The following has been sent by the Alliance of Nonprofit Mailers, the Association for Postal Commerce, the Direct Marketing Association, and the Association of Magazine Media to the Postmaster General of the United States regarding the Postal Service’s decision to move forward with a postal exigency request.
We are perplexed. In your presentations to the mailing community in recent months, we have heard you say repeatedly that you do not want an exigent price increase; an exigent increase will not occur; and mailers should budget for 2012 price increases at the CPI level, because a larger increase would be self-defeating due to its negative effects on mail volume. Simultaneously, however, the Postal Service has continued to file pleadings and signed statements with the Postal Regulatory Commission in Docket No. R2010-4 claiming that the Service still seeks a $2.3 billion exigent increase.
Under the current circumstances, the only prudent course for mailers is to assume that the Postal Service is still seeking Commission approval of an exigent rate increase in this docket, and that an increase approved by the Commission may very well be implemented by the Board of Governors. As long as the Postal Service’s exigent increase request remains in active litigation, the Commission must consider the request and issue a decision on it. Moreover, if the Commission ultimately authorizes any part of the requested increase, any portion of the authorized increase not implemented by the Postal Service could still end up as banked rate authority—rate authority that would force your customers to plan for above-CPI postage increases for the next five years, and adjust their mailing plans accordingly.
For these reasons, the mailing industry must continue to oppose the exigent rate request as long as it remains pending before the Commission. The resulting litigation will force both the Postal Service and the mailing community to divert precious time, energy, and resources to litigating an increase that you profess not to want – time, energy, and resources that would be far better deployed constructively collaborating to solve the Postal Service’s financial problems and pushing for Congressional action in our common interest. Further, the continuing pendency of this litigation—and the mere possibility that mailers may face an above-CPI rate increase in 2012 or 2013—has cast a pall of uncertainty over the industry’s budgeting and mailing plans. This business uncertainty almost certainly will cost the Postal Service mail volume and revenue.
These harmful consequences can be easily avoided. If you do not want an exigent increase and you do not want mailers to plan for one, withdraw the case. Actions speak louder than words.
Unless and until the Postal Service publicly withdraws its formal request for Commission approval of exigent rate increases, mailers must assume that the Postal Service is serious about seeking them. For the good of the Postal Service and the mailing community, we urge you to pull the exigent request.