• 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.

I meant to say that standard mail’s attributable costs represent 28.8% of USPS’ total attributable costs.

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.”

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.

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.

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.

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.

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.

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.