My name is Timothy Freeman and I am President of Printing Industries Alliance. Printing Industries Alliance is a trade association representing the $20 billion graphic communications industry in New York State, northern New Jersey, and northwestern Pennsylvania. A significant portion of the material that is produced by our membership enters the mail stream. I have reviewed 39 CFR Part 111 regarding proposed new standards for letter-size booklets and folded self-mailers and would like to offer the following comments.
Not only does the proposal create new size requirements for self-mailers (i.e., 6x10.5 versus current 6.1x11.5), it also creates production tabbing requirements that can double or triple production time and materials for mailing operations.
Every standard proposed requires a self-mailer or booklet to have tabs on the leading and/or trailing edge. Such configuration requires that the mail piece be passed through the tabbing equipment at least one and sometimes two more times. Currently most printers operate tabbing equipment inline with addressing equipment, and can tab on the parallel edges of self-mailers simultaneous to addressing, making the process cost effective for the customer and achieving compliance with existing tabbing requirements. As proposed, the perpendicular tabbing will require the piece to be passed either through the tabbing equipment independent of the addressing process, or turned and rerun on the same equipment. Additional production time will force most companies to pass along the added costs to customers. This, in addition to the anticipated postage increases, will further reduce mail volume.
Non-perforated tabs, no matter the size, will cause self-mailers to rip on opening. Customers will not accept the use of tabs that will damage their material. Current tabbing media is 0.75-inch clear perforated. The proposed change has two required sizes: 1 inch and 1.5 inches, with 2 inches recommended for booklets. A uniform size should be allowed so companies need not purchase smaller quantities of one or the other just to accommodate the rule change. Purchases in higher quantities are always more cost effective.
In summary, the proposed changes will significantly increase production costs for companies engaged in the printing/mailing of self-mailers. In addition, the larger non-perforated tabs that are being proposed will increase the time it takes to open a self-mailer and the damage that will occur in the opening process. Ultimately these factors will decrease the effectiveness of mail campaigns utilizing self-mailers, and have a negative impact on the volume of material entering the mail stream.
On behalf of our staff we would urge the USPS to reconsider proposed tabbing changes as outlined. Implementing these changes, especially in conjunction with the Mailing Services price change proposed for May 2009, will have disastrous consequences for the printing/mailing industry as well as the USPS.
Very truly yours,
Timothy Freeman, President