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Feb. 1 2012 11:22 PM

I recently responded to a semi-private internet post from one our industry leaders. His comments were not intended for public consumption, mine are. What lead to this thread (conversation) were multiple postal initiatives that recently came to light. It is my contention that these and past initiatives prove the USPS is at war with their MSP customers and those that provide services to the MSP community.

New revelations provided by the USPS:

1. 100 new sales people will be added to sell EDDM. Though not stated, they will also be selling services for Direct Mail Hub vendors. The Direct Mail Hub (uspsdmhub.com) is an umbrella of services provided by select vendors willing to share revenues with the USPS.
2. The USPS is looking to increase EDDM sales to $1 billion in 2012.
3. In a recent OIG report on DMU's, under "Management's Comments" was this section: "management agreed that additional tools are needed to increase mailer participation in Full-Service Intelligent Mail. Management is developing an online tool that will enable small business mailers to upload address files to match with delivery point validation, Move Update, Intelligent Mailpiece and tray barcodes, and sortation."
Our industry's traditional approach to disagreements with postal management is quiet diplomacy. The Postal Service, over many years, has taught me that a more confrontational, big stick approach is significantly more effective. The quiet diplomacy our industry has practiced over the past year has not slowed the Postal Service's substantial investment in competing with their best customers. Just the opposite! It is my firm belief that customer passivity significantly encourages postal aggression.

A one sided conversation:

kvetching? Being a hick from the sticks of Ohio I had to look that one up. Kvetching: "to complain persistently and whiningly." Don't you just love the internet? I'm relieved that we agree on several key points, namely that sitting around our keyboards and constantly whining about the USPS's threat to our businesses, without taking actions to stop them, is a digital waste of time. Secondly we agree that EDDM, as originally laid out, is simply saturation mail using a simplified address format. The USPS has tweaked the rules to make it easier to produce but not much new here, other than the fact that they are promoting it as a new fantastic direct mail program. I wish they would promote all direct mail more aggressively.

Where EDDM runs off the rails is when the USPS uses our customer data, coerced from us under the color of authority, to interfere with our customer relationships. Pushing EDDM to existing customers and counting that mail as new mail will get some postal employee a promotion and a raise, but does not increase mail volumes. I do agree that our industry should forget the concept of partnering with the USPS, and treat them as the parasitic competitor they have become.

The threat to our industry is not EDDM. The threat to our industry is the USPS expansion into providing data services (CASS, NCOA, Presort, Postal Documentation, Tray and Bag Tag information all by 2013 for free), campaign management, print services and of course mail preparation services. Your point that "What the USPS is doing with EDDM and the Hub is distasteful and subversive to our business interests but it's not illegal." Is factually incorrect!
 
We all know that PAEA limits the USPS to providing Postal Services. In SEC. 101. DEFINITIONS of the current postal law, it defines postal services as "the delivery of letters, printed matter, or mailable packages, including acceptance, collection, sorting, transportation, or other functions ancillary thereto" The PRC was tasked with determining if nonpostal services being provided prior to 2006 should continue. The criteria for this determination were (A) the public need for the service; and (B) the ability of the private sector to meet the public need for the service."

A good lawyer might argue that printing and data prep are ancillary services to delivering mail, but it is a stretch beyond the clear intention of the law. Even if production of mail might be deemed an ancillary service to the acceptance, collection, sorting, transportation and delivery of direct mail, the determination of whether the USPS could continue to provide these services would be based on "the ability of the private sector to meet the public need for the service." No one can argue (not even postal lawyers) that with the massive decline in mail volume that there isn't enough mail service providers to meet the public need. Nor can anyone argue that the USPS is bringing something unique or unusual to the market place that isn't already being provided by thousands of vendors across the country. The problem with the direct mail industry is a lack of customers; not a lack of service providers.

And you are correct that it is not the USPS's obligation to direct customers to any one vendor but it is unethical to direct my customers to a partner of the Postal Service in which they have a stake in the financial transaction. This is what they are doing with the Direct Mail Hub. If they are providing any nonpostal services, as outlined in the law, then these services are both unethical and illegal! This is one of many points we should be pressing vigorously in Washington and in the national press. I have no problem with the USPS promoting DIY (do-it-yourself), I have a problem with them illegally selling nonpostal services to my customer list that they required me to provide!

"the bottom line is that if the USPS wants to push EDDM or the Hub or any other legal mail generation initiative they can do so whether any of us likes it or not. Period." I have found over the years that if I can't compete playing under someone else's unfair rules, all you can do is change the rules. Never, ever helplessly walk away dejected and beaten to a pulp. Mail generation by the USPS is illegal. If that is not clear to postal bureaucrats, we should be lobbying senators so that after the next postal bill is passed it is crystal clear! Senator Collins does not seem to appreciate the USPS subverting the clear language and intentions of PAEA. Has anyone spoken to her, or is that too confrontational? Obviously congress did not want the USPS to compete with the private sector or the 2006 law would not contain the language it does!

My intent is to sound a call to arms, not whine. I'm trying to scare the hell out of people in our industry by showing a glimpse of what the USPS has in store for our businesses and industry from information in postal documents and past experiences. Either we stop the bureaucrats now or we may not be able to stop them in the future. We do not have to accept postal managements' plans for our demise; we can alter the future, but only if we are willing to fight for it.

kvetching? I agree, constantly complaining to friends won't solve our problems. We have to complain to the entire world and bring so much pressure down on the Postal Service that they have to change their evil ways!

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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