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.