American Catalog Mailers Association: Generally supportive of our position.
American Bankers Association: Supports our position.
American Forest & Paper Association: Supports our position.
American Postal Workers Union: Demand for mail is price-inelastic. PRC lacks authority to change collective bargaining system. Limits imposed by Section 3622(e) on work-sharing discounts are outside the scope of the 10-year review because Section 3622(e) is a different subsection than Section 3622(d)(3). Sen. Collins made clear that the CPI cap was covered by the 10-year review. The USPS can’t survive with a price cap. The USPS “has largely realized all the efficiencies it can.” USPS has slashed costs, and service is now suffering. The Commission should eliminate the CPI cap and allow the USPS to file a “true up” rate increase “outside of the restrictions of any old or new rate-making system.”
Congressmen Chaffetz and Meadows: Argue for full pass-through of work-sharing discounts; don’t mention any other issues.
Connectiv (a division of Software & Information Industry Association, formerly American Business Media): Generally supportive of our position, although renews traditional ABM complaint that small-circulation publications can’t qualify for deep discounts. The Commission should require the USPS to charge profit-maximizing prices for competitive products.
DMA, ACMA, AF&PA, PostCom, EMA, GCA, IDEAlliance, PSA, SMC: Consistent with our position.
eBay: Supports keeping the CPI cap.
EMA Foundation: Supports keeping the CPI cap.
Greeting Card Association: Generally supports our position, although defends 3622(e) limit on work-sharing discounts. Supports argument that the CPI cap is inviolate in the 10-year review.
Mailers Hub LLC and the National Association of Advertising Distributors: PRC should replace CPI cap in favor of a better index (not identified). Allow USPS to recover increases in its input costs “only to the extent that those costs are in reasonable alignment with those of comparable businesses.” Allow higher increases if necessary to avoid deterioration of service. Allow extra-cap increases when needed to recover “uncontrollable” costs like the prefunding requirement.
Major Mailers Association, National Association of Presort Mailers, National Postal Policy Council: Supports keeping CPI cap; workshare discounts should be set equal to costs avoided; USPS should be required to conduct cost-benefit analysis of changes in mailing requirements; the exigency provision should be interpreted consistent with its purpose; and market-dominant NSA rules should be revised to reduce difficulty to approve.
National Association of Letter Carriers: Eliminate the CPI cap in favor of an unspecified “system for regulating market dominant rates that allows USPS to charge prices that – while still reasonable and fair – would generate enough revenue for USPS to achieve the financial stability it needs to continue to fulfill its mission of providing prompt, reliable and universal service.” Also, allow a one-time “true up” rate case.
National Newspaper Association: Opposes network realignment. Supports one-time rate increase equal to half of the R2013-11 exigent rate surcharge.
National Postal Mail Handlers Union: Supports elimination or loosening of CPI cap.
Netflix: PRC should retain the CPI cap or at a minimum defer any changes until Congress acts.
Pitney Bowes and John Panzar (for Pitney Bowes): Commission should require that work-sharing discounts equal 100 percent of avoided costs.
Parcel Shippers Association: Generally supports current system, including CPI cap, but proposes several changes: (1) PRC should find that Periodicals Mail is being subsidized, and should require the USPS to raise Periodicals rates; (2) work-sharing discounts should be set equal to avoided costs; (3) PRC should be vigilant not to disclose terms of competitive Negotiated Service Agreements.
PRC Public Representative:
Senator Ron Johnson: PRC should finish case ASAP. “Doing otherwise could further jeopardize the financial viability of the Postal Service and create greater uncertainty among the businesses and communities that depend on it.”
Saturation Mailers Coalition and other associations of community newspapers: Keep the CPI cap.
Taxpayers Protection Alliance: The Postal Service should receive more revenue (comments don’t say how). Competitive products should pay more.
UPS: The Postal Service should be required to charge more for competitive products. The CPI cap should not be loosened. If the CPI cap is loosened, however, the Commission should enforce higher service standards for market-dominant products. Market-dominant revenue should be used only for market-dominant costs.
American Lung Association
Disabled American Veterans
National Wildlife Federation
American Institute for Cancer Research
American Lung Association (in addition to declaration)
American Parkinson Disease Association
Association of Direct Response Fundraising Counsel
Catholic Charity Appeal
The Children’s INN at NIH
Christian Appalachian Project
Diabetes research and Wellness Foundation
Food for the Poor
Franciscan Mission Associates
Guide Dog Foundation
Jewish Voice Ministries International
Lupus Foundation of America
March of Dimes Foundation
Marine Toys for Tots
National Catholic Development Conference (Sr. Georgette Lehmuth)
National Children’s Cancer Society
Poor Handmaids of Jesus Christ
SOS Children’s Villages USA
Whitman Walker Health
Wounded Warrior Project
Alliance for Retired Americans et al. (Katherine E. Isaac)
David Yao (APWU shop steward)