Trade Group Requests 120-Day Postal Case Implementation Period Mar 9, 2007 4:26 PM
, By Jim Tierney
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While the U.S. Postal Service Board of Governors (BOG)
considers the 700-page rate case recommendation from the Postal Regulatory
Commission (PRC), the Arlington, VA-based Mailers Council is asking the board
to adopt an implementation period of at least 120 days to allow mailers to
prepare for the wide-ranging new rates and rules changes.
In a March 8 letter to BOG chairman James C. Miller III,
council executive director Bob McLean asks that the minimum 120-day request
begin only after the BOG’s decision is published in the Federal Register. “In a
series of meetings over the last several months, ranging from first-line
managers to the Deputy Postmaster General, we have expressed the need for
adequate time between final implementation of new rates and regulations and the
implementation date,” the letter reads. “Our white paper on this issue,
previously delivered to your office, explains in detail why adequate
preparation time is beneficial because it makes rate cases less difficult,
litigious, and costly for both the Postal Service and its customers.”
Last August the Mailers Council, a coalition of mailers and
mailing associations, released a research paper detailing the benefits of a
standard implementation period for the Postal Service to follow when raising
rates. The paper called for a period of at least 90 days, longer in
more-complicated rate cases. No law or postal regulation currently mandates the
minimum number of days between the completion of a rate case and the date that
the USPS implements the changes, but the implementation period typically has
ranged from 30 to 60 days.
Mailers and postal employees alike need sufficient time to
plan for new rates, the research paper says, particularly in cases, like the
current one, that involve substantial rules changes and systems updates. “We
don’t assume anything until the Federal Register notice,” McLean says. “There
can be changes right up to the last minute. The Postal Service has a hard time
understanding. Preparing materials for a rate case like this is a perfect
example of why you don’t want to do anything until it’s necessary.”
Unlike the rate hike implemented in January 2006 — 5.4%
across the board — the pending case is much more varied. The PRC’s
recommendations call for an average rate increase of 7.6%, less than the U.S.
Postal Service’s proposed 8.1% hike. It recommends an average Standard mail
increase of 9.3%. But for some catalogers, rates would increase by appreciably
more.
Price recommendations for flats, for example--the category
affecting most catalogers--is appreciably higher than the increase originally
proposed by the Postal Service. For flats weighing less than 3.3 oz., the PRC
is recommending an increase of roughly 20%, instead of the originally proposed
9%-12%. Since the Feb. 26 release of the recommendations, the USPS has received
more than 1,000 pieces of correspondence regarding the PRC’s recommendations.
The tentative implementation date for the pending rate case
is May 6. If the board approves the PRC’s recommendations next week, that would
allow mailers less than two months before the implementation date. “Three years
ago we tried to do this without success,” McLean says. Although time is of the
essence, McLean hopes the letter sets the stage for future consideration.
“There are so many new faces in the Postal Service who don’t understand how we
work,” he adds. As for the chances of the request, McLean says: “I’m not sure
because we have so many new board members probably unaware of the needs of
mailers to prepare for a rate case.”
Historically, McLean says, the BOG usually accepts the PRC’s
recommendations. “In many rate cases, they’ve taken exception with small
matters, only occasionally making exceptions to big issues,” he says. “The
letter is trying to educate these new governors on what we consider a pressing
issue. Give us a standardized period of time, a minimum number of days. Right
now it varies from case to case. We never know how much time.”
