Docket No. MC2007-1: WHAT IN BLAZES IS GOING ON HERE?

The following is a perspective by PostCom President Gene Del Polito prepared for the PostCom Bulletin.

One of the essential aspects of the work we do is to follow proceedings that take place before the Postal Regulatory Commission (PRC) even when they don't pertain directly to the core interests of most of our members. Observing and reporting is an important aspect of the information services we offer our members to ensure they are informed of postal developments that can affect their businesses' use of mail as a medium for business communication and commerce.

Perhaps this is a needlessly long-winded way of saying we've been following the proceedings PRC Docket No. MC2007-1 with a relatively dispassionate eye simply for information's sake. Dispassionate, that is, until now. Indeed, some of the conduct in this proceeding has implications for reform postal policy that go beyond the interests of just the immediate participants.

I find more than perplexing the role that the OCA and Valpak have taken in this proceeding. MC2007-1, in essence, is a proposal brought by the Postal Service and a customer, which both have deemed will be in their mutual (and the postal system's) best interests. This should be a matter that involves largely the Postal Service and Bank of America without the involvement of those who seem to want to approach this issue as an opportunity to engage in social engineering.

Neither the OCA nor Valpak seem willing to note that Congress has passed a new postal law that is designed to move the nation's postal business to a more rational, business-oriented plane. Instead, they seem totally justified in their noodling simply because this proceeding was initiated under the old rules framed by the Postal Reorganization Act (PRA) rather than the new world view of things envisioned by the Postal Accountability and Enhancement Act (PAEA). For both parties, let alone the PRC, to address this case as if Congress had not repudiated the old business model that underlaid our nation's postal system for the past 35 years for the sake of something better is sheer folly.

Neither the constituencies represented by the OCA nor Valpak face any real danger in the MC2007-1 proposal. Who, in heaven's name, has ordained either of these parties to dictate how the Postal Service should structure its relationship with customers who are willing to conduct business in a manner that should benefit the system as a whole? While perhaps the PRC is used to seeing the OCA taking on the postal nannie role, what possibly can be Valpak's motivation here?

I can think of only one. Valpak is using this proceeding as its proxy war against those who compete more directly with it, like say, Advo(?). Valpak must live in the fear that Advo may be able to craft some future agreement with the Postal Service based on volume and revenue growth that Valpak could not match.

Well, if there is any truth to this assumption, the PRC shouldn't be diverted from its new role of ensuring that postal products and services remain fully compensable without cross-subsidy. If Valpak wants to engage in a proxy war, perhaps it should move to another venue.