. Loc8 is significantly different to Eircode, not just because it does not require a database to interpret, but also because it has visual logic which the average user can identify without the use of any technology. It can be used by a very diverse set of industries as opposed to Eircode which only has input from An Post requirements even though An Post itself has only identified occasional use for about 40% of the code.
An Post controlled the design of Eircode. Despite the fact that Eircode will not be of much benefit to An Post, it has been designed in such a way as to be of little use to society in general as it only serves where An Post deliver mail. Postal addresses are favoured over geographic addresses, thereby removing the vital dimension that, to use metaphors, makes Loc8 a 3D code but makes Eircode 2D. The postcode does not support small spatial areas and this – as will be covered in the next section – is being referred to as ‘dangerous’ by the emergency services.
Eircode is optional, therefore it will be infrequently used. This brings a host of negative issues including maintenance of databases and lack of postcode integrity. It must be mentioned that An Post will receive an outgoing revenue from Eircode, despite its lack of necessity, and predicted lack of use.
Not enough information. Gary Delaney notes that in an initial consultation document on Caller Location ID, published by COMREG, the telecom companies including Eircom and BT who provide Emergency Call and Answering Services (ECAS) “has very little information on Eircode, suggesting that they had not been consulted or briefed”, in spite of the fact that Eircode is to be used to assist the emergency services. These companies could not confirm that they would support the use of Eircode due to having little information and also because of its lack of mandatory use. Personally, when conducting research on Eircode, I found the information found on Eircode.ie is somewhat vague and contains references to the Eircode as ‘smart’ even though it does not have roots in GPS technology and is not a multimodal, multifaceted code.
Eircode is dangerous according to the emergency services. Emergency services have called Eircode ‘dangerous’ as it is easy to misinterpret the code which can cause errors in finding a location. As previously explained in this report, Eircode is not a logical coding system and it can get confusing. The Director of the National Ambulance Service has explicated that the Eircode system needs extensive testing before it can be even considered for use. It is pivotal that the emergency services use a coding system that works for them and for the past few years, Loc8 Code has been that system. John Kidd National Chairman of The Irish Fire and Emergency Services Association says that “The proposed new Irish national postcode, to be called Eircode, will not be suitable for Irish Emergency Services and it will cost lives". He continued to say that “It is regrettable that IFESA or indeed any of the emergency service unions, were not consulted or allowed test any of the proposals for a new postcode. Budgets are already under strain in Ireland's Fire and Emergency Services, so anything proposed must be deliver real benefits in delivering services and have an adequate budget to cover its implementation”.
No postal address – no access! Eircode only contains postal address data, therefore it is very difficult to pinpoint a location in a bigger area. Gary Delaney uses the UCD campus as an example to highlight how emergency services using Eircode will be directed only to areas of the university that receive mail. In the event of an accident or necessity for the emergency services, Loc8 codes can identify, within 6 metres, the exact location of an individual. If a tourist in a rural area requires the emergency services, this can become even more difficult as it will be almost impossible to pinpoint location. It is also worth mentioning that Eircodes will be ‘secret’ so one will not know the Eircode of a house without asking the homeowner. Again, these are the reasons why emergency services deem Eircode dangerous. It is clear now how Eircode cannot provide 100% access like Loc8 can because it simply does not have the technology required to enable it to navigate through these issues. Eircode’s restrictive system was rejected by Freight Transport Association of Ireland as the codes were deemed unfit for purpose.
Gardai already use Garmin SatNav technology in their vehicles. This software was installed by Gary Delaney for use alongside inherent Loc8 code feature for the location of elderly and vulnerable people. This system is effective and underwent extensive testing in the Garda training college, Templemore before it was implemented for use.
Eircode will not help the tourism sector. It is not possible to use Eircode in conjunction with basic navigation tools such as maps. If Ireland does not have a flexible, multifunctional postcode, there will be less inclination for tourists to leave urban areas in favour of rural areas because of the confusing Eircode system.
Cost of Eircode Vs Free Loc8 Code. It is unreasonable to expect tourists to download and pay for SatNav equipment that only details dwellings with post boxes. As Gary Delaney points out, “battlefields, ruins, parks, lay-bys, picnic areas, fishing spots, the Ploughing Championship etc. will all lose out here because only locations that An Post deliver to will get an Eircode”. Loc8 Codes, as explained multiple times in this report, are free and accurate. Eircode will be ultimately rejected by the tourism sector as there is absolutely no requirement for its use.
Health and safety. There will be hundreds, if not thousands of locations across Ireland that will not be allocated a postcode. It cannot be realistically expected that citizens and visitors who frequent these places are at a reduced health and safety status when doing so because they are out of the emergency services’ postcode ‘radar’. Ultimately, the health and safety of these people has not been considered in the design of Eircode.
Recommendations & Conclusion
I have three recommendations that I would like to make with regards to Eircode, having considered the information researched:
Eircode simply cannot serve as a definitive answer to Ireland’s call for a national postcode system. There is evidence here to support that Eircode will not work whereas Loc8 Code has a proven track record. Not only will millions of euro be saved by cancelling this project, Ireland will have the opportunity to utilise a technologically advanced, GPS integrated smart code that is useful for the emergency services, delivery and freight companies, the tourist and the Irish citizen. There is no logic behind the introduction of the Eircode system and I hope that having read this report, you will agree that Eircode does not fulfil Ireland’s postcode requirement and development of this project should not be permitted to proceed further.
By Cllr. Alan Tobin.
Annexe 1 Cllr. Alan Tobin’s motion and press release
Eircode original motion
9.7 Submitted by Councillor Alan Tobin (deferred from April meeting)
“This Council calls on Minister Alex White T.D. and the Department of Communications Energy and Natural Resources to scrap the controversial and confusing Eircode design, and asks that a free and open tender, that does not exclude small business, be held for the design of a modern, smart, structured postcode with integrated geolocation (GPS) data”.
Press Release Councillor Alan Tobin – Motion for the Scrapping of Eircode
Councillor Alan Tobin today welcomed the passing of his motion calling for the proposed National Postcode, Eircode, to be scrapped and he thanked his fellow Meath County Councillors for their foresight and decisiveness in identifying that Eircode is far from being the best option as a postcode for a modern and growing Irish economy. Councillor Tobin expressed his concerns that the Department of Communications had shown little foresight in the selection of Eircode and had appeared to base their decision-making on historic requirements instead of those suitable for current and future demands. Of particular concern he said was the apparent absence of a comprehensive assessment of other coding systems during the postcode tender process and it had been well noted in national media that the Loc8 Code alternative, which is backed by Enterprise Ireland, an arm of the State, was apparently blocked from participation.
Councillor Tobin wanted to emphasise the need for an expansive modern postcode that satisfied the needs of Irish businesses which are going to pay most to implement it. He called for a fresh tender process which starts off by identifying exactly the needs to be satisfied by a modern postcode and these must include those of property and asset management by Local Government, tourism and sporting needs and the very specific needs of the emergency services who must trial any proposal before implementation. Councillor Tobin also highlighted that before any postcode is implemented it must be subjected to piloting in a small geographic area as has been done in every other country and he suggested Navan for that purpose. He also stated that full implementation must be done as an integrated process which actively includes Local Authorities, the HSE, the NRA, the Road Safety Authority, the Health & Safety Authority, the National Ambulances Service, the Irish Fire &Emergency Services Association, Fáilte Ireland, the Freight Transport Association of Ireland, the business community and others as appropriate, many of whom, especially Local Authorities, will need dedicated budgets to ensure a full and proper roll-out.
He concluded that none of this has been planned for Eircode and he encouraged other Local Authorities to quickly follow suit with similar motions to ensure that Eircode is scrapped before approximately €27m is wasted from the economy and a once-in-a -generation opportunity is missed.
Web Sources
[1] Gary Delaney is a former Irish Naval officer and navigator. He has an MSc degree in Navigation technology for air, land and sea applications and is also an experienced land surveyor with clients across Ireland, the Middle East & Africa. His client base has been built up over 16 years working for himself and giving local employment in the Cork area. Gary is also a specialist in producing location forensic evidence to support prosecutions in the Irish court system and he routinely works for the State and its agencies and has contributed evidence and expert witness statements which have led to very significant prosecutions in Ireland and the UK. He has also trained thousands of field staff who use GPS as part of their employment and has amassed over 35 years’ experience in all matters to do with navigation, electronic positioning, mapping and GPS and it is this unique experience that contributed to the very particular design features of Loc8 Codes. Gary Delaney is an elected Fellow of the Royal Institute of Navigation and the Irish Institution of Surveyors.
[2] Delaney, Gary E. (2015) ‘Presentation on Eircode & a National Postcode’ To Oireachtas Joint Committee on Transport & Communications’
[3] John Kidd National Chairman IFESA: http://www.ifesa.ie/index.php?option=com_content&view=article&id=281:proposed-eircode-postcode-system-will-not-be-fit-for-purpose-and-can-hinder-emergency-services-&catid=81:press-and-media&Itemid=277
[4] Annexe 1