PRC Starts 10-year Regulatory Review

At 8:02:10 AM EST on December 20, 2016, a very long and complicated process was started. This is the 10-year anniversary of the passage of the Postal Accountability and Enhancement Act (PAEA) of 2006. The Postal Regulatory Commission (PRC) initiated the process by issuing a 12-page order that lays out its scope, the initial process, and proposed definitions and measurements for the 9 objectives that the law says the postal rate-making system must try to achieve.

Alliance members: this will be a long process. The Alliance will be involved and represent your interests. We also will provide you with guidance if you want to participate directly.

The order describes its scope as:

The Commission intends to examine all aspects of the rate-making system provided within section 3622, including the annual limitation on the percentage changes in rates, the schedule for rate changes, the 45-day notice before the implementation of rate adjustments, expedited rate changes due to extraordinary or exceptional circumstances, class level application of the annual limitation, the rounding of rates and fees, the use of unused rate authority, and work-share discounts.

The process set up for the initial determination by the PRC to determine whether the system is meeting its objectives is straightforward. Comments are invited from any interested party for the next 90 days ending March 20, 2017. All comments properly submitted will be posted on the PRC website.

To comment, one has three options. First, regular participants have a “permanent account” to file comments online. Second, one can apply for a “temporary account” to be able to submit comments online in this proceeding. Finally, the Commission will be accepting comments by U.S. Mail, but they caution that you should “should be mindful of possible delays given the irradiation process for mail delivered to the Commission.”

As they say in baseball, the heart of the order is the discussion of the 9 objectives. The PRC provides its “preliminary definition for each objective” and “suggests measurable key concepts within each objective.” These all have been developed within the PRC, and the Commissioners invite comments on them.

In fact, the Commission call for comments is very broad:

In particular, the Commission invites comments in response to the following questions:

  1. Is the framework proposed by the Commission appropriate for the review?
  2. For each objective, is the preliminary definition reasonable? If not, please suggest alternative definitions.
  3. For each objective, are the potential metrics for measuring the achievement of the objective reasonable? If not, please suggest alternative metrics for measuring whether the objective is being achieved.
  4. If the proposed framework is not appropriate for the review, please identify the framework that should be used for the review and describe how to measure the achievement of the objectives in that alternative framework.
  5. Based on the Commission’s proposed framework or an alternative framework provided in response to question 2, is the current system achieving each objective, while taking into account the factors? Please note that review of the system shall be limited to section 3622 as discussed in section II above.
  6. If the system is not achieving the objectives, while taking into account the factors, what modifications to the system should be made, or what alternative system should be adopted, to achieve the objectives?

This is only the very beginning of a very involved process; much more to come. While there might be a temptation to tune it out at times, nonprofit mailers must be as involved as possible to help ensure the future funding of their missions.