I have been called rude, confrontational, hysterical, boorish, disrespectful, unprofessional, delusional, self-serving, and disingenuous by some in our industry. All because of my belief (based on past experiences) that our industry should take an aggressive and, if necessary, confrontational approach anytime the Postal Service wanders beyond its limited statutory confines of delivering mail.

The Postmaster General in a March 7, 2013 meeting said that he (the USPS) would not compete with the direct mail industry. In July there was another meeting among industry people, postal associations, and the Postal Service. Many attendees were present for both meetings. The reason for the second meeting was to discuss small business adoption of the Full-Service IMB mandate and the Postal Service's IMsB Tool (USPS produced software that qualifies mailings for Full-Service and the lowest postage rates).

The word from the industry was that this tool was not needed, as it directly competed with existing services and functionality already provided by the direct mail industry. In August attendees received a letter from the Deputy PMG and Ellis Burgoyne stating that they were going ahead with the development and marketing of the IMsB Tool. Obviously, passivity when dealing with postal bureaucrats is a losing strategy!

The law governing the Postal Service clearly states that the USPS is restricted to providing "postal services" which are defined as "the delivery of letters, printed matter, or mailable packages, including acceptance, collection, sorting, transportation, or other functions ancillary thereto." The law also establishes two criteria under which the PRC can allow the USPS to provide non-delivery services. They are "the public need for the service," and the ability of the private sector to meet "the public need for the service."

In practice the USPS is only constrained by what our industry allows postal bureaucrats in Washington get away with. The law is on our side; all we need to do is find leaders willing to aggressively defend our rights. The IMsB Tool is a piece of software for use by small, occasional mailers. Small is defined as less than 10,000 pieces per mailing, occasional is no more than 250,000 pieces per year. A mailing services provider (MSP) could add significant revenue to their bottom line by picking up a couple of these underserved (according to the USPS) "small mailers." On the other hand, the MSP could go bankrupt if postal sales teams convince a couple of their customers to start preparing mailings in house using the IMsB Tool.

I've seen this movie before. It was called EDDM and the plot ended with postal sales teams using our customer information to convert our customers into direct postal customers. Can't wait for the IMsB sequel!

The IMsB Tool uploads a mailing list to USPS servers, provides for address correction and duplicate elimination. It presorts the list down to the finest sort, prints tray and bag tags, and provides for the output of addresses on labels, envelopes, or in a mail merged document. It uploads the postal documentation to PostalOne! and prints an Electronic Confirmation Acceptance Notice (ECAN) to facilitate seamless acceptance into the mail stream. The IMsB Tool qualifies the mailing for IMB full service (along with discounts), the lowest postage rates, and IMB tracing. Soon it will be providing NCOA processing. All of these software services are provided free to a restricted group of customers.

Well nothing is free

What the USPS means by free is that the people getting the benefit of the IMsB tool will not pay for its use. The rest of the industry (through postage increases) is paying for the development, implementation, hosting, maintenance, and extensive marketing costs for this software boondoggle. Implementation of the IMsB Tool demonstrates the hubris of the postal service, the fecklessness of many leaders in our associations, and the cowardliness of business leaders for not aggressively defending their markets and customers. At the time of this writing I know of no negative actions or public protests in response to the Postal Service's letter dated August 23, 2013.

Of course, aggressively fighting for our rights and businesses is considered boorish and hysterical by many. But there is no question that this tool competes directly with software vendors. No question it competes with professional mail service providers who have been selling their postal expertise to the "small mailer" market since the inception of bulk mail. There is no question the USPS does not have the money to spend millions on the continued development and maintenance of the IMsB Tool. There is no question that this is an unauthorized, illegal move by the Postal Service into a non-deliver service.

What passive industry leaders seem to be missing is context

The average size of most customer mailings is well under 10,000 pieces of mail per mailing. What if the Postal Service said that each permit could mail 250,000 pieces per year using the IMsB Tool? Owning two permits would allow you to mail 500,000 pieces, four permits one million pieces. Many mail service providers could save a significant amount of money by buying multiple permits, which currently have a onetime fee of $200. Jobs larger than 10,000 pieces could be split into multiple jobs or outsourced to another service provider.

As for our associations, if there were fewer customers due to postal competition there would be less revenue from which to pay association dues. This would lead to fewer members, fewer associations. With many associations more interested in keeping the channels of communication open than protecting my company from a loss in revenue, it's inexplicable as to why I or anyone else would want to continue to be a member. I don't need representation by a bunch of delusional sheep herders; I need representation by hungry wolves willing to protect my company from postal incursions.

You know
I've moved to sitting on the fence on this issue. Maybe we should be pushing the USPS to enhance the functionality of the IMsB Tool and loosen its restrictions. BMEU's would never question our paperwork or sortation accuracy. Would zero software costs make up for the loss of revenue from a couple customers that decided to go it alone? Maybe we should be encouraging the Postal Service to do even more.

You know what they say if you can't beat em, join em!

(How's that for context?)

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