By the time the Postal Regulatory Commission (PRC) had issued its March 26 advisory opinion urging the U.S. Postal Service to take more time to consider the impact of load leveling, the new cost-saving program was a fait accompli. The Postal Service had published the load-leveling service standards for pre-sorters of Standard Mail in the March 5 Federal Register, and put the plan into effect on April 10.
This sequence of events came as no surprise to a number of mailers. Indeed, to many it appeared that the PRC took the full 90 days allotted to deliver its opinion to give the industry as much time as possible to adjust to the new order. “We expected the Postal Service to yawn [over the PRC advisory] and put it through,” says Quad/Graphics Director of Postal Affairs Joe Schick.
Load leveling aims to reduce overtime hours and promote safety for late-working letter carriers by spreading out the heavy volume—up to 50% of which is on Mondays—of Standard Mail deliveries over the entire week. Before the plan, high-volume mailers that presort mail and transport it to Destination Sectional Center Facilities (DSCFs) on Friday could expect actual delivery to homes on Monday, a three-day turnaround. Load leveling, however, sets a new four-day service standard, forcing mailers to accept Tuesday delivery or to get their trucks to DSCFs by Thursday.
Why is Monday the magic day for mailers? “A lot of mailers want Monday delivery because they get a better response rate or have tied it to multichannel promotions,” says Angelo Anagnostopoulos, VP of postal affairs for GrayHair Software. “Some retailers want their weekly circulars in front of people before they go shopping and miss the sale.”
The prevailing sentiment among many mailers is that load leveling was inevitable because the Postal Service was eager to improve efficiency and consolidate some of its facilities—a move delayed while waiting for postal reform that never actually materialized. The PRC’s take was that testing load leveling at one facility was insufficient preparation for the program’s launch and that load leveling could also be interpreted as a further rate increase for mailers. USPS addressed those concerns in its rules posting in the Federal Register.
“Commenters [from the mailer community] focused primarily on the potential for the proposed rule to reduce the predictability and quality of delivery, increase costs for both mailers and the Postal Service, and unreasonably burden many customers,” USPS stated in the daily journal. “However, no commenter offered any empirical basis for the belief that the service change, by itself or in conjunction with recent price increases, could precipitate an accelerated decline in DSCF Standard Mail volumes.”
As a result of the program, direct mailers must learn by doing as they adjust drop-off schedules to make sure their mail is delivered by a particular date.
“Here’s the tricky part,” Anagnostopoulos says. “You can’t just say, ‘I’ll just drop off on Thursday to get delivery on Monday,’ because you may get delivered too early. Upstream, it can affect other processing like commingling and co-mailing, with pools now having to change to get the desired delivery results. We have to look at historical data to gauge the effects of load leveling and make adjustments.”
For the time being, direct mailers will have to accept a system of trial and error. “We just have to make some assumptions at this point,” QuadGraphics’ Schick observes. “Each mailer is going to have to react according to its own particular situation.”
This learning curve promises to come for mailers in July and August, when mail volumes begin increasing ahead of fall and for back-to-school promotions. Without question mailers have a full year of schooling on load leveling ahead of them.