March 1st was the deadline for all comments in response to the Postal Regulatory Commission’s request for reaction to its proposed changes to the mandated 10-year review of the consumer price index-capped system of postal ratemaking.

To briefly review, here’s how the PRC proposal would impact mailers’ postage rates upon approval and implementation:

  • USPS gains an additional 2 percentage points of pricing authority above the CPI for next five years after which the PRC will evaluate its financial health, and possibly extending the additional rate authority for another 5 years.
  • USPS may gain as much as an additional 1 percentage point of pricing authority if service and operational targets are met.
  • Postal products that are not covering attributable costs (eg: “underwater”) must have price increases at least 2 percentage points more than the average for their class. (ACMA note: This will lead to greater increases for Standard Flats.)
  • All told, this amounts to a cumulative ±​40% increase over the first five years (28% for carrier route) and upwards of 56% over the next decade (42% for carrier route).

The ACMA was aggressively involved in suggesting changes and improvements to the PRC proposal and in picking apart the assorted flaws with it. Below is are links to all our comments:

  • Filed our own comments offering myriad of ideas to improve the PRC proposal.
  • Jointly filed comments with more than 50 industry groups and companies brought together as the “American Mail Alliance,” a broad consortium of various mailing industry interests, all with the common goal of removing the mandated above-CPI increases from the PRC proposal.
  • Jointly filed comments with the Parcel Shippers Association (with supplementary data) to examine the impact of supplemental surcharges proposed for Marketing Mail Flats and Marketing Mail Parcels, the proposed USPS performance incentive, and to highlight the importance of the PRC explaining how it would accommodate changes in postal law made by Congress.
  • Jointly filed comments with the Alliance of Nonprofit Mailers, the Association for Postal Commerce (PostCom), Idealliance, and MPA-The Association of Magazine Media, crafted by law firm Venable, to address legal problems of the PRC Proposal and other issues including “underwater” products and classes.
  • ACMA members LSC CommunicationsQuad/Graphics, and The Bradford Group & Hammacher Schlemmer all filed their own comments.

We suggest you to review all these comments; ACMA is available to answer any questions that arise. Next up is the March 30th deadline, at which time the ACMA and others will be submitting reply comments. A decision is not expected until later in 2018.

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