ENVIRONMENTAL IMPACTS OF POSSIBLE RESPONSES TO ELIMINATING DIRECT MARKETING MAIL
As anyone who has read my past blogs on environmental issues knows, I believe that eliminating unsolicited direct marketing mail may help reduce the “annoyance factor” some mail recipients experience, but there’s no assurance that it will improve the environment.”
I have been concerned that if some of those individuals who stop receiving unsolicited mail get into their automobiles and buy an item at a retail store that they would ordered through a direct mail solicitation, the environment is worse off. Until I attended the recent Center for Research on Regulated Industries Conference, I did not have data to support my point. Now I do.
What I learned is that the carbon footprint of an automobile using an internal combustion engine in city or suburban driving going to and from a retail store is roughly 450 grams of carbon dioxide for every mile traveled. Preparing, transporting, and delivering a piece of direct marketing mail, including the work of converting trees to paper, results in approximately 70 grams of carbon dioxide. Therefore, if we were to eliminate 100 pieces of unsolicited marketing mail, and assume no substitute form of advertising that would generate carbon dioxide emissions, the result would be the elimination of 7000 grams of carbon dioxide. There is a small amount of carbon dioxide emission from the shipping out of the item by the postal service or a common carrier, but that carbon footprint is relatively small. This data was obtained from an economist who spoke at the conference, Larry Buc, in response to a question I asked.
What would happen to those 100 people not receiving the mail? Some would simply not shop at all for the item for which the direct mail solicitation was sent. Others would learn about it through the alternative form of advertising the marketer selected. Some would seek out a web site to shop for the item, such as a Google search effort, which, by the way, would have a substantial carbon dioxide emission resulting from the electricity consumed at the data centers containing the web site, at the routers transmitting the web site data to the shopper, and at the shopper’s own computer.
However, some would obtain the item at a retail store. If only one shopper of the 100 did a round trip in an automobile, the carbon dioxide emission would exceed the total for the 100 pieces of mail all by itself if the round trip exceeded 17 miles, i.e. 8.5 miles each way. When you add in the potential carbon footprint from the other potential choices, the only way in which eliminating 100 pieces of mail is a good environmental outcome is to assume that no one drives to a retail store and that most of the individuals do not otherwise attempt to acquire the item that was the subject of the solicitation.
More work has to be done to model out the impacts of eliminating unsolicited direct marketing mail, and, clearly, if someone has no intention of buying the item solicited from any source at any time, it makes sense for many reasons to eliminate sending the letter. Therefore, our goal should be to give mail recipients the ability to describe their choices and preferences in as much detail as possible as often as possible.
That is why the Direct Marketing Association Mail Preference Service is the best choice for people. It is the most sophisticated and granular consumer choice system in place, and, unlike the other systems, it recognizes the complexity and confusion that surrounds some consumer choices.
June 16th, 2008 at 10:49 am
Mr. Critelli,
I appreciate your intellectual approach to defending direct mail, but I think it’s a bit far-fetched to suggest that direct mail is environmentally beneficial because it replaces automobile trips.
For starters, even if we assume that your figures for carbon dioxide emissions are correct, the math just doesn’t add up to support the hypothesis that every 100 pieces of direct mail prevents one person from driving 17 miles in an automobile.
First, consider that the industry’s average response rate is only about 1 or 2%. Then consider that responses don’t necessarily translate into sales. Then consider that a large percentage of direct mail solicitations push products that don’t require driving (e.g. financial offers, insurance, internet / phone service, subscriptions, sweepstakes, charitable solicitations, etc.). Then consider that a large numbers of shoppers might not have purchased the item in the first place, if it weren’t for direct mail generating a desire for it. Then consider that most people don’t make separate trips for each individual item they purchase. Instead, they buy multiple items at once, as part of a shopping trip they would have made anyway. (In fact, one might argue that direct mail is inefficient because it causes people to buy individual items via mail rather than to purchase them as part of a consolidated shopping trip.)
When you take all this into account, it’s clearly wishful thinking to argue that one car trip is prevented for every 100 pieces of direct mail. The figure could just as easily be 1 out of 1000, or far worse. How many pieces of direct mail does an average postal worker deliver each day on an average route? It wouldn’t surprise me if delivering an entire postal route’s worth of direct mail prevents only a single person from making a car trip (if that), which means that a postal worker driving a route might be enough by itself to counteract the benefits of the direct mail being delivered. Finally, we have to consider that a few hundred thousand garbage trucks are required to haul it all away, and then there’s the environmental costs of recycling direct mail, or worse yet, not recycling it. (People often forget that recycling may be better than the alternatives, but it’s not without its own costs.)
I also fear that you’re committing a bit of an apples-and-oranges fallacy when you compare the environmental costs of computers and data centers with that of direct mail. No doubt, computers and data centers carry a huge environmental price tag, but they’re also doing a lot more than simply pitching a product. Direct mail does one thing. It sells, and it does so in an extremely inefficient manner (i.e. with an average response rate of 1 to 2%). Computers do an infinite number of things in addition to selling products, and they do so in a relatively efficient manner. You suggest that doing a Google search has a substantial carbon dioxide emission. What exactly would you say is the carbon cost of a single Google search?
Also, carbon emissions are obviously not the only environmental issue. Direct mail has other costs. Like the billions of gallons of water it wastes each year. And the pollution from paper mills, which release all kinds of nasty carcinogens into the water, air, soil, and food chain. And of course there’s the issue of trees. Yes, I know that “trees grow back” and that the nation’s quantity of trees has actually increased over the last half-century. But the paper industry is contributing to deforestation around the world, at a rate which National Geographic calls a “Forest Holocaust.” Furthermore, the industry routinely overlooks the vast qualitative differences between tree plantations and old growth forests in terms of biodiversity and so on. Not to mention that the industry’s creative accounting often ignores the double jeopardy of destroying a tree. When you kill a tree, you not only lose its ability to absorb carbon in the future, but you’re releasing the copious amounts of carbon it absorbed in the past. In other words, replanting a tree does not account for the full cost of killing one in the first place.
Finally, I would remind you that the environmental issue is only one among many. Even if you could prove that direct mail’s net effect on the environment is a positive one, there is still plenty of solid ground on which to build a Do Not Mail movement. (Remember that Do Not Call succeeded without any environmental arguments whatsoever.) For me, and millions of other Americans, it’s about the right to peacably enjoy one’s privacy and property. It’s about the right not to bear the hidden costs of a medium we despise. And it’s about the right to be left alone, which the esteemed Justice Brandeis famously called “the most comprehensive of rights and the right most valued by civilized men.”
Thanks for giving me this opportunity to share.
Rezzie Dannt
Junk Mail Revolt
http://www.junkmailrevolt.org/
June 17th, 2008 at 5:48 pm
Mr. Critelli,
In addition to the points I made previously, I’d like to mention one more flaw in your hypothesis that direct mail reduces car trips.
As you know, advertising mail often serves the sole purpose of driving traffic to local stores. For instance, I often receive coupons and sales notices from my local grocery stores, restaurants, bookstores, Home Depot, Macy’s, and so on.
Your analysis should probably factor in solicitations such as these, which encourage car trips that might not have otherwise been made.
Cheers,
Rezzie Dannt
Junk Mail Revolt
June 18th, 2008 at 12:02 pm
You have made a number of arguments both thoughtfully and respectfully, qualities often missing in the debate around mail. I agree most with the point you made in your last paragraph. The strongest reason for reducing the volume of unsolicited mail is the deference we should give to the rights of mail recipients to make an informed decision about what commercial marketing solicitations they should receive. That is why I strongly support the Direct Marketing Association’s Mail Preference (http://www.the-dma.org/index.php), since I believe it does the best job of any of the alternative services in driving the mail recipient toward informed choice. I would welcome your feedback or anyone else’s on the DMA service.
Pitney Bowes has been a strong believer that more targeted mail, particularly mail that is properly addressed, and mail that has been prepared only after accessing registries like the DMA Mail Preference Service is of much higher value than simply sending mass mailings without regard to whether someone wants to receive them.
With respect to your environmental arguments, your analysis is cogent, but you misunderstand the point I was attempting to make. I was not attempting to argue that for every 100 pieces of direct marketing mail eliminated, there would be one trip to the retail store. I was only trying to draw a comparison between the carbon footprint of two competing retail channels, with the goal of showing that bulk mail compares favorably to retail shopping, even the shopping trip at which a number of stops are made. By the way, the highest carbon footprint and energy consumption arises from starting a car, the stop-and-go driving that occurs at multiple retails stops, and the stopping of the car. Longer-distance high-speed driving, up to about 60 miles an hour, is a lower energy consumer and environmentally-polluting activity than a much shorter distance done at slower speeds.
No one can assess the relative environmental benefit of eliminating unsolicited mail without knowing what replaces it. Your analysis actually supports another argument I have made in the past, which is that the task of figuring out what replaces marketing mail is exceptionally complicated, because marketing of services is clearly different from the marketing of products, and because there are an almost infinite variety of retail marketing encounters, each with a different carbon footprint..
You have not figured into your calculation how the advertising money that was spent on mail would be spent alternatively, and what the carbon footprint of that alternative form of advertising would be. If the marketer uses web-based search engines, the storage and transmission of the search data each create a carbon footprint, starting with the prodigious energy consumption at the data center, and continuing with the energy consumed by routers and switches, and by the desktop computer or PDA that accesses the search engine.
You also make the assumption that when someone does not respond to a direct mail solicitation for a product, they are not using the catalog or direct mail piece to drive a decision to go to a retail store. I have done research and have asked around to a number of people, and I can find no research that gets at this behavioral response issue. However, without such research, we really do not know the environmental impact of eliminating mail.
With respect to your environmental arguments about trees, I support the efforts to insure that pulp and paper come from forestry practices that are certified by independent organizations like the Forestry Stewardship Council, and that we use recycled paper more than we do today. I am not convinced about your argument that tree harvesting is bad for the environment, but I will respond to that after getting feedback from others reading your comment and my response.
This is a complex subject, and I respect your effort to try to respond to my points with a level of seriousness and respect that I do not often see. To the degree that you find environmental research on this behavioral issue that I mentioned, I would welcome it, as I believe readers of this blog would as well.
June 19th, 2008 at 9:59 am
Thanks for the kind response. I agree that Do Not Mail is a more complex subject than it appears on the surface, and that respectful dialogue is too often lacking.
In regards to the DMA’s Mail Preference Service, I think it’s inadequate for a number of reasons. My primary complaint is that it’s not a comprehensive solution. It only applies to its 3,600 members, and not to the nation’s other 14 million businesses which send out some 20 billion pieces of direct mail each year.
In order to stop receiving mail from non-DMA members, the only option is to contact them one by one. When you consider the unholy volume of direct mail that the average household receives each year, this is clearly an unreasonable burden to place on the public.
It’s especially unreasonable when you consider how many businesses are unresponsive to opt-out requests. In my experience, it’s not just small, rogue mailers that fail to comply. It’s “respectable” organizations like Verizon, Home Depot, Dell, and Audubon Society. Even when contacted repeatedly over a period of months.
Opting out of mailing lists one by one is a Sisyphean nightmare, an unwinnable game of whack-a-mole. Even if you somehow manage to temporarily stem the flood of unwanted mail, there’s no guarantee that your data won’t be sold or rented, and that the flood won’t begin anew. God forbid you or someone you live with ends up on a “suckers list.”
Furthermore, the DMA’s service offers no legal recourse for the consumer. In fact, simply filing an informal complaint with the DMA can be a chore. How does one even know if a business is a member of the DMA or not? The member’s directory isn’t publicly accessible. Which highlights yet another issue – the DMA’s distinct lack of transparency.
And let’s talk about trust. The public has every reason to distrust the DMA. These are the same folks who fought on behalf of telemarketers to thwart Do Not Call (using a lot of the same disingenuous arguments they’re currently using against Do Not Mail). These are the same folks who at one point fought to perpetuate spam. And these are the same folks who are now fighting consumer-friendly legislation that would give consumers more choice over the mail they receive.
I could write a small book on why the DMA is undeserving of the public’s trust, but for now let me simply say that letting the direct mail industry regulate direct mail is like letting the fox guard the proverbial henhouse. The DMA’s service is almost 40 years old, yet 90% of Americans say they’re unhappy with the amount of direct mail they receive, and that they would favor a Do Not Mail registry. The DMA’s service has had four decades to work. It’s time for something new.
One final point: If Do Not Mail is superfluous, like the direct mail industry claims, then why is the industry fighting so fiercely to have it thwarted? If Do Not Mail is truly redundant, and the public’s needs are truly being met by existing services, then there’s nothing to fear, because nobody will need to use it. You see, there’s an inherent contradiction here. The industry either needs to admit that Do Not Mail is not as redundant as they say it is, or not as much of a threat.
Look forward to reading your response. I’ll leave the environmental issues on the table for another day.
June 23rd, 2008 at 8:22 am
With respect to retail trips resulting from direct mail solicitations, you are correct to the extent that some direct marketers which have retail outlets close to the homes and businesses of mail recipients, a minority of the total direct marketer population, try to drive retail traffic through the mail. I would note that this is equally true of e-mails, solicitations through web sites, TV, radio, and newspaper advertising, all of which try to drive consumers to visit retail outlets.
In fact, sophisticated multi-channel marketers use each channel, mail, retail, e-mail, the web site, and the telephone to reinforce one another in building customer relationships. This is why eliminating direct mail from the mix has unknown consequences. We do not know whether the result will be the use of TV, radio, the web site or multi-media messages sent via e-mail for more multi-media marketing, all of which could have an even bigger environmental footprint, or whether the customer will simply shop in more spaces to find the same item. What we most need is rigorous research on this subject.
Opponents of unsolicited marketing mail often assume that something unsolicited to which the recipient does not respond is unwanted, and, therefore, should not be sent in the first place. This is not accurate.
We know from privately-conducted research done by industry players that mail recipients distinguish between mail to which they do not respond, but that they value, and mail they do not want to receive at all. For example, we know that multiple discount coupons sent in one envelope may have a low response rate in any given mailing, but that recipients like to receive them.
We also know that recipients sometimes do not consider ordering through the mail until they receive a mailing that contains something they may have already acquired at retail. The result is that a mailing to which they do not respond will educate them about future opportunities to do mail-order shopping, instead of going to a retail store.
My biggest issue with intermediaries who collect names of people who want to get off mailing lists is that they are often uninformed about the nuances of customer relationships, and, therefore, cut off productive communications between marketers and their customers. We need to focus most on educating mail recipients to the fact that they have the ability to make informed and highly granular choices about their marketing preferences through the Direct Marketing Association Mail Preference Service.
I do not want to give the impression that the DMA should always be the only viable option for mail recipients who want to express their preferences. Their most productive dialogue may be directly with the marketer, which may have other offerings of which the customer is not aware.
With respect to other intermediary services, if they were to migrate toward a more informed, diverse, user-friendly, set of consumer choices that provided a viable competitive alternative to the DMA, I would certainly consider supporting them. However, we must keep in mind that having multiple “Do Not Mail” registries for consumers adds huge and unnecessary administrative costs for marketers, and probably drives some smaller, niche catalog companies out of business, thereby reducing product and service choices for consumers.
I appreciate the dialogue with you, and welcome any further comments you may have.
June 24th, 2008 at 11:31 am
I find it interesting that you didn’t address my specific concerns regarding the DMA’s Mail Preference Service (e.g. its lack of transparency, enforceability, comprehensiveness, and trustworthiness).
I’m also fascinated that you would praise the DMA’s registry for its diversity of choices, when it lacks the most fundamental choice of all – the option to completely opt out. That’s like a TV remote having 150 buttons, except for one that says “OFF.”
The fact is, the DMA can never provide comprehensive choice because, like I said before, its registry only applies to its 3,600 members. The only way consumers will ever have an OFF button is if it’s provided by way of legislation.
So here’s my proposal. Do Not Mail can serve as the OFF button, and consumers with more nuanced preferences can be referred to the DMA’s service. Everybody wins.
The added bonus is that a Do Not Mail list will encourage the industry to engage in more responsible mailing practices, and to improve its own registry in order to compete with Do Not Mail.
Surely, as a businessman, you can appreciate the age-old truth that competition leads to greater consumer choice. So if you’re as confident in the DMA’s service as you say are, then let it compete against Do Not Mail in the marketplace.
The fierce lobbying effort against Do Not Mail indicates that even those in the industry don’t believe their registry is very good. After all, if the DMA’s registry were good enough to withstand competition from Do Not Call, there would be little need to lobby against it.
Furthermore, if the DMA’s registry is truly as effective as you claim, then why after four decades do 9 out of 10 Americans still say they’re dissatisfied with the volume of advertising mail they receive?
And if the DMA’s registry is truly effective, then why do 9 out of 10 Americans support a national Do Not Mail list? (Hint: it’s not because they’re unaware of the DMA’s service.)
And if the DMA’s registry is truly effective, then why is the public pressuring lawmakers for Do Not Mail legislation?
And how do you account for the recent proliferation and success of third-party services like Catalog Choice? (The market has spoken, and it apparently doesn’t share your love for the DMA’s service.)
I’ve posed these question repeatedly to folks within your industry. Not surprisingly, the only response I ever get is the sound of crickets.
You suggest that third-party services are inferior to the DMA’s registry, but if that’s the case, then why is the DMA scrambling to catch up? There was nothing “diverse” or “granular” about the DMA’s registry until just recently, when it decided to copycat the feature-rich offerings provided by Catalog Choice.
Clearly, third-party service are forcing the DMA to improve. They’re the ones breaking new ground, while the DMA reluctantly follows. It only bolsters my argument that competition leads to greater consumer choice.
Also, I remember how the marketing industry used to praise its Telephone Preference Service, in much the same way that you’re now praising its mail registry. The industry was quite proud of the fact that after 20-plus years, it had registered nearly 5 million people.
Of course, the National Do Not Call List registered twice that number in its first WEEK, which would again tend to undermine the industry’s credibility when it claims that its registry is somehow a viable alternative to Do Not Mail.
One final point. You say that the “most productive dialogue may be directly with the marketer.” But as I’ve already pointed out, the average household receives over 800 pieces of advertising mail per year. It would take a lifetime to contact each marketer one by one, and even then, marketers often fail to comply with consumer requests.
I’m afraid that doesn’t sound like “productive dialogue” to me.
Thanks again for the opportunity to share.
July 1st, 2008 at 8:41 am
I deferred a response to the most recent comment about carbon being released into the atmosphere when trees are cut because I wanted to do some research on this. I also wanted to respond to the arguments about the water waste and pollution from paper mills.
With respect to the first point, the argument that all the carbon captured from the atmosphere is released back when a tree is cut is flawed. According to many sources, including Natural Resources Canada, http://cfs.nrcan.gc.ca/news/473, the Canadian Forest Service, in its May, 2007, Science Policy Notes, about 40% to 60% of the carbon remains in the forest when a tree is harvested, and the remainder remains in the logs that are removed from the mill. No carbon is released into the atmosphere. In fact, if trees are not harvested and they die and decay in the forest, carbon is much more likely to be released.
With respect to the water and other pollution that occurs when paper is produced from logs, this negative environmental impact needs to be balanced against the environmental impact of whatever replaces paper. To the degree that marketers or recipients connect through web-based search engines, depending on the amount of server capacity used on the web page and the time the recipient spends on the web looking at a marketing piece, there is significant data center power consumption from both operating the servers and cooling them. In fact, 2/3 of the energy consumed in a data center never gets to powering servers, but is used for cooling and power quality management. The electricity consumed is prodigious, and, in fact, according to a recent Gartner Group study, the IT industry, in total, is responsible for 2% of all carbon footprint.
As you might imagine, the environmental pollution from power plants, particularly if they are burning coal, is huge. Many of the components of each of these servers are hazardous and non-biodegradable once people need to dispose of them. In essence, there is no free lunch with respect to the environment.
I should also note that, as pointed out in a previous blog, many people who receive information electronically, particularly in the form of longer documents, print it at their desktops, and consume paper and ink even less efficiently than is the case when something is sent to them in the mail. For example, most marketing material is printed on two-sided paper, whereas most desktop printing is done on one-sided paper. Given the fact that 40-60% of the e-mails we receive are printed to be read and then disposed of, we may not eliminating paper once we eliminate direct mail and catalogs. We may simply be changing the point in the marketing value chain at which paper gets purchased and consumed.
I would reiterate my fundamental point: we should not eliminate paper-based mail for environmental or other reasons unless we have a reasonable understanding of what is likely to replace it.
July 2nd, 2008 at 6:59 pm
Thanks for the interesting article. I’d like to look at it more carefully before commenting.
If the IT industry truly accounts for 2% of the world’s carbon footprint, then what portion of that would you say is attributable to online advertising? There’s no way to say for sure, but would you care to make a ballpark estimate? Is the figure closer to 1% or 0.00000000000001%?
As you know, the nation’s computers do a LOT more than simply serve and display web ads. And as the Gartner Group study points out, the IT industry may account for 2% of the world’s carbon footprint, but it also promises to be highly instrumental in reducing the other 98%. The same can’t be said for direct mail.
Your environmental arguments are more clever than most because they rely heavily upon assumptions that are, at least for now, largely unverifiable and unfalsifiable (e.g. that online advertising represents a prodigious portion of the IT industry’s total carbon footprint). These kinds of arguments are a bit suspect when you consider that industries have a long history of using scientific uncertainty as a smokescreen.
The tobacco industry used scientific uncertainty as a strategic weapon during the debate over the carcinogenic and addictive nature of cigarettes. We saw similar maneuvering over lead, asbestos, and other toxins, and most recently, in the debate over global warming.
While I agree that the environmental impact of direct mail is a complex issue that warrants study, I would again suggest that the environment is only one important issue among many. Also of great concern is the fundamental right of 300 million Americans to be left alone, and to enjoy their privacy and property in peace.
The Supreme Court ruled in Rowan v. Post Office that, “a vendor does not have a constitutional right to send unwanted material into someone’s home, and a mailer’s right to communicate must stop at the mailbox of an unreceptive addressee.”
Furthermore, failure to give people the ability to opt out of unwanted mailings “would tend to license a form of trespass and would make hardly more sense than to say that a radio or television viewer may not twist the dial to cut off an offensive or boring communication and thus bar its entering his home.” (As I’ve already pointed out, the DMA’s registry is not a comprehensive opt out solution.)
The annoyance factor of direct mail is easy to dismiss as inconsequential, but let’s remember that “nuisance” is one of the most ancient and fundamental causes of action in common law. If my neighbor plays his radio too loud at night, I have legal recourse. But when direct marketers invade my home on a daily basis and at my own expense, I have none.
Most would agree that littering on someone’s property is wrong. But when strangers do it through the mail, dumping 800 pieces a year (up to 1,400 pieces for some demographics) on every American household, that’s somehow okay?
Most would agree it’s wrong when a computer hacker steals a mere fraction of a cent from a large number of people. But when an industry compels every taxpaying citizen in America to help foot the substantial cost of waste removal, that’s somehow okay?
Of course, it’s not just the money. Direct mail steals the most precious thing we have – time. It’s estimated that, over the course of a lifetime, direct mail robs each American of months worth of time that could be alternatively spent enjoying friends and family, learning a hobby, exploring new places, or just relaxing in the backyard.
Do Not Mail is not just about saving the environment or avoiding a minor annoyance. It’s about addressing the incremental erosion of our fundamental privacy and property rights. It’s about saying no to the unsanctioned encroachment upon our time, pocketbooks, homes, and lives. If that’s not important enough to warrant immediate action, I don’t know what is.
July 7th, 2008 at 1:57 pm
Let me begin by categorizing your points relative to unsolicited marketing mail into three categories:
• The right to be left alone;
• The “tax” on the removal of unwanted waste; and
• The relative environmental impact of mail vs. electronic communications.
You are most passionate about the right to be left alone, and, while I agree that the mail recipient should have the right to control what comes into the household relative to marketing communications, your comment about “months worth of time” lost to direct mail is ridiculous. Most Americans can make an instant decision about they want or do not want, and that decision is typically made in a few seconds a day. While that time might accumulate to 2-3 hours over 300 deliveries a year, it certainly is not months, weeks, or even days out of someone’s life.
This notion that 800-1400 pieces of mail are “dumped” into the household is also wildly overstated. About half of the mail is marketing mail, the other half consisting of transactional mail, such as bills and statements, greeting cards, personal correspondence, magazines, newspapers and parcels ordered by the household. The unsolicited marketing mail also includes non-profit and political solicitations, which, under every “Do Not Mail” proposal, are excluded from coverage. Surveys of mailers show that political and non-profit solicitations are as bothersome as unsolicited catalogs and credit card pitches, but those will continue to be “dumped” on the household. Essentially, we are talking about 200-600 pieces of unsolicited commercial marketing mail a year (more like an average of 1-2 a day) a legitimate annoyance issue, but not a crisis.
Your comment that the DMA registry is not a comprehensive “opt-out” solution is technically correct in that the DMA does not cover every marketer, but it has among its members the top 80% of the marketing population, and its registry, if used, would reduce unsolicited and unwanted mail to a small number, probably well below one piece a week.
The industry does not “compel every taxpaying citizen in America to help foot the substantial cost of waste removal.” The waste removal issue comes about either because recipients do not realize that virtually all unwanted mail is recyclable in most communities, or because a community’s recycling capability is not up to standard. I would agree that, to the extent recipients are “taxed” on the volume of mail they must put into landfills, their rights are being infringed, and their ability to stop receiving that mail should be enhanced.
Finally, your comment about scientific uncertainty is logically flawed. In the examples you cite, tobacco, lead, asbestos, or other toxins, the uncertainty debate hinged on flawed arguments by marketers of those products that there was uncertainty about their harmfulness. No one questioned that if tobacco, lead, asbestos, or other toxin production decreased, health and environment would improve.
In this case, we are acknowledging that unwanted mail has a carbon footprint, but the scientific uncertainty is based on the high likelihood that something else creating a carbon footprint will replace mail as a commercial marketing medium. The uncertainty is about the relative environmental impact of what replaces mail. If our mutual goal is to do no harm, then we cannot say that eliminating direct marketing mail achieves that goal.
Relative to your question about the environmental impact of using electronic media for marketing versus direct mail, that answer is not available today because no specific research has been done on it. We know that watching a TV for one hour has a carbon footprint of 70 grams, and that other common household activities like taking a two-minute shower has a carbon footprint equivalent to 40 pieces of letter mail (see http://www.pb.com/mailimpact) as a result of a study we released last week. However, no one has gone to marketers and asked them if they would replace direct mail with black-and-white text on their web site, color text on the web site, multi-media videos on the web site, blast e-mails, or some other form of web-based marketing, and what kinds of traffic volume they would anticipate.
No one has gone to consumers who forego receiving marketing mail to ask them how they would shop for items of interest to them. Would they go to a web site, drive to a mall, or, perhaps, go to a web site and print pages of interest to them to take to the mall? None of this kind of work has been done, so, unfortunately, it is difficult to answer your question.
Data on the power consumption and carbon footprint of data centers is highly proprietary information, and, in fact, data center operators are even reluctant to give their location or other information from which power consumption and carbon footprint data could be calculated. Moreover, the Internet, by its nature, involves the use of multiple telephone lines, multiple routers, and multiple servers in the presentation and transmission of data. Calculating carbon footprint is difficult relative to individual marketers and recipients, but this is the kind of exercise that needs to be attempted before we discard an effective communication and marketing medium.
July 7th, 2008 at 10:59 pm
“your comment about “months worth of time” lost to direct mail is ridiculous”
According to some estimates, a consumer spends eight months over the course of a lifetime dealing with advertising mail (see: “Marketing Without Consent,” Ross D. Petty, Journal of Public Policy & Marketing).
But let’s do the math ourselves.
The USPS says that people spend 20 minutes a day with their advertising mail. Folks will often scan or read an offer, even when they’re not interested. They’re likely paranoid about accidentally discarding something important, a justifiable fear when you consider what marketers do to make “junk” seem essential.
It takes time to separate and sort, scan and read, shred and dispose. (We won’t even talk about the time it takes to contact individual marketers regarding mail preferences, like you advise. The time spent on hold is enough to gray anyone’s hair.)
I personally think 20 minutes sounds a bit high. So let’s assume that people spend only 5 minutes a day with their ad mail, a mere 1/4 of the USPS’ estimate:
5 minutes a day * 303 delivery days a year * 60 years (average life expectancy after the age of 18) = 63 days over a lifetime
That’s 2 months right there. (3 months if you figure waking hours instead of a 24-hour day.)
“This notion that 800-1400 pieces of mail are “dumped” into the household is also wildly overstated.”
The numbers are straight from the 2007 USPS Household Diary Study.
On average, U.S. households receive 868.4 pieces of advertising mail per year. If you factor in unaddressed mail, the number rises to 977.6 pieces (see page 45). So in truth, I lowballed the numbers.
Some demographics suffer more than others. For example, when the head of a household is over 55 and earns more than $100,000 a year, the average number of advertising mail pieces rises to a whopping 1383.2 pieces per year.
In 2007, personal correspondence accounted for only 3.7% of mail received by households. That’s about 1 piece of personal correspondence for every 18.8 pieces of advertising mail. If current mail mix trends continue, the noise-to-signal ratio is only going to get uglier.
Yes, Do Not Mail proposals often exclude non-profit and political solicitations. Fortunately, those pieces account for a relatively small slice of advertising mail as a whole (i.e. around 14% for charities). I suspect most folks support this exemption, which is one of the reasons it’s there in the first place. Plus, the government affords greater liberty to political and charitable speech than it does to commercial speech, and that’s probably not a bad thing.
“would reduce unsolicited and unwanted mail to a small number, probably well below one piece a week.”
My family is signed up for the DMA’s registry, and I can tell you firsthand that this figure isn’t even close to being grounded in reality. Even the DMA doesn’t venture to make such a bold claim, and they say some wild things.
In June, my family received 39 pieces of ad mail. That’s with us being signed up with the DMA, using third-party services, protecting our personal data with religious zeal, contacting solicitors one by one, and filing prohibitory orders. When a privacy fanatic like me is on pace to receive 470 pieces a year, that says something.
“The waste removal issue comes about either because recipients do not realize that virtually all unwanted mail is recyclable in most communities, or because a community’s recycling capability is not up to standard.”
When I said “waste removal,” I was referring to the costs of picking up garbage AND recycling. Or are you suggesting that recycling programs don’t cost taxpayers money? In many cases, recycling is more costly than regular waste disposal.
“Finally, your comment about scientific uncertainty is logically flawed.”
All I said is “that industries have a long history of using scientific uncertainty as a smokescreen.” That’s a fact. The examples may not be 100% analogous to the mail situation, but they still support my basic point, which is that industries often wield scientific uncertainty as a rhetorical weapon.
“The uncertainty is about the relative environmental impact of what replaces mail.”
Yes, I fully understand your point. And as I’ve already stated, I agree that we should study the potential impact of Do Not Mail. I say this, in part, because I expect the findings to confirm my suspicion that your industry is wildly exaggerating on the relative environmental benefits of direct mail.
July 10th, 2008 at 8:58 am
This has been a fascinating dialogue. Thank you for continuing it.
Now, to your specific arguments:
• The person who finds unsolicited mail annoying does not spend 20 minutes with it. Survey data from multiple studies indicates that those who find such mail annoying typically discard it quickly. Those who spend 20 minutes a day or more are generally people who have an interest in what they receive. In fact, the U.S. Postal Service research from which the 20-minute-per-day figure comes indicates that the vast majority of mail recipients like to receive unsolicited mail, although parts of that mail annoy them.
• My comment about 800-1400 pieces per person being “overstated” does not refer to the total volume of mail, but to the portion of the mail that consists of unsolicited and unwanted marketing mail, which is a much smaller number. You noticeably avoided mentioning transaction mail, periodicals, parcels, and greeting cards, all of which come into the household with the consent of the recipient, and, which, cumulatively, are still about half of the total mailstream. Also within the remaining half of the mail, which is standard mail, are included newsletters, survey forms, and other relationship-building communications which people do not object to receiving.
• I would be happy to put you together with the DMA to figure out why you are still receiving so many pieces of unsolicited mail after signing on to the registry. I would note that it takes a few months for marketers to cleanse lists and that list cleansing after getting names from any registry is a complex process.
• That being said, the solution is not “Do Not Mail” legislation, but innovation in making existing registries, like the DMA Mail Preference Service, more effective and more widely known.
• Your comments about recycling costing taxpayers money is inconsistent with what I understand about the marketplace. Recyclable paper is in such high demand, particularly because of the demand from China and India, that municipalities can make a profit or at least break even for paper recycling programs (especially if they include the cost avoided for land filling or incineration). Recycling and waste removal firms are seeing a greater profitability as well.
• The fact that other industries use scientific uncertainty as a smokescreen may be true, but it is irrelevant in the context of the dialogue we are having here.
When we get past all the points made by each of us, the bottom line is that we agree on the need for further study of the relative environmental impact of mail versus other forms of marketing and communication.
I would go into such an inquiry without a predetermined conclusion, as I would hope you would. At the same time, I would make the following points:
• Whatever marketing channels are used in the future, we need to reduce their negative environmental impact. Requiring mail to be more environmentally friendly without constraining those who freely put multi-media videos on YouTube that consume significant electric power at a data center is applying a double standard.
• I am in full agreement with the notion that consumers should be able to make an informed choice about what they want and do not want to receive through any medium. Let us remember that, relative to the Internet, e-mail recipients must generally spend money and time to get an effective spam filter to screen out what they do not want to receive. If the right to be left alone is as deeply-imbedded in our society as you claim, then we need a system that does not require recipients to pay for screening out unwanted messages from some media, but requires them to pay for other screening mechanisms.
• We need to continue to be mindful of the difference between “unsolicited” and “unwanted” marketing communications. Survey research I have seen indicates that much of what mail recipients receive and do not respond to is not bothersome to them. For example, as surprising as it may seem, letters containing multiple coupons from multiple local vendors may not yield a high response rate, but they are not offensive or unwelcome in the household. On the other hand, repetitive solicitations addressed to deceased people or former residents of a household bother many people.
Let the dialogue continue.
July 12th, 2008 at 12:14 pm
This has been a fascinating dialogue.
I agree. This is an excellent debate, and I’m glad we’re having it. I appreciate your willingness to share your perspective.
One quick correction. The USPS “Mail Moment” study says that people spend 25 minutes a day reading ad mail, not the 20 I cited. Over the course of a lifetime, that amounts to ten months rather than eight.
The person who finds unsolicited mail annoying does not spend 20 minutes with it.
I’m not so sure.
According to a 2002 Yankelovich study, annoyance with ad mail goes hand-in-hand with high response rates. It’s a surprising paradox, but not inexplicable. Income is correlated with ad mail volume, which is correlated both with higher response rates and higher levels of annoyance.
Therefore, it wouldn’t surprise me if ad mail haters spend the most time reading it, seeing as how they’re the ones receiving the largest volume and responding at the highest rate. In other words, perhaps people grow more annoyed with ad mail as they receive, and thus read, more of it.
“Survey data from multiple studies indicates that those who find such mail annoying typically discard it quickly.”
What studies are those? I’d like to see them.
the U.S. Postal Service research… indicates that the vast majority of mail recipients like to receive unsolicited mail
No it doesn’t. What the study says is that 56% of us enjoy receiving mail. First of all, that’s mail in general, not ad mail specifically. Second, 56% hardly constitutes a “vast majority.” Third, I’m sure the figure would be much higher than 56% if people weren’t being bombarded with ad mail.
Show me a study that says people like ad mail, and I’ll show you a study that’s being twisted out of context, like the example above. Polls consistently show that 80 to 90% of Americans dislike ad mail, and would support a Do Not Mail list. In fact, the industry’s own focus groups confirm it.
My comment about 800-1400 pieces per person being “overstated” does not refer to the total volume of mail, but to the portion of the mail that consists of unsolicited and unwanted marketing mail, which is a much smaller number.
You raise a fair question. What percentage of advertising mail is unwanted? Sadly, the surveys are all but useless on this point. They ask questions like, “Do you sometimes find advertising mail interesting?” It’s misleading, because if respondents think two pieces out of 1,000 are interesting, then they answer yes, and the industry boasts, “See, people find ad mail interesting!”
The USPS Household Diary Study is the most helpful because it asks about individual mail pieces. However, it still uses terms like “interesting” or “useful,” rather than “wanted” or “welcome.” Big difference. I have personally read and responded to “interesting” offers that I would have preferred not to receive. I’m sure I’m not alone.
We need to continue to be mindful of the difference between “unsolicited” and “unwanted” marketing communications.
Likewise, we need to remain mindful of the difference between “mail that’s read” and “mail that’s wanted”; “mail that’s interesting” and “mail that’s wanted”; “mail that’s preferred over other mediums” and “mail that’s wanted”; “mail that yields a response” and “mail that’s wanted.” Too often, the industry fails to acknowledge these important distinctions.
Sure, people may read a piece of ad mail. They may describe it as “interesting.” They may prefer it over spam or a telemarketing call. They may even respond to it. But none of this proves that they want to receive it in the first place. What I’d like to see is a well-constructed survey that explicitly asks what people do and do not want. It’s the most basic question, but it’s never asked.
Regardless of how much is wanted, the fact remains that Americans receive an inordinate amount of advertising mail. Ad mail volume increased 32% between 2000 and 2007. Americans now receive a historically unprecedented 100 billion pieces of ad mail a year, which represents 3/5ths of all mail received by households, and almost a quarter of the world’s total mail volume (wow).
Again, we can debate how much of that is wanted, but there’s no denying that’s a lot of ad mail.
Your comments about recycling costing taxpayers money is inconsistent with what I understand about the marketplace.
I don’t know how the relative numbers add up nationwide. They vary from place to place. But I do know that in areas like New York City, recycling is more costly than regular trash disposal.
The fact that other industries use scientific uncertainty as a smokescreen may be true, but it is irrelevant in the context of the dialogue we are having here.
It is not irrelevant. It’s something for industries and consumers to be aware of when making and evaluating truth claims like the ones presented here. However, if you say that the mailing industry isn’t using smokescreen tactics, then I’ll take you at your word and we’ll leave it at that.
July 15th, 2008 at 12:57 pm
Thank you for your latest comment. Let me try to reconcile some of the areas of apparent disagreement between us:
• I am not surprised that those who receive a lot of unsolicited ad mail and respond frequently to it are also likely to be annoyed by it. Based on the surveys I have seen and the mail recipients with whom I speak, there is likely to be in a day’s mailbox at least one catalog or direct mail piece of interest to the recipient, and it is not improbable that the recipient would spend 25 minutes studying that catalog.
• At the same time, recipients receive many other solicitations, whether in the form of catalogs, letters, or postcards, that they either do not respond to, do not value, or do not ever want to receive again. What the Postal Service refers to as the “mail moment,” which is a moment of pleasure in checking the contents of the mailbox, often applies to a portion of what is received, as opposed to all of it.
• I also believe that there are catalogs that are valued only if received less frequently or at a different time of the year. We know that many recipients want the ability to continue to receive certain catalogs, but only at times when they are ready to shop. We also know that many recipients may like a particular catalog, but get it sent to them too frequently. We use the analogy of the remote control device: people want more than an on-off switch. They want the ability to change channels, to skip certain channels, to use a TIVO-like system to store programs until it is convenient to watch them, and to watch only so much TV at a time.
• Likewise, mail, for many recipients, is something they value in moderation, with high-quality marketing, proper targeting, and a compelling value proposition. When they get low-value mail, or they get it too frequently, they want the ability to say “stop.”
• As for your statistical data on mail volume, this is what I understand to be the correct data. In 2007, there were approximately 100.3 billion pieces of standard mail. There are 136 million delivery points, of which approximately 105 million are households. I am not sure about the breakdown of standard mail between households and other delivery addresses.
• Given the fact that standard mail includes not only marketing solicitations and catalogs, but also newsletters, newspapers, controlled circulation magazines, postcards containing notices and other information, such as community service information, I have to believe that the amount of pure marketing mail received by households is far less than the average of 100 billion, divided by 136 million, which is about 736 pieces per delivery point.
• I could not agree more with your observation that we need better survey data, because much of what we are attempting to interpret does not get at the issues about which you and I are having this conversation.
Do not misunderstand me. I believe that mail is most valuable as a communication medium when it is matched to people who want to receive it. Marketers should be eliminating duplicates, targeting people based on criteria that would indicate some predisposition of interest, and respecting the recipient’s preference not to receive some or all of the mail they receive.
The best marketers, like Jack Mitchell, the owner of Richard’s of Greenwich, a men’s clothing store, and the author of two great books, Hug Your Customers and Hug Your People, get to know customers through employees and managers that engage them in friendly and in-depth conversations every time they come into the store. Jack and his team understand when to make a phone call, when to send an e-mail, when to mail a handwritten note, and when even an unsolicited gift in the mail is a powerful message that they love the customer.
All marketers should be following that formula. Too many fall far short of that.
Recycling
Relative to your comment about recycling cost, I can only say that your waste disposal firm has the potential to make a profit from the recyclable material it collects from you. If that profit opportunity is not being shared with you, perhaps there is another way for you to profit from how you recycle your waste, or, at a minimum, to spend less.
In an unrelated context, Pitney Bowes used to receive customer postage prepayments and charge a fee, but give the customer no interest on prepaid deposits. We finally figured out that there was more money to be made from paying our customers 1% on their prepaid postage balances. I would hope that waste disposal firms will come to the conclusion that they are better off sharing profits with those from whom they collect waste.
Thank you again for your comments.
July 25th, 2008 at 11:58 am
Thanks for your latest post. I have a few belated comments.
As for your statistical data on mail volume, this is what I understand to be the correct data.
My statistical data comes directly from the 2007 USPS Household Diary Study. You seem to think I’m extrapolating my data from standard mail statistics, but that’s not the case. The USPS says, and I quote, “Households received 100 billion pieces of advertising mail in 2007.” Even this is an understated figure because it excludes unaddressed advertising mail, which accounted for an additional 12.6 billion pieces.
In 2007, there were approximately 100.3 billion pieces of standard mail.
You say that standard mail is more than just advertising. But let’s remember that the converse is also true — advertising is more than just standard mail. According to the USPS, only 83 percent of ad mail is standard; the rest is first-class.
We use the analogy of the remote control device: people want more than an on-off switch.
Do Not Mail is an off switch, yes. But let’s not paint it as a crude, all-or-nothing device that prevents “diverse” and “granular” choice. Bear in mind that Do Not Mail registrants can contact marketers directly if they wish to opt-in to mailings, or to express nuanced marketing preferences.
While contacting marketers directly is a highly impractical way of opting OUT of mailings, it is ideal for opting IN. In other words, it is far easier to opt in to a small handful of wanted mailings than it is to individually opt out of hundreds, or even thousands, of unwanted ones.
Of course, those who enjoy the bulk of their ad mail aren’t required to use the registry. They can simply contact marketers directly, as you recommend. For the rest of us, however, contacting individual mailers to opt out makes about as much sense as ordering at a restaurant by naming all the dishes on the menu that you don’t want, as opposed to the few that you do.
What the Postal Service refers to as the “mail moment,” which is a moment of pleasure in checking the contents of the mailbox, often applies to a portion of what is received, as opposed to all of it.
Clearly, for the 80 to 90% of Americans who support Do Not Mail, the pleasure of receiving advertising mail is outweighed by the pain.
By the way, the direct marketing industry has a long history of misrepresenting public opinion. Prior to Do Not Call, the industry claimed that most people like telemarketing calls. It wasn’t true, of course, and millions of Americans signed up for Do Not Call within the first week. Amusingly, even some top DMA executives signed up.
All marketers should be following that formula. Too many fall far short of that.
While we have our areas of disagreement, I’m glad we can agree on some of these points.
Have a great weekend.
July 28th, 2008 at 1:29 pm
I am posting your comment a few days ahead of my response, because, while I have read the 2007 Household Diary Study to which you refer, and believe that you have oversimplified a complex set of findings, I want to take time to frame a response and to review it with some of my colleagues. Nevertheless, I thank you for your thoughtful response and look forward to continuing this dialogue when I post my response.
July 28th, 2008 at 2:27 pm
I look forward to reading your reply. One word of caution — be careful not to confuse individuals with households. I noticed earlier that you were citing stats for individuals, while I was citing stats for households. That could explain why your figures are in the 500-600 range, while mine are in the 800-900 range.
July 31st, 2008 at 1:56 pm
Thank you for presenting data supporting your position from the 2007 U.S. Postal Service Household Diary Study (the “Study”). I had not read the Study from cover to cover until prompted to do so by your comment. You used it to support one conclusion, which is the total volume of advertising mail, but it also has very granular detailed analysis of consumer attitudes toward the mail they receive. As an absolute authority on total volumes, the Study can only estimate volumes, since it is a self-reported sampling of approximately 5,000 households that complete elaborate and detailed surveys of the mail they send and receive. From the results received from these households, the Postal Service draws conclusions about the total universe of mail. There is some degree of error inherent in any sampling process, although I commend the Postal Service for doing a better job than any postal service in the world in attempting to understand customer attitudes and behaviors.
Nevertheless, the differences in our numbers relative to the total volume of advertising can be explained by the fact that you are counting all first-class advertising mail and all standard mail classified by the Study as “advertising”. The Study categorizes certain mail as “advertising” that most people would not automatically consider advertising:
• For example, 11.1% of “advertising” mail is first-class mail which might have a transactional statement, but the statement may also have an advertising insert. The Study appears to categorize this as “advertising” (Table A1-3 of the Study)
• Additionally, if someone sends me an invitation to an event or an announcement of a change of address, a promotion, a formation of a partnership, or some other honor this is categorized as “advertising” and constitutes 1.9% of advertising mail. (Table A1-3)
• As you pointed out, 13% of the advertising mail is non-profit mail (Table 5.2)
• Newspapers and magazines constitute another 5% of the total. (Table A1-3)
• Mail from the federal government is another 1.3% (Table A1-3).
Thus, 18% of what the Study characterizes as advertising mail is not consistent with the popular understanding of what is advertising mail. The other 14.3%, non-profit and federal government mail, would not be able to be eliminated through any of the pending “Do Not Mail” legislation, even if it were objectionable advertising mail, since non-profit and government mail are excluded from all the proposed legislation.
.
There are 110 million households. There are 112.8 million pieces of mail classified as “advertising” (100.3 million, plus 12.5 of unaddressed mail). But 32.3% of the 112.8 million, or about 35 million, needs to be subtracted from the total. Assuming that the numbers are accurate, that is 700 pieces of self-described “advertising” mail per household, or about 300 per person per year. Thus, on average, Americans get one piece of advertising mail per delivery day each year. Obviously, some Americans receive considerably more per day, particularly at times of the year when direct marketers are aggressively marketing goods and services, such as the pre-holiday period. But, frankly, you have used aggregate numbers without analyzing what they mean.
With respect to whether the per-individual or per-household mail volumes are more relevant for purposes of determining the perceived overload relative to unsolicited mail, a case can be made either way. In multi-person households, we know that there is usually a “CEO” of the household who does an initial review and screening of the mail, so that person could arguably feel burdened by unsolicited. However, we also know that mail is addressed to multiple individuals in the household, and, therefore, each person has a smaller volume of mail to which to respond. In our household, for example, our 17-year-old son, who is between his junior and senior years of high school, is receiving a huge volume of unsolicited marketing pieces from colleges and universities. He did not receive this kind of mail a year ago, and will probably get less mail addressed to him next year at this time. He separately looks at these pieces, although we separate those out for him. Ultimately, the perception of overload is most likely to happen when it is based lack of value of what is received, rather than a particular volume level.
But I am glad you brought up the Study, because I believe it accurately profiles how Americans think about direct marketing mail, and I believe that your point of view and mine are not that far apart on what we would conclude.
The Study, along with many other studies we have seen over the years, including surveys done daily during the 2001 anthrax crisis consistently demonstrates the following:
• Table A3-18 of the Study probably gets it right in terms of the reaction to advertising mail. If someone is a previous customer of the advertiser, the mail is read or looked at 74.5% of the time. Organizations known to households also get a favorable response, even if the household is not a customer of that organization. On the other hand, if mail is from an organization unknown to the recipient, the mail is discarded or set aside 53.5% of the time. I would also suggest that there is a difference among unknown organizations as to whether they are local businesses or not. As I have noted in previous blogs, if someone moves into a community, they value receiving solicitations from businesses offering potentially valuable products and services, even if they do not know that organization. For example, they do not value receiving solicitations from unknown organizations offering a mortgage refinancing.
• Even when someone receives an advertising piece from a marketer with which they have done business, they still discard or set aside the piece over 25% of the time, which suggests that there is a limited tolerance for receiving advertising from any marketer. Marketers need to understand what that tolerance limit is.
• Your quote that 80-90% of Americans favor some form of “Do Not Mail” registry is probably accurate. What they hope to accomplish from such a registry is not clear from the survey. Most likely, they would like to receive considerably less mail from non-local organizations they do not know, and perhaps less frequent and voluminous mailings from organizations they know or with which they have done business.
What this all means is that marketers, individually and through organizations like the Direct Marketing Association, need to find ways to learn consumer preferences and to honor those preferences. The Postal Service needs to have rate structures that promote better targeting, as opposed to saturation mailings to a particular ZIP code.
We should not use blunt instruments like a mandated “Do Not Mail” registry operated by government, because it is highly unlikely to be designed to help consumers define their preferences with the precision needed for marketers, and because it will tend to disconnect marketers from building relationships with their customers that will result in the best possible matching of preferences and advertising solicitations.
I would make one other point that often gets forgotten in these debates about advertising mail. The content of mail is subject to anti-fraud and anti-obscenity laws that are subject to enforcement by postal inspectors. The same content, delivered through other media, other than telephones, is not subject to a specialized enforcement system. While general law enforcement authorities can take on fraudulent marketing practices in other media, they generally do not do so. Thus, if we believe that there is objectionable content in the mail, chasing it to another marketing medium does not necessarily cause it to go away. It may simply cause it to be delivered in a less-effectively-regulated medium.
August 1st, 2008 at 11:02 am
In regards to ad mail volume, I see some big errors in your reasoning and reading of the data.
First, ad mail is ad mail, regardless of who it’s from. It’s silly to suggest that solicitations from non-profits and government agencies don’t qualify as ad mail because they might one day be exempt under Do Not Mail. Your argument is a non sequitur if I’ve ever seen one.
So let’s add that 14.3% back to the total.
Next, your figures are wrong for secondary first-class advertising (e.g. inserts). If you look at Table 5.2, you’ll see that the correct figure is 7.9 billion pieces, not 11.1%. The 11.1% figure from Table A1-3 represents ALL first-class mail advertising, secondary AND primary. (I know, the table is confusing.)
Also, it’s not 11.1% of AD MAIL, like you say. It’s 11.1% of ALL 150.9 billion mail pieces (pp. 12-14) received by households. We can verify this by doing the math: 11.1% of 150.9 billion is 16.75 billion, which matches up nicely with Table 5.2’s total of 16.9 billion for first-class advertising.
Furthermore, according to Table A1-3, ad mail (minus periodicals) accounts for 66.3% of the total 150.9 billion mail pieces received by households. When you do the math, that’s 100.05 billion pieces of ad mail, which is consistent with the total of 100.5 billion shown in Table 5.2.
(Side note: it’s a pretty incredible statistic that ad mail accounts for two-thirds of all mail received by households. When you factor in unaddressed ad mail, and subtract secondary ads like inserts, the figure increases to 70%. That’s right, “junk mail” accounts for every 7 out of 10 pieces of household mail!)
What this means, of course, is that it was a mistake to subtract for magazines and newspapers, because the figure of 100 billion ad mail pieces already excludes periodicals. I repeat, the figure of 100 billion ad mail pieces does NOT include periodicals.
So here’s the bottom line. When we take 100.5 billion pieces of ad mail, add 12.6 billion pieces of unaddressed ad mail, and then subtract 7.9 billion pieces of secondary first-class ad mail (e.g. inserts), that leaves us with a grand total of 105.2 billion pieces of ad mail.
Please note that I originally ignored secondary first-class ad mail such as inserts for simplicity’s sake, not out of ignorance or an effort to deceive. I figured it wasn’t a problem since I was also ignoring unaddressed ad mail, which more than compensates for the omission.
Also, I intentionally count business invitations and announcements as ad mail, because many of us, including the Postal Service, view them as such. Of course, even if we didn’t count them, our ad mail totals would still surpass the 100 billion mark.
One final thought about ad mail volume. Even if my numbers were overstated, which they aren’t, my original point would still hold true–Americans receive a lot of ad mail. In fact, we receive a historically unprecedented amount that far exceeds what anyone else in the world receives.
Over the past two decades, ad mail has been the fastest growing medium besides the Internet. (source: Courier Express and Postal Blog) And in the last 50 years, the amount spent on direct mail has grown by 15,541%. Yes, that’s fifteen thousand percent! (see: The DMA 2005 Statistical Fact book, pp. 11-14)
Are Americans inundated with ad mail? You bet. It’s an indisputable fact.
I believe it accurately profiles how Americans think about direct marketing mail
We differ on this point, as well. In fact, I think the section on consumer attitudes and behaviors is the most problematic part of the entire study. The results are heavily, heavily skewed in favor of the mailing industry, and not at all consistent with other survey data.
A number of obvious shortcomings spring immediately to mind:
First, the study is prone to acquiescence bias (i.e. participants telling researchers what they want to hear). It’s obvious from the start what the study is about, who it’s for, and what sort of answers would please the researchers.
Second, the study is prone to selection bias. The self-selected participants know what the study is about prior to signing up. I suspect that those who possess an interest in, and fondness for, receiving mail may be more likely to participate than those with other views.
Third, participation in the study may very well taint participant attitudes. I know if I were commissioned to maintain a daily diary about the mail I receive, I would suddenly read my mail a lot more carefully and find it a lot more interesting. Do participants find ad mail just as interesting when they aren’t participating in a study? I somehow doubt it.
Fourth, the questions are sometimes poorly constructed.
Fifth, the data is at times misinterpreted and/or misapplied.
I’d say more on these last two points, but I’m running long.
The Postal Service needs to have rate structures that promote better targeting, as opposed to saturation mailings to a particular ZIP code.
I’m glad you mentioned saturation mailings. As you know, 12.6 billion pieces of ad mail are unaddressed. This is yet another reason why contacting individual marketers is an impractical solution for opting out of unwanted mail. There simply is no way to opt out of unaddressed saturation mailings. (To be effective, Do Not Mail legislation would obviously need to outlaw the practice altogether.)
On a side note, when the DMA claims that its registry stops up to 80% of ad mail, are they factoring in unaddressed ad mail? I highly doubt it, which means that the real number is probably around 68% rather than 80%. In my experience, even that’s probably generous.
We should not use blunt instruments like a mandated “Do Not Mail” registry operated by government… because it will tend to disconnect marketers from building relationships with their customers.
Couldn’t disagree more. For one thing, as you probably know, pre-existing business relationships will likely be exempt under Do Not Mail. Furthermore, Do Not Mail would offer a terrific incentive for marketers to focus on building better relationships.
Finally, your argument echoes the specious claims of the telemarketing industry prior to Do Not Call (DNC). Here’s what a few folks within the telemarketing industry have to say in retrospect:
“What’s happening is that outbound calling is changing, and it’s going from blind calling which by the end had a very, very small success rate (we’re talking one or two percent), to relationship calling which is a very positive event for everybody involved… DNC did not kill outbound dialing. DNC prevented companies from disruptive dialing, and therefore, I think it’s tremendously positive.” — Donna Fluss, Call Center Magazine Columnist
“(The Do-Not-Call list) is a positive thing. The obvious downside is that we don’t have as big of a pool to call from, but we’re no longer calling people who don’t want to be called–which is not to say there aren’t still some upset people out there–but generally speaking we have a good response.” — Mike Shipley, Director of Operations at Moneyline Financial, an outbound call center
”As we eliminate people who are less likely to buy from our call lists, the success rate of telemarketers gets better.” — Tim Searcy, Chief Executive of American Teleservices Association
“In recent years, despite the creation of a national do not call registry, the legitimate telemarketing industry has grown, according to the Direct Marketing Association.” — New York Times
“I favor it [the national 'do-not-call' list] strongly. I think I’m wasting money calling people who don’t want to talk to us. I’m irritating them and giving us a bad image.” — George Dalton, Telemarketing Executive
“[The national 'do-not-call' list] helped us. You have fewer names but a better hit ratio. You’re getting all the people who will never respond favorably to your phone call out of the way.” — Steve Korn, Telemarketing Executive
I have more, but I’ll leave it at that for now.
August 8th, 2008 at 8:59 am
You have made three points, but I will take them in reverse order:
1. Relevance of the “Do Not Call” experience
The “Do Not Call” registry was an appropriate response to a series of issues associated with unsolicited commercial telemarketing, including, the intrusiveness of the calls at times chosen by the solicitor, but inconvenient to the household, and the fact that many people receiving calls purchased goods and services under perceived duress.
Mail is a relatively non-intrusive medium. Recipients choose when to collect and read their mail, and mail does not demand a real-time response. For this reason, telemarketing and door-to-door solicitations have historically been subject to rescission because of the potential for undue sales pressure. As a company, we found that telemarketing was more effective than mail in getting business, but that the customer cancellation rates were higher for telesales versus direct mail sales, so we have reduced commercial telesales activity.
Many marketers increased direct mail activity to substitute for less-effective outbound telesales activity for good reason.
While the “Do Not Call” registry has significantly reduced unwanted telemarketing and telesales from commercial sources, its negative economic impact is far lower than a “Do Not Mail” registry would be. Telephone costs did not significantly increase because of the reduced number of telesales calls, since those calls were an insignificant part of the total call universe. As you correctly point out, the U.S. postal system is heavily dependent on direct marketing mail, even if we disagree on the exact percentage of the total. The economic impact on other parts of the mail, periodicals, packages, greeting cards, and transaction statements, would be devastating, since there is no realistic way to reduce the total postal system infrastructure in a short period of time. Prices of every other postal product would skyrocket if a high volume of direct marketing mail were removed quickly from the system.
2. Validity of Postal Household Diary Study Data
While every survey has potential bias built into it, the findings of the 2007 Postal Service Household Diary Study are consistent with multiple research surveys done by many organizations over many years. The particular relevant findings are that recipients are comfortable with receiving unsolicited mail that is relevant, credible, and personalized from organizations with which they have done business, national organizations with recognized and respected brands, and local community organizations. They do not like receiving mail from unknown non-local organizations, and, as the Household Diary Study indicates, they are likely to discard such mail without opening it.
3. Analysis and Interpretation of Household Diary Study Data
While I believe the Postal Service has done a thoughtful and even masterful job in conducting and presenting this survey data, we can agree on one thing: finding the data we are trying to pull from the survey is confusing and challenging.
Nevertheless, let me try to reiterate what I was saying:
• The data indicates that there are 100.3 billion pieces of addressed mail described as “advertising” out of 150.9 billion pieces received by households in 2007. Of that total, 7.9 billion consists of advertisements placed in first-class transaction statements, which are not generally troublesome to recipients, because they already have a relationship with the marketer. These kinds of advertisements would not be affected by any proposed “Do Not Mail” legislation.
• There are 13.5 billion pieces of advertising mail sent by non-profits and approximately 1.8 pieces sent by governments. While these may be bothersome and offensive to recipients, no proposed laws would eliminate them.
• There is potentially another 9.9 billion pieces of newsletter-type mail characterized as “advertising” by the Household Diary Study. These are not “periodicals” as the Postal Service defines them. They do not tend to be considered “junk mail” in any survey I have seen. Whether they are part of the population of “advertising” mail is unclear, although they are part of the “standard mail” population, which is generally characterized by the Postal Service as “Advertising.” (See page 10 of the Study.)
Therefore, when I was trying to cull these portions of the mailstream out, I was doing so because my broad-based understanding of what troubles people and what “Do Not Mail” legislation, if passed, would address, would exclude these types of mail. Whether they are “advertising” or not is not the question. The question is whether legislation is targeted at eliminating them. In the first two groups, ads placed in first-class transaction statements and ads placed by non-profits and government into the mail, the answer is clearly “no.”
The broader questions continue to be:
• What would replace unsolicited marketing mail, and what would its impact be?
• What is the best way to address the legitimate issue of people receiving mail and other forms of unsolicited marketing that they do not want to receive?
With respect to the first question, there are two parts to the question:
• How would marketers redirect their advertising dollars?
• How would recipients learn about what is available to them in the absence of unsolicited mail?
As I have noted in previous posts, with respect to environmental issues, there is no “free lunch.” Every alternative marketing channel is likely to have an environmental footprint, and studies need to be done about whether the most likely combination of marketer responses would be better or worse for the environment than unsolicited mail.
With respect to recipients, we need to follow the same line of inquiry. However, as I noted in the blog that precipitated this series of exchanges, if only one of 100 people who used to receive mail go somewhere to shop, the environmental impact would be worse. Whether that ratio is one of 100 or one of 1000 is unknowable, but work needs to be done on this.
Relative to privacy, there is far less protection for an individual’s privacy when he or she does a search on the Internet, given the ability to assemble data from multiple places, than any privacy issues associated with mailing lists. Mailing lists are single points of data about an individual, but a person’s activity on the Internet, in combination with publicly-available data posted on the Internet, has the potential to be far more intrusive from a privacy standpoint.
August 11th, 2008 at 1:54 pm
There is potentially another 9.9 billion pieces of newsletter-type mail characterized as “advertising” by the Household Diary Study…
Again, you’re misreading the data. I can assure you that newsletters are not counted as advertising. As table A3-1 clearly shows, newsletters constitute one category of standard mail, and advertisements constitute a different category altogether.
Now that I’ve systematically refuted your assertions that my figures for ad mail volume are inflated with newsletters, inserts, periodicals, etc., it’s time to concede that American households received 105.2 billion pieces of ad mail in 2007.
Honestly, I’m surprised that this is even a point of contention. The 100 billion figure is widely accepted in the industry. It’s cited by the Postal Service and respected industry news sources like Postcom. It’s right there in black and white for anyone to verify.
Whether they are “advertising” or not is not the question.
But it is the question. If you recall why I mentioned the 100 billion figure in the first place, it was to make the point that Americans are inundated with ad mail. You then questioned the accuracy of my statistical data, and said I “used aggregate numbers without analyzing what they mean.” That’s what we were debating. Possible exemptions under future legislation is a separate issue entirely.
Mail is a relatively non-intrusive medium.
The 89% of Americans who support legislation would probably disagree with you.
Ad mail may not interrupt dinner, but it can be even more invasive than telemarketing. For example, a telephone can be unplugged; a mailbox cannot. Calls can be filtered with caller ID; mail cannot. Moreover, sales calls don’t need to be shredded, or hauled to the curb and trucked away at taxpayer expense.
Also, it’s far easier to opt out of a telemarketing list than a mailing list, because you already have someone on the phone. You don’t need to call a business and wait 5 minutes on hold, or buy a stamp to opt out. And of course, telemarketing is less environmentally destructive than direct mail.
there is no realistic way to reduce the total postal system infrastructure in a short period of time.
You’re a business executive — and perhaps a parent, as well — so you know how excuses work. It’s easy to list a million reasons why something can’t be done. You don’t support a Do Not Mail registry, and I get that. But I’ve yet to hear to hear a compelling reason why one couldn’t or shouldn’t be created.
Take your argument, for example, that the postal infrastructure can’t be downsized in a short period of time. If that’s truly the case, then let’s do it gradually. Let’s create a first-come, first-serve registry that only allows a limited number of new registrations each year. You see, there’s always a workaround.
Prior to Do Not Call (DNC), the direct marketing industry told all kinds of gloom-and-doom stories. They said DNC would destroy the industry, sink the economy, harm the phone companies, devastate small towns and small businesses, on and on and on.
Of course, it was all hyperbole and propaganda. Not only did the telemarketing industry survive, it has actually grown since DNC was instituted five years ago. Industries and economies are far more resilient and adaptable than anti-regulation rhetoric would have people believe.
Prices of every other postal product would skyrocket….
Postal employees sometimes claim that if Do Not Mail passes, it will cost $5 or $6 to send a birthday card to Aunt Minnie. The DMA, I’m happy to report, is a little more restrained in their fear-mongering. They only claim that the price of a first class stamp will increase by 14 cents.
How did they arrive at this figure? Well, ad mail represents 1/3 of the Postal Service’s revenue, so by the DMA’s reasoning, postal rates would need to increase by 1/3 to make up the difference. (One-third of the cost of a 42 cent stamp is 14 cents.) Not exactly a thoughtful or thorough analysis, is it?
The first obvious flaw here is the convenient omission of the fact that in addition to revenue, ad mail also generates 1/3 of the Postal Service’s COSTS. In the long run, any decline in revenue will be accompanied by a relatively proportionate decline in costs.
(Sure, there are things like sunk costs and economies of scale to consider, but even so….)
The next flaw is the assumption that Do Not Mail will eliminate ad mail completely. If history is any guide, only about 65 to 70% of the population will sign up. Furthermore, there will be exemptions for pre-existing business relationships, charities, politicians, etc.
This alone could easily reduce the DMA’s estimated price increase by at least half. Let’s also remember that while Do Not Mail will shrink the pool of potential prospects, people who are more receptive to ad mail will likely receive more of it. Plus, some folks will choose to opt IN to certain mailings.
Furthermore, there are any number of alternatives to raising rates, like rethinking “sweetheart deals” for big mailers. Large corporate advertisers enjoy ridiculous discounts that have, at times, been well below the Postal Service’s costs.
Postal economics is an exceedingly complex topic, but something’s clearly wrong with the rate structure when direct mailers pay rock-bottom prices with razor-thin margins, and earn a whopping 1250% return on investment, while the Postal Service faces billion dollar deficits and struggles just to stay afloat.
…every survey has potential bias built into it…
All studies are susceptible to bias, but that doesn’t mean they all suffer from it in equal measure. Surveys can be scientifically designed to minimize bias, or they can be designed in a half-witted manner that renders their results useless.
For the reasons I cited earlier, the USPS study isn’t suited for accurately gauging consumer attitudes and behaviors. The flaws I mentioned are significant and avoidable. They need to be addressed before that section of the survey can be taken seriously.
Every alternative marketing channel is likely to have an environmental footprint
Yes, every medium has an environmental footprint. But you’ve yet to demonstrate that ad mail’s footprint is smaller than that of alternate mediums. If anything, your thought experiments have shown the opposite.
if only one of 100 people who used to receive mail go somewhere to shop, the environmental impact would be worse.
Again, your hypothetical 1:100 ratio is way off the mark. When you consider that the industry’s average response rate is only 2%, and that many ads are selling services that don’t require driving in the first place, and that folks often buy multiple items at a single shopping location, and that some folks would be too lazy or gas-conscious to make a special trip, etc., etc., the ratio is obviously nowhere near 1:100.
Here’s why we don’t need further study on the matter:
If it takes a lot more than 100 pieces of ad mail to replace a car trip, (which it clearly does), and we assume that the carbon footprint of 100 pieces of ad mail is roughly equivalent to one car trip, (as you suggest), then we can safely conclude that ad mail generates a much larger carbon footprint than the car trips it supposedly replaces. No further study is required.
But if you’re still not convinced, then let’s use the marketing industry’s own figures:
The DMA estimates that 110 million shopping trips were replaced by mail order purchases in 2004. If 105 billion pieces of ad mail replaces 110 million car trips, then we’re talking about a ratio of 1:1000. This means that the carbon footprint of ad mail is about 10 times greater than the car trips it replaces. It also means that your hypothetical ratio of 1:100 is off by a factor of 10.
there is far less protection for an individual’s privacy when he or she does a search on the Internet, given the ability to assemble data from multiple places, than any privacy issues associated with mailing lists.
Four quick points:
1) You’re fond of red herring. We’re talking about ad mail’s sins, not the Internet’s. Whether one is worse than the other is irrelevant. Both mediums have serious issues that need to be addressed.
2) The Internet is opt in. I know there are privacy risks when I go online, but I believe the benefits outweigh the costs–so much so that I’m willing to pay for Internet access.
In contrast, I never signed up for ad mail to invade my privacy, and I believe its costs outweigh the benefits–so much so that I’m willing to pay NOT to receive it. Entirely different situation.
3) The Internet’s most serious and persistent privacy issues can be avoided by exercising a little caution (e.g. disclosing personal information only to trusted websites). Those who are extremely concerned about privacy can use things like proxies and other technologies to anonymize web browsing.
4) Contrary to your claim, the mailing list industry is NOT just using single points of data. Mailers have been assembling data from multiple sources for decades. (See: “Data Mills Delve Deep to Find Information About U.S. Consumers,” Wall Street Journal, March 14, 1991).
What is the best way to address the legitimate issue of people receiving mail and other forms of unsolicited marketing that they do not want to receive?
I believe you already know my answer.
A Do Not Contact list has worked beautifully to reduce unwanted telemarketing calls. In fact, the FCC Commissioner refers to DNC as “one of the most significant things that the FCC has ever done for American families.” I’m confident that a similar registry would be just as effective for ad mail–and if not for certain technological and geopolitical issues that make enforcement impossible, for spam as well.
August 15th, 2008 at 7:44 am
Response on Household Diary Study
We are talking about the potential to reduce between 82 and 92 billion pieces of advertising mail through any mail preference service, whether mandated by government or done through a voluntary program.
Where we agree:
• There are 100.3 billion pieces of “advertising mail” received by households in 2007, of which 69.9 billion are commercial “advertising,” 13.5 billion are non-profit advertising, and 16.9 billion are first-class advertising. Of the 16.9 billion of first-class advertising, 7.9 billion consists of inserts, probably in transaction statements. There are also approximately 12 billion pieces of unaddressed mail.
• Of that total, the 7.9 billion of inserts and 13.5 billion of non-profit mail would not be affected by any proposed “Do Not Mail” legislation, and about 1.8 billion of the remaining advertising mail, which comes from the government would also not be affected by the legislation.
.
Where we disagree:
• You believe that households receive 100.3 billion pieces of addressed mail that is generally understood to be advertising mail. I believe that, of that total, 7.9 billion consists of inserts in first-class mail and another approximately 10 billion (or 9.9%) of the standard mail total consists of newsletters. You believe that the newsletters are incremental to the 100.3 billion.
• I have checked with the U.S. Postal Service official responsible for the Study, and he confirms that the newsletter volumes are included in the 83.4 billion of standard mail households received in 2007, not additional to them.
• Although you claim to have “refuted” my observation, looking at the tables in this Study in combination makes it clear that the newsletters have to be included in standard mail, not additional to it. Table E-1 breaks out the total of 150.9 billion the households received. Clearly, the standard mail newsletters are not included in the 58.9 billion pieces of first-class mail, the 6.6 billion periodicals, the 1.7 billion packages, or the.3 billion of expedited mail. The two remaining categories, standard regular mail and standard non-profit mail, total 83.4 billion and newsletters are included in them.
• Table A3-1, which breaks out the content of standard mail households received, states that 87.4% of standard mail is “advertising” and the remainder consists of “fund requests” (about 1%), “newsletters” (9.9%) and “don’t know” (1.7%). While Table A3-1 separates advertising standard mail from newsletters, the earlier table, which indicates that 83.4 billion of regular and non-profit standard mail were received by households does not separately break out newsletters.
Response to the Rest of Your Arguments:
• I have no doubt that 80-90% of those polled have sufficient frustration with some of the mail they receive that, if polled in a particular way, they would support some form of a “Do Not Call” registry. In fact, it is not clear from these surveys that those favoring some form of legislation are even aware of the DMA Mail Preference Service, much less that the survey is making a value judgment about it. Saying that Americans support some form of legislation is a far cry from saying that the many flawed pieces of legislation out there are consistent with the wishes of a majority of Americans. (By the way, your earlier comment about “accommodation bias” is far more applicable in this context than it was relative to the Household Diary Study. Accommodation bias occurs in oral surveys conducted by telephone or face-to-face methods, when the person being surveyed feels there is a particular answer desired. The Postal Service study is not an interactive oral survey. It is a data-gathering analysis that is done off-line by the household, so, while there may be inaccuracies because of data entry errors or delays in recalling and entering data, the desire to please the questioner is not relevant.)
• Virtually all mail is recyclable, and has the potential to be profitable to taxpayers if they are set up to transfer recyclable material to organizations that can get them to places demanding recyclable material. The notion that mail disposal inherently creates cost to taxpayers is flawed.
• Your comments about the intrusiveness of mail and the inability to stop it are simply inaccurate. While the DMA Mail Preference Service is not universal, if used, it stops the vast majority of unwanted mail.
• The idea of a limited “first-come, first-serve” registry is not what is being proposed by legislation, although using the DMA Mail Preference Service would essentially achieve the same effect.
• Ad mail constitutes far less than 1/3 of postal costs. It is lower-priced than first-class because the postal infrastructure exists to get first-class mail and periodicals from origin to destination within certain specified time periods, whereas standard mail is processed when spare capacity is available, so it is essentially priced at variable cost, plus a contribution to overhead. Standard mail makes a far higher contribution to postal overheads than do magazines and periodicals, and, indeed, far more of the work in moving standard mail is done by third-party mail consolidators than is the case with first-class mail or periodicals. Therefore, a significant drop in ad mail would add cost to first-class mail, and to periodicals and to non-profit mailers.
• As a practical matter, while the U.S. Postal Service is able to reduce its cost structure by allowing workers to retire without being replaced, closing unprofitable and underutilized postal facilities is extremely difficult. Lack of profitability of a retail outlet, by law, is not a sufficient reason to close it down. The Postal Service also has severe constraints on its ability to downsize its workforce under its various collective bargaining agreements. While the Postal Service has done a heroic job improving its productivity over the last seven years, it could not take costs down over time to keep postal rates relatively stable if there were a significant drop in advertising mail in a relatively short period of time.
• A 20% increase in postal rates, which would be an 8.5 cent increase, far less than the DMA projection, would have a devastating effect on many small businesses, on the periodicals business, and on the non-profits whose ad mail would not be affected by legislation. Many jobs would be lost because many small businesses which depend on the mail would see their costs of doing business skyrocket.
• Ultimately, we will probably agree to disagree on the merits of an industry-driven mail preference service that helps businesses understand better what customers want, and a government-mandated service that is highly likely to be inflexible and damaging to the economy.
If you wish to have a real-time discussion offline, send us your contact information.
August 15th, 2008 at 1:29 pm
Thanks for your patient reply. I know a few of these topics, such as ad mail volume, can be a bit tedious. Before I respond to your most recent points, I’d like for you to explain something to me.
How is it that Do Not Mail (DNM), in your opinion, threatens to damage the economy and cause postal rates to skyrocket, while the DMA’s Mail Preference Service (MPS) does not? What makes DNM dangerous and MPS harmless? Let me say it another way. Why doesn’t MPS threaten to harm the economy or Postal Service? What makes it benign?
It seems to me that philosophically and methodologically, DNM and MPS are practically identical. In fact, they’re so similar that the ad mail industry calls DNM “redundant.” They’re both opt-out registries, they both claim to eliminate the majority of a registrant’s ad mail, and until the MPS’s recent makeover, one wasn’t any more “granular” than the other.
So what’s the vital difference that makes DNM so dangerous to the economy and Postal Service? Is the key difference the amount of publicity that DNM would receive? I don’t think that’s it, because at least one survey says that the vast majority of Americans know about MPS, as well. Or could it be that MPS isn’t nearly as effective as you say it is? Or is it something else entirely?
I’d love to know your thoughts on this.
August 18th, 2008 at 8:44 am
Thank you for your comment and question. I want to compliment you for driving me to think much more deeply and analytically about the issues than I otherwise might have. At a minimum, you caused me to look much more closely at the Household Diary Study and see its richness of data.
Proponents of the Do Not Mal legislation have a clear agenda to reduce or eliminate unsolicited mail. Their reasons have been based on environmental, privacy, or anti-consumerism advocacy, or simply the desire to enable people who do not want to receive mail to be left alone. The DMA Mail Preference Service has a specific purpose of matching mail recipients with the mail they want to receive and to enable them to stop receiving mail they do not want to receive. While the DMA and the remainder of the industry have a desire to address the issues driving legislation proponents, their primary priority is to honor mail recipient choice.
For example, if the result of the Mail Preference Service were to cause recipients to get mail they are not getting today, the DMA would be happy. Do Not Mail legislative advocates want to see the total volume of marketing mail reduced.
As you suggest, in the short term, the practical effect of the legislation and the DMA Mail Preference Service would be similar: mail volumes would be reduced. However, over the long run, the Mail Preference Service is designed to grow the value of mail by establishing a richer base of knowledge about consumer preferences. If the Mail Preference Service achieved its long-term goal, the brand of mail would be enhanced, and more organizations would use it in a way that pleased recipients. The proponents of the legislation want to change marketing habits to eliminate or reduce the total volume of mail, regardless of long-term recipient preference.
More important, the DMA’s goal is to drive marketers and consumers together to have a richer dialogue about consumer preferences. Many Do Not Mail proponents want to interpose themselves between marketers and consumers, and to dictate consumer habits.
Not everyone in our industry agrees with me, but I believe that, over time, our industry will be best served by understanding what makes mail unwanted, and eliminating those mailings and attributes that devalue the brand of mail.
The DMA and the industry would welcome the opportunity to work collaboratively with proponents of the legislation to make the Mail Preference Service more effective, but that collaboration has not been forthcoming.
You have been a thoughtful advocate for your position, and I renew my offer to have an offline dialogue on this issue with you.
August 18th, 2008 at 5:53 pm
Thanks for the kind words. I, too, feel like I’ve benefited in a variety of ways from our discussion. The ad mail industry is fortunate to have you representing its cause. I’ve written a response to your earlier post, but before I share it, I’d like to briefly continue our current line of thought.
From what you say, the core difference between DNM and MPS is the intentions, agendas, and goals of the people who support them. But if the two services essentially do the same thing in the same way with the same results, then what difference does an agenda make? I don’t get it.
You say “the Mail Preference Service is designed to grow the value of mail by establishing a richer base of knowledge about consumer preferences.” But what specific design features enable MPS to accomplish this better than DNM can? (Excluding the features introduced this year.)
What specific, tangible functionality did MPS offer in its first 35 years that can’t be duplicated by Do Not Mail? I mean, we’re not talking about some highly complex system here. We’re talking about a simple collection of names and addresses. How different can two lists be?
You say that the industry would “welcome the opportunity to work collaboratively with proponents of the legislation to make the Mail Preference Service more effective.” I’m all for collaboration. How would you feel about collaborating together on a federal Do Not Mail registry?
A federal registry offers things that MPS can’t, like universal reach and enforceability. Conversely, the MPS has never, (at least not in its first 35 years), offered any features that can’t be easily duplicated by a federal registry.
If we’re going to collaborate on a service, wouldn’t it make sense to collaborate on the one with advantages that can’t be duplicated by the other?
the DMA’s goal is to drive marketers and consumers together to have a richer dialogue about consumer preferences. Many Do Not Mail proponents want to interpose themselves between marketers and consumers, and to dictate consumer habits.
Please explain how an opt-out list managed by the DMA constitutes a “rich dialogue,” but the same type of list managed by someone else constitutes “dictating consumer habits.” How can a simple list dictate anything at all? Especially when signing up is voluntary?
It seems to me that by denying consumers an additional registry, the ad mail industry is the only one interposing itself between marketers and consumers, and dictating consumer habits. To accuse Do Not Mail advocates of it is what psychologists call “projection.”
Finally, I’d like to repeat my question:
How can Do Not Mail pose a grave threat to the economy or Postal Service when it uses the same basic opt-out model as the DMA’s service, which has operated harmlessly for 36 years? I don’t see how you can reconcile this glaring contradiction in your position.
I renew my offer to have an offline dialogue on this issue with you.
That’s very kind of you. I appreciate the offer, and may take you up on it sometime.
August 21st, 2008 at 8:06 am
Thank you for your comments and questions.
As we explore the differences between a registry mandated by statute or regulation, compared with the DMA Mail Preference Service, there is some difficulty making a comparison because the exact details of legislation or regulation are not knowable. I will base my comments on what is in existing “Do Not Mail” proposals.
The big questions relative to any system for recording or acting upon consumer preferences relative to marketing communications are the following:
• Does a system give the consumer-registrant the preference options he or she wants?
• Is the system user-friendly for both the registrant and the marketer which is expected to comply with the registrant’s preferences?
• Does the system have adequate protection against fraud or error?
We have spent a lot of time having a dialogue about the first question. I do not believe you disagree with the proposition that consumers may have a wide range of preferences relative to unsolicited mail, including, for some, the desire to receive mail from a marketer, but to receive it less frequently or only at certain times during the year. For a marketer that reaches the consumer through multiple catalogs, consumers may prefer to receive some catalogs, but not others. Any preference service, whether mandated or voluntary, should have the ability to give the mail recipient an option he or she prefers.
User-friendliness is something that I believe a private registry is more likely to achieve and maintain than a government-mandated registry, although, on the surface, there is nothing inherent in a government registry that makes this the case. My experience with laws and regulations that mandate a particular kind of service is that, even if they perfectly reflect public preference when enacted, they do not tend to adapt to evolving public preference because getting a statute or regulation changed is too complicated and time-consuming.
There is also an issue of user-friendliness for the marketer. The way the registry communicates to the marketers what registrants want to stop receiving unsolicited marketing communication can be user-friendly or can impose significant cost on a marketer. Ideally, the registry should have the registrant’s name and address in a form and format identical to the way the name and address are stored in a marketer data base.
This sounds simpler than it is. Name and address matches are not always as straightforward as they seem. For example, if my son Michael wants to stop receiving mail at our home and signs up for the registry, how does the marketer determine whether the registrant is me or my son? What about men or women who move, but whose old address is still on the marketer’s data base? What about women or men whose name is recorded differently in the registry database versus the marketer’s data base? What about women at the same address who have changed their name because of a marriage, a divorce, or some other change in status? There is a cost associated with resolving each of these kinds of identity problems, and, if the cost is excessive, the user-friendliness of the registry is limited.
The third issue, protection against fraud or error, is much larger than it appears. Some estimates of error on the “Do Not Call” registry range as high as 40%. Beyond error, operators of a registry have to make sure that the registry is not misused by people. For example, there is evidence that, given the fact that the “Do Not Call” registry allows marketers to continue calling existing customers, some marketers simply registered their most profitable customers on the list to make sure that no competitor could ever call them. The customers, who may have wanted to be apprised of competitive choices, were deprived of that opportunity because the operators of the “Do Not Call” registry did not adequately verify that their preferences were being presented on the registry.
One of the reasons the DMA has not been able to come to agreement with some of the “Do Not Mail” registry advocates is that the DMA refuses to accept a bulk list from an intermediary without adequate validation that the mail recipients whose names and addresses are on the registry actually have expressed a preference not to receive mail. Historically, the DMA has taken the position that the mail recipient should register directly, not through an intermediary.
However, given the fact that many of these advocacy organizations have a stronger interest in accumulating names and fees for collecting those names, their willingness to take the steps necessary for validation has been insufficient to date.
Clearly, requesting a social security number or some other identifying number like a credit card number is out of the question for privacy reasons. The validation which would be most appropriate would be a confirmation sent to the registrant through the mail, but, for many advocacy groups, that requirement is a cost they are unwilling to incur.
You appear to recognize that the issues are complex, but appear to accept errors or validation issues as a price for addressing what you believe to be a serious societal issue. I go back to two points I have made previously in our ongoing dialogue. Ultimately, I do not believe that we are dealing with a serious issue, given the availability of not only the DMA registry, but others like Catalogchoice.org for consumers to express their preferences.
The risk of addressing this problem through a mandated registry that does not reflect true consumer preference is the potential for a significantly negative economic impact and an uncertain environmental benefit. I have come to the conclusion that the availability of one or more privately-managed registries meeting proper validation requirements and continuously adapting to evolving needs of those who receive unsolicited marketing communication is the best solution to the problem of people wanting better control over what comes to them.
August 22nd, 2008 at 10:33 am
You listed three characteristics of a good mail preference service, and I’m happy to report that we agree on all three points. The crux of our difference is not what features are desirable, but what type of service is most effective at providing them.
1) Giving consumers the preferences they want.
What I think you’re talking about here is “granularity” and diversity of options, and I think we both agree that this as a desirable feature. I believe a government registry can offer consumers a fair degree of flexibility.
You have suggest that a registry lacking in granularity might have a significant negative impact on the economy. But as I’ve said before, there was nothing granular about MPS during its first 35 years. Seeing as how it proved harmless, it would appear that your argument is without merit.
2) Providing a user-friendly interface.
It’s ironic that you mention this, because I’ve heard a number of complaints about the MPS’s clumsy design and poor usability. One blogger wrote that the DMA registry can be “intimidating to use, and is fraught with annoying obstacles.” I’ve heard no such complaints about the government’s Do Not Call website.
I believe any registry, whether federal or private, is fully capable of providing a user-friendly interface if they’re motivated to do so. Cynics have suggested that the DMA has intentionally made its website clunky in order to discourage widespread use. A government service would do away with this potential conflict of interest.
3) Adequately protecting against fraud and error.
If anyone is equipped to protect against fraud and error, it’s the government. You talk about the Do Not Call registry being abused, but the DMA’s registry has been abused in similar ways. Rogue marketers have even been known to use the DMA’s registry as a mailing list, reasoning that the registrant’s mailboxes would be relatively uncluttered and therefore an easy mark. (Source: “Data Mills Delve Deep”, New York Times)
Any error- or fraud-prevention methods used by the DMA can just as easily be adopted by the government. Plus, a federal registry provides transparency and accountability. In contrast, folks have no recourse when the DMA registry is abused or ignored. How does one even know if a business is a DMA member or not when the directory isn’t publicly accessible? (Probably doesn’t matter anyway, because from what I hear, the DMA’s complaint process is pretty pointless.)
You appear to recognize that the issues are complex, but appear to accept errors or validation issues
I accept no such thing. I see no reason to believe that a government registry is inherently more prone to fraud and abuse than a private service. Quite the contrary.
Clearly, requesting a social security number or some other identifying number like a credit card number is out of the question for privacy reasons.
It’s not out of the question at all. In fact, the DMA has demanded a credit card number for years (although recently relaxed its requirement for mail-in registrations). The credit industry’s opt-out service asks for a social security number.
In any case, I’m sure the public would rather share sensitive data like credit card or social security numbers with a federal service than with the “junk mail” industry.
The validation which would be most appropriate would be a confirmation sent to the registrant through the mail….
As far as I know, the DMA doesn’t confirm registrations through the mail either.
One of the reasons the DMA has not been able to come to agreement with some of the “Do Not Mail” registry advocates is that the DMA refuses to accept a bulk list from an intermediary….
You mistakenly equate third-party services like Catalog Choice with Do Not Mail advocacy. Most third-party services, including Catalog Choice, oppose Do Not Mail. (It represents competition.)
given the fact that many of these advocacy organizations have a stronger interest in accumulating names and fees for collecting those names, their willingness to take the steps necessary for validation has been insufficient to date.
Again, these third-party services are not “advocacy organizations,” they’re businesses. A federal registry would not require a third party to act as intermediary, collect names and fees, etc.I think most Do Not Mail advocates would agree that validation is an important consideration.
Now, to belatedly address a few of your points from August 15:
we will probably agree to disagree on the merits of an industry-driven mail preference service that helps businesses understand better what customers want, and a government-mandated service that is highly likely to be inflexible and damaging to the economy….
1) Fortunately, we don’t need to agree. We can simply let the public decide on the relative merits of the two services. If Do Not Mail is “inflexible,” and the DMA’s service truly knows “what people want,” then the marketplace will reflect that as people register for one service over the other.
By opposing Do Not Mail, you’re denying consumers the ability to weigh the relative merits of the two services for themselves. You’re also demonstrating a profound lack of confidence in the DMA’s ability to “give people what they want.”
2) You describe Do Not Mail as a “government-mandated” service, which is a little misleading. The only thing that a federal registry would mandate is compliance with the public’s wishes. Nobody is forced to sign up; registration is purely voluntary. It would be more accurate to say that Do Not Mail is people-mandated, government-enforced.
Insofar as marketer compliance is mandated, I would suggest that both services are “mandatory.” After all, the DMA “mandates” that its members comply with opt-out requests. The difference is that a government mandate would have teeth and apply to all marketers, whereas the DMA’s mandate is unenforceable and only applies to its members.
By opposing Do Not Mail and thwarting consumer choice, the ad mail industry is the only one “mandating” a particular service in any real sense of the word.
3) Let me give you one reason why Do Not Mail’s impact on the economy will likely be negligible. As you yourself said at the top of the page, when one marketing channel closes, “the advertising money that was spent on mail [will] be spent alternatively.” Even you recognize, at least in part, that the economic benefits of ad mail won’t be lost, but will simply shift to other mediums.
Virtually all mail is recyclable, and has the potential to be profitable to taxpayers…
You’re confusing revenue with profit. Municipalities can often, (but not always), earn revenue by selling the recyclables they collect. However, very rarely is this a “profitable” enterprise once you factor in the significant costs associated with running a curbside recycling program. Selling recyclables may offset some of the collection expenses, but that’s about it. In fact, curbside recycling often costs taxpayers MORE than regular garbage pickup, as illustrated in the NY Times article I mentioned previously.
Also, only about 60% of Americans have access to curbside recycling. Unfortunately, creating cost-effective recycling programs is a complicated and expensive process. For many communities, it’s a luxury they can’t afford. So it’s a bit misguided for you to shift responsibility away from the industry that sends ad mail, and blame the the poor communities who have to pay to have it hauled away.
As for what percentage of ad mail is recyclable, if you have a source to support your claim that “virtually all” ad mail is recyclable, I’d like to see it.
Ad mail constitutes far less than 1/3 of postal costs.
If you review the USPS financial data, you’ll notice that revenue for standard mail represents about 28.2% of USPS’ total revenue, and that standard mail’s attributable costs represent a proportional 28.8% of USPS’ total costs.
Looks like I’m in the right ballpark.
The idea of a limited “first-come, first-serve” registry is not what is being proposed by legislation
I know. But I’m proposing it here and now. Do Not Mail advocates are a very accomodating group, and if it’s true that the Postal Service can’t handle a sudden drop in ad mail volume, then I’m sure they’d settle for a gradual reduction instead.
A 20% increase in postal rates, which would be an 8.5 cent increase, far less than the DMA projection
A 20% increase is less than the DMA’s projection, but it’s still a grotesquely bloated estimate. You’re basically saying that:
a) 80% of ad mail will be stopped for 90% of the population
b) a reduction in ad mail will result in ZERO cost savings for the postal service
c) the postal service has ZERO alternatives to raising rates
All of these are highly flawed assumptions. I would argue that with a little creativity and some leeway from Congress, the Postal Service can avoid raising postal rates much, if at all.
Also, it’s fascinating that your calculations assume 90% of the population would sign up for Do Not Mail. How lousy is the DMA’s registry if you think such a large portion of the population would shun it in favor of a federal registry? Very telling.
…many small businesses which depend on the mail would see their costs of doing business skyrocket…
Again, I don’t buy the argument that Do Not Mail will inevitably lead to higher postal rates. But even if it did, I want to point out that only a tiny fraction of America’s small businesses use the mail to support their business. We’re talking about 1 or 2%. Even fewer small businesses use direct mail as a primary advertising medium–as few as 3 out of 1000.
I do not believe that we are dealing with a serious issue…
I mean no disrespect when I say this, but I wouldn’t expect you to understand the seriousness of the junk mail problem. As Upton Sinclair once said, “It is difficult to get a man to understand something when his salary depends upon his not understanding it.”
August 25th, 2008 at 8:20 am
One clarification:
I meant to say that standard mail’s attributable costs represent 28.8% of USPS’ total attributable costs.
August 25th, 2008 at 8:24 am
Thank you for your comments:
• I would agree that the current DMA Mail Preference Service web site can be improved as to user-friendliness, and I expect that it will be improsed.
• The credit card information requested was for verification purposes only, and, as you correctly point out, the best verification is a mailing address, rather than an e-mail address. As you correctly note, the DMA has eliminated the credit card verificaiton requirement.
• I would not disagree with your observation that, for most of its history, the DMA Mail Preference Service was not given as high a priority as would be needed today. I believe that the DMA has responded to consumer demand by significantly stepping up its efforts in the last two years. I also expect that it will continue its improvement efforts.
Ultimately, we have differing degrees of confidence in the ability of the government to do a better job managing this process than the private sector.
I think that continuing consumer demand for improvement is the best way to drive the DMA and its competitors to do the best job.
August 25th, 2008 at 9:22 am
Thank you for having this discussion with me. You’ve been a gracious host.
March 30th, 2009 at 12:21 pm
Small businesses continue to be the driver of the economy. As the owner of a small business, I need to use direct mail to build my business. With creative copy and coupons in a mailer that uses 25% less paper, these direct mail pieces drive prospects to my website; I can then shift to more email promotions for those who want correspondence by email. Cleaning up address lists saves me money, so I make a concerted effort to target my efforts carefully. Direct mail is not only the most effective means of generating new business for my company, I also respond favorably to any piece that catches my eye. Blogs and tweets are great once the business has scale, but only n concert with another kind of campaign. Otherwise, they get lost in the noise.
Rezzie Danni’s proposals would be very detrimental to the growth of many small businesses.