Will the U.S. Postal Service ever learn how to create sensible regulations, or will it continue to find new ways of making the same mistake over and over again?
The latest example of the Postal Service’s regulatory two-step came Friday with the announcement of indefinitely delays to "Full-Service eDoc postage corrections" -- that is, denial of Full-Service Intelligent Mail barcode discounts because of alleged errors -- which were supposed to be implemented on Jan. 2. The ostensible reason was “to give mailers more time to use information from a new report to help correct errors in their electronic documentation,” but there’s more to the story than that.
“The USPS needs more time just as much as, if not more so, than the mailers,” wrote Lisa Bowes, who has reported extensively on Intelligent Mail trials and tribulations at Intelisent’s Postal Affairs Blog. “Making mistakes is a part of learning, but the USPS needs to also learn and try not to repeat its’ mistakes. Setting dates without adequate time to test and implement keeps biting everyone over and over again.”
We’ve seen this dance before, and not just with Intelligent Mail: USPS announces when a new regulation will be implemented, mailers point out flaws with the regulation or the implementation timetable, postal officials forge ahead as planned, and then at the last minute someone at postal headquarters avoids disaster by pulling the plug.
A classic case of poorly considered postal regulations came early last year when USPS announced that the specifications for window envelopes would be changed within a few months, making all currently standard formats illegal. (See It's Curtains for the Window Envelope.) If the bureaucrats who crafted the language had spoken to a few mailers first, they would have realized that their plan would have sent billions of inventoried envelopes and forms to the dumpster.
Fortunately in that case, the proposed regs were taken off the table after only a few days. Unfortunately, the Postal Service has apparently done nothing since then to start the process of getting mailers to switch to window envelopes that work better on letter-sorting machines.
Mailers and their vendors have been saying for months that the Postal Service’s information systems were not ready for it to assess noncompliance penalties for Full-Service Intelligent Mail barcodes (aka FUBAR codes). But in this case, all of the brave "Mission Accomplished" talk from Intelligent Mail executives apparently prevented L’Enfant Plaza from realizing the truth until the eleventh hour.
I’m not saying mailers have to approve or even like every postal regulation. But the Postal Service could anticipate and avoid many problems merely by listening to mailers instead of assuming we’re just a bunch of whiners.
Implementation of the Flats Sequencing System shows how dialog with mailers and mail service providers can help the Postal Service avoid disaster. For example, by discussing its plans for FSS facilities with publication printers a few years ago, postal officials learned that some of the buildings didn’t have enough loading docks or highway access.
The FSS plan originally envisioned all flats being addressed on the top of the back cover, which would have ruined magazines’ most valuable advertising space. The final regulations ended up allowing upside-down addresses at the bottom of the front cover, which met the Postal Service’s needs while causing only minor grumbling among publishers.
Mailers and postal officials have worked together in developing mail-preparation standards that are achievable at the printing plant and should help the FSS facilities operate more efficiently. Declining flat-mail volume and balky machines are big enough challenges for the FSS program, but at least it’s not being hampered by uncooperative customers.
Other articles about Intelligent Mail fiascoes include: