The following is a perspective by postal commentator Gene Del Polito on an issue that is key to ensuring a continued growth of the quality of mail service. The views are the author's. PostCom welcomes the expression of alternative views by responsible spokespersons.

In the article just above, Business Mailers Review has provided a succinct summary of the arguments put forward by the Postal Service in its R2006-1 testimony regarding its proposed pricing of the Confirm service. I'd like to provide additional color.

Now, I don't know about anybody else out there who gives a hoot or holler for the preservation of the Confirm service, but I, for one, am quite tired of watching the Postal Service march down a road that (from my perspective) is guaranteed to drive mailers' interest in Confirm out of existence. I've toiled within this industry for some 23 years, but never...and I mean never...have I ever seen the Postal Service behave so obstinantly about an approach to an issue that was in opposition to the genuine and defensible views held by all...and I mean all...of its customers.

To put it bluntly, the Postal Service has, in this case, offered up a proposed Confirm rate structure that will cut off the legs of sorely needed mailer support. Not long ago, a gathering of postal customers sharing a vital interest in the continued viability of the Confirm program met with a cadre of postal lawyers and other postal functionaries. The purpose of the meeting was to voice the mailing industry's universal support for an alternative Confirm pricing proposal that had been advanced by the Office of the Consumer Advocate.

Just think about that for a moment. ALL mailers, representing First-Class and Standard Mail, chimed in with support for a proposal put forth by the OCA. Again, a truly unprecedented event.

The mailer representatives told the Postal Service in no uncertain terms that its pricing scheme would guarantee the crippling, if not the demise, of the Confirm service. On the other hand, the adoption of the OCA alternative, they said, would stimulate further industry interest in and use of Confirm as a method of monitoring mail processing and delivery. And there, I believe, is the rub.

The OCA and mailers were quite explicit in telling the USPS' representatives that they were baffled by the Postal Service's proposal or the rationale behind it. They noted that the deep-seated suspicion within the mailing community of the Postal Service's motivation was its desire to avoid the continued use of any mechanism that might provide some definitive transparency on the quality of service the USPS was providing.

Of course, the Postal Service, to a person, denied that it was trying to avoid transparent service performance measurement and public accountability. The affirmations of those who represented the Postal Service on that day may have been based in truth (at least as far as the participants were concerned), but the USPS' additional comments before the PRC in the R2006-1 proceeding have only strengthened the suspicion that the Postal Service was trying to avoid the bright light of accountability sunshine.

The USPS' witness affirmed that the only value Confirm had to the Postal Service was to provide some information on periodic, internally driven, service-related inquiries. It said it really didn't care what value mailers might be able to derive. All it wanted to know was that if mailers got any value, they'd have to pay for it.

Since when has the Postal Service derived no real value from Confirm? In numerous conversations with very senior postal officials, the USPS has always maintained that Confirm was of appreciable institutional value. And what also of the marketplace value that comes from telling prospective customers that the quality of service the USPS provides justifies continued investment in mail as a vehicle for business communication and commerce?

The Postal Service's arguments on this issue ring hollow. We can only hope that the Postal Rate Commission, and ultimate the postal Governors, can see through this thinly veiled attempt by management to be held up to public scrutiny.