What’s wrong with Eircode? Lots. Much of this document arises from discussions and emails with Loc8. I am not affiliated with them in any way but they have always seemed to me to be at least as good if not manifestly better than Eircode. And FREE!!! I understand that the material here plus more was provided to the Minister in December but as of now no response has been recieved. Perhaps the Minister might read this? Poor Design No Meaningful Testing Database driven Major Data Protection Security risk? Only for dwellings No Logic – Easily Confused· Requires constant updating / Delayed Updates Difficult to integrated with software / devices Limited use for emergency services & may cost lives No use for utility companies or local authority infrastructure No use for transport company infrastructure Limited use for tourism No use for temporary events What has Loc8 Code got to offer over Eircode? Designed to be simple to use and communicate

Lightweight algorithm driven

Faster and more secure

Self‐Service option saves money

For everywhere on island of Ireland.

Install once NEVER requires updating

Ideal for all emergency services/public safety on the island of Ireland

Ideal for utility company / local authority infrastructure

Ideal for tourism

Ideal for temporary events

Ideal for wildlife surveying A shoal of Red Herrings Random versus Sequential versus Nested?

Not accurate enough?

Giving a postcode to an apartment?

Checksum doesn’t work?

What if you can’t self service?

What’s wrong with Eircode? Eircode – Poor Design (No design?) No competition was ever held for the design of Eircode and as such the code has the appearance of being “designed by committee”. Eircode is not the code recommended by the Post Code board, Consultant reports or specified in Tender documents. An inexpensive design competition would have offered the DCENR an overview of the innovative code technologies already in existence. This would have allowed a more informed decision on the postcode to be made saving the department money when it came to adoption, delivery and maintenance. Essentially Eircode is dumb with no built in intelligent features as befitting a 21st century design. Eircode – No Meaningful Testing To my knowledge no large scale field trials have been carried out on Eircodes and there has been no independent oversight. Eircode – Database Driven The main problem with a database driven postcode is that to use the postcode you need access to the database. For persons out and about this means that they must either have a copy of the database on a handheld computer or smartphone or they must have access to the database using an over the air (OTA) connection. It has been reported that the full Eircode database will be in the region of 2GB in size and just to put that in perspective the full Navteq (maps& postcodes) for ALL of Europe are also approximately 2GB. If the database does indeed end up at 2GB then the vast majority of satnav devices already in use will not be able to physically fit the Eircode database and detailed maps of Ireland. This is if GPS manufacturers support the inclusion of Eircode on their devices which is very doubtful for the less abundant in car satnavs. It has been suggested that not all of the database is required and that users need only to load maps for select regions but this ignores reality. Business uses require the full country (& NI) to be on their satnav at all times as many work all over the country, ditto for tourists. Manufacturers of mapping do not split below Ireland and UK level because of market size – Ireland has low value on its own The alternative to having on‐board database access is to have over the air (OTA) access to the database but this requires good 3G/4G connectivity and as am sure you are aware that mobile provider data coverage is poor to non‐existent in the very areas that you will need to rely most on your postcode to navigate. OTA is not available at all when you run out of credit and no emergency data use provided for by network providers. So on‐devices databases go out of date right after an update and OTA databases suffer from coverage problems and a database in itself is expensive to maintain. Eircode – Major Data Protection Security Risk? Using an on‐board database will lead to the situation whereby there will be many thousands of devices in existence with a FULL copy of the entire Eircode database. This database will have to allow access to the GPS device so postcodes can be looked up. There will be no impediment to copying this database from the GPS device onto a server and either cracking its security or just reverse engineering the database by reading out every possible Eircode permutation. This will be a relatively simple and quick task because there are only 2 million approx. addresses, less if individual apartments are removed. Having a postcode reliant on a central database also introduces a single point of failure and a single target for “denial of service” attacks etc. Obviously redundancy and replication will be used but this increases cost.

Another type of threat a database faces is a silent data poisoning attack i.e. data could be modified so that postcodes could be switched, re‐directed or otherwise made unusable. Also remember that if a database is available “Over The Air” then copies of the database will be a target for attack 24/7. Some of the biggest companies and organisations in the world have been hacked, ICan Eircode security can be guaranteed at all and this is before we even consider internal personnel security breaches. Why proceed with a system that is open to attack why not design out the security threat. Eircode – Only for Dwellings (With a letterbox!) This is probably one of the most limiting aspects to the Eircode format and has implications for emergency services response times for non‐dwelling incidents, it also makes Eircode useless for any structure or location without a post‐box. I will cover the limitations of this further on. Eircode – No Logic Easily Confused The problem with a random code is that it cannot be memorised by persons who do not use the code on a regular basis. One example would be a manual parcel sorting depot where humans read the address on a parcel and then place it in a particular bay or cage for onward delivery, random codes will only add to address confusion unless every worker has a handheld computer with access to the database, this would be too slow and too expensive to use day to day. Emergency services especially will suffer from confusion with a code with no built in safeguards and that needs database access at all times. Having to always look up a code before knowing even the rough destination will introduce delays and may cost lives. Eircode – Requires constant updating / Delayed Updates Updating a satnav is a slow process, depending on the update coverage required the mapping download alone could be between 300MB and 2,000MB even before the Eircode database is added. On fast broadband this will not be much of an issue but lots of people and businesses throughout the country still have very slow broadband. The result of this will be that people will be very reluctant to update their GPS devices and the consequence of not updating will be that they end up using an out of data Eircode databases that will no longer be accurate. If there is a user cost to update the database then this will reduce the upgrade potential even more and therefore the uptake by the general public. For emergency services and utility companies it will mean that vehicles may have to be taken off the road on a regular basis to perform updates to the database or that an expensive maintenance and update regime will need to be created to keep tally of portable devise and their update state. In short this is just not practically feasible. This also asks the question of how quickly you can get an Eircode. If you are building a house in the countryside how do you get deliveries without an Eircode and how completed will a house have to be before you can apply for an Eircode. Once you do apply for an Eircode how long before you get one and how long before it appears on the master database. If people don’t update their own copy of the database on their satnav or car they will never be able to use Eircode to find you. Eircode – Difficult to integrate with software / devise This comes back to the Eircode design being reliant on a database and any device or application needing access to a code needs access to the full database. Many older satnav devices will not have enough ROM to store the database file and access by newer devices over 3G/4G will be reliant on sufficient OTA broadband coverage. Of course satnavs do not have 3G/4G connectivity so there is a good chance the vast majority of satnav units out in the wild will never receive Eircode compatibility again affecting uptake by small business, the general public and tourists. The emergency services cannot rely on OTA availability to carry out their respective missions and an on‐board database is much more expensive and resource demanding than a simple algorithm.

Eircode – Limited use for emergency services and may cost lives. There are 3 ways that Eircodes could cost lives either through omission or confusion. 1. Firstly because Eircodes are only for dwellings it means they are absolutely no use for Road Traffic Accidents which are a large percentage of call outs for the emergency services. Organisations such as the National Ambulance Service have pointed out to me that “At no stage has the NAS or myself (Martin Dunne) outlined that this system is the answer to all our needs in relation to rapid access to patients etc., however it is a mechanism that will assist and fill the void that exists at the moment.” Why not give the NAS and other emergency services what they want, rapid access to patients? Why have a system that only covers 50% of incidents? Add farm accidents, forestry accidents, inland waterway and mountaineering accidents to the long list where Eircodes will be of no use. There is merit in the suggestions by IFESA that Eircodes will cost lives and these warnings must be heeded. 2. Secondly because of the random nature of Eircodes the possibility exists in some locations whereby a single digit error may send emergency services many 10s of km in the wrong direction. For example Donegal has the 3rd highest km of roads per county and will be covered by three Eircode districts and each one of these districts will have >2,000km of roads meaning a single digit error for example between A65‐ABCC and A65‐ABCD could be 100km. Of course there are methods of verifying the address to narrow things down but why not have a code with built in error checking rather than relying on interrogating someone who called 999/112 who may not speak English, may be drunk or under the influence of drugs, or badly

injured etc. Why not remove the potential for confusion in the first place? 3. Thirdly, bizarrely Eircodes are a secret and so you will not know your neighbours or a strangers Eircode without being specifically told it. If you happen to be a tourist on a drive in a rural area and you come across a house on fire you may have no means to direct the emergency services to the fire location. No possibility exists with Eircode to generate a code on the spot unlike algorithm based codes which all offer this feature. In all 3 cases above Eircodes could cost lives either directly because of errors or indirectly because a better system would improve response times leading to more lives being saved. How can any minister stand over a system that will cost lives? Eircode – No use for utility companies or local authority infrastructure. Because Eircodes are only for dwellings that will receive mail from An Post. They will be of no use for utility companies or local authorities looking to manage dispersed infrastructure. Currently a multitude of different utilities, semi states and councils use their own systems for marking public lighting, telegraph poles and bridges etc. with Interpretation not available to the Public. Having one simple off the shelf system would save resources within each organisation, creating efficiency’s and saving money. Furthermore Neil Mc Donald of the FTAI summed it up when he listed locations that will never have an Eircode….workshops, farm buildings, windmills, piers, jetties, fields, large fixed assets, lay‐‐bys, points of interest, lanes, archaeological sites, roads, natural features, intersections, accident black‐‐spots, pylons, parks, motorways, junctions, antennae, wells, graveyards, pumping stations, viewing points, manholes/utility access points, car‐‐parks, beaches, level‐crossings, transformers, bridges, forests, bogs, lakes, playing pitches, cycle‐‐ tracks, picnic areas, public toilets, walkways such as the Wild Atlantic Way.

Eircode – No use for transport company infrastructure Companies like Irish Rail have a very large infrastructure to manage and do this using proprietary databases for bridges & level crossings etc. But the situation could exist whereby a truck could knock down a bridge and demolish or otherwise hide the sign showing the proprietary database name for that particular bridge. A one system fits all would allow persons on site to generate a code for that site and possibly prevent a derailment. Again because only dwellings with post boxes will get an Eircode they will be no use for bus stops or minor train stations. We should be making ease of access to public transport a priority and Eircode will not help with this. Eircode – Limited use for Tourism

Obviously for tourists with a compatible smartphone app or satnav Eircode will be of help trying to find a hotel or restaurant. However when it comes to heritage sites Eircodes will again be no use. No use for tourists visiting dolmens, stone circles, ruined castles etc. An increasing number of tourists are starting to visit Ireland for walking and cycling routes and again Eircode are an utter fail when it comes to highlighting points of interest along these routes. If we want to grow our tourism numbers why are we not acting in a coherent manner and doing everything possible to direct and help tourists once they are here? Will waypoints on the Wild Atlantic Way be on Eircode? NO! A Duty of Care responsibility also arises if the State encourages tourists to visit remote locations such as the Wild Atlantic Way. The state must provide reasonable means for public safety, signage, and fixed rescue points etc. unfortunately Eircode provide no mechanism to assist in these scenarios. Eircode – No use for temporary events Eircode has no provision for temporary postcodes for temporary dwellings. What has Loc8 Code got to offer over Eircode? Loc8 Code – Designed to be simple to use and communicate Loc8 Codes were designed by Mr. Gary Delaney a formal naval service ships officer with a Master’s Degree in Navigation from the University of Nottingham. Mr. Delaney’s career involved day to day navigation of Ireland’s 7 million square km of nautical territory. Since leaving the Defence Forces Mr. Delaney has further honed his navigational skills carrying out precise GPS surveys for industry. He also works as a Navigation Consultant and expert witness for the State. In short Mr. Delaney understands a lot about navigation & mapping and used his extensive knowledge & experience to design and introduce a consumer friendly navigation and waypoint code known as Loc8 Code. Loc8 Codes are based upon logical nested co‐ordinates ultimately allowing you to define a large area, a small area or an exact point with +/‐ 6 metre accuracy. It is important to point out that Loc8 Codes are not a sequential code, they are a logically assigned nested code. This is important as it allows codes to be assigned to new buildings that are built between two existing buildings. For full accuracy Loc8 Codes use 8 digits with 2 dashes separating the groups of digits. So for example my business in Rathcoole uses NT4‐82‐V23 to identify its location. That format of XXX‐XX‐XXX is important as it allows users and software to positively identify a Loc8 Code. Other codes do not use a structure like this and are likely to be confused with words or even phone numbers.

From the full 8 digit code reduced accuracy version of the code can be used by omitting some of the constituent parts. So NT4‐V23 will identify a locality 100m x 100m while NT4 will identify a zone 3.5km x 3.5km approx. These options would be useful for example for obtaining a delivery quote without having to reveal your full postcode to the shipping company privacy advantage that Eircode cannot match. It could also be useful for taxi dispatchers or emergency service operations to assign resources quickly to a given zone. One big advantage that Loc8 Codes have over Eircodes is that that the zone and locality codes are logically rather than randomly assigned. This means delivery drivers or emergency service personnel will be able to learn the zone or locality structures that apply to their area of responsibility. Another big plus over Eircodes is that the full and locality versions of the Loc8 Code include a checker digit that help detect common human errors. Please note the checker digit is NOT a checksum and therefore does not function like a checksum whereby the checksum would have to change when the code is shortened. A checker digit is designed with a consumer code in mind, it spots common errors without being unnecessarily complicated. Having a code that is logical and includes built in safeguards makes it easier to communicate and verify. Other steps have also been taken to avoid confusion with Northern Ireland postcodes e.g. BT and other common and predictable causes of confusion e.g. w and vv etc. Loc8 Code – Lightweight algorithm driven Unlike Eircodes Loc8 Codes do not rely on a database, they rely on a simple yet sophisticated engineered computer algorithm. The code is simple in that it consists of approximately 50 lines of computer code making it very small and lightweight when it comes to integrating Loc8 Codes into software or hardware. The code is sophisticated in that those 50 lines of code contain all the smart rules and exceptions for consistent generation or mapping of a Loc8 Code. Any device (computer, mobile phone, GPS system) which contains the Loc8 Code algorithm can calculate the exact location of a Loc8 without an Internet connection and/or database search. This means 100% coverage, 100% of the time without exception. It doesn’t matter if the user is looking up a Loc8 Code on the Blasket islands or in central Dublin, it will just work. Enter GPS co‐ordinates and get a Loc8 Code out, reverse the process and put in a Loc8 Code and get the exact same GPS coordinates back out. Loc8 Code – Faster and more secure Because a Loc8 Code can be translated into GPS coordinates without connecting over the Internet it is much quicker in use than Eircode. Consider the case of the emergency services, even if they do have an Internet connection, that connection can take time to connect and may be slow. Vital minutes could be lost. Because Loc8 Codes do not rely on a central database server they are much more secure and there is no single point of failure and generation or mapping is practically instant. The fact that Loc8 Codes can be generated on‐device and without broadband coverage (database access) makes them infinitely more available than Eircodes as planned. No security issues arise from reverse running the code because there are half a billion possible Loc8 Codes and no way of knowing which of these are actually dwellings. Reverse engineering of Eircode makes sense to a hacker while doing the same to Loc8 is simply unfeasible. Loc8 Codes are not a hack, DoS or data poisoning risk unlike like Eircodes. Also an algorithm needs no maintenance and thus suffers no downtime so no need to worry about an SLA. Loc8 Code – Self Service saves money Because of the publicly available nature of apps and websites that generate Loc8 Codes these can be used to “self‐service” the delivery of Loc8 Codes to early adopters. If it is the intention of the Department of Communication Energy and Natural Resources to notify 2.2 million addresses of their individual postcode then this is likely to cost €2.2 million to deliver when postage and printing are taken into account. If a sizeable number of these locations were able to self‐service the creation of their own postcode this would mean that the savings in postage alone could pay for the acquisition of the portion of Loc8 Code that is not already owned by the state via Enterprise Ireland.

The government could announce an initial self‐service phase of the postcode roll‐out followed up by a postal rollout at a later date to all those that have not already self‐generated a code. Self‐service creation of Loc8 Codes is already tried and trusted and has been integrated using ordinance survey house mapping and to date over 100,000 codes have been generated. Self‐service also has the advantage in that it can be applied to non‐dwellings such as building sites etc. and reduces bureaucracy and hence running costs for the overall postcode project. I suspect that self‐service will show transparency of code generation and may enhance “buy‐in” and adoption by citizens on the ground by offering them enhanced ownership. Exact details of how Loc8 would propose a roll‐out available from Loc8 themselves who have plans based on 4 years in market place. Loc8 Code – For every location on island of Ireland On a small island such as Ireland it makes sense to roll out a code that can be used in both jurisdictions. This makes it easier for people, businesses and tourists to travel around the island and it also can play a part enhancing emergency services co‐operation as there are many occasions, especially in border areas, where fire and ambulance appliances from the south head north and vice versa. Loc8 Code was designed from the beginning to be an all‐Ireland address code. Using a lightweight algorithm based code would impose very low adoption costs for all users north and south. Because it is algorithm based, northern ireland users simply need to opt‐in by creating a self‐service code, and there is no expensive database required. Loc8 Code – Install once NEVER requires updating Because the algorithm is so small it means that any update for a device such as a GPS or smartphone can actually be quite tiny and measured in kilobytes not megabytes or gigabytes. So the firmware update file needed to make a GPS compatible with Loc8 Code could potentially be 2 million times smaller than the update for Eircode which is important if your broadband is very slow. Importantly this firmware update for your GPS or satnav only needs to be carried out ONCE. Once the GPS is Loc8 aware it stays this way and never needs an update again. Garmin have featured Loc8 code since 2010 with expanding devices supported since then. Compare to Eircode this means consumers, businesses and tourists update ONCE only not every 3 months. Loc8 Code is much easier & cheaper for them to adopt and maintain which is even more important for organisations such as emergency services. For smartphone users the Point8 App is available now from the iTunes or Android Play store. Loc8 Code – Ideal for emergency services A dwelling based postcode is only useful for emergencies that occur in and close to dwellings but there are many accidents that happen away from dwellings such as RTAs, cliff, mountaineering & potholing accidents, farm accidents, forestry accidents, missing persons, light aircraft crashes etc. Loc8 Code can help in all these situations as ANY location on the Island of Ireland can be given a Loc8 Code. Getting ambulances or other emergency services to a casualty quickly saves lives but it also saves money and allows organisations to maximise the current resources they have at their disposal. I think it is well recognised that our emergency services are in crisis due to lack of resources amongst other reasons. The implementation by the DECNR of a genuinely useful postcode is a low cost way of helping these organisations (NAS, Fire brigade etc.) maximise their efficiency and effectiveness.

In one simple example Irish Water Safety and Local Authorities are already using Loc8 codes to mark ring buoys. If a member of the public notices a damaged or missing ring buoy they can call this in exactly without confusion. The Gardaí have also approved Loc8 code for use in their squad cars after a rigorous testing process in Templemore. The HSE also use Loc8 Code for Major Emergency Planning. Loc8 Code – Ideal for utility company / local authority infrastructure Eircodes are only useful when reporting issues relating to dwellings so for a lot of day to day problems experienced by utility companies or local authorities Eircodes are useless. Using Loc8 Codes on the other hand it is possible to accurately report a dangerous pothole with 6m accuracy to your local authority, or livestock on a road, or a faulty streetlamp or a gas leak etc. The benefits of Loc8 Code for utility companies and local authorities would be immeasurable, enhancing efficiencies and enhancing safety. It provides one simple streamlined system with no need to re‐invent a system every time they need to catalogue outdoor assets. For major emergencies such as winter’s storms Loc8 Codes are very useful making it easy to accurately report infrastructure damage and thus leading to quicker location of faults and thus quicker repairs saving time and money. Loc8 Code – Ideal for transport companies For the general public Loc8 Codes are ideal for identifying bus stops. For taxi services they would be invaluable for guiding taxies to a customer not located at a dwelling. And with regard to emergency access to transport infrastructure Loc8 codes are already being used for emergency access to the railway lines –. Loc8 Code – Ideal for tourism Because any location can have a Loc8 Code it is especially useful for tourism. Way marked trails can use the Loc8 Code to indicate points along trail or cycleway. Indeed tours could be devised that follow Loc8 Codes that would not be possible using Eircodes. For example a tour of the Wicklow mountains could start with a viewing point overlooking Dublin, then move on to the source of the River LIffey, and then move on go Glenmacnas waterfall before a visit to the round tour and lakes at Glendalough none of these attractions will ever have an Eircode. Loc8 Code – Ideal for temporary events There is no provision with Eircode to provide temporary postcodes to large events such as Bloom or the National Ploughing Championship. Events like this are very large shows with many hundreds of exhibitors and tens of thousands of visitors. While they may have their own system for mapping stands, using Loc8 Codes could simplify thing for them, again why invent your own system if Loc8 Codes will do the job. Using Loc8 Codes at these events could also enhance safety as emergency services such as first aid posts or defibrillators could be highlighted with a Loc8 Code.

`Loc8 Code – Idea for wildlife surveying The National Parks & Wildlife Services as well as multiple NGOs regularly run surveys to count wildlife or to plot invasive species etc. Using the simple consumer friendly Loc8 Code system would allow these organisations and their members conduct their surveys with greater ease. A simple code like Loc8 would also allow easier participation by the general public Red Herrings Some issues that may cause confusion. Random versus Sequential versus Nested Eircode features a routing key tied to the primary postal operator in Ireland followed by 4 random digits this allows for new postcode to be issued for a new building built in between two existing buildings. A sequential postcode would not allow for a new postcode to be issued for a new building in‐between two existing buildings but Loc8 Code is NOT a sequential postcode. Loc8 Code is a logically assigned nested code, this means it follows simple rules to generate a code from a GPS position. So Loc8 Code will allow a new unique postcode to be issued for a new building built in between two existing buildings. Not accurate enough The accuracy of Loc8 Code is +/‐ 6 metres and this matches the accuracy of consumer satnav devices. There is no practical reason to have a more accurate postcode because it cannot be resolved without the use of very expensive additional equipment. Giving a postcode to an apartment There is no logical reason to give a postcode to every individual apartment in an apartment complex. The front door of the apartment block is the first place a delivery person will look for and once there the apartment number will suffice. Adding thousands of apartments to the databases increases the size and cost of the database for no appreciable benefit as it will not lead you further than the front door of the block. It could also lead to the bizarre situation where an actual apartment block itself would not have a postcode which would hinder location by maintenance personnel. Giving a postcode to an individual apartment adds to public unease and could lead them to believe that Eircodes are only for collecting tax. Having multiple Eircodes for the same front door GPS position is just creating confusion and in no way adds to accuracy as the GPS location of the apartment will not be the physical location of the apartment. Checksum doesn’t work The checker digit in Loc8 code is not a checksum and does not work like a checksum it is designed to help identify common errors and also works when a shortened 6 digit version of the code is used.

What if you can’t self-service? Self‐service generation of a Loc8 Code is something that has been in use for almost 5 years and over 100,000 times. Self‐service of a postcode would allow the government to save millions of euro in printing, postage and man hours. It would also allow end users to obtain their postcode in a timely manner without having to rely on someone to do it for them. Persons unable to self‐service their own Loc8 code could receive their code in the manner similar to the way Eircodes plan to roll out to all addresses via a postcard or letter detailing your postcode. Self‐service allows the opportunity to save money and speedup a rollout but does not preclude or prevent any other method of dissemination post codes. Essentially the DCENR should welcome and encourage as much self‐service as possible so as to reduce ongoing administration costs and speed up delivery.

Full Loc8 Code – +/- 6m Accuracy – NT4-82-V23

Loc8 Locality – 100m x 100m area – NT4-V23

Loc8 Zone – 3.5km x 3.5km area – NT4