U.S. Postal Service
Mail-Related Recycling Initiatives and Possible Opportunities for Improvement Gao ID: GAO-08-599 June 3, 2008In 2006, the U.S. Postal Service (USPS) discarded about 317,000 tons of undeliverable-as-addressed advertising mail. Such mail can be disposed of using incineration, landfills or through other methods. USPS recently committed to minimizing the agency's impact on every aspect of the environment. Recycling undeliverable advertising mail can help USPS achieve this commitment, while generating revenue and reducing its costs and financial pressures. In response to the 2006 Postal Accountability and Enhancement Act, this report addresses (1) recent mail-related recycling accomplishments (initiatives) undertaken by USPS, the mailing industry, and others and (2) additional recycling opportunities that USPS could choose to engage in, or influence mailers to undertake. To conduct this study, GAO analyzed relevant data and documents, visited USPS and other facilities, and interviewed about 40 stakeholders.
USPS and the mailing industry have undertaken numerous initiatives to increase (1) the recycling of mail-related materials and (2) the amount of mail with environmentally preferable attributes, such as mail that uses recycled paper. USPS has five key recycling-related initiatives underway. For example, USPS recently established annual goals to increase its revenue from mail-related recycling from $7.5 million to $40 million from fiscal years 2007 to 2010. However, by excluding savings that result from lower waste disposal costs--which accompany increased recycling--the goals do not reflect the full financial benefit attributable to mail-related recycling. USPS also has launched a pilot recycling program in New York City, but it is not known whether USPS will require its managers elsewhere to adopt applicable "lessons learned" from the pilot. Representatives of the mailing industry and other stakeholders also have undertaken a wide range of initiatives to, among other actions, increase the amount of mail that is recycled. For example, three mailing industry associations recently introduced separate awareness campaigns to encourage mail recipients to recycle their catalogs, envelopes, and magazines. In addition, the Direct Marketing Association--whose members collectively send about 80 percent of all Standard Mail--is undertaking several initiatives, including an effort to encourage mailers to use environmentally preferable mail attributes. USPS, mailing industry, and other stakeholders GAO interviewed identified five opportunities that USPS could choose to undertake to increase its recycling of mail-related materials and to encourage mailers to increase the amount of mail with environmentally preferable attributes. The five opportunities stakeholders cited most frequently were for USPS to: (1) implement a program for recognizing mail-related recycling achievements; (2) increase awareness among mail recipients that mail is recyclable and encourage them to recycle their mail; (3) collaborate with parties interested in increasing the supply of paper fiber available for recycling; (4) establish a special, discounted postal rate--or "Green Rate"--as a means of inducing mailers to adopt environmentally preferable attributes; and, (5) initiate a "mail take-back" program in locations that do not have access to municipal paper recycling. Each of these opportunities appears to be consistent with the agency's long-standing commitment to environmental leadership and the Postmaster General's recent commitments to minimize the agency's impact on every aspect of the environment and to act as a positive environmental influence in U.S. communities. Based on GAO's analysis, however, USPS would need to assess several factors including cost, feasibility (including logistical considerations), and mission compatibility in deciding whether to adopt these opportunities. For example, depending on the magnitude of variance between the expected costs and revenues, USPS may find implementing one or more of the opportunities unacceptable. This is, in part, because USPS faces multiple short- and long-term pressures in improving its operational efficiency, increasing its revenues, and controlling its costs--some of which are increasing faster than the overall inflation rate.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-08-599, U.S. Postal Service: Mail-Related Recycling Initiatives and Possible Opportunities for Improvement
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Report to Congressional Committees:
United States Government Accountability Office:
GAO:
June 2008:
U.S. Postal Service:
Mail-Related Recycling Initiatives and Possible Opportunities for
Improvement:
GAO-08-599:
GAO Highlights:
Highlights of GAO-08-599, a report to congressional committees.
Why GAO Did This Study:
In 2006, the U.S. Postal Service (USPS) discarded about 317,000 tons of
undeliverable-as-addressed advertising mail. Such mail can be disposed
of using incineration, landfills or through other methods. USPS
recently committed to minimizing the agency‘s impact on every aspect of
the environment. Recycling undeliverable advertising mail can help USPS
achieve this commitment, while generating revenue and reducing its
costs and financial pressures.
In response to the 2006 Postal Accountability and Enhancement Act, this
report addresses (1) recent mail-related recycling accomplishments
(initiatives) undertaken by USPS, the mailing industry, and others and
(2) additional recycling opportunities that USPS could choose to engage
in, or influence mailers to undertake. To conduct this study, GAO
analyzed relevant data and documents, visited USPS and other
facilities, and interviewed about 40 stakeholders.
What GAO Found:
USPS and the mailing industry have undertaken numerous initiatives to
increase (1) the recycling of mail-related materials and (2) the amount
of mail with environmentally preferable attributes, such as mail that
uses recycled paper. USPS has five key recycling-related initiatives
underway. For example, USPS recently established annual goals to
increase its revenue from mail-related recycling from $7.5 million to
$40 million from fiscal years 2007 to 2010. However, by excluding
savings that result from lower waste disposal costs”which accompany
increased recycling”the goals do not reflect the full financial benefit
attributable to mail-related recycling. USPS also has launched a pilot
recycling program in New York City, but it is not known whether USPS
will require its managers elsewhere to adopt applicable ’lessons
learned“ from the pilot. Representatives of the mailing industry and
other stakeholders also have undertaken a wide range of initiatives to,
among other actions, increase the amount of mail that is recycled. For
example, three mailing industry associations recently introduced
separate awareness campaigns to encourage mail recipients to recycle
their catalogs, envelopes, and magazines. In addition, the Direct
Marketing Association”whose members collectively send about 80 percent
of all Standard Mail”is undertaking several initiatives, including an
effort to encourage mailers to use environmentally preferable mail
attributes.
USPS, mailing industry, and other stakeholders GAO interviewed
identified five opportunities that USPS could choose to undertake to
increase its recycling of mail-related materials and to encourage
mailers to increase the amount of mail with environmentally preferable
attributes. The five opportunities stakeholders cited most frequently
were for USPS to: (1) implement a program for recognizing mail-related
recycling achievements; (2) increase awareness among mail recipients
that mail is recyclable and encourage them to recycle their mail; (3)
collaborate with parties interested in increasing the supply of paper
fiber available for recycling; (4) establish a special, discounted
postal rate”or ’Green Rate“”as a means of inducing mailers to adopt
environmentally preferable attributes; and, (5) initiate a ’mail take-
back“ program in locations that do not have access to municipal paper
recycling. Each of these opportunities appears to be consistent with
the agency‘s long-standing commitment to environmental leadership and
the Postmaster General‘s recent commitments to minimize the agency‘s
impact on every aspect of the environment and to act as a positive
environmental influence in U.S. communities. Based on GAO‘s analysis,
however, USPS would need to assess several factors including cost,
feasibility (including logistical considerations), and mission
compatibility in deciding whether to adopt these opportunities. For
example, depending on the magnitude of variance between the expected
costs and revenues, USPS may find implementing one or more of the
opportunities unacceptable. This is, in part, because USPS faces
multiple short- and long-term pressures in improving its operational
efficiency, increasing its revenues, and controlling its costs”some of
which are increasing faster than the overall inflation rate.
What GAO Recommends:
GAO recommends, among other actions, that USPS (1) require managers at
other facilities to adopt applicable lessons learned from its New York
City recycling pilot and (2) adopt the opportunities identified in this
report that are feasible, compatible with USPS‘ mission, and
appropriate in view of cost and other considerations. USPS agreed with
three of GAO‘s recommendations and stated that it is acting to
implement them. USPS also agreed, in principle, with the remaining
recommendation to adopt lessons learned from its pilot.
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-599]. For more
information, contact Katherine Siggerud at (202) 512-2834 or
siggerudk@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
USPS and the Mailing Industry Have Undertaken Numerous Mail-Related
Recycling Initiatives:
Stakeholders Cited Five USPS Mail-Related Recycling Opportunities, but
USPS Would Need to Assess Several Factors in Deciding Whether to Adopt
Them:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Other USPS Actions to Increase the Amount of Mail with
Environmentally Preferable Attributes:
Appendix III: Depiction of Various Mail-Related Recycling Logos:
Appendix IV: Other Stakeholder Initiatives to Increase the Amount of
Mail with Environmentally Preferable Attributes:
Appendix V: DMA's List of 15 Environmentally Preferable Business
Practices:
Appendix VI: Comments from USPS:
Appendix VII: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Relevant Goals of the Five Greening the Mail Task Force
Subcommittees:
Table 2: Stakeholders Interviewed:
Figures:
Figure 1: Mail-Related Recycling Logos:
Figure 2: Logos Indicating Paper Products Contain Recycled Materials or
Are Recyclable:
Abbreviations:
DMA: Direct Marketing Association:
UAA: undeliverable-as-addressed:
USPS: United States Postal Service:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
June 3, 2008:
Congressional Committees:
During fiscal year 2007, United States Postal Service (USPS) customers
sent approximately 104 billion pieces of mail (mailpieces) as Standard
Mail, the primary class of mail used for advertising. Over time, most
of these mailpieces were presumably discarded as waste. Depending on
how the discarded mailpieces are disposed of, they could be recycled,
placed into landfills, or incinerated. The U.S. Environmental
Protection Agency reports that during 2006, Standard Mail comprised
about 2.3 percent (5.9 million tons) of all municipal solid waste. Of
this amount, recycling efforts captured about 39 percent, while
landfills or incinerators received the remaining quantity. USPS
discarded about 6.1 billion undeliverable-as-addressed (UAA) Standard
Mail mailpieces (about 317,000 tons) in 2006, while mailers discarded
the remainder.[Footnote 1] With the exception of UAA Standard Mail, the
responsibility for recycling discarded mail primarily lies with mail
recipients.
USPS, which receives only a small portion of its funding from federal
appropriations, is expected to generate sufficient annual revenue to
cover its costs. In fiscal year 2007, however, USPS' operating costs
exceeded its revenues by over $5 billion, largely due to the agency's
advance payments for retiree health benefits. Furthermore, USPS expects
to incur substantial additional costs that will need to be offset by
revenue increases and improved operating efficiencies. USPS has
reported that mixed paper (i.e., UAA mailpieces, including newsprint,
and mail discarded by recipients in postal facility lobbies) account
for up to 70 percent of its waste stream. Recycling these materials
provides USPS with a means to generate substantial revenues,
significantly reduce its waste disposal costs, and improve its
financial position. In addition, because recycling discarded mail-
related materials results in a variety of environmental benefits,
including reductions in the amount of mail incinerated or placed in
landfills,[Footnote 2] recycling these materials provides USPS with a
means to enhance its long-standing commitment to environmental
leadership.
During fiscal year 2007, revenue generated from Standard Mail comprised
about 28 percent ($20.8 billion) of USPS' total revenue, and Standard
Mail constituted the largest class of mail by volume (about 49 percent
of 212 billion mailpieces). The prevalence of Standard Mail is expected
to increase, in part, because businesses, non-profit organizations, and
others view it as an effective way to (1) provide consumers with
information about their products and services and (2) solicit
contributions from mail recipients. Some critics, however, view
Standard Mail as an annoyance that also poses identify theft concerns
and negatively impacts the environment. In response, numerous state
legislatures introduced "Do Not Mail" bills that, if enacted, would
require mailers to remove registered individuals from their mailing
lists (similar to the national "Do Not Call" registry).[Footnote 3]
In response to the 2006 Postal Accountability and Enhancement Act and
agreements reached with relevant congressional offices, this report
addresses (1) recent mail-related recycling accomplishments
(initiatives)[Footnote 4] undertaken by USPS, the mailing industry, and
others and (2) additional recycling opportunities that USPS could
choose to engage in, or influence mailers to undertake. Pursuant to our
legislative mandate, we issued a report on our interim results on
December 20, 2007.[Footnote 5] This report updates our interim report
and describes in more detail the key recycling initiatives that
recently have been undertaken by USPS, the mailing industry, and other
stakeholders. These initiatives include efforts to recycle mail-related
materials,[Footnote 6] including UAA Standard Mail, and to increase the
amount of mail with environmentally preferable attributes. Mail with
environmentally preferable attributes includes mail that (1) contains
paper with recycled paper fiber (recycled paper); (2) uses paper from
responsibly-managed forests (certified paper);[Footnote 7] (3) is
designed to use materials efficiently, (such as "two-way" envelopes);
(4) is accurately addressed for delivery; and (5) is targeted to mail
recipients who may wish to receive it. This report also describes
additional stakeholder-identified opportunities for USPS to engage in
(or influence mailers to undertake) mail-related recycling initiatives,
and identifies factors such as cost; feasibility, including logistical
considerations; and mission compatibility that USPS would need to
assess prior to adopting the opportunities.
To accomplish our objectives we, among other activities, (1)
interviewed a wide range of USPS officials and stakeholders from about
40 other organizations, including representatives from mailing, paper
recycling, and environmental advocacy organizations; (2) toured various
facilities, including USPS facilities in Baltimore and Philadelphia, a
paper recycling facility, and a printing facility; (3) attended
meetings of the "Greening the Mail Task Force"--a committee of USPS,
mailing industry, and other stakeholders that addresses environmental
issues regarding the mail; and (4) reviewed and analyzed relevant
documentation. We discussed matters related to recycling several
classes of mail with stakeholders; however, we primarily focused on
Standard Mail because of (1) its increasing prominence in the mail
stream; (2) its contribution to the municipal solid waste stream; (3)
USPS' responsibility for discarding large volumes of UAA Standard Mail;
and (4) the issues critics cite related to Standard Mail, which are
reflected in numerous "Do Not Mail" state legislative initiatives.
While there are a variety of ways to consider the environmental impacts
of mail, this report focuses on the role recycling plays in eliminating
mail and mail-related materials from municipal solid waste, increasing
USPS' revenue, decreasing USPS' waste disposal costs, and enhancing
USPS' commitment to environmental leadership. Appendix I provides a
more detailed explanation of our scope and methodology.
We conducted this performance audit from April 2007 to June 2008 in
accordance with generally accepted government auditing standards. Those
standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
Results in Brief:
USPS and the mailing industry have undertaken numerous initiatives to
increase (1) the volume of mail-related materials recycled and (2) the
amount of mail with environmentally preferable attributes. USPS has
five key recycling-related initiatives underway. For example, USPS
recently established annual goals to increase its revenue from mail-
related recycling from $7.5 million in fiscal year 2007 to $40 million
in fiscal year 2010. These goals do not reflect the full financial
benefit attributable to mail-related recycling, however, because they
exclude the savings that result from lower waste disposal costs that
accompany increased recycling. At the conclusion of our review, USPS
had not agreed to revise its goals or to adopt additional goals that
reflect its full financial benefit. Furthermore, while USPS intends to
develop a plan to help it achieve its recycling revenue goals, it is
not clear whether this plan will (1) specify how progress toward the
goals will be measured or (2) ensure that the data USPS will use to
measure its progress are accurate, reliable, and collected using a
consistent method. Similarly, although USPS also has launched a pilot
recycling program in New York City, it is not clear whether, or to what
extent, USPS will require its managers at other facilities to adopt, as
applicable, feasible, mission compatible, and appropriate in view of
cost and other considerations, the lessons learned from the pilot. USPS
also developed, among other initiatives, a task force to increase the
amount of mail with environmentally preferable attributes.
Representatives of the mailing industry and other stakeholders also
have undertaken a wide range of initiatives to, among other actions,
increase the amount of mail that is recycled. For example, three
mailing industry associations recently introduced separate recycling
awareness campaigns to encourage mail recipients to recycle their
catalogs, envelopes, and magazines. Other stakeholders, such as the
National Recycling Coalition; Time, Inc.; and Verso Paper, have
initiated a campaign to increase the volume of catalogs and magazine
recycled in selected cities. In addition, the Direct Marketing
Association--whose members collectively send about 80 percent of all
Standard Mail--is undertaking several initiatives, including an effort
to encourage mailers to use environmentally preferable mail attributes.
USPS, mailing industry, and other stakeholders we interviewed
identified five opportunities that USPS could choose to undertake to
increase the volume of mail-related materials it recycles and to
encourage mailers to increase the amount of mail with environmentally
preferable attributes. The five opportunities stakeholders cited most
frequently were for USPS to:
* Implement a program for recognizing mail-related recycling
achievements.
* Increase awareness among mail recipients that mail is recyclable and
encourage them to recycle their mail through, among other actions,
collaboration with mailing industry and other stakeholder initiatives.
* Collaborate with parties interested in increasing the supply of paper
fiber available for recycling.
* Establish a special, discounted postal rate--or "Green Rate"--as a
means of inducing mailers to adopt one or more environmentally
preferable attributes in their mailpieces.
* Initiate a "mail take-back" program in locations that do not have
access to municipal paper recycling.
Each of these opportunities appears to be consistent with (1) the
agency's long-standing commitment to environmental leadership and (2)
the Postmaster General's recent commitments to both minimize the
agency's impact on every aspect of the environment and to act as a
positive environmental influence in U.S. communities. USPS would
nonetheless need to balance those commitments, as well as the potential
environmental benefits that those opportunities might provide, against
factors such as costs to USPS, feasibility (including logistical
considerations), and compatibility with USPS' mission when deciding
whether to adopt these opportunities. For example, while the costs
associated with implementing a program for recognizing mail-related
recycling achievements are likely to be minimal (and more than offset
by increases in USPS' revenues), the remaining four opportunities
necessitate additional cost consideration. For example, two of the
opportunities--increasing awareness about mail recycling and initiating
a Green Rate--appear to have little likelihood of increasing the
agency's revenue. Furthermore, the remaining two opportunities--
collaborating with parties interested in increasing the supply of paper
fiber available for recycling and initiating a mail take-back program-
-may not generate sufficient revenues to cover their costs. Depending
on the magnitude of variance between the expected costs and revenues,
USPS may find implementing one or more of the opportunities
unacceptable. As we recently testified, USPS faces multiple short-and
long-term pressures in improving its operational efficiency, increasing
its revenues, and controlling its costs--some of which are increasing
faster than the overall inflation rate.[Footnote 8] In addition, unlike
in the past, USPS is now subject to an inflation-based cap on the
prices it can charge for its goods and services.[Footnote 9]
To increase USPS' recycling of mail-related materials and increase the
amount of mail with environmentally preferable attributes, we
recommend, among other actions, that the Postmaster General direct the
Manager of Environmental Policy and Programs and other parties, as
appropriate, to (1) require its managers at other facilities to adopt
applicable lessons learned from its New York City recycling pilot and
(2) assess the environmental benefits of the mail-related recycling
opportunities identified in this report, and any others, and adopt
those opportunities that are feasible, compatible with USPS' mission,
and appropriate in view of cost and other considerations.
USPS provided its written comments on a draft of this report by letter
dated May 2, 2008. These comments are summarized below and are
included, in their entirety, as appendix VI to this report. USPS agreed
with three of our four recommendations and stated that it had begun
initiating actions to implement them. USPS also agreed, in principle,
with our remaining recommendation to adopt applicable lessons learned
from its New York City recycling pilot nationwide, where feasible,
mission compatible, and appropriate in view of cost and other
considerations. USPS stated, however, that it cannot require all of its
facility managers to adopt these lessons since "not all lessons learned
are applicable nationwide." We recognize that the pilot's lessons will
not be applicable at every postal facility and, thus, clarified the
recommendation to avoid confusion.
Background:
As the primary mail carrier in the United States, USPS' mission is to
provide the nation with affordable and universal mail service. USPS'
authority was revised on December 20, 2006, with the enactment of the
Postal Accountability and Enhancement Act.[Footnote 10] Through this
act, Congress provided USPS with tools and mechanisms to help ensure
that USPS is efficient, flexible, and financially sound. The act also
introduced a rate cap for many postal services. While Congress oversees
USPS and provides direction to the agency on its operations and other
matters, USPS receives only a small portion of its funding from federal
appropriations.[Footnote 11]
According to a 2001 Mailing Industry Task Force study,[Footnote 12] the
mailing industry includes businesses, organizations, and other parties
(mailers) that send and rely on mail to maintain contact with their
customers. The mailing industry also encompasses mail preparers,
including printers and businesses that send or receive mail on behalf
of a third party. Vendors and suppliers of the hardware, software, and
labor related to mail processing, such as companies who help mailers
improve the accuracy of their mailing lists, also are included in the
mailing industry, according to this study.
USPS offers several classes of mail, including First-Class, Standard,
and Periodical Mail. The price for each class of mail varies, as does
the level of service that USPS provides. Mailers, including both
household and business customers, use First-Class Mail when sending
personal mail and personalized business correspondence, such as
letters, greeting cards, bills, and account statements. Mailers also
may use First-Class Mail to send advertisements and merchandise.
Standard Mail is the primary mail class for advertisements sent in bulk
quantities and cannot be used for sending personal correspondence, such
as handwritten letters, bills, or account statements. Periodical Mail
primarily is comprised of newspapers and magazines. Standard Mail rates
are generally lower than First-Class Mail rates, in part, because USPS
typically does not provide services such as return-to-sender and
forwarding for UAA Standard Mail.[Footnote 13]
USPS and the mailing industry view Standard Mail as an important
advertising medium for businesses, non-profit organizations, and other
parties who seek to inform mail recipients about their products and
services or to solicit contributions. While USPS currently receives
about half of its revenue from First-Class Mail, Standard Mail became
the largest class of mail (by volume) in fiscal year 2005. During 2005,
mailers spent about $56.6 billion on direct mail advertising--
comprising about 21 percent of all U.S. expenditures for
advertising.[Footnote 14] USPS expects the volume of Standard Mail to
continue to grow.
UAA mail is mail that USPS cannot deliver to a specified address due to
an incomplete, illegible, or incorrect address or insufficient postage,
among other reasons. USPS' treatment of UAA mail depends on the mail
class. USPS forwards UAA First-Class Mail to the addressee, returns it
to the sender, or, if the return address is missing, sends it to a USPS
Mail Recovery Center.[Footnote 15] In general, USPS retains UAA
Standard Mail and treats it as waste. Because of the large volume of
UAA Standard Mail that USPS discards annually (about 317,000 tons in
2006), USPS focuses most of its mail-related recycling efforts on this
material. USPS also treats the mail discarded by recipients in postal
facility lobbies (discarded lobby mail) as waste. While USPS does not
know how much mail post office box holders and other recipients discard
in its lobbies, a USPS official stated that the amount is "trivial"
relative to its total volume of mail-related waste.
USPS has reported that mixed paper (i.e., UAA mailpieces, including
newsprint, and discarded lobby mail) accounts for up to 70 percent of
its waste stream. According to USPS, these materials can be used to
make everything from low-grade paper products, such as hand towels and
tablet backings, to wallboard and stock for fuel pellets that can be
burned with coal to reduce harmful air emissions. Furthermore,
according to the agency, the large volume of its UAA mail is an
attractive and reliable source of clean mixed paper needed for
manufacturing these and other products.
A USPS-sponsored study reported that in fiscal year 2004, UAA mail cost
the agency more than $1.8 billion,[Footnote 16] which represented about
2.6 percent of USPS' total expenses (approximately $69 billion). About
two-thirds of UAA mail costs resulted from forwarding mail to the
intended recipients ($422 million--23 percent) or returning it to the
sender ($822 million--44 percent). The remaining one-third of UAA mail
costs are the result of processing waste ($270 million--15 percent),
correcting addresses ($197 million--10 percent), processing address
change requests ($132 million--7 percent), and general administration
and support ($24 million--1 percent). Furthermore, according to USPS,
creating and sending mail that cannot be delivered costs businesses
more than $2 billion annually.
With the exception of UAA Standard Mail, the responsibility for
recycling discarded mail primarily lies with mail recipients. While the
majority of mail is recyclable,[Footnote 17] according to the
Environmental Protection Agency, mail recipients and others recycled
only about 39 percent of the Standard Mail they received and
subsequently discarded in 2006. Studies find that the volume of
products recycled depend on, among other matters, whether a recipient
knows that a product is recyclable and whether the recipient has access
to a recycling program or facility. According to one study, over 40
percent of the public are unaware that it can recycle mail.[Footnote
18] Numerous stakeholders we interviewed confirmed this lack of
recycling awareness. Even if individuals are aware that mail is
recyclable, according to a 2005 survey conducted by the American Forest
and Paper Association, residents in about 31 percent of U.S.
communities (14 percent of the population) do not have access to paper
recycling programs.[Footnote 19] In addition, while a 2006 survey by
the Federal Trade Commission found that only a small number of victims
(2 percent) reported that the theft of their identify was connected to
the mail, several stakeholders told us that identity theft concerns
prevent some recipients from recycling their mail. In December 2006, we
reported on efforts to increase the volume of materials recycled and
found that, to increase recycling, U.S. municipalities need to conduct
public education campaigns and ensure that access to recycling is both
convenient and easy.[Footnote 20] Further, we identified federal policy
options that would help municipalities increase the volume of materials
recycled, including the establishment of (1) a nationwide education
campaign to inform the public about recycling and (2) programs that
enable consumers to recycle products by returning them to the
manufacturer or some other party for recycling. These programs are
known as "take-back" programs.
USPS and the mailing industry formed a Greening the Mail Task Force in
1996 to identify cost-effective ways to integrate environmental
considerations into mailing practices and business processes. The task
force issued a final report of its activities in 1999, including its
efforts to identify "green" mail attributes (environmentally preferable
attributes). According to the task force, environmentally preferable
mail includes, among other attributes:
* Mail that contains recycled paper.
* Mail that uses certified paper.
* Mail that is designed to use materials efficiently (such as "two-way"
envelopes).
* Mail that is accurately addressed for delivery.[Footnote 21]
* Mail that is targeted to recipients who may wish to receive it.
[Footnote 22]
USPS' Environmental Policy and Programs organization is principally
responsible for increasing the agency's recycling of mail-related
materials and is the focal point for executing its environmental policy
throughout the agency. USPS also has organizations that, among their
other responsibilities, attempt to increase the amount of mail with
environmentally preferable attributes. For example, Address
Management's goal is to decrease the amount of UAA mail. To accomplish
this, the organization provides mailers with tools to better manage the
quality of their mailing lists while, according to USPS, striving to
maximize its ability to efficiently deliver mail as addressed. The
Product Development organization within Marketing helps manufacturers
develop mail-related products that contain recycled materials. Finally,
USPS' Sales organization--also within Marketing--promotes the use of
environmental preferable attributes in direct mail advertising and in
USPS shipping materials.
USPS and the Mailing Industry Have Undertaken Numerous Mail-Related
Recycling Initiatives:
USPS and the mailing industry have undertaken numerous initiatives to
increase the recycling of mail-related materials and increase the
amount of mail with environmentally preferable attributes. For example,
USPS has undertaken five key mail-related recycling initiatives,
including the establishment of annual goals to increase its recycling
revenue from $7.5 million in fiscal year 2007 to $40 million in fiscal
year 2010 and a pilot recycling program in New York City.
Representatives of the mailing industry and other stakeholders also
have undertaken a wide range of initiatives to, among other actions,
increase the amount of mail that is recycled. For example, three
mailing industry associations recently introduced separate recycling
awareness campaigns to encourage mail recipients to recycle their
catalogs, envelopes, and magazines. In addition, the Direct Marketing
Association--whose members collectively send about 80 percent of all
Standard Mail--is undertaking several initiatives, including an effort
to encourage mailers to use environmentally preferable mail attributes.
USPS Has Undertaken Five Key Initiatives to Increase Its Recycling of
Mail-Related Materials:
USPS has undertaken five key initiatives to increase its recycling of
mail-related materials. Specifically, USPS recently (1) established
goals for increasing its recycling revenue; (2) refocused its attention
on environmental matters, including mail-related recycling, and intends
to require recycling where cost-effective and feasible; (3)
consolidated waste management contracts to generate increased recycling
revenues and reduce its waste disposal costs; (4) launched a pilot
recycling program in New York City; and (5) implemented tools to track
the environmental performance of its areas and districts. While USPS
recently established goals for increasing its recycling revenues,
inconsistencies in the way USPS collects data, if not resolved, will
hamper efforts to measure its progress in meeting these goals.
Furthermore, at the conclusion of our review, it was not clear whether,
or to what extent, USPS would require its managers at other facilities
to adopt--where applicable, feasible, mission compatible, and
appropriate in view of cost and other considerations--lessons learned
from its New York City pilot.
USPS Established Goals for Increasing Its Recycling Revenue, but
Inconsistencies in the Way It Collects Data, If Unresolved, Will Hamper
Efforts to Measure Its Progress:
In March 2008, USPS established annual goals for increasing the $7.5
million it generated from recycling mail-related materials in fiscal
year 2007. Specifically, USPS intends to generate $15 million in mail-
related recycling revenue in fiscal year 2008, $30 million in fiscal
year 2009, and $40 million in fiscal year 2010. According to USPS,
reaching its fiscal year 2010 goal could also reduce its solid waste
disposal costs by $10 million annually. Thus, in fiscal year 2010, USPS
could realize a full financial benefit of $50 million. To help reach
its initial fiscal year 2008 goal, according to USPS officials, each of
the agency's nine geographic areas developed a plan to generate $2
million from recycling in fiscal year 2008.[Footnote 23] Longer term,
according to these officials, the $40 million goal for fiscal year 2010
is based on the expectation that each of its 82 districts will generate
an average of about $500,000 in recycling revenues.
Such goals are a step in the right direction and address the need for
USPS to generate additional revenue, which is one of the agency's four
strategic goals. However, by excluding savings that result from lower
waste disposal costs, the goals do not reflect the full financial
benefit attributable to mail-related recycling. This is because when
USPS facility managers implement mail-related recycling programs, their
facilities generate less waste, thereby reducing the facilities' waste
disposal costs (in addition to generating recycling revenue). Revising
the agency's goals to include the savings from lower waste disposal
costs or adopting additional goals to reflect the full financial
benefit of recycling would help focus USPS employees on the need to
achieve greater cost reductions--consistent with a second USPS
strategic goal.[Footnote 24] According to USPS officials, USPS is
developing the capacity to track solid waste disposal volumes and
intends to develop a plan for achieving its recycling goals. However,
at the conclusion of our review, it had not agreed to revise its goals
or to adopt additional goals for measuring its savings from lower waste
disposal costs to reflect the full financial benefit attributable to
mail-related recycling.
Regardless of whether USPS finds it beneficial to revise its goals to
reflect the full financial benefit attributable to mail-related
recycling, in order to measure its progress, USPS will need to (1)
specify how it will measure its progress toward its goals and (2)
ensure that its organizations collect and report accurate, reliable,
and consistent data, which, according to agency officials, does not
presently occur. For example, according to both USPS officials and our
analysis of USPS documentation some district facilities combine
recycling revenues with waste disposal costs. Additionally, our
analysis of USPS documentation indicates that in fiscal year 2006 at
least one large district facility combined recycling revenues with
waste savings attributable to recycling--which, together, comprise the
full financial benefit of recycling.[Footnote 25] Inconsistent
reporting practices hamper efforts to accurately measure the agency's
progress in meeting its recycling revenue goals. To partially address
this problem, in March 2008, the agency's accounting organization sent
an e-mail to USPS area managers requesting that they report recycling
revenues separately from waste disposal costs. While this request
addresses the need to report recycling revenue separately, it does not
constitute a requirement for the managers at the area-, district-, or
facility-level to do so. Furthermore, the e-mail does not address
matters related to the reporting of USPS' savings from lower waste
disposal costs, or require these managers to report data on their
savings using a consistent method. Finally, at the conclusion of our
review, USPS had neither (1) specified how it will measure progress
toward its goals nor (2) required its organizations to collect and
report accurate, reliable, and consistent data. Without taking further
action, USPS may not be able to accurately assess its progress toward
meeting its goals--regardless of which goals it eventually adopts.
USPS Recently Refocused Its Attention on Environmental Matters,
including Mail-Related Recycling, and Intends to Require Recycling
Where Cost-Effective and Feasible:
While USPS has had a mail-related recycling program in place since the
1990s, security concerns arising from the introduction of anthrax in
the mail stream in 2001 caused USPS to deemphasize recycling until
recently, according to USPS officials. In December 2007, however, USPS
announced its intention to refocus its attention on environmental
matters, including the recycling of UAA mail and mail-related
materials.[Footnote 26] According to USPS, recycling will help protect
the value of Standard Mail as a form of advertising, generate
additional revenues, and reduce USPS' waste disposal costs. Recycling
UAA mail and other mail-related materials also provides USPS with a
means to enhance its long-standing commitment to environmental
leadership. Furthermore, recycling these materials appears to be
consistent with the Postmaster General's recent commitments to minimize
the agency's impact on every aspect of the environment and to act as a
positive environmental influence in U.S. communities.
As part of its refocused attention on environmental matters, in July
2007, USPS issued a revised policy--termed a Management Instruction--
that addresses its waste management issues.[Footnote 27] With respect
to recycling, the policy encourages district managers and installation
heads to establish recycling programs to collect UAA mail and discarded
lobby mail in central locations. While the policy indicates that
employees at USPS' plants and post offices "should recycle" these mail-
related materials, they are not required to do so if it is not cost-
effective or logistically feasible. For example, according to USPS
officials, recycling may not be cost-effective or logistically feasible
at facilities that lack storage space or generate a limited quantity of
recyclable mail-related materials.[Footnote 28]
The July 2007 policy superseded USPS' previous policy and guidelines,
issued in September 1995,[Footnote 29] which (1) were specific to
recycling mail-related materials and (2) provided significantly more
guidance on recycling UAA mail, discarded lobby mail, and facility
paper waste. In addition, while not explicitly stated, the 1995 policy
"technically required" facility managers to implement mail-related
recycling programs at all USPS facilities that generate these types of
waste, according to agency officials.
According to the prior policy, effective targeting of UAA mail can
achieve many objectives. For example, it "can help meet postal waste
reductions goals and implement more efficient and environmentally sound
alternatives to solid waste disposal practices." In addition, the 1995
policy noted that such an "effort saves [USPS] money in solid waste
disposal and reduces criticism that third-class [Standard Mail] mail
volumes contribute to municipal solid waste problems." Finally,
according to the prior 1995 policy, recycling UAA mail also enhances
the viability of Standard Mail as an environmentally friendly
advertising medium. To help USPS accomplish these objectives, the 1995
policy required facility managers to (1) keep records of revenues
generated by recycling, as well as the costs and quantities of solid
waste generated at their facilities; (2) conduct an annual evaluation
of their practices related to discarded mixed paper, disposal methods,
and recycling alternatives; and (3) supply information on their annual
evaluations, including the costs, volumes, disposal methods, recycling
alternatives, and barriers associated with implementing a mail-related
recycling program at their facilities to his or her district manager.
The prior policy also established others responsibilities. For example,
area managers were responsible for ensuring that facilities that
generate UAA mail conducted the annual evaluations and for assisting
district managers in finding markets for the material. USPS' latest
policy, issued in 2007, does not address these and other matters.
During the course of our work, we discussed differences between the two
policies with USPS officials, including the requirement for an annual
evaluation of facility practices related to discarded mixed paper.
According to USPS officials, the omission of this requirement was
unintended. To address this omission as well as others, the officials
indicated that USPS would develop a new policy that will, among other
things, (1) provide employees with specific information on how to
implement recycling programs at their facilities, (2) require USPS
facility managers to implement mail-related recycling initiatives
unless doing so is not cost-effective or logistically feasible, and (3)
specify requirements for reporting data on USPS' mail-related recycling
activities. USPS expects to release its revised policy, as well as
guidance for implementing its recycling program, later this year.
USPS Consolidated Contracts to Increase Its Recycling Revenue and
Reduce Its Waste Disposal Costs:
To increase its recycling revenues and reduce its waste disposal costs,
USPS began a multi-phased process to consolidate its waste disposal and
recycling contracts at USPS facilities nationwide. In the first phase,
completed in January 2006, USPS centralized its negotiation and
management of all waste disposal and recycling contracts at the
Memphis, Tennessee, Category Management Center (Memphis Center).
[Footnote 30] In the second phase, which recently began, the Memphis
employees are working with managers at facilities with existing waste
disposal and recycling contracts and are attempting to convince these
managers to incorporate their facilities within larger, regionally-
based USPS waste disposal and recycling contracts.[Footnote 31] Such
contract consolidations are consistent with our prior findings.
Specifically, in 2004, we reported that consolidating contracts allows
private-sector companies to leverage their buying power and identify
more efficient ways to procure goods and services.[Footnote 32]
The Memphis Center offers facility managers four types of contracts:
(1) waste disposal only; (2) removal of recyclables only; (3) removal
of waste and recyclables; and (4) Total Solid Waste Management
contracts, which cover both waste disposal and recycling.[Footnote 33]
In fiscal year 2007, the four types of contracts managed by the Memphis
Center resulted in approximately $6.6 million in recycling revenues
(about $6 million) and waste disposal cost savings (about $600,000).
Total Solid Waste Management contracts attempt to both (1) maximize
recycling revenues and (2) minimize waste disposal costs by using two
methods to collect and transport mail-related recycling materials. The
first method--"backhauling"--uses USPS' labor and existing
transportation network to collect and transport mail-related recyclable
materials from local USPS facilities (e.g., post offices) to a single
USPS location, such as a mail processing and distribution center, where
the materials are consolidated prior to USPS' subsequent delivery to a
paper mill or other vendor interested in purchasing the materials.
[Footnote 34] When consolidation at a single USPS facility is not
feasible, USPS uses a second method--"milk runs"--to collect its
recyclable materials. Milk runs use contractors, such as paper brokers
and other vendors, to collect recyclable materials stored at local USPS
facilities and transport them to their destination. USPS officials
stated that because the contractor uses its resources, including its
labor and transportation, to collect and transport the materials, USPS
must pay for these services--a factor that reduces both USPS' recycling
revenues and its savings from lower disposal costs.
Total Solid Waste Management contracts may include a shared savings
component with the contractor, whereby the contractor receives a
portion of USPS' recycling revenues and savings from lower waste
disposal costs. Cost-sharing arrangements are intended to encourage the
contractor to implement initiatives that maximize USPS' recycling
revenues while minimizing its waste disposal costs. One example of such
a contract is USPS' contract with Rand-Whitney, which covers 457
facilities throughout Pennsylvania. Rand-Whitney developed a recycling
program for each facility that, according to documentation supplied by
USPS, generated $177,000 in recycling revenues and reduced USPS' waste
disposal costs by $98,000--for a total financial benefit of $275,000
from July 2006 to June 2007. Because this contract allows Rand-Whitney
to share USPS' revenues and savings, Rand-Whitney received 25 percent
of this total, or approximately $69,000, during the 12-month period.
USPS Launched a Pilot Recycling Program in New York City:
In an attempt to demonstrate the value of mail-related recycling
programs, USPS began a pilot program in New York City in May 2007. The
goal of the pilot--termed "New York City SOARs!" (Saving of America's
Resources)--is to identify opportunities to establish and expand
recycling programs in USPS facilities throughout New York City and,
based on lessons learned, identify recycling practices that can be used
in other USPS facilities.[Footnote 35] USPS is implementing the pilot
in stages. The first stage assessed postal recycling activities
underway in each of New York City's five boroughs,[Footnote 36] using a
variety of factors, such as costs to USPS, feasibility (including
logistical considerations), and mission compatibility. The report on
the assessment, issued in September 2007, concluded that recycling in
New York City (1) can generate recycling revenues, (2) will
substantially reduce USPS' waste disposal costs, (3) will not interfere
with postal operations, and (4) will require only a "modest
incremental" effort to accomplish.
Based on the results of the first stage, the report suggested specific
recycling activities in each borough, including: (1) the initiation of
backhauling recycling programs for UAA Standard Mail and mail-related
materials in Manhattan, Brooklyn, and the Bronx, and the expansion of
the existing backhauling program in Queens; (2) the implementation of
milk runs for UAA Standard Mail and mail-related materials in Staten
Island; (3) the designation of sufficient loading dock space at USPS
processing and distribution centers in Manhattan to accommodate
trailers for storing and transporting mail-related recycling materials;
and (4) the establishment of recycling programs for discarded lobby
mail in all five boroughs. According to USPS, it is optimistic that, by
carefully implementing and enhancing mail-related recycling programs
throughout New York City, it could generate approximately $1.3 million
per year in recycling revenues and save an additional $800,000 in waste
disposal costs.[Footnote 37]
The pilot's second stage began in January 2008 and, in February 2008,
according to USPS officials, the agency issued a solicitation for a
contract to provide waste disposal and recycling services to USPS
facilities in four of New York City's five boroughs--Brooklyn, the
Bronx, Manhattan, and Queens. USPS expects the contract will begin in
October 2008. This pilot is in its early stages and, at the conclusion
of our review, USPS did not have a plan or timeline for, among other
actions, ending the pilot program or issuing a final report on the
pilot. Furthermore, it was not clear whether, or to what extent, USPS
would require its managers at other facilities to adopt--where
applicable, feasible, mission compatible, and appropriate in view of
cost and other considerations--lessons learned from the pilot.
USPS Has Implemented Tools to Track the Environmental Performance of
Its Areas and Districts:
USPS also has implemented tools for tracking the environmental
performance of its areas and districts. One such tool, called an
"environmental scorecard," tracks and ranks the environmental
performance of USPS' nine geographic areas.[Footnote 38] In fiscal year
2007, USPS used the tool to collect information needed to rank each
area's environmental performance in 12 general areas, such as pollution
prevention, that includes recycling.[Footnote 39] To measure
environmental performance at the district level, USPS also created a
budgetary line-item for tracking each district's recycling revenues.
USPS plans to share the results of both its environmental evaluation
tool and its analyses of the districts' recycling revenues (from the
budgetary line-item) with its postal managers. Because USPS officials
believe that the agency's employees are highly competitive, according
to USPS officials, relative differences between the areas and districts
are expected to foster competition and increase recycling revenues
throughout the postal network. While USPS currently does not use the
results of the environmental evaluation tool or its analyses of the
districts' recycling revenues for recognizing significant mail-related
recycling achievements, according to USPS officials, USPS could choose
to do so in the future. In the interim, according to these officials,
USPS (1) is considering establishing a program to nominate facilities,
teams, and individuals for environmental excellence in seven
environmental categories--one of which includes recycling--and (2) has
changed its accounting policy to allow districts to receive credit for
the revenue each district generates from recycling.
USPS Has Undertaken Two Multi-Faceted Initiatives to Increase the
Amount of Mail with Environmentally Preferable Attributes:
To increase the amount of mail with environmentally preferable
attributes, USPS has undertaken two multi-faceted initiatives.
Specifically, USPS (1) initiated a second Greening the Mail Task Force
to, among other activities, promote the use of environmentally
preferable attributes in mail and (2) established a UAA mail cost
reduction goal. It also has numerous actions underway that may help the
agency meet its UAA mail cost-reduction goal. Such actions include
USPS' implementation of a new mail processing method that identifies
and redirects incorrectly addressed mail to the intended addressee
before delivery is attempted. USPS also has taken other actions to
increase the amount of mail with environmentally preferable attributes.
We discuss these actions in appendix II of this report.
USPS Initiated a Second Task Force to Increase the Amount of
Environmentally Preferable Attributes in Mail:
In September 2007, USPS initiated a second Greening the Mail Task Force
to, among other goals, increase the amount of mail with environmentally
preferable attributes. As discussed earlier, USPS disbanded the first
task force in 1999 after it issued a final report that, among other
matters, identified environmentally preferable attributes associated
with mail. The most recent task force--formed to address mail-related
issues on a long-term basis--includes USPS officials, mailing industry
representatives, and other stakeholders. The task force has five
subcommittees, each with a different goal. Table 1 identifies each of
the subcommittees' relevant goals.
Table 1: Relevant Goals of the Five Greening the Mail Task Force
Subcommittees:
Subcommittee: Education and Awareness on Sustainability and Value of
the Mail;
Relevant goals[A]:
* Promote awareness that mail is recyclable;
* Encourage enhanced environmental mail designs;
* Encourage better address accuracy;
* Provide accurate information to policy makers, mailers, and the press
on the benefits of mail.
Subcommittee: Improving Mail Recyclability and Source Reduction;
Relevant goals[A]:
* Assess the recyclability of mail products;
* Identify recycling barriers;
* Evaluate the conditions that impact successful mail delivery;
* Identify ways to reduce UAA mail;
* Minimize the environmental impacts associated with mail.
Subcommittee: Recycling Collection of the Mail;
Relevant goals[A]:
* Increase paper recycling by implementing and supporting mail
recycling initiatives in postal facilities, office buildings, and
private residences.
Subcommittee: Life-Cycle Analysis of Mail;
Relevant goals[A]:
* Provide the mailing industry's perspective on the "life-cycle
inventory"[B] of mail and, if possible, conduct a full "life-cycle
analysis" of the mail.[C].
Subcommittee: Standards and Certification;
Relevant goals[A]:
* Facilitate the identification and creation of environmental
sustainability standards;
* Facilitate a certification process for the life cycle of mail.
Source: GAO analysis of Greening the Mail Task Force documentation.
[A] For the purposes of this table, we have excluded goals that are not
relevant to the topics discussed in this report.
[B] According to USPS, a life-cycle inventory of the mail attempts to
identify emissions of significant pollutants throughout the entire
"life-cycle" of the mail, including emissions resulting from harvesting
trees for paper; making the paper; turning the paper into mail;
processing, sorting, and distributing the mail to consumers; and the
end of the life-cycle--when the mail is eventually discarded.
[C] A life-cycle analysis is similar to a life-cycle inventory, but is
more costly, complex, and comprehensive to perform. If the life-cycle
inventory shows that mail significantly impacts the environment,
according to USPS, a life-cycle analysis would be conducted. At the
conclusion of our review, we were unable to ascertain how such an
analysis would affect mail-related processes and practices.
[End of table]
USPS Established a UAA Mail Cost Reduction Goal, and Actions Are
Underway That May Help USPS Meet This Goal:
USPS established a UAA mail cost-reduction goal in 2006 and has
developed numerous tools that mailers can use to improve the accuracy
of their mailing lists and reduce the amount of UAA mail they
send.[Footnote 40] More recently, USPS introduced two new requirements
that are expected to help USPS meet its UAA mail cost-reduction goal.
In addition, USPS has implemented a new mail processing method that
identifies and redirects incorrectly addressed mail to the intended
addressee before delivery is attempted.
USPS Established a UAA Mail Cost-Reduction Goal:
In addition to its recent establishment of goals for increasing the
revenue USPS generates from recycling mail-related materials, in 2006,
USPS set a goal of reducing UAA mail by 50 percent by fiscal year 2010.
In the summer of 2007, USPS clarified this goal, specifying that it
applied to the cost--not the volume--of UAA mail. USPS is developing
measures to accurately assess its progress in meeting the UAA mail cost
reduction goal. According to USPS, its interim measures are not
sufficient for this purpose; however, USPS officials believe that data
from its May 2009 deployment of Intelligent Mail, which we discuss
later in this report, will provide data needed to accurately measure
its progress in meeting this goal.
USPS' Tools for Improving the Accuracy of Mailing Lists Reduce UAA
Mail:
USPS has developed numerous tools that mailers can use to increase the
amount of mail that is accurately addressed for delivery. Mail that is
accurately addressed decreases UAA mail volume, which, in turn,
decreases USPS' operational and waste disposal costs. Since these
address accuracy tools decrease USPS' operational costs, USPS provides
lower postage rates (worksharing rates)[Footnote 41] to mailers who use
them. A partial description of some of USPS' address accuracy tools
follows:
* "Address Element Correction" identifies mailpieces that are
potentially UAA and corrects small errors in the addresses (e.g., the
omission of a directional indicator such as "NW," or errors that refer
to an avenue as a street).
* "Delivery Point Validation" verifies that the address on a mailpiece
exists in USPS' database of addresses to which it delivers.
* "National Change-of-Address LINK" allows mailers to check their
mailing lists against USPS' National Change-of-Address database, which
contains updated address information for mail recipients who have filed
change-of-address notices with USPS.
* "Address Change Service" allows mailers to receive, for a fee,
electronic notices that inform them when USPS cannot deliver their
mailpieces. For First-Class Mail, these electronic notices reduce the
amount of mail USPS must return to the sender, thereby decreasing UAA
mail and USPS' operating costs. For Standard Mail--which USPS generally
is not obligated to return to the sender--the electronic notices (1)
inform mailers when their Standard mailpieces are UAA and (2) provide
mailers with the correct addressing information. This information
enables Standard mailers to update their mailing lists with corrected
addresses prior to their next mailing, thereby reducing future UAA mail-
related costs.
USPS Introduced Two New Requirements That Are Expected to Reduce UAA
Mail:
USPS also introduced two recent changes that, according to USPS
officials, will reduce UAA mail and, consequently, help USPS meets its
UAA mail cost reduction goal (i.e., a 50 percent reduction by fiscal
year 2010). First, USPS has revised its "Move Update" requirement,
which currently obligates First-Class mailers to use at least one
approved address accuracy tool (such as National Change-of-Address LINK
or the Address Change Service) to qualify for worksharing rates. In
September 2007, USPS expanded this requirement to include mailers who
send Standard Mail, effective November 23, 2008. Furthermore, USPS will
begin requiring First-Class and Standard mailers to update their
mailing lists--using an approved address accuracy tool--95 days prior
to each of their mailings.[Footnote 42]
Second, beginning in May 2009, USPS intends to require mailers to use a
new barcode--called the "Intelligent Mail Barcode"--on their mailpieces
to qualify for worksharing rates. According to USPS officials, the new
barcode will allow USPS and mailers to track individual mailpieces as
they move through the mail stream. USPS officials believe that the
capability to track mailpieces will reduce UAA mail volumes--and,
potentially, USPS operating costs--because mailers will be able to use
the barcode to determine which of their mailpieces cannot be delivered
and correct their mailing lists accordingly. USPS has initiatives
underway, including an agreement with the Bank of America, to test the
effectiveness of the Intelligent Mail Barcode before it is fully
implemented.[Footnote 43]
USPS Has Implemented a Method to Identify and Redirect Improperly
Addressed Mail before Delivery Is Attempted:
In September 2007, USPS also implemented a new, nationwide mail
processing method--called the "Postal Automated Redirection System"--
that identifies and redirects mailpieces to individuals who have moved.
According to USPS, if a mail recipient has moved and filed a change-of-
address request with USPS, the automated redirection system identifies
mailpieces addressed to his or her prior address when these mailpieces
first enter the mail stream and initiates one of three possible
actions. The first possible action is for USPS to immediately redirect
the mailpiece to the new, correct destination. Second, if the mailpiece
is not eligible for forwarding or if the mailer has authorized its
disposal, USPS would remove the mailpiece from the mail stream and
discard it. Finally, if requested by the mailer, USPS would return the
mailpiece to the mailer (i.e., the sender). In the past, USPS
redirected mailpieces only after delivery had been attempted. In such
cases, Standard Mail was returned to the postal facility and discarded
as waste (and disposed of through recycling or some other means), while
First-Class Mail was processed and forwarded, returned to the sender,
or sent to a mail recovery center. Because USPS generally does not
forward or return UAA Standard Mail--regardless of when it is first
detected--the automated redirection system will not reduce the amount
of UAA Standard Mail that USPS must eventually discard. However, USPS
officials believe the automated redirection system will reduce the cost
of processing UAA mail, thereby contributing to the agency's UAA mail
cost-reduction goal.
The Mailing, Paper Recycling, and Environmental Advocacy Industries
Have Undertaken Several Key Initiatives to Increase Mail-Related
Recycling:
In addition to USPS' efforts, the mailing industry and other
stakeholders have undertaken several key initiatives to increase the
volume of mail-related materials that are recycled. Some of these
initiatives were developed by mailing industry associations, while
others are the result of efforts by individual mailers and
organizations in the paper and environmental advocacy industries. For
example, in 2007, the Direct Marketing Association (DMA), the Envelope
Manufacturers Association, and the Magazine Publishers of America
developed nationwide mail recycling awareness campaigns.[Footnote 44]
While similar in nature, the three programs use different logos to
increase recycling awareness and are intended for different types of
mailpieces (e.g., catalogs, envelopes, and magazines).[Footnote 45] DMA
members who participate in the association's "Recycle Please" program
are expected to include a logo in their catalogs and other mailpieces
to encourage mail recipients to recycle their mailpieces after reading
them. The envelope association's program--called "Please Recycle"--
promotes mail recycling by encouraging manufacturers to place a
recycling logo on the front of envelopes and other packaging materials.
Finally, the magazine association--which also calls its program "Please
Recycle"--developed recycling logos and a full-page recycling
advertisement that the association encourages its members to include in
their magazines in order to increase the volume of magazines recycled.
Participation in these recycling awareness campaigns varies.
Specifically, based on our calculations of data provided by officials
from DMA and the envelope and magazine associations, as of mid-March
2008, about 2 percent, 30 percent, and 10 percent of their members
participated in these programs, respectively.[Footnote 46] (The logos
used for these recycling awareness campaigns are depicted in fig. 1 of
app. III.)
The second key recycling initiative involves the National Recycling
Coalition,[Footnote 47] which intends to develop new recycling logos to
replace the familiar "chasing arrows" logo currently displayed on many
products. According to coalition representatives, one of the new logos
will be specific to mail. The coalition believes that this logo--which
has been used for many years--is confusing to the public. According to
coalition officials, the logo has been repeatedly altered by product
manufacturers and others since it was first introduced and, as a
result, multiple versions of the logo currently exist, each of which
signifies different meanings depending on its use.[Footnote 48] By
updating the existing logo, the coalition hopes to, among other
intentions, enhance consumer awareness that mail can be recycled.
(Examples of selected "chasing arrows" recycling logos are depicted in
fig. 2 of app. III.)
Finally, in 2004, Time, Inc.; Verso Paper; and the National Recycling
Coalition, among other parties, initiated the "Recycling Magazines is
Excellent" project to inform consumers--primarily via advertisements in
magazines--that catalogs and magazines are recyclable.[Footnote 49]
These parties have piloted the project in five areas: Boston,
Massachusetts; Prince George's County, Maryland;[Footnote 50] Portland,
Oregon; Milwaukee, Wisconsin; and New York City, New York. According to
a Time, Inc., official, in Boston, Portland, and Prince George's
County, the program increased magazine recycling by 18 percent, 6
percent, and 19 percent, respectively. Data for the Milwaukee and New
York City pilots were not available at the conclusion of our review.
The Mailing Industry and Other Stakeholders Have Undertaken Several Key
Initiatives to Increase the Amount of Mail with Environmentally
Preferable Attributes:
In addition to their efforts to increase mail-related recycling, the
mailing industry and other stakeholders have undertaken a variety of
key initiatives to increase the amount of mail with environmentally
preferable attributes. As described below, DMA is responsible for
several of these initiatives. Other stakeholder initiatives, including
those of individual mailers, environmental organizations, and other non-
profit organizations are discussed in appendix IV of this report.
DMA Has Undertaken Several Key Initiatives to Increase the Amount of
Mail with Environmentally Preferable Attributes:
DMA has undertaken several key initiatives to increase the amount of
mail with environmentally preferable attributes, particularly with
respect to improving its members' mail targeting practices and the
accuracy of their mailing lists. The first such effort, the Mail
Preference Service,[Footnote 51] was introduced in 1971 and is a list
of consumers who have requested not to receive (i.e., opt-out of)
"prospecting mail" sent by DMA members.[Footnote 52] DMA requires its
members to honor such requests and, consequently, forbids its members
from selling or exchanging this list for any purpose other than
removing prospective customers from their mailing lists.[Footnote 53]
According to DMA officials, by eliminating prospecting mail, the
Service (1) reduces the amount of mail a consumer receives by
approximately 80 percent and (2) prevented 930 million pieces of
unwanted mail from entering the mail stream in 2007.[Footnote 54] While
DMA officials stated that the association works with consumer advocacy
groups and other parties to inform consumers about the Mail Preference
Service,[Footnote 55] a recent study conducted by Pitney Bowes
indicates that two-thirds of Americans are not aware of the Service's
existence. In part to address this lack of awareness, several parties
within the environmental advocacy industry recently implemented other
opt-out programs. As noted previously, these programs are discussed in
appendix IV of this report.
More recently, DMA formed the Committee on Environment and Social
Responsibility, which is comprised of 16 executives from DMA's member
organizations. Formed in 2005, the committee's goals are to identify
challenges that direct marketers face with respect to "social
responsibility" issues, such as environmental sustainability and
corporate citizenship issues, and to develop guidance to address these
challenges. The committee designed and executed a survey to benchmark
the environmental practices of its members and developed a Web-based
tool to help members evaluate their environmental practices in five
areas: (1) paper procurement and use, (2) address quality (accuracy)
and data management, (3) design, (4) packaging and printing, and (5)
recycling and pollution reduction. The tool also enables mailers to
create an environmental vision statement or policy statement for, among
other purposes, displaying on their Web sites. DMA officials could not
supply data on the extent to which its members use this tool.
In 2007, DMA also passed the "Resolution Asserting Environmental
Leadership in the Direct Marketing Community." The resolution calls on
DMA members--by June 2008--to voluntarily establish internal
measurements and benchmarks for assessing their business practices with
respect to a list of 15 environmentally preferable practices. This
list--called the "Green 15"--aligns with mailer business activities,
such as paper procurement and use, mailing list accuracy, and mailpiece
design. While the adoption of the 15 environmentally preferable
practices is generally voluntary, in June 2008, DMA intends to
establish goals and timetables for measuring its members' success in
implementing these practices, which, according to DMA officials, could
lead to future DMA requirements.[Footnote 56] DMA officials stated
that, thus far, members generally have reacted positively to the list
of 15 preferable practices, although some members have expressed
concerns about purchasing recycled and certified paper. Specifically,
members expressed concerns that (1) the supply of these products may
not be sufficient to meet demand if DMA were to require its members to
use them; and (2) due to the number of forest certification programs
and the controversy over the programs' various merits, it is not clear
which program they should use.[Footnote 57] (For more information on
the Green 15, see app. V of this report.)
Finally, in October 2007, DMA launched its "Commitment to Consumer
Choice" program. Under this program, DMA members must, among other
actions, include--on every direct mail solicitation they send--an
option for consumers to opt-out of receiving future direct mail
solicitations from that member, regardless of whether the member has
previously established a business relationship with those customers.
[Footnote 58] The new requirement, effective in October 2009, will
strengthen DMA members' current obligation to provide mail recipients
with one opt-out notice per year. The Commitment to Consumer Choice
program also includes several other requirements related to consumer
choice. Some of these requirements are new or modified, while others
are long-standing.[Footnote 59] For example, DMA members must (1)
disclose, upon consumer request, the source from which they obtained
data about the consumer; (2) eliminate, upon consumer request, the
transfer or rental of the consumer's personal information to other
marketers; (3) increase the frequency with which they update their
mailing lists against information in DMA's Mail Preference Service opt-
out database (from a quarterly to a monthly basis); and (4) act on all
customer opt-out requests within 30 days and for a period of at least 3
years.[Footnote 60]
According to DMA officials, DMA has an internal process for ensuring
that members comply with its requirements.[Footnote 61] The process
begins with DMA's Corporate Responsibility group, which receives all
customer complaints regarding the receipt of unwanted mail.[Footnote
62] If a pattern of complaints about a company emerges, DMA officials
stated that the group would file a formal case before DMA's Committee
on Ethical Business Practices.[Footnote 63] If the offending mailer
still refuses to comply with DMA requirements, DMA's Board of Directors
can, among other actions, expel the mailer from the association.
According to DMA officials, however, member expulsions are rare. The
officials explained that the association's goal is self-correction, not
punishment, and that mailers normally alter their practices to avoid
expulsion from DMA.
Stakeholders Cited Five USPS Mail-Related Recycling Opportunities, but
USPS Would Need to Assess Several Factors in Deciding Whether to Adopt
Them:
USPS, mailing industry, and other stakeholders we spoke to identified
five opportunities that USPS could choose to undertake to increase its
recycling of mail-related materials and to encourage mailers to
increase the amount of mail with environmentally preferable attributes.
[Footnote 64] The five opportunities cited most frequently were for
USPS to (1) implement a program for recognizing mail-related recycling
achievements; (2) increase awareness among mail recipients that mail is
recyclable and encourage them to recycle their mail through, among
other actions, collaboration with mailing industry and other
stakeholder initiatives; (3) collaborate with parties interested in
increasing the supply of paper fiber available for recycling; (4)
establish a special, discounted postal rate--or Green Rate--as a means
of inducing mailers to adopt one or more environmentally preferable
attributes in their mailpieces; and (5) initiate a mail take-back
program in locations that do not have access to municipal paper
recycling. Each of these opportunities appears to be consistent with
(1) the agency's long-standing commitment to environmental leadership
and (2) the Postmaster General's recent commitments to both minimize
the agency's impact on every aspect of the environment and to act as a
positive environmental influence in U.S. communities. Based on our
analysis, however, USPS would need to assess factors such as costs to
USPS; feasibility, including logistical considerations; and mission
compatibility in deciding whether to adopt the opportunities.
Stakeholders Identified Five USPS Opportunities:
The stakeholders we interviewed identified five opportunities that USPS
could chose to undertake to increase its recycling of mail-related
materials or to encourage mailers to increase the amount of mail with
environmentally preferable attributes. First, several stakeholders
stated that USPS could increase its mail-related recycling activities
by offering recognition, financial awards, promotional opportunities,
and other incentives to reward exemplary USPS recycling achievements.
Three USPS officials stated that such incentives could target facility-
level managers and employees, who are likely to be critical to the
successful implementation of mail-related recycling programs. As
discussed, USPS is considering establishing a program to nominate
facilities, teams, and individuals for environmental excellence. As
currently envisioned, the program would honor excellence in seven
environmental categories, including "pollution prevention." While USPS
is contemplating recognition for "improvements in recycling processes
or programs" as part of its achievements related to pollution
prevention, the program under consideration does not specifically
recognize mail-related recycling achievements. An incentives program
targeted specifically toward such achievements could foster greater
competition throughout USPS, resulting in substantial increases in the
agency's recycling revenue and significant savings in its waste
disposal costs. Such a program could be based solely on recycling
revenues, or include other metrics--such as the amount (tonnage) of
materials recycled or its savings in waste disposal costs.
Second, because mail recipients often are unaware that mail can be
recycled, stakeholders suggested that USPS conduct a campaign to
increase awareness among mail recipients that mail is recyclable and to
encourage them to recycle their mail. Such a campaign could be
collaborative in nature, unilateral, or undertaken through some
combination of outreach efforts. For example, several stakeholders
stated that USPS could collaborate with one or more of the ongoing
mailing industry and other stakeholder initiatives to increase
recycling awareness among mail recipients and to encourage them to
recycle.[Footnote 65] Such an effort, among other matters, could (1)
address common misconceptions related to the recyclability of various
types of mail and (2) raise awareness about the primary causes of
identity theft--two reasons why recipients may not recycle their mail.
In addition, USPS could collaborate with members of the Greening the
Mail Task Force to design and implement a plan to increase the public's
awareness in these and other areas.[Footnote 66] If USPS desired to do
so, stakeholders suggested that the agency also could take unilateral
action to promote mail recycling by, for example, delivering an
informational post card or some other form of communication to each
address in America. Such an approach would be similar to USPS' actions
to promote its various products and services nationwide, which,
according to USPS officials, typically increase consumer awareness by
nearly 30 percent. Stakeholders also suggested that USPS develop
postmarks and stamps and install signage in postal lobbies to promote
mail recycling.
Third, numerous stakeholders suggested that USPS collaborate with
parties, such as the American Forest and Paper Association and U.S.
paper recycling companies, to increase the supply of fiber needed for
manufacturing recycled paper products. According to these stakeholders,
such fiber is typically in short supply domestically because it is
usually exported to countries, such as China and India, which pay
premium prices for the fiber. The stakeholders added that the constant
supply of UAA mail available through USPS could be used to increase the
domestic supply of recycled fiber. Such a supply increase could
potentially decrease the cost of using recycled paper products which,
in turn, could encourage their increased use.[Footnote 67] One way for
USPS to undertake this opportunity is to collaborate with the American
Forest and Paper Association, which, according to association
representatives, is eager to increase mail-related recycling.[Footnote
68] Such a collaboration, they said, would contribute to the
association's goal of recovering (i.e., preventing landfill disposal or
incineration) 55 percent of paper consumed in the United States by
2012. In addition, USPS could collaborate with members of its Greening
the Mail Task Force to design and implement a plan to increase the
supply of paper fiber available for recycling.[Footnote 69] USPS also
could choose to explore, or expand, partnerships with local recyclers.
One paper recycling company in New Jersey, for example, purchases and
transports UAA mail from USPS facilities in Maryland, Pennsylvania, New
Jersey, and elsewhere to manufacture recycled paper products, such as
paper towels, toilet paper, facial tissue, and napkins. According to a
company representative, because UAA mail is a critical feedstock for
the company's production methods, the company would like to increase
its supply of UAA mail as long as the cost of transporting UAA mail to
the company does not become prohibitive.
Fourth, numerous stakeholders in the environmental advocacy industry,
suggested that USPS establish a special, discounted postal rate--or
Green Rate--as a means of inducing mailers to adopt one or more
environmentally preferable attributes in their mailpieces. According to
these parties, for example, USPS could establish a special discount for
mailers that use recycled and/or certified paper. Such a discount, they
said, would help mailers offset the increased costs associated with
using recycled paper and would provide an incentive for mailers to use
certified paper.[Footnote 70] A Green Rate also could reward mailers
who, among other practices, (1) use certain targeted marketing
strategies, (2) can demonstrate measurable reductions in the amount of
UAA mail they send, and (3) use mail materials efficiently. With
respect to targeted marketing strategies, for example, a Green Rate
could reward mailers who voluntarily participate in mail opt-out
programs--such as the program offered by Catalog Choice[Footnote 71]--
and can demonstrate that they honor mail recipients' requests to be
removed from their mailing listings.[Footnote 72] A Green Rate also
could reward mailers who, over time, reduce the amount of UAA mail they
send. Beginning in May 2009, USPS intends to use its Intelligent Mail
Barcodes to establish large mailers' UAA mail rates (the baseline) and,
over time, measure changes in the frequency of the mailers' UAA mail.
While large mailers will be required to use the barcodes to receive
worksharing rates for their mailings, USPS also could choose to use
these data to reward mailers who meet a specified target for UAA mail
reductions. In addition, if USPS chose to do so, it could reward
mailers according to a "sliding scale," whereby mailers would receive
larger discounts for greater UAA mail reductions.[Footnote 73] A final
example of practices that could be considered for a Green Rate is the
use of two-way reusable envelopes and other mailpieces that use
materials efficiently.
Finally, numerous stakeholders suggested that USPS, using its existing
transportation network, initiate a mail take-back program to facilitate
the recycling of discarded and unwanted mail in rural, sparsely
populated areas that do not have access to municipal paper recycling.
[Footnote 74] While the details of such a program would need to be
developed, stakeholders suggested that USPS--possibly, in collaboration
with others--could supply mail recipients in these locations with pre-
addressed packages to send their discarded mail either directly to a
plant for recycling or, indirectly, to other facilities--including,
possibly, USPS facilities--where the packages could be held for
subsequent pick up and recycling. Conceptually, such a program
resembles several existing take-back programs for used products--such
as inkjet cartridges, digital cameras, and cellular phones--whereby the
program sponsor (e.g., a manufacturer) supplies the consumer with a pre-
paid and pre-addressed envelope for returning used products through the
U.S. mail. Stakeholders noted that USPS receives revenue for returning
the products under the existing take-back programs and, depending on
how such a program is funded, also could receive revenue under a take-
back program for mail.
USPS Would Need to Assess Several Factors in Deciding Whether to Adopt
the Opportunities:
Each of the five stakeholder-identified opportunities appears to be
consistent with (1) the agency's long-standing commitment to
environmental leadership and (2) the Postmaster General's recently
expressed commitment to minimize USPS' impact on every aspect of the
environment and to act as a positive environmental influence in U.S.
communities. However, based on our analysis, USPS would need to assess
factors such as cost; feasibility, including logistical considerations;
and mission compatibility in deciding whether to adopt the
opportunities.
Cost Considerations:
Each of the five opportunities has overall cost considerations given
their likely impact on staff and other resources that would be needed
to, among other actions, develop plans, procedures, and agreements for
implementing them. USPS also would need to identify the staff and
offices responsible for successfully initiating and carrying out the
opportunities, and provide training as appropriate. In addition, while
the costs associated with implementing a program for recognizing mail-
related recycling achievements are likely to be minimal (and more than
offset by increases in USPS' revenues), the remaining four
opportunities necessitate additional cost consideration. For example,
two of the opportunities--increasing awareness about mail recycling and
initiating a Green Rate--appear to have little likelihood of increasing
the agency's revenue. Furthermore, the remaining two opportunities--
collaborating with parties interested in increasing the supply of paper
fiber available for recycling and initiating a mail take-back program-
-may not generate sufficient revenues to cover their costs. Depending
on the magnitude of variance between the expected costs and revenues,
USPS may find implementing one or more of the opportunities
unacceptable. This is, in part, because as we recently testified, USPS
faces multiple short-and long-term pressures in improving its
operational efficiency, increasing its revenues, and controlling its
costs--some of which are increasing faster than the overall inflation
rate.[Footnote 75] In addition, unlike in the past, USPS is now subject
to an inflation-based cap on the prices it can charge for its goods and
services. Specifically, the 2006 Postal Accountability and Enhancement
Act includes an annual limitation on the average percentage changes in
rates for each market-dominant mail class--such as First-Class Mail and
Standard Mail--which is linked to the change in the Consumer Price
Index for All Urban Customers.[Footnote 76]
In addition to these overall cost considerations, three of the five
opportunities have additional cost-related factors that USPS would need
to assess prior to deciding whether to adopt them.[Footnote 77] First,
while the cost of collaborating with other entities to increase
recycling awareness among mail recipients and to encourage mail
recipients to recycle their mail could be minimal, according to a USPS
official, each of its recent nationwide promotional campaigns (which do
not involve collaboration) cost USPS approximately $2.1 million. Such
costs, however, may be overstated with respect to a recycling campaign
because USPS could choose, in collaboration with others, to target only
mail recipients in zip codes that do not have access to municipal paper
recycling (about 14 percent of the U.S. population). Furthermore, USPS
could elect to "piggyback" a recycling awareness message on another of
its promotional mailings, which, by itself, would result in little
additional cost. However, according to USPS officials, such a
promotional campaign would necessitate the use of recycled paper to
remain consistent with the agency's recycling awareness message. As
previously stated, using recycled paper is more expensive than using
virgin paper and, thus, would increase the cost of such a campaign.
Second, because establishing a special discount to induce mailers to
adopt more environmentally preferable business practices would--absent
other actions--reduce USPS revenues,[Footnote 78] USPS would have to
assess the overall affects of such a discount on its financial
position. In addition, USPS would need to assess the specific cost
implications associated with each environmentally preferable attribute
it chooses to include in a Green Rate. For example, if USPS were to
consider allowing mailers who, among other attributes, use certain mail
targeting strategies to qualify for a Green Rate (e.g., participation
in voluntary opt-out programs), USPS would need to assess whether, and
to what extent, doing so would reduce its revenues. USPS also would
need to assess the costs associated with, among other of its
activities, defining a Green Rate (i.e., determining which
environmentally preferable attributes mailers must use to qualify for
the discount) and, to avoid potential abuse, ensuring that the
mailpieces presented by mailers as "green" actually qualify for the
discount.
Finally, initiating a mail take-back program in locations that do not
have access to municipal paper recycling could greatly increase USPS'
costs and workload. The extent of these increases would depend on a
variety of factors, including (1) the volume of additional mail
generated by the program; (2) the characteristics, including the
dimensions and weight, of the take-back packages that would require
processing and delivery; (3) whether the packages would need to be
manually processed;[Footnote 79] (4) the frequency with which each
package needs to be handled; and (5) the distance the packages need to
be transported.[Footnote 80] First, depending on the rate of program
participation, the volume of mail requiring USPS processing and
delivery could increase substantially. In addition, because the intent
of such a program is for a mail recipient to combine all of the mail
they discard during a given time frame into a single package, the
package would greatly exceed the weight of typical mailpieces received
by the recipient.[Footnote 81] Furthermore, because communities that do
not have access to paper recycling are typically in rural, sparsely
populated areas, the increased volume of larger and heavier mailpieces
probably would travel long distances before reaching their final
destination, thereby increasing USPS' transportation costs throughout
the journey. The volume, weight, and size of these packages also could
overwhelm USPS' service capacity in certain rural locations. Rural
postal delivery service is typically carried out by USPS letter
carriers using privately-owned vehicles that may not be capable of
accommodating the increased volume, weight, and size of the take-back
packages.[Footnote 82] Thus, USPS may incur costs for additional
vehicles or changes in its operational arrangements with its rural
postal carriers. Finally, the packages mailed by recipients would not
be presorted and, depending on how the program is implemented, may not
be barcoded--two factors that would require more costly, manual
processing before delivery.
Feasibility Considerations:
Four of the five stakeholder-identified opportunities also have issues
related to their feasibility, which USPS would need to assess prior to
their adoption.[Footnote 83] For example, if USPS chose to implement a
program for recognizing mail-related recycling achievements, such as an
incentive program for facility-level managers and employees, it would
first need to collect the data needed to do so. The two existing
sources for USPS recycling data--the agency's evaluation tool for its
areas and the budgetary line-item for its districts--do not include
facility-level data. Furthermore, collecting this data may not be
feasible due to staffing constraints and the large number (about
37,000, according to USPS) of postal facilities nationwide. In light of
this feasibility limitation, however, and given USPS' goal of earning
$40 million in recycling revenue in fiscal year 2010 from its
districts' efforts (approximately $500,000 per district), the agency
could, instead, focus on recognizing the significant achievements of
its district managers and employees. A district-level incentives
program, however, has its own feasibility constraints. For example, to
help ensure equity in such an incentives program, USPS would need to
resolve several factors related to the program's successful
implementation. Specifically, USPS likely would need to make
adjustments for large, regional variations in the price paid for
recyclable mail-related materials.[Footnote 84] If USPS did not
consider these variations, an incentives program based solely on
revenue generated from mail-related recycling would seriously
disadvantage certain districts. One possibility for resolving this
issue may be to structure an incentives program on other metrics, such
as the total tonnage of material recycled or a district's savings in
waste disposal costs, either in lieu of, or addition to, recycling
revenues. However, such an action would introduce other issues related
to the opportunity's feasibility because, according to USPS officials,
USPS does not currently require its organizations, including its
districts, to (1) report their recycling tonnage or savings from waste
disposal costs[Footnote 85] or (2) collect and report their recycling
data using consistent methods.[Footnote 86] The Manager of USPS'
Environmental Policy and Programs organization told us that the agency
intends to require its area managers to report information on their
recycling tonnage, in addition to their recycling revenue and waste
disposal costs, but at the conclusion of our review, USPS had not
required these managers to do so.
Second, if USPS chose to coordinate with parties, such as domestic
recyclers, to increase the supply of fiber available for paper
recycling, it would need to resolve a multitude of logistical
considerations. For example, (1) Where will USPS store its mail-related
materials for recycling? (2) Is sufficient storage available within
USPS facilities? (3) Who will load the materials for delivery to the
recycler? (4) Who will be responsible for transporting the materials
and how will the deliveries be accomplished? and (5) Given space
constraints, how often will the materials need to be transported, and
to whom? Furthermore, to the extent that USPS facilities, vehicles, and
other materials (e.g., crates and moveable carts) are used, the agency
would need, among other actions, to develop a method for sharing its
costs with recyclers and others who benefit directly from its efforts.
If USPS were to undertake this opportunity with a goal of recycling
domestically--as recommended by some stakeholders--USPS may also wish
to explore arrangements to recoup a portion of any reduction in its
revenues attributable to using domestic recyclers. If USPS did not use
its staff or if sufficient and capable staff is not available to
undertake these and other efforts, USPS could hire a third party to
identify locations where this opportunity may be feasible to implement
and, in such cases, act as USPS' intermediary in addressing these and
other logistical considerations.[Footnote 87]
Similarly, if USPS chose to establish a Green Rate, the agency would
need to resolve a wide range of issues related to the feasibility of
doing so. For example, USPS would need to assess whether a discount for
mailpieces with certain environmental attributes is the appropriate
mechanism for promoting environmentally preferable business practices.
If USPS were to proceed, it would need to define the parameters of the
discount and, to avoid abuse, determine how it would ensure that mail
presented as "green" actually qualifies for the discount. Several
stakeholders expressed particular concern about the feasibility of
enforcing a Green Rate, indicating that such a task would be
administratively difficult and, possibly, impossible to accomplish.
Finally, to determine whether a Green Rate is feasible, USPS would need
to (1) assess the impact of such a discount on its net revenues and
existing postal rates; (2) determine whether, and to what extent, a
Green Rate would affect its market-dominate products, which are subject
to an annual inflation-based price cap; and (3) if the establishment of
the discount resulted in the need to raise postal rates, evaluate
whether USPS would be able to raise rates in accordance with the
requirements in Postal Accountability and Enhancement Act.
Finally, to initiate a mail take-back program, USPS would need to
consider the logistics and overall feasibility of collecting and
transporting the increased volumes of larger and heavier mailpieces
through the mail stream. USPS, probably in collaboration with others,
also would need to determine how the program would work--which likely
would be a complex arrangement. For example, what classes of mail would
the program cover? Who would supply the packages and postage needed to
return the discarded mail? How would the appropriate postage be
determined? Furthermore, where would the packages be sent, and to how
many locations? In addition, to estimate its costs, USPS would need to
develop, among other factors, a method for estimating (1) the number of
mail recipients who would participate in the program and (2) the
volume, size, and weight of their discarded mail take-back packages.
While these considerations are numerous, the most serious question with
respect to the program's feasibility is "Who will pay the substantial
costs associated with implementing the program?"
USPS has three options to cover the costs of a mail take-back program.
First, USPS could explore increases in its postage rates for the
applicable classes of mail--an action that mailing industry
stakeholders would likely strongly oppose. Furthermore, it may not be
feasible to raise these rates because of a limitation specified in the
Postal Accountability and Enhancement Act. Second, while USPS could
require mail recipients to pay the postage needed to cover the
program's costs, such an action, in our view, would greatly diminish or
eliminate public participation. As we reported in 2006, one key to
increasing the volume of materials recycled is to offer financial
incentives to increase recycling. Thus, a mail take-back program that
departs from this premise is, in our view, unlikely to succeed.
Finally, USPS could solicit funding from other parties, such as
communities, federal and non-profit organizations, businesses,
environmental organizations, Congress, and other interested parties.
While USPS could explore this option, it is unclear whether other
parties would find it in their best interest to fund such a program.
[Footnote 88]
Mission Compatibility Considerations:
While each of these opportunities appears to be consistent with the
agency's environmental commitments, including the Postmaster General's
recent commitments to both minimize the agency's impact on every aspect
of the environment and to act as a positive environmental influence in
U.S. communities, it is unclear to what extent USPS views actions to
fulfill these commitments as being compatible with its mission and
strategic goals. Similarly, it is not clear whether, or to what extent,
USPS would be willing to sacrifice revenue and/or incur additional
costs to further its environmental commitments.
In addition, two of the five stakeholder-identified opportunities--the
establishment of a mail take-back program and a Green Rate for
mailpieces that incorporate a variety of environmentally preferable
attributes--would necessitate additional cost considerations. First,
several mailing industry stakeholders told us that they strongly oppose
a Green Rate, in part, because of mission compatibility concerns.
According to these stakeholders, unlike worksharing rates that reward
mailers for reducing USPS' costs, a Green Rate discount does not align
with USPS' primary mission of delivering the mail. In addition, they
said that market forces and mailer preferences--not the establishment
of a Green Rate--should determine whether mailers choose to include
environmentally preferable attributes in their mailpieces. Depending on
how USPS chose to define a Green Rate, some specific aspects of the
definition could cause additional mission compatibility concerns. For
example, if the use of certified paper was included in a Green Rate,
USPS lacks the expertise needed to evaluate the relative merits of the
various--and controversial--certification programs.[Footnote 89]
Likewise, if a Green Rate incorporated certain targeted marketing
strategies, USPS could be drawn into a contentious debate about the
relative merits of various opt-out programs, including voluntary
programs administered by Catalog Choice and others.[Footnote 90]
Finally, as discussed previously, establishing a mail take-back program
likely would result in significant increases in the volume, size, and
weight of packages moving through the mail stream. Such increases could
overburden USPS' delivery networks and create delivery delays. Related
to this, several stakeholders from USPS and the mailing industry told
us that USPS' mission is to deliver the mail in a timely fashion--not
to help mail recipients recycle their discarded and unwanted mail.
Conclusions:
USPS, the mailing industry, and others have developed a wide range of
initiatives that, over time, could alleviate some concerns related to
the perceived negative impact of mail on the environment. Several of
the initiatives also have the potential to improve USPS' financial
position--while also enhancing its environmental reputation in U.S.
communities. However, it is not clear what level of trade-offs,
including decreased revenue and/or increased costs, USPS would find
acceptable to incur to further its commitments and reputation on
environmental matters.
While much is being done, USPS has numerous opportunities to enhance
its mail-related recycling efforts. For example, while establishing
goals should assist USPS in generating substantial additional mail-
related recycling revenues, the agency has not established similar
goals for reducing its costs associated with waste disposal.
Consequently, its recycling goals do not reflect the full financial
benefit attributable to mail-related recycling. In our view, revising
USPS' recycling goals to include savings from lower waste disposal
costs or adopting additional goals that reflect the full financial
benefit attributable to mail-related recycling would help focus USPS
employees on the need to achieve greater cost reductions--consistent
with one of USPS' strategic goals. Related to this, while USPS intends
to develop a plan to help it achieve its recycling goals, it is not
clear whether this plan will (1) specify how progress toward its goals
will be measured or (2) ensure that the data USPS will use to measure
its progress are accurate, reliable, and collected using a consistent
method. Furthermore, while USPS launched a pilot recycling program in
New York City to, among other objectives, apply lessons learned to
other postal facilities, it is unclear whether, and to what extent,
USPS will require its facility managers to adopt these lessons where
applicable, feasible, mission compatible, and appropriate in view of
cost and other considerations. Finally, while these considerations are
also applicable to the adoption of the five stakeholder-identified
opportunities discussed in this report, each opportunity, at a minimum,
provides thoughts and insights on activities that USPS might find--
after careful analysis--beneficial to adopt.
Recommendations for Executive Action:
To increase USPS' recycling of mail-related materials and increase the
amount of mail with environmentally preferable attributes, we recommend
that the Postmaster General direct the Manager of Environmental Policy
and Programs and other parties, as appropriate, to take the following
four actions:
* Revise the agency's recycling goals to include savings from lower
waste disposal costs or adopt additional goals that would reflect the
full financial benefit attributable to mail-related recycling.
* Ensure that the mail-related recycling plan it develops specifies,
among other matters, how USPS will (1) measure progress toward its
goals and (2) ensure that the data it uses for these measurements are
accurate, reliable, and collected using a consistent method.
* After completion of the New York City pilot, require facility
managers at other facilities to adopt lessons learned, where
applicable, feasible, mission compatible, and appropriate in view of
cost and other considerations.
* Assess the environmental benefits of the mail-related recycling
opportunities identified by stakeholders in this report, and any
others, and adopt those opportunities that are feasible, compatible
with USPS' mission, and appropriate in view of cost and other
considerations.
Agency Comments and Our Evaluation:
USPS provided its written comments on a draft of this report by letter
dated May 2, 2008. These comments are summarized below and are
included, in their entirety, as appendix VI to this report. USPS agreed
with three of our four recommendations and stated that it had begun
initiating actions to implement them. USPS also agreed, in principle,
with our remaining recommendation to adopt applicable lessons learned
from its New York City recycling pilot nationwide, where feasible,
mission compatible, and appropriate in view of cost and other
considerations. USPS stated, however, that it cannot require all of its
facility managers to adopt these lessons since "not all lessons learned
are applicable nationwide." We recognize that the pilot's lessons will
not be applicable at every postal facility and, thus, clarified the
recommendation to avoid confusion.
We are sending this report to the congressional requestors and their
staffs. We are also sending copies to the Postmaster General and other
interested parties. We will make copies available to others upon
request. In addition, the report will be available at no charge on the
GAO Web site at [hyperlink, http://www.gao.gov].
If you or your staffs have any questions regarding this report, please
contact me at siggerudk@gao.gov or by telephone at (202) 512-2834.
Contact points for our Office of Congressional Relations and Public
Affairs may be found on the last page of this report. GAO staff that
made key contributions to this report are listed in appendix VII.
Signed by:
Katherine A. Siggerud:
Director, Physical Infrastructure Issues:
[End of section]
List of Congressional Committees:
The Honorable Joseph I. Lieberman:
Chairman:
The Honorable Susan M. Collins:
Ranking Member:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable Thomas R. Carper:
Chairman:
The Honorable Tom Coburn, M.D.
Ranking Member:
Subcommittee on Federal Financial Management, Government Information,
Federal Services, and International Security:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable Henry A. Waxman:
Chairman:
The Honorable Tom Davis:
Ranking Member:
Committee on Oversight and Government Reform:
House of Representatives:
The Honorable Danny K. Davis:
Chairman:
The Honorable Kenny Marchant:
Ranking Member:
Subcommittee on Federal Workforce, Postal Service, and the District of
Columbia:
Committee on Oversight and Government Reform:
House of Representatives:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
Our objectives were to (1) describe the key, recent recycling
accomplishments (initiatives) of USPS,[Footnote 91] the mailing
industry, and other stakeholders and (2) identify additional recycling
opportunities that USPS could choose to engage in (or influence mailers
to undertake), including the factors that USPS would need to assess
prior to adopting the opportunities. Such factors include costs to
USPS; feasibility, such as logistical considerations; and compatibility
with USPS' mission.
To address our overall reporting objectives, we interviewed a wide
range of USPS officials as well as representatives from about 40
organizations (stakeholders) that have expertise in mail and paper
recycling issues. For expertise in mail, we contacted numerous, major
mailing industry associations which encompass the three major classes
of mail that contain advertisements--First-Class, Standard, and
Periodical. For expertise on environmental matters, we contacted
organizations with positions on a wide range of environmental matters,
including the waste generated from mail. For expertise in paper
recycling issues, we contacted organizations that, among other matters,
have an interest in increasing the amount of paper fiber available for
recycling. During our interviews, we requested contact information for
other relevant stakeholders and, as appropriate, contacted
representatives from those organizations who agreed to speak with
us.[Footnote 92] The stakeholders we interviewed are listed in table 2.
Table 2: Stakeholders Interviewed:
Catalog Choice;
Conservatree;
Co-op America;
EcoEnvelopes;
Environmental Defense;
Forest Ethics;
GreenDimes;
McDonough Braungart Design Chemistry;
National Envelope;
Norm Thompson Outfitters;
Pitney Bowes, Inc.;
Rand Whitney Recycling;
RR Donnelley;
The Alliance of Non-Profit Mailers;
The American Forest and Paper Association;
The Association for Postal Commerce;
The Bank of America Corporation;
The Direct Marketing Association;
The Direct Marketing Association Nonprofit Federation;
The Envelope Manufacturers Association;
The Forest Stewardship Council;
The Fulfillment Management Association;
The Greeting Card Association;
The Institute for Local Self-Reliance;
The Magazine Publishers of America;
The Mail Moves America Coalition;
The Mailers Council;
The National Newspaper Association;
The National Postal Policy Council;
The National Recycling Coalition;
The National Solid Wastes Management Association;
The National Wildlife Federation;
The Newspaper Association of America;
The 100% Recycled Paperboard Alliance;
The Saturation Mailers Coalition;
Time, Inc.;
United States Environmental Protection Agency;
United States Office of the Federal Environmental Executive;
United States Postal Service;
Weyerhaeuser.
Source: GAO.
[End of table]
In addition, to describe recent USPS initiatives, we (1) reviewed and
analyzed relevant documents related to the initiatives; (2) toured
various facilities engaged in recycling activities, including USPS
facilities in Baltimore and Philadelphia, a paper recycling facility
and a printing facility; and (3) attended meetings of the "Greening the
Mail Task Force"--a committee of USPS, mailing industry, and other
stakeholders whose mission is to identify and address environmental
issues that relate to the mail. We also interviewed a wide range of
officials in various USPS organizations, including Environmental Policy
and Programs, Address Management, Product Development, Pricing and
Classification, Marketing, Government Affairs, the Office of Inspector
General, and the Memphis Category Management Center. In addition, we
interviewed USPS staff involved in implementing the New York City
pilot; facility managers and employees involved with recycling in
Baltimore and Philadelphia facilities; and employees involved with the
National Postal Forum and the Mailers' Technical Advisory Committee,
among others. To determine recent initiatives of the mailing industry
and others, we interviewed each of the stakeholder organizations listed
above and reviewed and analyzed relevant documents related to the
initiatives they identified. We selected key, recent initiatives
undertaken by USPS, the mailing industry, and others based on our
professional judgment.
To identify additional mail-related recycling opportunities that USPS
could choose to undertake, we solicited the views of representatives
from the aforementioned stakeholders. We specifically inquired about
opportunities to increase the recycling of mail and the amount of mail
with environmentally preferable attributes.[Footnote 93] We reported on
those opportunities that stakeholders cited more than twice and that
were not currently being addressed by an ongoing USPS initiative.
Finally, using our professional judgment, we analyzed pertinent
factors, such as cost; feasibility, including logistical
considerations; and compatibility with USPS' mission, that USPS would
need to assess prior to adopting the opportunities.
We discussed First-Class, Standard, and Periodical Mail with
stakeholders; however, we primarily focused on Standard Mail because of
(1) its increasing prominence in the mail stream; (2) its contribution
to the municipal solid waste stream; (3) USPS' responsibility for
discarding large volumes of UAA Standard Mail; and (4) the issues
critics cite related to Standard Mail, which are reflected in numerous
"Do Not Mail" state legislative initiatives and a recent online
petition for a national Do Not Mail Registry. While other studies
measure the environmental impact of mail using different measurements
(e.g., the carbon footprint attributable to mail),[Footnote 94] this
report focuses on the role recycling plays in eliminating mail and mail-
related materials from municipal solid waste, decreasing USPS' waste
disposal costs, increasing USPS' revenue, and enhancing USPS'
commitment to environmental leadership.
We conducted this performance audit from April 2007 to June 2008 in
accordance with generally accepted government auditing standards. Those
standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
[End of section]
Appendix II: Other USPS Actions to Increase the Amount of Mail with
Environmentally Preferable Attributes:
In addition to the two multi-faceted initiatives discussed in the body
of this report, USPS also has undertaken other actions to increase the
amount of mail with environmentally preferable attributes. First,
according to USPS officials, the agency uses 100 percent recycled
paperboard in its Priority Mail and Express Mail packages and
envelopes.[Footnote 95] In addition, these officials stated that the
agency's marketing materials, such as postcards and brochures,
typically contain at least 10 percent recycled paper. Finally, USPS
recently approved a change in its mailing standards which allows
mailers to use reusable mailpieces, such as "two-way" envelopes. Such
envelopes enable mail recipients to either remove or cover the
recipient's address in order to reveal a return address.[Footnote 96]
Mailers that use two-way envelopes do not need to include a return
envelope in their mailpieces, which reduces their paper use and costs.
[End of section]
Appendix III: Depiction of Various Mail-Related Recycling Logos:
Figure 1: Mail-Related Recycling Logos:
[See PDF for image]
This figure contains mail-related recycling logos from the following
organizations:
Direct Marketing Association;
Envelope Manufacturers Association;
Magazine Publishers of America;
Sustainable Forestry Initiative Program;
Forest Stewardship Council;
Recycling Magazines is Excellent (collaboration between Verso Paper,
Time Inc., and the National Recycling Coalition).
Sources: The Direct Marketing Association; Envelope Manufacturers
Association; Magazine Publishers of America; Verso Paper, Time Inc.,
and the National Recycling Coalition; Sustainable Forestry Initiative,
Inc.; Forest Stewardship Council.
[End of figure]
Figure 2: Logos Indicating Paper Products Contain Recycled Materials or
Are Recyclable:
[See PDF for image]
This figure contains logos indicating paper products contain recycled
materials or are recyclable, with the following associated text:
Product contains recycled materials;
Product is recyclable.
Source: National Recycling Coalition.
Note: These logos appear on many products, including mail, but are not
specific to mail.
[End of figure]
[End of section]
Appendix IV: Other Stakeholder Initiatives to Increase the Amount of
Mail with Environmentally Preferable Attributes:
While several initiatives have been taken by the Direct Marketing
Association (DMA), other stakeholders in the mailing industry and
environmental advocacy organizations also have initiatives underway to
increase the amount of mail with environmentally preferable attributes.
For example, the National Postal Forum--a non-profit educational
corporation--sponsors an annual postal event and trade show with the
same name. This forum, among other goals, provides USPS and mailing
industry attendees with training, education, and opportunities to
communicate with USPS officials on matters related to the mail. In
2007, the forum included a series of workshops designed to educate
mailers on USPS' tools for improving the accuracy of their mailing
lists and reducing UAA mail volumes. The May 2008 forum featured more
workshops on improving the accuracy of mailing lists, including a
series of "Xtremely Green" workshops to address the environmental
implications of the mail and ways to effectively communicate to mail
recipients about environmental issues.
A second stakeholder, the Mailers' Technical Advisory Committee, (1)
shares technical information on matters of mutual interest related to
mail-related products and services and (2) discusses ways to enhance
the value of these products and services.[Footnote 97] The committee
recently published two reports. The first report, issued in 2006,
contained a list of best practices for accurately addressing mailpieces
and recommended, among other matters, that mailers--prior to each
mailing--update their mailing lists by using USPS' tools for improving
address accuracy. We were unable to ascertain the extent to which
mailers have adopted the report's recommendations. The second report,
issued in 2007, (1) outlined a system by which USPS could certify the
accuracy of mailing lists purchased by mailers and (2) described
several scenarios in which such a system would reduce UAA mail.
According to USPS, it intends to develop a list certification system by
October 1, 2010. However, this time frame is contingent on the
deployment of software upgrades related to its postal automated
redirection system and the mailing industry's implementation of
Intelligent Mail barcodes, expected in May 2009.
Third, several parties within the environmental advocacy industry have
undertaken initiatives to decrease the amount of unwanted mail received
by mail recipients. For example, "41 Pounds" and "GreenDimes"--a non-
profit and for-profit organization, respectively--were established in
2006 to help mail recipients decline (i.e., opt-out of) many types of
unwanted mail, including credit card and sweepstakes offers, insurance
promotions, coupon booklets, and catalogs. These organizations
accomplish this goal by, among other activities, (1) helping mail
recipients register for DMA's Mail Preference Service and (2) directly
contacting non-DMA mailers--who are not required to use this service--
to request them not to send mail solicitations to these mail
recipients. 41 Pounds charges $41 for its services and, according to
its Web site, donates one-third of this fee to community and
environmental organizations. GreenDimes charges $20 for its services
and, as of mid-March 2008, planted five trees for its services and an
additional tree for every catalog that a member (mail recipient)
declined (up to five additional trees). In addition, Catalog Choice--a
non-profit program sponsored by the Ecology Center and endorsed by the
National Wildlife Federation and the Natural Resources Defense Council-
-offers a free service that allows consumers to stop receiving unwanted
catalogs. Consumers can search for catalogs on the Catalog Choice Web
site and, after providing their address information, opt-out of those
they do not wish to receive.[Footnote 98] According to the
organization's Web site, nearly 700,000 people had registered for its
service, opting out of over 9 million catalogs as of March 31, 2008.
[Footnote 99]
Fourth, some parties within the envelope industry also have undertaken
initiatives to increase the amount of mail with environmentally
preferable attributes. For example, one major envelope manufacturer
enables its customers to customize their envelopes with an assortment
of environmentally preferable attributes, including recycled and
certified paper. A company official estimated that 80 percent of his
company's envelope sales include at least one environmentally
preferable attribute. Another company designed reusable "two-way"
envelopes that are made with at least 30 percent recycled paper.
Fifth, some individual catalog mailers have undertaken their own
efforts to incorporate environmentally preferable attributes in their
mailpieces. In 2007, Forest Ethics--an environmental non-profit
organization that, among other activities, encourages catalog companies
to improve their environmental practices--surveyed the catalog industry
and reported that nine major catalog mailers had attained its highest
environmental rating by, among other actions, reducing the quantity of
paper they use and using certified and recycled paper. Another catalog
mailer partnered with Environmental Defense in 2001 and began using
paper with 10 percent recycled paper. This company also offers mail
recipients a "frequency opt-out" option that enables mail recipients to
choose how often they wish to receive the company's catalog.
Finally, to increase the prevalence of environmentally preferable
attributes in magazines, a non-profit organization called Co-op America
created the "Magazine PAPER Project."[Footnote 100] The project helps
magazines change their business practices to better protect the
environment by, among other actions, educating magazine publishers
about the environmental consequences associated with the paper they use
and working with publishers to help them adopt environmentally
preferable practices, such as the use of recycled or certified
paper.[Footnote 101] A representative of Co-op America estimated that
the percentage of magazines using recycled paper is extremely
low.[Footnote 102] According to the representative, convincing magazine
officials to use recycled or certified paper is difficult, due, in
part, to (1) confusion regarding the environmental benefits of using
these products, (2) the higher cost of recycled paper, (3) the
availability of recycled paper, and (4) the perception among many
magazine companies that using recycled paper will adversely affect the
appearance of their products.
[End of section]
Appendix V: DMA's List of 15 Environmentally Preferable Business
Practices:
As discussed in the body of this report, DMA developed a list of 15
environmentally preferable business practices--the "Green 15." While
adoption of these 15 practices is mostly voluntary, in June 2008, DMA
intends to establish goals and timetables for measuring its members'
success in implementing these practices, which, according to DMA
officials, could lead to future DMA requirements. Overall, the Green 15
consists of five mailer business practices: paper procurement and use,
mailing list accuracy and data management, mail design and production,
packaging, and recycling and pollution reduction. A description of the
specific practices related to each of the five overall business
practices follows:
Paper procurement and use - Mailers should:
1. Encourage paper suppliers to increase their wood purchases from
recognized forest certification programs;
2. Require paper suppliers to commit to implementing sustainable
forestry practices that (a) protect forest ecosystems and biodiversity
and (b) provide wood and paper products that meet industry needs;
3. Ask paper suppliers where their paper comes from before purchasing
it, with the intent of avoiding paper from unsustainable or illegally
managed forests;
4. Require paper suppliers to document that they do not produce or sell
paper from illegally harvested or stolen wood; and;
5. Evaluate the paper used for advertising, product packaging, and
internal consumption in order to identify opportunities to increase
their environmentally preferable attributes.
Mailing list accuracy and data management - Mailers should:
6. Comply with DMA guidelines for list management,[Footnote 103] such
as:
a. maintaining lists of consumers who do not wish to receive their mail
solicitations;
b. updating their mailing lists against the Mail Preference Service
database;
c. including--on every direct mail solicitation they send--an option
for mail recipients to opt-out of receiving all direct mail
solicitations from that member, regardless of whether a business
relationship has been previously established;
7. Use tools developed by USPS or other parties to improve the accuracy
of their mailing lists; and:
8. Apply predictive targeted marketing models to reduce unwanted mail,
where appropriate. [Footnote 104]
Mail design and production - Mailers should:
9. Review their direct mail solicitations and other printed marketing
material to determine whether, for example, smaller or lighter designs
(that use less paper) are appropriate; and:
10. Test and use production methods that reduce waste.
Packaging - Mailers should:
11. Encourage their packaging suppliers to submit price quotes for
environmentally preferable packaging alternatives, in addition to
approved or existing packaging specifications.
Recycling and pollution reduction - Mailers should:
12. Purchase office paper and packaging materials that are made from
recycled paper, where appropriate;
13. Integrate the use of electronic communications (e.g., e-mail,
internet, and intranet) for both internal and external communications;
14. Ensure that all environmental labeling is clear, honest, and
complete; and;
15. Participate in DMA's "Recycle Please" campaign and/or other
recycling campaigns in order to demonstrate that their company or
organization has a program to encourage recycling.
[End of section]
Appendix VI: Comments from USPS:
Deborah Giannoni-Jackson:
United States Postal Service:
Employee Resource Management:
475 L'Enfant Plaza, SW, Room 9840:
Washington, DC 20260-4200:
Fax: 202-268-3803:
[hyperlink, http://www.usps.com]
May 2, 2008:
Ms. Katherine A. Siggerud:
Director, Physical Infrastructure Issues:
United States Government Accountability Office:
Washington, DC 20548-0001:
Dear Ms. Siggerud:
Thank you for providing the U.S. Postal Service with the opportunity to
review and comment on the draft report titled U.S. Postal Service: Mail-
Related Recycling Initiatives and Possible Opportunities for
Improvement, (GAO-08-599).
The Postal Service prides itself as a recognized federal leader in
environmental stewardship. Over the past 10 years we have received 39
White House Closing the Circle Awards and we continue to develop new
and innovative strategies to help protect the environment. We have
implemented a number of programs that reduce, reuse, recycle and
rethink our use of resources that impact the environment. As such the
Postal Service concurs with GAO's recommendations 1, 2 and 4 and we
have already begun actions to implement those objectives. On
recommendation 3, we agree in principle with this recommendation but
not all lessons learned are applicable nationwide and therefore cannot
be required of all managers.
Recommendation 1 - Revise the agency's recycling goals to include
savings from lower waste disposal costs or adopt additional goals that
would reflect the full financial benefit attributable to mail-related
recycling.
Postal senior management has communicated recycling revenue improvement
and solid waste disposal cost reduction goals for the next three years
to the Vice Presidents, Area Operations. Monthly reporting on recycling
revenue has been initiated and similar waste cost reduction data
reporting is being developed. Fiscal Year 2009 area objectives for
recycling are being reviewed to include solid waste cost reduction.
These revised recycling revenue/solid waste disposal cost reduction
objectives will be included in our national recycling plan that
supports the Postal Service's Strategic Transformation Plan.
Recommendation 2 - Ensure that the mail-related recycling plan it
develops specifies, among other matters, how USPS will (1) measure
progress toward its goals and (2) ensure that the data it uses for
these measurements are accurate, reliable, and collected using a
consistent method.
The Postal Service currently tracks recycling revenue data from the
organization's Enterprise Data Warehouse (EDW), which provides
standardized, consistent and reliable information. The EDW also is
expected to provide the same level of standardized data for solid waste
disposal cost reduction. Each month, Environmental Policy and Programs
reports to Areas and other USPS functions regarding recycling,
including comparative data to other operating units and to same period
last year (SPLY). The Postal Service also is improving its data
collection/analysis ability for solid waste activities as part of its
upgrade of the Environmental Management Information System (WebEMIS) in
Fiscal Year 2008. The Postal Service also is leveraging its
participation in the Environmental Protection Agency's (EPA) Waste Wise
program to provide accurate, reliable recycling and solid waste
disposal information from an independent source.
Recommendation 3 - After completion of the New York City pilot, require
managers to adopt applicable "lessons learned" nationwide, where
feasible, mission compatible, and appropriate in view of cost and other
considerations.
Throughout Fiscal Year 2008, the Postal Service has developed and
provided training, messaging, policy and on-site and analytical support
to share best management practices and other "lessons learned" from
various USPS recycling programs, including San Diego, Houston,
Connecticut, Alabama, Northern Virginia and Dallas. This training
included recycling training at the national meeting of USPS
environmental employees in November 2007 and a two-day training course
for Area Recycling Coordinators in December 2007. Since January 2008,
Environmental Policy and Programs has conducted monthly telecons with
each Area Recycling Coordinator and the Area Manager, Environmental
Programs, about the progress, roadblocks and prospective solutions to
improve recycling revenue. A Management Instruction on Recycling and a
Recycling Guide have been written and will be distributed later this
year. Moreover, Environmental Policy and Programs has funded a detail
to provide on-site support for New York City and other districts to
revitalize their recycling programs. Lessons learned from New York and
other revitalization efforts have been and will continue to be shared
with other districts and areas.
Recommendation 4 - Assess the environmental benefits of the mail-
related recycling opportunities identified by stakeholders in this
report, and any others, and adopt those opportunities that are
feasible, compatible with USPS' mission, and appropriate in view of
cost and other considerations.
The Postal Service continues to engage customers, mailers, mailing
industry associations, suppliers, regulators, non-governmental
organizations and other stakeholders regarding mail-related recycling
activities. This dialogue includes the continuing work of the "Greening
the Mail" Task Force, interactions with stakeholders at the National
Postal Forum and in various ongoing dialogues within and outside the
organization.
If you or your staff wish to discuss any of these comments further, I
am available at your convenience.
Sincerely,
Signed by:
[Illegible] for:
Deborah Giannoni-Jackson:
[End of section]
Appendix VII: GAO Contact and Staff Acknowledgments:
GAO Contacts:
Katherine A. Siggerud (202) 512-2834 or siggerudk@gao.gov:
Staff Acknowledgments:
In addition to the individual named above, Kathleen Turner, Assistant
Director; Samer Abbas; Kathleen Gilhooly; Jeff Jensen; Joshua Ormond;
Daniel Paepke; Stephanie Purcell; and Erin Roosa made key contributions
to this report.
[End of section]
Footnotes:
[1] Approximately 6 percent of all Standard Mail was UAA in 2004. USPS
returns a small portion of UAA Standard Mail annually to mailers, at
their request, and discards the remainder.
[2] Recycling also helps reduce the incidence of water and air
pollution and helps lower greenhouse gas emissions, among other
benefits. Furthermore, manufacturing paper from recycled paper fiber
may require less electricity, fuel, and water.
[3] In addition, Forest Ethics, an environmental non-profit
organization, recently initiated an online petition for a national Do
Not Mail Registry.
[4] Because many of USPS' mail-related recycling efforts are in the
early stages of their implementation, we discuss these efforts as
"initiatives," rather than as "accomplishments."
[5] GAO, Postal Service and Mailing Industry Mail-Related Recycling:
Accomplishments and Postal Opportunities-Interim Results, [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-08-348R] (Washington, D.C.: Dec.
20, 2007).
[6] Mail-related materials include UAA mail, mail discarded in USPS
facilities, and other materials related to mail such as plastic
wrappings and cardboard.
[7] Several forest certification programs exist. The programs are
intended to recognize and promote environmentally preferable forestry
management practices.
[8] GAO, Postal Reform Law: Early Transition Is Promising, but
Challenges to Successful Implementation Remain, [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-08-503T] (Washington, D.C.: Feb.
28, 2008).
[9] Specifically, the 2006 Postal Accountability and Enhancement Act
includes an annual limitation on the average percentage changes in
rates for each market-dominant mail class--such as First-Class Mail and
Standard Mail--which is linked to the change in the Consumer Price
Index for All Urban Customers. The act includes exceptions to this
inflation-based limitation, but USPS cannot raise postage rates beyond
its legal authority.
[10] Pub. L. No. 109-435 (Dec. 20, 2006).
[11] Congress reimburses USPS for providing free or reduced postage
rates to certain groups, such as the blind and overseas voters. For
fiscal year 2008, Congress appropriated $118 million to USPS for these
purposes.
[12] The Mailing Industry Task Force, Seizing Opportunity: The Report
of the 2001 Mailing Industry Task Force, October 2001. This task force
includes chief executives of 11 leading mailing industry companies and
the Deputy Postmaster General of USPS.
[13] While USPS generally does not forward UAA Standard Mail to the
addressee, mailers can pay USPS an additional fee to have this mail
returned to them.
[14] Direct mail refers to advertisements sent to recipients through
the mail.
[15] USPS operates two First-Class Mail recovery centers in St. Paul,
Minnesota, and Atlanta, Georgia. These facilities are responsible for
the final disposition of First-Class UAA mail.
[16] Christensen Associates, Volumes, Characteristics, and Costs of
Processing Undeliverable-As-Addressed Mail and Personal-Knowledge
Required Mail (Madison, WI: March 2006).
[17] In the past, some mail components, such as transparent envelope
address windows and certain pressure-adhesive stamps, were difficult to
recycle. However, according to USPS officials and other stakeholders,
concerns about the recyclabilty of mail have generally been addressed.
[18] The National Task Force on Greening the Mail, Recommendations of
the National Task Force on Greening the Mail, January 1999.
[19] The communities that do not have access to paper recycling
programs generally are located in sparsely populated, rural areas.
[20] GAO, Recycling: Additional Efforts Could Increase Municipal
Recycling, [hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-37]
(Washington, D.C.: Dec. 29, 2006).
[21] As previously discussed, USPS treats UAA Standard Mail as waste
when it cannot be delivered.
[22] We adopted these environmentally preferable attributes for our
reporting purposes.
[23] For management purposes, USPS divides the country into nine
geographic areas. Each area is comprised of districts, and there are 82
districts nationwide.
[24] USPS' Strategic Transformation Plan 2006-2010 lists four strategic
goals: generate additional revenue; reduce costs; achieve results with
a customer-focused, performance-based culture; and improve service.
[25] Specifically, according to documentation supplied by USPS, in
fiscal year 2006, the Processing and Distribution Centers in Boston,
Massachusetts, and Carol Stream, Illinois, did not record waste
disposal cost savings, while the Processing and Distribution Center in
Portland, Oregon, combined recycling revenues and waste disposal cost
savings in a single figure. Similar reporting inconsistencies exist at
the district-and area-levels, according to USPS officials.
[26] December 2007 update to USPS' Strategic Transformation Plan for
2006-2010.
[27] Integrated Waste Management, July 2007, Management Instruction EL-
890-2007-5.
[28] In September 2007, USPS also published guidance for implementing
the policy, including information on how to initiate successful mail-
related recycling programs at postal facilities entitled Implementation
Guide for Managers: District Recycling Programs, September 2007.
[29] Recycling of Discarded Mail and Undeliverable Bulk Business Mail,
September 1995, Management Instruction AS-550-95-14.
[30] Previously, USPS managed these contracts at the Memphis Center and
three other similar centers located in California, Illinois, and
Connecticut, according to USPS officials.
[31] According to USPS officials, managers at small facilities still
can enter into separate contracts for their facilities, if the
contracts are cost-effective and valued at less than $2,500.
[32] GAO, Postal Service: Progress in Implementing Supply Chain
Management Initiatives, [hyperlink, http://www.gao.gov/cgi-
bin/getrpt?GAO-04-540] (Washington, D.C.: May 17, 2004).
[33] USPS received a White House "Closing the Circle" award in 2007 for
its use of Total Solid Waste Management contracts. These awards
recognize outstanding federal achievements in a variety of
environmental areas, including waste prevention, recycling, purchasing
environmentally-preferable products, environmental management,
sustainable buildings, disposal of electronics, and reduced fuel usage.
[34] For example, after a USPS vehicle is loaded with mail at a mail
processing and distribution center and transports the mail to local
USPS facilities (e.g., post offices), the vehicle returns to the
processing and distribution center. Instead of returning empty, or
partially empty, however, the vehicle is loaded with UAA mail and other
mail-related recycling materials, which have been collected and stored
at local USPS facilities. The use of backhauling as a means to
transport items and materials between postal facilities is not new.
Rather, USPS has historically used backhauling to transport other
items, such as mail processing equipment, between facilities.
[35] New York City was chosen as the pilot site, in part, because of
its complex delivery and operational network. USPS officials stated
that if a mail-related recycling program can be successfully
implemented in New York City, similar recycling programs probably could
be implemented at postal facilities elsewhere.
[36] New York City is comprised of five boroughs--Brooklyn, the Bronx,
Manhattan, Staten Island, and Queens. References to "New York City"
refer to all five boroughs, unless a particular borough is specified.
[37] For perspective, if New York City had generated $1.3 million in
recycling revenues in fiscal year 2007, it would have increased USPS'
nationwide recycling revenues of $7.5 million by approximately 17
percent that year.
[38] As noted previously, USPS has nine areas and 82 districts.
Facility managers report to district managers who, in turn, report to
area managers.
[39] The tool collects, among other information, data on revenues
generated from recycling mail-related materials and other items. Such
revenues include those generated from the sale of wastepaper, twine,
and dead mail. Dead mail includes UAA mail and other mail-related
materials.
[40] The process of improving the accuracy of addresses that comprise
mailing lists is often referred to as "address hygiene."
[41] Worksharing rates are discounts that USPS provides to mailers who
perform certain activities that avoid costs that USPS would otherwise
incur. Worksharing activities include, among other things, having
mailers (1) update and accurately format their addresses; (2) barcode
and prepare mail so that it can be sorted by USPS' automated equipment,
which reduces manual and other handling of mail; and (3) presort mail,
such as by zip code or specific delivery location, to reduce the number
of times USPS must sort the mail before delivery to a mail recipient.
[42] Prior to the requirement's change, First-Class mailers had to
update their mailing lists 185 days prior to each of their mailings.
[43] In December 2007, USPS' Board of Governors approved a negotiated
service agreement between USPS and the Bank of America. The agreement-
-the first ever performance-based negotiated service agreement--
requires the Bank of America to, among other actions, reduce its volume
of UAA mail in exchange for worksharing rates. USPS has entered into
other negotiated service agreements, but the previous agreements
provided mailers with postage rate discounts based on (1) the volume of
mail they sent and (2) the amount of work that USPS avoided, not on
reductions in the mailers' UAA mail volumes.
[44] DMA is the main trade association for the direct mail industry. It
represents, among others, about 2,700 large mailers who send,
collectively, about 80 percent of all Standard Mail. The Envelope
Manufacturers Association represents envelope manufacturers, includes
approximately 147 organizations, and collectively produces about 80
percent of U.S. envelopes and about 60 percent of envelopes worldwide.
The Magazine Publishers of America is the main trade association for
the magazine industry and represents approximately 240 companies, which
publish over 1,400 magazine titles.
[45] The volume of materials recycled varies for different types of
mail. For example, according to industry stakeholders, Americans
recycled about 36 percent of the catalogs and direct mail delivered to
their residences in 2005, while prior studies (pre-2006) indicate that
about 20 percent of magazines delivered to U.S. homes were recycled.
[46] While association officials provided us with data on their
members' participation rates, officials from two of the three
associations believe their data underestimate the extent of
participation in their programs. For example, DMA stated that its
recycling awareness campaign is targeted toward DMA members that market
to consumers. Thus, according to DMA, 4 percent of these members
participate in the association's "Recycle Please" program. In addition,
DMA noted that some DMA members "operate multiple brands, so the
Recycle Please logo could be widely disseminated across many brands by
a single parent company." Furthermore, a magazine association official
stated that at least 16 percent of its members' magazine titles use the
"Please Recycle" logo and that these titles account for about 54
percent of the total number (copies) of magazines currently in
circulation.
[47] The National Recycling Coalition is a non-profit organization that
focuses on recycling and waste prevention nationwide.
[48] The chasing arrows logo can indicate, for example, that a product
is recyclable, made from 100 percent recycled content, or made
partially from recycled content.
[49] The logo used in the "Recycling Magazines is Excellent" project is
depicted in figure 1 of appendix III.
[50] The Prince George's County pilot also includes the Washington,
D.C., metropolitan area.
[51] One of our objectives is to report on the recent key initiatives
undertaken by USPS, the mailing industry, and other stakeholders. While
the Mail Preference Service is not new, we discuss it in this report
because, historically, it was the main tool available to mail
recipients who wanted to decrease the amount of unwanted mail they
receive.
[52] "Prospecting mail" is advertising mail that mailers send to mail
recipients in an attempt to establish a business relationship (i.e.,
future business) with them.
[53] Consumer requests to opt-out of receiving prospecting mail do not
affect DMA member mailings to consumers when the member has already
established a business relationship with the customer. Instead, these
mailings will continue. Additionally, DMA members that have pre-
existing relationships with consumers who have registered with the Mail
Preference Service can continue to exchange these consumers' personal
information with other companies for marketing purposes.
[54] Until recently, DMA charged consumers a $1 fee, payable by credit
card or check, to sign up for the Mail Preference Service--regardless
of how the consumer signed up for the service. The $1 fee still applies
to opt-out requests sent through the mail. However, DMA eliminated this
fee in January 2008 for internet-based requests. While a valid credit
card number is still required for authentication purposes, according to
a DMA official, the association is testing different methods to
authenticate consumer opt-out requests and no longer requires a credit
card number for non-catalog internet-based requests.
[55] A similar DMA service--the Deceased Do Not Contact List--enables
family members to permanently remove a deceased individual from
prospect mailing lists. The Deceased Do Not Contact list was created in
response to concerns that mail addressed to deceased individuals (1)
poses a risk of identity theft--particularly when the mailpiece
contains sensitive information, such as an unsolicited credit card
offer--and (2) distresses grieving family members.
[56] To encourage members to adopt the 15 environmentally preferable
practices, DMA developed a "Green 15 Toolkit," which contains, among
other matters: (1) information on paper recycling, paper procurement,
and the environmental impact of mail; (2) guidance on how members
should benchmark their progress toward adopting environmentally
preferable practices; (3) strategies to improve address accuracy and
reduce UAA and unwanted mail; and (4) a "paper pledge" template that
members can use to develop a paper procurement policy that considers
environmentally preferable practices.
[57] According to DMA officials, DMA intends to educate and encourage
its members to use recycled and certified paper whenever feasible, but
does not intend to specify which certification program its members
should use. Instead, DMA specifies a list of available forest
certification programs and allows its members to choose the program or
programs that best suits their needs.
[58] In other words, if a consumer contacts a company and asks to be
removed from its future mailings, that consumer will no longer receive
any mailpieces from the company. Should the consumer later place an
order for a product with that company, the consumer will receive the
product and any correspondence related to it (e.g., invoices and
bills), but--under the terms of the program--would not receive other
direct mail solicitations from the company.
[59] Currently, members must comply with all of the program's
requirements, except for the provision that every mail piece contain an
option to opt-out of future direct mail solicitations from that member.
DMA officials stated that the Association has delayed enforcement of
this requirement to allow sufficient time for its members to redesign
and test their mailpieces.
[60] The Commitment to Consumer Choice program also allows DMA members
to provide customers with a "frequency opt-out" option. When available,
such an option would allow mail recipients to specify the frequency
with which they wish to receive future mailings, such as catalogs, from
a DMA member without opting out of all mailings from the member.
[61] Although DMA's process for ensuring that its members comply with
its requirements also is not a recent initiative, we nonetheless
describe it to convey the method by which DMA officials said the
association enforces its member requirements.
[62] According to DMA officials, the association also randomly selects
about 200 of its members annually for monitoring using a "secret
shopper" program. According to these officials, the monitoring program
helps to ensure that DMA members are complying with the association's
requirements.
[63] According to a DMA official, the Committee on Ethical Business
Practices is comprised of approximately 15 DMA members, who meet once
per month to resolve consumer complaints against DMA mailers.
[64] As discussed in appendix I, we reported on those opportunities
that stakeholders cited more than twice and that were not currently
being addressed by an ongoing USPS initiative.
[65] As discussed previously, these initiatives include DMA's "Recycle
Please" program, the magazine and envelope associations' "Please
Recycle" programs, the National Recycling Coalition's development of a
recycling logo specific to mail, and the "Recycling Magazines is
Excellent" program initiated by the National Recycling Coalition; Time,
Inc.; and Verso Paper.
[66] As noted previously, one of the Task Force's five subcommittees--
the subcommittee on "Education and Awareness on Sustainability and
Value of the Mail"--intends to, among other goals, promote awareness
that mail is recyclable.
[67] Many mailers told us that using recycled paper is more expensive
than using virgin paper (i.e., paper made from unrecycled fiber
harvested directly from forests) for their mailings.
[68] According to USPS officials, the agency recently invited
representatives of the American Forest and Paper Association to
participate on the Greening the Mail Task Force.
[69] As previously noted, one of the Task Force's five subcommittees--
the subcommittee on "Recycling Collection of the Mail"--intends to,
among other goals, increase mail recycling by implementing and
supporting mail recycling initiatives in postal facilities, office
buildings, and private residences.
[70] As previously described, certified paper is produced from forests
that are managed according to a variety of environmentally preferable
practices. The two major forest certification programs in the U.S. are
the Sustainable Forestry InitiativeŽ and the Forest Stewardship
Council. The Sustainable Forestry InitiativeŽ--formerly a part of the
American Forest & Paper Association--is now an independent organization
managed by the Sustainable Forestry Initiative, Inc. The logos for
these certification programs are depicted in figure 1 of appendix III.
[71] As previously discussed, mail opt-out programs enable mail
recipients to decline to receive certain mail solicitations, such as
credit card offers and catalogs, from direct mail marketing companies.
One such program is Catalog Choice, which is a free service that allows
mail recipients to opt-out of unwanted catalogs that they currently
receive. For more information on Catalog Choice, see appendix IV.
[72] As discussed, DMA allows mail recipients to opt-out of receiving
certain mailings from its members. Because DMA members are required to
honor those requests, it seems unlikely that such actions would qualify
for a special postal discount. Therefore, if USPS were to develop a
Green Rate related to the mailers' participation in opt-out programs,
it would likely focus on programs in which mailer participation is
voluntary.
[73] The current performance-based Negotiated Service Agreement with
Bank of America is structured in a similar fashion.
[74] According to a 2005 survey conducted by the American Forest and
Paper Association, 14 percent of the population (31 percent of U.S.
communities) reside in these areas.
[75] GAO, Postal Reform Law: Early Transition is Promising, but
Challenges to Successful Implementation Remain, [hyperlink,
http://www.gao.gov/cgi-bin/getrpt?GAO-08-503T] (Washington, D.C.: Feb.
28, 2008).
[76] The Act includes exceptions to this inflation-based limitation,
but USPS cannot raise postage rates beyond its legal authority.
[77] We did not identify any additional cost considerations related to
two of the five opportunities--implementing an incentives program and
collaborating with others to increase the supply of paper fiber needed
for recycling.
[78] Generally speaking, if USPS chose to implement a Green Rate, its
net revenues would decrease by the amount of the discount multiplied by
the number of mailpieces that were mailed using the discount. Although
the lower cost for postage could cause some mailers to increase the
number of mailpieces they send, we believe that such an increase would
be marginal and that it likely would not offset the lost revenues to
USPS caused by a Green Rate.
[79] Manual mail processing is far more costly than processing mail on
USPS' automated equipment.
[80] This distance includes both the mileage between (1) the mail
recipient's residence and the recipient's local post office (i.e., the
locations where the package presumably would be picked up and initially
delivered) and (2) the local post office and the location of the
package's destination.
[81] Additional take-back packages would be needed if the amount of
discarded mail exceeded the capacity of a single package. The
additional packages also would be heavier than those of typical
mailpieces.
[82] As noted previously, such packages likely would be picked up at
the mail recipient's address during the U.S. letter carriers' normal
mail deliveries.
[83] We did not identify any factors related to the feasibility of
increasing recycling awareness among mail recipients.
[84] For example, according to USPS documentation, a Processing and
Distribution Center in Portland, Oregon, sold its UAA mail for $25 per
ton in fiscal year 2006, whereas the Southeastern Pennsylvania
Processing and Distribution Center was able to sell the same material
for $105 per ton.
[85] According to USPS documentation, in fiscal year 2006, three
(Albany, New York; Southeastern Pennsylvania; and Carol Stream,
Illinois) of the nine Processing and Distribution Centers USPS surveyed
do not collect information on the amount of materials (tonnage) they
recycle and two (Boston, Massachusetts; and Carol Stream, Illinois) do
not collect data on savings from avoided waste disposal costs.
[86] As discussed, according to both USPS officials and our analysis of
USPS documentation some district facilities combine recycling revenues
with waste disposal costs. Additionally, our analysis of USPS
documentation indicates that in fiscal year 2006, at least one large
district facility combined recycling revenues with waste savings
attributable to recycling, which, together, comprise the full financial
benefit of recycling. Similar reporting inconsistencies exist at the
District and Area levels, according to USPS officials.
[87] In New Jersey, for example, Rand Whitney serves as an intermediary
between a paper-recycling company and 457 USPS facilities in
Pennsylvania and, in return for its services, receives 25 percent of
the full financial benefit generated under its contract.
[88] While a mail take-back program is similar conceptually to several
existing take-back programs for other used products (e.g., inkjet
cartridges, digital cameras, and cellular phones), the critical
difference is that for these programs, another party (not USPS) pays
all of the costs--an action that the party presumably views as
beneficial to its self-interest.
[89] Evaluating the relative merits of the various certification
programs likely would require expertise in environmental principles and
practices associated with managing forests.
[90] For example, DMA recently advised its members not to accept opt-
out requests originating from Catalog Choice and other (non-DMA)
programs. Appendix IV provides additional information on this matter.
[91] Because many of USPS' mail-related recycling efforts are in the
early stages of their implementation, we discuss these efforts as
"initiatives," rather than as "accomplishments."
[92] Despite several attempts, we were unable to obtain interviews with
representatives from numerous organizations including the American
Bankers Association; the American Catalog Mailers Association; the
Center for a New American Dream; the Mailing & Fulfillment Service
Association; the Major Mailers Association; the National Association of
Presort Mailers; the Printing Industries of America; and the U.S.
Conference of Mayors.
[93] As described previously, these attributes include mail that (1)
contains paper from recycled paper fiber (recycled paper); (2) uses
paper from responsibly-managed forests (certified paper); (3) is
designed to use materials efficiently, such as reusable "two-way"
envelopes; (4) is accurately addressed for delivery; and (5) is
targeted to mail recipients who may wish to receive it.
[94] For example, USPS issued a study in 2007 that concluded that
advertising mail has a positive overall environmental impact, in part,
because it reduces the number of shopping trips consumers would
otherwise make to purchase products.
[95] USPS received a "Cradle to Cradle" certification from a consulting
firm in 2007 for its Priority Mail and Express Mail packages and
envelopes. The consulting firm--which helps clients create
"ecologically intelligent products"--awards these certifications to
parties that demonstrate an understanding of their products'
environmental impact.
[96] USPS officials stated that reusable mailpieces are not frequently
used because mail recipients often inadvertently destroy the return
mechanism when they first open the envelope. In addition, according to
a USPS marketing official, USPS typically does not encourage customers
to reuse its Priority Mail or Express Mail packaging and envelopes
because doing so likely would decrease the image of these items and
detract from USPS' brand name.
[97] The committee is comprised of USPS officials, over 50 mailer
associations, and a small number of other organizations in the mailing
industry.
[98] The Catalog Choice Web site includes links to hundreds of catalog
company Web sites. Catalog Choice also plans to offer consumers the
opportunity to "opt in" to catalogs they wish to receive.
[99] The introduction of services offered by organizations such as 41
Pounds, GreenDimes, and Catalog Choice has been contentious. In late
2007, the Direct Marketing Association met with its members and advised
them not to accept opt-out requests provided by these and other
organizations unless they meet certain authentication and privacy
requirements. According to DMA officials, the advice was offered, in
part, to address concerns about whether opt-out requests submitted
through these organizations truly originated from a mail recipient. DMA
officials explained that, several years ago, one company registered its
entire mailing list with DMA's Mail Preference Service, with the
objective of ensuring that its customers would not receive mail from
other direct marketers. A Catalog Choice official explained that his
organization also has measures in place to detect fraudulent opt-out
requests. Additionally, the official said that although DMA's Service
offers consumers the opportunity to opt-out of catalogs, he believes
the service provided by Catalog Choice is easier to use.
[100] According to its Web site, Co-op America's mission is to harness
economic power--the strength of consumers, investors, businesses, and
the marketplace--to create a socially just and environmentally
sustainable society.
[101] While there are several forest certification programs, the
Magazine PAPER Project only supports paper certified by the Forest
Stewardship Council.
[102] Specifically, out of approximately 18,000 distinct magazine
titles in the United States, the official estimated that less than 1
percent use recycled paper. His estimate is likely to understate the
percentage of magazines that use recycled paper, however, because some
magazines have low circulation rates and, consequently, are not known
to Co-op America.
[103] DMA requires its members to comply with its list management
guidelines. Currently, this is the only required component of the Green
15.
[104] Predictive targeted models use customer data such as age, gender,
and purchase history to forecast customer purchasing behaviors.
[End of section]
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