Heresy: any belief or theory that is strongly at variance with established beliefs, customs, etc.
(from dictionary.com)

It is time to close your eyes, pinch your nose, and open your mouth (and your mind) because what I am going to propose will taste like a dose of cod-liver oil. You may also want to sit down to keep from fainting. Now with your eyes closed start thinking of all the advantages of putting the USPS in charge of a national Do Not Mail list.
The most current assault by Catalog Choice on the direct mail industry is over EDDM mail. They and other anti-mail zealots hate this postal product's attempt at making it easier to generate more mail. Their current angle of attack is to condemn those companies and schools that refuse to remove individuals from EDDM (saturation) mailing lists. Catalog Choice has provided a petition (http://www.citizensformailchoice.com/) that is to be sent (by email) to the Postmaster General. In the petition it requests that penalties be established for offending organizations. Catalog Choice knows that the arcane and bureaucratic Do Not Mail (DNM) procedures established as part of EDDM, combined with substantial penalties, will significantly reduce mail volume.

Since the USPS inspired this renewed assault on our industry by developing EDDM, I think the USPS should be responsible for cleaning up the mess they created. When it comes to producing unaddressed advertising mail our industry gets all of its information from the Postal Service. They own, manage, update, and distribute the information used to produce and deliver EDDM mail. The Postal Service knows when new homes are added to routes, when route realignments change route numbers for existing addresses and when people move into and out of neighborhoods, regardless whether they file a change of address card (COA) or not.

Our industry's goal should be to have access to as many mailboxes as possible without forcing our advertising on people that do not want it.

The way DNM should work for unaddressed ad mail is that people wishing not to receive advertising would leave a signed form (available from their carrier or on-line) in their mail box for their carrier to take back to the local delivery unit. The local delivery unit manager would put that address on a master Do Not Mail (DNM) list for that delivery unit. They would also reduce the allowed number of addresses for mailing unaddressed advertising to that route by one. The address would stay on the DNM list for two years, when the DNM request would have to be renewed. If the people at that address were to move during those two years, the address would immediately be taken off of the DNM list by the delivery unit manager. Only residents could sign up for the unaddressed advertising mail DNM list; no agent communications (such as from Catalog Choice) would be accepted.

The Postal Service would maintain two delivery stop counts for each route. One route count would total all possible deliveries, as they do today. The other count would be the total deliveries on a route less the number of addresses on the DNM list for that route. Politicians (never to be limited in their ability to provide us with useless information) could continue to mail to everyone on a route. Everyone else would only have access to the addresses not on the DNM list. Carriers would know which addresses were on the list and would be responsible for not delivering any unaddressed advertising to those who had signed up as a DNM delivery stop.
Mail owners would produce printing and pay postage based on the total allowed delivery addresses. Saturation rules would be based not on total delivery stops but on the total number of allowed deliveries. So if there were 500 total deliveries on a route and 25 addresses were on the DNM list, then the number of possible deliveries for that route provided to mail owners would be 475. If the mail owner mailed to 90% (current rule) of the 475 allowed delivery stops, they would then be able to claim all saturation rates as they do now. Therefore mail owners would only purchase enough printed material and pay postage for the number of allowed deliveries (475 in this example). The USPS would not be throwing away our mail and postage for those addresses not wishing to receive unaddressed advertising mail, as some carriers do now.

With this proposed new system, mail owners can never be held responsible for failing to honor Do Not Mail requests for unaddressed advertising mail.

As for addressed mail, the USPS should play a role here also. The way a list for DNM addressed mail would work is that mail recipients would use current change of address (COA) procedures to put their name and address on a national DNM list. Consumers would enter their name and address on COA cards (or on-line) and flag the fact that they do not want to receive advertising mail. As mail owners matched their files to the NCOA database, records with a DNM flag would identify addresses for exclusion from their mailing. This process would be simple, easy to administer and inexpensive for the entire direct mail industry. As people moved, their old address would be removed by the USPS from the DNM list automatically.

Both the DNM list for unaddressed advertising mail and the separate list for addressed ad mail would be an all or nothing listing for consumers. So if a consumer signed up because they didn't want an EDDM coupon from the local dry cleaner, they would also not receive unaddressed coupons from their grocery store. If a consumer went on-line and registered their name and address through the change of address procedures for no addressed advertising mail, they would not get any addressed ad mail. An exception to the NCOA DNM flag would be made for existing customer relationships. All or nothing keeps the process simple for our industry to manage and retains the maximum number of allowable addresses to mail too.

I believe most people would not sign up for DNM under an all or nothing circumstance. Most will accept some unwanted unaddressed advertising to make sure that they get their grocery coupons.

Our industry has been pushing the concept that we must refine our mailing lists and target recipients more accurately. As mail owners push harder and harder to reduce costs by reducing the number of mail pieces printed and distributed, it would seem logical that the first cut in targeting would be to eliminate those that do not want their advertising. It is time for our industry to honor DNM requests.

What is clear is that Catalog Choice and others like them, the FTC, and congress will eventually coalesce around one Do Not Mail legislative solution. The fact is that neither we nor the USPS will be happy with their solution which will do far more than just create a DNM list. We can live with Do Not Mail as outlined above. We will not survive regulations that start out to limit whom we can or cannot mail too, but morph (as legislation does) into limiting our ability to collect and use information about existing and/or potential customers. With the USPS providing a simple and effective Do Not Mail process, it would be less likely that the FTC or congress would step in to fix something that has been resolved by another government agency.

The choice is clear, let Catalog Choice, the FTC, and Congress determine our fate, or chart our own course.

Todd Butler, Butler Mailing Services, eKEY Technologies can be reached at 513.870.5060, toddb@butlermail.com or www.ekeymailer.com.
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