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exchanges to transfer mail between
each other as an added flexibility for
customers. But there is a proviso
which would, if adopted, give EC
Member States the right to refuse
DXs the freedom to interlink if they
are 'convinced' that the presence of
DXs would 'harm' their ability to
provide a universal service.
The AEDE is seriously concerned
that this broadly worded proviso
may be open to a range of entirely
subjective interpretations. How is
one to gauge the extent to which
DXs could 'harm' the ability of
PTTs to provide a universal service?
A PTT might feel DXs per se are
harmful because they deprive PTTs
of revenue no matter how small the
proportion. One thing is for sure. If
DXs cannot interlink, members will
not use them and DXs will close.
This would be a great loss since the
AEDE believes DXs are relatively
harmless to PTTs and even
beneficial. With their minuscule
market, the DXs scarcely pose a
threat. Moreover, as DXs are limited
in the type of subscribers they can
serve, their potential for growth in
those markets is strictly limited. In
addition, DXs simply
cannot
compete
in the PTTs key market
sectors such as mail order, direct
mail advertising and mailings of
magazines and newspapers.
Understandably, PTTs fear certain
private operators will enter the
market, cream off the profit-making
routes and leave the loss-makers for
the PTTs, thus threatening the
viability of the universal service. The
AEDE is keen to point out that DXs
serve an extremely heterogenous type
of business subscriber from the large
banks and financial institutions in
London and Brussels to the sole
legal practitioner in Galway. The
DXs are committed to operating a
full overnight service to
all members
on all routes regardless of
profitability.
Interestingly, the AEDE believes that
the DXs can actually assist in the
running of the universal mail service.
With their 99.5% rate of delivery
overnight for acutely time-sensitive
mail such as legal documents, DXs
actually remove the onus from the
PTTs, who frequently find providing
such services unprofitable and
fraught with hassle.
But perhaps the most compelling
argument for allowing the DXs to
continue is the fact that for the last
15 years in Ireland and for the last
17 years in the UK, the DXs and
PTTs have operated side by side
without any problem whatsoever. It
would be tragic - and costly for
DXs and their members - if the
DXs were not allowed to function in
the future as they have so
successfully in the past.
As debate over the Green Paper
continues, the AEDE is taking every
opportunity to present its case and
sincerely hopes that the Commission
will remove the proviso and guarantee
DXs the unconditional right to
operate and interlink with each other
nationally and internationally in any
forthcoming legislation.
DXs are, of course, accustomed to
99.5% success overnight. This
particular battle will take rather
more than a night, but the AEDE
looks forward to achieving a similar
success rate!
•
* Paul Puxon is chairman of the
Association of European Document
Exchanges.
The Younger Members Committee
in association with Dublin Solicitors Bar
Association
A NN U AL Q U I Z N I GHT
31 October, 1992
Royal Marine Hotel, Dunlaoghaire, Co. Dublin.
SPONSORED BY THE IRISH PERMANENT
BUILDING
SOCIETY
all proceeds to
SOLICITORS BENEVOLENT
FUND
Fee £25.00 per team (five people per team)
Entry forms may be collected from the Law Society's premises at
Solicitors
Buildings, Four Courts, or by contacting
Joan Doran,
Secretary YMC, Blackhall
Place, Dublin 7.
Numbers are limited so please book early to avoid
disappointment.
74