PostalWatch, Inc.
Suite 100
3831 Virginia Beach Blvd.
Virginia Beach, VA 23452
(877) 576-7825
http://www.postalwatch.org

August 20, 1999

Mr. Jim Tozzi
The Center for Regulatory Effectiveness
Suite 700
11 Dupont Circle, N.W.
Washington, DC 20036

Dear Mr. Tozzi:

I am contacting you on a matter that appears to be directly in the purview of the Center for Regulatory Effectiveness.

On March 25, 1999, the United States Postal Service published new regulations in the Federal Register which require Commercial Mail Receiving Agencies to both register themselves and their customers utilizing the Postal Service's revised Form 1583. This form requires that CMRAs and their customers divulge their home addresses, submit two forms of identification, and allow that information to be made public in exchange for the "privilege" of receiving mail. In addition, all individuals and businesses that utilize CMRA boxes must designate their addresses with PMB (or "Private Mail Box") to distinguish them from suites, apartments, and P.O. Boxes. This requires that the individuals and businesses get new letterhead, envelopes, and business cards, as well as requiring them to notify each and every business contact of their "new address". The Postal Service claims this is being done to reduce fraud. They have since revised their regulations and delayed implementation of the measures because of an uproar from the general citizenry as well as the submittal of House Joint Resolution 55, a Ron Paul-sponsored bill with currently 50 co-sponsors in the House of Representative.

The Postal Service has yet to publish any statistical data that would lend credence to their claim that fraud is rampant at CMRAs. However, a recent PostalWatch study published by the Cato Institute (available at http://www.cato.org/pubs/briefs/bp-048es.html) estimates the cost to individuals and small businesses at $1 billion plus.

In addition to the costs and the Postal Service's refusal to report any facts backing up their claim, they have claimed (via title 39 Section 410) that they are exempt from any of the provisions of the Paperwork Reduction Act, the Congressional Review Act, the Unfunded Mandate Act, and other statutory law which we believe clearly requires them to follow.

If you would be so kind, could you do the following and let us know of your decisions?

• Place this on your CRE WatchList or Emerging Regulatory Issues list.
• Give a clear reading of whether the Postal Service is exempt from any or all of the Acts stated above (Note: One of the co-authors of the Congressional Review Act, a Fellow at the Heritage Institute, claims it was always legislative intent that the Postal Service be covered under the Congressional Review Act).
• If your group is so inclined, assist PostalWatch in legal action to effect the recall of these dreaded new regulations.

If you have further questions or comments, please contact Rick Merritt or myself at 800-901-3332. Thank you for your time in dealing with this matter.

Sincerely,

Barry L. Moore
Director, PostalWatch, Inc.