March 20 2008 10:36 AM

The following is a perspective by postal commentator Gene Del Polito.

How many of you are old enough to remember the movie Network? Good! My mental telepathy says that a number of hands have been raised. Recall the scene where the actor Peter Finch, in the role of a disgruntled newscaster, urges his audience to open their windows and show their displeasure by yelling out "I'm mad as hell, and I'm not going to take it anymore." Well, after reading the March 6 National News page of the Washington Post, the one with the article entitled "Postal Service Feels Weight Of 'Junk Mail,'" I am mad as hell, and I'm not going to take it anymore.

The article itself provided a succinct summary of the prior day's events which were played out before the Senate postal oversight subcommittee. The purpose of the hearing was to allow the Senate to punch the card to show that an oversight hearing on the Postal Service had been held as required by law. The hearing quickly became focused on one of the more significant challenges the U.S. Postal Service (USPS) now facesthe mindless march of state legislators to enact bills that would impose restrictions on those who choose to use mail for business communication and commerce. Be sure to read this article. It's readily available on the Washington Post's web site. You can find it at http://tiny.cc/2ABtM.

I'll spare you the details of recent efforts by some misguided souls who genuinely believe that unsolicited advertising mail is an environmental pariah and by others who simply are more crassly looking for yet another way to turn a quick buck. This isn't a new issue; it's a recurrent one. It's been an issue that the direct mail industry has allowed to come into repeated play, because it has lacked an appreciation of the ongoing nature of this challenge, and has lacked the resolve to provide the necessary resources to set, and re-set, straight the record about mistruths, outright lies, and myths that are a part of this debate.

Periodic debates over the value and utility of advertising mail have been a part of the direct mail industry's experience for more than 60 years. In the early years, newspaper publishers were the chief antagonists who sought to undermine the viability of printed advertising distributed through the mail for the sake of printed advertising distributed through newspapers. In more recent times, the antagonists can be found within the camps of some major environmental groups who should have done a much better job discerning the myths from the realities on this issue. Ironically, many of them are mightily dependent on the same medium they seek to disparage.

The main arguments raised by direct mail's opponents can be characterized as the following:

·         Advertising mail is nothing but "junk."

·         Nobody wants advertising mail. Advertising mail requires demolition of the nation's forests (all which are good to the planet's ecology) to produce the paper upon which ads are printed and ultimately turned into solid waste.

·         Discarded unsolicited advertising mail is creating a monumental environmental problem largely in the form of solid waste that is saturating landfills.

·         Discarded advertising mail is a vehicle that facilitates criminal identity theft.

·         Unsolicited advertising mail is an annoyance.

·         Nobody really wants it and mail recipients should determine what they want to appear in their mailboxes.

Bunkum! Now let's examine these assertions and review the facts.

ADVERTISING MAIL IS NOTHING BUT "JUNK." "Junk" signifies something without value, which clearly is not the case with advertising mail. To put the matter simply, if advertising mail is junk, if it is unwanted, unread, and unproductive, then it would have been abandoned long ago by advertisers. The fact is that advertising by mail works. People send it. People read it. People respond to it. Far from being valueless junk, for those who pay for its planning, production, and distribution, advertising mail is of enormous value to their businesses and the people that they employ.

In fact, mail-based advertising is part of a segment of the economy that is vital to America's well-being. As Congress noted during its debate on postal reform, mail (including the more than 50% that contains advertising matter) is responsible for the production and sale of some $900 billion in goods and services, for the creation and maintenance of some nine million jobs within the public and private sectors of the economy, and represents some nine percent of the nation's gross domestic product. That is far from an insubstantial, "valueless," contribution to this nation's economy growth and well-being.

NOBODY WANTS ADVERTISING MAIL. There's an old saying that the squeaky wheel gets the grease. It's also true that people, by their very nature, are willing to be much more declarative about their unhappiness rather than their satisfactions.

There are people who would prefer not to receive unsolicited advertising mail, and, for sure, some have been very vocal about it. The assertion, however, that nobody wants advertising mail seems unjustified in the fact of years worth of public surveys (particularly the USPS' annual household diary studies) that have showed that most people, when asked, reportedly have found advertising mail of some value and interest. Indeed, more than 80% have consistently reported looking and reading the pieces they receive before making any decision to retain or discard them. U.S. Postal Service data have shown consistently that considerably fewer than 10% of such survey respondents say they object to receiving any form of advertising mail at all.

ADVERTISING MAIL DESPOILS THE NATION'S FORESTS. Yes, advertising mail is largely produced on paper, and, yes, paper is a product manufactured from trees. Other than that, however, there is no factual basis to support the supposition that the nation's forests are being destroyed at great cost to the quality of the air we breathe for the sake of advertising mail.

When it comes to forest lands, says The New York Times, "the acreage is essentially the same as it was a century ago, and there is over 30 percent more wood volume per acre than in 1952." (See: Family Matters, Generational Shifts Loom for Big Tracks of American Woods, June 14, 2007)

One reason for the preservation of so much forest land is that tree farms have proven to be enormously successful:

In 1957 the U.S. had 516 billion cubic feet of trees for growing stock. In 1997, the volume of trees for growing stock had increased 36 percent to 856 billion cubic square feet. In 2007, the U.S. had 925 billion cubic feet of growing stock, 79 percent more than in 1957 and 9.6 percent than in 1997.

There was a time when trees were felled for fuel. Those days are long gone. If trees do disappear, they do so more to make way for agriculture or new home construction, and community development. National and state forests are not disappearing to make paper pulp. Even when agriculture and construction are accounted for, as the U.S. Forest Service has reported, today's forest land area amounts to about 70 percent of the area that was forested in 1630.

The pulp that is used to produce today's paper, believe it or not, comes from something called "tree farms." That's right, farms, farms that are not unlike all the other farms that produce the food which we humans consume. In this case, they are farms that have been planted and cultivated with trees that are designed to be harvested. Furthermore, trees are a renewable resource. Once harvested, new straplings are planted to go and mature into trees that once again will be harvested.

PAPER WASTE IS AN ENORMOUS ENVIRONMENTAL PROBLEM. This is just more uninformed clap-trap. Here are the facts, at least as the Environmental Protection Agency has reported them:

Some municipal waste is recycled. Some is incinerated, and some is consigned to landfills. That which finds its way to a landfill is known as municipal solid waste. When that waste is analyzed, discarded advertising mail accounts for some two percent (2%) of municipal solid waste.

Now, according to the math I learned in school, two percent is a very small percentage of the whole. In other words, discarded advertising mail constitutes a very small percentage of the municipal waste stream.

It is important to note, however, that landfills contain considerably more matter than municipal solid waste. Check any landfill and you'll find industrial nonhazardous waste, utility waste, construction and demolition waste, and municipal sludge. In EPA terms, this stuff constitutes what is known as Subtitle D nonhazardous waste. Again, when this waste is analyzed, discarded advertising mail actually accounts for no more than 0.04% of the Subtitle D waste stream. Zero point four percent!! And that constitutes an enormous environmental problem? Get real!

Self-styled environmentalists and others of their ilk also should be directed to learn a little more about paper waste and recycling. Indeed, a substantial amount of paper waste is recycled for subsequent manufacture into other paper products, such as newsprint, direct mail circulars and catalogs, stationery, paper towels, baby diapers, facial tissue and toilet tissue. Just how many of these direct mail critics do you think would be willing to go without paper baby diapers and toilet paper for the sake of some alleged environmental benefit?

DISCARDED ADVERTISING MAIL FACILITATES IDENTITY THEFT. All it would take is a simple inquiry to the Postal Inspection Service and the FBI to learn that this is simply not the case. Advertising mail is largely what the USPS calls Standard Mail. Unlike First-Class Mail, Standard Mail cannot contain information that is wholly specific to any individual. The information contained in Standard Mail is mostly generic in kind with some market-based data refinement. Most consumers would stand a greater chance of having their identities stolen from the many credit card transactions they make throughout the day than from the mail they routinely discard.

UNSOLICITED ADVERTISING MAIL IS AN ANNOYANCE. The charge that advertising mail is "annoying" can be levied just as easily at advertising that is distributed via any other medium. Some people find unsolicited advertising mail a bother. Then, again, some people find unsolicited advertising that is printed in newspapers and magazines or broadcasted via radio and television to be even more annoying.

RECIPIENTS SHOULD DETERMINE WHAT THEY GET IN THE MAILBOX. Hold on here. Let's get the facts straight. In the United States, the recipients of mail are not primarily responsible for paying the cost of the nation's universal mail service. The fact is that it's the senders of mail underwrite the cost of universal service. This is in contrast with the realities of telephone, radio, television, or the internet. In these cases, recipients actually do pay fees to connect to the networks that produce these information, communication, and entertainment services.

Here's the interesting conundrum. While people admit they are annoyed receiving advertising via any of these communication channels, they only demand control over one medium, the mail, the very medium for which they pay nothing to be connected to a universal mail service network.

Why is it that people do not see fit to make similar demands on newspaper and periodical publishers or television and radio broadcasters, or web sites on the internet? The answer is simple. No publisher or broadcaster would concede for a second that those who receive their products should have the right to dictate whether they contain advertising. Furthermore, most sentient beings recognize that the revenues derived from broadcast and print advertising underwrites the cost of the production and distribution of these media. For instance, without advertising, the price for a copy of your daily newspaper, your weekly or monthly magazine, or the television and radio services you receive would be substantially more than you are paying today.

These very same realities also are true for mail. The advertising that's distributed in the mail makes today's free, universal mail delivery system possible. Without such advertising-based revenue, the cost of daily mail service would go through the roof, and the quality of service would be far from universal.

LAWS SHOULD BE PASSED TO LIMIT ADVERTISING MAIL. Our industry's antagonists in today's debate differ from those of years past in one particular regard. Today those who attack direct mail are calling on state legislature to enact laws that would limit a business' right to use mail for advertising and marketing. They use anti-telemarketing, anti-fax, and anti-spam legislation and regulation as something that should be emulated in the mail.

Again, unlike those other media, those who receive the mail pay nothing to get it. The revenue that enables the Postal Service to provide this service is provided by senders, not recipients.

Normally, government restrains itself from interfering in a market's operation unless there is a compelling government interest to do so. Since government has never seen fit to impose restrictions on the distribution of advertising in newspapers, magazines, on the interest, or via radio or television, one has got to ask "what is the compelling governmental interest that demands the state to impose restrictions on advertising distributed through the mail."

The fact is, there is none. Indeed, I would argue that state legislatures don't even have the power to interdict the commercial use of mail. America's founders clearly specified in the constitution they adopted that Congress alone would have authority over the post and post roads. Consequently, any state's enactment of a law restricting advertising mail would be unconstitutional, since it would represent the state's usurpation of a power reserved by the constitution solely for a higher national authority.

CLOSING REMARKS. As someone who has worked in this industry's behalf for some 25 years, I'm mad as hell about the mindless attacks advertising mail's disparagers have levied at our industry. I'm tired of having some outsider who understands so very little about our industry create the kind of enviro-speak garbage that passes today for informed news and comment.

I know the companies that make up our industry account for a significant portion of our nation's economic growth and well-being. I also know that their customers find the information, the services, and the products they bring to the marketplace of enormous value. I don't find a need to apologize for what I do within this industry.

That's right. I'm mad as hell, and you should be too.

 

 

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