Postal Rate Case
December 19, 2006
To Postal Commission
Fr: Association of Educational Publishers
Re: USPS Rate case
Dear Postal Commissioner,
AEP is a not-for-profit association of educational publishers.
We come to you with our concerns about the rate case filed by the
USPS in May 2006. At that time AEP had yet to determine if our
organization would become a party to the case, but decided not
to do so and now choose to provide these comments about the proposed
increases. Even in light of the recent passage of postal
reform legislation we are still concerned about the impact such
increases will have on our member’s products. Ultimately
there will be a greater cost to our public school system.
It is our understanding that the USPS needs the additional revenue
to comply with the breakeven constraint provision in the law, and
by 2008 they will carry a significant debt without the changes. What
the USPS proposes is an average increase of 8.5% on top of the
5.4% increase just last January. Even with these fiscal realities,
we in general object to a rate increase that is more than double
the CPI for 2005 at 3.4%.
As you are probably aware the law provides some protection for
the mailers of educational materials in the classroom periodical
rate. However, the proposed 6.4% increase will still affect our
ability to provide the periodicals to SEA’s and LEA’s
at the current rates. Our prices will have to increase in
proportion to the final rate increase. This may affect the
decision of certain SEA’s or LEA’s to discontinue to
purchase such materials as they are not required materials, but
a supplement to the core curriculums. Losing these materials
will not only cost jobs, but will also diminish the richness of
the classroom experience for children who depend on many periodicals
to enhance their learning.
We are also concerned about proposed increases in the Library
and BPM rates. In recent years the BPM rate has increased
34.8% in last three years - more than any other mailing class -
the library rate is still 48.6% higher than the BPM rate. Currently,
the library and book rates aren't taking into account the, "educational,
cultural, scientific and informational value" of the mail
and its recipient as mandated in the 1970 Postal Reorganization
Act. As a consequence, these rates are failing to support educational
needs and important educational programs. Any increases in either
rate will exacerbate the problem causing educational mailers to
continue their migrations to private carriers.
Thank you for your attention to the concerns of our organization. Please
feel free to contact us for further information.
Sincerely,
Charlene Gaynor
CEO
Association of Educational Publishers
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