In comments filed February 3 with the Postal Regulatory Commission in response to the PRC’s proposed rule (System for Regulating Market Dominant Rates and Classifications, published in the December 11, 2019, Federal Register), Mailers Hub offered a view about “non-compensatory products,” (market-dominant products whose rates do not cover costs). The passage discussing such “underwater” rates was also excerpted in the February 3, 2020, issue of Mailers Hub News:

“Most non-compensatory classes and products did not become ‘underwater’ in a year or two or even ten; Periodicals, as a class, for example, hasn’t covered its costs since the PAEA was passed.

“… Aside from the resistance of ratepayers in those classes or for those products to accelerated rate increases to bring them to full cost coverage, the PAEA itself thwarted such efforts; the CPI cap is a two-edged sword that keeps rate increases to no more than CPI but also prevents larger rate increases to correct ‘underwater’ classes and products. …

That cost coverage for non-compensatory classes and products needs to be brought to 100% is not debatable, but neither is the need for caution in how that’s to be done. … Though the price sensitivity of most non-compensatory mail will be challenged by an additional 2% per year rate increase above the CPI cap, requiring that seems the least than can be done.