Two Important USPS Filings: Marketing Mail Pass-through Calculations and Non-Profit Rates


The USPS has filed two important filings with the Postal Regulatory Commission, PRC.


“For many years, since at least the beginning of the PAEA regime (e.g., the FY 2007 Annual Compliance Report), the Postal Service has calculated the USPS Marketing Mail (formerly Standard Mail) dropship passthroughs for flats and parcels rate categories only with reference to the per-pound price element above the piece-pound breakpoint. The per-piece price element below the breakpoint has not been considered. For greater accuracy, the Postal Service now proposes to include the perpiece price element below the breakpoint in the calculation.”


“Under the PAEA, the Postal Service has been applying Section 1(d) of Public Law 106-384 (the “60 percent rule,” governing the ratio of average revenue per piece between Nonprofit and Commercial mail) at the class level, i.e., to USPS Marketing Mail (formerly Standard Mail) overall. The Postal Service now proposes to return to its prePAEA convention of applying the rule at the former Domestic Mail Classification Schedule “subclass” level, i.e., to USPS Marketing Mail Regular and USPS Marketing Mail Enhanced Carrier Route (ECR) separately. Such an approach is consistent with the language of the statute, and will help alleviate an ongoing problem: a failure to reach 60 percent in the Nonprofit-to-Commercial average revenue per piece ratio, at the subclass level, due to a different mail mix between Nonprofit and Commercial. The focus of the instant filing is on the effects of this different mail mix, but changes in the mail mix can also have an effect on relative Nonprofit and Commercial prices. That issue is briefly addressed in an appendix. It has also been taken up in an interesting and thought-provoking way by the American Catalog Mailers Association in the past two Annual Compliance Reviews.”