Monday, May 21, 2007
Moyers on Postal Ratemaking
by Tom Bozzo
Moyers describes the situation as follows:
Perhaps more to the point, The Nation L.P., which publishes The Nation, is a member of the Magazine Publishers of America, one of the more active of the 60 participants. Several other publishers directly intervened, as did another trade association representing Periodicals mailers. So there was, in fact, an extensive airing of differences between (in MPA's words) "efficiency hard-liners" seeking maximal reward for publications prepared to have low processing costs for the Postal Service, parties who wanted to limit the recognition of cost differentials in rates on fairness grounds, and parties such as MPA who sought a middle ground that would encourage efficient mailing practices while mitigating "rate shock" on small mailers. Additionally, the direction of rate design had been extensively previewed in a complaint case brought by Time Warner in 2004. So it's just not accurate to say that there wasn't diverse input from the interested public.
All thrilling stuff, I'm sure, but that's life under the Administrative Procedures Act for you.
Usually, I stay away from blogging about postal issues, even though it's theoretically my area of expertise, to avoid work-related conflicts. But I see via Avedon Carol that Bill Moyers contributed a short article to The Nation — I am a print subscriber, BTW — regarding the claimed effect of Periodicals rate increases on small publishers, and Moyers' short piece has some issues that go in large part to the postal rate-setting process itself, regarding which I don't suppose many people are very well-informed. (Also a h/t to Tom C. in NYC for forwarding another account of the situation. There are significant and very complex economic and other regulatory policy issues involved as well, which are well beyond the scope of this post.)
Moyers describes the situation as follows:
An impending rate hike, worked out by postal regulators, with almost no public input but plenty of corporate lobbying, would reward big publishers like Time Warner, while forcing these smaller periodicals into higher subscription fees, big cutbacks and even bankruptcy. [Emphasis added.]In any regulatory proceeding, "public input" may not quite be of the Springfield town meeting variety. Still, the rate case that led to the controversial Periodicals changes involved 60 "intervenors" representing various interests — large and small mailers, competitors to the Postal Service, and even a couple members of the public who regularly participate on their own time. Intervening in Postal Regulatory Commission proceedings is just about as easy as sending a letter to the Commission's secretary. Thanks an excellent electronic docket section, it's also easy and inexpensive (except in one's time) to follow proceedings online. It's not hard for interested parties to have their say.
Perhaps more to the point, The Nation L.P., which publishes The Nation, is a member of the Magazine Publishers of America, one of the more active of the 60 participants. Several other publishers directly intervened, as did another trade association representing Periodicals mailers. So there was, in fact, an extensive airing of differences between (in MPA's words) "efficiency hard-liners" seeking maximal reward for publications prepared to have low processing costs for the Postal Service, parties who wanted to limit the recognition of cost differentials in rates on fairness grounds, and parties such as MPA who sought a middle ground that would encourage efficient mailing practices while mitigating "rate shock" on small mailers. Additionally, the direction of rate design had been extensively previewed in a complaint case brought by Time Warner in 2004. So it's just not accurate to say that there wasn't diverse input from the interested public.
All thrilling stuff, I'm sure, but that's life under the Administrative Procedures Act for you.
Labels: Postal Service, Regulation
