Comments to the Postal Regulatory Commission on Current Issues and Pricing

By at 21 June, 2019, 2:25 pm


Postal Regulatory Commission
901 New York Avenue, NW Suite 200
Washington, D.C. 20268

RE: Docket No. CP2019-155

To the Attention of the Commission:

On behalf of our organization’s diverse array of entrepreneurs, small business owners, and state
and local business organizations, the Small Business & Entrepreneurship Council (SBE Council)
is respectively submitting its views regarding the ongoing concerns with international mailing
measures and pricing regimes proposed by the U.S. Postal Service (USPS).

As our organization has emphasized in previous communications, there is a clear need to ensure
a non-discriminatory pricing system that will allow domestic sellers to access a level playing
field in reaching American consumers. The status quo regimes have regretfully set in place
fundamental challenges in which foreign mailers continue to be charged much lower rates by
USPS in comparison to the prices that American businesses pay to send items within the United

Thankfully, the Administration has established a positive course of action to promote fairness, as
well as unrestricted and undistorted competition. This includes the stated objectives (in
Presidential Memoranda dated August 23, 2018) to set rates that fully reimburse the USPS for
costs to the same extent as domestic rates for comparable services, and to avoid preferential
treatment of inbound foreign small packages containing goods.

To consider these issues, the member countries of the Universal Postal Union have agreed to
convene an extraordinary Congress scheduled for Sept. 24-25 in Geneva, Switzerland. The
outcomes of a vote on multiple proposals will certainly set new a course on objectives and
requirements for postal operators, which largely renders the Postal Service’s advancements in the
CP2019-155 docket to be premature.

Thus we encourage the Commission to withhold any actions and directives in this case until after
the UPU’s decisions on remuneration have taken place, and following initiation of the State
Department’s subsequent procedures.

As the Postal Service continues to outline alternative pricing regimes surrounding this service
segment, our organization believes strongly in adhering to procedural specificity and
transparency in order to best serve the interests of small businesses.

In the latest proposed rates notice, the Postal Service calls for a range of rates, which marks an
inherent lack of ideal pricing specificity that small businesses need in order to align their cost
structures in accordance with fluctuating market conditions.

Furthermore, the Postal Service’s measures to seek non-public treatment of materials and process
such filings under-seal represents a fundamentally non-democratic approach that diminishes the
possibilities for business associations, elected lawmakers, industry analysts, and the general
public from offering substantive feedback and perspectives of the impacts downstream.

SBE Council is steadfastly focused on strengthening the environment for robust
entrepreneurship, investment, innovation and small business growth. We express our thanks to
the Postal Regulatory Commission for this opportunity to express our views, and for maintaining
open dialogues on key matters impacting the nation’s postal system.
Our leadership would be pleased to engage directly with Commission should any further
opportunities arise for these proceedings.


Karen Kerrigan
President & CEO, SBE Council

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