Postcom: Remove CASS issues from rate case

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The Association for Postal Commerce wants the U.S. Postal Service to address proposed changes to CASS-matching requirements separately from the current rate case.

Postcom filed a response Nov. 10 to the agency's proposed rules concerning address quality that were published Sept. 27 in the Federal Register. These rules are being considered as part of the rate case, approval of which is expected early next year.

"The proposed address changes are not linked to the [rate case] implementation rules [and] so should not be included in the present rulemaking," Postcom wrote.

The USPS proposed that effective July 2009 mailers of all discount letters and flats "must properly code and match their address lists using one of the CASS-certified address matching methods ... and use the correct ZIP+4 code on each mail piece."

Postcom also discussed other aspects of the rate case in separately filed comments. The association said the proposed rules and rate structures are complex and interrelated, requiring extensive software changes.

"Postcom believes it will be impossible for some of the major presort software vendors to deliver a fully compliant product in time for mailers to install, test and complete their own programming changes necessary to comply with an early May implementation date," Postcom wrote.

The USPS filed May 3 with the Postal Rate Commission for an average 8.5 percent rate increase. Postmaster General John E. Potter told USPS business customers Sept. 20 that the agency must prepare for a possible May 6, 2007, rate change date.

"We strongly urge the [USPS] to delay implementation and make contingency plans to accommodate those mailers that are simply unable to comply by the implementation date," Postcom wrote.

The association also raised concerns with the proposed Not Flat Machinable category, which would cover Standard Mail pieces with parcel-like characteristics including rigid pieces that are not flexible and not of even thickness.

Today, Standard pieces with parcel-like characteristics qualify as automation flats under USPS guidelines and are handled as parcels, especially at delivery. Under the proposed standards, these pieces would be presorted, entered and processed as parcels.

"The potential consequences of these changes on mailers' ability to meet the various other preparation and entry requirements of the new categories has not been considered, nor has the potential impact on postal service operations and service," Postcom wrote. "Mailers prepare, presort and drop ship a wide variety of pieces, and the effects on the mailers' abilities to maintain the volumes necessary to presort and drop ship it is simply unknown."

Postcom also urged the USPS to identify characteristics that would cause a mail piece now eligible for Standard letter or flat treatment to be entered as an NFM piece. Also, it said USPS should identify the full range of permissible characteristics of an NFM piece. Postcom wants any NFM category implementation delayed until major issues are resolved.

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