Submission: Moving towards a financially sustainable mail service
This week, Anna made a submission on proposed changes to New Zealand Post’s minimum service obligations, which are set out in the Postal Deed of Understanding. Proposed changes include reducing the number of mail delivery days from 3 to 2 in urban areas and from 5 to 3 in rural areas. The content of Anna’s submission, which reflects the views of Antistatic more generally, is re-posted below.
You can read the discussion document, Moving towards a financially sustainable mail service, and further information about the consultation on the Ministry of Business, Innovation and Employment's (MBIE) website.
The submission below has been reformatted for publishing online, and we have removed the questions Anna did not provide answers for. The submission was lodged as a Word document using the template provided.
Name: Anna Pendergrast
Organisation: Antistatic New Zealand Limited
I am writing this submission from three perspectives: as an individual who uses the mail service, a small business owner, and a writer and strategist who has a specific focus on digital technology and infrastructure systems and their impacts on people.
Introduction
The postal service in Aotearoa New Zealand is an important infrastructure that supports community connections, businesses and democracy. I consider the approach proposed in the discussion document — including reducing the number of delivery days and postal outlets – makes sense within the State Owned Enterprise model and in the context of dwindling mail volumes. However, I am concerned that this approach, and particularly the reduction of delivery days, is a concrete step towards dismantling the infrastructures that support regular, reliable mail delivery.
One of the concerns expressed both in the discussion document and in media commentary on the subject is that people who are not digitally included may be disproportionately impacted by the reduction in mail delivery days and post office service centres. While I agree with this concern, I also think there is also a wider issue to consider – that a regular, reliable mail system allows for a fundamentally different type of connection and communication than email and other internet-enabled communication.
Beyond the goal of ensuring NZ Post can be financially sustainable, we should be asking: what will be lost if the underlying infrastructures are further dismantled? The ability to send and receive a written card or letter – even if it’s very occasionally – is powerful. The internet as a “place” to congregate is in flux, and shouldn’t be seen as the inevitable replacement for as much physical mail as possible.
To this end, I recommend that the next review of the Deed of Understanding includes a broader consultation to understand what people in Aotearoa need and want from a postal system (including NZ Post parcel and courier products). Focusing on the outcome of NZ Post needing to operate profitably is too narrow and does not allow for community and business aspirations to be shared and a clear strategy to be made to get there.
General questions for organisations and businesses
What sector of the economy does your business or organisation operate in?
Antistatic is a communications and research consultancy.
Roughly how many letters does your business or organisation send in a month? And how many do you receive?
On a day-to-day basis, we operate primarily digitally and do not send much mail.
However, at the end of each year, we send out a physical Antistatic Print Object as a gift to colleagues and friends. We use the mail service to do this and I typically send about 60 A5 envelopes around Aotearoa and Australia (my colleague who is US-based sends about 80 pieces of mail using the USPS).
This project is a purposefully offline exploration of alternative methods of distribution, and reflects that there is inherently a different feeling from receiving a physical object you can hold and share than an email that arrives in an already crowded inbox.
Are you planning to undertake any programmes to reduce your business’ or organisation’s reliance on mail e.g. transitioning towards digital alternatives. Why/Why not?
We will continue to send people a physical Print Object annually and will likely add an e-commerce mail-based offering in 2025.
Is there some amount of mail you still need or expect to send even if your business uses alternative communication channels?
As above, once a year we will send about 60 A5 envelopes within Aotearoa and Australia. This may increase in future years as we plan to have an option that allows us to cover costs which will increase the number we can send.
General questions for individuals
Roughly how many letters do you send in a week?
In a personal capacity I send about 2 letters or postcards a month, with more over the Christmas period.
What is your main reason for using the mail service, versus other means of communication e.g. face-to-face, email, online etc.?
As noted above, there is a real joy from receiving a physical piece of mail that someone has sent. The process of writing or making a card or letter, sending it off, and then having something you can keep or display is something I treasure. While email and the internet more broadly enables communication at a scale and speed that was previously impossible, there are limitations to what it can enable.
What types of communications do you regularly receive by mail?
For example, bank statements, utility (telephone, electricity) bills, rates bills and hospital notifications.
Rates bills, ad hoc mail for administrative purposes, letters and postcards from friends and family.
Questions about the proposals in the discussion document
Changes to minimum delivery frequency
How would the proposed delivery frequency changes impact how you send and receive mail, if NZ Post were to operate at the proposed minimum levels?
On an individual level, the impact will not be significant for me, although I will need to plan further in advance for sending and receiving mail. However, I consider that the move to reduce the days of delivery will have a significant impact on New Zealand having a regular, reliable postal service for mail items.
I recommend the provision to require non-consecutive delivery days should stay in the deed. I do not consider that this should be left to NZ Post operational decisions and delivery targets. Having a delivery on two consecutive days (e.g. a Monday and Tuesday) may mean that there is a five-day gap between mail delivery, which could have significant flow-on effects, especially for official paperwork that requires a prompt response or has limited timeframes.
Changes to where NZ Post would be required to deliver mail
If you were moving to a location that was not currently within NZ Post’s mail network footprint (e.g. not receiving mail delivery), how would you feel about receiving mail at a community collection point, or other means than through a letterbox at your property?
The proposal to enable 5% of pre-existing mail delivery points a year to become communal pick-up points signals a major potential shift in how mail is delivered in Aotearoa more generally. I am interested in whether NZ Post intends to use this provision to its greatest extent, which (if I understand correctly) could mean that by 2045, 100% of mail delivery points will be transitioned from individual house post boxes to community mail boxes or pick up counter services. While this isn’t necessarily an issue, and many other jurisdictions use the approach of a central pick up place for mail, it does deserve a more broad conversation which is explicit about this proposed change so communities can understand how it will impact them.
Changes to requirements regarding NZ Post’s retail presence
Do you typically require assistance when sending mail items (not parcels) at a postal outlet and what type of assistance do you require and/or receive?
I think this question should have been scoped more broadly to understand people’s use of postal outlet services overall if you are proposing making changes to this number. First, it is hard to separate out the use of Post Shop facilities for mail and parcel service. Second, clause 14 of the Restated Deed of Understanding (2013) notes that New Zealand post shall “maintain at least 240 service points where personal assistance is available to consumers for the purchase of Additional Postal Services”. Additional Postal Services are defined in the Deed to include parcel and package postage products and the lodgement of those products (but excludes NZ Post courier services). Therefore, other parcel/package services by New Zealand Post do appear to be in scope. It seems inappropriate to scope this question only around mail products (which I assume is only around stamps – although this is not clear).
When making decisions about whether this level of service should remain, it is important that MBIE considers the current demand for people’s use of Additional Postal Services and NZ Post courier more broadly rather than just standard/basic mail services.
Do you believe the existing requirement of at least 240 manned points of presence should be maintained in the revised Deed?
I recommend this should be retained unless it is very clear that people are not requiring assistance, including for parcel and NZ Post Courier products. I think the term “manned” should be updated in the Deed to be gender neutral.
Future Review date for a revised Deed of Understanding
Do you have any feedback on the proposal for the next Review of the Deed to take place by three years from the date of any revised Deed following the 2024 Review?
I recommend the next review should take place by five years from the date of a revised review, unless there is a significant decline in mail numbers (and this threshold should be stated in advance). There does not appear to be anything in previous Deed wording that would prevent an earlier review if it was considered necessary. I note that there have been two amendments to the 2013 revised deed to extend the timeframe – in this context, 3 years for the next review seems optimistic.
Closing comments
Do you have any other feedback about the proposals in this discussion document that you would like to provide to MBIE?
The postal system is a vital infrastructure for Aotearoa New Zealand – and in this I am including parcel and courier services as well as the standard mail system, which is primarily letter-based. I think the next review of the Deed should take a more holistic look at the needs of New Zealanders – the scope of what is included as “basic mail” and how we meet our universal post service obligations more broadly should be up for discussion to ensure it meets the communications needs of New Zealanders into the future.
It feels like there is a specific end-state in place that NZPost is considering for its provision of mail services – including a move towards more central pick up areas for mail – and this deserves a bigger conversation than doing it around a specific Deed of Understanding that has a very specific scope.
While the internet has meant people can communicate via email and other online tools and fewer letters are being sent, I think it’s worth looking at the benefit of the postal system for communities and connection – including the increased focus on sending things to each other. There was limited discussion of how the postal system is used for postal voting in local elections, to confirm people are on the electoral roll, to send jury summons and many other activities that are vital to a functioning democracy. In all these cases, it can’t be assumed that email or online voting will supersede the need for reliable mail in the short-term.