[COMPANY LETTERHEAD]
[DATE]
<Mayor>
<Address>
Re: Changes to the Process of Installing Community Mail Boxes (CMBs) in New
Developments
Your Worship,
I am writing to alert you to the recent announcement by Canada Post Corporation. It
proposes a “super-box” levy of $200 per house, to be collected during the subdivision
process. The <<local association/member company>> does not believe that Canada
Post has the legal authority to implement the fee.
In a March 26, 2013 letter from the Canadian Home Builders’ Association (CHBA) to the
Minister responsible for Canada Post (Hon. Denis Lebel) it was noted that “Canada Post
has not been able to point to any existing authority for its levy; nor is it able to point to
any future legal authority”, (e.g. any regulation that would authorize this fee). CHBA
solicitors have advised members and local home builders associations that there is no
existing or prospective legal authority which has been further supported by legal advice
received other members across Canada. We are also aware of at least one provincial
Premier, and one GTA Mayor, who has advised of their government's opposition to any
further attempt, by Canada Post, to intervene in Subdivision Agreements and related
matters outside federal jurisdiction.
In addition, <<local association/member company>> has a number of additional
concerns with the proposed fee itself, including:
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Canada Post has indicated to our national and provincial home builders’
associations that Canada Post has historically incurred the full costs of installing
CMBs and activating all addresses in new developments. This is simply not the
case. Our industry already accepts initial infrastructure costs associated with
building mail box pads in new low-rise developments. These costs far exceed the
installation of mailboxes, and the costs are not transferred back to Canada Post to
absorb.
Additionally, when our industry builds super mail boxes, this effectively lowers
Canada Post’s operations and maintenance costs on a per unit basis. New
community residents have accepted ‘the walk to the mailbox’ in an effort to support
service efficiency.
A component of Canada Post’s rationale for implementing the new fee is the rapid
decline in mail, leading to the corporation’s unprecedented financial losses. This is
an unfortunate circumstance, but new home buyers should not be the ones to
accept the displacement of burden for operational shortfalls.
<<Please add any further local concerns>>
<<local association/member company>> notes that CMBs represent a reduced quality
of mail service. The adoption of this reduced service standard was taken to help
address fiscal issues being experiences by Canada Post. A new $200 levy to accept a
lower standard of mail service will ultimately be paid for by the new home buyer.
There is currently no agreement with respect to the justification of the fee itself or with
respect to the proper implementation, transition for previously approved projects and
potential collection and remittance of the proposed fee by municipalities on behalf of
Canada Post. Due to a continued absence of legal authority and an unclear
implementation process for which fees are supposed to be collected by municipalities,
the <<local association/member company>> strongly recommends that ______
<<municipality>> should support new home buyers and housing affordability and not
collect the fee on behalf of Canada Post.
Sincerely,
cc:
Canadian Home Builders’ Association (chba@chba.ca)
(Insert Provincial HBA) (email address)
(Insert Local HBA) (email address)