Manager, Mailing Standards

U.S. Postal Service

475 L’Enfant Plaza SW, 11th Floor N

Washington DC 20260-3436

 

Letter-Size Booklets and Folded Self-Mailers

 

MailingStandards@usps.gov

 

To Whom It May Concern:

 

This is my final response and will deal with section 201.3.15 Folded Self-mailers and section 3.16 Booklets. All comments and references relate to letter sized mail.

In March of 2008, the USPS brought together an industry group to discuss its problems in processing slim jims, bound letter sized catalogues. Postal engineers presented data from tests they had run and plans for future tests. The industry reaction was of great skepticism, but was invited to participate by testing their own slim jims and observe the testing of postal designed mail pieces.

In every meeting, webinar, conference call and slide presentation I have seen since slim jim testing started, industry observers have confirmed that the Postal Service is having a major problem processing slim jims as currently presented. The consensus, from those involved in the testing, is that changes need to be made if the industry wants to keep catalogues in the letter mail stream. The Postal Service achieved success through its outreach to the industry it serves. It identified a problem, made the industry aware of the problem, found one solution to fix the problem, and convinced the industry that the problem must be resolved. We don’t like it, but if the USPS can not process what we are producing we will have to change the products we mail.

Unfortunately, as well as the slim jim testing process was handled, everything else associated with this proposed rule was hijacked by “zealots” (the term used in a current industry publication) in the engineering and operations departments, destroying any trust your customers had in postal management’s ability to rationally (sensibly, reasonably, realistically, wisely, judiciously, logically, lucidly) manage the mail stream.

The industry was aware the USPS was going to test non slim jim pieces but weren’t present for any of the testing. The tests apparently showed that the changes needed to fix letter sized mail are drastic, massive, and so dire they have to be made within the next few months. Judging by the dimensional changes, paper weight requirements, tabbing positions, tab sizes, and tab construction, folded self mailers are obviously not compatible with the automated letter mail stream as currently manufactured. Certainly, with the extreme urgency these rules are being pushed on the industry, not completing these changes by May will mean the total destruction of the entire postal system. I’m sure many in Washington don’t see this as zealotry; these are hard working dedicated employees trying to prevent the demise of the Postal Service.

Except they are zealots and have taken it on themselves to reengineer the entire direct mail industry without caring about the consequences of their proposals! If the industry is correct, and we’re the ones on the front lines (not in a lab), these proposed changes will increase mail owners’ total cost and severely reduce mail volumes. The financial threat to the Postal Service is from within and is manifested in these proposed rules, the proposed rules released 1/22/09 and the future filing for cards. Our self mailers, unbound letter sized mail pieces, may not process as smoothly or consistently as non-windowed envelopes, but the equipment used to process this mail was purchased for this mail stream, not the homogenized mail stream you are attempting to engineer through these mandates.

Why wasn’t the industry involved in the testing of self mailers?   Why haven’t the results of these tests been released? Were the results of testing so muddled they proved nothing, or worse proved the hypotheses of the sainted engineers wrong?  Were the results and these proposed rules engineered to justify the expenditure of postal resources for the unnecessary testing of mail pieces generating few problems and most of the Postal Service’s revenue?  Was the testing of self mailers done at all?

There are some very big mailers producing envelope mail and various styles of self mailers that have tracked identical scan rates through the DBCS for both designs. This means that the equipment is capable of efficiently processing self mailers meeting current DMM standards. Cost coverage data for letter mail proves the same point. I have always worked under the premise that figures never lie, but can be twisted to represent anything you want. The test results of the biggest study the USPS has ever done weren’t released. Does that mean that even using twisted data, none of these changes can be supported?

The numbers the Postal Service did release from early testing don’t support the changes to self mailers in these proposed rules. There seems to be mass amnesia at postal headquarters about the results of your early testing, so I have attached the power point slides produced by the USPS for the March 08 industry meeting to this reply as a reference.

The early testing found that thickness and cover weight were the primary determinants in whether a piece of mail is compatible with processing equipment. Industry testing showed the same thing. Fairly thick pieces meeting the current tabbing rules with very heavy covers (80# and 100# cover stock) process without jams. In the early postal tests, bound thin pieces meeting current standards, processed at acceptable rates.  Well, actually the slide said they processed poorly compared to letters.  I assume “letters” means non-windowed enveloped mail, since everything else (the industry is being told) has to be massively redesigned to be compatible with processing equipment.

Using envelope mail as the standard by which all mail is measured to determine acceptable jam rates is incorrect and a blatant attempt to use smoke and mirrors to twist the data! The correct standard for the machine compatibility of any mail piece is: does it process on the DBCS well enough for the revenues allocated to processing the piece cover its actual cost of processing on the DBCS? The only step, from acceptance to delivery, affected by changes in mail piece design is four trips through the DBCS for sequencing, which takes about five seconds a pass. The vast majority of all postal costs for delivering letter mail are incurred by acceptance, transportation, and final street delivery. These costs are unaffected by mail piece design or tab location!

Slide 3 of the postal power point (attached), has a bullet point that says: “None of these factors made significant difference”. It then listed: size, tab location, tab type, and finally binding as insignificant factors. So apparently the size of a mail piece had no affect on processing compatibility. There was no testing proposed in phase 2 studies for changing the dimensional sizes of the mail stream, nor was there any testing of windowed enveloped mail planned. Yet all of these design factors are about to change significantly. On slide 4, lines L1 and L2 show that tabs on the top and tabs on the ends of a thin mail piece processed with identical jam rates. 

One issue, also not tested by the engineers, deals with their apparent personal preference for positioning tabs on the ends of a mail piece. If tabs are placed on the lead and trail edges and they are not tight to the mail piece, they will catch and snag on processing equipment and other mail. Think of a hang nail and a loose knit sweater. All of the problems the USPS has with tabs on the bottom of mail pieces (“they are a disaster” to quote postal engineers) will be amplified and affect all self mailers and slim jims if the proposed changes are enacted. If tabs on the bottom aren’t compatible with the equipment neither will tabs on the lead and trail edges.

Our industry can not consistently place tabs within 1/32 of an inch of the edge of the mail piece. In fact with my equipment, the thicker and slicker the piece, the more my tabs hang beyond the edge of the piece. Do you think we in the industry intentionally leave our tabs sticking up (or down) beyond the edge of the piece? Do you believe a 1/32 rule will improve our equipments’ ability to control a piece of mail or our ability to control an operator’s setup any better than the existing rules? And if our tabs hang over more than a 1/32 of an inch, will this mail shut your machines down completely, destroying the fantastic productivity you now have?

If no changes are made to the DMM, Standard Mail Letters will continue to cover their costs by 192.7% with First Class Letters and cards covering their costs by nearly 300%. This means the Postal Service now charges nearly double what it costs to process Standard Mail Letters and charges triple what it costs to process First Class Letters. This is the most profitable mail sorted on postal equipment! The first rule of thumb for any business in a down turn is to do no harm to the cash cow! Any gains, achieved through an increase in DBCS processing speeds of letter sized mail pieces, will be insignificant but the risks to the letter mail stream are massive. The CEO of FedEx or UPS would fire the person or persons that would suggest negatively impacting their customer base to the extent these proposed rules negatively impact the entire mailing industry. Good thing the USPS only gives lip service to operating as a “real business”, or everyone associated with this fiasco would have been looking for a new job before these proposed rules were even released! 

I realize you are a governmental monopoly and can dictate compliance, but has anyone tested the ramifications of these changes based on the real world processing of mail? Or, are you trusting the theoretical opinions of engineers who are making the assumption acceptance units will totally control this aspect of mail piece design? Are you sure that a tab overhang of 1/32 is close enough to the mail piece so the tab will not interfere with the equipment and other mail? Or is a protrusion of 1/32 of an inch on the lead and trail edges just enough to act as a hang nail, snagging on every thing it gets close too? Postal engineers did not test this scenario; therefore they do not have an answer as to the affects of this redesign on processing speeds. This is a disaster waiting to happen. And according to slide 4, lines L1 and L2, totally unnecessary!  

What is not in these proposals is a method for testing new ideas and materials. How can our industry innovate mail piece designs without the ability to test around the rules? How can we test new materials and ideas intended to deliver greater marketing value and processing speeds if we can not test and gain approval for successful concepts? You allow testing for compatibility with the flat mail stream and testing was mandated for letter sized disc mailers. This is an opportunity for a win win for the USPS and the industry.

The way I see a testing program working is that customers would go to an MDA for the testing of a design. The MDA and customer (mail owner or agent) would test pieces on a DBCS and when both agreed the pieces ran well, 50 samples would be sent to the PCSC for final testing and approval. Customers seeing your equipment destroy their mail pieces will lead to better construction and designs in the mail stream. It worked with the industry testing of slim jim.

3.15.1/3.16.1    Definition      Retain the current definitions. Nothing you have done, tested, or said justifies a change in definitions for self mailers or booklets. Proposed definitions prevent anything but paper from being mailed in anything but an envelope.

A reasonable case (with additional testing) could be made to change the definition of self mailers and booklets from a construction based definition (folds, covers, bound edges, open edges) to identifying pieces and their corresponding construction requirements based on thickness.

3.15.2/3.16.2      Paper Weight     Paper weight can not be used as a DMM standard until acceptance units can measure it. As paper weight requirements become more complex, the need to measure becomes more critical. Basically the entire industry ignores the current paper weight requirements. In fact, some of the initial parameters for the phase 2 engineering tests didn’t meet the current minimum DMM paper weight requirements.  How do you know if the problems you’ve seen during processing self mailers were caused by pieces meeting the current standards, if you don’t know the current standards? Even if the engineers knew the standards, they apparently don’t have any way to tell if observed pieces are within spec.

3.15.3/3.16.3     Physical Standards     There has been no basis provided by the USPS to warrant these changes. There are companies in this industry that have had machinery engineered to current specs, and for no good reason you want them to reengineer or replace their equipment. There are serious concerns from the industry in dealing with trim sizes, salvage and (this rules) ecological impact.

How ironic, the USPS wins awards for going green but forces rules on the industry causing ecological damage. This won’t look good when the greenies get a hold of it.

3.15.4/3.16.4     Design and Sealing     The tabbing requirements in these proposed rules will cause Butler Mailing Services to purchase two new tabbers and a bump turn to comply and still be able to process mail in a single pass as we do now. Tabbing equipment cost, estimated at $45,000. I will also have to add a new inkjet capable of printing the IMB, since my legacy Videojet printer can not. Estimated cost for something cheap, $35,000, another Videojet that prints on everything starts at $100,000.

I have been told using a bump turn will cut my production speed in half. To maintain current production capacity I will need to double my equipment purchases, total estimated cost for the equipment $160,000. I will also have to hire two people to run the additional ink jet line, estimated yearly cost of $100,000. The building I currently lease can not handle the amount of equipment necessary to maintain my current production capacity so I will have move to a larger building.  Cost of the move is estimated at $5,000. Cost estimate of the increased lease payments, $18,000 per year for an additional 3,000 sq feet. First years interest cost on the new equipment, $20,000.

Estimated first year costs to comply with new postal regulations, $175,000 assuming I use the five year straight line depreciation schedule for the equipment. Increased revenues from these expenditures, zero!

Finally, the cost of a good bankruptcy lawyer is a hell of a lot less than producing mail meeting these unnecessary rules.

My small business, currently utilizing a single ink jet line, will have to spend $175,000 this year to maintain our existing production capacity under these proposed rules. Think what a larger company has to spend if they currently run ten, twenty five, or fifty ink jet lines! And you wonder why the industry is so upset with these proposed rules from an organization that does not evaluate the consequences of its actions, and is never held accountable for bad decisions.

Only the Federal Government can print money, and it sure doesn’t grow on trees. You either don’t know the consequences of your proposals or you don’t care. The cost of compliance is going to drive many companies out of business and the ones that remain will have to charge more to prepare mail. These increased costs will fall totally on mail owners, many of whom are having trouble justifying their continued use of direct mail. Instead of instituting policies that drive customers generating mail with 192.7% cost coverage out of the mail stream, the Postal Service had better start begging mail service providers’ assistance in retaining these customers!

The Postal Service has mail owners stating in their responses to this proposal that implementation of these rules will force them to pull millions and millions of pieces of mail out of the mail stream. How are you going to replace the revenue generated by this mail if these rules are enacted? Periodicals don’t cover their costs and Package Services barely break even. The 144 billion pieces of mail currently being processed on the DBCS is some of the most profitable mail handled by the USPS! Don’t fix what ain’t broken, based on half baked ideas from people that don’t have a clue as to how the industry they serve operates.

These proposed rules will limit the creativity and vitality of the mail stream, substantially increase overall costs for mail owners, and will permanently destroy the USPS’s ability to remain a self-sustaining government entity. At the first slim jim industry meeting you were told to go slowly, tread lightly, and only make changes that were absolutely necessary. You were not listening.

Are you listening now?

Sincerely,

Todd Butler

Butler Mailing Services, Inc.

513-870-5060