Documenti di Didattica
Documenti di Professioni
Documenti di Cultura
August 1982
Foreword
This study of the implications of electronic mail and message systems (EMS)
for the U.S. Postal Service (USPS) is one of four components of the OTA assess-
ment of Societal Impacts of National Information Systems. It should be read along
with the September 1981 OTA report on Computer-Based National Information
Systems: Technology and Public Policy Issues, which provides the larger context
for understanding EMS-related public policy questions. Also relevant is the March
1982 OTA background paper on Selected Electronic Funds Transfer Issues: Pri-
vacy, Security, and Equity.
The House Committee on Post Office and Civil Service, one of the original
requesting committees, indicated an interest in the possible impact of EMS and
electronic funds transfer (EFT) on the USPS mailstream and labor force, and im-
plications for the future role of USPS in electronic mail and message systems.
The Senate Committee on Governmental Affairs, Subcommittee on Civil Service,
Post Office, and General Services, expressed a similar interest. In response, OTA
initiated a review of relevant EMS and EFT developments since the completion
of the work of the Commission on Postal Service in 1977. Several working papers
and computer-based models were developed by OTA staff and contractors. These
were reviewed by an OTA advisory panel representing postal, labor, telecom-
munication carrier, computer service, business, academic, and consumer interests.
On the basis of that review, a revised and integrated report was prepared.
OTA appreciates the participation of the advisory panelists, external reviewers,
and others who helped bring this study to fruition. It is, however, solely the respon-
sibility of OTA, not of those who so ably advised and assisted in its preparation.
Director
...
Ill
OTA Electronic Message Systems Advisory Panel
iv
OTA Electronic Message Systems Project Staff
Contractors
*March 1981 through February 1982; Stephen E. Doyle served as Program Manager through February 1981; Fred W. Weingarten was appointed
Program Manager effective March 1982.
**since June 1979; Rumn E. Pengov served as Project Director through May 1979.
v
Acknowledgments
The following individuals also contributed as reviewers or provided assistance during the course of
this study.
William F. Bolger, The Postmaster General, and John F. McLaughlin, Harvard University
staff members of the U.S. Postal Service Arnim H. Meyburg, Cornell University
Ronald G. Carr, U.S. Department of Justice Roger K. Salaman, National Telecommunications
Kathleen Casey, GTE-Telenet Communications and Information Administration
Corp. Stephen L. Sharfman, Postal Rate Commission
Henry B. Freedman, Policy Studies Corp. Jack D. Smith, Federal Communications
Dean Gillette, Bell Telephone Labs, Inc. Commission
Henry H. Hitchcock, J. F. Coates, Inc. Scott K. Socol, Satellite Business Systems
Herbert N. Jasper, Ad Hoc Committee for Frederic Withington, Arthur D. Little, Inc.
Competitive Telecommunications
vi
Contents
Chapter Page
Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ix
1. Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
2. Background and Purpose of Study. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
3. Market Penetration Model and Technology Assumptions . . . . . . . . . . . . 23
4. Market Penetration Results . . . . .,’ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
5. Revenue/Cost Model and Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51
6. Implications for Postal Rates, Service Levels, and
Labor Requirements.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61
7. Implications for the Telecommunication and Computer Industries,
EMS Privacy and Security, and USPS Long-Term Viability . . . . . . . . . 73
8. Congressional Policy Considerations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87
Appendix Page
A. Supplemental Detail on the Market Penetration Model . . . . . . . . . . . . . 101
B. Logistic Substitution Process. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 105
C. Equation Used to Calculate Labor Requirements . . . . . . . . . . . . . . . . . . 107
D. E-COM Interconnection Arrangements . . . . . . . . . . . . . . . . . . . . . . . . . . . 108
Index . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 111
vii
Overview
Advances in communication and computer technology provide new ways to
convey messages and carry out financial transactions. These are called electronic
mail and message systems (EMS) and electronic funds transfer (EFT) systems.
Commercially offered EMS and EFT will increasingly compete with portions of
the traditional market of the U.S. Postal Service (USPS). While there is disagree-
ment on how fast EMS and EFT may develop, it seems clear that two-thirds or
more of the current mainstream could be handled electronically, and that the volume
of USPS-delivered mail is likely to peak in the next 10 years. Any decline in the
volume of mail has significant implications for future postal rates, USPS service
levels, and labor requirements.
A key policy issue requiring congressional attention is how USPS will par-
ticipate in the provision of EMS services, both in the near term and in the longer
term. If USPS does not attract and keep a sizable share of the so-called Genera-
tion II EMS market (electronic input and transmission with hardcopy output)
and conventional (especially first-class) mail volume declines, USPS revenues will
probably go down, with the likelihood of an unfavorable impact on rates and/or
service levels. If USPS does develop a major role in the Generation II EMS market,
and if Generation II EMS costs are low enough, the effect on USPS rates and/or
service could be favorable.
Two of the major factors influencing USPS labor demand are total mail volume
and worker productivity. Regardless of whether USPS participates in Genera-
tion II EMS, improving worker productivity and eventually declining conventional
mail volumes could lead to considerably lower labor demands in the future. If USPS
does participate successfully in Generation II EMS, this potential decline in labor
requirements could be deferred or partially offset.
USPS is already involved in EMS to a limited extent. For example, it delivers
some industry EMS hardcopy, provides a portion of Western Union’s Mailgram
service, and in January 1982 introduced a domestic service called “electronic com-
puter-originated mail” or E-COM. (In E-COM, USPS accepts letters in electronic
form, converts them to hardcopy, including printing and enveloping, and delivers
them.) The role of USPS in EMS activities is already controversial, and it is like-
ly to become more so if its role expands.
As a result of technological advances, historical (and legal and regulatory)
distinctions between conventional and electronic mail have blurred, along with
the application of the the congressional mandates embodied in the Postal and Com-
munications acts. Absent congressional action to provide a clear direction for USPS
and to clarify or redefine regulatory boundaries, the controversy over the USPS
role in EMS is likely to continue indefinitely and Generation II EMS opportunities
for USPS, private telecommunication carriers, and mailers may be lost.
OTA identified a number of areas related to USPS participation in EMS that
warrant congressional consideration:
● Potential Contribution to USPS Mail Volume.—A USPS role in Genera-
tion II EMS has the potential to provide a volume “cushion” to partially
offset reductions in conventional mail. Since private firms are neither will-
ing nor able to duplicate the nationwide physical delivery infrastructure
of USPS, any large-scale Generation II EMS service depends on the par-
ticipation of USPS. There is, however, little consensus on what USPS role
ix
would be most conducive to growth of Generation II traffic (and hence USPS
mail volume).
● Potential Contribution to USPS Finances.— While Mailgram apparently
estimates of the Generation II market have probably been high, and that
prudent planning should be based on a mature market (20 years hence) in
the range of 7 billion to 17 billion messages annually, rather than 25 billion
as previously estimated by RCA (for comparison, conventional mail in 1981
totaled 110 billion pieces). Even the lower estimate depends on mailer ac-
ceptance and successful institutional marketing strategies. Several modifica-
tions to E-COM have been proposed that deserve consideration, such as
1-day guaranteed delivery rather than 2-day, flexible letter formats, and
the use of telecommunication carrier and mailer logos to personalize the
E-COM output and provide incentives for aggressive marketing. A full
review of the E-COM market should include governmental as well as private
sector mailing needs.
. Impact on Competition.—USPS believes its participation in E-COM is au-
thorized by the Postal Reorganization Act mandate to use new facilities
and equipment to improve the convenience, efficiency, and cost effectiveness
of mail service. However, various telecommunication and computer firms
view E-COM as: 1) the entry of a Federal agency into competition with pri-
vate industry; 2) possibly subject to the Communications Act as well as
the Postal Act; and 3) raising questions about the fairness and legality of
a USPS role in EMS in general. The applicability of the Private Express
Statutes to delivery of Generation II EMS hardcopy output has also been
challenged.
● Regulatory Jurisdiction. —The E-COM case has surfaced disagreements over
the division and extent of regulatory jurisdiction by the Postal Rate Com-
mission and Federal Communications Commission. As a result, USPS
brought suit against both commissions and the Department of Justice
brought suit against USPS–all on jurisdictional grounds, not on the merits
or faults of E-COM. Some private firms believe this demonstrates the dif-
X
ficulty of regulating USPS ratesetting and preventing the potential cross-
subsidization of E-COM from conventional mail revenues. One proposed
response to that concern would be to require a separate USPS entity for
any EMS offering.
● E-COM Privacy and Security. –The involvement of USPS in E-COM has
pointed out the need for additional security measures to protect the privacy
of EMS messages. The Postal and/or Communications Act may need to
be amended to provide additional statutory privacy protection.
● Role in Telecommunication and/or Generation III EMS.—The USPS role
xi
Chapter 1
Summary
Contents
—
Page
Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
USPS Mainstream . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
USPS Rates and Service Levels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Labor Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Policy Implications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
Provide a Clear Direction for USPS Involvement it ems. . . . . . . . . . . 9
Reduce or Eliminate Further Regulatory and Judicial Delay . . . . . . . . . 10
Strengthen Privacy and security protection . . . . . . . . . . . . . . . . . . . . . . . 10
Maintain Oversight and Initiate Planning on USPS Long-Term
Viability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Chapter 1
Summary
Introduction
This study addresses three major questions: in general, and in E-COM in particular, con-
tinues to be in dispute before various regula-
1. To what extent are privately offered elec-
tory agencies, the courts, and Congress. USPS
tronic mail and message systems (EMS)
believes its participation in EMS is authorized
and electronic funds transfer (EFT) sys-
by the Postal Reorganization Act mandate to
tems likely to affect the volume of mail
handled by the U.S. Postal Service use new facilities and equipment to improve
the convenience, efficiency, and cost effective-
(USPS)?
ness of mail service. Various mailer organiza-
2. Are changes in USPS mail volume likely
tions, consumer groups, and postal labor
to lead to significant adjustments in
unions see a USPS role in EMS as essential
USPS rates, service levels, and/or labor
to USPS long-term viability and to maintain-
force requirements? and
ing, or at least minimizing any reductions in,
3. What are the implications of EMS for the
mail services that are vital to a large part of
future of USPS and how it might partici-
pate in the provision of EMS services? the U.S. population. They point to the critical
role of USPS in providing a universal, low-
These questions are of concern because his- cost, nondiscriminatory nationwide commu-
torically USPS has served a variety of social nication service. Various private telecommu-
purposes mandated by Congress, such as “to nication and computer firms view USPS in-
bind the Nation together through the personal, volvement in EMS as the entry of a Federal
educational, literary, and business corres- agency into competition with private industry
pondence of the people” and to provide mail (possibly subject to the Communications Act
service “to (postal) patrons in all areas . . . and as well as the Postal Act), raising difficult
all communities, ” including rural areas, com- questions of ratesetting and potential cross-
munities, and small towns (Postal Reorganiza- subsidy.
tion Act of 1970). In recent years, there has
There are no easy answers to the questions
been a continuing revolution in computer and
addressed in this study. Prior studies have
communication technology, a gradual dereg-
proven to be oversimplified. In order to bet-
ulation of the telecommunication industry (the
ter understand the complexities involved,
computer industry being essentially unregu-
OTA used computer-based models to project
lated), and a proliferation of new and old firms
independently the levels of conventional and
offering or planning to offer EMS and EFT
electronic mail volumes under different sets
services that compete with portions of the tra-
of assumptions, and to project the possible ef-
ditional USPS market. Technology is, in ef-
fects of changes in USPS mail volumes on
fect, blurring the historical (and legal and
regulatory) distinctions between conventional USPS rates, service levels, and labor re-
quirements. Still, while computer modeling
and electronic mail.
permits consideration of a larger number of
USPS is already involved in EMS to a lim- variables and interrelationships than would
ited extent. It currently delivers some in- otherwise be possible, the precision of the pro-
dustry EMS hardcopy output, provides a por- jections can be misleading. The models are
tion of Western Union’s Mailgram service, and highly sensitive to initial assumptions and
in January 1982 introduced a domestic service have limited ability to anticipate unexpected
called “electronic computer-originated mail” events. The study as a whole, and the use of
or E-COM. However, the role of USPS in EMS computer modeling in particular, is intended
3
- -——
4 ● Implications of Electronic Mail and Message Systems for the U.S. Postal Service
to help Congress better understand the possi- intended to make a prediction of the future
ble implications of EMS for USPS, and is not course of events.
USPS Mainstream
To a substantial extent, the volume of stream. Because of the need to sort and deliver
USPS-delivered mail in the future is beyond the hardcopy output from Generation II EMS,
the direct control of USPS. It will be affected mail diverted to Generation II EMS was as-
by diversion to electronic modes of “written” sumed to remain in the USPS mainstream.
communication (EMS and EFT), by overall Mailgram and E-COM are Generation II serv-
economic factors, and by competition from pri- ices. In all of 1980, about 40 million Mailgrams
vate message and parcel delivery systems. were sent; in the first half-year of its existence
Taken together, it seems clear that two-thirds (January through June 1982), about 660,000
or more of the mainstream could be handled E-COM messages were sent. During July
electronically, and that the volume of mail is 1982, E-COM averaged about 172,000 mes-
likely to peak in the next 10 years and fall sages weekly. USPS also delivers an unknown,
below today’s level sometime in the 1990’s. but small, number of letters that represent the
hardcopy output of private sector Generation
EMS penetration of the mainstream will be II EMS.
paced by the introduction and widespread use
of technologies such as high-quality electronic OTA did not independently estimate overall
printers, office automation, home computer future economic growth or competition from
terminals, viewdata/teletext, and inexpensive private delivery services; representative past
home hardcopy terminals. EFT will be paced growth rates of the USPS mainstream were
by the increased use of automated teller ma- projected into the future. For example, the
chines and point-of-sale terminals, and con- USPS mainstream has grown by about 2 per-
solidation of bills and payments through tel- cent per year if averaged over the 1900-77
ephone bill payer, debit cards, and direct de- period, and 3 percent over the 1947-77 period.
posit. In the long run, both EMS and EFT are In 3 of the last 4 years, the growth rate ex-
likely to be possible over the same electronic ceeded 3 percent. However, between 1971 and
terminals and communication networks. But 1976, the growth rate was only about 1 per-
in the shorter term, they are separate technol- cent.
ogies. EMS itself has two distinguishable If the recent 3 percent growth rate held for
modes-Generation II EMS (electronic input the next 20 years, USPS conventional mail
and transmission with hard copy output) and would exceed the 1981 level (110 billion pieces)
Generation III EMS (all-electronic). This di- until the mid-1990’s, even in the face of com-
version of mail from conventional paper-based petition from high but plausible EMS and
to electronic form is likely to stretch over EFT growth. Assuming that USPS delivers
many years and probably decades, depending the hardcopy output from Generation II EMS
on the rate of technological advance, on future in that timeframe, USPS total deliveries would
postal rates, on regulatory constraints, and in exceed the 1981 level until the turn of the cen-
part on intangible factors such as consumer tury. Similarly, at 2-percent annual growth,
acceptance and institutional marketing strat- and the same conditions, USPS conventional
egies. mail volume would exceed the 1981 level until
OTA made several estimates of the rate of about 1990, and total mail until the
mid-1990’s.
diversion of conventional mail to EMS and
EFT. Mail diverted to Generation III EMS OTA conducted several sensitivity analyses
and EFT was assumed lost to the USPS mail- to determine the conditions under which the
.
Ch. 1—Summary ● 5
USPS mainstream might decline even faster. 25 billion pieces. However, this exceeds even
OTA concluded that the most likely condition OTA’s high but plausible Generation II pro-
would be continued economic recession or de- jection by roughly 40 to 80 percent, depending
pression, which in the past (early 1970’s and on the underlying growth in demand for mail.
early 1930’s) has resulted in a flat or even It appears that RCA was overly optimistic
negative mailstream growth. This, coupled about Generation II market development, ig-
with even faster than anticipated introduction nored competition with Generation III EMS
of all-electronic Generation III EMS and EFT, services, or both. OTA also identified a slow-
or escalation of USPS costs and rates above growth Generation II path that projects a vol-
the level of alternative conventional and elec- ume of about 40 million messages 5 years
tronic delivery services, would accelerate the hence, increasing to about 600 million mes-
decline of the USPS mainstream. sages after 10 years and around 3 billion after
15 years. Given the highly volatile and unpre-
Regardless of the underlying mainstream
dictable nature of the EMS market, it appears
growth, the effect of Generation II EMS vol-
that prudent planning should be based on a
ume is to “cushion” or offset some of the
maximum of one-half of the RCA-projected
decline in conventional mail, assuming USPS
volume on down to the OTA-projected volume
delivers the Generation II hardcopy output.
for Generation II slow growth. This would
Put differently, if Generation II volume
place the projected Generation II market 20
reached significant levels, USPS-delivered
years hence in the range of 7 billion to 17 bil-
mail volume (conventional plus Generation II)
lion pieces rather than 25 billion.
might be maintained at or above a given level
for an additional 5 years or so. There are legitimate differences of opinion
as to how Generation II would fare after 2000,
For planning purposes, it is reasonable to
which was beyond the timeframe of the OTA
assume that mail volume is likely to remain
study. Some analysts believe that Generation
strong for most of the 1980’s, and decline
II would taper off very slowly and remain sig-
significantly in the 1990’s. Under any plausi-
nificant for many years. Others are convinced
ble scenario, USPS is still likely to be handling
that Generation II might decline rather pre-
a large volume (70 billion to 110 billion pieces)
cipitously. However, it is likely that Genera-
of mail in 2000.
tion III would surpass Generation II in ab-
Independent of the total USPS mainstream, solute volume well before 2000. Indeed, unless
the size of the potential Generation II EMS Generation II grows at a high or very high
market itself takes on considerable importance rate, it is possible that Generation II would
with respect to decisions concerning USPS in- never exceed Generation III. Various private
volvement. OTA has concluded that prior mar- telecommunication carriers have indicated
ket estimates probably have been high. For ex- that most research and development (R&D)
ample, RCA Corp. previously estimated a ma- and marketing effort is going into Generation
ture Generation II market (20 years hence) of III, not Generation II.
97-918 0 - 82 - 2
6 ● Implications of Electronic Mail and Message Systems for the U.S. Postal Service
contribution to fixed costs of any class of mail. about $650 million (1980 dollars). A 1976
In fiscal year 1980, first-class mail made up USPS staff study projected a $1.1 billion (1977
about 57 percent of the total mainstream. Its dollars) savings for delivery 3 days a week.
contribution to USPS fixed costs was about
In the longer term, USPS fixed costs may
$4.2 billion, based on an actual volume of 60
be reduced below the current 36 percent; other
billion pieces (and assuming 20¢/piece revenue
ways to improve productivity might be iden-
and 13¢/piece variable cost). This was about
tified such that service levels could be main-
55 percent of total fixed costs ($7.6 billion) in
tained even at lower volumes and revenues.
that year.
However, some significant portion of USPS
The example of first-class mail just cited is costs clearly is required to pay for maintain-
particularly relevant to this study because it ing the basic nationwide delivery system and
is likely that most of the conventional mail di- infrastructure, largely irrespective of the
verted to EMS or EFT over the next 20 years volume. For example, a substantial number of
will be first-class mail. Not only does it repre- carriers are required to cover the approximate
sent the largest volume of mail, but it is gen- ly 69 million city USPS delivery points and
erally more amenable to electronic transmis- 15 million rural delivery points (as of 1980)
sion than are other classes. Three-quarters of each day, 6 days a week, and to maintain win-
first-class mail is made up of correspondence, dow service at over 30,000 post offices, 9 hours
negotiable instruments (e.g., checks), and bills or more a day, 5 or 5½ days a week. Likewise,
and financial statements. some minimum level of truck transportation
between post offices must be maintained to
If the first-class mainstream declined 10 bil-
meet delivery performance standards, regard-
lion pieces by the year 2000, and the 1980 cost
less of whether the trucks are carrying several
and markup is assumed, first-class mail would
dozen or several thousand letters. Labor cur-
contribute $700 million less to USPS fixed
rently accounts for about 85 percent of USPS
costs than it does today. Making up that loss
costs and transportation about 7 percent
by raising first-class rates alone would require
(largely for trucks and other postal vehicles,
a 7-percent increase. To the extent that USPS
plane and rail transportation). Thus, from this
was delivering Generation II EMS hardcopy
perspective, it is not clear that fixed costs
and making a profit on it, some or all of this
could be reduced substantially without cutting
rate increase could be avoided. This latter pos-
service levels.
sibility is highly dependent on the cost of Gen-
eration II EMS (not well known) and the mar- In sum, any projections of USPS revenues,
ket price (also not well known). costs, and rates are difficult at best, given:
Cost cutting would ease the necessity of in- 1. the complexity of USPS revenue and cost
creasing rates. This strategy would be par- relationships;
ticularly prudent if first-class rate increases 2. the fact that costs obviously vary by type
would lead to a further volume reduction, of mail route (e.g., urban, suburban, rural),
which could set off a spiral of rate increases although USPS does not collect such cost
and volume reductions. Whether or not cut- data;
ting costs would result in service cuts would 3. the problem of how to assign common
depend in part on the USPS cost structure. costs properly to different mail services;
Under the current cost structure (36 percent 4. the uncertainty in determining what costs
fixed costs, 64 percent variable), some service are variable with volume changes over
cuts would appear to be necessary. For exam- various time periods; and
ple, USPS officials have estimated that deliv- 5. the uncertainty over future costs, rates,
ery 5 days a week (instead of 6) would save and volumes of Generation II EMS.
Ch. 1—Summary ● 7
Labor Requirements
USPS is a labor-intensive organization, with with mail volume. Included would be head-
labor representing about 85 percent of total quarters, regional, and inspection service
USPS costs. By making assumptions about employees. On the other hand, almost all of
the kind of service provided by USPS, the divi- the activities carried out by clerks and mail
sion of labor among its employees, and their handlers varied with mail volume (86 percent
productivity, it is possible to estimate the variable/14 percent fixed). In fiscal year 1980,
labor requirements for projected future mail this group included 303,560 full- and part-time
volumes. employees, or about 45 percent of the total
1980 USPS work force of 667,000 employees.
For the purposes of this labor force analysis,
The clerks and mail handlers would have lim-
OTA assumed that the kind of service pro-
ited participation in a Generation II EMS
vided by USPS (service levels) would remain
service, which would bypass many of the tradi-
constant. That is, there would be no change
tional mail sorting and processing functions
in the number of delivery days (e.g., 6 days a
performed by clerks and handlers. The hard-
week), post offices (over 30,000), weekday win-
copy output of Generation II EMS would still
dow service hours (typically 9 hours), or city
require physical delivery by city or rural
and rural delivery points (over 84 million).
carriers.
OTA calculated the division of labor among
Most other employee groups fall in between,
USPS employees by assuming that each func-
having some activities that vary with total
tional group of employees would allocate their
USPS-delivered mail volume (conventional
time in the future the same as they do now. plus Generation II EMS) and some that do
That is, each employee group spends a certain
not, but with a larger fixed component than
fraction of its time in activities that are in-
clerks and handlers. These would include su-
dependent of the volume of mail (“fixed
pervisory and technical personnel (48 percent
labor”); most groups also spend time in ac- fixed), city delivery carriers (50 percent fixed),
tivities that do vary directly with the volume
maintenance personnel (about 55 percent
of mail (“variable labor”).
fixed), and rural delivery carriers (73 percent
OTA estimated variable and fixed percent- fixed).
ages for each major group of USPS employees
With respect to productivity, OTA assumed
from the USPS fiscal year 1980 Revenue and
an average labor productivity improvement of
Cost Analysis. The variable labor percentage
1.5 percent per year as a baseline. For com-
is based on the variable attributable cost from
parison, USPS labor productivity is credited
the USPS analysis; the fixed labor percentage
as increasing by roughly 3 percent annually
on the sum of specific fixed attributable costs
during the 1970’s, as measured by the number
plus all other institutional costs for each
of pieces of mail per workyear. In fiscal year
employee group. The variable and fixed labor
1970, 741,000 postal employees delivered 85
percentages determined by OTA were re-
billion pieces of mail, while in fiscal year 1980,
viewed with USPS and found to be reasonable.
667,000 employees delivered about 106 billion
The overall cost split for the entire USPS pieces. The 3-percent figure may not reflect
labor force was calculated to be 61 percent true labor productivity since service levels did
variable and 39 percent fixed. Individual change. For example, mailbox collection fre-
employee groups varied from those independ- quencies (per day) were generally reduced and
ent of USPS mail volume to those almost com- cluster boxes were substituted for home de-
pletely dependent on it. As of 1980, 14,268 livery in many new suburban residential de-
employees, or about 2.1 percent of the total velopments. Still, between 1971 and 1980 the
USPS labor force, had no activities that varied number of city delivery points increased by
8 ● Implications of Electronic Mail and Message Systems for the U.S. Postal Service
about 21 percent and the number of rural de- ployee groups. The post office clerks and mail
livery points increased by about 50 percent. handlers group would be expected to be hit the
Even assuming that the 3-percent annual aver- hardest, losing perhaps two-fifths of their 1980
age during the 1970’s is an accurate measure, complement by 2000. Post office supervisors
this does not appear to be a realistic expecta- and city delivery carriers could, by 2000, be
tion for the 1980’s in view of the fact that most reduced by about one-fifth and rural delivery
productivity improvement from automation carriers by about one-tenth of their 1980 com-
and mechanization has already been realized. plements.
Even the expanded ZIP code program, known Whether or not these labor force reductions
as ZIP + 4, would realize a total labor pro- could be handled through attrition depends
ductivity improvement of only 2.3 percent, ac- largely on future USPS retirement, quitting,
cording to USPS estimates. and new hire rates. But the uneven impact of
Taking these variables together, and assum- reductions on various employee groups makes
ing high but plausible EMS growth, OTA con- this unlikely. In addition, the uneven distribu-
cluded that the USPS labor force requirement tion of minority employment among employee
in 2000 is most likely to be roughly 20 to 25 groups raises the possibility that such reduc-
percent below the 1980 level. This result is pro- tions may fall disproportionately on black and
jected for the base case of 1.5-percent annual perhaps other minority employment. For ex-
labor productivity improvement and 2-percent ample, as of late 1978, the mail handlers,
annual underlying mainstream growth, and whose employment would be reduced the
also for the cases of 3-percent productivity im- most, had one of the highest percentages of
provement/3-percent mailstream growth, and black employment. Involuntary labor force re-
O-percent productivity improvement/1-percent ductions in this area, if needed, would likely
mainstream growth. Under all three of these raise some difficult social and political issues.
scenarios, the need for significant labor force Overall, the impact of labor force reductions
reductions is not likely to be felt until the late
on promotion opportunities, upward mobility,
1980’s and early 1990’s, but would increase employee morale, and union contract negotia-
quite rapidly thereafter. tions could be significant. These areas warrant
Whatever the level of reductions, they are further study.
not likely to be spread evenly among all em-
Policy Implications
The OTA analysis indicates that, regardless Although a USPS role in Generation II
of what role USPS plays in Generation II elec- EMS has the potential to provide a volume
tronic mail, reductions in USPS-delivered mail and revenue “cushion” to partially offset re-
volume due to diversion to Generation III ductions in conventional mail volume and rev-
EMS and EFT could reach significant levels enue, there is little consensus among USPS
by 2000. The threat to USPS-delivered mail and major stakeholders on exactly what the
could come even sooner if Generation III EMS USPS role should be in the provision of Gen-
services (all-electronic) develop faster than cur- eration II EMS.
rently anticipated, if the underlying growth The market penetration results indicate that
in the mainstream is less than the historical USPS-delivered mail volume (conventional
average, or if diversion of second- and third- mail plus Generation II EMS hardcopy out-
class mail to alternative (nonelectronic) deliv- put) is one key factor in considering a USPS
ery services increases significantly beyond cur- role in Generation II EMS. USPS-delivered
rent levels. volume is a function in part of the rate of
.
Ch. 1—Summary ● 9
Generation II EMS growth. Assuming that USPS role in EMS is likely to continue indef-
USPS delivers Generation II EMS hardcopy initely. The fairness and legality of a USPS
output, the faster the rate of growth (and the role in EMS, the impact on innovation and
earlier the takeoff), the larger the Generation competition in the EMS industry, and implica-
II EMS volume and USPS-delivered volume. tions for EMS privacy and security continue
There is currently little agreement on which to be in dispute. Although the U.S. District
USPS role would contribute the most to Gen- Court of Appeals has denied a Department of
eration II EMS growth and volume. Justice petition to block E-COM, further reg-
The revenue/cost results indicate that Gen- ulatory proceedings are anticipated and addi-
tional legal actions are possible.
eration II EMS cost displacement and con-
tribution to covering USPS fixed costs are also With continuing uncertainty over the future
key factors in considering a USPS role. The of E-COM, and in general over the USPS role
greater the cost displacement (avoidance of in EMS, the prospects for a successful USPS
conventional mainstream costs) and contribu- entry into domestic EMS services are uncer-
tion to covering USPS overhead, the less likely tain. This affects both USPS and its potential
the need for service (and/or labor) reductions. competitors in the private sector. Some firms
Mailgram apparently provides both a substan- have indicated to OTA that they are reluctant
tial cost displacement and contribution to to make any major commitments until they
fixed costs; it is not clear whether E-COM are certain what role USPS is going to have.
would do likewise at current rates and in its Meanwhile, most private sector R&D efforts
present configuration. All parties, including are going into Generation III EMS, which
USPS, agree that the RCA cost estimates pre- would completely bypass USPS. In addition,
pared for the Electronic Message Service Sys- given the continuing adversarial atmosphere,
tem in 1977 and the original E-COM cost es- USPS is unable to establish effective working
timates prepared for the Postal Rate Commis- relationships with many private carriers and
sion in 1978 are now outdated. If E-COM is potential Generation II EMS users.
to be fully evaluated and its role in USPS’
Should Congress wish to take action, there
future understood, a comprehensive cost re-
are several possibilities: 1) provide a clear
view of E-COM is needed.
direction for USPS involvement in EMS; 2) re-
In contrast, there is general agreement that duce or eliminate further regulatory and ju-
USPS participation in Generation II EMS dicial delay; 3) strengthen privacy and security
would generate only a relatively small number protection; and 4) maintain oversight and in-
of new jobs. An estimated 200 persons (125 itiate planning on USPS long-term viability.
operations, 50 maintenance, 25 marketing and These possibilities are outlined below.
administrative) currently work on E-COM. A
fully deployed service (at 150 serving post of- Provide a Clear Direction for
fices (SPOs) rather than the current 25) is es- USPS Involvement in EMS
timated to require perhaps 2,000 persons. The
additional volume from USPS delivery of Gen- There is a range of alternatives for a USPS
eration II EMS hardcopy output could help role in EMS: .
to offset some of the reductions in the existing
1. no real involvement other than delivery
labor force that will be necessary if the pro-
of Generation II EMS hardcopy output
jected decline in USPS-delivered mail materi-
when deposited into the mainstream;
alizes.
2 delivery of all hardcopy output when con-
Based on interviews with many of the stake- veyed over postal roads;
holders and a comprehensive review of the his- 3 hardcopy delivery plus location of
torical record, OTA has concluded that absent carrier-provided EMS terminal equip-
congressional action, the controversy over the ment on USPS premises (as in Mailgram);
—
10 ● Implications of Electronic Mail and Message Systems for the U.S. Postal Service
4. the current E-COM role or variations of ● whether or not space should be provided
it (e.g., the use of logo envelopes to retain in SPOs for carrier output equipment;
carrier and mailer identities); ● whether or not the technology selected by
5. involvement in the telecommunication RCA for E-COM is the best available;
portion of EMS as well-as printing, envel- ● whether technical modifications to the
oping, and delivery; and current E-COM interconnection arrange-
6. involvement in Generation III EMS as ment could permit more total lines (and
well (e.g., through lease or contract with at what cost) for carrier and user access,
private industry). and whether alternative access allocation
schemes should be considered; and
Each of these alternatives is technically ● whether E-COM performance standards
feasible. In evaluating each, Congress may and design should be modified to guaran-
wish to take into account some or all of the tee 1-day delivery.
following broad considerations:
● the extent to which each alternative Reduce or Eliminate Further
would contribute to Generation II EMS
growth and volume;
Regulatory and Judicial Delay
● the extent to which each alternative The most important action Congress can
would favorably affect USPS finances, take to reduce delay is to provide clear direc-
i.e., EMS cost displacement and contribu- tion for USPS involvement in EMS. A note
tion to covering USPS fixed costs; of caution is in order. If the direction set out
● the extent to which each alternative, is not well understood and does not reflect a
through creating new jobs and increasing substantial consensus, further regulatory dis-
USPS mail volumes, would defer or par- putes and litigation could result.
tially offset labor reductions that might
otherwise be necessary; Additionally, Congress could:
● the extent to which each alternative ● clarify the applicability of the Private Ex-
would provide incentives for marketing press Statutes to delivery of Generation
by USPS and/or private firms; II EMS hardcopy output;
● whether changes in the Postal Reorgani- ● delineate the division of regulatory juris-
zation Act are needed to permit more flex- diction between the Postal Rate Commis-
ibility in the USPS decisionmaking proc- sion and the Federal Communications
ess (including regulatory review) with re- Commission; and
spect to USPS involvement in EMS; ● decide on the desirability of a separate
● whether the term “demonstrated need” USPS entity for any EMS offering.
for USPS to contract with a telecommu-
nication carrier to transmit messages elec-
tronically on behalf of USPS needs to be Strengthen Privacy and
clarified; and Security Protection
● whether or not there are any conditions Privacy protection in a USPS EMS service
that would constitute demonstrated need is a continuing issue. Preliminary discussions
for USPS involvement in electronic deliv- with USPS indicate that while the E-COM
ery (presumably by contract with private equipment is apparently physically secure, the
Generation III EMS firms); for example, potential for security breaches does exist. User
in geographic areas where conventional account numbers are visible on the outside of
mail service could no longer be main-
E-COM envelopes. When combined with an ac-
tained at present levels.
cess code and familiarization with the E-COM
With regard to E-COM itself, Congress may technical interconnection standards, this in-
wish to review the following specific issues: formation would permit unauthorized use of
Ch. 1—Summary ● 11
E-COM. Incoming messages are stored for 1 ● joint technical and market tests with pri-
week in computer memory or on magnetic vate firms to evaluate various EMS alter-
tape, providing another target for security natives;
violations. These archived messages could also ● use of EMS to help USPS maintain ade-
be tapped via the management information quate service levels to rural and less pop-
system, since the E-COM computers in the 25 ulated areas;
centers are connected electronically with this ● use of EMS to help USPS offset the re-
system. duction (or elimination) of the revenue for-
gone subsidy (which is provided to offset
Congress may wish to consider: 1) whether
revenue losses from mail service provided
an independent review of E-COM security is
at reduced rates) and permit continuation
warranted to ensure that adequate security
of a lower rate to nonprofit and educa-
measures are in place to protect the privacy
tional organizations;
of EMS messages, and 2) whether the Postal ● use of EMS in the future in combination
Act and/or Communications Act should be
with the USPS infrastructure (perhaps
amended to provide additional statutory pri-
scaled down) and delivery network to pro-
vacy protection (including the possible man-
vide other Federal Government services
dating of data encryption to provide additional
(e.g, printing and delivery of forms and
technical privacy protection).
documents); and
● USPS long-range planning on the possi-
Maintain Oversight and ble need for labor force reductions, job re-
Initiate Planning on USPS training, adjustments in retirement and
Long-Term Viability new hire rates, and implications for union
contract negotiations.
Although the immediate focus is on E-COM,
and on providing a clear direction for USPS In view of aggressive private sector Genera-
involvement in EMS and resolving current tion III EMS activity and the continuing eco-
regulatory problems and delays, EMS issues nomic trends that work in favor of electronic
are likely to be with Congress for many years, mail and against paper-based mail, it seems
driven by the impact of EMS on USPS, the clear that Congress and USPS should begin
role of USPS in EMS, and the broader impact planning now for the future viability of USPS.
of EMS on American society and the public Changes are taking place so fast in the so-
at large. For a discussion of these broader im- called “communications revolution” that by
pact areas, see the related OTA report on Com- the time USPS might actually experience sig-
puter-Based National Information Systems nificant impacts on mail volume, most oppor-
(1981). Within this context, Congress will need tunities for participation in EMS will have
to maintain oversight and initiate planning on passed and it will be much more difficult to
USPS long-term viability. adjust.
The following areas warrant further study:
● USPS initiatives designed to develop im-
proved working relationships with private
telecommunication and computer firms;
Chapter 2
Background and
Purpose of Study
Contents
Page
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
Congressional Interest.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . + . . . . . . . . . . . . 17
Study Purpose and Approach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
Chapter 2
Introduction
By some measures, the U.S. Postal Service Why, then, is there concern about the future
(USPS) has done remarkably well in the 10 of USPS? While recent years have been rela-
years since postal reorganization.* Gross pro- tively good, the 1980’s and 1990’s will pose
ductivity, as measured by number of pieces of a number of new and perhaps more difficult
mail per workyear, has increased by 34 per- challenges.
cent since fiscal year 1970 when 741,000 postal First, the potential for further improve-
employees delivered 85 billion pieces of mail. ments in postal productivity through presort
In fiscal year 1980, 667,000 employees de-
discounts and through mechanization and
livered 106.3 billion pieces of mail. In 1980,
automation is limited. Even a fully im-
mail volume increased by 6.5 percent over
plemented expansion of the ZIP code to nine
1979. First- and third-class mail volumes con-
digits (known as ZIP + 4) would mean a
tinue to show strength with increases of ap-
cumulative reduction of only about 15,600
proximately 15 and 36 percent, respectively,
workyears by 1987 according to USPS esti-
over the last 5 years. During the same period,
mates. Compared to the current USPS annual
pieces of mail per capita have increased by
workyears of 679,000, the productivity im-
about 13 percent, from 418 pieces per person
provement would amount to about 2.3 per-
in fiscal year 1976 to 480 pieces in 1980.1
cents This means that continued automation
On the financial side, USPS more than broke will provide only a small part of the total pro-
even over the combined 1979-80 period. The ductivity improvement needed by USPS to
surplus of $470 million in fiscal year 1979 off- offset inflationary increases in employee com-
set a deficit of $306 million in 1980. The cost pensation and transportation, which together
of postage continues to rise, but since 1975 at account for over 92 percent of total USPS an-
a rate that is lower than the consumer price nual expenditures.4
index. If fully adjusted for inflation since 1975,
Second, while USPS operating statistics in-
a first-class stamp would cost 22¢ rather than
dicate that ontime delivery has been main-
the current 20¢. However, if fully adjusted for
tained for 95 percent of first-class mail des-
inflation since 1967, a first-class stamp would
tined for local or metropolitan area overnight
cost only about 14¢. Thus, about 6¢ out of the
delivery, ontime delivery within 600 miles and
current 20¢ represents a real increase in the for cross-country fist-class mail generally has
first-class letter rate since 1967. The letter rate
declined since 1977. Two-day delivery of let-
in the United States continues to be well below
ters within 600 miles was achieved 86 percent
rates in most other countries. For example, in
of the time in 1980 compared to 90 percent in
1980 the letter rate was about 29¢ in Britain
1977. Three-day delivery of cross-country let-
and Japan, 31¢ in France and Sweden, and 33¢ ters was achieved 87 percent of the time in
in West Germany.2
1980 compared to 91 percent in 1977.5 Part of
‘Comptroller General of the United States, Imph”cations of
Ekctmnic Mad for the Postal S&vice Work Fome (Washington,
*Th po9~ Mrgani.zation Act of 1970 enacted by Congress
e D. C.: U.S. General Accounting Office, Feb. 6, 1981), p. 32. The
abolished the Post Office Department as a cabinet level agen- estimated changes in workyears per year from the nine-digit
cy of the executive branch. Postal functions were transferred ZIP are as follows: 1981 ( +3), 1982 (+87), 1983( – 1334), 1984
to an independent Government agency known as the United (–2382), 1985 (–3301), 1986 (–4378), and 1987 (–4295) for
States Postal Service, which commenced operations on July 1, a total reduction of 15,600 workyears. Per Nov. 4, 1981, discus-
1971. sion with Douglas Lynn of the USPS Operations Group.
IAnnual Report of the Postmaster General fiscal 1980. ‘Annual l?epor~ op. cit., p. 24.
‘Ibid. ‘Ibid., pp. 8, 11.
15
16 ● Implications of Electronic Mail and Message Systems for the U.S. Postal Service
—.
the problem can be attributed to cutbacks in traffic from other media, including a portion
air carrier service, but it is also possible that of the message traffic currently handled by the
the rising total volume of mail has begun to U.S. Mail. This diversion would come at a time
tax the capacity of the overall mail distribu- when mail volume may also be reduced by the
tion system. For example, postal officials have consolidation of many bills and payments, or
testified that the elimination of Saturday the elimination of some billing and payment
delivery alone would create a mail backlog suf- transactions altogether, as a consequence of
ficient to overload the system for Monday the implementation of electronic funds trans-
delivery. On the other hand, postal officials fer (EFT) systems.
point to the system’s ability to handle peak
volumes during holiday periods as evidence Substantial erosion of U.S. Mail volumes,
that overall capacity has not been reached. particularly first-class mail, could tend to raise
the unit cost of carrying the remaining mail
Third, a variety of technical regulatory, and volume and/or force a reduction in the quali-
market developments are contributing to a ty and convenience of mail service, thus pro-
rapid increase in commercially offered elec- viding further incentive for mail users to
tronic mail and message systems (EMS) that switch to alternatives such as private delivery
increasingly will compete with USPS As early services, newspaper inserts, and the like. Such
as 1977, studies projected that EMS could a development could disadvantage users with-
divert substantial portions of mail from USPS, out a viable alternative to the U.S. Mail,
to the extent that total mail volume might ac- jeopardize the ability of USPS to provide
tually start to decline by the early 1980’s.6 universal service, and adversely affect USPS
None of these projections has yet been real- employees.
ized. However, the large number of commer-
cial firms now in the electronic message An important issue for USPS is whether and
market,* coupled with recent developments in how it will participate in the provision of elec-
personal computers, viewdata/teletext, and tronic mail and message services. USPS cur-
other home information systems, suggests rently provides a portion of Western Union’s
that this prospect is much more realistic than Mailgram service, and in January 1982 in-
it was just a few years ago. Furthermore, regu- troduced a domestic service called “electronic
latory decisions by the Federal Communica- computer-originated mail” (E-COM). An inter-
tions Commission over the last few years, national EMS service, known as “interna-
coupled with congressional actions to rewrite tional electronic post,” has also been initiated.
the Communications Act of 1934, are clearing INTELPOST is outside the scope of this
the way for increased competition in the elec- study. USPS has been developing a more ad-
tronic message market. Thus, while EMS will vanced “electronic message service system”
undoubtedly stimulate new message “traffic” or EMSS which, for the purposes of this study,
between individuals and organizations, they is considered to be an extension of E-COM to
also have the potential for diverting existing full nationwide deployment at all or most serv-
ing post offices. There are a variety of ways
%%, for example, F. B. Wood, R. W. Anthony, et al., USPS in which USPS could play one or more roles
and the (hnxnunications Revolution: Impacts, Options, and
Issues, Final Report to the Commission on Postal Service,
in the provision of EMS services, ranging from
prepared by the Program of Policy Studies in Science and Tech- the delivery of hardcopy output to the provi-
nology, The George Washington University, Washington, D. C., sion of a complete end-to-end electronic mail
Mar. 5, 1977. Also see Arthur D. Little, The Impact of Elec- service.
tronic (%mmunication Syst%ms on First Class Mail Volume in
J9801990, Cambridge, Mass., April 1978.
*Ex~ple9 include Quik-COmm (General Electric), Telemail The Annual Report of the Postmaster Gen-
(GTE Telenet), On-Tyme (Tymnet), InfoPlex (Plexus), Faxgram eral for fiscal year 1979 states flatly: “In the
(Graphnet), Mailgram (Western Union), and Datapost (southern future, the only way the Postal Service will be
Pacific). Electronic mail is also one of several services offered
by Satellite Business Systems and other specialized or value- able to keep its volume rising and finances
-added common carriers. dependable is through participating in elec-
Ch. 2—Background and Purpose of Study ● 17
———-——
tronic mail services.”7 In a July 1979 policy ly implemented differs significantly in other
statement, the White House agreed, stating ways from the concept originally recom-
that “the national interest requires a Postal mended by PRC. A 1981 inquiry opened by
Service which can serve all Americans and in- PRC to review what form of E-COM USPS
terface with the world’s postal services effi- should be offering was suspended after its
ciently and economically. The service has pro- legality was challenged by USPS.
gressively achieved productivity improvement
Comments filed before PRC jointly by the
by mechanization and automation in process-
Departments of Commerce and Justice and a
ing of conventional mail . . . A postal EMS is
court challenge to E-COM filed by Justice in-
the next logical step to achieve further cost
dicate that the current administration is not
reduction and mail processing improvement.”8
supportive of E-COM as presently operating,
Over the last 3 years, the role of USPS in or possibly of any USPS role in EMS that in-
EMS has been in dispute before various reg- volves telecommunication, data processing, or
ulatory agencies, the courts, and Congress. printing. This in part reflects continuing con-
USPS initiated E-COM service in January cern that E-COM places an independent Gov-
1982 after the USPS Board of Governors ap- ernment agency (USPS) in competition—per-
proved the Postal Rate Commission’s (PRC) haps unfairly and/or illegally-with private
1980 recommended decision, with the excep- firms. Some of these firms believe that the de-
tion of PRC’s “experimental” designation (of mand for EMS can be met by private offer-
E-COM as an experimental rather than a per- ings, and that the USPS role should be re-
manent service) which was successfully ap- stricted to the delivery of hardcopy output
pealed by the Governors to the courts. How- from electronic message systems. Others are
ever, several private firms and the current ad- concerned that in the future USPS may ex-
ministration believe that E-COM as present- pand its EMS role from printing, enveloping,
and physical delivery-as in E-COM—to in-
7AnnuaJ Report of the Postmaster Genera4 fiscal 1979, p. 6.
8
Administration Policy Statement, The White House, July clude telecommunication and perhaps elec-
19, 1979. tronic delivery as well.
Congressional Interest
The implications of electronic mail and involved with an EMS service that is subject
message systems for USPS, and especially the to the Communications Act of 1934, in whole
role of USPS in EMS, have been and continue or in part. These committees include the
to be a primary concern of congressional com- House Committee on Energy and Commerce
mittees with direct jurisdiction over USPS (and the Subcommittee on Telecommunica-
and the Postal Reorganization Act of 1970, tions) and the Senate Committee on Com-
i.e., the House Committee on Post Office and merce, Science, and Transportation (Subcom-
Civil Service (and particularly the Subcommit- mittee on Communications). In addition, other
tee on Postal Operations and Services and the committees, such as the House Committee on
Subcommittee on Postal Personnel and Mod- Government Operations Subcommittee on
ernization) and the Senate Committee on Gov- Government Information and Individual
ernmental Affairs (especially the Subcommit- Rights, have an interest in the privacy, com-
tee on Civil Service, Post Office, and General petitive, and related implications of a USPS
Services). role in EMS.
Despite a variety of legislative initiatives in
The role of USPS is also of interest to the recent years, Congress has yet to agree on a
committees with jurisdiction over telecom- clearly defined EMS role for USPS. H.R. 2813,
munications to the extent that USPS becomes introduced in the 97th Congress, would require
18 ● Implications of Electronic Mail and Message Systems for the U.S. Postal Service
This study gives primary emphasis to im- are highly sensitive to initial assumptions. For
pacts on the USPS mainstream (based on re- this reason, sensitivity runs were conducted
sults of the market penetration model) and on to see how much projections would change
USPS rates, service, and labor (based on com- with different assumptions. Third, the models
bined results of the market penetration model have limited ability to anticipate unexpected
and the revenue and cost model). Implications events. For example, the possibilities of a
for rates, service, and labor are summarized World War III, second Great Depression,
in chapter 6. Secondary emphasis was placed mandatory wage/price freeze, nationwide
on the potential implications for the telecom- postal labor strike, or repeal of the Private Ex-
munication and computer industries, EMS pri- press Statutes were not included. In other
vacy and security, and the long-term viabil- words, the models are based on a relatively
ity of USPS, discussed in chapter 7. Congres- “surprise-free” future. Fourth, the models do
sional policy considerations are discussed in not fully reflect the possible effect of rates on
chapter 8. mail volumes. There is a feedback process, but
its exact nature is unknown. That is, changes
A note on computer modeling is in order. in rates may have a significant effect on mail
Prior studies on mail diversion have proven volume, which in turn affects mail rates 1, 2,
to be oversimplified. In order to better under- or 3 years later (in the next ratesetting cycle).
stand the complexities involved, OTA devel- Despite these limitations, computer modeling
oped and used computer-based models to per- can be a useful analytical tool.
mit consideration of a larger number of vari-
ables and interrelationships than would other- Again, the study as a whole, and particular-
wise be possible. While this approach is more ly the use of computer modeling, is intended
systematic and complete than those used in to help Congress better understand the possi-
prior studies, computer modeling has its ble implications of EMS for USPS. The study
limitations. is not intended to make a prediction of the
future course of events. Many variations are
First, the precision of the projections can be possible. Finally, the study specifically avoids
misleading. The reader should focus on general making judgments about the impacts identi-
trends and relationships rather than the spe- fied and makes no recommendations relative
cific numbers projected. Second, the models to the role of USPS.
Chapter 3
Page
Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
Mailstream . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
EFT Diversion. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
EMS Diversion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ............ 27
Generation II Growth and Timing Estimates . . . . . . . . . . ............ 29
Generation III Growth and Timing Estimates . . . . . . . . . ............ 30
Relationships Between Generation II and Generation III Estimates. . . 31
Alternative Generation II Growth and Timing Estimates ............ 32
Mainstream Growth . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
TABLES
Table No. Page
l. Baseline Mainstream . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
2. Mail Content . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
3. Major Mailstream Segments Vulnerable to Penetration by Electronic
Funds Transfer . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
4. Major Mainstream Segments Vulnerable to Penetration by Electronic
Mail and Message Systems ....,... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25
5. Assumptions About Rate of EFT Penetration . . . . . . . . . . . . . . . . . . . . . 26
6. Assumptions About Rate of EMS Penetration . . . . . . . . . . . . . . . . . . . . . 29
7. Assumptions for Generation II Growth Alternatives . . . . . . . . . . . . . . . 32
8. Alternative Assumptions About Underlying Mainstream
Growth Rate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
FIGURES
Figure No. Page
l. Market Penetration Model . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
2. Comparison of Conventional Mail Service With Generations I,II,
and III EMS Service . . . . . . . . . . . . . . . . . . . ........... 28
Chapter 3
Introduction
The primary purpose of the market penetra- 1995, and 2000. The basic elements of the mod-
tion model is to estimate the level of electronic el are shown in figure 1. (See app. A, fig. A-1,
and conventional mail volumes in 1985, 1990, for further details.)
SOURCE: Office of Technology Assessment, see app. A, table Al for further details.
23
24 . Implications of Electronic Mail and Message Systems for the U.S. Postal Service
Baseline Mainstream
As one input to the market penetration mod- Table 1.— Baseline Mainstream
el, the baseline mainstream was divided into To households To nonhouseholds
a number of different submarkets (subclasses From 7.60/o 9.90/0
of mail) in two ways—by mail content and by households . . . . . . . . . (7.1 billion pieces) (9.2 billion pieces)
sender/receiver pairs. The mail content cate- From 53.3% 29.20/o
gories included correspondence, merchandise, nonhouseholds. . . . . . (49.7 billion pieces) (27.3 billion pieces)
volume and about four-fifths of third-class natures, endorsements, and documentation for
mail. Actually, only the merchandise and mis- many such instruments. Even here, the possi-
cellaneous segments and nonhousehold to non- bilities for electronic certified mail and elec-
household legal/financial instruments were tronic contract signing are being researched.3
assumed to have no vulnerability. Legal/finan-
cial instruments were assumed to have no
potential for electronic handling due to the fre- “’Cryptographers Gather to Discuss Research,” Science, vol.
quent requirement for verified and original sig- 214, NOV. 6, 1981, p. 647.
26 ● Implications of Electronic Mail and Message Systems for the U.S. Postal Service
—
EFT Diversion
The next step in the market penetration Table 5.—Assumptions About Rate of EFT
model was to subtract from the baseline mail- Penetration
stream the mail that could be diverted to EFT.
Year of 5 percent penetration—1985
While for some purposes EFT might be viewed Year of 75 percent penetration—2005
as a special type of EMS, other EFT applica- Initial exponential growth rate (1985)—20 percent
tions, such as the point-of-sale use of debit Growth rate at 50 percent penetration (year 2000)–
5 percent
cards, could eliminate certain payment Penetration potential —0.9 for bills and financial state-
messages altogether. Accordingly, in this ments
1.0 for negotiable instruments
study EFT was considered to be separate from Key technologies
EMS. Mail diverted to EFT was considered Automated teller machines (ATMs)
unavailable for EMS. For mainstream seg- 25,000 in operation (1981)
ATMs estimated by industry to at least double by 1990
ments such as bills and statements where both and could increase to 120,000 (an annual growth rate of
EFT and EMS could produce diversion, EFT roughly 10 to 20 percent):
diversion was assumed to occur first. The . deposit
● cash withdrawal
residual mail volume in each mail segment ● bill or loan payment
after EFT diversion was then considered the ● cash advance
ments is likely to take place via EFT, but that ● account status inquiry
● interaccount transfer
it will take many years. OTA has assumed
SOURCE Off Ice of Technology Assessment, see app A, table A-3, for further
that the use of EFT for bills and financial deta{ls.
statements in the long run would result in a
90-percent reduction in total bills and state- sion was estimated to be 2005. As shown in
ments received via conventional mail by the table 5, this growth rate is generally consist-
average household or nonhousehold. Thus, the ent with rates of growth projected by industry
maximum potential fraction (or penetration for key EFT technologies.
potential) of bills and statements that could Likewise, the results of the OTA study sug-
be diverted to EFT is 0.9, as shown in table gest that EFT is likely to displace checks and
5. OTA assigned an initial growth rate of 20 other paper-based negotiable instruments, but
percent, as indicated in table 5. Given the that this displacement will take many years.
nature of the logistic substitution process, a OTA has assumed that all such instruments
20-percent initial growth rate would decline to eventually could be displaced by EFT. Thus,
a 5-percent growth rate for the 20th year out. the EFT penetration potential is 1.0 for nego-
It would take 20 years to progress from 5 to tiable instruments sent to households or non-
75 percent of the maximum potential diver- households. As with bills and financial state-
sion. The year of 5-percent diversion (time ments, OTA has assigned an initial growth
when 5-percent diversion occurs) was esti- rate of 20 percent and estimated the year of
mated to be 1985. The year of 75-percent diver- 5-percent diversion to be 1985. (See app. A,
4
table A-3, for details.)
See OTA report Sleeted Electronic finds Transfer Issues: The OTA assumptions for bills and finan-
Privacy, Security, and Equity, OTA-BP-CIT-12, March 1982.
See also El?/l The Next Fifteen Y- Electronic Banking, Inc., cial statements and for negotiable instruments
June 1980, a working paper prepared for the above report. were optimistic in the sense that the actual
—
penetration potential might be lower than 0.9 the mainstream. The assumptions about EFT
and 1.0, respectively. Therefore, the actual may be affected by various intangible consid-
EFT penetration is more likely to be lower erations important to EFT and EMS users,
than assumed. EFT was defined, in effect, as especially those relating to consumer prefer-
an all-electronic service completely outside of ences and institutional marketing strategies.
EMS Diversion
As noted earlier, the residual mail volume the use of the television set and the tele-
in each mail segment after EFT diversion is phone.
the potential market for EMS diversion. EMS 6. Inexpensive hardcopy receiver. Facsimile
diversion is divided between Generation II and receivers or character printers at a price
Generation III and was calculated through use which could find acceptance in a major-
of the same logistic substitution process used ity of homes are included in this category.
for estimating EFT diversion (see app. B). The
The maximurn market penetration potential
terms Generation II and Generation III are
was estimated for each mainstream segment.
explained and compared in figure 2.
As with EFT, the assumptions about EMS
The EMS diversion model was based on a penetration potential were optimistic in the
set of EMS technology assumptions discussed sense that the actual penetration potential
below, highlighted in table 6, and detailed in might be lower due to restrained consumer ac-
appendix A (table A-4). The assumptions re- ceptance and other intangible factors. In most
late to the following six categories of technol- instances, the entire segment was judged 100-
ogy as applied to the various combinations of percent susceptible to Generation II and Gen-
mail content and sender/receiver pairs: eration III EMS. The exceptions are as
follows.
1. Generation II EMS systems with early
About 30 percent of the “other nonadvertis-
electronic printers (no color). This cate-
gory includes such industry offerings as ing” segments (nonhousehold to nonhousehold
Mailgram, Datapost and Tyme-Gram, and nonhousehold to household) is made up of
and USPS offerings such as E-COM. pamphlets, newsletters, official documents,
2. Generation II EMS systems with ad- coupons, and stockholder communications.
vanced electronic printers (including a col- Items of this type were judged not likely to
or capability). be susceptible to EMS technologies that are
3. Electronic data processing and office expected to achieve widespread use over the
automation. This category includes Gen- next 20 years. Hence a maximum potential
eration III technologies such as computer penetration of 70 percent (P = 0.7) was
networks, communicating word process- estimated.
ors, public and private message and pack- The displacement of direct mail “advertis-
et-switching networks, and facsimile sys- ing” and greeting “cards” segments to the
tems oriented toward nonhousehold use. home (nonhousehold to household and house-
4. Home computer terminals. Included are hold to household) by TV-based Generation
home computers and associated commu- III home terminals was judged to be limited
nications concepts/services such as PC by the constraints of the video medium. Thus,
Net (Personal Computer Network). a maximum Generation III penetration poten-
5. Viewdata/teletext. This category includes tial of 30 percent (0.3) was estimated for these
services, primarily to the home, based on segments.
28 ● Implications of Electronic Mail and Message Systems for the U.S. Postal Service
Figure 2.—Comparison of Conventional Mail Service With Generations I, II, and Ill EMS Service
SOURCE: Office of Technology Assessment; and National Academy of Sciences, .Hectromc ~essa9e Systems for the U.S. Postal Service, 1976.
.—— .
Early Generation II EMS (using current technology black Advanced Generation Ill EMS (using home computer ter-
and white printers) for correspondence, bills, third-class minals) for household to household correspondence:
bulk mail: Year of 5 percent penetration—1987
Year of 5 percent penetration—1983 Year of 75 percent penetration—2007
Year of 75 percent penetration—1996 Initial growth rate (1987)—20 percent
Initial exponential growth rate (1983)—30 percent for nonhousehold to household correspondence and bulk
Advanced Generation III EMS (using inexpensive home mail:
hardcopy receiver) for nonhousehold to household bills and Year of 5 percent penetration—1987
statements: Year of 75 percent penetration—1997
Year of 5 percent penetration—1990 Initial growth rate (1987)—40 percent
Year of 75 percent penetration—2010 Key technologies:
Initial growth rate—20 percent Home computers:
Advanced Generation II EMS (using high resolution color ● 500,000 installed (1980)
printers) for advertising, greeting cards: ● Estimated by industry to grow to 4.5 million installed
Year of 5 percent penetration—1995 by 1985 and 33 million by 1990 (roughly a 50 percent an-
Year of 75 percent penetration—2015 nual growth rate).
Initial growth rate (1995)—20 percent Video computer games:
Generation Ill EMS (using public and private message and ● Revenues increased from $308 million in 1978, to $968
packet-switching networks, communicating word proces- million in 1979, to $2.8 billion in 1980 (roughly a 300 per-
sors, computer networks) for intraoffice correspondence: cent annual growth rate).
Year of 5 percent penetration—1983 Mini and small business computers:
Year of 75 percent penetration—1996 ● Revenues of about $9.4 billion worldwide (1980)
Initial growth rate (1984)—20 percent . Estimated by industry to grow at 30 percent annually
Generation Ill EMS (using viewdata/teletext) for household over the next 5 years.
to household cards: Data communications:
Year of 5 percent penetration–1985 ● Estimated revenues of about $4 billion (1979) and grow-
Generation II Growth and scale, and color capabilities and probably will
Timing Estimates include greater flexibility in materials han-
dling. Recent technology and product an-
The attractiveness of Generation II services nouncements suggest that advanced printers
is determined primarily by the capabilities and may be available earlier than assumed for this
cost effectiveness of the devices for converting study.
the electronic signals back to hardcopy. De-
vices that have black and white capability only Generation II EMS services using early elec-
and limitations in page size and print style are tronic printing capabilities, if priced competi-
frequently not as attractive as conventional- tively with mail service, could begin to find
ly printed material. Also, printing systems substantial use by nonhousehold senders in
must be very cost effective or EMS prices will the next few years. For correspondence, bulk
be too high to compete successfully with con- statements, and other nonadvertising content,
ventional mail. OTA estimated a 5-percent diversion of exist-
ing mail to Generation II EMS by 1983, with
For the purposes of this study, OTA as- a high initial rate of growth (30 percent) which
sumed that the electronic printers available in could lead to a 75-percent market share about
the 1980’s will be limited in resolution and 13 years thereafter, as summarized in table 6.
flexibility and will lack color capabilities. Ad- The use of Generation II for advertising pur-
vanced electronic printers, which are expected poses, however, is expected to be largely de-
to become available at cost-effective prices in layed until color capabilities become available,
the 1990’s, will add greater resolution, grey and even then growth will be slower to the ex-
30 ● Implications of Electronic Mail and Message Systems for the U.S. Postal Service
tent that cost and relative inflexibility contin- based message systems, intelligent communi-
ue to limit the advantages of electronic color cation networks, and store and forward mes-
printing over conventional printing. Thus, for sage systems. Until recently, this competition
the advertising segment (nonhousehold to non- has tended to impede the development of
household and nonhousehold to household) a standards among different vendors supporting
5-percent market share was forecast for 1995, each technology, and for information exchange
with an initial growth rate of 20 percent. between systems based on the different tech-
nologies. The International Standard Organi-
Households will not be able to initiate a sig-
zation, the Consultative Committee for Inter-
nificant volume of Generation II EMS until
national Telephone and Telegraph, and the
home terminals capable of originating text
U.S. standards groups continue to work on
come into widespread use. About 500,000
developing standards. The process of agree-
home computers had been sold by 1980, 5
ing on and then implementing standards has
though many of these were not equipped for
been slow but appears to be accelerating. The
communications. OTA assumed that it will
time required to achieve and implement stand-
take several more years before 5 percent of
ards at a variety of system levels will be a prin-
households, or roughly 4 million homes, are
cipal determinant of the rate of growth of Gen-
equipped with communications-capable home
eration III message systems within the non-
computers, and that there will be additional
household sector.
delays before many of these home computers
are used routinely for correspondence. Thus, The problem will be easiest to resolve within
OTA assumed that the EMS market share for individual companies. OTA estimated a 5-per-
correspondence originating in the home will cent market share for Generation II EMS in
not reach 5 percent before 1987. A high initial 1983, and initial growth at a fast rate (30 per-
growth rate (30 percent) was projected, which cent). As shown in table 6, OTA estimated a
is consistent with growth rates projected by 75-percent market share for Generation III
industry for home computers, as indicated in EMS intra-office correspondence in 1996. A
table 6. slower initial growth rate (20 percent) was pro-
jected for interoffice correspondence due to in-
The requirement for a color capability is ex-
compatibility and the number of different
pected to put greeting cards in the same posi-
standards issues involved. These rates of
tion as advertising, thus delaying a 5-percent
growth are generally consistent with industry
market share for Generation II EMS until
projections (listed in table 6) for small business
1995.
computers, computer software, and data com-
munications.
Generation III Growth and
Timing Estimates The standards problem will begin to be re-
solved first for correspondence, which requires
Generation III EMS services between non- a minimum of content standardization. OTA
household senders and receivers are expected estimated a 5-percent market share in this seg-
to be based largely on electronic data-process- ment in 1984. Generation III will become at-
ing and office automation technologies. There tractive for bills and statements when the re-
are strong incentives within this sector for cipients can automatically process the infor-
keeping information in electronic form and for mation received. This requires considerable
machine processing by the receiver. As a result standardization of data elements and formats.
of these incentives, there is a healthy competi- OTA anticipated a slow penetration of these
tion among several technologies for this mar- complex standards to other sectors, in part
ket, including word processors, computer- due to the software development required to
employ them. Initially, exchanges frequently
6U.S. Congress, Office of Technology Assessment, (%mputen
Based National Information $@.ems: Technolo~ and Pubfic are likely to be via hand-carried or mailed com-
Policy Issues OTA-CIT-146, September 1981. puter tapes substituting for numerous paper
Ch. 3—Market Penetration Model and Technology Assumptions ● 31
messages will elect Generation III instead of Table 7.—Assumptions for Generation II Growth
hardcopy delivery when it suits their purposes Alternatives
or is convenient to do so, regardless of whether High but plausible Generation II EMS growth (baseline
the hardcopy comes from conventional mail alternative):
● Peak volume (year 1995) about 60 to 75 percent of RCA
or is the output of a Generation II system.
projected year 2000 volume
Thus, the rate of penetration of Generation III ● Early Generation II—5 percent penetration in 1983
data, transmitting bills or statements between ● Initial growth rates same as very high growth alterna-
computers, reading messages from a comput- tive
Slow Generation II EMS growth
er-based message system, or placing orders ● Peak volume (year 2000) about 25 percent of RCA pro-
against a supplier using an online catalog and jected year 2000 volume
● Generation II growth rates cut in half compared to
order entry system are not functional exten- moderate growth alternative—20 percent for Early
sions of a store and forward message system Generation II
like that which forms the basis for Generation —15 percent for Ad-
vanced Generation II
II. Both developer and user decisions for Gen-
eration III message systems are expected to SOURCE: Office of Technology Assessment (see flg 8, ch. 4, for graphic com-
parison of alternatives).
be quite independent of the status of Genera-
tion II.
Generation II EMS growth. When compared
Alternative Generation II to the 1977 estimates made by RCA for the
USPS with respect to EMSS,6 the baseline
Growth and Timing Estimates
alternative (high but plausible Generation II
The assumptions outlined above for the growth) would project a peak volume of about
growth and timing of Generation II EMS are 60 to 75 percent of the RCA peak of 25 billion
intentionally on the high side (i.e., optimistic messages. The very high growth alternative
in terms of rate and extent of development), would project a peak of 110 to 130 percent of
but still are plausible in terms of technical, the RCA peak, and the slow growth alterna-
economic, and market realities. Henceforth, tive about 25 percent of the RCA peak. The
this set of assumptions will be referred to as moderate growth alternative would project a
the baseline alternative for Generation II peak of 55 to 65 percent of the RCA peak, but
EMS development. would show a growth track substantially slow-
er than the baseline alternative but faster than
In order to test the sensitivity of the market the slow growth alternative. (See ch. 4, fig. 8,
penetration model and the projected mail vol- for a graphical comparison.)
umes to changes in the baseline Generation II
EMS assumptions, OTA has defined three
other alternatives, as presented in table 7: 1)
‘RCA Government Communications Systems Division, Elm
very high Generation II EMS growth, 2) mod- tronic Message Service System: Growth and Economic Anal-
erate Generation II EMS growth, and 3) slow yses, Camden, N. J., 1977, p. 6-13.
Ch. 3—Market Penetration Mode/ and Technology Assumptions ● 33
These alternatives are used in later chapters force requirements to assumptions about the
to test the sensitivity of the projected mail vol- growth and timing of Generation II EMS.
umes, first-class revenues and costs, and labor
34 ● Implications of Electronic Mail and Message Systems for the U.S. Postal Service
percent per year, the total mail volume would rate, all results of the computer modeling were
grow from about 93 billion pieces in 1977 to increased by 10 percent to make the projected
about 100 billion pieces in 1981. The actual and actual figures for 1981 consistent and to
USPS mail volume grew from about 92 billion remove the effects of the 1977-81 growth dis-
pieces in 1977 to an estimated 110 billion crepancy from future year projections. With-
pieces for fiscal year 1981.9 In order to com- out the 10-percent adjustment, future year
pensate for this higher-than-expected growth projections would have been penalized for this
‘Ibid.
discrepancy.
—
Chapter 4
Contents
Page
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
Base Case Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37
Sensitivity Analyses. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
Three-Percent Underlying Growth Rate . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
Other Sensitivity Runs. . . . . . . . . . . . . . . ...... . . . . . . . . . . . . . . . . . 42
Comparison of Alternative Generation II EMS Growth and
Timing Estimates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
TABLE
Table No. Page
9. Sensitivity Analyses. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44
FIGURES
Figure No. Page
3. Market Penetration for High But Plausible Generation II EMS
Growth Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
4. Breakdown of Mail by Class for High But Plausible Generation II
EMS Growth Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
5. Market Penetration for High But Plausible Generation HEMS
Growth Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
6. Breakdown of Mail by Class for High But Plausible Generation II
EMS Growth Alternative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41
7. Sensitivity Analyses of Market Penetration Projections Assuming
High But Plausible Generation II EMS Growth . . . . . . . . . . . . . . . . . . . 43
8. Generation II EMS Market Projections . . . . . . . . . . . . . . . . . . . . . . . . . . 47
Chapter 4
Introduction
This chapter presents the results of the mar- would be diverted to EFT and EMS and the
ket penetration analysis using the model and portion that would remain as conventional
technology assumptions described in chapter mail. OTA has assumed that, unless otherwise
3. The primary use of the model here is to indicated, the U.S. Postal Service (USPS)
estimate future levels of conventional and elec- would deliver the hardcopy output of EMS
tronic mail volumes under a variety of condi- services but not the electronic output. The por-
tions. tion of the mainstream diverted to EMS is fur-
ther divided into Generation II (defined as
To recap, the starting point for the model
EMS with hardcopy output and delivery) and
is the baseline mainstream, which is then
Generation III (defined as EMS with elec-
broken down into a number of different sub-
tronic delivery). The total remaining USPS
markets (classes or subclasses of mail). The
mainstream for any given set of assumptions
model estimates the maximum potential frac-
will then be the sum of all submarkets of un-
tion of each submarket which appears to be
divertable conventional mail (mail not suitable
suitable for handling by (i.e., diverted to) elec-
for electronic handling), plus residual conven-
tronic funds transfer (EFT) or electronic mail
tional mail (mail that is suitable for electronic
and message systems (EMS). Then, based on
handling but has not yet been diverted), plus
specific assumptions about the relevant tech-
Generation II EMS volume. As defined in this
nology, the model estimates the rate and tim-
study, Generation III EMS and EFT both in-
ing of penetration of EFT and/or EMS into
volve electronic delivery and therefore are
each submarket.
assumed to be completely outside of the USPS
For each submarket, the model is thus able mainstream.
to estimate the portion of the mainstream that
37
97-918 0 - 82 - 4
Figure 3.—Market Penetration for High But Plausible Generation II EMS Growth Alternative
(assuming 2°/0 growth in underlying mainstream)
.; mail (conventional -
“1 and Generation II EMS)
“,.
.,
.,1 .
‘ .; ~ USPS - delivered .’;- .IT ‘*. .if
,!* ~, , (conventional and ,:1
Generation II EMS) . . . ...115.77 118.21 106.20 88.52 ‘: ““%
EFT about 28 percent, and Generation II delivered mail would decline somewhat less–
EMS about 17 percent. By 2000, Generation by about 20 percent–due to the offsetting ef-
III EMS and EFT would still be increasing fect of increases in Generation II EMS
at a fairly rapid rate, while Generation II EMS volume. However, this Generation II EMS
would have peaked and started to decline. “cushion” would peak about 1995 and be on
the decline by 2000 in the face of competition
Overall, the picture that emerges is one from Generation III EMS.
where conventional mail volume would decline
by about 32 percent by 2000 compared to the The breakdown of USPS-delivered mail
1981 volume of 110 billion pieces. USPS- among the various classes of mail would also
Ch. 4—Market Penetration Results 39 ●
change significantly. As shown in figure 4, the year 1980 mail volume statistics. By 2000,
split in conventional mail between first class however, first-class conventional mail would
and all other classes would essentially reverse. account for only about 43 percent of total con-
In 1985, first-class conventional mail would ac- ventional mail, while the share for all other
count for about 61 percent of total conven- classes of mail would increase to 57 percent.
tional mail, and all other classes would account When Generation II EMS first-class mail is
for about 39 percent. This is essentially the taken into account, all first-class mail (conven-
same as the split indicated by actual fiscal tional plus Generation H EMS) declines some-
Figure 4.— Breakdown of Mail by Class for High But Plausible Generation II EMS Growth Alternative
(assuming 2°/0 growth in underlying mainstream)
70
60
50
40
30
Volume of mail
(in billions of pieces)
.
0 I t
1985 1990 1995 2000
Year
what less as a percentage of total USPS- (51/49) in 2000. Given the revenue/cost struc-
delivered mail. However, even including Gen- ture of USPS, this change could have signifi-
eration II EMS, the split between first class cant implications for USPS revenues, rates,
and all other classes of mail would change from and competitive posture, as will be discussed
61/39 in 1985 to essentially an even split later.
Sensitivity A n a l y s e s
Several computer runs were performed to ly. A 3-percent growth rate can be justified on
determine the- sensitivity of the base case the several grounds summarized earlier in
results to changes in key variables and/or table 10. Some researchers believe that a
assumptions. 3-percent rate should be defined as the baseline
rather than 2 percent. Figure 5 shows the
Three-Percent Underlying results of the market penetration analysis for
Growth Rate high but plausible Generation II EMS growth,
assuming a 3- rather than a 2-percent underly-
As discussed in chapter 3, the growth in ing growth rate in the mainstream. The dif-
USPS mail volume since World War II has ferences from the base case are significant.
averaged over 3 percent compounded annual- USPS-delivered mail would peak at about 134
Figure 5.—Market Penetration for High But Plausible Generation II EMS Growth Alternative
(assuming 30/’ growth in underlying millstream)
billion pieces in 1990 and decline to slightly below the estimated 1981 volume of 110 billion
more than 110 billion pieces in 2000. Thus, if pieces until 2000. Even the conventional mail
the underlying growth rate in the mainstream volume would not drop below 110 billion pieces
equals or exceeds 3 percent annually, USPS- until roughly 1994. The relative breakdown of
delivered mail volume would exceed 1981 mail by class would not be significantly dif-
levels at least through 2000. In other words, ferent for an underlying growth of 3 percent
with a 3-percent underlying growth rate, the as compared with 2 percent, but the volumes
USPS-delivered mail volume (conventional for all types of mail would be significantly
plus Generation II EMS) would not drop higher, as indicated in figure 6.
Figure 6.—Breakdown of Mail by Class for High But Plausible Generation II EMS Growth Alternative
(assuming 3°/0 growth in underlying mainstream)
80
70
60
c
u)
.o-
—
--
n
c 40
.-
. Volume of mail
(in billions of pieces)
Type of mail 1985 1990 1995 2000
Conventional first-class . . . . . . . . . . . 74.43 72.16 56.20 40.51
Conventional othera . . . . . . . . . . . . . . . 48.03 51.78 51.94 53.47
Generation II EMS first-class . . . . . . . 2.06 8.25 16.26 15.65
20 . b
Generation II EMS other . . . . . . . . 0.66 2.02 2.19 1.17
USPS - delivered totals
First-class. ... . . . . . . . . . . . . . . . . 76.49 80.41 72.46 56.16
Other classes ., . . . . . . . . . . . . . . ....48.69 53.80 54.13 54.64
a
Second, third, fourth classes, and mmcellaneous
bTh lrd class
10 .
0
1985 1990 1995 2000
Year
SOURCE: Office of Technology Assessment.
42 ● Implications of Electronic Mail and Message Systems for the U.S. Postal Service
——.. ———.-——
Figure 7.—Sensitivity Analyses of Market Penetration Projections Assuming High But Plausible
Generation II EMS Growth
130 —
Table 9.—Sensitivity Analyses would drop below the present level by 1990.
USPS-delivered mail volume would be reduced compared to
Generation II EMS volume would grow much
the baseline projections if: faster and sooner, and would outpace Genera-
● Growth in underlying mainstream were 1 percent—
tion III EMS at least through about 1995. By
Unlikely, except in event of economic depression.
● EFT growth rate doubled from 20 percent (in 1985) to 40 comparison, in both the base case and the
percent—Unlikely. 3-percent underlying growth case, Generation
● Generation Ill EMS were accelerated by 3 years from
III EMS would overtake Generation II EMS
1987 (for 5 percent penetration) to 1984—Unlikely.
● Significant reduction in USPS delivery of private sector as early as 1990. Overall, a 100-percent stim-
Generation II hardcopy output occurred—Unlike/y ulation of Generation II EMS traffic would
under current USPS interpretation of Private Express result in a higher projected USPS-delivered
Statutes (PES); however, FCC and some private firms
believe that hardcopy output falls within the jurisdic- mail volume than the base case, but not as
tion of the Communications Act, not the PES. high as the 3-percent underlying growth case.
● Significant diversion of second-/third-class mail to There is, however, a question as to whether
alternative delivery occurred—Possible; some diver-
sion known to be occurring, but second-class has re- the 100 percent EMS stimulation assumption
mained essentially constant over last 10 years and is realistic.
third-class has increased by 52 percent. USPS rate in-
creases may accelerate use of alternative delivery. Generation III EMS Three Years Sooner.—
USPS-delivered mail volume would be increased compared Generation III EMS involves end-to-end elec-
to the baseline if: tronic service; that is, electronic delivery of
● Growth in underlying mainstream were 4 percent—
Unlikely over the long-term, although short-term mail as well as electronic sending and trans-
growth spurts of 4 percent are possible. mission. Electronic delivery requires that both
● EFT growth rate were halved from 20 percent (in 1985)
to 10 percent— Possible due to marketing, competitive,
senders and receivers of mail have the neces-
and regulatory uncertainties. sary terminal equipment. In developing the
b Generation Ill EMS were delayed by 3 years from 1987
market penetration model, OTA made a num-
(for 5 percent penetration) to 1990–Possible due to
marketing and competitive uncertainties; however,
ber of assumptions about the growth of Gen-
sales of home computers, computer games, and small eration III. For example, OTA projected that
business computers look very strong.
● Stimulation
in 1987 home computer terminals (or their
of additional Generation II EMS volume
occurred—Possible given that other electronic tech- equivalent) would achieve a 5-percent share of
nologies (e.g., telephone, computer conferencing) have mail segments involving the household as
generated additional message volume; however, either sender or receiver. While this was
whether experience with all-electronic technologies
applies to hybrid forms (such as Generation II EMS) is OTA’s best estimate based on economic, mar-
unknown. ket, and technological conditions at the time
● Growth in underlying mainstream were 3 percent—
of the study, the timing and rate of home com-
Quite possible given the historical growth trends dur-
ing periods of relative economic prosperity. puter development is a subject of considerable
SOURCE: Office of Technology Assessment.
debate.
In order to test the sensitivity of the base-
results of the market penetration analysis for line market penetration results to Generation
high but plausible Generation II EMS growth, III, the model was run with all Generation III
assuming 100-percent stimulation of EMS timing estimates advanced by 3 years. That
traffic. This means that for each message is, 3 years were subtracted from all estimates
diverted from conventional mail to Generation of the year of 5-percent penetration for a par-
II EMS, a new Generation II EMS message ticular Generation III technology and market
is generated. segment. For example, the time to 5-percent
penetration for home computer terminal pen-
Under this assumption, USPS-delivered
etration of household-to-household corre-
mail would peak at about 127 billion pieces in
spondence was changed from 1987 to 1984.
1990 and decline to a little over 100 billion
pieces in 2000. USPS-delivered mail volume Under the base case, Generation II volume
would exceed present levels through about would be greater than Generation III volume
1998, although the conventional mail volume through about 1990. With 100-percent EMS
Ch. 4—Market Penetration Results ● 45
—— — —.
46 ● Implications of Electronic Mail and Message Systems for the U.S. Postal Service
——
EMS growth and timing parameters have sent a very high (i.e., optimistic) market
been held constant while other variables (e.g., development scenario, that they have ignored
EFT growth rate, Generation III 5-percent competition with Generation III EMS serv-
penetration date, underlying mainstream ices, or both. The size of the Generation II
growth rate) have been changed. In order to EMS market takes on considerable impor-
test the sensitivity of the projected mail tance with respect to the actual deployment
volumes to changes in the baseline Generation and pricing of any USPS EMS offering.
II EMS assumptions, computer runs were con-
ducted for each of the four Generation II EMS Based on the figure 8 results, it would ap-
alternatives defined in chapter 3 (table 7): pear that a conservative estimate (assuming
slow to moderate Generation II growth and
1. baseline alternative-high but plausible a 2-percent underlying mainstream growth)
Generation II EMS growth; would place the year 2000 Generation II EMS
2. very high Generation II EMS growth; volume in the range of 7 billion to 14 billion
3. moderate growth; and pieces, rather than the RCA estimate of 25
4. slow growth. billion. Likewise, a conservative estimate
The Generation II EMS market projections would place the 1995 volume in the range of
for these four alternatives are presented in 3 billion to 10 billion pieces, rather than the
figure 8. Results are shown for both 2- and 23 billion RCA estimate. If Generation II
3-percent underlying mainstream growth rates. EMS growth actually followed the slow
The market projections developed by RCA growth path, volume is projected to reach only
(under contract to USPS for the electronic 40 million pieces in 1985, equivalent to the
message service system concept, known as volume of Mailgrams for fiscal year 1980. On
EMSS) are also included in figure 8 for com- the other hand, if Generation II EMS grows
parison purposes. very rapidly, the projected volume would ex-
ceed the RCA estimates until the late 1990’s.
As expected, projected volumes for the high If a 3-percent underlying mainstream growth
but plausible Generation II growth alternative rate is assumed, the projected year 2000 vol-
fall in the middle when compared to the very ume of about 23 billion pieces for the high but
high, moderate, and slow alternatives. Some- plausible Generation II EMS alternative is es-
what surprisingly, however, volumes for the sentially the same as the RCA estimate.
high but plausible alternative are considerably
below the RCA projections. If this alternative In sum, the projected mail volumes are very
is indeed a high but plausible market develop- sensitive to the assumptions implicit in the
ment scenario, as assumed by OTA, then it four alternatives considered for Generation II
would appear that the RCA projections repre- EMS development.
Ch. 4—Market Penetration Results ● 47
/
/
Underlying
mainstream
Generation II EMS volume
(billions of pieces)
growth
Chapter 5
Revenue/Cost Model
and Results
Contents
Page
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51
USPS Revenue/Cost Model for First-Class Conventional Mail . . . . . . . . . . 51
USPS Revenue/Cost Model for First-Class Electronic Mail . . . . . . . . . . . . 52
Results of the Revenue/Cost Analysis for First-Class Mail. . . . . . . . . . . . . 53
FIGURES
Figure No. Page
9. Contribution of USPS-Delivered First-Class Mail to USPS
Fixed Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54
10. Contribution of USPS-Delivered First-Class Mail to USPS Fixed Costs
for High But Plausible Generation II Growth Alternative . . . . . . . . . . 55
Revenue/Cost Model and Results
Introduction
This chapter describes the revenue/cost structure proved to be too complex, and the
model used by OTA to project the impact of available baseline data too ambiguous, to
U.S. Postal Service (USPS) involvement in make complete projections. Instead, OTA has
electronic mail and message systems (EMS) focused on the financial impacts for first-class
on its finances and outlines the results of the mail which, according to the results of the
analysis. OTA originally intended to prepare market penetration analysis discussed in
projections of USPS revenues and costs for all chapter 4, will be affected most by EMS. The
classes of mail under the four alternatives con- revenue/cost model for conventional mail is
sidered for the years 1985, 1990, 1995, and described first, followed by the model for elec-
2000. However, the USPS revenue and cost tronic mail.
51
.
52 ● Implications of Electronic Mail and Message Systems for the U.S. Postal Service
—. —
the Postal Rate Commission (PRC). The in “constant dollars. ” Changes, too, are
primary fixed costs were estimated by expressed in so-called “real” revenues or
PRC to be $5.8 billion for USPS institu- “real” costs—net of changes due to infla-
tional costs (e.g., headquarters, postmas- tion.
ters, inspection service) and $1.8 billion ● Public Service Subsidy. For the purposes
for service-related fixed costs that could of this analysis, the postal public service
be assigned to various mail classes.’ subsidy level was held constant at the
● Revenue and Cost Per Piece. The 1980 $692 million level assumed by PRC in the
PRC rate case was also used as the basis 1980 rate case.3 At the present time, there
for determining revenue and variable cost are no proposals to increase the subsidy;
per piece. For first-class mail, the per in fact, the Omnibus Budget and Recon-
piece revenue and variable costs were 20¢ ciliation Act of 1981 has reduced the
and 13¢, respectively.2 The 20¢/piece rev- authority for such appropriations to zero
enue estimate assumed an 18¢ first-class by fiscal year 1984.
stamp. ● Productivity. In terms of costs, any over-
● Economies of Scale. OTA assumed that all productivity improvements with re-
USPS is still operating with economies of spect to conventional mail were assumed
scale, so that mail volume reductions to be offset by increases in the cost of cap-
would tend to increase the per piece cost ital and increases in real wages. Produc-
of the remaining mail. If mail volumes tivity gains due to the introduction of
reached or exceeded the optimal capacity EMS were considered as part of the rev-
of the system, then volume reductions enue/cost model for electronic mail.
might actually reduce rather than in- ● Use of the Model By using the 1980 esti-
crease the per piece cost. mates of per piece first-class mail cost and
● Inflation. Clearly, inflation will cause applying this to future projections of
postal costs to rise, and presumably rate USPS volumes for conventional first-class
increases will be necessary to keep up mail, future costs were calculated in 1980
with inflation (to the extent that increased dollars. Likewise, by using the 1980 esti-
costs are not offset by improved produc- mate of per piece first-class revenue and
tivity). For the purposes of this analysis, applying this to projected mail volumes,
future revenues and costs are expressed future revenues were calculated in 1980
dollars.
‘Postal Rate Commission, Opinion and Recommended Deci-
sion, docket No. R-80-1, p. 222.
‘Ibid., app. G, schedule 1, p. 1. ‘Ibid.
5¢/piece less than the mainstream cost of con- USPS delivery of Generation II first-class
ventional mail. The 5¢/piece cost displacement hardcopy output.
is also reasonably consistent with estimates For average revenue per piece of Generation
made by RCA for a USPS electronic system II EMS hardcopy output delivered, OTA as-
(specifically the electronic message service sys-
sumed that the “markup” of per piece revenue
tem (EMSS) concept).’ over the per piece cost for EMS must be the
For the electronic portion, OTA did not in- same as the markup for the corresponding
dependently verify either the RCA estimates classes of conventional mail. Analysis of the
for EMSS or the USPS estimates for electron- 1980 PRC rate case indicated that the average
ic computer-originated mail (E-COM). There- per piece revenue level for first-class mail was
fore, cost estimates were developed only for roughly 50 percent higher than the per piece
variable cost. This 1.50 factor was used to esti-
‘RCA Government Communications Systems Division,
EMSS System Analysis Task AB, VOL II, (%st and Service mate a 12¢/piece revenue for USPS delivery
Impact of System Decentralization, October 1977. of Generation II EMS hardcopy output.
97-918 f) - 82 - 5
54 ● Implications of Electronic Mail and Message Systems for the U.S. Postal Service
Figure 9.–Contribution of USPS-Delivered First-Class Mail (conventional plus Generation II EMS) to USPS
Fixed Costs (assuming 2°/0 underlying mainstream growth)
1
<
0
Ch. 5—Revenue/Cost Model and Results ● 55
Figure 10.—Contribution of USPS-Delivered First. Class Mail to USPS Fixed Costs for High But Plausible
Generation II Growth Alternative (assuming 1%, 2%, and 3% underlying mainstream growth)
s
1980 contribution
of first-class mail
to USPS fixed costs
—— —— _L —
s
II
,> j 1% 2% 3% 1% 2% 3%
. . ’ ” Conventional first-class with 20¢/piece revenue, 13¢/piece cost
Volume (billions of pieces) . . . . . . . . . . . . ....39.49 47.15 56.20 25.81 32.37 40.51
Revenue ($ billions) . . . . . . . . . . . . . . . . . . . . . . 7.90 9.43 11.24 5.16 6.47 8.10
Variable cost ($ billions) . . . . . . . . . . . . . . . . . . 5.13 6.13 7.31 3.36 4.21 5.27
Contribution to fixed costs ($ billions) . . . . . . . 2.77 3.30 3.93 1.80 2.26 2.83
>* “;
Generation II EMS first-class with 12¢/piece revenue, 8¢/piece cost
Volume . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11.42 13.64 14.78 9.98 12.51 15.65 “ ‘ ‘
Revenue. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.37 1.64 1.77 1.20 1.50 1.88
!. Variable cost. . . . . . . . . . . . . . . . . . . . . . . . . . . . 0.91 1.09 1.18 0.80 1.00 1.25
‘ . . . . Contribution . . . . . . . . . . . . . . . . . . . . . . . . . . . . 0.46 0.55 0.59 0.40 0.50 0.63
.
. ..-
. .’ Total first-class contribution to fixed costs. . . . . 3.23 3.85 4.52 2.20 2.76 3.46
. ,.F‘. k:”,. :“ : ‘ . .’ W’ ‘ ‘
SOURCE. Off Ice of Technology Assessment,
contribution would be $2.2 billion, a full $2 would appear to be quite significant consider-
billion below the 1980 level. ing that the total public appropriation (public
service subsidy plus revenue forgone) to USPS
How significant is a $0.75 billion, $1.25 bil- for fiscal year 1980 was about $1.6 billion. The
lion, or $1.50 billion reduction in first-class fiscal year 1980 revenue forgone appropriation
mail contribution to USPS fixed costs? It (to offset revenue losses from mail service pro-
56 ● lmplications of Electronic Mail and Message Systems for the U.S. Postal Service
tided at reduced rates, primarily nonprofit sec- contribution to fixed costs) from EMS than
ond-class mail, nonprofit bulk rate third-class from conventional mail.
mail, library materials, and free mail for the
Under the alternative revenue/cost assump-
blind and handicapped) alone was $0.782 bil-
tion tested by OTA, EMS first-class rates
lion. And the incremental cost of delivery 6
were assumed to be the same as conventional
days per week compared to 5 has been esti-
first-class mail rates. In this scenario, USPS
mated by USPS to be about $0.65 billion.
would, in effect, be pricing Generation II EMS
In other words, the projected reduction in first-class mail to contribute a higher percent-
first-class mail contribution in 2000 is roughly age (or markup) to fixed costs than would con-
equivalent, under the baseline assumptions, ventional mail. Thus, a revenue per piece of
to the combined 1980 public service and reve- 20@ was used for EMS instead of 12¢. As
nue forgone appropriation, or to the revenue shown in figure 9, when using the alternative
forgone appropriation plus the cost of Satur- revenue/cost assumption, the high, very high,
day delivery, or the equivalent. Under the or moderate growth alternatives would result
3-percent mainstream growth assumption, the in an additional first-class mail contribution
reduction in first-class mail contribution is of roughly $1 billion in 2000 (compared to the
roughly equivalent to the 1980 public service projected contribution under the baseline as-
subsidy, or the revenue forgone appropriation, sumptions). This level would still be a few hun-
or the cost of Saturday delivery. dred million dollars below the current first-
class mail contribution to fixed costs. Note
In general, as long as Generation II first
that the analysis also assumed no loss in EMS
class costs less per piece than conventional
volume due to the higher USPS rates. If EMS
first class but has the same markup of revenue
users were sensitive to the increase from 12
over cost per piece (50 percent), the first-class
to 20¢/piece (for USPS delivery of Generation
mail contribution to USPS fixed costs will de-
II hardcopy output), then the increased reve-
cline as Generation II volume increases (as-
nue from higher rates might be offset by re-
suming Generation II EMS costs USPS less
duced revenue from lower volume.
than conventional.) Thus, as indicated in figure
9, the first-class contribution is greater for the If 100-percent EMS stimulation is also as-
slow Generation II EMS growth alternative sumed (each Generation II message stimulates
than for the high or very high growth alterna- an additional new message), the first-class mail
tives. contribution to fixed costs in 2000 would be
The financial contribution of Generation II significantly higher than the 1980 contribu-
tion, by as much as $1 billion for the high and
EMS could be increased if the rate for USPS
moderate growth alternatives and $1.5 billion
delivery of EMS hardcopy output were the
for the very high growth alternative. These
same as the rate for conventional mail deliv-
projections are included in figure 9. This
ery. Up to this point in the analysis, OTA as-
scenario would enable USPS to use net rev-
sumed that all cost savings from EMS would
enues from Generation II EMS to help keep
be passed on directly to the EMS user (i.e.,
down overall rates for conventional mail, even
whoever is paying the postage). Thus, the rela-
in the face of the declining conventional mail
tionship between EMS first-class mail per
volumes projected for 2000. However, as noted
piece revenue and cost was assumed to be the
in chapter 5, the 100-percent EMS stimulation
same as for conventional first-class mail. In
assumption is considered speculative at this
other words, cost savings from EMS were re-
time.
flected in lower EMS rates rather than in lower
rates for other classes of mail or the mail- Under current USPS pricing policies, to the
stream as a whole. As a result, USPS could extent that private firms transmit Generation
not obtain any greater return (“markup” or II messages and present them to USPS for
Ch. 5—Revenue/Cost Model and Results ● 57
local delivery, these messages will be delivered veloping, and/or transmission) as well as
as first-class mail at the same rates as for con- physical processing and delivery, USPS would
ventional mail. Thus, the alternative revenue/ establish rates to cover the costs of electronic
cost assumption would apply, and the contri- services plus some markup over costs. This
bution to USPS fixed costs would be 12¢/piece would provide an additional contribution to
rather than 4¢. To the extent that USPS pro- fixed costs. OTA has not estimated or ana-
vides electronic services (e.g., printing, en- lyzed this contribution.
.
Chapter 6
Contents
Page
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61
Postal Rates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61
Service Levels . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63
Labor Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64
TABLES
Table No. Page
10. Projected First-Class Mail Rate Increases or Decreases,
Years 1995 and 2000 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62
11. USPS Service Levels, Fiscal Year 1980 . . . . . . . . . . . . . . . . . . . . . . . . . . 63
12. Structure of the USPS Labor Force, Fiscal Year 1980 . . . . . . . . . . . . . 65
13. Changes in USPS Labor Force Requirements for High But Plausible
Generation II EMS Growth Alternative, Year 2000, As a Function of
Underlying Mainstream Growth Rate and Labor productivity
Improvement per Year. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68
14. Projected USPS Year 2000 Labor Force Requirements by Employee
G r o u p , Assuming High But Plausible Generation II EMS Growth,
Z-Percent Underlying Mainstream Growth, and 1.5-Percent Labor
Productivity Improvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68
15. Projected USPS Year 2000 Labor Force Requirements by Employee
Group, Assuming High But Plausible Generation II EMS Growth,
Z-Percent Underlying Mainstream Growth, and 3-Percent Labor
Productivity Improvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69
16. Projected Year 2000 USPS Labor Force Reductions Assuming
2-Percent Underlying Mainstream Growth and 1.5-Percent Productivity
Improvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70
FIGURE
Figure No. Page
11. Sensitivity Analyses of Projected Changes in USPS Labor Force
Requirements for 1995 and 2000 Assuming High But Plausible
Generation II EMS Growth and 1.5-Percent Annual Labor
Productivity Improvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67
Chapter 6
Introduction
Postal rates, service levels, and labor re- fiscal year 1980 accounted for about 85 per-
quirements are integrally related. By law, the cent of total USPS costs.1 For the current level
U.S. Postal Service (USPS) is required to of service, about 60 percent of labor costs are
achieve break-even operations; that is, reve- fixed; that is, are required to maintain the
nues should equal costs as nearly as possible. service level regardless of variations in mail
Thus, postal rates are established at the levels volume. 2
needed to generate revenues sufficient to cover
projected costs over a given period of time (2 IAnnual Report of the Postmaster Genera~ fiscal 1980, p. 24.
to 3 years in a typical ratesetting cycle). The ‘USPS fiscal year 1980 Revenue and Cost Analysis; also see
Robert W. Anthony, et al., Strategy for Decisions: American
projected costs are based on assumptions Postal Workers Union and the Electronic Information R.evolu-
about USPS mail volumes and service levels. tioq The George Washington University Program of Policy Sci-
The major cost component is labor, which in ence and Technology, Washington, D. C., Mar. 1, 1980, pp. 55-56.
Postal Rates
While OTA was not able to do a revenue/ baseline high growth alternative, require a
cost analysis for all classes of mail, the results small rate increase to maintain the first-class
of the analysis for first-class mail suggest that mail contribution to USPS fixed costs, based
under the baseline high but plausible Genera- on the chapter 5 revenue/cost analysis (see
tion II electronic mail and message system figs. 9 and 10). By 2000, the required rate in-
(EMS) growth alternative, postal rates would crease could be more substantial, on the order
have to increase in constant dollars (net of in- of 18 percent. If the underlying mainstream
flation) after 1995, assuming service levels growth turned out to be 1 percent rather than
were not reduced. As shown earlier in figure 2 percent, a rate increase of more than 30 per-
4 (based on the market penetration analysis), cent might become necessary. On the other
the breakdown of mail by class for the high hand, for a 3-percent underlying mainstream
but plausible Generation II EMS growth alter- growth, the required rate increase in 2000
native indicates that through the early 1990’s would be about 7 percent. For illustrative pur-
the split between first-class mail and other poses, an 18-percent increase in first-class mail
classes would be roughly the same as in 1980. rates would translate roughly into an increase
Reductions in conventional first-class mail of 3.5¢/piece in the conventional first-class
would be largely offset by increases in Genera- mail rate and a 1.5¢/piece increase in the rate
tion II EMS hardcopy output delivered by for delivery of Generation II EMS first class.
USPS. These rate increases would recover the pro-
jected $1.5 billion shortfall in first-class mail
However, by 1995 the net reduction in total contribution to fixed costs in 2000 for the
USPS-delivered first-class mail would, for the baseline high growth alternative.
61
—.—— ——
62 ● Implications of Electronic Mail and Message Systems for the U.S. Postal Service
Projected rate increases (or decreases) under jected rate decreases are even larger for the
various assumptions are summarized in table alternative representing very high Generation
10. As shown, using the alternative/revenue II EMS growth. Even the slow growth alter-
cost assumption (where revenue/piece is the native would not require a rate increase in
same for conventional and Generation II hard- 2000.
copy fist-class delivery, as would be the case
In comments to OTA, the Department of
under current USPS pricing policies), a small
rate decrease is projected for 1995. If the Justice (DOJ) has expressed the view that
USPS could not successfully charge a different
100-percent EMS stimulation assumption also
rate for delivery of Generation II as compared
applied, for the high Generation II growth
to conventional first-class mail, either legally
alternative, rate decreases of about 16 and 9
under the Postal Reorganization Act’s rateset-
percent are projected for 1995 and 2000, re-
ting requirements or as a practical operational
spectively. Under these assumptions, the pro-
matter. Both the Postal Rate Commission and
Table 10.—Projected First-Class Mail Rate DOJ reviewers believe that OTA’s alternative
Increases or Decreases, Years 1995 and 2000 revenue/cost assumption is the most likely
rate basis, absent a change in USPS pricing
1995 2000 policies.
High but plausible Generation II EMS growth alternative
Underlying mainstream growth rate All of the foregoing projections assume
1 percent . . . . . . . . . . . . . . . . . . . . . . . + 10.50/0 + 31.40/0 other variables are held constant, including
Underlying mainstream growth rate
2 percent , . . . . . . . . . . . . . . . . . . . . . . + 3.2 + 18.1 volume. If first-class volume was sensitive to
Underlying mainstream growth rate rate increases, a volume reduction could result
3 percent ... , . . . . . . . . . . . . . . . . . . . – 2.5 + 7.4 which might in turn necessitate further rate
Assume alternative revenue/cost
figures. . . . . . . . . . . . . . . . . . . . . . . . . – 6.1 + 4.9 increases, and so on. A 20- to 30-percent in-
Assume alternative revenue/cost crease (net of inflation) in first-class rates could
figures and 100 percent EMS
stimulation . . . . . . . . . . . . . . . . . . . . . – 15.9
be enough to adversely affect the competitive
-9.2
position of first-class mail. If second- and
Very high Generation ii EMS growth alternative
Underlying mainstream growth rate third-class volumes declined significantly, per-
2 percent . . . . . . . . . . . . . . . . . . . . . . . + 6.2 + 20.4 haps due to competition from alternative de-
Assume alternative revenue/cost livery services, additional pressure on rates
figures. . . . . . . . . . . . . . . . . . . . . . . . . – 9.9 + 2.6
Assume alternative revenue/cost would be generated. Also, all of the rate pro-
figures and 100 percent EMS jections are in constant 1980 dollars and do
stimulation . . . . . . . . . . . . . . . . . . . . . – 23.7 – 14.3 not reflect increases due to inflation. And the
Moderate Generation ii EMS growth alternative revenue/cost analysis in chapter 5 assumed
Underlying mainstream growth rate
2 percent . . . . . . . . . . . . . . . . . . . . . . . + 2.0 + 18.1 that productivity improvements with respect
Assume alternative revenue/cost to conventional mail would offset increases in
figures. . . . . . . . . . . . . . . . . . . . . . . . . – 4.4 + 5.0 the cost of capital and real wages. Should the
Assume alternative revenue/cost
figures and 100 percent EMS real cost of capital or labor or both exceed the
stimulation . . . . . . . . . . . . . . . . . . . . . —1 1.8 – 9.1 inflation rate, further upward pressure on
Slow Generation ii EMS growth alternative postal rates would be experienced. In addition,
Underlying mainstream growth rate the revenue/cost analysis assumed significant
2 percent . . . . . . . . . . . . . . . . . . . . . . . + 0.3 + 14.6
Assume alternative revenue/cost cost displacement for USPS delivery of Gen-
figures. . . . . . . . . . . . . . . . . . . . . . . . . – 1.6 + 8.4 eration II EMS hardcopy output. If the cost
Assume alternative revenue/cost displacement turned out to be less, or if other
figures and 100 percent EMS
stimulation . . . . . . . . . . . . . . . . . . . . . – 4.3 + 0.1 kinds of USPS EMS services resulted in a net
( + ) = projected first-class mail rate increase
real cost increase, the rate projections could
( -) = projected first-class mail rate decrease
Unless otherwise indicated, 2-percent underlying mainstream growth rate is
be substantially different. Finally, the rev-
assumed. enue/cost analysis assumed that current
SOURCE: Office of Technology Assessment; based on data from figs. 9 and 10. USPS service levels would be maintained.
Ch. 6—implications for Postal Rates, Service Levels, and Labor Requirements ● 63
—
However, USPS could choose to reduce serv- increase rates in the face of declining USPS-
ice levels and labor requirements rather than delivered mail volume.
Service Levels
Based on projected mail volumes for the Table 11.— USPS Service Levels, Fiscal Year 1980
baseline high Generation II growth alter- Service criteria Level of service
native, it appears that USPS might have to
Days of delivery per week . . . . . . . . . 6
reduce current service levels significantly after Number of post offices . . . . . . . . . . . 30,326
1995 in order to avoid real rate increases. After Number of branches and stations . . 9,160
that time, the shortfall in the first-class mail Number of city delivery points . . . . . 68.5 million
Number of rural delivery points . . . . 14.7 million
contribution to USPS fixed costs could be- Overnight delivery of local area
come large enough to warrant consideration mail . . . . . . . . . . . . . . . . . . . . . . . . . 95 percent on time
.
of service cutbacks rather than rate increases, 2-day delivery of 600-mile radius
mail . . . . . . . . . . . . . . . . . . . . . . . . . 86 percent on time
particularly if rate increases would further 3-day delivery of cross-country
reduce USPS mail volume. On the other hand, mail . . . . . . . . . . . . . . . . . . . . . . . . . 87 percent on time
if the alternative revenue/cost assumption held SOURCE: Annua/ Report of the Postmaster Genera/, F/sea/ 1980, pp. 10, 11,
31.
up, and if Generation II EMS could contribute
significantly more per piece to USPS fixed
costs than could conventional mail, then major lated areas such as suburban or exurban resi-
real rate increases (net of inflation) or service dential developments.
cutbacks could be forestalled until past 2000. While OTA did not study USPS service lev-
This would also be the case if the underlying els in detail, there is some evidence to suggest
mainstream growth was 3 percent rather than that the mail system is nearing capacity. In
2 percent. other words, there may be limits to the volume
Present USPS service levels are summarized of conventional mail that can be handled
in table 11. Since the USPS commenced opera- without sacrificing quality of service. For ex-
tions on July 1, 1971, the number of days of ample, a USPS task force concluded that 5-day
delivery per week has remained the same. The delivery “would have a negative impact on
number of post offices, branches, and stations service, including overtime, inconsistent
has declined at a very slow rate. For example, delivery, delayed deliveries, equipment short-
over the last 5 years, the number of post of- ages, inadequate space to store accumulated
fices declined at a rate of 1.4 percent per year.3 mail, and inadequate vehicle capacity.”5 Also,
In contrast, the number of city delivery points since 1977 when total mail volume reached
has increased by about 21 percent since 1971, about 92 billion pieces, first-class mail delivery
and the number of rural delivery points by performance has declined for all but local area
about 50 percent.4 Since USPS is obligated by mail. Ontime (overnight) delivery for local area
law to provide mail service to all business and mail has remained quite stable at about 95 per-
residential addresses in the United States, the cent, but ontime delivery (2-day) for 600 mile
number of delivery points has expanded along radius mail has decreased from 90 to 86 per-
with growth in population and in populated cent since 1977. Ontime (3-day) delivery for
areas. USPS has instituted some measures, cross-country mail has dropped from about 91
such as the use of cluster mailboxes, to limit to 87 percent.6 The long-term performance
the increase of delivery points in newly popu- trends since 1973, the year when comparable
delivery data first were collected, indicate that On the other hand, Generation II EMS serv-
possibly USPS has reached its peak in terms ice could help to improve USPS performance.
of improvement in national delivery perform- To the extent that excessive mail delays now
ance with the current mail system.7 While per- occur in processing and sorting the large
formance is dropping off (for other than local volumes of conventional mail, Generation II
area first-class mail), delivery work hours are EMS could help to relieve these strains since
creeping up again after declining for many Generation II would bypass many of the proc-
years. More specifically, delivery work hours essing and sorting steps now required. Pre-
decreased by about 8 percent from 1970 to sumably, Generation II EMS would also speed
1978 while total USPS delivery points in- up delivery of mail sent outside the local area
creased by 20 percent during that period. But since electronic transmission would be much
since 1978, delivery work hours have increased faster than physical transport. A fully
by about 4 percent while delivery points rose deployed nationwide Generation II EMS serv-
by 6 or 7 percent.8 ice could reasonably be expected to provide
l-day delivery nationwide 95 percent of the
EMS have several implications for USPS
time. Cost savings associated with the reduced
●
Labor Requirements
USPS is a labor-intensive organization. As are primarily determined by three factors—
noted earlier, labor represents about 85 per- USPS service levels, labor productivity, and
cent of total USPS costs. Labor requirements mail volumes. By making assumptions about
—
Ch. 6—lmplications for Postal Rates, Service levels, and Labor Requirements ● 65
service levels and labor productivity, it is ages were reviewed with USPS and found to
possible to estimate the labor requirements for be reasonable.
projected future mail volumes. The overall cost split for the entire USPS
As a first step in the analysis, OTA esti- labor force was calculated to be 61 percent
mated variable and fixed percentages for each variable and 39 percent fixed. This fixed
major group of USPS employees. The results percentage is somewhat higher than the 36
are summarized in table 12, along with the percent fixed for total USPS costs used in the
total number of employees in each group as OTA revenue/cost analysis (ch. 5). The 36 per-
of fiscal year 1980. The variable percentage is cent reflects the lower fixed percentages of the
the labor component that varies directly with cost components for transportation (primari-
mail volume. The fixed percentage is the labor ly air, rail, and highway) and building occupan-
component that is necessary to maintain the cy (rents, fuel, and utilities). The 61/39 split
current service levels. The variable and fixed for labor is reasonably consistent with actual
percentages in table 12 were derived by OTA data on the relationship between USPS labor
directly from the USPS fiscal year 1980 Rev- work hours and mail volume changes collected
enue and Cost Analysis. The variable labor during 1979 and 1980.11
percentage is based on the direct and indirect As a next step, OTA calculated labor pro-
variable attributable cost from the USPS anal- ductivity index values at 5-year intervals from
ysis, expressed as a percentage of total ac- 1980 to 2000. An average productivity im-
crued costs. The fixed labor percentage is the provement of 1.5 percent per year was as-
sum of specific fixed attributable costs plus sumed as the baseline. USPS labor productivi-
all other institutional costs for each employee ty improved by roughly 3 percent annually
group. The variable and fixed labor percent- during the 1970’s, and a goal of 3 percent im-
provement per year has been announced. But
this does not appear to be realistic in view of
Table 12.—Structure of the USPS Labor Force, the fact that most productivity improvement
Fiscal Year 1980 from automation and mechanization has al-
ready been realized. Even the expanded ZIP
Employee group
a
Number of
employees
Variable
percentage
Fixed
percentage
code program, known as ZIP + 4, would
realize a cumulative labor productivity im-
Headquarters employees
Regional and other field
2,798 0 1000/0 provement of only 12
2.3 percent, according to
units . . . . . . . . 6,228 0 100 USPS estimates. For comparison purposes,
Inspection service ...
Postmasters. ... . .
5,242
28,967
0
190/o
100
81
labor force requirements were also calculated
Post office supervisors for 3.0- and O. O-percent productivity improve-
and technical
personnel . . . . . 36,481 52 48
ment per year.
Subtotal . . . . 79,716 Employee groups with 100 percent fixed
Post office clerks and
mail handlers . . . . . . . 303,560 86 14 costs would not vary with mail volume. A total
City delivery carriers and
vehicle drivers . . . . 193,730
of only 14,268 employees, or about 2.1 percent
50 50
Rural delivery carriers . . . . 53,069 27 73 of the total USPS labor force, fall into this
Special delivery
messengers . . . . . . . 2,502
category. Included here would be head-
39 61
Building and equipment quarters, regional, and inspection service
maintenance personnel
Vehicle maintenance
29,409 45 55 employees. This assumes that current service
facility personnel . 4,837 29 71 levels are maintained. If, for example, a signifi-
Total . . . . . . . . . . . . . . . . 666,823 61% 39% cant number of major post offices were closed,
then some portion of the costs for these em-
alncludes fu1l- and part-time employees.
bB=ti on Annual Report of the Postmaster General, Fiscal 1980, P. 31, and data ployee groups would become variable. In this
supplied by F. L. Ben Kinney, USPS Manager of Financial Planning.
cB~ed on USPS , Fyao Revenue and Cost Analysis, Cost Se9menfs and Com-
ponents Workpaperj pp. 742. 1lRobert W. Anthony, et al., op. cit., pp. 55-56,
SOURCE: Office of Technology Assessment.
12* Ch. 2, footnote ~.
—..
66 Implications of Electronic Mail and Message Systems for the U.S. Postal Service
case, the fixed percentage for postmasters quirement calculations are based. (See fig. 7
would be lower than the 81 percent shown in for the corresponding mail volume projec-
table 12. tions.) The projected labor force reduction
ranges from 2.7 to 22.8 percent in 1995, and
Costs for the 303,560 clerks and mail han- from 13.8 to 34.3 percent in 2000. The base
dlers (full- and part-time) would vary sig- case (assuming 2-percent underlying mail-
nificantly with conventional mail volume. The stream growth) falls roughly in the middle of
clerks and mail handlers represent the one the range, with a 12.2-percent labor force
employee group with very limited participa- reduction projected for 1995 and a 23.3-per-
tion in a Generation II EMS service. Genera- cent reduction projected for 2000.
tion II would bypass many of the traditional
mail sorting and processing functions per- For the base case, this translates into a
formed by clerks and handlers, but would still reduction of 81,352 employees by 1995 and
require physical delivery (whether by city or 155,370 employees by 2000. By comparison,
rural carriers). The cost split for the clerks and between 1971 and 1980 the USPS labor force
mail handlers is 86 percent variable/14 percent declined by roughly 65,000 employees. Thus,
fixed. Most other employee groups would vary the projected rate of reduction under the base
significantly with total USPS-delivered mail case (high but plausible Generation II EMS
volume (conventional plus Generation II growth, 2-percent underlying mailstream
EMS). This would include supervisory, main- growth, 1.5 percent per year labor productivi-
tenance, and technical personnel plus the city, ty improvement) over the next two decades
rural, and special delivery employees. A total would be higher than the rate of reduction ex-
of 320,028 employees, or about 48 percent of perienced during the last decade. However, as
the total USPS labor force, are in this cat- shown in figure 11, if the underlying mail-
egory. This includes part-time and casual em- stream growth is 3 percent rather than 2 per-
ployees who function in part to help the USPS cent, the labor force reduction in 2000 would
accommodate to fluctuations in mail volume, be 13.8 percent or 92,022–significantly less
for example, at peak holiday mailing periods. than the rate of reduction experienced in the
1970’s. On the other hand, if the underlying
The equation used by OTA to calculate labor mainstream growth rate turned out to be 1 per-
requirements, given the variable labor cost, cent or if USPS did not deliver industry Gen-
labor productivity, and projected mail volume, eration II hardcopy output, the labor force
is provided in appendix C. In order to simplify reduction would be about 30 percent, which
this analysis, clerks and mail handlers were translates into 200,000 employees.
assumed to vary with total USPS-delivered
mail volume, not just with conventional mail. Of course, if 3-percent-per-year labor pro-
This will tend to understate the projected ductivity improvement is assumed, the pro-
change in requirements for clerks and mail jected labor force reductions would be even
handlers and in the total USPS labor force. higher or, if zero labor productivity improve-
ment is assumed, labor force reductions would
Figure 11 presents the projected overall be lower. The sensitivity of labor force re-
USPS labor force changes for the years 1985, quirements to both labor productivity im-
1990, 1995, and 2000 under the baseline high provement and underlying mainstream growth
but plausible Generation II EMS growth alter- rate is illustrated in table 13 for the high
native, and assuming 1.5-percent annual labor Generation II growth alternative. As shown,
productivity improvement. The projected in- with 3-percent annual growth in the underly-
crease or decrease, expressed as a percentage ing mainstream and a zero-percent annual labor
change in the total USPS labor force, is shown productivity improvement, no reduction-and
for each of the various sensitivity assumptions indeed a small increase—in the labor force re-
used in chapter 4 to develop the USPS-de- quirement is projected for 2000. At the other
livered mail volumes on which the labor re- extreme, with l-percent underlying mail-
Ch. 6—Implications for Postal Rates, Service Levels, and Labor Requirements ● 67
Figure Il.–Sensitivity Analyses of Projected Changes in USPS Labor Force Requirements for 1995 and 2000
Assuming High But Plausible Generation II EMS Growth and
1.5-Percent Annual Labor Productivity Improvement
I 1 J
i 1990 1995
Year
68 Implications of Electronic Mail and Message Systems for the U.S. Postal Service
Table 13.—Changes in USPS Labor Force case modified to assume a 3-percent annual
Requirements for High But Plausible Generation II labor productivity improvement. Actually, as
EMS Growth Alternative, Year 2000, As a Function
of Underlying Mainstream Growth Rate and Labor
indicated in table 13, in terms of overall pro-
Productivity Improvement per Year jected labor force changes, the base case is
roughly the same as the 1-percent mailstream/
Labor productivity O-percent labor productivity and 3-percent
improvement per year
Underlying mainstream mainstream/3-percent labor combinations. The
growth rate per year 0% 1 .5% 3.0%
2-percent mainstream/3-percent labor produc-
3% . . . . . . . . . . . . . . . . . + 2.7% – 13.8% – 25.6%
2% . . . . . . . . . . . . . . . . . – 10,1 – 23.3 – 32.9
tivity is about the same as the 1-percent mail-
1 0/0 . . . . . . . . . . . . . . . . . – 20.4 – 30.9 – 38.6 stream/1.5-percent labor productivity combi-
NOTE. Changes In labor force requirement expressed as percentage In. nation.
crease ( + ) or decrease ( – ) from 1980 USPS labor force
SOURCE: Office of Technology Assessment As summarized in tables 14 and 15, the pro-
jected net reduction in the total USPS labor
stream growth and 3-percent productivity im- force for these two cases is about 158,000 and
provement, a very substantial 38.6-percent 223,000 employees, respectively, with a re-
reduction in labor force is projected in 2000. maining labor force in 2000 of roughly 506,568
However, only about half of this reduction and 452,813 employees.
would be due to declining mainstream volume,
The projected labor force reductions are not
with the other half due to labor productivity
spread evenly among all employee groups.
improvement.
Almost two-thirds of the reductions would be
Labor requirements could be calculated for from the post office clerks and mail handlers
every separate employee group under various group--99,900 and 141,000, respectively, for
assumptions in any future year specified. OTA the two cases shown in tables 14 and 15. This
estimated detailed labor force requirements in is because the work of clerks and mail handlers
2000 for the base case (high but plausible Gen- is more directly related to mail volume than
eration II EMS growth alternative, 2-percent any other employee group. In addition, USPS
underlying mainstream growth, 1.5-percent delivery of Generation II EMS probably
labor productivity growth) and for the base would not require many of the sorting and
Table 14.—Projected USPS Year 2000 Labor Force Requirements by Employee Group, Assuming High But
Plausible Generation II EMS Growth, 2-Percent Underlying Mainstream Growth, and 1.5-Percent Labor
Productivity Improvementa
Table 15.—Projected USPS Year 2000 Labor Force Requirements by Employee Group, Assuming High But
Plausible Generation II EMS Growth, 2-Percent Underlying Mainstream Growth, and 3-Percent Labor
Productivity Improvementa
processing functions now performed by clerks Up to this point, all the discussion and anal-
and mail handlers. A lesser but still significant ysis of projected labor force requirements has
percentage (almost one-quarter) of the total been in terms of the high but plausible Genera-
employee reductions would be in the city de- tion II EMS growth alternative. OTA con-
livery carrier group. ducted additional sensitivity runs to deter-
mine if the labor force changes would be
Overall, the clerks and mail handlers could
significantly different under very high, mod-
be reduced by about 33 to 46 percent of their
erate, and slow growth alternatives. The re-
1980 complement, respectively, for the two
sults are summarized in table 16. Basically,
cases in tables 14 and 15. Post office super-
the net reduction in the overall USPS labor
visors could be reduced by about 20 to 28 per-
force would not change unless the 100-percent
cent, and city delivery carriers by 19 to 27
EMS stimulation factor applies. That is, if
percent.
each Generation II EMS message stimulates
The projections in tables 14 and 15 do not a new Generation II message, then the overall
reflect any addition of employees for operation labor force reduction would be somewhat less
of USPS Generation II EMS facilities. RCA for all alternatives. The labor force reduction
estimated that 5,000 new USPS jobs would would then be smallest (–15.3 percent) for the
be created if a USPS Generation II EMS serv- very high Generation II growth alternative
ice were fully deployed. 13 OTA did not in- and largest ( – 20.4 percent) for the slow
dependently verify this estimate. However, it growth alternative.
seems clear that, qualitatively, any increase Whether or not these labor force reductions
in USPS employees for Generation II opera- could be handled through attrition depends
tions would be very small compared to the pro- largely on future USPS retirement, quit, and
jected employee reductions. new hire rates. In recent years, retirements
have averaged about 4 percent of the full-time
labor force and about two-thirds of all separa-
—. tions.” However, over the last 10 years, net
19The RCA study conducted for USPS estimated that 5,000 “U.S. Department of Labor, “The Labor Impact of Insti-
new USPS jobs would be created through full deployment of tuting Electronic Mail Systems in the United States Postal
the EMSS. See RCA, IWctronic Message Service System: Service” pp. 9-10, paper prepared for the 1979 Presidential)
Growth and Economic Analyses, 1977. Review Memo on USPS electronic mail policy.
97-918 0 - 82 - 6
. . ..
70 ● Implications of Electronic Mail and Message Systems for the U.S. Postal Service
Table 16.—Projected Year 2000 USPS Labor Force Reductions Assuming 2-Percent
Underlying Mainstream Growth and 1.5. Percent Productivity Improvement
USPS mail volume
in billions of pieces
Conventional Generation II Labor force
EMS alternative mail mail Total reduction
.- . -- . -- - .
High but plausible growth . . . . . . . 75.1 13.4 88.5 – 23.3 ”/0
Very high growth . . . . . . . . . . . . . . 69.9 18.6 88.5 – 23.3
Moderate growth . . . . . . . . . . . . . . 75.2 13.3 88.5 – 23.3
Slow growth . . . . . . . . . . . . . . . . . . 81.8 6.7 88.5 – 23.3
High but plausible growthb . . . . . . 75.1 26.9 102.0 – 17.5
Very high growthb, . . . . . . . . . . . . . 69.9 37.2 107.1 – 15.3
Moderate growthb . . . . . . . . . . . . . 75.2 26.7 101.9 – 17.5
Slow growthb. . . . . . . . . . . . . . . . . . 81.8 13.4 95.2 – 20.4
aExPressed as a percentage of 1980 employee levels
bAs~umes loo-percent” EMS stimulation.
separations (retirements plus quits minus new reaching retirement eligibility each year.15 In
hires) have averaged slightly under 1 percent. addition, the removal of mandatory age 70
This would be adequate to absorb the pro- retirement restrictions may encourage some
jected labor reductions for the baseline alter- employees to work longer, and the poor state
native (assuming 2-percent mainstream growth of the economy could discourage retirements
and 1.5-percent productivity improvement). and quits. Whether or not this poses a problem
But any significant drop in the retirement would depend on the actual retirement and
and/or quit rates would mean fewer new hires, quit rates in the late 1980’s and early 1990’s,
restricted promotion opportunities, and lim- the time when the need for significant labor
ited upward mobility. If the labor force reduc- force reductions (due to declining USPS-de-
tion was higher than the baseline, a further livered mail volume) is first likely to be felt.
cutback in new hires would be necessary. The
Finally, as noted earlier, the impact of labor
adjustment could be quite difficult for groups
force reductions would fall unevenly on the
that would be affected most, such as clerks
various employee groups. For example, the
and mail handlers. All of these conditions
mail handlers would be hit especially hard,
could adversely affect employee morale and
complicate future contract negotiations, and since to a substantial extent their current
deserve serious attention by USPS manage- skills would not be needed in processing elec-
ment and labor unions. tronic mail. This might be one employee group
where retraining opportunities for possible
There is some evidence to suggest that re- EMS jobs might be emphasized. Another re-
tirement rates may decline in future years. As lated concern is that, as of late 1978, the mail
of 1980, the age distribution of the USPS handlers as a group had one of the highest
workforce shows a bimodal distribution with percentages of black employment, more than
peaks at about age 58 and age 33. This means double the USPS-wide average. 16 Thus, the
that a peak has been passed in terms of the possibility exists that labor reductions might
numbers of employees reaching retirement fall disproportionately on black and perhaps
eligibility (age 55). Of course, many employees other minority employment. This possibility
wait until age 62 or 65 to retire. The age warrants further study.
distribution suggests that, for the next 17
years or so, decreasing although still signifi- “Ibid., p. 8.
cant numbers of USPS employees will be “Ibid., p. 11.
Chapter 7
Page
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 73
Telecommunication and Computer Industries . . . . . . . . . . . . . . . . . . . . . . . . 73
Fairness of USPS Role in EMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 73
Legality of USPS Role in EMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 76
Competition Between Generations II and III . . . . . . . . . . . . . . . . . . . . . . 77
Innovation and Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 78
EMS Privacy and Security . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79
USPS Long-Term Viability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81
Chapter 7
Introduction
Although the primary emphasis of this electronic mail and message systems (EMS)
study is on the U.S. Postal Service (USPS) on the telecommunication and computer in-
mailstream and on rates, service, and labor, dustries, EMS privacy, and the long-term via-
a discussion of the effects of a USPS role in bility of the Postal Service is included.
73
74 . Implications of Electronic Mail and Message Systems for the U.S. Postal Service
of total volume while UPS delivered 77 firms, and that any advantage from tax ex-
percent.2 empt status is more than offset by the costs
of service and regulatory requirements im-
Thus, the so-called “postal monopoly” pro- posed on it by the Postal Reorganization Act.4
vided to USPS under the PES is limited to Still, to the extent that private EMS firms are
only a few of the many classes of mail service profitable and pay income and other taxes,
offered by USPS. Available evidence suggests such taxes represent a cost not incurred by
that even among these protected services USPS. Some firms believe that nonprofit
USPS market power is eroding in the face of status offers USPS a price advantage over
competitive alternatives, both electronic and private competitors.
nonelectronic. 3 Nonetheless, the Department
of Justice (DOJ), among others, believes that On the subject of access to the U.S. Treas-
there is a significant chance that a USPS EMS ury for investment purposes, the Postal Reor-
offering (such as E-COM) could be subsidized ganization Act authorizes USPS to issue and
by revenues from the USPS monopoly on de- sell obligations not to exceed $10 billion out-
livery of first-class letter mail. standing at any one time. As of September 30,
1980, USPS long-term debt totaled about
If E-COM were priced artificially below $1.84 billion, consisting of $250 million in
what it costs, DOJ believes that E-COM Postal Service bonds and $1.59 billion in notes
might be used at the expense of both conven- payable to the Federal Financing Bank.5
tional first-class mailers and the taxpayers (to USPS observes that “private industry obtains
the extent that USPS continues to receive various forms of financial aid including loans
public funds appropriated by Congress). DOJ from the Treasury. Moreover, private firms do
also argues that underpricing of E-COM might not operate under the same statutory or prac-
discourage other firms from offering a similar tical limits on their borrowing authority as
service, thereby decreasing competition. In does the USPS.”6 In addition, the Secretary
general, the DOJ position is that the existing of the Treasury has the option not to pledge
regulatory structure and oversight process do the full faith and credit of the U.S. Govern-
not provide adequate safeguards against the ment for USPS bond issues if the Secretary
impacts of E-COM that could be anticompeti- determines that it would not be in the public
tive and discriminatory. interest, although the Secretary has never ex-
With respect to taxes, as an independent ercised this option. Clearly, USPS competitors
Federal Government agency USPS is not le- do not have comparable access to the U.S.
gally subject to Federal or State income taxes. Treasury for purposes of long-term borrowing,
Whether or not this is a real competitive ad- a factor that becomes even more significant
vantage is a matter of dispute. USPS argues when money is tight and interest rates are
that under the Postal Reorganization Act and high.
current ratesetting procedures it is effective- USPS also receives annual appropriations
ly prohibited from making a profit; thus, even from the U.S. Government as authorized by
if it were subject to income taxes USPS gener- the Postal Reorganization Act. In fiscal year
ally would pay none because it would have no 1980, the annual appropriations totaled $1.6
taxable net income. Also, while USPS does not billion, which included $828 million for public
pay property taxes on USPS-owned property, service costs and $782 million for revenue for-
some State and local property taxes are paid gone due to free and reduced rates for certain
indirectly when USPS is the lessee rather than mail services.7 Some USPS competitors have
the owner. Finally, USPS points out that it
does not benefit from tax advantages (such as ‘Sept. 18,1980, letter to OTA from Charles R. Braun, USPS
accelerated depreciation) available to private Assistant General Counsel, pp. 11-12.
‘Annual Report of the Postmasta General fiscal 1980, p. 21.
‘Ibid., p. 25. ‘Letter from Braun, op. cit., p. 11.
‘Ibid.
7
Annual Report of the Postmaster General fiscal 1980, p. 24.
Ch. 7—Telecommunication and Computer Industries, EMS Privacy and Security, and USPS Long-Term Viability ● 75
argued that this constitutes an unfair public cludes the requirement that “each class of mail
subsidy to the USPS. However, the revenue or type of mail service bear the direct and in-
forgone subsidy is intended to reimburse the direct postal costs attributable to that class
USPS for the revenue given up or “forgone” or type plus that portion of all other costs of
as a result of providing mail service free (for the Postal Service reasonably assignable to
the blind and handicapped) or at a reduced rate such class or type.”9
(e.g., for library materials, nonprofit bulk mail,
In addition, all USPS rate requests are sub-
and classroom publications), as required by the
ject to usually extensive and lengthy hearings
Postal Reorganization Act.
conducted by the Postal Rate Commission
Likewise, the public service subsidy is in- (PRC) at which all postal rates (for all classes
tended to reimburse USPS “for public service of mail and service) normally are considered.
costs incurred by it in providing a maximum Many USPS competitors and mail users par-
degree of effective and regular postal service ticipate in these hearings, along with USPS,
nationwide.”8 In any event, the public service PRC and the Officer of the Commission
subsidy was reduced from $828 million in fis- (charged with representing the interests of the
cal year 1980 to approximately $468 million general public), and occasionally other Govern-
in fiscal year 1981. * The fiscal year 1982 con- ment agencies (such as, in the E-COM proceed-
tinuing resolution provided a public service ap- ing, the Departments of Commerce and Jus-
propriation of about $221 million, and the Om- tice). Given the statutory requirements and
nibus Budget and Reconciliation Act of 1981 the adversary regulatory process in which all
reduced the public service authorization to interested parties are represented (and which
$100 million for fiscal year 1983 and $0 for fis- itself is subject to judicial review), postal
cal year 1984. The phasing out of the public cross-subsidies would seem to be rather dif-
service subsidy minimizes or eliminates any ficult to hide. Nonetheless, there is no absolute
competitive advantage this may have given guarantee against cross-subsidies since the al-
to USPS. DOJ and some private firms have location of indirect and institutional costs is
expressed concern that there is nothing to pre- always somewhat arbitrary (in any organiza-
vent a future administration and Congress tion), and the statutory criteria included in the
from reinstituting the subsidy, thereby pos- Postal Reorganization Act may not be neces-
sibly resulting in a significant USPS advan- sarily as applicable or appropriate now as they
tage over private industry in any competitive were when it was enacted in 1970. Some pri-
activity. vate firms are concerned that the rates initial-
ly set for E-COM service do not fully reflect
The USPS cost and ratesetting process is the actual costs, and that at the present time
admittedly complex, which has led some pri- there may be a hidden cross-subsidy of E-COM
vate firms to be concerned about possible hid- by other classes of mail. OTA has not inde-
den cross-subsidies. These firms are particular- pendently evaluated this concern. However,
ly concerned about cross-subsidies from con- the public record indicates that the PRC ap-
ventional mail services to EMS services; that proved the E-COM rate of 26¢ based on an es-
is, the use of revenues from conventional mail timated capital cost of $7.4 million and first
to subsidize EMS costs which would keep year volume of 12.5 million messages (240,000
down the rates for EMS services. OTA has not per week). In comparison, the actual capital
independently verified USPS costs and reve-
cost of E-COM is apparently close to $39 mil-
nues by class of mail. However, the Postal Re-
lion, with volume averaging about 25,000 mes-
organization Act generally prohibits cross-
sages per week for the first 6 months of 1982.
subsidization between classes of mail and in-
8
1 bid., p. 20.
*$1,25 b~on continuing appropriation ta USPS for fiscal year ’39 USC 3622(b)(3). Institutional costs are also apportioned
1981 less $782 million revenue forgone subsidy. by class or service based on statutory criteria.
.———.—
76 ● Implications of Electronic Mail and Message Systems for the U.S. Postal Service
Legality of USPS Role in EMS The PRC Recommended Decision was based
substantially on its finding that “the general
From a strictly legal perspective, some pri- obligation imposed on regulatory agencies to
vate firms have argued that a USPS role in consider and promote competitive policies ap-
EMS (other than delivery of hardcopy output) plies to this Commission." 12 The PRC decision
is beyond the mandate of the Postal Reorgani- was also based on the clearly procompetitive
zation Act of 1970, and is in direct conflict policy of FCC and the fact that the FCC as-
with Federal Communications Commission serted jurisdiction over the original USPS
(FCC) regulations promulgated pursuant to E-COM proposal, primarily on the grounds
the Communications Act of 1934 and with Of- that it included telecommunication transmis-
fice of Management and Budget regulations sion functions to be provided by a telecom-
concerning Federal Government procurement munication firm (Western Union), which was
of goods and services from and competition subject to FCC jurisdiction under the Commu-
with the private sector. nications Act of 1934.13 PRC concluded that
The Postal Reorganization Act mandates competition would be best served if USPS did
USPS to “provide prompt, reliable, and effi- not provide telecommunications. This also per-
cient service, “ “give the highest consideration mitted PRC to avoid both a possible regula-
to the requirement for the most expeditious tory impasse with FCC and any direct conces-
collection, transportation, and delivery of im- sion of FCC jurisdiction over postal services
portant letter mail,” and “emphasize the need per se.
for facilities and equipment designed to create USPS subsequently appealed the FCC rul-
. . . a maximum degree of convenience for effi- ing which asserted jurisdiction over E-COM.
cient postal services . . . and control of costs However, the appeal was dismissed and the
to the Postal Service.”10 Thus, USPS views its FCC ruling vacated as moot by the court in
use of electronic equipment and technology as view of the PRC Recommended Decision and
consistent with the Postal Act and as a sim- USPS cancellation of the Western Union con-
ple extension of its prior use of, for example, tract.* Thus, the court did not rule on the
automated sorting machines to carry outpost- merits, and the legal jurisdiction of FCC over
al policy as defined in the act. From this USPS involvement in EMS remains unclear.
perspective, EMS technology would be consid-
ered, along with the stagecoach, pony express, However, regulatory developments since the
railroad, truck, and airplane, as another step FCC ruling on E-COM suggest that so-called
in a long succession of new technologies used “enhanced services” such as electronic mail
to expedite the provision of postal services. No may not be subject to active FCC regulation
private firm or Government agency has suc- under title II of the Communications Act. In
cessfully challenged the USPS interpretation other words, as long as USPS does not own
on legal grounds. In its original Opinion and and operate its own telecommunication trans-
Recommended Decision, PRC supported the mission system and uses telecommunication
use of EMS technology by USPS although it services of firms who are regulated as pro-
differed with USPS in the application of that viders of so-called “basic services, ” the USPS
technology. More specifically, the PRC recom- EMS offerings would not necessarily be regu-
mended that USPS provide only the printing, lated by FCC.14 The applicable FCC decision,
enveloping, and hardcopy delivery functions known as Computer II, is still under
and not the telecommunication function.11 regulatory reconsideration and judicial chal-
lenge, and also may be affected by congres-
‘“Public Law 91-375, sec. IOl(a), (e), and (g). ]Z1bid., ~. 52 (caps and underlining removed).
“U.S. Postal Rate Commission, Opinion and Recommended “Ibid., pp. 36-51.
lkbion on Ekxtronic Mad Classification Proposal docket No. *SW rela~d discussion in ch. 3.
MC78-3, Dec. 17, 1979, pp. 278ff. 14Dec. 8, 1980, letter to USPS from Philip L. Verveer of FCC.
Ch. 7—Telecommunication and Computer Industries, EMS Privacy and Security, and USPS Long-Term Viability ● 77
sional revision of the Communications Act. As in the 97th Congress and the subject of exten-
noted in chapter 2, S. 898 as passed by the sive hearings by the House Government Oper-
Senate would limit FCC jurisdiction to USPS ations Subcommittee on Government Infor-
EMS services involving USPS leasing of tele- mation and Individual Rights,17 would appear
communications from private firms, and then to have the effect of prohibiting USPS from
only to establishing costs of the telecom- providing data-processing or telecommunica-
munication portion of the EMS service and to tion services to non-Federal entities or persons
assuring that such service is offered by a sep- unless explicitly authorized by statute.
arate organizational entity within USPS.
More recently, various computer service and Competition Between
data-processing firms, among others, have ex- Generations II and III
pressed concern that a USPS role in Genera-
Other implications for the telecommunica-
tions I or II EMS, let alone Generation III,
tion and computer industries are also difficult
could violate Federal Government policy (ex-
to assess. The market penetration projections
pressed, for example, in OMB Circulars A-76
suggest that by 2000, even with 100-percent
and A-121) that the Government should not
Generation II EMS stimulation, Generation
produce goods and services otherwise avail-
III EMS volume (end-to-end electronic mail in-
able from the private sector and should not
cluding electronic delivery) would exceed Gen-
compete with private firms, except as a last
eration II EMS volume. The sum of electronic
resort. USPS has procured the computer and
funds transfer (EFT) (a form of Generation III)
electronic equipment for E-COM from private
plus Generation III EMS would exceed Gener-
firms, but USPS operation of E-COM is con-
ation II EMS by the mid-1990’s. Under the
strued by some to constitute a computer-based
high but plausible Generation II EMS growth
electronic message processing service. 15 It is
alternative, as shown in figure 3, Generation
unclear whether or not this is any different
III EMS would surpass Generation II EMS
from USPS owning (through purchase from
by 1990, and EFT plus Generation III EMS
private manufacturers) and operating its own
would exceed Generation II EMS as early as
fleet of nearly 120,000 vehicles as it does
1985. However, Generation II EMS volume
now. 16
could still be substantial in 2000 and beyond,
At present, the use of computers and mes- even though the Generation II market share
sage processing in the E-COM service is inter- would be declining.
nal to USPS, and serves to convert the elec-
To some extent, perhaps until 1990, Genera-
tronic input to hardcopy output within a given
tion II EMS would compete with Generation
postal facility. As long as USPS is not in-
III EMS for relative but not absolute market
volved in telecommunication or electronic de-
share. In developing the market penetration
livery, there is no direct competition with pri-
model, OTA assumed that development of
vate Generation III EMS providers. However,
Generation III EMS and EFT would be large-
various Generations I and II electronic mail
ly independent of the USPS role in EMS (short
providers and computer service bureaus be-
of a role in electronic delivery or ownership and
lieve that USPS to some extent is competing
operation of telecommunications). * Prelimi-
with them. These firms have suggested several
nary review of the initial responses to the
alternatives (discussed in ch. 8) to establish
USPS invitation for telecommunication indus-
what would be, in their judgment, a coopera-
try participation in E-COM indicates that
tive rather than competitive relationship. As
mentioned in chapter 2, H.R. 4758, introduced “See statements of Philip M. Walker of GTE-Telenet and
William D. English of Satellite Business Systems before the
‘We Association of Data Processing Service Organizations, Oct. 5, 1981, hearings of the House Government Operations
position paper on “Government Provision of Electronic Mes- Subcommittee on Government Information and Individual
sage Services, ” Feb. 16, 1982. Rights.
‘“Annual Report of the Postmaster General fiscal 1980, p. 14. *See app. A.
78 ● Implications of Electronic Mail and Message Systems for the U.S. Postal Service
ly to impose inferior standards on the industry rate of private sector development, the
as long as current regulatory oversight and mainstream of technological innovation ap-
safeguards are maintained. pears to be beyond the scope of the USPS re-
search and development capability, present or
With respect to technology, the picture is
planned.
less clear. The selection of technology (e.g.,
computers and printers) for E-COM was made As for market innovation, USPS believes
by RCA under contract to USPS, not by that a Generation II offering like E-COM will
USPS itself. Some private firms have ques- help stimulate innovation by private firms. In-
tioned whether the best state-of-the-art tech- deed, as mentioned earlier, some of the smaller
nology was selected, particularly with respect firms that applied for dedicated access view
to the printing equipment. USPS believes that E-COM as an opportunity to get into the EMS
the initial E-COM technical configuration was market and compete with the larger, more
the best possible using off-the-shelf products well-established firms. But various telecom-
with proven reliability, and given the nature munication carriers and computer service
of the E-COM market. USPS also believes that bureaus have stated that their EMS service
it can stimulate innovation in some areas, such innovation will be stifled unless the relation-
as advanced high-volume printing and envel- ship with USPS is cooperative rather than
oping technology, where USPS is one of the competitive, and have proposed alternatives
largest users. However, given the relatively (discussed inch. 8) that they believe will en-
limited expertise of USPS in telecommunica- courage maximum innovation in the EMS
tion and computer technology, and the rapid market.
E M S P r i v a c y and Security
The subject of privacy with respect to EMS “sealed against inspection. ” Generally it does
includes two components of interest. One is not matter whether the mail is physically
the legal protection afforded such services, and sealed. The message contents of a postcard are
the other is the technical vulnerability of such legally or constructively sealed, as are the con-
systems to interception of information, and tents of letters opened in the dead letter of-
the willingness and ability of system providers fice to determine to whom they might be deliv-
to secure these systems against such intercep- ered. The effect of being “sealed against in-
tion. 21 spection” is to prohibit the mail from being
opened without a warrant, or any use or dis-
USPS is required by law to maintain “one
closure of information obtained in the course
or more classes of mail for the transmission
of opening a sealed letter without a warrant.
of letters sealed against inspection.”22 First-
The Supreme Court has held that mail which
class mail, priority mail, express mail, and in-
is sealed against inspection must be consid-
ternational letter mail are “sealed against in-
ered as though it had been retained in the
spection.
sender’s home. It cannot be opened without
The sender’s choice of the class of mail serv- the consent of the sender or addressee, except
ice determines whether the contents are under the authority of a search warrant issued
by a court upon probable cause. 23
“This section of the report is based in part on a 1980 USPS Access to addressor-addressee information,
memorandum regarding “Applicability of Mail Privacy Legal
Protections to Electronic Mail. ” For additional general discus- however, is possible without a warrant. Access
sion see chs. 7 and 8 of the OTA report C%mputer-Based i’Va-
tional Information Systems: Technology and Publik Policy
Issues, OTA-CIT-146, Washington, D. C., September 1981. 23Exp=& Jac~oa 96 U.S. 727, 732-733 (1877); uni~ s~~s
22
39 USC 3623(d), v. Van Jkeuwen, 397 U.S. 249, 251-252 (1970).
80 Implications of Electronic Mail and Message Systems for the U.S. Postal Service
The nature of an EMS service raises some ness, and financial information, the incentives
security concerns beyond those encountered to intercept such messages would increase.
in conventional mail delivery. Because mes- Some security experts have recommended
sages may be stored for some time (1 week in that USPS provide, in cooperation with tele-
the case of E-COM), there is the potential for communication carriers, an ‘‘electronically
access to an historical file of traffic. Also, EMS sealed” message service that offers protection
systems could easily produce extensive data (through encryption) at least equivalent to
on sender-addressee patterns. Finally, the that of conventional first-class mail.
hardcopy output of EMS systems maybe vul-
Electronic mail is also vulnerable to securi-
nerable to unauthorized inspection at the point
ty threats at the electronic switching and com-
of printing and/or enveloping. None of these
puter locations (including printing and en-
types of security intrusion can be performed
veloping functions). The security of conven-
as easily or as efficiently in the conventional
tional mail is protected by sealed envelopes,
mail system.
diligent monitoring of postal employee activ-
In these respects, electronic mail is more vul- ities, locked delivery and route mailboxes, and,
nerable than conventional mail. Any EMS al- as discussed earlier, a variety of postal stat-
ternative that involves telecommunications, utes that provide criminal sanctions for unlaw-
whether offered by USPS or by private firms, ful intrusion by postal employees or private
faces the threat of interception and monitor- parties. Additional new security measures will
ing of telephone, microwave, and/or satellite be necessary at switching and computer cen-
transmissions. While available data encryp- ters involved in providing electronic mail.25
tion technology can help to secure telecommu-
nication systems, most transmissions at pres-
ent are unencrypted and therefore intercep- “For further discussion of privacy and security, see chs. 4
and 5 of the OTA background paper on Selected Electronic
table. To the extent EMS services include Funds Transfer Issues: Privacy, Security, and Equity,
growing volumes of sensitive personal, busi- OTA-BP-CIT-12, March 1982.
III EMS activity and the continuing economic seem that, with orderly planning, enough of
trends that work in favor of electronic mail the basic USPS infrastructure could be main-
and against paper-based mail, especially for tained to provide adequate conventional mail
first-class letter mail. services, although at reduced service levels.
Also, new ways might be identified for USPS
For an important institution the size of
to carry out some of the elements of its statu-
USPS, 15 or 20 years is not an excessive lead tory mandate, such as to “provide prompt,
time for planning an orderly transition. It can reliable, and efficient service to (postal)
also be argued that changes are taking place patrons in all areas and to render postal serv-
so fast in the so-called “communications revo- ices to all communities,”28 and to “provide a
lution” that by the time USPS actually experi- maximum degree of effective and regular post-
enced significant mail diversion, it would be al services to rural areas, communities, and
much more difficult to adjust if steps are not small towns where post offices are not self-sus-
taken in advance to avoid a crisis situation. taining.” 29
For example, while normal attrition may be
able to accommodate any necessary labor force Generation II EMS might be able to help
reductions over the next 10 or 15 years, after USPS maintain adequate service levels to
that time necessary reductions may become rural and less populated areas that would be
rather severe, particularly for volume-sensitive unable to sustain cost-effective conventional
groups of employees such as mail handlers, mail service at present levels under reduced
clerks, and part-time employees. Maintaining mail volume. Indeed, in some rural and very
good employee morale and career continuity remote areas where even Generation II EMS
would be difficult at best under these circum- delivery might be cut back, USPS might con-
stances. sider contracting with Generation III EMS
providers to assure regular electronic delivery
As another example, significant mail diver-
to individual homes and offices or, at a min-
sion could undermine the ability of USPS to imum, perhaps to provide self-service elec-
carry out its primary mandate “to provide tronic hardcopy printers in post offices or
postal services to bind the Nation together other public locations. Of course, Generation
through the personal, educational, literary, III EMS providers may find it profitable to
and business correspondence of the people.” 26 provide such services on their own without
Reductions in USPS-delivered mail volume any USPS involvement. These possibilities
could generate severe financial pressures warrant further research.
which would force service and labor cutbacks.
This could translate, for instance, into reduc- Generation II EMS might also help USPS
tions in the number of days of delivery, num- maintain reduced rates for certain classes of
ber of collection points, or number of post of- mail, such as educational and nonprofit mail-
fices. Such cutbacks could seriously disadvan- ings, that have been partially subsidized by
tage some postal customers who may not have the annual revenue forgone appropriation from
access to satisfactory electronic alternatives, public funds. Even if the revenue forgone sub-
or whose mailing needs are not amenable to sidy is reduced, the cost advantages of Genera-
electronic transmission. tion II EMS over conventional mail might per-
mit the continuation of a lower rate to those
On the other hand, the projections in chap-s
many nonprofit and educational organizations
ter 4 indicate that USPS still is likely to have
that depend on the mail for their livelihood.
a significant though reduced volume of con-
ventional nonelectronic mail in 2000—perhaps is~ October 1981, pp. 11-16; and Robert W. Anthony, et al.,
70 billion to 75 billion pieces. 27 Thus, it would An Exploratory Amemment of timputer Asskted Makeup and
Imaging $w~ The George Washington University Program
‘“Public Law 91-375, sec. IOl(a). of Policy Studies in Science and Techology, Washington, D. C.,
~~~ver~ studie9 have concluded that a significant volume Jan. 31, 1980.
of paper-based mail will continue almost indefinitely. See Henry tafiblic Law 91-375, %. lol(a).
B. Freedman, “Paper’s Role in an Electronic World,” The fitur “public Law 91-375, Sec. IOl(b).
Ch. 7—Telecommunication and Computer Industries, EMS Privacy and Security, and USPS Long-Term Viability ● 83
It also seems likely that Generation II EMS USPS infrastructure and delivery network,
service could help to meet the needs of small could be used to provide other Federal Govern-
mailers of all kinds, even though the service ment services. For example, with proper inter-
may be of greatest absolute economic benefit connection and technical enhancements, a
to large mailers. For example, as of February Generation II system might be used by USPS
1982, over 90 business mailers had applied to to provide printing and delivery of various
USPS for technical certification to use E-COM Government forms and documents. 31 This kind
service, including such high volume mailers as of role would, of course, compete to some ex-
Shell Oil Co., Equitable Life Assurance Co., tent with functions now carried out by the
and Merrill Lynch Pierce Fenner & Smith. Government Printing Office, the National
However, at least three of the telecommunica- Technical Information Service, and other Fed-
tion carriers that have applied for dedicated eral agencies, but might prove to be more cost
access (ITT World Communications, TRT effective in the long run. This role might even
Communications Corp., and Netword, Inc.) in- be extended to include provision of abstracts
tend to offer batch mailings from low-volume of and indexes to Government forms, docu-
mailers to meet the 200-message minimum ments, and other kinds of Government infor-
volume requirement for E-COM use. A spokes- mation. These possibilities, too, deserve fur-
man for ITT World Communications has indi- ther study.
cated that “ITT would allow customers to
mail as few as 25 letters per mailing” and then
‘] See Robert W. Anthony, Lynne Filderman, Henry Freed-
consolidate orders to meet E-COM volume re- man, and Henry H. Hitchcock, Strategy for Decisions: APWU
quirements. 30 and the Electronic Information Revolution, The George
Washington University Program of Policy Studies in Science
In the longer term, it is possible that a and Technology, Washington, D. C., Mar. 1, 1980; and Alfred
USPS Generation II EMS capability, perhaps M. Lee and Arnim H. Meyburg, The Impact of Electronic
Message Zhnsferon USPS Operations, Working Paper No. 3,
combined with a scaled-down version of the Cornell University Program on Science, Technology, and Socie-
ty, September 1980. Also see “Electronic Computer Orginated
‘OSelz, “Electronic Mail, ” op. cit. Mail, ” Technology Watch vol. 2, No. 2, December 1981, p. 2.
—. —
Chapter 8
Congressional
Policy Considerations
Contents
Page
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87
Provide a Clear Direction for USPS Involvement in EMS . . . . . . . . . . . . . 89
Impact on USPS-Delivered Mail Volume . . . . . . . . . . . . . . . . . . . . . . . . . . 90
Impact on USPS Finances. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 90
Impact on USPS Labor Force . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 90
Space in SPOs for Carrier Output Equipment . . . . . . . . . . . . . . . . . . . . . . 90
Electronic Transmission to SPOs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91
Electronic Delivery to Recipient . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91
Interconnection and Standard Interface . . . . . . . . . . . . . . . . . . . . . . . . . . . 92
Transmission Facilities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 92
Marketing of EMS Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 92
Performance Standards for EMS Services . . . . . . . . . . . . . . . . . . . . . . . . . 93
Reduce or Eliminate Further Regulatory and Judicial Delay . . . . . . . . . . . 93
Applicability of Private Express Statutes . . . . . . . . . . . . . . . . . . . . . . . . . 93
Regulatory Jurisdiction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 94
USPS Subdivision for EMS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 95
Privacy Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 96
Maintain Oversight and Initiate Planning on USPS Long-Term Viability 97
Chapter 8
Introduction
Congressional authority over the role of the the 1934 Communications Act to bring it in
U.S. Postal Service (USPS) in electronic mail line with current technological, economic, and
and message systems (EMS) derives in the competitive realities. During the last decade
first instance from the U.S. Constitution and a half, there has also been a concerted ef-
which vests in Congress the power to establish fort by Congress, exemplified by the 1967
post offices and post roads (sec. 8, clause 7) “Brooks Act” amendment to the Federal
and to regulate commerce among the several Property and Administrative Services Act and
States (sec. 8, clause 3). the Paperwork Reduction Act of 1980, to im-
prove the Federal Government’s management
USPS operates as an independent Federal
and procurement of data-processing and re-
agency pursuant to the Postal Reorganization
lated telecommunication equipment and serv-
Act enacted by Congress in 1970. It is sub-
ices, and to rely on the private sector for pro-
ject to policy direction by the USPS Board of
vision of such equipment and services on a
Governors and to regulatory review of mail
competitive basis wherever possible.
rates and classifications by the Postal Rate
Commission (PRC), both established by the In essence, technological advances have
Postal Act. Private EMS firms operate pur- reached the point where these three original-
suant to the Communications Act of 1934 and ly independent congressional policy directions
regulations promulgated by the Federal Com- are increasingly in conflict. USPS stands near
munications Commission (FCC) under authori- the center of this conflict. Privately offered
ty granted by the Communications Act. EMS services can and ultimately will compete
Historically, technology has been used to with and divert a significant portion of the
improve and speed up the processing, trans- USPS conventional mainstream, based on the
portation, and delivery of mail. Thus, the market penetration analysis in chapters 3 and
railroad, plane, truck, and automated sorting 4. Absent any USPS participation, this pros-
machine have been integrated into postal op- pect would likely lead to significant rate in-
erations. The Postal Act reiterates and creases and/or service and labor force reduc-
strengthens the mandate to use new facilities tions by the year 2000. It seems clear that
and equipment to improve the convenience, ef- USPS can benefit from participation in pro-
ficiency, and cost effectiveness of mail service. viding EMS services, and indeed it can be
Electronic message technology is viewed from argued (see ch. 7) that USPS has the statutory
this perspective as one more step in an evolu- authority to participate as long as the final
tionary process of keeping the “post offices output is in hardcopy letter form delivered
and post roads” up to date and competitive. over postal roads. But even a minimal USPS
role—delivery of EMS hardcopy output—is of
Over the last three decades, there has been concern to some private firms if such delivery
a continuing revolution in computer and com- is considered subject to the Private Express
munication technology, a gradual deregulation Statutes (PES). These firms believe that de-
of the telecommunication industry (the com- livery of hardcopy output is ancillary to com-
puter industry being essentially unregulated), munication services subject to the Communi-
and a proliferation of new and old firms offer- cations Act as well as the Postal Act.
ing or planning to offer EMS services. Con-
gress has generally encouraged this deregula- A larger USPS role that involves message
tory process, and continues to work to revise processing and computer-based printing and
87
88 ● Implications of Electronic Mail and Message Systems for the U.S. Postal Service
enveloping, as well as hardcopy delivery, ap- on a major role for USPS, but they disagree
parently troubles portions of the computer in- with USPS on what that role should be. Vari-
dustry (particularly computer service bureaus) ous mailer organizations, consumer groups,
because of concern over potential competition and postal labor unions see a USPS role in
from USPS and the belief that the industry EMS as essential to USPS long-term viabili-
is willing and able to provide such services. ty and to maintaining, or at least minimizing
Should the USPS role extend to the telecom- any reductions in, mail services that are vital
munication portions of an EMS service, then to a large part of the U.S. population. They
many telecommunication carriers would view point to the critical role of USPS in providing
USPS as a direct competitor. Even with re- a universal, low-cost, nondiscriminatory na-
spect to E-COM, where the USPS role does not tionwide communication service that is stat-
include telecommunication, some carriers are utorily mandated by Congress.
concerned that it was designed to accom- Based on interviews with many of the stake-
modate future functions (e.g., magnetic com- holders and USPS, as well as a comprehensive
puter tape input) that are not presently au- review of the historical record, OTA has con-
thorized. These carriers believe that any USPS cluded that, absent congressional action, the
involvement in telecommunication, whether
controversy over the USPS role in EMS is like-
directly or by resale, would be subject to the ly to continue. Although the U.S. District
jurisdiction of the Communications as well as Court of Appeals has denied a Justice petition
the Postal Act, and would constitute the en-
to block E-COM, further regulatory proceed-
try of a Federal agency into competition with ings are anticipated and additional legal ac-
private industry. The computer service bu- tions are possible. With continuing uncertain-
reaus apparently feel the same way with
ty over the future of E-COM, and in general
respect to USPS provision of message proc-
of the USPS role in EMS, the prospects for
essing. a successful USPS entry into domestic EMS
Reaching a consensus on a role for USPS in services are uncertain. Some firms have in-
EMS has been further complicated by jurisdic- dicated to OTA that they are reluctant to
tional conflicts between PRC and FCC, PRC make any major commitments until they are
and USPS Board of Governors, FCC and certain what role USPS is going to have.
USPS, and the Departments of Commerce and Meanwhile, many of the carriers continue to
Justice and USPS. These conflicts have come put much of their research and development
to a head over E-COM, resulting in legal ac- effort into Generation III EMS, which would
tions brought in Federal court by USPS completely bypass USPS. In addition, USPS
against FCC and PRC, and by Justice against is unable to establish effective working rela-
USPS. Various parties, especially telecom- tionships with many private carriers and po-
munication value-added carriers, have filed tential Generation II EMS users, given the
briefs in these judicial proceedings, and before continuing adversarial atmosphere.
FCC and PRC in regulatory proceedings on
Should Congress wish to take action, there
E-COM, raising substantive issues of rateset-
are several major possibilities. Congress could:
ting, potential cross-subsidization, and pri- 1) provide a clear direction for USPS involve-
vacy, among others. ment in EMS; 2) reduce or eliminate further
On the other hand, many of the private tele- regulatory and judicial delay; and 3) maintain
communication and computer firms who have oversight and initiate planning on long-term
been adversaries of USPS also believe that full USPS viability. These possibilities are dis-
development of Generation II EMS depends cussed below.
Ch. 8—Congressional Policy Considerations ● 89
believe that USPS is not receptive to such pro- authority of USPS to contract with a telecom-
posals, and question why Western Union munication carrier to transmit messages elec-
should receive special accommodation. It is tronically on behalf of USPS.2 However, PRC
not clear whether physical constraints and conditioned this authority on a showing of
economies of scale would permit the location demonstrated need, a term that has not been
of equipment from a large number of carriers, clearly defined but presumably implies a situa-
or that a large number of carriers would find tion where the needs of E-COM users could not
such an arrangement to be cost effective. This be met adequately through the telecommuni-
question deserves further study. cation services of private carriers. The Gover-
nors have accepted this condition.3 However,
In E-COM, USPS does not provide space in
some carriers are concerned that the ambigui-
SPOs for carrier hardcopy output devices. In-
ty of this condition could be used in the future
stead, USPS owns and operates its own print-
to, in their opinion, improperly and unjusti-
ing equipment and provides access facilities
fiably permit USPS to contract with a carrier
to enable carriers to interconnect directly with
(or carriers) to provide electronic transmission
SPOs. USPS has purchased the interconnec-
on behalf of USPS. Congress may wish to clar-
tion equipment and leases it to carriers desir-
ify the definition of demonstrated need.
ing dedicated access at a monthly charge.1
Some carriers are not happy with the relative-
ly limited capabilities of the E-COM equip- Electronic Delivery
ment. According to USPS, the selection of E- to Recipient
COM equipment was made by RCA, and was
USPS has not proposed, nor have the Gover-
judged to be the best technology available off nors or PRC considered, any EMS service
the shelf that met USPS requirements. Con-
whereby USPS would provide electronic de-
gress could request an independent review of
livery of mail directly to the recipient. USPS
the technology selected.
has stated repeatedly that it “will not provide
‘Generation III’ services which transmit mes-
Electronic Transmission sages all the way through telecommunica-
to SPOs tions.” 4 However, some consumer advocates
and researchers have suggested that electronic
The role of USPS in the telecommunication
delivery might be justified to maintain USPS
portion of EMS has proven to be controver-
service levels in geographic areas where con-
sial. USPS originally proposed to initiate its
ventional mail service could no longer be main-
E-COM service using a telecommunication
tained at present levels. Congress may wish
network leased from Western Union. That is,
to examine what, if any, conditions would con-
USPS would have provided telecommunica- stitute a demonstrated need for USPS involve-
tion as well as printing, enveloping, and
ment in electronic delivery (presumably by
delivery. In December 1979, PRC recom-
contract with private Generation III EMS
mended an alternative plan under which USPS
firms). Any USPS role in Generation III would
would not own or operate a telecommunication
have to be carefully defined to avoid either the
network, but all telecommunication carriers
appearance or reality of competition with
would be permitted to interconnect with
private firms and the substantial controver-
E-COM at the designated SPOs. In April
sy and opposition that would likely generate.
1980, on remand from the USPS Board of
Governors, the PRC explicitly recognized the
‘The monthly charge per SPO ranges from $102 to $412, de- ‘Further Recommended Decision, docket No. MC78-3, Postal
pending on the type of equipment. See “Telecommunication Rate Commission, Apr. 8, 1980.
Connection Arrangements for Postal Service Electronic Com- ‘I bid., pp. 4-9; Decision of the United States Postal Service
puter Originated Mail (E-COM) Service and Innovation for Board
4
of Governors, docket No. MC78-3, Feb. 22, 1980,
Capacity Planning Cooperation, ” Federal Register, vol. 46, No. Mar. 12, 1981, letter and position paper from Edward E.
199, Oct. 15, 1981, p. 50882. Horgan, Jr., of USPS to Sen. Barry Goldwater.
92 ● Implications of Electronic Mail and Message Systems for the U.S. Postal Service
The current E-COM service is designed to In 1978, USPS projected a volume of 230
achieve guaranteed 2-day delivery. Since 2-day million E-COM messages 5 years out. A more
delivery is already guaranteed for conven- recent Opinion Research Corp. survey commis-
tional mail deposited within 600 miles of sioned by USPS projected a market of 500
destination, the time advantage of E-COM is million messages per year now and 1 billion
primarily for cross-country mail where normal messages per year 5 years out. This latter pro-
delivery is 3 days. Of course, mailers may jection falls somewhere between the moderate
realize benefits other than time; for example, and high OTA projections.
reduced printing and enveloping or computer
Because of the uncertainty of such projec-
processing costs. Still, some carriers and
tions, an incremental approach to expansion
mailers have argued that l-day delivery, as is
appears to be warranted. For example, E-COM
available with Mailgram, would be preferable.
(or some other alternative) could be expanded
According to USPS, E-COM could achieve in a small number of selected origin-destina-
1-day guaranteed delivery if the number of tion pairs (e.g., Washington, D. C.-San Fran-
SPOs equipped with E-COM facilities were ex- cisco, New York-Los Angeles) to test the
panded from the current 25 to about 150. The feasibility of and market for l-day guaranteed
total capital cost is estimated at about $250 delivery. An incremental approach would ap-
million (roughly six times the current cost of pear to require more flexibility in the USPS
E-COM system design and implementation), decisionmaking process (including regulatory
a substantial investment but considerably less review) than is presently the case. Congress
than the $1.5 billion to $2.0 billion originally may wish to consider some changes in the
estimated by RCA for a nationwide electronic Postal Reorganization Act to provide more
mail service system (EMSS). However, it is flexibility.
a matterof hours. Many electronic mail serv- before delivery are letters,” 15 and thus are sub-
ices might qualify under this exception. ject to PES.
USPS regulations define a “letter” as a Nonetheless, some private firms question
“message in writing” addressed to a “par- not only the applicability of PES to Genera-
ticular person,” and include electronically tion II hardcopy delivery, but are also con-
transmitted messages when in hardcopy form cerned that USPS may attempt to extend PES
and delivered over postal routes. 10 F C C , to Generation III EMS. Congressional clari-
among others, has claimed that PES do not fication may be needed.
extend to physical delivery of hardcopy out-
put from electronic communications, on the Regulatory Jurisdiction
grounds that such delivery is incidental to
electronic communications as defined in the Over the last 3 years, the question of which
Communications Act of 1934 and therefore is regulatory bodies have what jurisdiction over
not subject to PES.11 In addition, FCC has various USPS proposals for offering EMS
challenged a USPS proposal to redefine a pre- service has been considered extensively in
viously granted exemption for telegrams. regulatory proceedings. In two court actions,
USPS had proposed to limit the exemptions USPS has challenged the extent of appropri-
to telegrams “as commonly sent in the past ate jurisdiction as asserted by both PRC and
by other members of the public.” Other forms FCC.
of hardcopy output from electronic communi- By declaratory ruling, FCC asserted authori-
cations would not be exempt.12 Although this ty under section 2(a) of the Communications
proposal was subsequently withdrawn, USPS Act of 193416 to regulate parts of the original
has taken the general position that its long- USPS plan for E-COM. This plan called for
standing exemption for telegrams does not USPS to contract for transmission and other
apply to other types of hardcopy output from services on a sole source basis with a single
electronic transmission. common carrier (Western Union) .17 FCC ap-
Some private firms dispute the USPS posi- parently based its assertion on the grounds
tion, but to date no party has successfully that Western Union was already subject to
challenged the legality and applicability of FCC regulation, and furthermore, to the ex-
PES to the delivery of hardcopy output as de- tent that USPS offered electronic communica-
fined by USPS regulations. On the other hand, tion services, it was a “person” within the
PES do not apply to end-to-end electronic com- meaning of the Communications Act and was
munication of messages, according to recent therefore itself subject to FCC jurisdiction. 18
statements by USPS officials and USPS in- USPS petitioned the U.S. Court of Appeals for
terpretation of PES. “The PES will remain ap- the District of Columbia for a review of the
plicable only to ‘hardcopy’ letters.”13 “Mes- FCC action arguing that, under the Postal Re-
sages transmitted by wire or wireless or elec- organization Act of 1970, PRC is the ap-
tronically between sender and addressee are propriate regulatory body and further that
not letters since the PES apply only to cor- USPS is not a “person” subject to the jurisdic-
poreal messages physically carried on post tion of FCC. On October 14, 1980, the court
routes." 14 However, as discussed earlier, dismissed the USPS appeal and vacated the
“messages so transmitted which are converted FCC ruling as moot for two reasons: 1) “the
to physical form and carried over a post road contract between Western Union and the
151bid.
1039 CCFOR. 152 (197o) and USPS order 71-10” 1047 U.S.C. $152(a).
IIMm. 12, 1979, letter to Louis A. Cox, USPS Gener~ l~post~ Rate commission, docket No. MC78-3.
Counsel, from Robert R. Bruce, FCC General Counsel, pp. 2-3. lsFeder~ communications Commission Common Ctl.ITier
12 F~. R,ego 60,616 (1978); 45 Fed. Wg. 59,871 (1980)”
43
Postal Service . . . that was objectionable to Absent clear direction from Congress, it
the FCC has been cancelled, and 2) PRC itself seems likely that USPS entry into EMS will
rejected several features of the Postal Service precipitate continued regulatory (and related
electronic mail system proposal found objec- judicial) conflicts. Congress, through legisla-
tionable by the FCC.” 19 Thus, the court did not tion or otherwise, could clarify regulatory
rule on the merits of the case and the legal jurisdiction over USPS involvement in EMS.
jurisdiction of FCC over USPS involvement For example, this might take the form of the
in the telecommunication portion of EMS re- amendment to S. 898 which stipulates that
mains unclear. FCC shall establish costs for the telecom-
USPS also petitioned the court for review munication portion of any USPS EMS service
of that part of the PRC Final Recommended and shall assume that any such telecommu-
Decision that designates E-COM as an “ex- nication services are offered by a separate
perimental” subclass of first-class mail organizational entity within USPS. Apart
authorized only through October 1, 1984. from these two provisions, the amendment to
Basically, USPS claimed that PRC far ex- S. 898 states that FCC shall not regulate
ceeded its authority and sought to exercise a USPS.22 As another example, Congress might
power reserved to the USPS Board of Gover- clarify-through an amendment to the Postal
nors.20 In June 1981, the court ruled for USPS Act—the extent of PRC jurisdiction over a
and remanded the matter back to PRC for fur- USPS role in EMS.
ther consideration.21
USPS Subdivision for EMS
However, two issues were still in dispute.
First, PRC believed it was proper to review As discussed in chapter 7, a number of pri-
the entire E-COM decision, not just the “ex- vate firms and other parties have expressed
perimental” designation which was the sub- concern that USPS involvement in EMS
ject of the court proceeding. A number of com- would constitute unfair competition between
munication carriers and others (including the an independent Government agency and the
Departments of Commerce and Justice) who private sector. This concern focuses in part on
filed statements with PRC took the position the possibility that USPS might use public ap-
that the court, in effect, vacated the PRC propriations or revenues from other USPS
Recommended Decision in toto, and that services to cross-subsidize EMS services. In
USPS was not authorized to proceed with July 1979, the White House proposed the crea-
E-COM on January 4, 1982. USPS maintained tion of a separate USPS subdivision for EMS
that the court’s remand, and therefore PRC’s service in order to make cross-subsidies easier
reconsideration, extended only to the question to detect and prevent. The original White
of “experimental” designation and that USPS House proposal suggested “a separate entity
was otherwise authorized to initiate E-COM for accounting and ratemaking purposes.”23
service in January. In December 1981, PRC H.R. 2813 would require USPS to establish by
suspended the proceedings, leaving the legal regulation “a separate organizational unit . . .
status of E-COM uncertain. On January 4, to provide for the management of all electronic
1982, USPS started E-COM service. In April mail service of the USPS.”24 S. 898 would re-
1982, the U.S. Court of Appeals for the Dis- quire “a separate organizational entity” for
trict of Columbia denied a Department of any telecommunication
25
services offered by
Justice petition to block implementation of USPS.
E-COM.
96 ● Implications of Electronic Mail and Message Systems for the U.S. Postal Service
———
USPS has already established a separate Of- adjustments may be necessary so that costs
fice of E-COM Operations and implemented are fully covered over a given period of opera-
detailed cost accounting procedures which, ac- tion and projected volume. However, Congress
cording to USPS, are more stringent than any- may wish to consider stronger safeguards (e.g.,
where else in the organization. USPS has in- outside audit) and a greater degree of organiza-
itiated a complete review of E-COM costs to tional separation to prevent cross-subsidiza-
date, recognizing that some costs have been tion and allay private sector fears.
higher than initially estimated and that rate
Privacy Protection
Privacy protection in a USPS EMS service anteeing dissemination in a physically visible
is a continuing issue. First raised in the manner of one of the two pieces of informa-
original PRC consideration of the E-COM pro- tion needed to use E-COM. The account num-
posal, a 1982 National Research Council (NRC) ber, together with an access code and familiari-
report 26 has amplified the privacy and securi- ty with the E-COM technical interconnection
ty concerns discussed in chapter 7. To quote standards, would permit unauthorized use of
from the NRC report: “Electronic mail pre- E-COM. A third potential problem is that all
sents potentially serious problems of securi- incoming messages are stored for 1 week in
ty and privacy protection. The processing, computer memory or on magnetic tape in the
storage, and transmission of large amounts of E-COM computers. While this archiving may
data, which are functions central to electronic be necessary in case of errors in message con-
mail, offer an attractive target for anyone version or transmission, it also could present
seeking access to individual and corporate another target for security violations. This
information. ’27 security risk is heightened by the fact that
computers at each of the 25 E-COM locations
OTA has not conducted a thorough review are interconnected electronically to the USPS
of E-COM security and privacy. However, pre-
management operations center in Wilkes-
liminary discussions with USPS indicate that
Barre, Pa. The purpose of the management in-
while some protections are in place, additional formation system is to validate account num-
security measures appear to be necessary. The
bers and access codes and keep track of
E-COM equipment is apparently physically message volume by account. However, it may
secure, but the technical configuration makes
be technically possible to tap the archived
it possible for the operator to read the hard-
messages via the management information
copy printouts before being enveloped. Oper-
system which apparently uses dedicated, but
ators are instructed not to read the contents, not otherwise secure, leased telephone lines.
and unauthorized personnel are not permitted
in the E-COM facilities when printers are in Congress may wish to mandate an independ-
operation. Nonetheless, the potential for secu- ent review of E-COM security to ensure that
rity breaches does exist. the necessary security measures are either in
place or implemented shortly. Since it appears
A second potential problem is that the user that the postal statutes do not at present ex-
(carrier or mailer) account numbers are printed tend to the electronic transmission portion of
on the outside of E-COM envelopes, thus guar-
Generation II EMS, or at least it is not clear
that the statutes apply, Congress may wish
‘Nationa.l Research Council, Assembly of Engineering, Com- to consider the possibility of amending the
mittes on Review of U.S. Postal Setice Plannin g for Electronic Postal Act and/or Communications Act to pro-
Mail Service Systems, Review of Electronic Mail Service vide additional statutory protection, and con-
Systems Planning for the U.S. Postal Service, National
Academy Press, Washington, D. C., 1981. sider the use of data encryption to provide ad-
2TIbid., p. xi. ditional technical protection.
Ch. 8—Congressional Policy Considerations ● 97
—
I I
t
P a t.
101
97-918 0 - 82 - 8
102 ● Implications of Electronic Mail and Message Systems for the U.S. Postal Service
franked mail
The major mail segments in table A-1 were Table A-4 provides complete detail on the Gen-
regrouped to combine some of the smallest cate- eration II and Generation III EMS diversion
gories, and to further divide some of the larger cat- parameters. In order to simplify the analysis, the
egories. For example, household/household cor- 26 mainstream segments listed in table A-2 were
respondence was separated into letters and greet- consolidated into 12 segments shown in table A-4.
ing cards, since the potential for electronic han- For the purposes of table A-4, the analysis focused
dling of letters maybe significantly greater than on the type of mail content and sender/receiver
that of greeting cards. Also, nonhousehold/non- pairs, rather than on different classes of mail. The
household correspondence was separated into in- parameters that determine the growth and timing
tracompany and intercompany categories, since of the projected Generation II logistic substitution
the potential for electronic handling of intracom- curve for each mailstream segment are summa-
pany mail maybe developing significantly faster rized in the upper half of the cells in table A-4. For
than for intercompany mail. The miscellaneous each mainstream segment (column), the values ~
categories, merchandise, and segments with a and t. for Generation II are listed in the row op-
volume of less than 1 billion pieces per year were posite the technology that controls growth and
combined into one expanded miscellaneous cat- timing for that segment. For example, for Genera-
egory for each class of mail. tion II household-household (H-H) greeting cards,
The mainstream segments resulting from this re- a = 0.2 and to = 1995 is projected, based on the
grouping are listed in table A-2, along with the estimated availability of cost effective advanced
mail class (first, second, third, fourth, other) and electronic printers. The parameters that determine
1977 baseline mail volume for each segment. Those the growth and timing of the projected Generation
segments judged to be susceptible to penetration III logistic substitution curve for each mainstream
by EFT and/or EMS are marked by an “X” in segment are shown in the lower half of the cells
table A-2. in table A-4. Again, the values are shown in the
Table A-3 provides further detail on the EFT di- row opposite the controlling technological devel-
version parameters (P, CY , to) for each mainstream opment.
segment judged to be susceptible to EFT.
App. A—Supplemental Detail on the Market Penetration Model ● 103
Penetration Growth
1977 volume potential constant Time when 5 percent
Mainstream segment (billions) (P) (a) diversion occurs t.
NH-H bills . . . . . . . . . . . . . . . . . . . . . . . . . 8.9 0.9 0.20 1985
NH-H financial statements. . . . . . . . . . . 2.6 0.9 0.20 1985
NH-NH bills, statements, etc. . . . . . . . . 8.4 0.9 0.20 1985
H-N H negotiable instruments . . . . . . . . 6.5 1.0 0.20 1985
NH-H negotiable instruments . . . . . . . . 1.9 1.0 0.20 1985
NH-NH negotiable instruments . . . . . . . 1.5 1.0 0.20 1985
SOURCE: Office of Technology Assessment; see OTA, selected Hecfrorrlc Funds Transfer Issues: Secur/ty, Privacy, and Equity, OTA-BP-CIT-
12, March 1982, for further discussion of EFT trends and developments which are generally consistent with the EFT diversion
parameters.
104 . Implications of Electronic Mail and Message Systems for the U.S. Postal Service
Table A-4.—EMS Technology Assumptions and Diversion Parameters by Mail Content and Sender/Receiver Pair
———.
From-to N-N Intra N-N Inter N-N N-N N-N N-H H-H H-H H-N “NH N-H N-H
Other non- Other non- BiIIs and
Content Corr Corr advertising Bills Advertising Advertising Cards Corr Corr Corr advertising statements
Penetration
Generation II 100% 100 ”/0 70°/0 100% 100 ”/0 100 ”/0 100 ”/0 100 ”/0 100% 100 ”/0 70 ”/0 100 ”/0
Generation Ill 100 ”/0 100 ”/0 70 ”/0 100% 100 ”/0 30% 300/o 100 ”/0 100% 100 ”/0 7 0 % 100 ”/0
—
Early electronic II 30% 1983 30 ”/0 1983 300/o 1983 30% 1983 30% 1983 30 ”/0 1983
printers Ill
Advanced II 20 ”/0 1995 20 ”/0 1995 20 ”/0 1995
Viewdata/ II .
teletext 4 0 % 1985 20 ”/0 1985
Ill
Inexpensive HC II —
receiver 20 ”/0 1990
Ill
.
N = Nonhousehold
H = Household a tm
.,
(r = Initial rate of growth
Key to Entries: Generation II EMS
t = Year of 5% diversion
o
Table A-5 shows the actual procedure used by Table A-5.—Procedure Used by Computer Program
the computer program to obtain the overall diver- for Market Penetration Projections
sion results. The computer program applied an
underlying growth rate to each mainstream seg- calculated.
ment, and then calculated the portion of each seg- 2. Compute a “UG” factor for the underlying growth in the
ment diverted to EFT, Generation II EMS, and mainstream relative to 1977. For most runs the assump-
Generation III EMS. These diversion estimates tion was 2 percent compounded growth. Hence the “UG”
factor is 1.02 raised to the power (t-1977).
were calculated using the logistic growth curve 3. Compute EFT penetration for each of the segments in
(described in app. B) for each mainstream segment, table A-2 which are penetrated by EFT. First compute
with the parameters P (penetration potential), ~ the penetration fraction f using the logistic substitution
(growth constant) and t0 (time of 5-percent penetra- formula in appendix B, and the values of ~ and t. from
tion), as specified earlier in tables A-3, A-4, and table A-3. Then multiply the 1977 volume x the “UG”
factor x the penetration potential P (from table A-3) x f.
A-5. The diversion estimates for each mailstream This yields the volume diverted to EFT in year t for each
segment were then added together to give overall mainstream segment.
estimates for residual conventional mail volume 4. Reduce the 1977 volumes for segments affected by EFT
and for the volumes of mail diverted to EFT, Gen- by the amount of EFT diversion before computing EMS
diversion.
eration 11 EMS, and Generation 111 EMS. 5. Compute diversion to Generation Ill EMS for each mail-
Diversion estimates were calculated for the stream segment affected by EMS just as in step 3 above
years 1985, 1990, 1995, and 2000. As explained in for EFT, except use the reduced 1977 volumes for EFT
chapter 3, the results of the computer runs were impacted segments, and use w tO , and P for Generation
Ill from table A-4. The penetration potential P is con-
adjusted upward by 10 percent (multiplied by a tained in the third row of table A-4 (marked “PENETRA-
factor of 1.10) to compensate for the difference be- TION”). The a and t. values for Generation Ill are in the
tween the projected and actual growth rate in the lower half of the cells in table A-4.
mainstream for the years 1977-81. 6. Compute diversion to Generation II EMS for each seg-
ment in the same manner as in step 5 above, using a and
t. from the upper half of each cell in table A-4. Then
reduce the computed Generation II volume by the com-
puted Generation Ill volume. If the Generation III volume
exceeds the Generation II volume, then Generation II
volume is zero.
7. Add results across mainstream segments for each class
of mail to get diversion totals by class of mail.
—
SOURCE Office of Technology Assessment
Appendix B
The logistic substitution process is one math- only with time. As the available market ap-
ematical formulation that can be used to describe proaches saturation, the rate of growth declines.
the encroachment of one technology on the market In mathematical terms, the key variable is the
of another. In the field of systems ecology a mul- market share of the new technology, expressed as
titude of models have been used for this purpose. a fraction f of the total potential market. Ultimate-
However, the more complex models require data ly, the entire potential market will be penetrated,
that are significantly more detailed than were and f will equal 1 or the maximum penetration po-
available for this analysis, and for all their com- tential P, whichever is less. Initially, the market
plexity have no more inherent validity than a sim- share fraction f is very small, but grows with time
ple model such as logistic substitution. The most at a rate proportional to the market share itself.
important considerations for any model used for Thus, in the early stages of growth, the growth of
this kind of analysis are that it be based on sup- f per unit of time is expressed as ~ X f, where CY
portable data and that it make sense. is a constant for the particular technology and
The logistic substitution curve (fig. B-1) presents market being considered. The factor Q will be
a reasonable macroscopic model of the encroach- referred to as the “growth constant” for the par-
ment of a new technology into the market of an ticular substitution process. It is a measure of how
established, mature technology. When the new quickly the technology will penetrate the market.
technology becomes available, it penetrates the For example, with CY = 0.4 (per year), the market
market slowly at first due to relatively high cost share will rise from 5 to 75 percent in 10 years,
and limited consumer acceptance. As time goes on, whereas with CY = 0.2 such a change in market
cost declines as volume of use builds, leading to share will require 20 years.
an accelerating growth. Growth remains gradual, The market share at any time can be computed
however, since consumer acceptance can be gained from the equation in figure B-1 if the growth con-
stant Q and the time of 50-percent market pene-
tration t are specified. Alternatively, some other
Figure B-1.— Logistic Substitution Growth Process point on the curve can be specified along with the
growth constant ~. OTA chose to specify a par-
ticular logistic substitution curve by specifying
the growth constant, a , and the time (calendar
year) at which 5-percent penetration of the avail-
able market occurs. This 5-percent penetration
time is designated to. The market share f can then
be expressed in terms of a and tO as follows:
105
106 ● Implications of Electronic Mail and Message Systems for the U.S. Postal Service
107
—.
Appendix D
E-COM Interconnection
Arrangements
Dial-Up Access Arrangements ASCII character set, and full-duplex operations at
2400, 4800, or 9600 bits per second.
1. Binary synchronous, compatible with the 2. DEC (Digital Equipment Corporation)
IBM 2780 and 3780 terminals using EBCDIC DDCMP serial synchronous byte oriented line pro-
character code sets, operating in half-duplex mode tocol, using the ASCII character set, with full-
at 2400 bits per second with Bell System 201C duplex operation at 2400, 4800, 9600, or 56,000
compatible modems and at 4800 bits per second bits per second.
with Bell 2088 compatible modems. 3. Binary synchronous, compatible with the
2. Asynchronous, using the Texas Instruments IBM 2780 and 3780 terminals using EBCDIC
700 series convention for data block transmission character code sets, operating in half-duplex mode
and the 96 character ASCII subset as defined by at 2400 bits per second with Bell System 201C
ANSI Standard X3.4—1977, currently used in a compatible modems and at 4800 bits per second
wide variety of message and data terminals, oper- with Bell System 208B compatible modems, and
ating at 300 and 1200 bits per second full-duplex at 9600 bits per second with Bell System 209A
with Bell System 212A compatible modems. compatible modems.
4. Asynchronous, using the Texas Instruments
Dedicated Access 700 series convention for data block transmission
and the 96 character ASCII subset as defined by
Arrangements ANSI Standard X3.4—1977, currently used in a
wide variety of message and data terminals, oper-
1. Packet switched X.25, with LAP data link
ating at 300 and 1200 bits per second full-duplex
protocol, binary synchronous framing using the with Bell System 212A compatible modems.
‘USPS; see Federal Register, vol. 46, No. 199, Thursday, Oct. 15, 1981,
p. 50879.
108
Index
Index
American Telephone and Telegraph (AT&T), 78 interconnections with telecommunication
automation, 27, 30 providers, 78, 92, 108
legal challenge to USPS role in, 17
Communications Act (see Communications Act of projected growth of, 93
1934) regulation of, 94-95
Communications Act of 1934, 3, 11, 16, 17, 76, 77, technical standards of, 78
80, 87, 88, 89, 94, 96, 97 volume of, 75
competition, 17, 18, 91 electronic funds transfer (EFT), 4, 5, 6, 8, 16
in data processing and office automation diversion of first-class mail to, 4, 5, 6, 26-27
technologies, 30 Generation III systems, 4, 5, 11, 81
in EMS market, 16 electronic mail and message systems (EMS)
impact of private delivery services on USPS, 73 alternatives for involvement of USPS in, 9, 10
restrictions on USPS, 77 competition between Generations 11 and III
between USPS and private industry, 76, 87-88 systems, 77-78
computer modeling, 3, 18 congressional interest in, 17-18
equation for labor requirements, 107 cost displacement by, 9
limitations of, 19 diversion of first-class mail to, 6
logistic substitution process, 105-106 effects on USPS finances, 90
market penetration model, 19, 23-24, 101-104 effects on USPS labor requirements, 7-8, 64-70, 90
revenue and cost model, 19, 51-52 effects on USPS postal rates, 5-6, 61-63
computers, 4, 16, 27, 30, 31, 32, 42, 44, 79, 87, 88 effects on USPS service levels, 5-8, 63-64
Congress, 3, 4, 75 fairness of USPS role in, 73-75
concern over USPS role in electronic mail and Generation I systems, 77
message systems, 17-18 Generation II growth and timing estimates, 29-30,
House Committee on Energy and Commerce, 17 32-33, 45-48
House Committee on Post Office and Civil Generation II systems, 4, 5, 6, 7, 8, 9, 10, 27, 29,
Service, 17 30, 31, 32, 33, 37, 38, 39, 40, 41, 42, 44, 45, 46,
House Government Operations Subcommittee on 52, 53, 56, 61, 62, 64, 66, 68, 69, 77, 81, 88,
Government Information and Individual 89, 90, 94
Rights, 77 Generation 111 systems, 4, 5, 8, 9, 10, 11, 27, 30,
possibilities for action by, 9-11, 87-97 31, 32, 37, 38, 42, 44, 45, 46, 77, 78, 81, 83,
proposed legislation, 17, 18, 77, 95 88, 91, 94
Senate Committee on Commerce, Science, and growth of Generation III services, 30-31
Transportation, 17 legality of USPS role in, 76
Senate Committee on Governmental Affairs, 17 marketing of, 92
Subcommittee on Government Information and market penetration analysis of, 37-48
Individual Rights, 77 penetration potentials of, 27
Consultative Committee for International Telephone performance standards for, 93
and Telegraph, 30 policy implications of, 8-11
cross-subsidization, 18, 75, 88, 95 projected growth of, 4-5
relationship between Generation 11 and III
Datapost, 27 estimates, 31-32
data processing, 17, 18, 27, 30, 87 revenue and cost assumptions, 56
Department of Commerce, 17, 75, 88, 95 revenue and cost model analysis of, 51-57
Department of Justice, 9, 17, 62, 74, 75, 88, 95 stimulation of demand for new messages by, 42
deregulation electronic message market, 16
of the telecommunication industry, 87 electronic message service system (EMSS), 9, 16, 32,
Dialcom, Inc., 78 53, 90, 93, 97
Domestic Mail Classification Schedule, 92 EMS (see electronic mail and message systems)
EMSS (see electronic message service system)
E-COM (see electronic computer-originated mail) Equitable Life Assurance Co., 83
EFT (see electronic funds transfer)
electronic computer-originated mail (E-COM), 3, 4, 9, FCC (see Federal Communications Commission)
10, 11, 16, 27, 53, 74, 76, 77, 79, 81, 83, 88, 89, Federal Communications Commission (FCC), 10, 16,
90, 93, 95, 97 77, 78, 87, 88, 93, 94, 95
capital cost of, 75 Computer II decision of, 76
establishment of a separate USPS office for, 96 Federal Express, 73
initiation of service, 17 Federal Financing Bank, 74
111
112 Implications of Electronic Mail and Message Systems for the U.S. Postal Service
Federal Property and Administrative Services Act Postal Reorganization Act of 1970, 3, 10, 11, 17, 45,
of 1980, 87 62, 74, 75, 80, 87, 88, 89, 93, 96, 97
as authority for USPS involvement in EMS, 76
Government Printing Office, 83 Postal Service (see United States Postal Service)
Graphnet, 78 Postmaster General, 16
greeting cards, 27, 32 privacy protection, 10, 88, 93, 96
GTE Telenet, 78 data encryption, 81
of electronic communication, 80-82
INTELPOST, 16 and EMS, 79-81
international electronic post (see INTELPOST) of sealed mail, 79
International Standard Organization, 30 Private Express Statutes (PES), 10, 42, 73, 87,
ITT World Communications, 78, 83 89, 93
Purolator Corp., 73
judicial delay, 10
RCA, 5, 9, 10, 32, 46, 53, 69, 79, 90, 91, 93
mail (also see mailstream) regulation, 11, 93-96
advertising, 27, 31
content categories, 24 Satellite Business Systems, 78
covers, 80 security (see privacy protection)
financial statements, 31, 32 Shell Oil Co., 83
first-class, 6, 56 Supreme Court, 79
greeting cards, 31 Survey Research Center, 18, 24
growth of volume, 33-34
sender/receiver pairs, 24 telecommunication, 17, 18, 77, 80, 87, 89, 91, 92, 95
volume of, 4-5 telecommunication and computer industries, 3
Mailgram service, 3, 4, 9, 16, 27, 52, 89, 90, 93, 97 effects of a USPS role in EMS on, 73-80
mainstream Telecommunications Deregulation and Competition
baseline, 24-25, 101-104 Act of 1981, 18
EFT penetration of, 4, 26-27 teletext (see viewdata/teletext)
EMS penetration of, 4-5, 27-33 TRT Communications Corp., 83
growth of, 4, 6, 33-34 TRT Telecommunications Corp., 78
percent as first-class mail, 6 Tyme-Gram service, 27
vulnerability to penetration by electronic mail Tymnet, 78
systems, 24-25
Merrill Lynch Pierce Fenner & Smith, 83 United Parcel Service, 73
United States Postal Service (USPS)
National Research Council (NRC), 96 alternatives for involvement of, in EMS, 9, 10
National Technical Information Service, 83 annual appropriations for, 74
Netword, Inc., 83 constraints on, 97
contribution of first-class mail to fixed costs of,
Office of Management and Budget, 76, 77 6, 56
Office of Technology Assessment (OTA), 3, 4, 5, 7, cost and ratesetting process, 75
8, 9, 11, 26, 29, 30, 31, 33, 42, 44, 45, 46, 51, 52, disputed role of, in EMS and E-COM, 3, 78-79
53, 56, 57, 62, 63, 64, 65, 66, 68, 69, 75, 81, 88, effects of reducing mail deliveries by, 5-8, 82
97 innovation stimulated by, 79
Omnibus Budget and Reconciliation Act of 1981, introduction of E-COM by, 3
52, 75 jurisdictional conflicts with other Federal
Opinion Research Corporation, 93 agencies, 88
labor-intensiveness of, 64
Paperwork Reduction Act of 1980, 87 labor requirements of, 7-8, 64-70
Personal Computer Network, 27 legal mandates of, 3, 60, 76, 79, 82, 87
Postal Act (see Postal Reorganization Act of 1970) long-term viability of, 11, 81-83
Postal Rate Commission (PRC), 9, 10, 17, 45, 52, 62, performance of, 15-16
76, 78, 87, 88, 90, 91, 92, 93, 94, 95 public service subsidy, 75
hearings of, 75 rates and service levels of, 5-6
postal rates role in EMS, 9, 10, 17
implications of Generation II systems growth for, service levels of, 63-64
61-63 tax-exempt status of, 74
Index 113