December 7, 2007

Ms. Sharon Daniel

Manager, Mailing Standards

U. S. Postal Service

475 L'Enfant Plaza SW Room 3436

Washington DC 20260-3436

Re: Proposed Rule, New Address Requirements for Automation, Presorted and Carrier-Route Letters,

CFR Vol 72 No. 195, 57505-57506

Dear Ms. Daniel:

We are writing regarding the USPS' proposed New Address Requirements for Automation, Presorted and Carrier-Route Letters, published by the USPS in the Federal Register on October 10, 2007. Our position is based on the careful evaluation of the proposals by our large membership, which is comprised of direct marketing firms, printers, lettershops, suppliers, and others who either use or support the use of mail for business communication and commerce.

In this set of comments, PostCom addresses its concerns with respect to (1) the proposed minimum font size requirement and (2) the proposed rule concerning character and line spacing for letter mail. PostCom addresses both the same and other concerns with respect to flat-size mail in separate comments on the proposed rule concerning New Address and Barcode Requirements for Automation, Presorted and Carrier-Route Flat-Size Mail, also published in the Federal Register on October 10.

Proposed Minimum Font Size Requirement. The Postal Service proposes that "all letters mailed at discount rates must be addressed using a minimum 8-point type." PostCom does not believe the Postal Service has collected or shared sufficient data to justify the need for a minimum 8-point font size. Rather, driving this requirement is the Postal Service's perceived need for this requirement with respect to flat-sized mail, and the desire to promote consistency for letters and flats.

Many mailers report difficulty in accomplishing the combined impact of the proposed standards (not looking at them in isolation) without significant changes to processes or equipment. Combining a minimum 8-point font size requirement with the proposed minimum address line spacing/clearance requirements, and proposed Intelligent Mail Barcode (IMB) spacing and clearance requirements, for many mailers would create an address

block size that exceeds their existing address label/block size. Mailers would need to make extensive processes and equipment changes to accommodate a larger address block.

The need for a rule that requires mailers and vendors to make extensive equipment changes is not at all apparent, particularly in the absence of any supporting data. In its 2006 Comprehensive Statement on Postal Operations, the Postal Service noted that "[r]ecognition improvements deployed to 342 mail processing centers under the Letter Recognition Enhancement Program (LREP) this year raised the letter mail encode rate to more than 92% while slightly reducing the error rate." The Postal Service further noted that additional improvements "are projected to yield an additional 2-3 percentage point increase in the overall system encode rate by late 2007."

The mutual goal of achieving lowest combined costs prompts PostCom to recommend that the USPS continue to pursue mail recognition improvements through the modification of its own equipment. Shifting an overwhelming cost burden to mailers would not be consistent with the lowest combined cost goal and will disserve the Postal Service as well as mailers.

Proposed Character/Line Spacing Requirements. The USPS proposes that "for all automation pieces, the lines and the characters in the address must not touch or overlap, and each element of the address line may be separated by no more than three blank character spaces." PostCom does not oppose the proposed requirement that lines/characters in the address must not touch or overlap, except if that requirement prohibits the use of handwritten fonts (which are designed to have characters that touch). If a correct and complete barcode is used that meets the USPS' proposed requirements, then handwritten fonts should be allowed for letters.

However, PostCom asserts that the proposed requirement that elements on the address line must be separated by no more than three blank character spaces is too limiting. In all the years since the Postal Service and industry embarked on the letter-automation program, the USPS has not reported any issue with readability caused by elements on the address line having more than three blank character spaces between them. For years, mailers have used software systems that use fixed length fields for city names or state names. Under such circumstances, the printed result can be a blank space between these address elements greater than three spaces (e.g., when the city or state name is much shorter than the fixed field length). Yet never has the USPS reported any issues in reading these addresses.

The USPS has not provided any data to substantiate whether a problem exists with readability of these pieces. Modifying existing software systems would place a significant cost burden on mailers. PostCom recommends that the USPS conduct tests to determine whether any readability problems exist based on the space between address elements on the same line. If a significant problem were found to exist, then the USPS should work with industry to identify a lowest combined cost solution. (Please note that any future reference to "character spaces" would be better stated in terms of an actual physical measurement.)

In Conclusion. PostCom supports the Postal Service and industry goal of improving address readability, but feels that the specific standards proposed by the Postal Service in this rulemaking may be unnecessary and place an undue cost burden on mailers. W e urge the Postal Service to conduct appropriate tests to determine the extent of existing readability problems that any new letter standards may rectify, then work with industry to identify the lowest combined cost solution.

If you have any questions, or if I can be of any service to you, please be sure to contact me.

Sincerely,

Gene Del Polito

President