U.S. Postal Service

475 L’Enfant Plaza SW, 11^th Floor N

Washington DC 20260-3436

 

Letter-Size Booklets and Folded Self-Mailers

MailingStandards@usps.gov

To Whom It May Concern:

This is my first response to your proposed rules for ‘Letter-Size Booklets and Folded Self-Mailers.” Due to the size, scope and significant ramifications of your proposed rules I will need several targeted responses to cover, what I believe are some of the unnecessary and or negative affects these changes will have on the direct mail industry.

Breaking my comments into multiple responses also has the beneficial affect of generating an increase in the number of responses. With postal headquarters’ emphasis on numbers rather than the content of responses, it is necessary for each customer to respond, and respond often. A better approach would be for companies to aggregate responses, providing an accumulation of ideas that are presented succinctly. But since one, two or even five responses (no matter the content) means to postal employees that there is little or no customer resistance to change, it is imperative for the industry to beef up the quantity of responses.

This first response will concentrate on the introductory information to the proposed rule, published in the Federal Register 12/29/08.  This is an attempt to show postal management that nearly all of the changes they propose for non-enveloped letter mail are, according to their March Federal Register filing, unnecessary. It is often forgotten in postal proceedings that the direct mail industry pays all of the Postal Service’s bills. For this reason, management should finally heed the industry’s issues with the proposed rules!

In the Summary section of the proposed rules, it is explained that a filing on March 14, 2008 provided “…an advance notice of our intent to develop new mailing standards for folded self mailers and booklets mailed at automation and machinable letter prices.” The December summary continues with “we provided justification for these changes…”

Even though the advance notice included the words “folded self-mailers” the whole discussion was about BOUND booklets! It discussed the fact that with the massive rate increase on (bound) catalogues mailed as flats, letter sized catalogues had become more popular. One thing the notice didn’t say was that it was postal headquarters that encouraged customers to down size their flat mail to letters, as a way to reduce postage costs.

The March Federal Register talked of the progression from flat sized catalogues (bound) to letter sized catalogues (bound) and stated “These types of letter-size booklets and folded self-mailers are often called “slim jims””. This notice and ensuing discussion referred to and described BOUND letter sized catalogues!

Clearly by the descriptions used in the Background Section of the March notice, the Postal Service intended to develop new automation requirements for bound pieces only! So the only changes the March filing provided some justification for in the new proposals are the sections dealing with bound letter sized self mailers!

You have not provided any justification supporting the need for specification changes in these sections:

3.3 Static and Coefficient of Friction

3.12 Tabs, Tape, and Glue

Tab size and placement as they pertain to unbound mail pieces

3.15 Definition[of Folded Self-mailers]

3.15.3 Physical Standards for Folded Self-mailers

3.15.4 Folded Self-mailer Design and Sealing

As it pertains to the design of self mailers along with the placement and size of tabs

3.16.1 Definition [of Booklets]

As it pertains to unbound pieces

Nowhere in the March notice did the USPS tell customers that it was going to redesign the entire non-enveloped mail stream! To claim in the December filing that “we provided justification for these changes…” is the greatest bait and switch scheme ever perpetrated by a bureaucracy on customers who are compelled to use their services. The reason you didn’t get but 5 responses to the March notice is that 95% of your customers do not produce slim jims (bound catalogues) and thought there would be little if any affect on them or their customers.

You did not tell customers you intended draconian tabbing regulations for unbound pieces, that these new regulations would require massive spending for new equipment, and that the intended tabbing requirements would cause as much as a 50% decrease in our production speeds. Your March filing didn’t tell customers you were redefining the definitions of mail piece designs in an effort to massively increase regulations on these pieces and significantly decrease their marketing value. And you didn’t tell us that you were changing the dimensional sizes of non-enveloped mail. In fact you haven’t told us yet what your plans are for cards, which were not even mentioned in the March filing.

Here are some things the March filing did say but were obviously ignored as the proposed rules were being prepared for the December Federal Register. They are listed by their appropriate section headings:

Under the preliminary data section in March you told customers “…that the most important characteristics by far are thickness and tab integrity…” and “The next most significant characteristic is the cover stock.” Nothing stated here would have much bearing on unbound letter sized mail pieces. Nothing here justifies a redefinition of mail piece design or the resizing of all letter sized mail.

This section states “… the 1/16-inch-pieces ran with jam and damage rates somewhat higher than the rates anticipated for similar enveloped letters.” OK, somewhat certainly sounds acceptable to me. Different pieces are going to run at different rates on equipment, letter shops experience this every day. If the Postal Service only wants envelope mail, you should have that discussion with your customers, not incrementally destroy non-enveloped letter sized mail and the companies that produce it!

The March filing did make it clear that 1/8 inch pieces, as currently manufactured and prepared had unacceptable jam rates. So 1/16 inch pieces, which take in nearly the entire unbound letter mail stream, are OK if you’re able to define good tabs.

Well, the first sentence in this section of the March notice is gibberish. I am not an engineer, if you want paper and adhesion strengths as part of DMM specifications, then let the standards say “use only USPS approved tabs” and work out what those specifications are with the people that manufacture tabs!

The rest of this section, counter to the December standards, says that there is a perforation level (2.5/3/3) that performed reasonably well. In fact you state, “All of the other tabs that were tested performed reasonably well when fed with tabs on top, or on the left and the right edges of the mailpiece.”   One inch perforated plastic tabs that were weaker (2/1/1) were unacceptable. Perforated tabs (2.5/3/3) were part of the “All” of the other tabs, and were OK! Just as astonishing, the March filing stated that tabs on the top performed as well as tabs on the lead and trail edges.

In this section, the March notice goes on to say “Variations of size…, tab locations (top and ends…) and binding did not have a significant effect on the test results for the 1/16-inch-thick mail pieces.” Since the majority of letter sized pieces that we mail for our customers are less than 1/16 of an inch thick, I certainly didn’t feel threatened by the March notice.

The undeniable facts are that statements in the Tabs and Other Characteristics sections of the March filing are in direct conflict with and totally discredit the December proposed rules on tabs and tab placement!  

Additional Mailpiece Characteristics:

One mail piece characteristic mentioned in this section as a concern was compatibility of mail pieces with current letter trays. All letter sized mail pieces are compatible with current letter trays. The USPS provides to customers two tray sizes, the MM tray for pieces up to 4.5 x 9.75 (inside dimensions of this tray) and EMM trays for pieces up to 6 1/8 x 11.5. It may be a shock to the headquarters staff, but all letter mail currently delivered by customers is “compatible with current letter trays…”

The March filing goes on to say that “slim jims are more sensitive to damage” than envelope mail. Since all sizes of letter mail have USPS containers in which they fit, “new standards for these characteristics” are unnecessary.

If there is a problem here, it is with postal operations. The simple solution to mail damaged in USPS plants, is to educate employees on how important it is to use the correct tray size when working and transporting our mail! Sleeving this mail would also be a big help.

Rather than justifying the proposed changes, as stated in your December filing, examination of the information provided in the March Federal Register demand a decidedly different conclusion. This information comes from the Postal Service (published in the March Federal Register) and completely supports the industry’s total repudiation of the proposed rules.

·         Piece size and binding did not have a significant affect on the test results

·         Tabs on top or on the lead/trail edge did not have a significant affect on test results

·         In fact, a slide of the test results show identicaljam rates

·         Stronger perforations (2.5/3/3 what ever this means) performed reasonably well whether they were plastic, paper, translucent, or vinyl.

·         The most significant mail piece characteristics were thickness, tab integrity, and cover stock.

·         Slim jims (bound letter sized catalogues) and some perforated (2/1/1) plastic tabs, are the cause of the USPS’s processing problems.

It is irrefutable that information presented by the USPS in the March Federal Register and concerns expressed by the mailing industry, were intentionally ignored in writing these proposed rules!

I admit that I didn’t respond to the March notice. I didn’t respond because the March notice was straight forward and non-controversial. The Postal Service was having problems with bound mail pieces and certain tab perforations and you were testing to see what changes needed to be made. You weren’t, after all, redesigning the entire letter mailstream.

One responder in March was the Association of Postal Commerce or PostCom, as most people know it. They, unlike your characterization in the Overview Comments section of the proposed rules, did not express concern about tabs without perforations. In fact, they didn’t mention tabs at all.

What PostCom did was offer solid advice and a few warnings:

·         “… characteristics of letter sized booklets and folded self mailers (slim jims) can not be considered as a purely operational matter.”

·         Impacts on revenue and volume must be considered

·         There is a need for lowest combined costs

·         Engineering tests must reflect current industry practices

·         They cautioned about the potential for unintended consequences

·         Consideration must be given to building volume and revenue

·         There must be an imperative to keep more mail from leaving the postal system

·         A warning that if a significant portion of non-enveloped mail is prevented from qualifying as auto letters, customers will actively pursue alternative media choices and not transition back to the flat mail stream

·         PostCom recommended the USPS determine the volume of non-enveloped letter mail, so the USPS would be aware of the revenue put at risk by adoption of new regulations.

·         “… the Postal Service must balance its goals of reducing mail processing costs and the equally important goal of maintaining volumes and corresponding revenues.”

·         When it comes to mail piece dimensions, “[customer] operations are set to specific paper-size requirements to minimize waste.”

·         Changing piece sizes “could result in sub-optimal paper utilization, increasing paper costs, paper waste, and associated environmental impacts.

·         After phase 2 testing, the USPS should provide the industry with “disaggregated data on specific mail piece characteristics.”

·         In conclusion, “PostCom emphasizes the need for a cautious, balanced approach to developing and implementing changes in standards for non-enveloped automation letter-size pieces.”

It’s safe to say the USPS has disregarded every comment PostCom and its members made in response to the March filing. You also disregarded every comment made by customers during the webinar meeting with the industry prior to release of the proposed rules in December! 

Some industry people make the claim the USPS is tone deaf in dealing with customers’ concerns. By proposing this unnecessary, ill-conceived total redesign of the non-enveloped letter mail stream, the Postal Service has proven that not only is it tone deaf, but management refuses to work with or listen to the industry it serves. The historical approach to customer interaction from the Postal Service has been to pat customers on the head and kick’em in the back side on the way out the door. These proposed rules show that the more things change the more they stay the same.

It’s impressive that after only twelve years of struggling with certain letter sized mail pieces, the Postal Service brought the industry in and discussed processing issues. It was true cooperation when the USPS agreed to test industry designs and “… encouraged [customers] to resubmit modified pieces for additional testing and evaluation.”

The testing of industry (slim jim) mail pieces had many failures. It also had some successes, and yet these successes were not recognized in the “it’s my way or the highway” attitude exhibited by the proposed rules. And in fact, under these proposed rules, successfully redesigned mail pieces will not be accepted into the automated letter mail stream. Apparently it’s better for ad dollars to go on-line than for the USPS to allow automation compatible but non-conforming mail pieces to touch their machines!

One question remains unanswered. The USPS has stated that these proposed changes are “incremental opportunities for improvement while preserving as many mailpiece design options as possible.” If these massive changes to the non-enveloped mail stream are incremental, what’s the next “incremental opportunity” for the Postal Service going to do to our industry?

 

Todd Butler

Butler Mailing Services, Inc.

513-870-5060