Submissions

To: Ministry of Business, Innovation & Employment
Date: December 2024

Purpose

This submission’s core purpose is to express significant concern regarding the proposed service reductions within the postal system. DPA aims to advocate for the protection of postal services for digitally excluded groups, including disabled people, older people, rural communities, and Māori, who rely on traditional mail for essential information and communication due to various barriers to digital access.

Summary of DPA submission

DPA expresses deep concern about the proposed service reductions outlined in the "Moving towards a financially sustainable mail service" consultation paper. While acknowledging the shift towards digital communication, DPA highlights the growing digital divide, which disproportionately affects groups like disabled people, individuals in insecure housing, refugees, migrants with English as a second language, rural communities, and unemployed people. For disabled people, digital exclusion manifests through barriers such as inaccessible web content, poor digital skills, high costs, inaccessible devices, and increased reliance on support people for online access.

DPA emphasizes that MBIE and NZ Post must prioritise the interests of digitally excluded and older people in all decisions regarding changes to mail services. DPA recommends that the Deed of Understanding be amended to include a postal services transition plan that allows for the retention of current service levels until the next review is triggered. This transition plan should be developed in full partnership with all impacted communities, including disabled people, to prevent the creation of a "full-blown communications divide" that would exclude those unable to access digital modes of communication.

The proposed changes include reducing urban postal delivery to two days per week, rural delivery to three days, and PO Boxes/Private Bags to two days per week, which contrasts significantly with current, more frequent deliveries. These reductions will particularly impact disabled people in rural areas, digitally excluded Māori, and those who rely on printed essential documents like Total Mobility ID cards, mobility parking permits, or formal letters for critical appointments with Work and Income NZ or health services. DPA notes that current mail delivery is already inefficient, with members reporting delays that cause them to miss important appointments.

DPA disagrees with the removal of language regarding non-consecutive delivery days and urges NZ Post to retain commercially set, published targets on mail delivery timeframes, particularly for communities experiencing high rates of digital exclusion. They also recommend that all current NZ Post outlets in community locations, such as dairies, remain in place to ensure accessibility for disabled and other disadvantaged communities. While DPA supports the concept of community collection points in areas not currently within the mail network, they strongly recommend that direct letterbox delivery is retained for disabled and older people upon application, acknowledging the difficulties these groups may face in accessing community collection points independently.

Key Recommendation/Finding:

DPA recommends that MBIE and New Zealand Post change the Deed of Understanding to include a postal services transition plan enabling the retention of current service levels until the next review is triggered.

Supporting Statement 1:

"Groups who are highly overrepresented in digital exclusion statistics include disabled people, people living in insecure housing situations, refugees and migrants with English as a second language, people living in rural communities and unemployed people."

Supporting Statement 2:

"It is important that postal services are available so that people can receive these important cards through the post as these enable community participation and inclusion for many disabled people."