Texas Press Association

In December 2009, USPS Mailing Standards published a proposed rule in the Federal Register regarding deflection standards and proposed postage increases for flats that failed to meet these standards. In short, this proposal would have taken all basic carrier route rates away from most newspapers.

A period of time was allowed for comments, with TPA and NNA submitting comments on behalf of their members articulating the unfairness and negative impact of the proposed changes. Several members also submitted comments. These comments appear to have had some effect in that the postal service revised the proposed rule to lessen the negative consequences to most newspapers.

Earlier this month the final rule was published. The deflection standards will become effective June 7 and postage consequences (rate increases) will become effective Oct. 3. The final decision states that DDU entered, carrier route flats would be exempt from the deflection standards, and not be subject to higher postage rates, but all nonDDU entered flats would have to meet the deflection standards or be subject to higher postage costs. Both In-County and Outside County nonDDU carrier route pieces not meeting the deflection standards would be charged the 5-digit rate, and machinable barcoded or automation flats not meeting the deflection standards would be charged nonmachinable or nonautomation rates. Virtually every member’s postage costs are going to go up. Every newspaper will be affected differently based on DDU entry, in-county, outside county, automation and other factors. Some members may only see a couple percent increase, others could see their postage cost go up significantly. A separate postage increase article is included to help you estimate your postage increase.

The entirety of this final rule as well as the background, summary of comments, responses to comments, deflection standards, and summary of changes is available at: http://pe.usps.com/FederalRegisterNotices.asp All members are strongly encouraged to review this ruling as virtually every member newspaper will be subject to higher postage costs on October 3, 2010.

This revised ruling is considered at least a partial victory for member newspapers. However the postal service stated they may reevaluate this decision to exempt DDU entered Carrier Route pieces in the future and strongly encourages customers to work toward meeting the deflection standards. To control inevitable future postage increases TPA also strongly encourages members to work toward meeting the deflection standards.

How to Avoid Upcoming Postage Increases

By Joel Allis, TPA Postal Consultant

The vast majority of Texas Press Association member newspapers will be affected by the final rule relating to the deflection standards and piece price increases released earlier this month. This final rule and related information is available at http://pe.usps.com/FederalRegisterNotices.asp.

As information, DDU-entered Basic, High Density and Saturation pieces are currently exempt from the deflection test and postage increases.

But your postage costs are going to increase. In-County non-DDU Basic Carrier Route pieces will go up almost 80 percent. The loss of Outside County machinable piece rates will cost you from 5 percent to more than 30 percent more than you are paying now. Consider taking the following steps before June 7, the effective date of the standards, and Oct. 3, the effective date of the postage increases.

-- Check your postage statement to ensure you are properly claiming eligible DDU copies.

-- Consider adding additional DDU or Exceptional Dispatch entry locations.

-- Make sure you are claiming every DDU entered Carrier Route piece you are entitled to claim.

-- Investing in approved presort software may provide valuable assistance.

-- Maximize the use of firm bundling.

Communicate with and work with your printer and your peers to discuss ways to enable your newspapers to become compliant with the deflection standards. This would include considering changes in paper characteristics, adding stiffeners or quarterfolding. Success stories from Texas Press Association and National Newspaper Association members and any additional information will be shared as they are made available.

In the comments released with the final rule, the Postal Service stated the decision to exempt DDU-entered Carrier Route pieces may be reevaluated in the future ... and strongly encouraged customers to work toward meeting the deflection standards.

This means even more postage increases may lie ahead for flats not meeting the deflection standards. Flat-size pieces that do not meet deflection standards are not currently eligible for any automation flat prices, including full-service Intelligent Mail prices. The importance of taking this issue seriously and working to meet the deflection standards cannot be overemphasized.

How to estimate your postage increase if your newspaper fails deflection test

Your newspaper will be subjected to the new deflection standards on June 7 and if your paper does not meet these standards higher piece price postage rates will be charged beginning Oct. 3. You can avoid postage increases by meeting the new deflection standards. The following information will help you estimate how much your postage will increase with failed deflection. You will need a copy of a representative postage statement to calculate the estimated postage increase.

In-County: Multiply number of non DDU basic carrier route copies times 4.6 cents if not barcoded, 4.0 cents if barcoded.
Automation Flats; Basic, 3-Digit and 5-Digit, will go to Nonautomation. Increases by line number are as follows:
Line A6 goes up 1.6 cents
Line A9 goes up 1.2 cents
Line A12 goes up 0.6 cents

Outside County: Multiply number of Non DDU Basic Carrier Route copies times 10.8 cents if not barcoded, 9.8 cents if barcoded.
Machinable flats will go to Nonmachinable flats. Increases by line number are as follows:
Line C1 goes up 15.8 cents
Line C2 goes up 17.1 cents
Line C3 goes up 9.0 cents
Line C4 goes up 9.1 cents
Line C5 goes up 4.5 cents
Line C6 goes up 3.4 cents
Line C7 goes up 2.4 cents
Line C8 goes up 1.5 cents

Totaling the above line increases will give you an estimate of your postage increases for each beginning Oct. 3. As you can see from the above information some of the postage increases are significant. In-County non-DDU Basic Carrier Route pieces will go up almost 80 percent. The loss of Outside County machinable piece rates will cost you from 5 percent to more than 30 percent.

Please contact your TPA Periodicals Consultants with your questions and concerns.

The U.S. Postal Service recently concluded that a business case exists to support consolidating the Dallas Processing and Distribution Center’s outgoing mail operation into the North Texas Processing and Distribution Center.

In a letter dated Feb. 24, Robert J. Batta, deputy assistant inspector general for mission operations, wrote,  "Opportunities exist to consolidate mail processing operations where plants are in a close proximity to one another. As a result of this consolidation, the Postal Service could save more than $11.9 million annually for a total economic impact of more than $114 million over a 10-year period."

Batta also wrote that inspectors found:

1. Adequate capacity exists at the North Texas P&DC to process the increase in mail volume.
2. Customer service should generally improve.
3. Limited number of employees would be impacted.
4. Efficiency should improve.
5. Prior consolidation of the Dallas P&DC’s Saturday outgoing mail into the North
6. Texas P&DC produced favorable results.

By JOEL ALLIS, Texas Press Postal Consultant

USPS Mailing Standards submitted a new proposal in which all classes of mail would be charged higher rates if they fail the new deflection standards (droop test).  

The proposal is that Basic Carrier Route copies failing the new droop test standards would be charged the significantly higher 5-Digit rate.  Machinable or Automation rates would be taken away on other sortation levels.  This would apply to both in-county and outside-county copies.

The proposal appeared in the Federal Register on December 14.  Changes, if accepted, would become effective June 7, 2010.  These new standards are being put in place in advance of the USPS implementation of the Flat Sequencing System.
If this proposal is accepted as currently written it would mean higher postage costs for virtually every member newspaper as the vast majority of newspapers will not pass the droop test, and there is no easy fix to allow newspapers to pass this test.  

The results of the test would depend on paper weight, trim size, inserts and other factors, and could vary issue to issue. The implementation of this proposal could affect delivery standards as well.

Please take the time to find and read the DMM Advisories dated Dec. 2 and Dec. 14, and the Federal Register proposal relating to this topic.  These references will describe the deflection standards and the proposed rate adjustments for mailpieces failing this test.  

The Dec. 14 DMM Advisory solicits comments and provides information on submitting comments, which are due by January 13, 2010. These recommended references are available online through Postal Explorer at http://pe.usps.com/dmmAdvisory.asp.

The National Newspaper Association is aware of this proposal and its negative consequences for newspapers.  It is working to overturn or modify this proposal.

The TPA Periodicals Consultant team will be available at the TPA Trade Show in Galveston to perform a droop test or show you how to perform one on your publication.  We will also be available to further discuss this issue and provide any updated information relating to this important topic.

Congress completed work last weekend on appropriations for a number of federal agencies, including the U.S. Postal Service.  H.R. 3288 — the Consolidated Appropriations Act, carries forward the language requiring 6-day mail service.

This mandate probably eliminates all chance of an end to Saturday delivery in calendar year 2010, said Tonda Rush, lobbyist for the National Newspaper Association in Washington D.C.

"Though Congress could overrule itself with a new bill, nothing we hear on the Hill indicates the postal oversight committees are ready to take that step. But it will arise anew this summer as the 2011 appropriations bills come up," Rush said.

By Harley Hitchcock

The purpose of this article is to ensure your publication is taking advantage of every postage discount to which you are entitled.  In this difficult business climate and with postal rates in general rising every year, it is important you are aware of and taking advantage of every discount available to you.

One discount you may be entitled to is the Limited Circulation Discount.  This discount is applied to outside county postage charges.  To be eligible for this discount the publication must mail some in-county copies and less than 5000 outside county copies per issue.  The DMM reference for this discount is 707.11.1.4.  This discount is often overlooked, even by certain approved software products.  If you think you are entitled to this discount check your postage statement and make sure you are getting the discount.

11.1.4 Limited Circulation Discount

Publications, excluding Nonprofit, Classroom, and Limited Circulation Science-of-Agriculture publications, receive a 5 percent discount off the total Outside-County postage, excluding the postage for advertising pounds, if eligible copies are mailed at In-County prices and the total number of Outside-County copies mailed for that issue is less than 5,000. Nonsubscriber or nonrequester copies claiming the Limited Circulation discount are subject to the standards in 7.0.

Barcoded piece rate discounts average from one to three cents per piece.  If your mailings meet the requirements (DMM 707.14.0) for this rate check your postage statement and make sure you are getting the discount.  If you are paying for vendor software you should have the capability of meeting the requirements for this rate.  If you have questions relating to this please contact your vendor.  If you are not currently using approved software, the potential to claim the barcoded rate could offset some of the costs of obtaining approved software.

Destination Delivery Unit discounts apply to both in-county and outside county, as well as both pound and piece rates.  If your mail is deposited at a facility which will deliver a portion of your mail, this discount would apply to those pieces.  The DMM reference is 707.29.5.
29.5 Destination Delivery Unit
29.5.1 Definition

For this standard, the destination delivery unit (DDU) is the facility where the carrier cases mail for delivery to the addresses on the pieces in the mailing.
29.5.2 Price Eligibility

Determine price eligibility as follows:

a. Piece Prices. In-County pieces are eligible for a per piece discount off the addressed piece price.

b. Pound Prices. Carrier route pieces (In-County and Outside-County) are eligible for DDU pound prices when deposited at the facility where the carrier serving the delivery address on the mail is located.

c. Container Prices. Outside-County mailers may claim a DDU container price for 5-digit scheme and more finely presorted containers that are entered at and destined within the service area of the DDU at which the container is deposited.

Carrier Route High Density is another often overlooked discount.  The majority of member publications claim a certain number of carrier route copies, but some of these copies may be eligible for the lower high density rate. The current price difference is 1.5 cents per piece.  The requirement for the high density rate is either 125 pieces per carrier route, or 25 percent of total active possible deliveries for that route.  The DMM reference is 707.13.3.4.b and c.  Not all approved software automatically gives you this lower rate.  If you think you are entitled to this discount check your postage statement and make sure you are getting the discount.  If you are using approved software and are not getting this discount please contact your vendor.

b. Except under 13.3.4c, at least 125 walk-sequenced addressed pieces must be prepared for each carrier route receiving mail claimed at the high density price. Mail for carrier routes of 124 or fewer possible deliveries can qualify for the high density price if there are at least 125 addressed pieces for the route or if pieces are addressed to every possible delivery on the route. This mail may also qualify for the saturation price, subject to 13.3.4e. In-County price pieces may also qualify for high density prices under 13.3.4c.

c. Mail may qualify for In-County high density prices when there are addressed pieces for a minimum of 25 percent of the total active possible deliveries on a carrier route. If a route contains addresses both within and outside the county, the number of pieces addressed to the entire carrier route will be used to determine if percent requirement, only the pieces for that carrier route that are addressed to addresses within the county in which the original entry is located may qualify for the In-County high density prices.

As always, if you have questions please contact your TPA Periodicals Consultants.

Postmaster General and U.S. Postal Service CEO John E. Potter, in the letter below, delivers this good news: No Periodicals Class rate increases are planned for 2010. But there is no mention of the idea of reducing service to five-day delivery to save money, a concept Potter (pictured at right) has advocated. Saturday delivery is safe through the end of this month (October 2009) and news on that should come soon.

From: John E. Potter
To: Postal Service Customers

Many of you have expressed concerns regarding mailing costs for 2010.  The tough economic climate has presented significant challenges to all of us and pessimistic speculation has suggested that postal prices could increase by as much as 10 percent. As we begin a new fiscal year and as many of you, our business clients, are preparing your 2010 operating budgets, we want to end all speculation.

The Postal Service will not increase prices for market dominant products in calendar year 2010.  Simply stated, there will not be a price increase for market dominant products including First-Class Mail, Standard Mail, periodicals, and single-piece Parcel Post.  There will be no exigent price increase for these products.

This is the right decision at the right time for the right reason.  Promoting the value of mail and encouraging its continued use is essential for jobs, the economy, and the future of both the Postal Service and the mailing industry.

The U.S. Senate on Sept. 30 passed an appropriations bill that gives the U.S. Postal Service $4 billion in relief on payments into the health benefits trust fund. It also continued funding of all other federal agencies in a status quo situation until Oct. 31.

This “continuing resolution” has become a practice in federal funding dating back to the 1980s. When Congress cannot get its main homework of appropriating money to operate the federal government by the beginning of the Oct. 1 fiscal year, it passes a series of continuing resolutions that maintains funding at current levels until a date certain.

The mandate for six-day mail remains. It will come up again before Oct. 31, if and when Congress decides to address appropriations for the Postal Service for the fiscal year that began Oct. 1. The $4 billion rider, however, is good for the fiscal year.

Go to your post office and get a handful of "Consumer Service Cards" (PS Form 4314C) and complete a card when you have a problem.

This becomes part of an official file that will ultimately determine if the customers are satisfied with service (delivery, lack of brown sacks or not being helpful would be excellent reasons to complete a Consumer Serive Card).

This will give you and postal managment an audit trail to identify problem areas.

Send them to your customers when they complain about mail delivery or torn and wet newspapers.

If you wish to telephone a complaint, a postal employee will fill out the card for you.

The Consumer Advocate represents consumers at the top management level in the Postal Service. If your postal problemss cannot be solved by your local post office, then write to the Consumer Advocate. His staff stand ready to serve you: The Consumer Advocate, US Postal Service, Washington, D.C. 20260-6320 or phone 1-202-268-2284.

The postal reviews I have conducted at more than 300 Texas newspapers have really been a great experience for me. I cannot express how great it is to receive the friendly and sincere welcome I received at each newspaper.

However, I did not receive this welcome when I was auditing the U.S. Postal Service, a very pleasant change. I have reviewed about three-fourths of the newspapers in Texas during the past year and a half.

Texas is a very large state and requires many hours (days) to travel and visit each paper so I would like to schedule visits with newspapers based on need for those facing problems with the USPS.

To qualify for a visit, I will need the following information from your newspaper:

1 A copy of your postal report (completed report, returned from the post office).

2 A copy of your PS Form 3553, the CASS certification, if mailing carrier route copies.

3 The actual sack labels you place on each sack. This may require generating an extra set of labels.

4 The required postal documentation that you submit with each mailing. (Postage statements must be supported by documentation produced by PAVE-certified software or standardized documentation under P012 of the Domestic Mail Manual).

Q: I hate shrink-wrap for inserting the newspaper (more for the landfill), but we receive better delivery and fewer claims for ripped and tom issues. Are there any alternatives?

A: Shrink-wrap is one option for a wrapper. For other options, the Domestic Mail Manual, (DMM) C200. 1.7, states, "A mail ing wrapper is an envelope, sleeve, partial wrapper or Polywrap used to enclose the mail piece. Advertising, non-advertising or both may be printed on the cover or protective cover. The cover and protective cover on a publication

are included when measuring advertising percentage." Section C200.3.3 and 3.4 covers "Without Mailing Wrapper" and "With Mailing Wrapper" requirements, respectively.

Under the subject of "Paper Bags and Wraps," the DMJvI refers to section C010.3.3 "For easy loads up to 5 pounds, paper bags and wraps are acceptable when at least a 50-pound basis weight (the strength of an average large grocery bag) and the items are immune from impact or pressure damage. A combination of plies adding up to or exceeding 50- pound basis weight is not accept able. Easy and average loads of up to 20 pounds, reinforced bag or bags with a minimum of 70-pound basis weight are acceptable. Nonreinforced loose-fill padded bags are not acceptable as exterior containers, unless the exterior ply is a least 60-pound basis weight.

Q: Regarding address changes for the emergency service operations (911), we have trouble getting new address information on the returned piece of mail. Instead we just get a "no such street," or "no such number" returned mail piece. Can you post this information on the web as a PDF file or in a database?

A: This has been a continuing issue for many rural areas. Some areas are still undergoing conversion to the new 911 emergency addresses.

Many people were slow to change to the new addresses, because they had been using the old address for years. Forwarding for letter mail is good for a year, then for an additional six months the letter is returned to sender with the forwarding address on the return piece. After 18 months, the letter would be sent back with a reason for non-delivery such as "no such number."

There are two options for obtaining these EMS or 911 addresses.

They cannot be posted on the Internet due to privacy issues. However, the Postal Service does have a service called Locatable Address Conversion System (LACS) that is sold by the U.S. Post Office to National Change of Address (NCOA) licensed vendors NCOA keeps its address information for up to three years.

Check with your local Mailpiece Design Analyst for more information on LACS and a list of licensed NCOA vendors.

It pays to shop around with the various vendors. There is a mini mum start up fee for each vendor, and then the cost usually runs around $2 to $7 per thousand names processed.

A list of NCOA vendors is available on the Internet at the postal web site usps.gov.

NCOA also tells you who has moved and CASS certifies your mailing list.

More and more NCOA vendors are allowing you to e-mail your database to them for processing.

The other option is for a mailer to submit sequence cards to the local post office in rural areas.

Section A920.5.5.a of the Domestic Mail Manual states "If the customer includes a rural address (box number) in a deck of cards submitted for sequencing, and a street address is assigned to that box number so it can be served on a city delivery route, a correct address card is included at no charge."

See Section A920, "Address Sequencing Services" for more details on the various options for card preparation and submission.

In our day to day business we normally have checks and balances to ensure that we do not make mistakes.

As an example we can randomly count our mailing labels and compare the number of labels against the postal statement (they should be the same) to determine if the software is working correctly. If you have approved software, you should review the qualification report on a random basis to check the 5-digit, 3-digit and carrier route copies claimed vs. number authorized.

I have reviewed hundreds of postage statements over the past year and have discovered that many publishers do not have any checks and balances in place for postage statements. This is costing you thousands of dollars in revenue that could have initially been prevented with a simple check and balance.

I also have reviewed some of the Statements of Ownership, Management and Circulation published in October and was concerned that no checks and balances are in place.

As an example, Line 7, on the Form 3526 requires the known office of publication to be completed (a physical address [optional unless no letter carrier service], street, city, county, state, and ZIP+4). Many publishers are incorrectly reporting this information by using a PO Box (instead of street address) and the wrong city!

Does the city and address agree with the ID statement and your known office of publication? Again, no checks and balances are in place and this simple mistake could cause you untold grief, depending on the actual facts.

The known office of publication is “The location where the original entry for Periodicals mailing privileges is authorized and the known office of publication must be a public office for transacting the business of the publication during normal business hours. It also must be the office where the publication’s circulation records are kept or can be available for the USPS examination.”

The known office of publication cannot be a PO Box. You are not authorized to do business from a PO box.

An additional downside to this situation is that In-County rates apply to subscriber copies only when they are entered within the county in which the post office of original entry is located for delivery to addresses within that county. So, if you are considering consolidation of newspapers to a central location, remember the requirements to be eligible for In-County rates and the checks and balances.

The ultimate nightmare would be that you are mailing at an office without official authorization (RE-ENTRY approval). This may require repayment at the Standard or First-Class mail rate.

Q: What are the guidelines for determining the advertising percentage in my newspaper that I report to the Postal Service?

A: First, “if you receive something of value or someone pays to place an ad, it is considered advertising."

You receive something of value when a columnist writes articles for your paper so it would be considered advertising when you run their ad in exchange for the article.

If an air conditioning contractor took care of the maintenance of your newspaper for an exchange of running their business ad in your paper, it would also be considered advertising.” Anything of value offered in exchange for an ad would be considered advertising. This is commonly referred to as "quid pro quo", or something for something.

Next, if you run a house ad for subscriptions to your paper giving various options (prices, time, etc.), this would not be considered advertising.

The subscription ad must state only subscription information the subscriber would need to subscribe.

If the subscription ad mentioned advertising rates, phone numbers for contacting other services of the publication, it would be considered advertising.

Advertising

The Domestic Mail Manual (DMM) part E211.110, states:

Advertising is restricted or prohibited by E212 for the categories of Periodicals authorization. For these standards, the term advertising includes:

a. All material for the publication of which a valuable consideration is paid, accepted, or promised, that calls attention to something to get people to buy it, sell it, seek it, or support it.

b. Reading matters or other material for the publication of which an advertising rate is charged.

c. Articles, items, and notices in the form of reading matter inserted by custom or understanding that textual matter is to be inserted for the advertiser or the advertiser's products in the publication in which a display advertisement appears.

d. A newspaper's or periodical's advertisement of its own services or issues, or any other business of the publisher, whether in display advertising or reading matter.

Public Service Announcement

Part E211.2 of the DMM states, “The Term public service announcement means any announcement for which no valuable consideration is received by the publisher, which does not include any matter related to the business interests of the publisher, and which promotes programs, activities, or services of federal, state, or local governments or of nonprofit organizations, or matters generally regarded as in the public interest. A public service (PSA's) is not treated as advertising.”

Advertising Standards

Part E212.1.3 of the DMM states in part; “Advertising is defined in E211. General publications primarily designed for advertising purposes do not qualify for Periodicals mailing privileges, including publications that:

a. Contain more that 75% advertising in more that half of the issues published during any 12-month period.

b. Are owned or controlled by individuals or business concerns and conducted as an auxiliary to and essentially for the advancement of any other business or calling of those who own or control the publications…”

Clarifications

a. Text, which is used to promote a product, called “advertorial,” must be marked and counted as advertising.

b. Strictly subscription related material and public service announcements (provided free of charge) do not count as advertising but are charged for the weight.

c. Blank sheets are not eligible for periodical rates. If you require extra sheets to balance your publications, simply put a page number on it. They are counted as neither advertising nor non-advertising. However, blank pages cannot be used to complete the 24-page rule (for requestor pubs).

d. In the new rate case, the USPS has asked that the Ride-Along becomes a permanent feature and that it increases to 12.4 cents. Once it is permanent, a questionnaire will not be required.

Generally speaking the term, “quid pro quo” if you receive something of value for the advertising, in exchange for something, It will be counted as advertising.

Over the past few years I have received many questions concerning how to mail or how to get the postmaster off my back.

Problems

First, if you are having a postal problem you should know exactly why. Please ask the postal official to state the concern in writing, stating the facts and giving you an opportunity to correct the problem in a reasonable amount of time. More often than not this (statement in writing) corrects the concern; one or both parties realize the issue can be resolved without intervention from outsiders.

10% Rules for Samplings

Sampling

Next, the reoccurring most popular question over the years has been “I want to do a sample mailing; what do I need to do?” You must keep records of your mailings during a calendar year in order to correctly determine how many nonsubcribers have been mailed in county and outside county! Yes, there are multiple rules concerning mailings of nonsubscriber copies, and most sample mailings are nonsubscriber mailings.

Simplified Address

Nonsubscriber copies may be mailed to boxholders with each copy addressed in the simplified address format if mailed to each boxholder on a rural route or highway contract route, or to each boxholder at post offices that do not have city carrier service.

If simplified address mailing results in a subscriber or requester receiving a copy in addition to his or her subscriber copy, the additional copy is considered a nonsubscriber copy.

Sample Copies

Sample copies are nonsubscriber copies.

Out of County and In County rates

For publications authorized both outside county and in county rates, once the total number of nonsubscriber copies mailed during the calendar year (regardless of rate) exceeds 10 percent of the total number of copies mailed to subscribers during the calendar year, further mailings of nonsubscriber copies are not eligible for any preferred rate (in-county).

Nonsubscriber copies over the 10 percent allowance must be part of a presorted commingled mailing (i.e., including subscriber copies) to qualify for outside-county rates.

Copies Over 10% Allowance

Nonsubscriber copies, over 10 percent of the total number of copies mailed to subscribers during the calendar year, are eligible for outside-county rates when they are commingled and presorted with subscriber copies.

Excess Noncommingled Mailing

A mailing is not eligible for periodicals rates if it consists entirely of nonsubscriber copies over the 10 percent limit of the total number of copies mailed to subscribers during the calendar year. These copies are subject to the appropriate express mail, first-class mail, standard mail, or package services rate.

Mixed Mailing

If all copies in a mailing are to nonsubscribers, and some copies are within the 10 percent limit while the rest are over the 10 percent limit, the portion exceeding the 10 percent limit is not eligible for periodicals rates. That portion is subject to the appropriate express mail, first-class mail, standard mail, or package services rate.

Exceptional Address

The exceptional address for (i.e., “Jane Doe or Current Resident” or Jane Doe or Current Occupant”) may be used on any mail except mail types listed in 3.2. The word “Current” is optional. The order of the words may be reversed (e.g., “Current Resident or Jane Doe” rather than “Jane Doe or current Resident”).

Prohibited Use

The occupant address format is prohibited on mail addressed to an overseas post office and on periodicals publications intended to count as subscriber copies to meet the applicable circulation standards.

Use-City Routes, P.O. Boxholders

When distribution is to be made to each stop or possible delivery on city carrier routes, to each post office boxholder at a post office with city carrier routes or to each post office box holder at a post office with city carrier service, the addressee’s name, street address or post office box number, city, state, and ZIP Code must be on the mail piece.

Only these forms of address may be used instead of the addressee’s name and address:

1. Postal Customer (delivery desired at all addresses).
2. “Residential Customer” (Delivery desired at residential addresses only.)
3. “Business Customer” (delivery desired at business addressees only).

The 10 percent rule for mailing at in-county rates during the calendar year. Publishers can easily identify non-subscriber copies on their postage statement. There also is more than one 10 percent rule and this may or may not come into play depending upon the number of comp copies that are mailed outside county.

Step 1: Count the number of subscriber copies mailed in-county during the past year and take 10 percent of that figure — that equals the number of copies (non-subscriber) that can be mailed at the in-county postal rates during the calendar year.

A newspaper may exceed the 50 percent circulation rule more than once during a calendar year. The Postal Service allows you to mail more non-subscriber copies than paid if they are within the 10 percent limit for a calendar year.

Step 2: Count the number of subscriber copies mailed outside county and the number of subscriber copies mailed in-county and take 10 percent of the total subscribers (in-county + outside county). This would be an overall 10 percent limit.

Once a newspaper meets the in-county 10 percent limit or the overall 10 percent limit, whichever comes first, the newspaper is not eligible to mail any additional nonsubscriber copies at the in-county rates.

Caution

A mailing is not eligible for periodicals rates if it consists entirely of nonsubscriber copies over the 10 percent limit.

These copies are subject to the appropriate other rate. Therefore, you must track the number of copies mailed to subscribers and nonsubscriber before mailing all copies as nonsubscriber.

If the numbers (exceeding 10 percent) look close and you do not have time to check records of prior mailings, you should include at least two subscriber copies. The two subscriber copies must have a name and address and be claimed on the postage statement as subscriber copies.

Q:The postmaster just called me and said we will owe back postage for mailing our newspapers incorrectly.

We publish several newspapers using the same content throughout except that we change the front page and masthead for each community. So each of our papers is different and unique to the community it serves.

We are paying the postage so why should the post office care if the content is basically the same for each publication?

A: I examined concurrent issues of two of your newspapers and discovered that they are identical except for the front page and identification statements. It appears you are publishing the same newspaper under two titles even though you have a separate periodicals authorization for each title.

Periodical mailing privileges may only be authorized for one newspaper. The Postal Service recognizes that newspapers often change out page one during a press run to include breaking news, but that does not change the identity of the periodical.

Under your current method of preparation there is in fact only one newspaper so you would not be authorized to change the flag and mail at in-county rates under additional periodical permit numbers.

Q: So I would be forced to mail the same newspaper flag to all communities? I would lose subscribers and I’d have to mail at out-of-county rates.

A: If you can prepare the newspapers in such a manner that you can demonstrate by customary journalistic standards that the newspapers are different, each newspaper can be considered independent for postal purposes.

This means that if the nonadvertising portion in one newspaper differs by at least 20 percent from the nonadvertising portion in the other newspaper, they will be considered as being separate and independent newspapers.

This percentage is an interpretative aid to help the Postal Service make this determination on a consistent and fair basis.

Q: So how can I determine if I meet the 20 percent rule?

A: Try this method to determine whether the non-advertising portions of two publications differ by at least 20 percent:

1) Measure the non-advertising content of each publication.

2) Compare the non-advertising matter in the publications and, in the publication with the greater number of column inches of non-advertising matter, (publication “A”) mark all such matter that is different from the non-advertising contents of the other publication (Publication “B”).

3) Measure the number of column inches of non-advertising matter in publication “A” that was marked as different.

4) Divide the figure from (3) by the total number of column inches of non-advertising matter in publication “A”.

5) Multiply the result by 100 to express the answer as a percentage.

Regardless of preparation or characteristics, or otherwise meeting the standards stated above, the materials described below are not eligible for the Periodical rates.

• A separate price or subscription instructions different from those of the host publication.

• The word “catalog.”

• A First-Class Mail, Standard Mail, or Package Service permit imprint.

• An ISBN (International Standard Book Number).

• An ISSN (International Standard Serial Number) or USPS number different from that of the host publication.

• Products that may not be mailed at Periodicals rates.

• Examples include stationery (such as pads of paper or blank printed forms); cassettes; floppy disks; merchandise; and wall, desk, and blank calendars. Printed pages, including oversized pages and calendars, are not considered products if they are not offered for sale.

• Package Services (parcels) may not be combined with a Periodical publication.

Important postal records that newspapers should have on hand and in a secure place:

• Original Authorization (This was difficult to obtain, protect it.)

• Changes to the original authorization (frequency, title, additional entry and exceptional dispatch offices)

• A copy of the last Statement of Ownership, Management and Circulation (PS Form 3526)

• Any instructions or correspondence from your post office concerning the newspaper delivery or preparation (Remember you want instructions in writing.)

Postal Reports

• Keep a separate folder for each year, in chronological order. If you pay postage at two or more post offices for a newspaper, have a separate folder for each account.

• Keep a folder for documentation/CASS certification (Form 3553) for each postage statement.

Retention

• The publisher must keep records for each issue of a publication for three years from its issue date.

Printed Sheets

Periodical publications must be formed of printed sheets.

Electronic or e-mail subscribers may not be counted as part of paid circulation.

Keep in mind that if your stated frequency is Wednesday you still must publish, change your frequency or enter your mail early (Tuesday) and date it Wednesday.

If your frequency is weekly, and you normally publish on Wednesday, just mail some time during the week.

If you have a frequency of weekly, 52 times a year, and want to have Christmas off, you have several options:

1) Change frequency.

2) Note the word publish. It does not mean you must mail, you could publish a two-page newspaper (front and back sheet), have three copies printed, two for your record and one for the post office, this would meet the requirement of maintaining your established frequency! The two-page publication must meet all the requirements; title, volume number, masthead information (identification statement) and a short memo to the post office stating you are filing your marked copy with them to prove frequency of publishing, and that the issue was not mailed.

3) Write the post office a memo stating that you will not be able to publish at your stated frequency because of staffing problems during the Christmas week. This may cause the post office to send you a letter, stating the requirements of meeting your established frequency. This should not be a habitual way of changing your frequency.

The publisher must keep records for each issue of a publication for three years from its issue date.

Records for any year for which postal verification is done by a USPS-authorized audit bureau are required to keep source records of requests and subscriptions only as long as the audit bureau requires. This is an important part of Periodicals authorization.

Reconstructing a postage statement may be accomplished using your computer database. A paper trail or audit trail (records) is necessary to provide proof that the subscription is genuine and the amount paid is above a nominal rate.

Type of Records:

1. Print orders and invoices showing the total number of copies printed.

2. Individual and bulk orders for subscriptions and nonsubscriber copies.

3. Stubs or copies of receipts issued.

4. Sales records and returns for over-the-counter sales.

5. Cash books, bank deposit receipts, or similar records.

6. Records of copies of the publication destroyed.

Note: The above records are required when applying for a new publication.