Postal Service Price Changes, 34376-34379 [E9-16783]
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34376
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fee. The core of the service is the sack
handling and entry as domestic mail
and it is not dependent on the
underlying domestic mail services. The
Postal Service states that the instant
contract is functionally equivalent to the
IDE contracts previously submitted, fits
within the Mail Classification Schedule
(MCS) language included as Attachment
A to Governors’ Decision No. 08–6 and
should be included within the IDE
Contracts product. Notice at 2.
The instant contract. The Postal
Service filed the instant contract
pursuant to 39 CFR 3015.5. The contract
is with P&T Express Mail Service Joint
Stock Company (VNPE). VNPE is
established under the auspices of the
Vietnam Post and Telecommunications
Group, the public postal administration
for Vietnam, responsible for Vietnam’s
compliance with international
obligations relative to Express Mail
Service. The Postal Service submitted
the contract and supporting material
under seal and attached a redacted copy
of the contract and certified statement
required by 39 CFR 3015.5(c)(2) to the
Notice. Id., Attachments 1 and 2
respectively.4
The Postal Service will notify the
customer of the effective date of the
contract within 30 days after receiving
all regulatory approvals. The contract
term is 1 year from the effective date.
The contract is subject to automatic
renewal after the 1 year term unless the
parties determine otherwise. Id.,
Attachment 1.
The Notice advances reasons why the
instant IDE contract fits within the Mail
Classification Schedule language for IDE
contracts. The Postal Service states that
the instant contract is functionally
equivalent to the IDE contracts filed
previously because it shares similar cost
and market characteristics and
therefore, the contracts should be
classified as a single product. Id. at 3–
4. It states that in Governors’ Decision
No. 08–6, a pricing formula and
classification system were established to
ensure that each contract meets the
statutory and regulatory requirements of
39 U.S.C. 3633. The Postal Service states
that the costs of each contract must
conform to a common description and
the contract language of the MCS
prescribes that each IDE contract must
cover its attributable costs. Id.
The Postal Service reports that the
instant contract covers the same
domestic services as those in Docket
Nos. CP2008–14 and CP2008–15 except
for the addition of the Priority Mail
small flat rate box. It asserts that in
‘‘almost all substantive respects,’’ the
instant IDE contract resembles the
contracts in CP2008–14 and CP2008–15.
Id. at 4. The Postal Service contends
that even though fees or the underlying
domestic services offered may be
different, these distinctions do not affect
the contracts’ functional equivalence
because the total costs associated with
IDE Contracts are volume variable and
the basic service offered of handling
inbound sacks in the domestic mail
stream is the same. Id. Other changes
include language to update changes in
policies and product structures and
terms to clarify the applicability of
Postal Service export requirements. Id.
The Postal Service also affirms the
instant contract has material differences
reflected in the language of this
agreement compared to other IDE
contracts. Id. These differences include:
(1) The 1 year term of the instant
contract is subject to automatic renewal
which differs from the contracts in
CP2008–14 and CP2008–15 which are
automatically renewed unless
terminated; (2) Priority Mail small flat
rate box has been added as a domestic
mail type which Vietnam Post can
access via IDE service while other
included domestic mail services
included are the same as in previous
contracts but have updated rate
structures; 5 (3) terms are included
which express the parties’ wish to
explore future opportunities for volume
based discounts which the Postal
Service states does not represent a new
commitment; (4) terms that clarify
charges for non-conforming size or
weight items, and Delivery
Confirmation charges for First-Class
Mail parcel items; (5) language which
explains the need for a permit
application fee; (6) terms which address
changes to IDE customer payment
requirements upon detention or seizure
of mail by Customs and Border
Protection; and (7) terms to explain the
use of the Centralized Trust Account
payment method as applicable to
Vietnam’s financial regulatory
requirements which were not offered in
the contract for CP2008–14. Id. at 5–6.
The Postal Service maintains that
these differences only add detail or
amplify processes included in previous
IDE contracts and do not affect the
fundamental service being offered or the
4 Attachment 1 was revised by Notice of United
States Postal Service of Filing Erratum to
Attachment 1 to Notice of United States Postal
Service of Filing Functionally Equivalent Inbound
Direct Entry Contracts Negotiated Service
Agreement, June 30, 2009.
5 The Postal Service states that the other domestic
mail services are the same as in Docket Nos.
CP2008–14 and CP2008–15, but the instant contract
reflects the updated Priority Mail rate structure
based on the price adjustments for competitive
products in Docket CP2009–8.
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essential structure of the contracts. Id. at
7. It asserts that the contracts are
substantially equivalent in all pertinent
respects. Id.
The Postal Service maintains that
certain portions of the contract and
certified statement required by 39 CFR
3015.5(c)(2), related financial
information, portions of the certified
statement which contain costs and
pricing as well as the accompanying
analyses that provide prices, terms,
conditions, and financial projections
should remain under seal. Id. at 2–3.
II. Notice of Filing
The Commission establishes Docket
No. CP2009–41 for consideration of the
matters related to the contract identified
in the Postal Service’s Notice.
Interested persons may submit
comments on whether the instant
contract is consistent with the policies
of 39 U.S.C. 3632, 3622, or 3642.
Comments are due no later than July 10,
2009.
The public portions of these filings
can be accessed via the Commission’s
Web site (https://www.prc.gov).
The Commission appoints Paul L.
Harrington to serve as Public
Representative in this docket.
III. Ordering Paragraphs
It is Ordered:
1. The Commission establishes Docket
No. CP2009–41 for consideration of the
issues raised in this docket.
2. Comments by interested persons in
these proceedings are due no later than
July 10, 2009.
3. Pursuant to 39 U.S.C. 505, Paul L.
Harrington is appointed to serve as
officer of the Commission (Public
Representative) to represent the
interests of the general public in these
proceedings.
4. The Secretary shall arrange for
publication of this order in the Federal
Register.
Dated: July 1, 2009.
By the Commission.
Judith M. Grady,
Acting Secretary.
[FR Doc. E9–16584 Filed 7–14–09; 8:45 am]
BILLING CODE 7710–FW–P
POSTAL REGULATORY COMMISSION
[Docket No. R2009–4; Order No. 236]
Postal Service Price Changes
Postal Regulatory Commission.
Approval of price changes.
AGENCY:
ACTION:
DATES: Implementation is scheduled for
July 19, 2009.
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FOR FURTHER INFORMATION CONTACT:
Stephen L. Sharfman, General Counsel,
202–789–6924 or
stephen.sharfman@prc.gov.
SUMMARY: This document discusses the
Commission’s consideration and
approval of a Postal Service request to
reduce prices for a component of the
mail stream referred to as Standard Mail
high density flats. The approval means
that the Postal Service may implement
the planned price reductions.
SUPPLEMENTARY INFORMATION: Regulatory
History, 74 FR 27843 (June 11, 2009).
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I. Introduction
On June 1, 2009, the Postal Service
filed a notice with the Commission
announcing its intention to adjust prices
for Standard Mail High Density flat
pieces pursuant to 39 U.S.C. 3622 and
39 CFR Part 3010.1 The proposed
adjustment (decrease) has a planned
implementation date of July 19, 2009.
The Postal Service submits that this
proposal represents a way that it can
take advantage of its greater pricing
flexibility for market dominant products
under the Postal Accountability and
Enhancement Act (PAEA), Public Law
109–435, 120 Stat. 3218 (2006), to
‘‘respond quickly and flexibly to
perceived needs in the mailing
community.’’ Id. at 3.
In Order No. 220, the Commission
established Docket No. R2009–4 to
consider matters raised by the Postal
Service’s filing, appointed a public
representative, and afforded interested
persons an opportunity to comment on
specific issues as well as any other
matters related to the Postal Service’s
filing.2 In particular, the Commission
sought comment on whether the price
cap and unused rate adjustment
authority were applicable to this overall
price decrease.
On June 5, 2009, Chairman’s
Information Request No. 1 was issued.3
CHIR No. 1 sought information from the
Postal Service with respect to price
adjustment authority and annual
limitation calculations. The Postal
Service filed its response to the
Chairman’s Information Request on June
12, 2009.4
This case raises the issue of how the
Commission should address a rate
decrease in a period of deflation. The
1 United States Postal Service Notice of MarketDominant Price Adjustment, June 1, 2009 (Request).
2 PRC Order No. 220, Notice and Order
Concerning Price Adjustment for Standard Mail
High Density Flats, June 4, 2009 (Order No. 220).
3 Chairman’s Information Request No. 1, June 5,
2009 (CHIR No. 1).
4 Response of the United States Postal Service to
Chairman’s Information Request No. 1, June 12,
2009.
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Postal Service’s proposal was not
opposed by any commenter. The
Commission finds the Postal Service’s
proposal to be appropriate given the
unique factual circumstances of this
case. The Commission will initiate one
or more rulemakings to consider
revising its rules to address issues
concerning application of the price cap
and calculation of rate adjustment
authority.
II. Postal Service Request
The Postal Service explains that it has
heard the concerns expressed by High
Density flats mailers on the detrimental
impact that the above-average price
increases implemented on May 11,
2009, will have on their businesses.
Request at 2. After taking these concerns
into consideration, the Postal Service
determined that High Density flat prices
that reflect an increase from the
previous year similar to the average
Standard Mail increase are more
appropriate at this time. Id. As a result,
the Postal Service seeks to change the
current rates for Standard Mail High
Density flats. It asserts that the proposed
reduced rates could potentially avoid
diversion of large mail volumes from the
postal system. Id. at 5.
The Postal Service’s proposal reduces
prices for the Standard Mail High
Density flats price categories for both
commercial and nonprofit mailpieces.
Id. at 2. The adjustment decreases the
minimum per-piece prices for
commercial and nonprofit High Density
flats by 0.1 cent, and decreases the
pound price element for commercial
and nonprofit High Density flats to
match the Standard Mail Saturation flats
pound price element. The per-piece
price element for pound-rated pieces
increases by 0.7 cents per piece to
‘‘ensure a smooth transition at the
breakpoint,’’ according to the Postal
Service. Id. at 3. Dropship discounts for
High Density flats do not change under
this proposal.
III. Comments
Several parties filed comments in this
case: Valpak Direct Marketing Systems,
Inc. and Valpak Dealers’ Association,
Inc., the Public Representative, and
Newspaper Association of America.5 In
addition, the Postal Service responded
to questions posed in Order No. 220
5 Valpak Direct Marketing Systems, Inc. and
Valpak Dealers’ Association, Inc. Comments
Regarding Price Adjustment for Standard Mail High
Density Flats (Valpak Comments), Public
Representative Comments in Response to Notice of
Price Adjustment for Standard Mail High Density
Flats (Public Representative Comments), Comments
of the Newspaper Association of America on Notice
of Market-Dominant Price Adjustment (NAA
Comments), all filed June 22, 2009.
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34377
concerning the Request.6 The parties’
comments are summarized below.
Valpak comments. Valpak argues that
the Commission’s rules should apply to
price decreases, and that the
Commission did not intend to permit all
types of rate decreases without any
Commission review. In support, it cites
to the Commission’s rules which, for the
most part, discuss the price cap in terms
of ‘‘adjustments’’ rather than increases
or decreases. Valpak Comments at 2.
Valpak submits that in the current
‘‘abnormal economic circumstances’’
application of the Commission’s rules
can create ‘‘strange results.’’ Id. It
believes that the proper response may
be to modify the Commission’s rules on
this subject. The better approach here,
according to Valpak, would have been
for the Postal Service to file a motion to
waive the filing requirements or request
another type of one-time relief. Id. at 4.
Public Representative comments.
First, the Public Representative points
out that the Postal Service does not
provide any support or estimate for its
claim that the request ‘‘could potentially
avoid diversion of large volumes’’ of
High Density flat mail. Public
Representative Comments at 1–2.
Second, the Public Representative
contends, based on the text of 39 U.S.C.
3622(d)(1), that the price cap does not
apply to price decreases. Such an
application would be ‘‘illogical,’’
according to the Public Representative.
He notes that the PAEA does not
include any provision suggesting that a
rate decrease must be at least as great as
the drop in consumer price index. He
also discusses Congress’ purpose in
creating the price cap limitation—to
create a ceiling to ensure against
unreasonable price increases—a concern
that is not present when rates are
decreasing. Id. at 3–8.
Third, the Public Representative
contends that in the absence of a price
increase calculation, the Postal Service’s
unused rate adjustment authority is not
required or needed. In support of this
conclusion, he cites certain Commission
rules which he believes demonstrate
that the annual limitation and unused
rate adjustment authority only apply to
rate increases. With respect to whether
the Postal Service can waive unused
rate adjustment authority, he believes
this issue is ‘‘moot’’ because this rate
decrease does not generate any unused
rate adjustment authority since
consumer prices have decreased. Id. at
8–9.
6 Response of the United States Postal Service to
Order No. 220 (Postal Service Comments), June 22,
2009.
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NAA comments. NAA supports the
Postal Service’s proposed adjustment to
Standard Mail High Density Flats rates
because it will encourage retained mail
volume and discourage a migration of
customers out of the mailstream. NAA
Comments at 1.
Postal Service comments. The Postal
Service believes that applying the price
cap to a price decrease is not required
under the language or purpose of
section 3622. Postal Service Comments
at 2–3. First, it argues that section
3622(d)(1)(A) uses the word ‘‘increase,’’
and that the section is supposed to
apply only to limit the Postal Service’s
flexibility with respect to increases. Id.
at 3. Second, it believes that the
legislative history of the PAEA indicates
that Congress was concerned about
capping the extent to which the Postal
Service could increase prices, not
decrease prices. Id. at 4. Third, it cites
to Commission rule 3010.22(a) which
generally discusses price adjustments in
terms of ‘‘increases.’’ 7
The Postal Service notes that section
3622(d)(1)(A) does not foreclose the
Commission from adjusting the Postal
Service’s authority due to mid-cycle
price decreases. Id. 8 However, it
submits that the Commission should not
adjust the Postal Service’s pricing
authority due to the unique factual
circumstances present in this case,
where the partial-year annual limitation
applicable to the proposed adjustment is
negative. Id. at 2, 5. Applying the price
cap would require the Postal Service to
utilize a large portion of its unused
price adjustment authority for Standard
Mail to effectuate the decrease. This
would, according to the Postal Service
‘‘create a perverse incentive for the
Postal Service not to implement midyear price decreases in order to respond
to market conditions, during an
environment of declining CPI–U’’ by, in
effect, ‘‘penaliz[ing] the Postal Service
for making a mid-cycle price decrease in
7 The Postal Service notes that the Commission
may wish to consider the need for additional rules
concerning the effect of mid-year price adjustments
that consist entirely of a decrease on the Postal
Service’s price adjustment authority. Id. at 7.
8 See also Postal Service Comments at 3, 4–5
(‘‘Thus, while the Commission must apply the price
cap structure of section 3622(d) to price
adjustments that include increases to prices (i.e.,
either a price adjustment that consists solely of
price increases, or a price adjustment that includes
increases to some prices and decreases to others),
it is not required to do so with respect to price
adjustments consisting solely of a decrease in
prices.’’); (‘‘While the statute clearly does not
require that the price cap structure established by
section 3622(d) apply to a mid-year decrease, this
does not mean that the statute affirmatively
forecloses the Commission from decided that the
Postal Service’s price adjustment authority may in
certain circumstances be altered as a result of such
a decrease.’’).
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order to respond to market conditions,
by requiring that the Postal Service give
up a large portion of its unused price
adjustment authority.’’ Id. at 2–3, see
also Id. at 5.
The Postal Service also suggests that
even if a mid-year decrease during a
period of declining CPI–U does not
implicate the Postal Service’s price
adjustment authority, the other
provisions of section 3622 (such as
sections 3622(b), (c), and (e)), still
apply, and the Commission can make a
determination on such issues under rule
3010.13(j).
With respect to the issue of waiver,
the Postal Service states that it does not
view a price adjustment that is outside
the price cap structure as presenting a
question as to whether it can ‘‘waive’’
price adjustment authority because, in
such circumstances, there no authority
is being generated that would be eligible
to be waived.
IV. Commission Analysis
Impact on the price cap. The Postal
Service considers this price adjustment
to be outside the Commission’s current
rules because the proposed High
Density flat price adjustments are
decreases and were not part of the
regular annual price adjustment.
Request at 3. The Postal Service states
that it ‘‘is not claiming any new unused
rate adjustment authority as a result of
this price decrease.’’ Id.9 In its
comments, the Postal Service elaborates
on its position. It believes that
application of the price cap to this
situation would ‘‘requir[e] the Postal
Service [to] give up a large portion of its
unused price adjustment authority.’’
Postal Service Comments at 5. In
support of this statement, the Postal
Service points to its calculation in
response to CHIR No. 1 which shows a
reduction to the Postal Service’s unused
rate adjustment authority as a result of
this case.10
However, this position does not take
into consideration the fact that any
adjustment to the Postal Service’s
unused rate adjustment authority as a
result of this case would also ‘‘reset’’ the
9 The Postal Service submits that the unused
price adjustment authority for Standard Mail
should remain at 0.081 percent. Id. at 3 (citing PRC
Order No. 191, Order Reviewing Postal Service
Market Dominant Price Adjustment, May 16, 2009).
10 The Postal Service’s Notice and Response of the
United States Postal Service to Chairman’s
Information Request No. 1 use a ‘‘before rates’’
unused price adjustment authority for Standard
Mail of 0.081 percent. See, e.g., Notice at 3. This
before rates unused price adjustment authority is
incorrect. The proper before rates unused price
adjustment authority is 0.103 percent which is
found in Order No. 201, Order Approving Revisions
in Amended Notice of Market Dominant Price
Adjustment at 4, April 9, 2009.
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cap calculation. In other words, if the
unused rate adjustment authority is
changed as a result of this case, the cap
calculation going forward would also be
‘‘reset.’’ The negative change in CPI–U
for the last five months of last year
would have already been taken into
account by the resetting of the cap
calculation. Therefore, a future rate
increase could be larger than it
otherwise could have been if the cap
calculation and unused rate adjustment
authority were not reset as a result of
this proceeding. Indeed, the change in
unused rate adjustment authority as a
result of this proceeding would be offset
by the negative change in CPI-U that
would have to be taken into account as
a result of this proceeding. See Library
Reference PRC–R2009–4–LR–1 for an
example of this mathematical
phenomenon. This balancing occurs
whether or not the change in CPI-U is
positive or negative.
The Commission believes that the
larger issue with respect to this
proposed rate change is the impact that
the one decimal place rounding
constraint found in 39 CFR 3010.21 and
3010.22 potentially could have on the
rate adjustment authority altered as a
result of this proceeding. If the
Commission alters the Postal Service’s
unused rate adjustment authority as a
result of this proceeding, depending on
how CPI-U changes in the upcoming
months, proper application of 39 CFR
3010.22 could result in a lower amount
of Postal Service’s rate adjustment
authority for the next regular annual
price adjustment due to rounding. See
Library Reference PRC-R2009–4–LR–1
for an example of this calculation. This
potential problem would not occur if
the unused rate adjustment authority
and annual limitation calculation were
rounded to the same number of digits.
If the Postal Service continues to
exercise its pricing flexibility in a
similar manner in the future (small
increases or decreases in rates), this
rounding problem could become more
pernicious.
In addition to these problems, an
issue is whether the procedures of 39
CFR part 3010 used for calculating rate
adjustment authority are applicable to
rate decreases. The Commission’s rules
do not directly address such a situation.
The Commission’s rules are designed for
price adjustment proposals during
periods of inflation. However, as noted
above, this case has highlighted some
problems with the application of the
Commission’s current rules in
unforeseen factual circumstances.
Accordingly, the Commission will
accept the Postal Service’s approach
here based on the unique facts of this
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particular situation. Moreover, no
commenters voiced opposition to the
Postal Service’s suggested approach.
Nonetheless, the issues raised by the
Postal Service’s filing need to be
addressed on a holistic basis. Therefore,
the Commission will be initiating a
rulemaking to solicit public comment
on how a rate decrease should affect the
cap calculation and unused rate
adjustment authority in the future, as
well as how to deal with the rounding
issue discussed above.
The Commission’s action in this case
should not be construed as a finding
that the Commission does not have
authority under either the PAEA or its
rules to apply the compliance cap
calculation or adjust the Postal Service’s
unused rate adjustment authority in
cases where there is a rate decrease. As
the Postal Service correctly notes,
‘‘[w]hile the statute clearly does not
require that the price cap structure
established by section 3622(d) apply to
a mid-year decrease, this does not mean
that the statute affirmatively forecloses
the Commission from deciding that the
Postal Service’s price adjustment
authority may in certain circumstances
be altered as a result of such a
decrease.’’ The Commission’s
determination that the price cap should
not apply in this case is limited to the
narrow, unique factual situation at issue
here.
The rates resulting from this
proceeding will be used as the base rates
for the next cap calculation for the
Standard Mail class. The unused rate
adjustment authority for the Standard
Mail class remains at 0.103.
Objectives and factors. Pursuant to
the Commission’s rules, 39 CFR
3010.14(b)(7), the Postal Service
addresses how this proposed rate
adjustment helps achieve the objectives
of 39 U.S.C. 3622(b) and takes into
account the factors of 39 U.S.C. 3622(c).
The Postal Service lists and discusses
what it considers the relevant objectives
and factors of 39 U.S.C. 3622 to the
proposed price adjustment. Id. at 4–8. It
believes that, at most, the price
reductions will cause only a modest
decrease in Postal Service revenues, and
could potentially avoid diversion to
non-postal delivery of large volumes of
mail currently paying High Density flats
prices.
The Commission finds that, under the
circumstances of this case, the
objectives and factors in 39 U.S.C.
3622(b) and (c) appear to be satisfied by
explanations and data in the Request.
Workshare discounts. 39 U.S.C.
3622(e) requires that workshare
discounts given by the Postal Service do
not exceed their avoided costs unless
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certain criteria are fulfilled. The Postal
Service maintains its view that the price
differences between the High Density
categories and the Saturation and
Carrier Route categories are not
workshare discounts. It recognizes that
the Commission has instituted Docket
No. RM2009–3 to consider that issue. In
this case, the Postal Service provided in
Appendix B (and an associated Excel
file) a table showing the cost and price
differences, as well as passthroughs for
Carrier Route, High Density, and
Saturation flats (both commercial and
nonprofit) following the proposed
adjustments to the prices of High
Density flats. The Postal Service notes
that none of the passthroughs exceeds
100 percent, so the limitations of section
3622(e) do not apply. It explains that all
of the passthroughs for the High
Density/Carrier Route relationship are
slightly higher and the passthroughs for
the High Density/Saturation
relationship are slightly lower than
those reported in Docket No. R2009–2
due to the instant proposed High
Density flats price reduction.
The Commission finds that the rate
changes have only a minor effect on the
passthroughs approved just a few
months ago and they do not cause any
of the affected ‘‘passthroughs’’ to exceed
100 percent, Thus, the requirements of
section 3622(e) are satisfied here.11
Preferred rates. 39 U.S.C. 3626
requires that nonprofit categories of
products shall be set to yield 60 percent
of the per-piece revenue of their
commercial counterparts. The Postal
Service explains that nonprofit High
Density flats receive the same price
reductions as commercial flats. Due to
the fact that the proposed price changes
apply to both commercial and nonprofit
flats and due to the small volumes of
High Density nonprofit flats, the Postal
Service submits that the required 60
percent ratio, required under 39 U.S.C.
3626, between commercial and
nonprofit prices is not altered as a result
of the proposed price adjustment.
As the current commercial/nonprofit
price ratio is not altered as a result of
the proposed price adjustment, the
Commission finds that the required 60
percent differential will be maintained.
V. Ordering Paragraphs
A full review of the United States
Postal Service Notice of MarketDominant Price Adjustment with
respect to Standard Mail High Density
flats, filed June 1, 2009, has been
11 As the Postal Service notes, the Commission is
currently considering whether the relationship
between High Density and Saturation mailpieces is
to be considered ‘‘worksharing’’ for purposes of 39
U.S.C. 3622(e) in Docket No. RM2009–3.
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34379
completed. With regard to the price
adjustments contained therein, for the
reasons set forth above
It is ordered:
1. The Commission approves the
Standard Mail High Density flats rate
adjustment.
2. The rates resulting from this
proceeding will be used as the base rates
for the next cap calculation for the
Standard Mail class.
3. The unused rate adjustment
authority for the Standard Mail class
remains at 0.103.
4. The Secretary of the Commission
will arrange for publication of this
Order in the Federal Register.
Issued: July 1, 2009.
By the Commission.
Judith M. Grady,
Acting Secretary.
[FR Doc. E9–16783 Filed 7–14–09; 8:45 am]
BILLING CODE 7710–FW–P
SECURITIES AND EXCHANGE
COMMISSION
Proposed Collection; Comment
Request
Upon Written Request, Copies Available
From: Securities and Exchange
Commission, Office of Investor
Education and Advocacy,
Washington, DC 20549–0213.
Extension:
Rule 206(3)–2; SEC File No. 270–216; OMB
Control No. 3235–0243.
Notice is hereby given that, pursuant
to the Paperwork Reduction Act of 1995
(44 U.S.C. 3501 et seq.), the Securities
and Exchange Commission (the
‘‘Commission’’) is soliciting comments
on the collection of information
summarized below. The Commission
plans to submit this existing collection
of information to the Office of
Management and Budget for extension
and approval.
Rule 206(3)–2, (17 CFR 275.206(3)–2)
which is entitled ‘‘Agency Cross
Transactions for Advisory Clients,’’
permits investment advisers to comply
with section 206(3) of the Investment
Advisers Act of 1940 (the ‘‘Act’’) (15
U.S.C. 80b–6(3)) by obtaining a client’s
blanket consent to enter into agency
cross transactions (i.e., a transaction in
which an adviser acts as a broker to both
the advisory client and the opposite
party to the transaction), provided that
certain disclosures are made to the
client. Rule 206(3)–2 applies to all
registered investment advisers. In
relying on the rule, investment advisers
must provide certain disclosures to their
clients. Advisory clients can use the
E:\FR\FM\15JYN1.SGM
15JYN1
Agencies
[Federal Register Volume 74, Number 134 (Wednesday, July 15, 2009)]
[Notices]
[Pages 34376-34379]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E9-16783]
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POSTAL REGULATORY COMMISSION
[Docket No. R2009-4; Order No. 236]
Postal Service Price Changes
AGENCY: Postal Regulatory Commission.
ACTION: Approval of price changes.
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DATES: Implementation is scheduled for July 19, 2009.
[[Page 34377]]
FOR FURTHER INFORMATION CONTACT: Stephen L. Sharfman, General Counsel,
202-789-6924 or stephen.sharfman@prc.gov.
SUMMARY: This document discusses the Commission's consideration and
approval of a Postal Service request to reduce prices for a component
of the mail stream referred to as Standard Mail high density flats. The
approval means that the Postal Service may implement the planned price
reductions.
SUPPLEMENTARY INFORMATION: Regulatory History, 74 FR 27843 (June 11,
2009).
I. Introduction
On June 1, 2009, the Postal Service filed a notice with the
Commission announcing its intention to adjust prices for Standard Mail
High Density flat pieces pursuant to 39 U.S.C. 3622 and 39 CFR Part
3010.\1\ The proposed adjustment (decrease) has a planned
implementation date of July 19, 2009. The Postal Service submits that
this proposal represents a way that it can take advantage of its
greater pricing flexibility for market dominant products under the
Postal Accountability and Enhancement Act (PAEA), Public Law 109-435,
120 Stat. 3218 (2006), to ``respond quickly and flexibly to perceived
needs in the mailing community.'' Id. at 3.
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\1\ United States Postal Service Notice of Market-Dominant Price
Adjustment, June 1, 2009 (Request).
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In Order No. 220, the Commission established Docket No. R2009-4 to
consider matters raised by the Postal Service's filing, appointed a
public representative, and afforded interested persons an opportunity
to comment on specific issues as well as any other matters related to
the Postal Service's filing.\2\ In particular, the Commission sought
comment on whether the price cap and unused rate adjustment authority
were applicable to this overall price decrease.
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\2\ PRC Order No. 220, Notice and Order Concerning Price
Adjustment for Standard Mail High Density Flats, June 4, 2009 (Order
No. 220).
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On June 5, 2009, Chairman's Information Request No. 1 was
issued.\3\ CHIR No. 1 sought information from the Postal Service with
respect to price adjustment authority and annual limitation
calculations. The Postal Service filed its response to the Chairman's
Information Request on June 12, 2009.\4\
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\3\ Chairman's Information Request No. 1, June 5, 2009 (CHIR No.
1).
\4\ Response of the United States Postal Service to Chairman's
Information Request No. 1, June 12, 2009.
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This case raises the issue of how the Commission should address a
rate decrease in a period of deflation. The Postal Service's proposal
was not opposed by any commenter. The Commission finds the Postal
Service's proposal to be appropriate given the unique factual
circumstances of this case. The Commission will initiate one or more
rulemakings to consider revising its rules to address issues concerning
application of the price cap and calculation of rate adjustment
authority.
II. Postal Service Request
The Postal Service explains that it has heard the concerns
expressed by High Density flats mailers on the detrimental impact that
the above-average price increases implemented on May 11, 2009, will
have on their businesses. Request at 2. After taking these concerns
into consideration, the Postal Service determined that High Density
flat prices that reflect an increase from the previous year similar to
the average Standard Mail increase are more appropriate at this time.
Id. As a result, the Postal Service seeks to change the current rates
for Standard Mail High Density flats. It asserts that the proposed
reduced rates could potentially avoid diversion of large mail volumes
from the postal system. Id. at 5.
The Postal Service's proposal reduces prices for the Standard Mail
High Density flats price categories for both commercial and nonprofit
mailpieces. Id. at 2. The adjustment decreases the minimum per-piece
prices for commercial and nonprofit High Density flats by 0.1 cent, and
decreases the pound price element for commercial and nonprofit High
Density flats to match the Standard Mail Saturation flats pound price
element. The per-piece price element for pound-rated pieces increases
by 0.7 cents per piece to ``ensure a smooth transition at the
breakpoint,'' according to the Postal Service. Id. at 3. Dropship
discounts for High Density flats do not change under this proposal.
III. Comments
Several parties filed comments in this case: Valpak Direct
Marketing Systems, Inc. and Valpak Dealers' Association, Inc., the
Public Representative, and Newspaper Association of America.\5\ In
addition, the Postal Service responded to questions posed in Order No.
220 concerning the Request.\6\ The parties' comments are summarized
below.
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\5\ Valpak Direct Marketing Systems, Inc. and Valpak Dealers'
Association, Inc. Comments Regarding Price Adjustment for Standard
Mail High Density Flats (Valpak Comments), Public Representative
Comments in Response to Notice of Price Adjustment for Standard Mail
High Density Flats (Public Representative Comments), Comments of the
Newspaper Association of America on Notice of Market-Dominant Price
Adjustment (NAA Comments), all filed June 22, 2009.
\6\ Response of the United States Postal Service to Order No.
220 (Postal Service Comments), June 22, 2009.
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Valpak comments. Valpak argues that the Commission's rules should
apply to price decreases, and that the Commission did not intend to
permit all types of rate decreases without any Commission review. In
support, it cites to the Commission's rules which, for the most part,
discuss the price cap in terms of ``adjustments'' rather than increases
or decreases. Valpak Comments at 2. Valpak submits that in the current
``abnormal economic circumstances'' application of the Commission's
rules can create ``strange results.'' Id. It believes that the proper
response may be to modify the Commission's rules on this subject. The
better approach here, according to Valpak, would have been for the
Postal Service to file a motion to waive the filing requirements or
request another type of one-time relief. Id. at 4.
Public Representative comments. First, the Public Representative
points out that the Postal Service does not provide any support or
estimate for its claim that the request ``could potentially avoid
diversion of large volumes'' of High Density flat mail. Public
Representative Comments at 1-2. Second, the Public Representative
contends, based on the text of 39 U.S.C. 3622(d)(1), that the price cap
does not apply to price decreases. Such an application would be
``illogical,'' according to the Public Representative. He notes that
the PAEA does not include any provision suggesting that a rate decrease
must be at least as great as the drop in consumer price index. He also
discusses Congress' purpose in creating the price cap limitation--to
create a ceiling to ensure against unreasonable price increases--a
concern that is not present when rates are decreasing. Id. at 3-8.
Third, the Public Representative contends that in the absence of a
price increase calculation, the Postal Service's unused rate adjustment
authority is not required or needed. In support of this conclusion, he
cites certain Commission rules which he believes demonstrate that the
annual limitation and unused rate adjustment authority only apply to
rate increases. With respect to whether the Postal Service can waive
unused rate adjustment authority, he believes this issue is ``moot''
because this rate decrease does not generate any unused rate adjustment
authority since consumer prices have decreased. Id. at 8-9.
[[Page 34378]]
NAA comments. NAA supports the Postal Service's proposed adjustment
to Standard Mail High Density Flats rates because it will encourage
retained mail volume and discourage a migration of customers out of the
mailstream. NAA Comments at 1.
Postal Service comments. The Postal Service believes that applying
the price cap to a price decrease is not required under the language or
purpose of section 3622. Postal Service Comments at 2-3. First, it
argues that section 3622(d)(1)(A) uses the word ``increase,'' and that
the section is supposed to apply only to limit the Postal Service's
flexibility with respect to increases. Id. at 3. Second, it believes
that the legislative history of the PAEA indicates that Congress was
concerned about capping the extent to which the Postal Service could
increase prices, not decrease prices. Id. at 4. Third, it cites to
Commission rule 3010.22(a) which generally discusses price adjustments
in terms of ``increases.'' \7\
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\7\ The Postal Service notes that the Commission may wish to
consider the need for additional rules concerning the effect of mid-
year price adjustments that consist entirely of a decrease on the
Postal Service's price adjustment authority. Id. at 7.
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The Postal Service notes that section 3622(d)(1)(A) does not
foreclose the Commission from adjusting the Postal Service's authority
due to mid-cycle price decreases. Id. \8\ However, it submits that the
Commission should not adjust the Postal Service's pricing authority due
to the unique factual circumstances present in this case, where the
partial-year annual limitation applicable to the proposed adjustment is
negative. Id. at 2, 5. Applying the price cap would require the Postal
Service to utilize a large portion of its unused price adjustment
authority for Standard Mail to effectuate the decrease. This would,
according to the Postal Service ``create a perverse incentive for the
Postal Service not to implement mid-year price decreases in order to
respond to market conditions, during an environment of declining CPI-
U'' by, in effect, ``penaliz[ing] the Postal Service for making a mid-
cycle price decrease in order to respond to market conditions, by
requiring that the Postal Service give up a large portion of its unused
price adjustment authority.'' Id. at 2-3, see also Id. at 5.
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\8\ See also Postal Service Comments at 3, 4-5 (``Thus, while
the Commission must apply the price cap structure of section 3622(d)
to price adjustments that include increases to prices (i.e., either
a price adjustment that consists solely of price increases, or a
price adjustment that includes increases to some prices and
decreases to others), it is not required to do so with respect to
price adjustments consisting solely of a decrease in prices.'');
(``While the statute clearly does not require that the price cap
structure established by section 3622(d) apply to a mid-year
decrease, this does not mean that the statute affirmatively
forecloses the Commission from decided that the Postal Service's
price adjustment authority may in certain circumstances be altered
as a result of such a decrease.'').
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The Postal Service also suggests that even if a mid-year decrease
during a period of declining CPI-U does not implicate the Postal
Service's price adjustment authority, the other provisions of section
3622 (such as sections 3622(b), (c), and (e)), still apply, and the
Commission can make a determination on such issues under rule
3010.13(j).
With respect to the issue of waiver, the Postal Service states that
it does not view a price adjustment that is outside the price cap
structure as presenting a question as to whether it can ``waive'' price
adjustment authority because, in such circumstances, there no authority
is being generated that would be eligible to be waived.
IV. Commission Analysis
Impact on the price cap. The Postal Service considers this price
adjustment to be outside the Commission's current rules because the
proposed High Density flat price adjustments are decreases and were not
part of the regular annual price adjustment. Request at 3. The Postal
Service states that it ``is not claiming any new unused rate adjustment
authority as a result of this price decrease.'' Id.\9\ In its comments,
the Postal Service elaborates on its position. It believes that
application of the price cap to this situation would ``requir[e] the
Postal Service [to] give up a large portion of its unused price
adjustment authority.'' Postal Service Comments at 5. In support of
this statement, the Postal Service points to its calculation in
response to CHIR No. 1 which shows a reduction to the Postal Service's
unused rate adjustment authority as a result of this case.\10\
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\9\ The Postal Service submits that the unused price adjustment
authority for Standard Mail should remain at 0.081 percent. Id. at 3
(citing PRC Order No. 191, Order Reviewing Postal Service Market
Dominant Price Adjustment, May 16, 2009).
\10\ The Postal Service's Notice and Response of the United
States Postal Service to Chairman's Information Request No. 1 use a
``before rates'' unused price adjustment authority for Standard Mail
of 0.081 percent. See, e.g., Notice at 3. This before rates unused
price adjustment authority is incorrect. The proper before rates
unused price adjustment authority is 0.103 percent which is found in
Order No. 201, Order Approving Revisions in Amended Notice of Market
Dominant Price Adjustment at 4, April 9, 2009.
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However, this position does not take into consideration the fact
that any adjustment to the Postal Service's unused rate adjustment
authority as a result of this case would also ``reset'' the cap
calculation. In other words, if the unused rate adjustment authority is
changed as a result of this case, the cap calculation going forward
would also be ``reset.'' The negative change in CPI-U for the last five
months of last year would have already been taken into account by the
resetting of the cap calculation. Therefore, a future rate increase
could be larger than it otherwise could have been if the cap
calculation and unused rate adjustment authority were not reset as a
result of this proceeding. Indeed, the change in unused rate adjustment
authority as a result of this proceeding would be offset by the
negative change in CPI-U that would have to be taken into account as a
result of this proceeding. See Library Reference PRC-R2009-4-LR-1 for
an example of this mathematical phenomenon. This balancing occurs
whether or not the change in CPI-U is positive or negative.
The Commission believes that the larger issue with respect to this
proposed rate change is the impact that the one decimal place rounding
constraint found in 39 CFR 3010.21 and 3010.22 potentially could have
on the rate adjustment authority altered as a result of this
proceeding. If the Commission alters the Postal Service's unused rate
adjustment authority as a result of this proceeding, depending on how
CPI-U changes in the upcoming months, proper application of 39 CFR
3010.22 could result in a lower amount of Postal Service's rate
adjustment authority for the next regular annual price adjustment due
to rounding. See Library Reference PRC-R2009-4-LR-1 for an example of
this calculation. This potential problem would not occur if the unused
rate adjustment authority and annual limitation calculation were
rounded to the same number of digits. If the Postal Service continues
to exercise its pricing flexibility in a similar manner in the future
(small increases or decreases in rates), this rounding problem could
become more pernicious.
In addition to these problems, an issue is whether the procedures
of 39 CFR part 3010 used for calculating rate adjustment authority are
applicable to rate decreases. The Commission's rules do not directly
address such a situation. The Commission's rules are designed for price
adjustment proposals during periods of inflation. However, as noted
above, this case has highlighted some problems with the application of
the Commission's current rules in unforeseen factual circumstances.
Accordingly, the Commission will accept the Postal Service's approach
here based on the unique facts of this
[[Page 34379]]
particular situation. Moreover, no commenters voiced opposition to the
Postal Service's suggested approach.
Nonetheless, the issues raised by the Postal Service's filing need
to be addressed on a holistic basis. Therefore, the Commission will be
initiating a rulemaking to solicit public comment on how a rate
decrease should affect the cap calculation and unused rate adjustment
authority in the future, as well as how to deal with the rounding issue
discussed above.
The Commission's action in this case should not be construed as a
finding that the Commission does not have authority under either the
PAEA or its rules to apply the compliance cap calculation or adjust the
Postal Service's unused rate adjustment authority in cases where there
is a rate decrease. As the Postal Service correctly notes, ``[w]hile
the statute clearly does not require that the price cap structure
established by section 3622(d) apply to a mid-year decrease, this does
not mean that the statute affirmatively forecloses the Commission from
deciding that the Postal Service's price adjustment authority may in
certain circumstances be altered as a result of such a decrease.'' The
Commission's determination that the price cap should not apply in this
case is limited to the narrow, unique factual situation at issue here.
The rates resulting from this proceeding will be used as the base
rates for the next cap calculation for the Standard Mail class. The
unused rate adjustment authority for the Standard Mail class remains at
0.103.
Objectives and factors. Pursuant to the Commission's rules, 39 CFR
3010.14(b)(7), the Postal Service addresses how this proposed rate
adjustment helps achieve the objectives of 39 U.S.C. 3622(b) and takes
into account the factors of 39 U.S.C. 3622(c). The Postal Service lists
and discusses what it considers the relevant objectives and factors of
39 U.S.C. 3622 to the proposed price adjustment. Id. at 4-8. It
believes that, at most, the price reductions will cause only a modest
decrease in Postal Service revenues, and could potentially avoid
diversion to non-postal delivery of large volumes of mail currently
paying High Density flats prices.
The Commission finds that, under the circumstances of this case,
the objectives and factors in 39 U.S.C. 3622(b) and (c) appear to be
satisfied by explanations and data in the Request.
Workshare discounts. 39 U.S.C. 3622(e) requires that workshare
discounts given by the Postal Service do not exceed their avoided costs
unless certain criteria are fulfilled. The Postal Service maintains its
view that the price differences between the High Density categories and
the Saturation and Carrier Route categories are not workshare
discounts. It recognizes that the Commission has instituted Docket No.
RM2009-3 to consider that issue. In this case, the Postal Service
provided in Appendix B (and an associated Excel file) a table showing
the cost and price differences, as well as passthroughs for Carrier
Route, High Density, and Saturation flats (both commercial and
nonprofit) following the proposed adjustments to the prices of High
Density flats. The Postal Service notes that none of the passthroughs
exceeds 100 percent, so the limitations of section 3622(e) do not
apply. It explains that all of the passthroughs for the High Density/
Carrier Route relationship are slightly higher and the passthroughs for
the High Density/Saturation relationship are slightly lower than those
reported in Docket No. R2009-2 due to the instant proposed High Density
flats price reduction.
The Commission finds that the rate changes have only a minor effect
on the passthroughs approved just a few months ago and they do not
cause any of the affected ``passthroughs'' to exceed 100 percent, Thus,
the requirements of section 3622(e) are satisfied here.\11\
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\11\ As the Postal Service notes, the Commission is currently
considering whether the relationship between High Density and
Saturation mailpieces is to be considered ``worksharing'' for
purposes of 39 U.S.C. 3622(e) in Docket No. RM2009-3.
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Preferred rates. 39 U.S.C. 3626 requires that nonprofit categories
of products shall be set to yield 60 percent of the per-piece revenue
of their commercial counterparts. The Postal Service explains that
nonprofit High Density flats receive the same price reductions as
commercial flats. Due to the fact that the proposed price changes apply
to both commercial and nonprofit flats and due to the small volumes of
High Density nonprofit flats, the Postal Service submits that the
required 60 percent ratio, required under 39 U.S.C. 3626, between
commercial and nonprofit prices is not altered as a result of the
proposed price adjustment.
As the current commercial/nonprofit price ratio is not altered as a
result of the proposed price adjustment, the Commission finds that the
required 60 percent differential will be maintained.
V. Ordering Paragraphs
A full review of the United States Postal Service Notice of Market-
Dominant Price Adjustment with respect to Standard Mail High Density
flats, filed June 1, 2009, has been completed. With regard to the price
adjustments contained therein, for the reasons set forth above
It is ordered:
1. The Commission approves the Standard Mail High Density flats
rate adjustment.
2. The rates resulting from this proceeding will be used as the
base rates for the next cap calculation for the Standard Mail class.
3. The unused rate adjustment authority for the Standard Mail class
remains at 0.103.
4. The Secretary of the Commission will arrange for publication of
this Order in the Federal Register.
Issued: July 1, 2009.
By the Commission.
Judith M. Grady,
Acting Secretary.
[FR Doc. E9-16783 Filed 7-14-09; 8:45 am]
BILLING CODE 7710-FW-P