The USPS received over 400 comments, nearly all from nonprofit organizations, when the First Class vs. Standard proposed rule was published in the Federal Register. It may well have been one of the most controversial proposals offered by the USPS.

At the Alliance of Nonprofit Mailers Board of Directors meeting last summer, Anita Bizzotto, a member of the Senior Executive Team and the chief marketing officer of the USPS, outlined the process governing the rulemaking that becomes effective June 1, 2005. She also agreed that the USPS was not fully aware of the SOP-98 regulations or other accounting rules that affect nonprofit fundraisers.

The Alliance of Nonprofit Mailers Board offered its assistance in the USPS rulemaking process and felt comfortable that the revised rule would reflect a better understanding of nonprofit accounting rules, especially since Stephen Kearney, USPS vice president, Pricing and Classification, assured the nonprofit community, "If you are able to mail it at Nonprofit Standard mail rates today, you will be able to do so on June 1, 2005."

However, the mailing community is not as optimistic today as it was last summer. Businesses and organizations rely on discounted postage rates for printed matter that does not require First Class or fast delivery service; weighs less than one pound (16 ounces); is made of printed pieces identical in content, size and weight; and meets USPS requirements. Standard mailings are an effective means to reach a large audience at discounted postage rates. The postage costs are discounted because the sender provides the labor required to prepare the mail for entry into the USPS system. It can be classed as Nonprofit or Regular. Nonprofit rates are lower than Regular Standard mail and have strict USPS content requirements. Over the last several years, as advances in technology have facilitated the increase of personalization in computer-generated mailings, mailers have invested great effort in developing direct mail packages that comply with existing requirements.

Many mailers fear that some types of mail currently prepared for entry as Standard mail will require substantial modification if they are to remain eligible under the new · rule. For example, organizations are currently able to mail membership cards at Nonprofit Standard Rates; however, the inclusion of an expiration date or identification number may be enough to disqualify the use of the Standard mail rates after June 1. The mailing community needs the reassurance that Kearney's promise will be kept.

The final rule represents a marked improvement of the earlier proposal, and the USPS has introduced a process by which mailers can obtain pre-production review of mailpiece eligibility. The voluntary Centralized National Cases Program is an effort to ensure consistency of ruling and implementation of standards. However, the USPS is evaluating the impact on existing interpretations of the rule as it considers rewriting Customer Support Rulings (CSR). Customer Support Rulings are decisions made by postal management that interpret the Domestic Mail Manual. The U.S. Postal Service has already issued a revised customer support ruling just before the new year regarding personal information contained in a mailpiece and another clarifying that certain customer markings on the outside of advertising matter do not constitute personal information according to the Domestic Mail Manual. The fear among mailers is if rulings that have become the backbone for mailing decisions are changed, entire campaigns will have to be restructured.

Mailers will need to make sure that personal information is not included for any reason other than the support of advertising or a charitable solicitation. On June 1, when personal information is included for other purposes in whole or in part rather than only to support a related advertisement or solicitation the mailpiece will be considered to have the character of actual and personal correspondence and will not be eligible for Standard mail rates.

Of particular importance to the nonprofit mailing community is the Customer Support Ruling, PS-262, Computer Prepared Contribution Notices and Pledges (updated in March 2001). This CSR states that personal information regarding financial transactions to a nonprofit organization qualifies under DMM E610.2.3 to be mailed at the Nonprofit Standard Mail rates of postage as long as a statement that requests increased pledges or additional donations is included.

However, charitable organizations have recently been forced to pay higher First Class rates because USPS officials deemed certain mailings containing acknowledgements of prior contributions ineligible. These mailers had conscientiously sought the advice of the USPS before introducing the mail.

Mailers now wonder if the USPS intends to impose a somewhat subjective test of guessing their "intent." Near the very end of the notice, the USPS states, "Thus, it is possible that an additional consequence of this rulemaking will be to reduce the amount of personal information in Standard mail." Yes, and force mailers to mail at much higher First Class rates. Mailers will be compelled to mail less. E-mail, anyone?

Ellenor A. Kirkconnell is assistant director of the Alliance of Nonprofit Mailers. For more information, please visit the company's Web site at www.nonprofitmailers.org.