Talk to the Postal Service about electronic subscriptions

Tell the Postal Service your views on electronic subscriptions

The US Postal Service has responded to a long-pending request from Max Heath and NNA's Postal Committee to recognize electronic subscriptions as paid or requester circulation. Its current new proposed rule contains some qualifications that USPS is considering. If the rule is adopted, newspapers could begin counting "e-subs" as early as September 30, 2012, in time for October publishers' statements.

NNA wants to provide the comments of its members to USPS as it considers this new rule. To make it easy to comment, NNA designed this survey for your response. Your comments here will be provided to USPS. If you want NNA to know your views but do not wish to share them with USPS or you have questions, please contact tonda@nna.org or maxheath@lcni.com. Also, please consult your February Pub Aux for an excellent survey of electronic subscriptions.

Please read the questions carefully. Your name and contact information are needed. If we do not have those, your comment will not be included.

Comments included before Feb. 28 will be shared with the Postal Service.

Thank you for participating!

Question Title

* 1. In general, do you believe electronic subscriptions should be counted as paid circulation, provided the integrity of the Periodicals permit is maintained?

Yes, without restriction

Yes, with qualifications

Undecided

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* 2. USPS proposes to count .pdf copies or other electronic facsimile copies as paid subscriptions if the newspaper charges a subscription rate that is above a nominal rate. (Nominal rate is considered to be anything less than 30% of basic price per term.0 Do you agree that these subscriptions should be counted as paid?

Yes, pdf copies and similar facsimiles should count

No, they should not count

Please provide a short explanation of your views on this question.

Other (please specify)

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* 3. USPS also proposes to count as paid subscriptions any subscription charged for electronic content behind a website paywall, provided the price is greater than nominal. The proposal does not require that the paid content be formatted exactly like the newspaper, as in a pdf, only that the content be a "copy of a Periodical publication." Do you agree that subscriptions for newspaper content behind a paywall should be counted?

Yes

Please briefly explain your response

Other (please specify)

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* 4. In keeping with Periodicals standards, demand for each subscription must stand alone. Therefore USPS would not permit a newspaper to sell the electronic subscription "in conjunction with" the printed newspaper if the publisher wishes to separately count the electronic subscriber. In other words, a print subscriber who took an electronic subscription as an add-on could not be counted twice.

USPS is not clear on whether a subscriber purchasing two full price subscriptions--one print and one electronic--could be counted twice. Please consider how this aspect of the rules would affect your newspaper.

We would not "upsell" an electronic subscription. Readers would elect either print or electronic

We want to be able to sell both as stand-alone subscriptions and count each of them

This rule is confusing. We would need additional clarification

Please provide any further comments below.

Other (please specify)

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* 5. USPS would permit no more than 40% of your paid circulation to be electronic subscriptions. If that ceiling reasonable for your newspaper? If not, please explain whether your newspaper is today primarily electronic with a small print circulation.

A 40% ceiling would be sufficient for my newspaper

A 40% ceiling would be too low for my newspaper

Other

Please briefly explain your response

Other (please specify)

Question Title

* 6. If the proposed rule is adopted before September 30, 2012, your newspaper would be permitted to count electronic subscriptions for the October publisher's statement. How would this new flexibility affect your newspaper?

We have existing electronic subscribers who could be immediately counted

We will begin selling electronic subscriptions right away to build up a base before October

We do not yet have electronic subscriptions but expect to offer that option to readers

We do not expect to have electronic subscriptions in the foreseeable future

Please provide any additional comment on this question here.

Other (please specify)

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* 7. Does your newspaper rely primarily upon the October publisher's statement as proof of circulation or do you use an auditing bureau, or both?

The USPS statement is our only proof of circulation

An independent auditing bureau (ABC, VAC or others) audits the newspaper

We rely upon both USPS and an independent audit

Please provide additional comment at your option

Other (please specify)

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* 8. The same options would be made available to requester publications, i.e., electronic requests for emailed facsimile or paid content behind a paywall would be counted as requesters, with the same 40% ceiling. Requests must be received in writing, either by hard copy or electronic. For requester publications, do these proposed rules make sense?

Please note states requiring a Periodicals permit without specifying paid circulation presently permit Requester publications to qualify.

Yes

Please briefly explain your response

Other (please specify)

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* 9. Please provide any other thoughts you wish to share with the Postal Service on the topic of electronic subscriptions.

Question Title

* 10. Please identify yourself. (Comments provided anonymously will not be submitted to the Postal Service.)

Name:

Company:

Address:

Address 2:

City/Town:

State:

ZIP:

Country:

Email Address:

Phone Number: