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POSTAL TIPS by Max Heath
Higher rates for basic carrier route newspapers and shoppers are in the works, if a new USPS proposal prevails. The National Newspaper Association is working to turn it back.
The Postal Service, acting in response to complaints from magazines and their printers, postponed a January 2010 implementation of a reduction in the “angle of deflection” allowed to determine if a “flat” is too flimsy. In doing so, its Mailing Standards department wrote a new proposal with higher prices that would be charged for all classes of mail when failing the so-called “droop” test. Lighter weight publications would be most affected.
USPS has decided to propose that Basic carrier-route prices for Periodicals and Standard Mail that failed to meet the new deflection, or “droop” standards, would sharply increase to the 5-digit non-automation rate in both classes. The proposal, put out for public comment in the Federal Register Dec. 14, would be effective June 7, 2010. (The deflection reduction from 4 inches to 3 inches had previously been postponed from May 2009 to January 2010. The allowed “droop” was increased to 4 inches in 2007 from less than 3 inches for the years before that.)
How is the “angle of deflection” determined, you might rightly ask?
HERE’S THE TEST
For pieces longer than 10 inches (which includes most newspapers and shoppers): “Place the piece on a flat surface with the address side facing up and the length perpendicular to the edge of the surface, and extend the pieces 5 inches off the edge of the surface. Turn the piece around 180 degrees and repeat the process.
The piece is mailable at flat prices if it does not droop more than 3 inches vertically at either end.” Got that?
If not, I’m not surprised, because even under the 4-inch droop standard now applicable only to automation-rate mail, newspapers are rarely tested. All this hullabaloo of a second postponement and re-filing will likely bring much more attention to the new rule than the old, throwing up more obstacles to newspapers trying to survive “the great recession.” And the test is subject to misapplication by local post offices with little experience in such testing.
Basic carrier-route price is for six-124 pieces on a route in Periodicals (or 25 percent of Active Possible Deliveries in-county under an NNA-won rule), and 10-124 pieces in Standard Mail, with only Line-Of-Travel sequencing required, which is applied by CASS-certified list processing.
For Periodical Class newspapers that failed the “flimsy” test, the price would increase from 5.9 cents per piece to 10.5 cents. That’s a 78 percent increase from line A13 to line A10 of the 3541 postage statement. A newspaper with 500 copies in that price category would pay nearly $1,200 more a year simply for having lightweight paper or thin issues that do not stand up to the stiffness standards USPS says it now wants.
For Standard Mail shoppers or free newspapers the price would increase from 21 cents per piece to 32.4 cents per piece. That’s a 54.3 percent increase when shifted from line I-12 DDU Carrier-route Flats to Non-Automation Flats at line E9 of a 3602-R for DSCF entry, which covers such mail entered at a DDU or DSCF, since there is no DDU rate in that part of the subclass.
The strange twist to all this is that “flat-size pieces mailed at Saturation or High-density carrier route prices are not required to meet these deflection standards.” So newspapers are faced with this bizarre proposal that would greatly harm newspapers with Basic carrier-route mail at a time when many community dailies have moved from their own motor route carriers to mail to save money.
These new postal customers have helped NNA demonstrate expanding volume in the in-county mail class, for the benefit of all users. The increase, if it stands, may pressure some of these dailies to move back out of the mailstream.
In-county mail volume was up 3.4 percent in total pieces in postal fiscal year 2009 ending Sept. 30, despite a terrible recession. This volume increase, rare among any mail class, came on top of a 12.8 percent volume increase in FY 2008.
Worse yet, newspapers and shoppers forced to pay higher 5-digit prices could simply quit sorting their mail by carrier route and just “throw the mail in the door” for each 5-digit post office where DDU entry is maintained, and let the carriers figure out how to sort it.
While that might be an extreme reaction, which would not be in the best interest of newspaper readers for timely service, newspapers should not be penalized for mail sorted to the carrier route and delivered to the DDU below High-Density and Saturation standards. A penalty like that would reverse nearly 30 years of USPS incentives to make mail more efficient.
Such mail is often presented at offi ces with all or mostly rural routes, where the mail can usually be delivered as a “third bundle” in the carrier’s vehicle. The proposal clarifies that “… pieces may remain sorted as per price originally claimed…” And the “droop test” could show passing one week, failure another.
ADVO and other marriage mailers would surely fail the “droop” test, but are exempt, as are newspaper Saturation and High-Density shoppers. For this reason, the proposal would affect Periodical Class newspapers more than their shoppers, which tend to be at the prices exempt from the deflection standards. But it is simply unfair to put newspapers at a relative disadvantage by pricing flimsy flats higher just because they are eligible only for Basic carrier-route prices.
NNA will file comments before the Jan. 13 deadline, and inform higher management of our concern about this half-baked (or perhaps over-baked) proposal. The filing said the delay “offers mailers the opportunity to make changes to slightly stiffen or redesign their ‘droopy’ flats to meet the new standards.”
I’m not sure how much magazines can do, but newspapers are not in a good position to make changes. While quarter-folded newspapers are much more likely to meet the deflection standards, many printing presses no longer accommodate quarter-folding, and machine insertion of preprinted advertising supplements does not work well in quarter-folds.
NNA’s clear and simple position is that Periodical or Standard Mail carrier-routed flats entered at a DDU should not be subject to this rule. While some could be too flimsy for machine processing, there is no justification for this price penalty. © Max Heath 2010
MAX HEATH, NNA postal chair, is a postal consultant for Publishing Group of America and Landmark Community Newspapers LLC. E-mail
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with questions about this policy.
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