Postcom reader: “Summer sale” raises lots of issues
Seen on Postcom.org:
“From one of our readers on the proposed USPS summer sale:
“Comailed/comingled volume mailed under a vendor’s permit are not credited to the mail owner. Companies who take advantage of comingling efficiencies are penalized under this program. Mail volumes can be manipulated by moving mail from lettershops that comingle to lettershops where the mail owner has permits linked to their own CAPS account.
I’m sure that there are quite a few cominglers who do not support the proposal. There are issues with determining the level of corporate ownership. If our company acquires or divests wholly owned subsidiaries (or business segments) during the entire analysis time frame, the reconciliation becomes a nightmare. Is the discount available on a company basis, a subsidiary basis, or a product line basis within a company?
Most marketing plans (testing, scheduling, and purchasing) are planned months in advance. Direct mail promotion and product inventory issues become paramount. Internal business issues will arise if a division mails deeper into their list assuming the discount will be attained yet if the baseline is not exceeded product lines could falter/fail.
If the program is available only to the top 4,000 customers, I see litigation on the horizon. Within reason, companies will delay some mailings and accelerate others just to fit within the window of opportunity. This does not generate volume. I think it would be simpler, less costly, and less litigious to just delay the rate increase on Standard Mail letters and flats until September 2009 and then implement the summer rate program for 2010.”
