Coronavirus issues affecting publications

Recap: I'm summarizing questions to the NNA Postal Hotline of interest to members.
The identity of the questioner and location is withheld.

Q:  I have a question about our periodical permit. All of our advertisers have pulled their ads until at least the first of May. We cannot make it as a small newspaper without these major advertisers. If we take a short recess from publishing for about 3-4 weeks, will we lose our permit? What do we need to do in order to do this? This is crucial for us to stay in business.

A: USPS has advised NNA that periodicals permits will not be revoked if a newspaper must suspend a print issue during coronavirus quarantines.
Technically, a change in publication frequency requires a change in the permit. But during this emergency, USPS says a letter to the postmaster of the entry office advising USPS of the newspaper's revised publication plans will be sufficient. The letter should be updated as plans change.
Questions from members may be directed to the NNA Washington Office here: tonda@nna.org (as sent to members in emailed news release March 16).
Note from Max: This same logic would apply to a temporary change in publication day the issue appears. However, if a newspaper decided to permanently change publication day or frequency, a PS Form 3510 Form, Application for Reentry, should be filed. Current fee is $85. You can find it via Google search; 2014 is the latest version.

Q: My requester newspapers are not able to produce 24 pages as required due to business conditions caused by coronavirus. What do we do?

A: For newspapers publishing under a requester permit, relief from the required 24-page minimum is available during the national emergency. Publishers seeking this waiver should send a letter (by email, if possible) to the office where mail is entered — a postmaster or a business mail entry manager. The letter should state that the newspaper is unable during this period to comply with the 24-page requirement.  If there is any question from USPS, please contact Tonda Rush for help at tonda@nna.org.

Q: NNA members are asking whether we anticipate a shutdown of mail services.

A: USPS has assured us it has seen only minor disruptions to its network so far. It has imposed some restrictions on international mail. At this point, it has advised mailers that the mail is an essential service. (NNA news release 3-18)

Q: Is there anything in the DMM stating periodical subscription prices can’t go below 50% of newsstand prices, or something like that?

A: There is no linkage in rules between single-copy pricing and subscriptions. The only rule existing specifies that the subscription price charged cannot be below a nominal rate. But that is defined only as any amount that is 30% or more of the basic price per term. Domestic Mail Manual 207.6.1.2f states the rule in reverse:
DMM 207.6.1.2f. At least 50% of a publication‘s distribution must be to persons who have paid above a nominal price. (For inclusion of electronic copies, see 6.5.) Nominal price subscriptions include those sold at a price so low that it cannot be considered a material consideration; or at a reduction to the subscriber (under a premium offer or any other arrangement) of more than 70% of the basic annual subscription price. The value of a premium is its actual cost to the publisher, its recognized retail value, or its represented value, whichever is highest.

Q: Late delivery issues appear not to have occurred with the local post offices; rather they send our papers from our main post office to a larger processing plant in another state and then back to our local post offices. What do you suggest?

A: Mail that is DDU-entered and sorted into carrier-route bundles should NOT be sent upstream to a postal processing plant for handling. The whole idea behind discounts for entry at the office of delivery is to provide work-share discounts for publishers who prepare such mail and take it to each delivery office. You can and should enter in un-sacked bundles, no sacks or trays, per reg NNA got changed in DMM 207.23.4.2, as excerpted below:
Sacking or traying is not required for carrier route bundles entered at a DDU when the mailer unloads bundles under 29.6.5. Mail presented under this exception is not subject to the container charge (but is subject to the bundle charge). Mailers must prepare un-sacked, un-trayed bundles as follows:
a. The maximum weight for one bundle is 40 pounds; the maximum number of bundles per carrier route is one bundle for each 10 pounds (or increment) of mail for that route.

Max Heath, NNA postal committee member, is a postal consultant for Landmark Community Newspapers and NNA members. He can be reached by email at maxheath@lcni.com.