On October 9, 2019, The United States Postal Service (USPS) filed new rates for 2020 with the Postal Regulatory Commission (PRC). The USPS elected to keep the rate for the Forever Stamp at 55 cents and the rate for an additional ounce at 15 cents meaning that the cost of the Butterfly Stamp will also remain unchanged for 2020. An additional year of rate stability for individual consumers is a positive for the greeting card industry and would likely not have occurred if not for GCA’s support of the legal challenge to the 55-cent rate brought by Doug Carlson and our filings opposing the increase at the PRC upon which the Court of Appeals for the D.C. Circuit relied on in its decision vacating the rates.
Unfortunately, the USPS filing for the new rates indicates that we still have more work to do. Even though the rates will not change, the USPS continues to base the new rates on the previous 2019 rate structure and on a questionable legal theory, and remains committed to increasing stamp prices in nickel increments moving forward. The reliance on a flawed rate structure that was rejected by the Court in the Carlson appeal is troubling and GCA is taking additional steps to protect greeting card mailers.
First, the GCA will continue to coordinate with Mr. Carlson to ensure that the Court decision rejecting the 55-cent rate is sustained through any further petitions. GCA is also in the process of pursuing our own complaint at the PRC against the 55-cent rate and the unduly discriminatory Metered Letter differential of 5 cents, and will be meeting with the USPS legal team for a pre-conference required by law to review our concerns. It is possible that that discussion could produce additional actions by the Postal Service that would resolve our concerns or some of them; however, our complaint is ready to be filed at the PRC if no agreement can be reached.
Finally, the GCA has submitted comments encouraging the PRC to adopt a process that will allow for issues with the 2020 rates to be fully adjudicated consistent with the appeal decision that found that the Commission had failed to adequately consider issues with the 55-cent rate. We will be prepared to challenge the flaws in the USPS price structure and assertions that stamp prices must be raised in nickel increments in that proceeding as well.
The GCA has made great strides in developing an impactful working relationship with the USPS marketing team that has resulted in three straight years of positive volume growth for greeting cards totaling 160 million additional cards in the mail but continues to face challenges from the approach adopted by the USPS pricing department on rates and weight limits. We will continue to work with both departments to maximize our cooperation to grow the greeting card market in the mail while ensuring that stamp rates remain as affordable as possible and consistent with the protections and requirements provided under the law.