An unfortunate yet chronic criticism of the Postal Service is that it seems to not understand its commercial customers’ businesses. What they do, why they do it, what their business objectives are – all that seems too often to escape the USPS, despite decades of exchange between the agency’s personnel and its customers at a range of levels and venues.
To many in the commercial mailing business, as well as their clients and associated agencies, the latest example of this circumstance was an unexpected proposal the agency published for comment in the August 23 Federal Register. In what was described as an “advance notice of proposed rulemaking,” the Postal Service stated it was considering, and in turn sought public comment on, a change to the content standards for Standard (USPS Marketing) Mail. The revision the USPS described would limit what can be sent under the classification to only paper-based material, effectively excluding other small items and requiring them to be sent at a parcel rate. Beyond that, the “supplementary information” in the notice wasn’t very elucidating:
“… The limitation to non-merchandise, paper-based/printed matter content would serve three goals: (1) Facilitate levels of service expected for the processing and delivery of merchandise that include end-to-end tracking and visibility, (2) move fulfillment of merchandise and goods out of USPS Marketing Mail, consistent with the transfer of fulfillment parcels out of Standard Mail (the predecessor to USPS Marketing Mail) in Docket No. MC2010-36, and (3) reduce operational inefficiencies when machines are unable to process letter-size or flat-size shaped inflexible items. Shifting goods and merchandise out of the letter-size and flat-size categories helps improve processing capabilities and ultimately shifts these items to mail streams with full end-to-end tracking capability consistent with market expectations. The Postal Service has many products available to support this shift and seeks to align postal processing with the intentions of its mailing customers. This shift also simplifies the mailing experience: Letter-size and flat-size pieces will move through processing and delivery more efficiently. Packages with goods and merchandise will have an Intelligent Mail package barcode (IMpb) and will travel through the package network stream.”
Many found the proposal to be an extreme measure to remedy a poorly defined problem. If its goal was operational efficiency, it wasn’t clear how or why the current standards for mail piece characteristics weren’t effective, or how simple revisions to those standards wouldn’t achieve the same objective.
What was most disturbingly unclear was how thoroughly the USPS analyzed the mailstream to validate its apparent conclusion that processing compatibility can be defined or assured by implementing a simple paper vs. non-paper distinction.
Perhaps not surprisingly, the notice didn’t explore how the proposal would impact mail preparation or postage costs, or whether existing Standard Mail rate categories for “commercial marketing parcels” or samples would be eliminated. But the initial respondents to the notice didn’t need this missing discussion to comment on how ratepayers, especially nonprofits, would be severely impacted. Plastic membership cards, refrigerator magnets, T-shirts, and pens, all now sent in Standard Mail letters and flats, would instead have to be sent at a parcel rate, and those rates are substantially higher – rendering them unaffordable for some mail users.
Well before the October 22 end of the comment period, two large associations, the Association for Postal Commerce (Postcom) and the Alliance of Nonprofit Mailers, challenged the proposal on legal grounds. Simply put, those groups contended that what the USPS was trying to do through rulemaking was, in fact, a classification change that could be done legally only through a proceeding before the Postal Regulatory Commission (PRC).
In the wake of the initial response from the mailing industry – both in writing and in person – the USPS sought to clarify that it was, essentially, just asking for input on an idea. In a September 20 Industry Alert, the Postal Service stated:
“... We issued the advance notice to receive comments from as many stakeholders as possible on a potential change to the content eligibility standards of USPS Marketing Mail letters and flats. The goal of the notice is to inform our decision-making by seeking broad feedback from all interested stakeholders with regard to potential changes we are contemplating to our content eligibility requirements. … To be clear, we are seeking stakeholder feedback to assist us in making an informed decision on whether to propose changes, but at this stage no decision has been made, and no alternative rule or rule changes have been proposed.
“... Upon conclusion of the comment period, we will be working with the Mailing Industry to evaluate, define, and determine whether to propose any changes to USPS Marketing Mail content eligibility standards, and if changes are warranted to design the proposed rule. This is part of an in-depth evaluation of USPS Marketing Mail. We will seek necessary approvals from the Postal Service Governors and the Postal Regulatory Commission as warranted should any content changes be recommended at the conclusion of the evaluation process. If the Postal Service decides to make content changes, and they are approved, the earliest they would be implemented is calendar year 2020.”
However, by indicating there’s an ongoing “in-depth evaluation” and a potential timeline, the “clarification” didn’t diffuse anxiety as it likely had hoped, and instead seemed to indicate the USPS is farther along with its proposal than initially indicated.
Privately, some in the Postal Service have acknowledged that the proposal was a subject of considerable debate within the agency and that, despite urgings to the contrary, its publication was directed from the highest levels of management. The apparent need to gather reaction to the proposal begs the question of why USPS executives would even wonder how the industry would react. Shouldn’t it have been obvious? Does the fact that the proposal actually got into print confirm the industry’s long-held belief that the Postal Service just doesn’t understand its customers – what they do, and why they use the mail?
Whether the industry’s responses to the agency’s proposal will have any educational benefit in that regard remains to be seen, as is how much farther the USPS will pursue its proposal. Hopefully, the voluminous and doubtlessly consistent responses it gets should provide that answer convincingly.
Leo Raymond is the owner and managing director of Mailers Hub, which is dedicated to providing information, resources, training, and expert advice to support mailing service providers and help them succeed. He can be reached at lraymond@mailershub.com.
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