June 3, 2022
Dear Members and Sponsors of the Alliance:
Today, we filed a request that the Postal Regulatory Commission direct the U.S. Postal Service to report delivery service performance for Nonprofit Marketing Mail separately from commercial mail. Within Nonprofit Marketing Mail, we asked that regular mail be reported separately from political and election ballot mail. The Alliance likewise asked that Nonprofit Periodicals’ service performance be reported separately from commercial Periodicals. Finally, we requested that nonprofit use of First-Class Mail for both outbound and return mail, including both stamps and Business Reply Mail be reported as a distinct category from other uses of FCM.
In our May 19 Alliance Report, we notified you that on April 26, the PRC issued an Advance Notice of Proposed Rulemaking to revise the Periodic Reporting of Service Performance. The regulator invited our input into this process which is largely driven by the new requirements in the Postal Service Reform Act of 2022 that directs the Postal Service to develop and maintain a publicly-available online “dashboard” that provides weekly service performance data for Market Dominant products. It also mandates that the PRC provide reporting requirements for this USPS dashboard as well as “recommendations for any modifications to the Postal Service’s measurement systems necessary to measure and publish the performance information” located on the dashboard.
We believe that more granular service data will prove helpful to the nonprofit sector in gauging the value and effectiveness of mail, and in planning future mail programs. Our requests are consistent with and part of our ongoing effort to enable the postal agencies to recognize and embrace nonprofit mail as an important and distinct customer segment and to increase the value of mail to our industry.
Our comments concluded:
Nonprofits purchase and send between approximately 12-15 billion pieces of mail
each year, and nonprofit mailings account for roughly ten percent of the Postal Service’s
mail volume. Nonprofit postal customers thus have a significant interest in service
performance reporting, and such reporting should reflect that nonprofit mail is a distinct
and important customer segment. The Alliance respectfully requests that the
Commission use its regulatory authority to require that nonprofit, political, and
election/balloting mail service performance be reported separately from commercial
Marketing Mail, and that nonprofit mail be reported separately within the Periodicals and
FCM classes as well.
We will keep you posted on how the USPS and PRC respond.