POSTAL REGULATORY COMMISSION

Washington, DC 20268-0001

Office of the Chairman

April 13, 2018

VIA U.S. MAIL AND EMAIL

Kevin E. Moley

Assistant Secretary for International

Organization Affairs

Bureau of International Organization Affairs

U.S. Department of State

2201 C Street NW, Room 6323

Washington, DC 20520

Dear Assistant Secretary Moley:

In accordance with 39 U.S.C. § 407(c)(1), I am writing to provide the Secretary of

State with the Postal Regulatory Commission's (Commission) views with respect to the

consistency of proposals to amend rates or classifications for market dominant products

at the April 2018 Universal Postal Union (UPU) Postal Operations Council (POC)

session with the standards and criteria established by the Commission under 39 U.S.C.

§ 3622.

After reviewing all proposals available as of April 12, 2018, the Commission has

identified one proposal that requires a view. This proposal (enclosed), from a standing

group of POC Committee 2 (Physical Services and E-Commerce), is contained in the

document "POC Committee 2 2018.1-Document 6, Annex 5." It would amend Article

18-104, International Business Reply Service (IBRS), of the Regulations of the

Universal Postal Convention (Regulations), to take effect on January 1, 2019. This

proposal would reduce the rate paid to designated postal operators for the return of

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Postal Regulatory Commission

Submitted 4/23/2018 12:13:16 PM

Filing ID: 104649

Accepted 7/12/2018
Kevin E. Moley

April 13, 2018

Page 2 of 3

IBRS small packets and bulky letters. 1 The new rate would be based on 80 percent of

the terminal dues paid for the delivery of small letters (P format) and large letters or flats

(G format), rather than 80 percent of the higher terminal dues paid for the delivery of

small packets and bulky letters (E format).2

Theoretically, the proposal could result in less revenue paid to the Postal Service

for the return of IBRS small packets and bulky letters to mailers in other countries and

could lower the Postal Service's costs for the return of IBRS small packets and bulky

letters from other countries to U.S. mailers. IBRS rates are only applied if the IBRS mail

flow between designated postal operators is over 1,000 items per year. According to

the data provided by the Postal Service, no bilaterallBRS mail flows exceed the

minimum threshold. 3 Therefore, in actuality, it is unlikely that this proposal would impact

the Postal Service financially.

In addition, the Commission finds that this proposal facilitates operational and

accounting processes and reduces costs for the Postal Service because the separation

of small packets and bulky letters from small and large letters within IBRS mail would

not be necessary. Furthermore, streamlining the Postal Service's operational and

accounting processes would promote and encourage the efficient operation of

international postal services.

The Commission finds that this proposal is consistent with the standards and

criteria established by the Commission under 39 U.S.C. § 3622 as it should increase the

1 E format IBRS mail is part of the UPU letter post product and consists of small packets

containing goods and bulky letters containing documents weighing less than 50 grams (1.76 ounces).

2 The total rate paid for the return of IBRS items would continue to include the UPU rate for

international air conveyance.

3 The Postal Service does not report IBRS costs in the International Cost and Revenue Analysis

report. See Docket No. ACR2011, Responses of the United States Postal Service to Questions 1-18 and

26-27 of Chairman's Information Request No.2, February 7,2012, question 6(a); Docket No. ACR2012,

Responses of the United States Postal Service to Commission Requests for Additional Information in FY

2012 Annual Compliance Determination June 26, 2013, question 1.

901 New York Avenue· Suite 200 • (202) 789-6820 • www.prc.gov
Kevin E. Moley

April 13, 2018

Page 3 of 3

Postal Service's efficiency, reduce its costs, and promote and encourage the efficient

operation of international postal services.

On behalf of the Postal Regulatory Commission, I wish the U.S. delegation the

greatest success at the POC session.

With best wishes, I am

Robert G. Taub

Chairman

Enclosure

cc: Joseph Murphy

Chief, International Postal Policy Unit

Office of Specialized and Technical Agencies

Bureau of International Organization Affairs

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