Alert–Our Comments on the PRC Rates Proposal


For Immediate Release

Thursday, March 1, 2018 Contact:

Mike Czin,

Mail-Industry Leaders File Joint Comment in Opposition to Massive Postal Rate Increases

Group Calls Out PRC for Not Having the Power to Re-write Rate-making Provisions or the Right to Implement Massive Price Increases While Ignoring Efficiency, Cost Savings and Rate Stability

Washington, D.C. – Today, MPA – the Association of Magazine Media, the Alliance of Nonprofit Mailers, the Association for Postal Commerce (PostCom), Idealliance and the American Catalog Mailers Association filed a public comment with the Postal Regulatory Commission (PRC) in response to the 10-year review proposal that would dramatically increase postage rates for some classes of mail by as much as 40 percent.

To view the filing, CLICK HERE.

The five filers represent different postal stakeholders across the business and nonprofit spectrum, but they are unified in their belief that the PRC’s rate-increase proposal is not only harmful to their industries – and the Postal Service itself – but is not permissible under existing statute.

“The simple fact is that under the Postal Accountability and Enhancement Act (PAEA), the PRC does not have the legal authority to re-write the law’s cornerstone ratemaking provision—the CPI cap on postal rate increases—and implement these massive increases,” said Michael Plunkett, President and Chief Executive Officer, PostCom. “Further, the statute is clear: the PRC must balance the nine objectives when determining rates. Instead they chose to elevate one – the financial stability of the Postal Service – and ignore crucial factors like, efficiency, cost savings and rate stability.”

According to the filing, the PRC proposal effectively eliminates rate stability from the statute.  The increases proposed by the Commission—as much as 30 percent above inflation over five years, and as much as 40 percent or more in nominal terms—are the antithesis of rate stability:

“The PRC conflates rate stability and rate predictability, and rates that increase this much faster than inflation are not stable,” said Linda Thomas Brooks, President and CEO of MPA—The Association of Magazine Media. “If approved, these rate increases would force some magazines to cut back on issues and circulation and would put others out of business entirely. While it would hurt businesses and consumers across the country, it would do virtually nothing to improve the Postal Service’s finances.”

The filing argues that the PRC’s proposed ‘non-compensatory products’ surcharges would provide little financial benefit to the Postal Service, and thus would do little to advance the PRC’s objectives. The decreased volume from the proposed rate increases would offset any positive financial benefits of the rate increases.

“The nonprofits we represent don’t just use the Postal Service to communicate with their members, they rely on the Service for their financial survival,” said Stephen Kearney, the Executive Director of Alliance of Nonprofit Mailers who previously served as a senior executive at the Postal Service for more than 30 years. “The PRC proposal will shift dollars away from nonprofits and others, and totally decimate programs and outreach that so many Americans rely on. It’s not too late—there’s still plenty of time for the PRC to reconsider its approach and produce a balanced approach that considers all nine criteria that the law stipulates.”

The deadline for public comments on the PRC’s proposal is today, Thursday March 1, and reply comments are due by March 30. The PRC is expected to deliberate their proposal in the coming weeks and months.


Michael Czin

Vice President | SKDKnickerbocker @skdknick

o: 202-464-6602 | c: 202-286-7654