The U.S. Postal Service (USPS) on March 12, 1996 published
in the Federal Register its final rule on mail classification
implementation standards. These regulations are slated to be
implemented on July 1, 1996. The USPS previously outlined its
proposed implementation standards in two separate Federal
Register notices in July and August 1995, and again as a
proposed rule published in December 1995. AMMA submitted
comments in each instance. (see AMMA Bulletins 33-95, 42-95
and 1-96 for further background).
The following are highlights of the USPS' final ruling on
some of the significant mail classification reform mailing
standards. A complete version of the revised mailing
standards contained in the Domestic Mail Manual (DMM) was
distributed by the USPS in a March 11, 1996 special Postal
Bulletin (PB 21914A). The DMM revisions are also contained in
the March 12, 1996 Federal Register, which can be obtained
electronically via AMMA's 24-hour computer bulletin board,
AmericaPost, at (202) 347-5127 in the MC95-1 file area under
the filename FIN_STDS.TXT (for the ASCII text version of the
rules), FIN_STDS.PDF (for the Adobe Acrobat version of the
rules), NEW_RATE.TXT (for the ASCII text version of the rate
schedule changes), and NEW_RATE.PDF (for the Adobe Acrobat
version of the rate schedule changes). To obtain a hardcopy
version of the Federal Register notice, call AMMA at (202)
347-0055.
Scheme Presorting
In its final rule, the USPS revised its
proposed standards, making 3-digit scheme presort for
automation letters required, rather than optional as
originally proposed by the USPS and supported by AMMA and
others. The USPS reiterated in its final rule that 5-digit
scheme presort for automation letters will not be available
at the time of mail classification reform implementation on
July 1, 1996, and rejected AMMA's suggestion that a work
group be formed to discuss the obstacles to implementing
5-digit scheme sorts for automation letters. In addition, the
USPS indicated that a 5-digit scheme sort for automation
flats "is not foreseeable in the near future." The
USPS did state, however, that a 3-digit scheme sort for
automation flats is feasible and that it has begun work on
developing such a sortation scheme, which it stated should be
available in 1997.
Mailings of 100 Percent
Barcoded Mail
The USPS did not revise its position
concerning the requirement for 100 percent barcoded mail for
automation mailings in First Class and Standard Class, and
extended the requirement to automation (barcoded rate)
mailings within the Regular Periodicals subclass.
Changes To The AIS Product
Cycle
In its final rule, the USPS retained the
standards increasing the frequency at which it updates all of
its AIS (Address Information Systems) products to bi-monthly,
beginning with the October 15, 1996 product updates.
Thereafter products will be released on December 15, February
15, April 15, June 15, and August 15. The USPS also retained
the standard requiring mailers to implement all new AIS
product releases within 45 days of their release date.
Matching Addresses To Current
CRIS File
Within 90 Days Of The Mailing
The USPS also retained the standard
requiring that mailers update carrier route information
within 90 days of the mailing date for carrier route mail.
150-Piece Minimum Requirement
To Qualify For Automation/Presort Rates
The USPS, after a lengthy discussion of
comments received from AMMA and others opposing this
standard, maintained its position in defining full trays as a
minimum of 150 pieces rather than a physically full tray.
Under this required standard, mailers must have a minimum of
150 pieces to a 5-digit ZIP code or 3-digit ZIP Code
destination (scheme combination, where required) in order to
qualify for the 5-digit or 3-digit automation rates. Mailers
also must have a minimum of 150 pieces to a 3-digit area to
qualify for the 3/5 nonautomation Regular Standard rates.
The USPS in its final rule stated its belief that applying
the 150-piece minimum to an entire 3-digit area to qualify
for 3/5 nonautomation Regular Standard rates "will, on
average, result in comparable or better rate qualifications
when compared to current qualification criteria, even for
heavier pieces of mail." According to the USPS'
rationale, currently the 125-piece/15-pound sacking rules are
applied separately to 5-digit sacks and to 3-digit sacks. If,
for example, a mailer had heavier weight pieces currently
meeting the 15 pound requirements with 75-80 pieces of mail
to an individual 5-digit or 3-digit sack, that mail would
still be able to meet the 150-piece requirement per 3-digit
area in instances where they had an equivalent number of
pieces that are now contained in two 5-digit sacks for the
same 3-digit area, or in other combinations of 5-digit and
3-digit sacks for the same 3-digit area.
Line-of-Travel Sequencing
The USPS retained its standard requiring
Standard Mail Enhanced Carrier Route basic carrier route mail
to be prepared in line-of-travel sequence (or walk-sequence
at the mailer's option). Walk-sequencing will be required for
Enhanced Carrier Route mail prepared at the High Density and
Saturation rate levels. No additional sortation beyond
carrier route sort will be required for the Enhanced Carrier
Route automation (barcoded) basic letter rate. The USPS also
remained steadfast in its position to identify mailers whose
mailings are frequently prepared in reverse line-of-travel
order (descending vs. ascending) and work with them to ensure
mailings are presented in the proper order.
Availability of ECR Basic
Automation Rates
In its proposed rule, the Postal Service
had included a draft list of approximately 3,935 destinating
five-digit ZIP Codes where Enhanced Carrier Route automation
basic letter rates will not be available. The USPS made no
revisions to this provision in its final rule and rejected
recommendations made by AMMA to publish the ineligible ZIP
Code list on its computer bulletin board system, RIBBS, or to
make available to mailers its automation equipment deployment
schedule so that mailers could anticipate and plan for
additions to the ineligible 5-digit ZIP Code list. The USPS
stated that obtaining information as to which are the
permissible ZIP Codes for automation carrier route rates will
be done at the same time as addresses are matched to the
applicable CRIS, ZIP+4 or other USPS AIS product that
contains carrier route codes.
One- and Two-Foot Trays For
Letter Preparation
The USPS maintained and clarified its
proposed requirement that mailers utilize both one-foot and
two-foot trays for letter mail preparation, but revised the
standard for preparation of nonautomation mailings. For
automation and upgradeable mailings of letter-size (other
than card-size) pieces, the USPS would like the fewest number
of packages, which are only prepared in less-than-full trays.
Accordingly, for these mailings, the USPS will require that
"when the mail remaining after filling all possible
two-foot trays exceeds the physical capacity of a one-foot
tray, but is less than the minimum quantity for a full
two-foot tray, mailers must place this mail in two one-foot
trays (a full one-foot tray without packaging, and a
less-than-full one-foot tray with packaging)."
For nonautomation letter-size mailings and for automation
and upgradeable mailings consisting entirely of card-size
pieces (which are prepared in banded packages), however, the
USPS would like to receive the fewest number of trays.
Accordingly, for these mailings, the USPS will require that
"when the mail remaining after filling all possible
two-foot trays exceeds the physical capacity of a one-foot
tray, but is less than the minimum quantity for a full
two-foot tray, mailers must place this mail in a single
less-than-full two-foot tray."
According to the USPS' final rule, if local shortages of a
particular tray size develop, mailers will have to use the
size tray available, and working out "individual mailing
solutions locally."
Barcoded Sack and Tray Labels
The USPS revised its standard requiring
the use of barcoded sack and tray labels for automation First
Class and Standard Mail to include a phase in period, and to
extend the requirement to include mail prepared at automation
Periodicals rates. Effective January 1, 1997 the USPS will
require the use of barcoded sack and tray labels. In
addition, the final rule makes changes to the barcode tray
and sack label specifications and revisions to the Contents
Identifier Codes used on the labels, which are included in
the DMM revisions section of the final rule (also available
in special Postal Bulletin issue 21914A, dated March 11,
1996).
PAVE Software or Standardized
Documentation
The USPS revised its final rule to
include requirements for "standardized
documentation". The final rule requires the use of
PAVE-certified software or standardized documentation when
preparing mailings under any of the reformed subclasses. DMM
Section P012 is revised to include required elements and
format for standardized documentation. In addition, the USPS
states that PAVE test files will be available to software
vendors on March 22 for First Class and Regular Standard
letters and flats categories, and on March 29 for Enhanced
Carrier Route Standard categories. Test files for Regular
Periodicals will not be available until early summer as a
result of the significant changes made to the quality and
preparation standards in this category from those published
in the proposed rule, and, therefore, the standard for use of
PAVE software or standardized documentation for Regular
Periodicals will not be required until January 1, 1997.
Grouping of Pieces In AADC
Trays
The USPS revised its standards requiring
mailers to group pieces in mixed-AADC trays in automation and
upgradeable letter mailings by AADC, and, within each AADC
group, by 3-digit ZIP code. The requirement now states that
mail in these mixed-AADC trays will be required to be grouped
only by AADC area.
CASS Report Requirements
The USPS added in its final rule a
requirement for mailers to submit a Form 3553, CASS Report,
with automation carrier route First Class, automation and
nonautomation Enhanced Carrier Route Standard Mail, and
carrier route Regular Periodicals.
Tray Sleeving/Strapping
The USPS has revised its standards
concerning tray sleeving and strapping. In its final rule,
the USPS states "there will be no exceptions to
sleeving." Exceptions to strapping of local mail have
been extended to allow such exceptions for mail entered and
delivered within the service area of the SCF serving the
entry post office if approved by local USPS management. The
DMM palletization standards have been modified to make it
clear that only trayed mail on stretchwrapped 5-digit,
3-digit, and SCF pallets are exempt from tray-strapping. All
trays in all circumstances will be required to be sleeved.
For palletized mailings, sleeving will be required to all
trays, but strapping will be required only for trays placed
on ADC, ASF, BMC, mixed-ADC, and Mixed-BMC pallets. Sleeving
and strapping requirements will take effect July 1, 1996.
Move Updating Requirements for
First Class Mail
The USPS revised its standard requiring
move update qualifications to begin the qualification process
at the time of classification reform implementation, but not
to condition the eligibility of First Class and Presorted
First Class mailings on complete move update qualification
until January 1, 1997. The USPS stated in its final rule that
use of move update methods on mailings in other classes would
meet the standard for the addresses in the mailing list and
qualify them for access to First Class automation or presort
rates. Any new addresses added to the mailing list would be
"move updated" during the next scheduled processing
of the addresses. In addition, the USPS anticipates
availability of the Multiline Forwarding System (now renamed
"FASTFORWARD ") with certification of MLOCR
operating systems to occur in summer 1996. The USPS also
revised its standards to allow that, in circumstances where
clearly demonstrated legal constraints limit a mailer from
using address changes provided by the USPS, an individually
approved alternative process (granted by the USPS on a case
by case basis with clearly identified legal limitation) will
be acceptable to meet the move update standard.
Reply Envelopes Contained
within Automation Rate Pieces
The USPS maintained its standard
requiring that, effective January 1, 1997, courtesy or
business reply envelopes or cards included in pieces mailed
at First Class and Standard Mail automation rates must be
automation-compatible and bear a facing identification mark
and a correct barcode. In addition, the USPS revised its
standard to include automation Regular Periodicals mail.
Mailers will be required to certify, by checking a box on the
"postage statement" (formerly called the
"mailing statement") and signing the statement,
that enclosed reply pieces are properly prepared when the
mailing is presented to the post office. According to the
USPS' final rule, "it will be up to mailers to work with
their customers and advertisers to ensure that reply pieces
provided to mailers comply with the standards for barcoded
reply pieces." If mailers cannot certify that this
standard has been met, or if noncomplying reply pieces are
found within the outgoing mailing, the mailing may not be
mailed at the automation rates and must pay the higher
nonautomation rates.
In addition, the final rule revises the USPS' position to
indicate that ZIP+4 barcodes will be required for business
reply mail and that courtesy reply mail must bear the correct
delivery point barcode for the delivery address as defined by
the Postal Service. Unique 5-digit and ZIP+4 barcodes
provided by the USPS for use with courtesy reply mail will be
considered valid delivery point barcodes.
Changes to Class/Rate Markings
The USPS revised the standards in its
final rule to allow mailers to continue using the current
"Presorted First-Class" and "Bulk Rate"
or "Blk. Rt." markings for First Class and Standard
Mail respectively. The USPS has, however, revised the
requirements for class markings, mailing markings and rate
markings. In most cases, class markings must appear in the
postage area. Where required, rate markings--such as
"AUTO", which is required on all pieces in
automation First Class, automation Regular Standard, and
automation Enhanced Carrier Route Standard mailings--may
appear in the postage area, on the top line of the address,
or--for MLOCR users--to the left of a barcode in the lower
right corner of the mailpiece or to the left of a date
applied by the MLOCR in the postage payment area. Other
requirements for rate markings are included in the final
rule.
Banding Material
The USPS revised its standard
prohibiting plastic strapping and string from being used as
banding materials on certain mailings. The current options of
banding materials for packaging mail will remain in effect,
however the USPS stated its intent to require the use of only
rubber bands or elastic strapping for automation mailings at
a future date, and said that it will work with mailers on the
timing of this future standard revision.
Weight Breakpoints
The USPS clarified its position
concerning the minimum per piece rate weight breakpoints, and
revised its standard for weight breakpoints determining
barcode letter rate eligibility. Separate weight breakpoints
exist for the Regular, Enhanced Carrier Route, and Nonprofit
subclasses in Standard Mail. These breakpoints determine when
mailers pay either the minimum piece rate or the pound rates.
The USPS has not revised these breakpoints from its proposed
rule.
For barcoded letter rate eligibility, however, the USPS
sets a maximum weight based on operational and administrative
criteria. In its proposed rule, the USPS had set a different
barcoded letter rate maximum weight for First Class and for
Standard Mail. AMMA stressed that the USPS handles barcoded
letter mail in the same operational manner regardless of
class, therefore one maximum weight should apply. The USPS
has revised its standard to allow First-Class and Periodicals
letter mail weighing up to the higher Standard Mail weight
breakpoint to be eligible for barcoded letter rates (provided
that such mail meets all other standards for that rate) to
afford as many mailers as possible the highest weight cut-off
for automation letter rates.
Definition of a Mailing
The USPS clarified its standards
concerning the definitions of a "mailing" and a
"mailing job", as well as the requirements for
mailing minimum quantities and preparation of mailing
statements. According to the USPS in its final rule, the
Domestic Mail Classification Schedule approved by the USPS
Board of Governors specifies separate 500-piece minimum
quantity standards for the following First Class mailings:
(1) Letters and Sealed Parcels Automation, (2) Cards
Automation, (3) Letters and Sealed Parcels Presorted, and (4)
Cards Presorted.
For Standard Mail, separate minimum quantity standards of
200 pieces or 50 pounds apply to each mailing of Standard
Regular and Enhanced Carrier Route rate mail. The USPS
further has determined that, due to operational differences
in the way mail is handled, automation mail and nonautomation
mail must be prepared and presented as separate
mailings--with separate minimum quantity standards. So, for
Standard Mail, separate minimum quantity standards apply for
mailings of (1) automation Enhanced Carrier Route, (2)
nonautomation Enhanced Carrier Route, (3) automation Regular,
and (4) presorted nonautomation Regular. If, after preparing
one or more of the above mailings within a class, mailers are
left with a quantity of pieces that do not meet the minimum
quantity standards for First Class Presort or Standard Mail
Regular, such pieces must be mailed at single-piece rates.
The USPS further defined a "mailing" as consisting
of a group of mail of the same class and subclass which will
be processed in the same manner by the USPS, which is
submitted to the USPS for verification at the same time.
Separate mailings of the same class of mail and in the same
"mailing job" that are presented for verification
at the same time may be claimed on a single postage (formerly
mailing) statement, but separate documents describing each
mailing will be required with some exceptions.
Destination Delivery Unit
Discount Revisions
The Postal Service retained its proposed
standard requiring mailers to take destination delivery unit
(DDU) drop ship carrier route sorted mail to the postal
facility where sequencing is performed for the carrier route
serving the delivery address on the mailpiece (which could
differ from the facility where the carrier is located). This
revision applies only to barcoded carrier route letter mail.
Mailers of Periodicals and of Standard letters mailed at
other than automation Enhanced Carrier Route letter rates
will continue to drop ship their mail at the destination
where the carrier is located. For automation Enhanced Carrier
Route letter mail, however, mailers will be required to drop
their mail at the postal facility where the mail is
sequenced. According to the USPS, "[m]ailers may contact
the appropriate USPS district drop shipment coordinators to
determine the sites where this mail should be dropped to
obtain DDU discounts." The USPS plans to incorporate
this information in its AIS Drop Shipment product in the
future.
Palletization of
"Fletters" in Packages
In its final rule, the USPS revised its
position allowing mailers of "fletters" at the
flats automation rates to prepare that mail as packages on
pallets. Under the USPS proposed rule, if a portion of the
mailing job consisted of "fletters" being mailed at
automation flats rates, and was prepared as an automation
flats mailing as packages on pallets, the USPS would allow
the entire mailing job (which could include Enhanced Carrier
Route and nonautomation Regular Standard mail) to be prepared
as packages on pallets if no more than 10% of the total
number of pieces in the mailing job were claimed at
nonautomation Regular rates and provided the pieces claimed
at the nonautomation Regular rates were paid at non-letter
rates. In its final rule, the USPS revised this standard to
be terminated after January 1, 1997.
In response to an appeal from AMMA, however, the USPS has
indicated that it will publish a correction in the final rule
removing the January 1, 1997 termination provision for this
standard, and will continue the standard indefinitely.
Preparation of Entry-SCF Mail
The USPS revised its final rule to
require preparation of less-than-full 3-digit trays or sacks
only for the 3-digit ZIP codes served by the SCF of the post
office where the mail is verified. These trays or sacks would
be optional for other entry points. Other revisions in mail
for the entry-SCF are included in the final rule.
