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and thus, most of their tenants have not been

tion about them filed under the pre-PMB

asked to submit to the new regulations. At

address. Many businesses have in circulation

some point those tenants might find that

promotional literature, books, and CD/ROMs

their mail is not being delivered because of

with the pre-PMB addresses that cannot be

their failure to comply with regulations of

changed. And many CMRA renters will simply

which they were unaware. In addition,

not think to send notices to individuals or

because the USPS decided only in late April

establishments that send mail to them infre-

1999 that executive suites and similar com-

quently or irregularly. Most individuals, for

panies would be subject to those regulations,

example, might not think to send their auto-

the businesses and their tenants did not have

mobile manufacturer a change-of-address

an opportunity to register their opinions

form, or know where to send it. Under the new

during the 1997 comment period. The move

rules, the Postal Service would refuse to deliv-

to include executive suites and similar orga-

er a recall notice without the PMB address,

nizations under the new regulations also cuts

thus possibly subjecting the car owner to seri-

off a sanctuary of privacy previously offered

ous danger. Others that might not receive

to small businesses by those organizations.

change-of-address notices could include cus-

tomers that have not done business with an

enterprise for some time, alumni associations,

Undelivered Mail

and hospitals.

Moreover, the new address regulations

assume that individuals who mail to CMRA

The new regulations seem to violate a fun-

boxes will be as meticulous in observing the

damental operating principle of the Postal

new strict rules as is the Postal Service. Many

Service--namely, that the USPS make every

people might continue to put a box number

reasonable attempt to deliver the mail. Under

on the same line as the street address--for

the new rules the Postal Service will make no

example, "123 Main St., PMB 4." It will be dif-

effort to deliver mail to a CMRA box holder.

ficult for many individuals, who assume that

The friendly carriers who for years have been

mail carriers have the common sense to fig-

delivering to individuals in care of their

ure out small variations in address format-

CMRAs, who know exactly where those boxes

ting, to learn that obedience to burdensome

are, after October 24, 1999, will be required to

regulations, not delivery of the mail, is the

withhold mail without the PMB address on a

Postal Service's priority.

separate line. (In the June 25 press release,

The forwarding of CMRA mail creates

USPS officials suggested that they might

another problem. People can have mail for-

move that date back to April 26, 2000, but this

Without the PMB

warded to a new address for six months.

simply delays the problem instead of eliminat-

address, the

Usually the CMRA will collect a week's or two

ing it.) The situation also raises the question of

Postal Service

weeks' worth of mail and send it via the

whether the new regulations violate interna-

Postal Service to a new CMRA or a regular

tional treaties that require the Postal Service to

would refuse to

mailbox of the box renter's choice. That for-

attempt to deliver international mail.

deliver an auto

mer box renter must pay the CMRA for the

Refusal to deliver mail without the PMB

recall notice, thus

postage.

address is contrary to past USPS practice.

Under the new CMRA regulations, the

When ZIP codes were introduced, the Postal

possibly subject-

Postal Service will not deliver mail addressed

Service did not have the authority to refuse

ing the car owner

to any individual in care of a CMRA without

delivery of mail without those codes after a

a new Form 1583 and the two forms of iden-

certain day. Even today, although it may take

to serious danger.

tification that must be shown in person at

longer, the USPS will deliver mail without a

the CMRA. That includes former box renters

ZIP code.

who were having their mail forwarded before

The new regulations also make it impossi-

the new regulations took effect and who still

ble for box holders to know who has informa-

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