Mailer Groups Seek to Change PRC Ratesetting Proposal

In the latest installment in what’s become a years-long rulemaking by the Postal Regulatory Commission, a trio of industry associations has asked the PRC to delete a provision of its most recent proposal.

A brief recap

As required by the 2006 Postal Accountability and Enhancement Act, the PRC began a review of the act’s rate-setting process in December 2016, and produced its conclusions in December 2017.  Finding that the process did not reach the objective of allowing generation of sufficient revenue for the Postal Service to be financially stable, the commission proposed a series of revisions to the process in a subsequent rulemaking.  (Consideration of the underlying cause of the financial instability – the outsized prefunding requirement – was not within the PRC’s chartered purview.)

The proposals in the rulemaking centered on rate increases greater than would be allowed under the CPI-linked cap, and were roundly opposed by commenters.  The PRC retreated and developed a revised proposal, published in December 2019, but it also focused on allowing rate increases larger than what the CPI cap would allow.  Industry reaction to the redesigned proposals was again strongly negative.

Earlier this year, with the commission’s next steps unknown and the COVID pandemic blossoming, industry associations asked that the PRC defer further action on the rulemaking to “ensure that any Commission order issued in this proceeding will reflect the significant … changes that are likely to result from the current emergency.”

Twice the PRC denied motions to suspend the rulemaking, responding that there were no pending actions or procedural deadlines to defer, but adding that “[s]hould any substantive issues develop that would affect the Commission’s evaluation of the revised proposal, the Commission will address those issues at that time.”


On July 2, three associations, MPA (The Association of Magazine Media), the Alliance of Nonprofit Mailers, and the Association for Postal Commerce (PostCom) filed “supplemental comments” stating:

Now is the time.  The postal world (indeed, the entire world) has significantly changed in the nearly four months since the public comment period in this docket closed on March 4.  So material is this change that the administrative record in this case must be updated to reflect it.”

...this article continues in the July 6 issue of Mailers Hub News

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