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DEVELOPMENTS MAY WEAKEN INDUSTRY SUPPORT OF IMB

The following is a report...and comment...prepared by Kathleen Siviter (President, Postal Consulting Inc.) for the PostCom Bulletin.

The USPS on August 21, 2008, published in the Federal Register its final rules for Implementation of New Standards for Intelligent Mail barcodes (see PostCom Bulletin 33-08). Although the 16-page final rule included a commitment from the USPS that it will recommend to its Board that a two-tier automation pricing structure be put into place in fall of 2009 that will include "lower prices for letters and flats that require a barcode and that are eligible for the full-service use of Intelligent Mail," customers are beginning to question the value proposition of IMB adoption as more unknowns continue to surface. The final rule also states that use of POSTNET barcodes will be extended until May 2011, and includes an outline of IMB implementation and options effective in May 2009 as well as responses to technical issues.

The final rule is effective May 11, 2009. PostCom recaps changes in the final rule below as well as reports on other recent developments, but encourages members to closely review the full rule as well as supporting documentation posted on the USPS’ web site (see below).

IMB Implementation Time line

The USPS noted in its final rule that it has pushed back its mandatory IMB implementation time line as a result of comments from mailers that "questioned the readiness of mailers, software and hardware vendors, and the Postal Service to support full-service use of Intelligent Mail barcodes by May 2009."

Although the USPS insisted in its final rule that it will be ready to support use of Full Service Intelligent Mail option in May 2009, it said it is "aware of the technological challenges that the mailing industry faces."

"We will continue to work closely with the mailing industry to ensure a successful implementation," the USPS noted. "We recognize that mailers need time to incorporate vendor-supported solutions and must establish budgetary priorities," it said, "[t]herefore, Intelligent Mail barcodes will not be required for automation prices in May 2009." The USPS said it will "offer the benefits to those mailers who are ready for full-service in May 2009."

Two IMB Options in May 2009

The USPS in its final rule noted that beginning in May 2009, it will offer two options for using Intelligent Mail barcodes: the Basic option and the Full Service option. As previously proposed, the Basic option includes use of an IMB that contains routing information for the delivery address but does not require the barcode to uniquely identify the mailpiece. The Full Service option requires use of unique IMB on mailpieces, IM tray barcodes and IM container barcodes, and electronic submission of postage statements and mailing documentation.

Beginning in May 2009, "customers who qualify for the full-service Intelligent Mail option" will be offered the following "benefits," the USPS noted in its final rule: "Start-the-clock information at no additional charge to notify mailers when USPS takes possession of mailings; and Address correction information at no charge for qualified letters and flats that do not have the most current address or that are undeliverable for other reasons, when those pieces are endorsed as specified for OneCode ACS."

The USPS clarified that in May 2009, "all First-Class Mail, Periodicals, Standard Mail, or Bound Printed Matter (BPM) letters and flats requiring a barcode will be eligible for the full-service option if the pieces bear Intelligent Mail barcodes and meet all other full-service option requirements."

Pricing Details Still to Come

The USPS stated in its final rule that customers have asked it to provide information about the pricing structure for Intelligent Mail barcoded pieces, both for the Basic and Full Service options. "Most of these commenters stated that this information is needed to evaluate the financial costs and benefits of implementing the full-service option

by May 2009," the USPS noted. The USPS re-capped a variety of recommendations from customers and associations relative to how it could provide pricing information and how those prices should be structured.

In response, the USPS said that "[t]he benefits of Intelligent Mail reside in the enhanced value of the information-enriched mailstream, rather than in any prices that may accompany the Intelligent Mail barcode’s introduction." "While we understand that a number of factors affect how rapidly our customers adopt this new technology, we want to ensure that mailers focus on the groundbreaking nature of the Intelligent Mail barcode itself," it said. It continued,

"Responses to our Federal Register proposed rule revealed that there are wide variations in preparedness. Given the variation in mailers’ readiness, and the current state of the economy, we want customers to adopt the new technology at their own pace. We do not want the implementation of any price to be interpreted as a mandate to adopt the full-service option in May 2009.

As we noted in our proposed rule, the Postal Service typically does not comment on specific prices in advance of a general price change announcement. As part of our price adjustment announcement in 2009, we will recommend to the Board of Governors that there be two automation pricing tiers, with lower automation prices in the Fall of 2009 for letters and flats that require a barcode and that are eligible for the full-service use of Intelligent Mail. We also will announce prices for related services as part of the annual price adjustment announcement."

The USPS went on to reiterate that it believes "that the benefits of the information-enriched mailstream will be evident to most mailers and that they will determine that those benefits (those included in the full-service option as well as the internal uses of the data generated for the mailer through use of the Intelligent Mail barcode) will be worth their investments."

Mailers reading between the lines of the Postal Service’s comments are becoming more concerned that the USPS does not realize the importance of offering a significant price differential for the Full Service IMB option. Many mailers have already spent millions on the assumption that they will achieve a positive ROI based on a significant Full Service price differential. Now they are becoming less confident that will happen and some are putting the brakes on IMB readiness until the USPS unveils the details of its IMB prices, which is expected to occur in January/February when the USPS announces its annual price changes.

POSTNET Barcodes Allowed Until May 2011

The USPS in its final rule noted that in response to mailer requests, it will continue to allow POSTNET barcodes on automation letters and flats until May 2011. The USPS previously had proposed discontinuation of POSTNET barcodes in May 2010, but the final rule extends the use of POSTNET until May 2011. "However," the USPS noted in its final rule, "effective May 2009, we will require all automation flats to bear barcodes that include delivery point routing codes, as currently required for automation letters."

Other Full Service IMB Benefits

Concerns also were raised by customers about the address correction information and induction information that the USPS said it will provide at no charge with the Full Service option. In addition to asking for more detail, commenters asked the USPS to address issues related to customer costs, value of the data, and maturity of the data feedback system proposed by the USPS.

The USPS said that it will provide "automated address correction notices for letters and flats and start-the-clock information for mailings prepared under the full-service option." "Mailers will receive actionable address correction information so that the right mailpiece is delivered to the right recipient at the right time," the USPS noted, which it said "improves mail quality and the return on investment of mailings." "Start-the-clock information," the Postal Service responded, "will enable visibility for when a mailing is inducted in the mailstream, allowing participants to bring accountability to the supply chain."

The USPS further stated that because Full Service requires unique identification of pieces and containers as well as electronic documentation, mailers can "automate and improve document management processes, quality control, and hand-off to third party suppliers." Reduction in hardcopy reports and postage statements also was cited by the USPS as a benefit of using Full Service IMB.

Address Correction Information – Free or Sometimes Free?

As a result of comments from postal officials at the last Mailers Technical Advisory Committee (MTAC) meeting and during interim discussions, customers are now uncertain what the USPS intends to provide in terms of "free" address correction information. In its final rule, the USPS stated that it "will provide automated address correction notices for correctly formatted full-service mailpieces that meet OneCode ACS requirements." The USPS said it will provide the information either by downloadable files via the Internet to authorized entities, or via electronic exchange.

As far as whether the address correction information will be "free," the USPS said in its final rule "[m]ailers will qualify for automated address correction notices at no additional charge for mailpieces verified as eligible for Intelligent Mail full service, when mailers use the provided information to update their address records." "Mailers who do not update an address record after notification may incur charges for subsequent notices for that address," the USPS stated. The USPS also stated that "[m]ailpieces that are ostensibly presented as part of full service mailings, but which do not maintain the required uniqueness or fail to qualify for full-service for any reason will not be eligible to receive automated address correction notices at no additional charge." PostCom members report that the USPS is still developing its verification procedures, and there is much still unknown in terms of what price would be assessed for non-compliance, error tolerances, and verification procedures.

These caveats, which were only vaguely mentioned at the MTAC meeting and not included in the USPS’ proposed rule, have raised numerous concerns with customers that have built their ROI projections for using Full Service IMB based on the assumption that the address correction information would be free. Coupled with the growing doubt that the USPS will price Full Service IMB in a way that recognizes the capital investments made to meet the requirements, customers are becoming alarmed that they will not be able to achieve any positive ROI from IMB adoption.

Some PostCom members report that the USPS is considering free address correction information for First-Class Mail with no time limit, but for Periodicals it would only be free for 60 days from the first notification, and for Standard Mail it would only be free for 30 days from the first notification.

Mailers find such a concept untenable, and are outraged that the USPS appears to be backing off on the commitment made in its proposed rules, as well as during many customer discussions, that the address correction information would be provided at no charge. For many mailers, the existing 95 days allowed for the Move Update requirement is only just attainable in complex supply chains that often include multiple parties performing multiple list functions and address maintenance. The USPS has seen the difficulties mailers have in moving from the 185 day Move Update compliance requirement to the 95 days, and should respect that customers need at least 95 days to meet such requirements.

Start-the-Clock Information

PostCom and others had raised numerous issues around the start-the-clock information the USPS said it would provide with Full Service IMB. The USPS responded that it "will provide information about when the mail is inducted into the mailstream," including "[a]ll available induction scan data." The information will be provided via an online method or an electronic data exchange capability, the USPS said.

The USPS did not respond to concerns raised by PostCom and others that providing container scan data "when available" (i.e., perhaps only ten percent of containers, per past performance of the USPS’ container scan rates) provides little value to mailers. PostCom had recommended that quality metrics be put in place to track and measure the USPS’ scan performance, as well as other quality assurance processes.

And a Big Surprise for Flats...

Mailers of flats have been taken completely unaware in that the USPS stated in its final rule that it will "consider including carrier route flats as eligible for full-service benefits in the future." Industry-wide assumption was that carrier route presort flats were included in the USPS’ IMB implementation and would be able to take advantage of the benefits in May 2009.

Flats mailers had included their carrier route presort pieces in their ROI calculations for capital investment in IMB – without the free ACS and price differential on a high percentage of their mailings, that ROI is wiped out. Catalogers and other flats mailers are urging the Postal Service to seriously consider the impact of this change on an already-weakened industry.

Confirm Service

PostCom and others had requested that the USPS maintain the existing Confirm service, allowing mailers to use either IM barcodes or PLANET codes to access mailpiece tracking information. "We agree that Confirm provides

information that improves the value of mail for customers;" the Postal Service said, "this is consistent with the Intelligent Mail vision." "Any changes in the pricing or availability of Confirm would be pursued separately," it stated in its final rule.

"This notice reiterates the availability of OneCode Confirm through the use of a Service Type ID in the Intelligent Mail barcode," the USPS said, "and does not change the existing ability of authorized third parties to receive Confirm data."

In response to questions raised by PostCom and others about the future of PLANET Code barcodes, currently used for Confirm service, the USPS said it "will retain the PLANET Code barcode for Confirm service as long as we continue to allow the POSTNET barcode for automation price eligibility."

Technical Requirements

The USPS noted that a primary concern voiced in the comments to its proposed rule was the need for "final technical requirements that would allow vendors to supply new software and hardware that will enable mailers to print high-quality barcodes and provide electronic documentation via Mail.dat. or Mail.XML (replacing Wizard Web Services)." It noted that many commenters said that vendors may need "six to twelve months to develop, test, and finalize their products, followed by additional testing and implementation time for mailers."

"This final rule contains the final mailing standards for basic and full-service use of Intelligent Mail barcodes," the USPS said. "A Guide to Intelligent Mail Letters and Flats (the Guide), available on the USPS Web site at ribbs.usps.gov, provides direction on how to implement the technical requirements." The USPS noted in its final rule that the guide "has been updated to reflect changes to support the full-service option."

It should be noted that this is the guide previously titled "Guide to Electronic Documentation and Appointments for Full-Service Mailings" in the USPS’ earlier proposed rule (or as commonly referred to by industry, the "e-doc guide"). It should also be noted that although the USPS’ final rule states that the guide has been published on the USPS’ web site (above), the version of the guide currently published there (as of the writing of this article) is not the final version – or even the most recent version – of the guide. According to PostCom members active on the workgroup tasked with providing industry feedback on the IMB technical requirements, the USPS has indicated it is still reviewing the guide, with no date yet provided as to when it will publish a final version. With a May 2009 implementation planned by the USPS, the clock is counting down with currently less than nine months to go.

Mailer ID. The USPS noted that in response to concerns raised by customers to streamline and improve its Mailer ID application process, it has simplified the application form and will allow mail preparers to obtain IDs for mail owners via a redesigned application form available online.

PostCom and others also had raised concerns with the USPS existing process which required separate Mailer Ids and a separate application process for OneCode ACS, OneCode Confirm, and general use of IM barcodes. The USPS said in its final rule that "[o]ne Mailer ID will be sufficient to access Confirm service, OneCode ACS, and the full service option, except for specific uses of OneCode ACS." It said,

"When a mailer uses the same ACS endorsement on all mailpieces, the same Mailer ID can be used. If a mailer uses different endorsements, such as ‘Address Service Requested’ for some mailpieces and ‘Change Service Requested’ for other mailpieces, a separate Mailer ID may be needed for each endorsement."

The USPS said the guide (see above) "explains the limited circumstances when mailers will need to use a different Mailer ID to support multiple endorsements." The Postal Service said it redesigned the application to remove sections that asked for information customers said were proprietary in nature. It also addressed concerns raised by MLOCR service providers relative to Mailer IDs.

In response to concerns raised about using the mail owner’s Mailer ID vs. the mail preparer’s ID, the USPS said that "[e]xcept for mailpieces with unreadable barcodes that may need to have a replacement barcode applied by a mail preparer, we are reiterating the requirement that mail preparers honor mail owners’ requests to use their Mailer IDs in the Intelligent Mail barcode." "We also retain the requirement," it said, "to identify the mail owner via electronic documentation."

Mailpiece Uniqueness. In response to requests that mailpiece uniqueness be achieved by linking the delivery routing code with the serial number ID, the USPS reiterated its position that as of May 2009, when mailpiece uniqueness is required for full-service, the serial number ID in combination with the Mailer ID and Service Type ID (by class of mail) will be required for mailpiece uniqueness. It noted that "[w]hen mailers separate pieces of

identical weight permit imprint mail by price category, or when the correct postage is affixed to each piece in fullservice mailings of less than 10,000 pieces, mailpieces may have the same serial number on all pieces."

In response to concerns raised by PostCom and others about the requirement to maintain uniqueness for 45 days, the USPS simply stated that because the Mailer ID takes volumes into account (a 9-digit Mailer ID allows up to 1 million pieces with unique serial numbers for a period of 45 days and a 6-digit Mailer ID allows up to 1 billion pieces), mailers should be able to maintain uniqueness for 45 days.

11-Digit Barcode Requirement. PostCom and others raised the issue of how valid addresses for which a ZIP+4 code is not returned by USPS-approved coding software would meet the IMB requirements. The USPS in its final rule said that barcodes with 11-digit routing codes will be required for automation flats in May 2009 and already are required for automation letter barcodes. "The USPS makes a continuous effort to identify and resolve any missing information in its address database," the USPS noted, "[h]owever, not all addresses maintained by the mailing industry represent valid delivery points served by the USPS." "When a mailer has addressed a piece to an address that is not a USPS delivery point, or when the address cannot be matched to the USPS address data, an 11-digit routing code cannot be provided."

"As a reminder," the USPS said, "current DMM standards accommodate situations when mailpieces are addressed for delivery to an address with a unique 5-digit ZIP Code or unique ZIP+4 code."

IMB Print Specifications. In response to concerns raised about the print specifications for IM barcodes, including the height, the USPS said that it understands the "barcode printing concerns and the necessity of maintaining an address area that facilitates use of a 1-inch-high label." "The USPS Engineering and Intelligent Mail Planning and Standards departments have worked extensively with mailer groups over the past 18 months to resolve barcode specification issues," it noted. "Ink jet printer manufacturers also provided recommendations and testing."

"As a result," it said, "the Postal Service revised the barcode specification to reduce the barcode minimum height to 0.125 inch (from 0.134 inch) and the minimum vertical text-to-barcode spacing to 0.028 inch (from 0.040 inch)." "This results in an overall line height that is actually less than the POSTNET barcode requirements," the Postal Service stated. "In addition," it said, "the void spacing maximum (the empty space between print dots that make up a bar) has been doubled from 0.005 inch to 0.010 inch and MERLIN barcode thresholds have been altered to be lower than the minimum heights of the barcode with slightly lower text-to-barcode spacing to allow for printing variations."

"These specifications are final," the USPS said. "Barcode theory and USPS testing indicate that any further reductions in barcode height will erode the readability of the barcode," it said. It continued,

"This issue is due to the physical limitations of creating four different elements within the barcode’s height. In addition, ink jet printer manufacturers are concerned that further reductions in barcode height would exceed the tolerance their equipment can meet.

As an alternative to further barcode dimension changes, the Postal Service has reduced the address block text sizes for barcoded mail. These new dimensions allow a minimum text height of 0.065 inch (0.080 inch was initially proposed). These changes represent significant steps in facilitating address block and barcode printing. Ink jet printer manufacturer feedback to these latest changes has been unequivocally positive."

Container Placards and Barcodes. The USPS in its final rule retained the current two-placard requirement for pallets due to concerns raised about the cost of applying a third placard as the USPS had proposed. "As of May 2009, under the full-service option," the USPS said, "we will require two affixed placards on adjacent sides on the outside of shrinkwrapped pallets." "Mailers who load pallets on trucks must position the pallets so that one pallet placard faces the rear of the truck," it said.

The USPS did not respond, however, to the concerns raised by PostCom and others relative to the proposed requirement that no more than two layers of shrinkwrap cover pallet placards – in fact, it went a significantly negative step in the opposite direction. "We reiterate the importance of having all pallet placards placed so that they are readable and the barcodes may be scanned," the USPS said in its final rule. "We cannot generate or provide scans for placards that are obscured by shrinkwrap," it noted. "In May 2009, for full-service mailings," the USPS stated, "we require that all pallet placards with Intelligent Mail container barcodes be affixed on the outside of shrinkwrap."

PostCom members are voicing their concerns with this new requirement, which was never presented in the proposed rules. "It is unacceptable for any major cost item to be presented to the industry without opportunity for comment and without the USPS exploring the significant impact it will have on many customers," one member said. In order to meet this requirement, most service providers will need to add additional manpower or expensive automation, which negatively impacts their ability to achieve a positive ROI. Although some mail service providers may be able to make such a change in a cost effective manner because of their existing process design, for many it represents a significant cost.

The USPS also clarified that the current Intelligent Mail container barcode specification supports the use of either leading dashes or zeros, and mailers are welcome to use Intelligent Mail container placards on Basic IMB mailings, even though not required.

Tray Labels and Barcodes. The USPS clarified that the final specifications for the 10/24 transitional IM tray label and the 24-digit IM tray label have been published on its web site. "Mailers will be able to use the 24-digit barcoded label on, but not before, April 6, 2009," the USPS stated. "The need for accurate 24-digit barcodes on labels generated through vendor software is imperative to the success of full-service implementation," it said, "[t]herefore, we are requesting that all vendor software that generates the 24-digit barcoded labels go through a certification process to ensure readiness." The USPS noted that the certification process is posted on its Intelligent Mail web site (http://ribbs.usps.gov). It also included in its final rule the specifications for the 24-digit IM tray label.

In response to concerns raised by PostCom and others regarding the availability of adequate supplies of plastic sacks and label holders, the USPS said that it has "an adequate supply of plastic sacks and sack label holders, and we welcome specific suggestions for improving the quality of existing label holders."

IMB and Reply Mail. The USPS in its final rule responded to the concerns raised by PostCom and others around the USPS’ proposed requirements to use IM barcodes on all reply mail, and the proposed requirement for a Mailer ID in IM barcodes on Business Reply Mail (BRM). The USPS stated that BRM or Courtesy Reply Mail (CRM) pieces "will not be required to have Intelligent Mail barcodes until May, 2011." "However," it said, "letters claiming Qualified Business Reply Mail (QBRM) prices and Permit Reply Mail (PRM) pieces will be required to use Intelligent Mail barcodes, including Mailer IDs, as of May 2010."

"We will continue to allow, until May 2011," the Postal Service stated, "either POSTNET or Intelligent Mail barcodes on other reply mail that is enclosed within automation mailpieces." In response to an issue raised about placement of IM barcodes on BRM, the USPS noted that "[t]he Intelligent Mail barcode specification provides ample tolerance for printers to comply with the clear zone dimensions." [More information provided in the final rule.]

Other Technical Issues. The USPS noted that IM barcodes would not be required on nonautomation pieces, but it would allow correct barcodes at the mailer’s option. It also said it has "decided not to make a modification to the Postal Automated Redirection System (PARS)" to spray a new IMB on forwarded pieces so that the data in the original barcode is retained, as requested by one commenter.

Move Update Compliance

In response to the question raised by PostCom and others as to whether use of Full Service IMB would meet the Move Update requirement, the USPS said in its final rule that "Full-service mailings would meet Move Update requirements as long as address correction information previously obtained has been used to update addresses within 95 days (effective November 23, 2008) of the date of mailing." "It is important that mailers use the information provided in address correction notices to update addresses used in future mailings," the USPS said, noting that "[a] premailing method, such as NCOALINK., is necessary for Move Update compliance when mailers use newly purchased lists or lists that have not used an approved Move Update process within the previous 95 days."

The USPS also noted that when "Periodicals, Standard Mail, and BPM pieces have endorsements requesting an undeliverable mailpieces’ forwarding or return, additional charges apply for these services." "Also," the USPS stated in its final rule, "when hard copy notices are provided at the mailer’s request associated with the forwarding of a mailpiece, current prices apply." "However, as today, mailers will not be required to pay the manual notice fee for a hard copy notice for pieces properly prepared for OneCode ACS when the endorsement is Electronic Service Requested."

Data Security

PostCom and others had raised numerous concerns relative to security and privacy of mailer data contained in IM barcodes and electronic documentation. The USPS in its final rule said that Intelligent Mail implementation "will be in compliance with comprehensive security standards as published in the USPS Handbook, AS–805, Information Security." "The AS–805 handbook and its related documents are based upon industry and government standards and best practices," the USPS said.

Customer/Supplier Agreements (CSAs)

PostCom and others questioned the Postal Service about the process and guidelines around establishing Customer/Supplier Agreements (CSAs). "Customer/supplier agreements are the result of cooperation between mailers and USPS plant managers to establish appropriate separation of mailing containers related to critical mail acceptance times," the USPS said. "Customer/supplier agreements will be used for origin-entered mailings verified at a mailer’s facility, for mail presented at the BMEU requesting later entry times, and for time-sensitive drop-shipped Periodicals mailings requesting later entry times," it noted.

The USPS said the process for establishing customer/supplier agreements is outlined in the Guide (yet to be published in final form) and that CSAs "will be established as needed for eligible customers." The USPS further noted that "[s]pecial postage payment agreements will remain as they are currently, with customer/supplier agreements supplementing special postage payment agreements rather than replacing them."

Mixed Mailings

The USPS in its final rule included standards allowing Full Service and Basic IMB pieces, as well as pieces with POSTNET barcodes, "to be combined in a single mailing, including copalletized mailings, when appropriate documentation is provided." "As a reminder," the USPS noted, "when there are full-service pieces in a mailing, mailers must use Intelligent Mail tray labels and Intelligent Mail container placards (if the mail is containerized) and provide the USPS with electronic mailing documentation which includes piece level documentation for all mailpieces in those mailings." The USPS said its guide provides detailed information concerning documentation for mixed and copalletized mailings that include pieces with different types of barcodes.

Verification Procedures

In response to questions raised by PostCom and others about proposed tolerances and penalties for failure to meet requirements, the USPS in its final rule said that "[c]urrent verification procedures, including use of MERLIN and established levels of error tolerances, will apply to basic and full-service mailings." "Failure to meet qualifications for the full-service option, such as not maintaining mailpiece uniqueness, would result in a mailing being ineligible for full-service benefits; however, it may still be eligible for automation prices," the USPS said.

Facility Access and Shipment Tracking (FAST) Requirements

The USPS clarified that "Facility Access and Shipment Tracking (FAST.) appointments would not be generally needed for First-Class Mail mailings and for origin-entered mailings of other mail classes." It noted that "[u]pdates for recurring appointments may be provided via Mail.dat or Mail.XML, whereas updates to one-time appointments would be provided only via Mail.XML." "FAST will be used," the USPS said, "as defined in the customer/supplier agreement, to create appointments for origin entered mail that is transported by the mailer." "The FAST system is also used to schedule appointments for drop-shipment mailings, which typically do not require a customer/supplier agreement," the USPS noted.

IS THE IMB HOUSE OF CARDS STARTING TO SHAKE? A Comment

In many ways, the USPS’ Intelligent Mail barcode (IMB) implementation is like a house of cards – pull the wrong card out, or make too much wind, and the whole thing could fall down.

In the USPS’ IMB final rule published this week (see article in this issue of the PostCom Bulletin), the USPS stated "we are encouraged by the mailing industry’s support of our Intelligent Mail vision." They forgot to mention that the support they were referring to came from industry comments to its proposed IMB rules several months ago. That was before the USPS said there would be no price differential between Basic and Full Service IMB. [It quickly altered that position, however, after a maelstrom of negative feedback from major customers.] And that was before the USPS started making noises that "free" address correction information may not be so free.

It’s one thing for the Postal Service to take away a card or two by continuing to change the IMB technical specifications, adding a few difficult ones here and there. It’s quite another thing when you pull the whole bottom floor from that house of cards by taking away the "benefit" of free ACS and a significant price differential.

Even mailers that have already spent huge amounts of money preparing for IMB implementation are now putting the brakes on programming and system changes until the USPS definitively states its proposed IMB prices and benefits. Mailers can’t make the ROI and justify the expense without a significant price differential or, for some, the benefit of free ACS. There is a significant cost for mailers not just in achieving the IMB requirements, but in maintaining IMB the systems and processes necessary to support IMB compliance from one mailing to the next.

In comments to the Postal Service’s proposed IMB rules, PostCom and others asked the USPS to provide a 5-year roadmap of its Intelligent Mail implementation vision. With all the new cards being dealt by the USPS over the last few weeks, perhaps we should have asked for a roadmap of the next five months.