Friday, October 19, 2012

Time for all to comment on Full Service IMb 2014 Mandate


Implementation of Full-Service Intelligent Mail Required for Automation Prices

The Postal Service's proposed rule to modify eligibility requirements for mailers to obtain automation prices for First-Class Mail®, Standard Mail®, Periodicals®, and Bound Printed Matter® when mailing postcards, letters, and flats was published in yesterday’s Federal Register. Effective January 2014, use of “full-service” Intelligent Mail® would be required to obtain automation prices.

The Postal Service is interested in receiving stakeholder feedback, which is due no later than November 16, 2012.  Information on where to provide written comments is contained in the Federal Register notice. 

The Federal Register notice provides advance information to help mailers prepare and plan for the transition to Full-Service (use of unique Intelligent Mail barcodes applied to letters, postcards, flats, trays, sacks, and containers such as pallets and submission of electronic mailing documentation). Initiatives are proposed to limit the impact on customers who enter small volume mailings, particularly customers who mail infrequently and have limited resources to adopt new mailing practices.

To post your comments, send an email to:  mailingstandards@usps.gov
with the subject line: full-service January 2014

In case you are interested, here was my reply:

This line in the sand deadline for conversion to Full Service IMb to receive automation discounts is a very bad idea.  Although I am a business partner with the USPS, this new mandate would cause a huge drop in those participating in work share discounts.  Without these discounts many mailers will simply not mail, or use larger third party providers.  This conversion may improve USPS efficiency but it will lead to the decline of mail by smaller stakeholders.  The last thing the USPS needs is any further decline of mail, especially by rule or mandate.

Besides the fact that this will be a hardship to smaller mailers, the USPS is not even ready for the tens of thousands of current permit holders that would need to convert.  With less than 1000 Full Service users today, if every permit holder was to convert by the 2014 deadline, they would have to do so at a rate of over 200 per day.

The conversion by industry to Full Service should be driven by incentives for business reasons, not by mandate.