July 28, 2025
Dear Alliance Members:
Today, your Alliance of Nonprofit Mailers filed regulatory comments in support of a return to no more than annual postage rate increases and no more reductions of work-share discounts below the cost avoided by the Postal Service.
We also urgently ask the Postal Regulatory Commission to quickly address the need to eliminate above-inflation rate increases.
Our comments are posted on the PRC website.
Our summary:
The Commission’s two proposals constitute a good, but insufficient, start to the process of modifying the ratemaking system to better achieve Congress’ balanced objectives.
Pre-PAEA, rate increases generally occurred once every few years. Between 2007-2021, market-dominant rate increases occurred once annually. Modifying the current system to restore this cadence is a sensible and discrete action that the Commission can take now. So, too, is the proposed rule closing the workshare discount loophole and maximizing efficient pricing.
But the Alliance urged the Commission during Phase 1 to promulgate regulations that limited both the frequency and the magnitude of the Postal Service’s pricing power. While we do not object conceptually to a multi-phased review with several rulemakings, we cannot emphasize enough the urgency with which the Commission must claw back the massive amount of rate authority it granted the Postal Service five years ago. The density authority that perversely allows the Postal Service to charge higher rates as it loses volume – the very “death spiral” that Congress sought to avoid – must be eliminated via regulation promptly.
The Alliance thanks the Commission for undertaking this review earlier than expected, appreciates the two proposals put forth in this phase of the proceedings, and asks the Commission to propose further modifications that restrain the magnitude of the Postal Service’s pricing authority as soon as possible.
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