Select Committee on Transport, Local Government and the Regions Appendices to the Minutes of Evidence

Memorandum by Association for Geographic Information (OS 13)


  1.  The Association for Geographic Information (AGI) is a not-for-profit company limited by guarantee founded in 1988 (after a House of Lords Committee of Inquiry into geographic information chaired by Lord Chorley) to represent the interests of those concerned with geographic information as users, producers, consultants or academics. The Association has about 1,500 members in individual, corporate and sponsor member categories. It is the largest representative of the Geographic Information (GI) community in the UK and is a leading GI organisation in Europe. Ordnance Survey is a sponsor member of the Association.

  2.  The mission of the AGI is to "maximise the use of geographic information for the benefit of the citizen, good governance and commerce".

  3.  The AGI represents organisations and individuals that use, supply, or have an interest in geographic information in many forms, including electronic and paper, for many purposes, rather than the consumers of Ordnance Survey's paper map output (either that produced by Ordnance Survey themselves, by third party publishers or by Ordnance Survey's SuperPlan agents). For that reason I will limit myself to comments on digital data pricing, the costs of updating and maintaining databases and the effects of new technology on costs. I will also make some observations on the provision of maps for electioneering.


  4.  The issue of the price of Ordnance Survey data has been raised with the AGI on many occasions and we have held a number of meetings on this issue. The AGI has close working relationships with the Royal Institution of Chartered Surveyors (RICS) who have also expressed considerable concern over Ordnance Survey pricing.

  5.  We recognise the fact that in many of the markets to which Ordnance Survey supplies data, Ordnance Survey is either the sole supplier and enjoys a monopoly position, or is the dominant supplier and enjoys a near monopoly.

  6.  Sir John Bourn, the head of the National Audit Office, qualified his opinion of the 1999-2000 accounts of the Ordnance Survey because of a disagreement about the value of Ordnance Survey's digital database. Ordnance Survey is obliged, under its present Trading Fund status to recover its full costs and make a return to the Treasury, which represents a return on the value of the assets employed. Thus the value placed on Ordnance Survey's digital database can have a significance effect on prices, however there is no agreed mechanism for valuing such a unique asset. Valuing this asset, which I feel constitutes part of the nation's information infrastructure, and requiring Ordnance Survey to make a return on that value, effectively places a tax on geographic information rather than reflecting any realistic market conditions.

  7.  The combination of its monopoly position, and its financial responsibilities to the Treasury as a Trading Fund, make pricing a critical issue for Ordnance Survey. Ordnance Survey cannot rely on a competitive marketplace to help them set prices, because of their dominant position in the market, yet they are obliged to recover their full costs and make a return on capital employed. This combination of circumstances makes Ordnance Survey's relationship with its major customers in local government, the utilities, central government and other agencies such as Her Majesty's Land Registry (HMLR) at times difficult. As a result Ordnance Survey became embroiled in many counter-productive debates with its principal customers over "fair" pricing. The effect of these debates is often to damage Ordnance Survey's relationship with its principal customers; to reduce the use of Ordnance Survey data in parts of government that cannot afford to pay the prices charged to other major customers; and to waste a great deal of time and energy among public servants pretending to be operating market based discipline.

  8.  Once prices have been set for the major, usually captive, customers, prices for other users must take into account what is being paid by the major customers. These prices are frequently far too high to allow the development of any significant secondary market for Ordnance Survey data.

  9.  Even once these quasi-commercial agreements are in place there are a number of activities that Ordnance Survey undertakes "in the national interest" for which there is no direct commercial justification. Such activities include the revision and maintenance of rural mapping for which there is little current demand, but which may be needed in case of an emergency. The availability of up-to-date rural mapping proved vital following the Lockerbie air crash, when emergency services needed to search a very large part of the rural borders and, more recently, to assist in a swift response to the foot and mouth crisis. Such non-commercial activity is part-funded by money provided under NIMSA (the National Interest Mapping Service Agreement) through DTLR.

  10.  Ordnance Survey's room for manoeuvre may be limited by the proposed HMSO regulation of the activities of Trading Funds in disseminating government information. In the recent consultation document circulated for comment by HMSO it is proposed that HMSO will take on the role of regulator both for bodies that disseminate government information at low or no cost (charges being levied only to cover the cost of that dissemination) and for trading funds, that are required to cover their costs in full. A proposal in that discussion document suggests that there should be full transparency of trading fund pricing policies. This may make it necessary to remove price advantages that are enjoyed by, for example, the charitable and educational sectors. Such transparency might be difficult for Ordnance Survey to achieve in its current commercial contracts. The removal of the right to provide discounted data to not-for-profit bodies would also appear to be counter-productive, if one wishes to maximise the use of national resources.

  11.  It is clear, therefore, that Ordnance Survey suffers from a number of fundamental contradictions. On the one hand the Treasury wishes them to behave, and provide a return on capital invested, as would be required by the shareholders of any private business. On the other hand Ordnance Survey has non-commercial obligations which are not fully met by NIMSA money; has a sometimes uneasy relationship with its main customers because of its monopoly or quasi-monopoly position; is now likely to be subject to external regulation by a body, HMSO, that has primary responsibility for the not-for-profit dissemination of government information and operates in an environment where there are many calls for it to distribute its main product, "data", below "cost" (as costs are very hard to ascertain on a product by product basis). At the same time Ordnance Survey finds itself in competition with many private sector companies that are interested in "cherry-picking" the most lucrative parts of its market, but are not prepared to provide a comprehensive national mapping and geo-data service for the whole of the country up to the standards that Ordnance Survey currently supplies.

  12.  Ordnance Survey had to compete in this new environment with a complement of staff whose numbers and skills reflected its origins as a national mapping agency and were less well suited to becoming the custodians and maintainers of a national geo-data business (geo-data being the underlying data from which maps are constructed rather than the maps themselves). The high cost of redundancy and early retirement in the public sector made it difficult for Ordnance Survey to re-structure itself into a new role. However Ordnance Survey have now rapidly accelerated the extent to which new technology can be employed to reduce Ordnance Survey's costs.

  13.  Despite the many disadvantages of its present position the directors of Ordnance Survey may well prefer to remain in the commercially more predictable financial regime of cost recovery, than to have to submit themselves again to the annual struggle for Treasury funds which would have a less certain outcome and which may curtail activities at times when the need to invest in geo-data may be highest.

  14.  By contrast there are Ordnance Survey's customers, users and potential-users who feel that the agency's products would be used much more widely, and would benefit the nation more, if they were available at the cost of dissemination and Ordnance Survey's base costs were met directly out of a block grant along NIMSA lines. For example, the national statistical service is working in this way while the national mapping service is expected to be commercially viable. The two organisations are expected, of course, to provide quite different services and different funding models may be appropriate.


  15.  There is much anecdotal evidence that Ordnance Survey is one of the best large scale mapping agencies in the world. It is harder, however, to find objective evidence for this assertion.

  16.  The reason for this is the fact that there are few directly comparable mapping organisations. However it is clear, that the content, currency and detail of Ordnance Survey mapping are widely admired.

  17.  Ordnance Survey is seen as a leading mapping organisation by its peers and runs very effective, and well attended, international conferences for mapping agencies from around the world. It has been active in collaborative ventures between the European mapping agencies. Former Ordnance Survey staff have leading positions in the national mapping agencies of Ireland and Northern Ireland. The US national mapping agency, USGS, suffers from the vagaries of uncertain government funding, to provide often out-of-date mapping at much smaller scales, but is only able to charge dissemination costs. They have sent staff to Ordnance Survey to learn the secrets of their "success".

  18.  It is unusual for large scale mapping activity to be separate from land registration. In many other countries the land registration function of HMLR is combined with the production of detailed maps, which in Great Britain are produced by Ordnance Survey. (However the option to combine the functions of Ordnance Survey and HMLR was rejected in HMLR's recently published Quinquennial Review.) This, in particular, makes international comparison difficult as well as creating the anomaly that land ownership is not recorded on Ordnance Survey's large-scale maps. It also makes this widely admired set of maps and underlying geo-data much less useful than it might otherwise be and separates the cost of large scale mapping from the most obvious source of revenue (land registration) that might have supported it. In Scotland closer collaborative arrangements exist between Registers of Scotland and Ordnance Survey to capture interests in property.


  19.  It can be argued that Ordnance Survey, as the national mapping and geo-data agency, should withdraw from activities that can be carried out by other companies or organisations or from the provision of products that can be supplied by a competitive private market. However, it is not easy to break down Ordnance Survey's activities in this way. Ordnance Survey has four main areas of work: surveying, the maintenance of the national geo-data base, digital data sales and the publication of paper maps.

  20.  Of these four activities, only the production of paper maps could easily be separated from the others. If Ordnance Survey retains a national remit to provide consistent and up-to-date map and data coverage for the whole country it must retain an ability to survey; it must maintain a single consistent database of geo-data (Ordnance Survey does not yet have such a database but the current Digital National Framework programme, and the associated product MasterMap is moving in that direction) and it must be able to stock, and rapidly print to order, map sheets for any part of the country.

  21.  It can be argued that the surveying and printing operations could be contracted out without loss of coverage or ability to respond promptly to national circumstances. However as mentioned in 12 above such re-structuring of the business may be too expensive for Ordnance Survey.

  22.  However there is a clear core activity that creates a natural monopoly that appears to be appropriate for Ordnance Survey. That is the maintenance of the geo-data that should be collected, stored and maintained only once and then used for a very wide range of purposes. This geo-data framework includes the geodetic framework (the scientifically measured and maintained set of reference points from which the location and altitude of any other point in Great Britain can be established; a digital elevation model a computerised model of the height of the land) and a database of topographic features—visible and surveyable features that make up the surface of the land. This geo-data framework should be collected once and only once, should be definitive, and should be re-used for many purposes. Ordnance Survey has a clear plan for creating supporting and marketing such a framework. Beyond that there are some more controversial areas.

  23.  There is much geographical framework data that cannot be seen in an aerial photograph or easily surveyed. Such data includes definitive information about addresses, currently maintained for postal purposes by Royal Mail (the Postcode Address File is maintained on behalf of the Postal Regulator) and being compiled for the purposes of recording land and property by local government (the National Land and Property Gazetteer, NLPG). It also includes data about land ownership, which is currently held by HMLR/RoS and is being compiled into a national index map by them. Ordnance Survey's role in holding, disseminating and reselling address and property data is less clear.

  24.  Another type of geo-data that is not directly visible, and surveyable, is data about electoral, administrative and statistical boundaries. Ordnance Survey is currently responsible for the maintenance of the definitive map of electoral boundaries as defined by the Electoral Commission. However this data is then disseminated on a commercial basis as the product BoundaryLine, and by its inclusion on other maps. The cost of boundary data is a significant impediment to its wide use. It could be argued that the maintenance of boundary data is not a core topographic mapping activity for Ordnance Survey and that both its collection and dissemination should become activities fully funded by NIMSA.


  25.  It would now be technically possible to provide on a ward by ward basis (or for any other geographical unit) street maps with accurate electoral boundaries and the location of every property linked to a list of electors, from the electoral register, living at that property. Such maps could be provided on paper or as a simple application running on lap top, tablet or personal digital assistant devices.

  26.  Such resources are currently assembled by some political party activists who have access to printed electoral registers and street maps. However this is a time consuming and cumbersome operation which may involve some breach of copyright if street maps are reproduced without permission.

  27.  The automation of the whole process will become feasible once local government completes the creation of the NLPG and the uniform rolling Electoral Register is in place. Ordnance Survey needs to improve its current BoundaryLine product (and the maps it obtains from the Boundary Commissions and in future the Electoral Commission) to ensure no ambiguity at the level of individual buildings.

  28.  However two major impediments to such a development exist. The first is the range of intellectual property rights that would exist in such a product. The NLPG and Electoral Roll will, under current plans, be owned collectively by local authorities. The street map data will be owned by Ordnance Survey and the electoral boundary data will be owned by the Electoral Commission (although exploitation rights may be ceded to Ordnance Survey). Each of these bodies would wish to be financially recompensed for the use of the data and collectively the resulting product may be too expensive for local political parties to use. If the respective bodies were not recompensed they would need alternative sources of income to produce such a product.

  29.  The second impediment is the anomalous position of the electoral register with respect to the Data Protection Act. As a public register the electoral register is exempt from the act and provisions, originally intended to make the register available at reasonable cost to political parties, have been exploited by the financial services industry and others, such as police forces, which require a source of personal identity information to re-use the register for other identity purposes.

  30.  This situation was meant to be regularised by the Representation of the People Act 2000, which allows for the production of a single national rolling electoral register, and allows an edited version of that register, from which individual electors may opt out, to be distributed for gain. The Home Office and IDeA, representing local government, expected the publication of the edited register to become an opportunity to raise funds which would more than cover the cost of electoral registration. However a recent High Court decision in Wakefield has put the legality of such dissemination in question as it is seen to breach the Data Protection principles (if not the Data Protection Act itself) and the Human Rights Act. At present the government has decided not to appeal that decision and that leaves the Representation of the People Act in an anomalous position.

  31.  Whatever the outcome for the process of electioneering, a wider issue of spatial privacy is raised. Now that geo-data down to the level of the individual building, and addressed properties within that building, is becoming widely available and is traded, it is inevitable that that data will be matched to addressed data about individuals such as the electoral register. The consequence of this is that it will become technically feasible, and trivial, to point at a building on a map and get a list of its occupants or to list the names and addresses of individuals and organisations and have those displayed on an electronic map. Parliament must decide on the spatial privacy implications of these developments and act accordingly so that all users of personal information and geographic information systems know where they stand.


  32.  Ordnance Survey is a widely admired and effective organisation. However, its anomalous position between the public and the private sectors, and the balance between public service aspirations and commercial survival make it a difficult organisation to run.

  33.  This anomalous position often places Ordnance Survey in conflict with its clients, potential clients, commercial partners and competitors.

  34.  These circumstances create a serious conflict of interests for the Director-General and Chief Executive of Ordnance Survey, who is the principal adviser on geographical matters to the Government and, at the same time, is the largest commercial supplier of geographical information to Government.

  35.  It is hoped that the Quinquennial Review of Ordnance Survey, which will be placed before Parliament before this Select Committee considers this evidence, will resolve some of these issues.

  36.  It may be desirable if the Government were to consider the appointment of an independent advisory Geographic Commission to resolve issues about geographic information in the same way as the Statistics Commission advises on the statistical service. Such a Commission could also advise on issues such as the spatial privacy considerations of other legislation.

  37.  Discussions about the pricing and availability of geographic information are not simple issues of determining fair market prices, but reflect deeper issues about the production and maintenance of a national geographic data infrastructure. They need to be seen in that light.

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