Mr. CUNNINGHAM. And that would cost extra, wouldn't it? Mr. SEITZ. Yes, sir; it would. This is updating and maintaining the list. Mr. CUNNINGHAM. Thank you, Mr. Chairman. Mr. OLSEN. Thank you, Mr. Cunningham. I want to make this observation for the record, while we are on the subject, about some of the mailings. I received complaints on sectional centers and ZIP code from county weeklies in my district, and I contacted the Post Office Department. They sent inspectors into those areas who designated a transportation clerk to visit the smaller post offices in that area. He also visited all the newspapers in his area and found that they were making the same mistake. They were tying off their publication going to Denver, and they tied off going east and marked it "east," and, of course, it got to Minneapolis and Omaha before it got to where it was going, which was no fault of the Post Office Department. When they properly tied it off, as instructed by the Post Office Department, their service was very greatly improved. I recently visited these newspapers in that northwest corner of Montana, and they are all very happy now. And what did I find about their own mechanization? They do the publication. in their own shop, but the publication constitutes only the typing, and they then take it down to a new printing plant that is 30 or 40 miles away from each of these publications, and there they have it printed in a common printing plant. Then they bring it back to their shop where they have their Elliott machine and they put the addresses on, which are printed on plates. So, I heckled them a little bit about their modernizing. They are going to a new machine method, but they are reluctant to support the Post Office wanting to machine itself. I found a little greater understanding, though, since now they have gotten this assistance from the Post Office Department in making up their mail. They are more sympathetic to the fact that the Post Office does have to do some mechanization. Mr. SEITZ. We have gotten very good cooperation from the Post Office in assisting us, especially in the initial stages of ZIP coding. Mr. OLSEN. You are in Montgomery, Ala? Mr. SEITZ. Yes. Mr. OLSEN. You received expert help, didn't you, from the Post Office Department? Mr. SEITZ. Yes. Mr. OLSEN. And there is no reluctance on their part to come and talk with you upon your making a request? Mr. SEITZ. No; as a matter of fact, voluntarily they have come out on several occasions, knowing that we are a large user of the mails in Montgomery, and, of course, they are interested in expediting the mail themselves, and so we have very good cooperation. Mr. OLSEN. I would hope so, and if you don't get it, I hope you will complain, because that is really what happened out in our country. Just a general growling doesn't help anything at all. When these second-class mailers made the specific complaint, they got service. If they make a grumble on the editorial page, there is nothing you can do for them. If they make a specific complaint about what is happening to their mails, it can be studied and corrected. I hope all mailers would bear this in mind, that a specific complaint is welcome, because it can be corrected. Mr. SEITZ. We have found this to be true. Mr. OLSEN. Thank you very much. The subcommittee stands adjourned. (Whereupon, at 11 a.m., the hearing was adjourned.) STANDARDIZING THE SIZES OF MAIL WEDNESDAY, MARCH 20, 1968 HOUSE OF REPRESENTATIVES, SUBCOMMITTEE ON POSTAL RATES OF THE Washington, D.C. The subcommittee met, pursuant to recess, at 10:10 a.m., in room 210, Cannon Building, Hon. Arnold Olsen (chairman of the subcommittee) presiding. Mr. OLSEN. The subcommittee will come to order. The Chair recognizes our distinguished colleague, Mr. Button. I would like, if I may, to introduce the first witness. He is one of the most distinguished of my constituents from the 29th District of New York, a resident of Albany, and a businessman, as well, in three other cities throughout the country. He is Mr. Howard Russell, president of the Russell Distributing Co., with business offices in Albany as well as in other cities, as was made known to this subcommittee very well last year when he testified on the rate bill. He speaks as a director of the Mail Advertising Service Association, the Associated Third Class Mail Users, and the National Association of Advertising Distributors. Mr. OLSEN. Thank you very much, Mr. Button. Mr. Russell, you may proceed as you will, and Mr. Lee Epstein, executive vice president, Mail Advertising Service Association, and Mr. Norman Einziger, Advertising Distributors of America. If they are accompanying you, they can step forward and join you. Mr. RUSSELL. Thank you. Mr. OLSEN. You may proceed in whatever order you gentlemen wish. Mr. RUSSELL. If we want to follow the order, Mr. Einziger will be first, and Mr. Epstein next. My line is a sort of specialty and this might be a good idea to do it this way. Mr. Epstein will speak first. TESTIMONY OF LEE EPSTEIN, EXECUTIVE VICE PRESIDENT, MAIL ADVERTISING SERVICE ASSOCIATION Mr. EPSTEIN. Mr. Chairman and members of the subcommittee, I would like to express my appreciation to the chairman of the committee and its members for the time granted our association to express our views on H.R. 14029. In my capacity as chairman of our postal affairs committee, and as my association's representative to the Postmaster General's Mailers Technical Advisory Committee, I have been able to gain a broader perspective on the problems that confront the Post Office Department in its quest for greater efficiency at lower cost. This experience added to my business background as president of Mailmen, Inc., in Syosset, N.Y., will, I trust, lend some degree of credibility to the remarks expressed herein. Before offering my remarks on H.R. 14029, I would like to comment briefly on the Mail Advertising Service Association, International. It was founded 47 years ago, and today has more than 500 members in the United States and 14 foreign countries. Membership is composed of the producers of mail advertising and range from the smallest lettershop up to and including the major mailers and producers of the industry. The international headquarters is located in Washington at 815 17th Street NW. In addition to the international operation, we have 16 chapters of MASA throughout the United States. My remarks this morning on this proposed legislation reflect the attitude of this association. H.R. 14029 appears to me to be a rather strange mixture of items, both general and specific, covering broad areas of study on specific subjects and omitting other areas which need study. It also contains specific changes in rates based on standards which have not as yet been determined. To begin with, I and my association are in total agreement with section 2 of the bill which authorizes the Postmaster General to conduct the study of (1) mail handling characteristics; (2) present and anticipated mailing patterns; (4) standardization of mail. We are also completely in agreement with the proposition that before legislation is enacted, a period of time be used for research and study, and that a further period of time be allocated before the regulations go into effect. There are, however, other areas of the bill that I feel could stand improvement, and to this end I offer the following constructive criticism: First, line 7, section 4656, subhead (a), calls for an additional charge for nonstandard, first-class and airmail letters. I fail to see the logic or understand the reasoning which would make a determination of a specific penalty of 2 cents on mail which is nonstandard when we do not know what "nonstandard" will mean. I feel that the amount of penalty to be assessed upon nonstandard mail cannot be determined until the standards are spelled out and a study of the costs of handling these nonstandard pieces are determined. It is entirely possible that the penalty to be assessed could be 3 cents, 4 cents, 5 cents, or 1 cent. In my opinion, it would be best to wait until these studies are completed and evaluated before a specific amount is recommended. Second, under line 6, section 2, subhead (a), the Postmaster General is authorized and directed to conduct a comprehensive study. Nowhere in the bill is the Postmaster General specifically directed to include industry representatives as a part of the study and research committees. Although I know it is the intent to include industry members in these studies, since steps have already been taken by the Department to set up various committees containing such industry members, I feel the specific inclusion of this concept in the bill would go a long way to reassure the mail advertising industry that their needs will be considered in such a vital area as standardization of mail. Third, under the same section as above, there is no provision for the analysis of the economic impact of the standards to be set by the Postmaster General. I feel that such a study must be an integral part of any contemplated changes in the traditional rules and regulations under which we live today, and as such should be provided for in the bill. Fourth, under the proposed bill the Postmaster General shall publish in the Federal Register his findings made as a result of the study conducted. I feel that before such regulations go into effect, that Congress and its appropriate committees should have the opportunity to review the findings and decisions of the Post Office Department and to make certain that they are in accord with the wishes of Congress. I don't think it is wise to permit regulations of so broad a nature to be authorized without utilizing every reasonable system of checks and balances. Therefore, I recommend the inclusion of such a review and approval procedure in the bill. Fifth, I believe that the study to be undertaken by the Post Office Department on nonstandard mail should be broadened to include all classes of mail, not just first class and airmail. We know that standards will differ between classes of mail, but it would make sense now to attempt to evaluate these standards for all classes since such a piecemeal approach can only result in piecemeal savings. Both your committee and the Post Office Department have expressed such interest and concern in the other classes of mail in prior testimony. Certainly an overall review would provide the means for maximum impact in achieving the Department's long-range goals of modernization and standardization. I therefore recommend that the bill be broadened to include a review of all classes of mail. My interest in building into this bill certain safeguards and checks should not be construed as an effort to thwart the Department in its quest for standards. We believe in standards; we recognize their importance and will cooperate in any manner the Department and Congress shall direct. However, from information issued by the Department itself and in testimony before this committee, I find that their preliminary thinking could, if not fully explored and discussed, have serious consequences for our industry. Let me give you a few examples. One, the Department has issued a chart showing minimum and maximum acceptable sizes. I can tell you now that any standard that penalizes such traditional popular sizes of mail like the 6 by 9, the 81⁄2 by 11, or the 9 by 12, will have serious repercussions, not only to the mailing industry but also to the printers, paper mills and merchants, and the envelope manufacturers. In addition, it would effectively take away what has become one of Mail Advertising's most productive formats; namely, the jumbo envelope. Two, I assume that these sizes are predicated on machinability requirements for first-class mail since second- and third-class mail is ZIP coded and presorted and, therefore, for the most part requires no machine handling. Three, I further assume that the size limitations as applied to second and third class results from the difficulty that the carrier experiences |