The Alliance of Nonprofit Mailers (ANM) has asked the Postal Regulatory Commission (PRC) to request more information from the United States Postal Service (USPS) and also to change the procedures for its 10-year regulatory review of the rate-making system.
ANM, along with the MPA – The Association of Magazine Media, filed a motion yesterday with the PRC.
The Postal Accountability and Enhancement Act (PAEA) of 2006 requires the PRC to review the current rate system 10 years later to determine whether it’s achieving the objectives established by Congress. The PRC announced its review on Dec. 20.
ANM Executive Director Stephen Kearney said the PRC promised a two-stage process, first to determine whether the current system is adequately meeting objectives. Only after making that determination should the PRC consider how to change the system, he said, such as whether to change the Consumer Price Index (CPI) cap. “In their order for Stage 1, the PRC threw in a request for Stage 2 comments on how to change the system; that is premature,” Kearney said.
The alliance also requested more data, including estimates and calculations of the USPS’ actuarial liabilities, real estate valuations, and scorecard performance metrics of the Flats Sequencing System (FSS). Such information, Kearney said, would help everyone comment more intelligently to the PRC questions about how well the objectives are being met.
“We also think the regulator would be able to do its best job if it allowed all parties to file reply comments after the initial comments are published,” he said. Public comments are due March 20.
If the PRC finds that the objectives are not being met, it has the authority to either propose rules that change the system or adopt an alternative system to achieve them.
“This is a critical process for all nonprofits that rely on USPS mail to raise funds and distribute information,” Kearney said.
The PRC’s review will include evaluating all aspects of the ratemaking system, including:
- Annual limitation on the percentage changes in rates;
- Schedule for rate changes;
- 45-day notice before implementation of rate adjustments;
- Expedited rate changes due to extraordinary circumstances;
- Class level application of the annual limitation;
- Rounding of rates and fees;
- Use of unused rate authority; and,
- Worksharing discounts.