Playing Post Office

Whether to fight mail fraud as they allege or simply to legally ruin competition for the last monopoly protected area of their business, postal authorities will no longer play with renters of private mail boxes. By June 24 every one of the more than two million customers of what the USPS calls "Commercial Mail Receiving Agencies" (places such as Mail Boxes, Etc.) will be required by a "Procedural Revision," implemented by Postal Bulletin 21994 last March, to fill out and sign under notary a new Form 1583.

Form 1583 requires the disclosure of a considerable amount of personal information along with production of two items of valid identification one of which "must contain a photograph of the addressee" (for the vast majority this means a drivers license which, of course, includes a residence address) and the "other credential showing the applicant's signature and a serial number or similar information that is traceable to the bearer" (read: social security card).

The new form must then be filed with the post office for use in creating a massive new database. A photocopy of the ID's must be retained by the CMRA and made available to anyone who asks to see it -- not just law enforcement or someone with a warrant.

The new regulation is carefully constructed to circumvent two different federal laws.

First, under the Privacy Act of 1974, the Postal Service is prohibited from retaining all of this information itself. The new regulations force the CMRA's to act as their surrogate.

Second, federal law has always prohibited requiring an individual to provide his or her SS# for identification purposes. (This has, obviously, long since become something of joke; nevertheless, the law remains in force and the fiction of privacy in this regard must be maintained). You will note that, though no other document comes to mind that meets the criteria for the second form of identification, "social security card" is not specified.

But wait, there's more.

Within the next six months. Every CMRA box renter will have to somehow contact every potential person or entity that will ever send them mail any time in the future and advise them that henceforward the acronym "PMB" (Private Mail Box) must precede the renter's box number on a separate line in the address.

According to the revisions, any mail addressed to a private mail box renter after the October 11, 1999 deadline that does not have the required "PMB" designator in the correct place will not be delivered and will be returned to the sender (which, incidentally, suggests some interesting questions with regard to international treaties and the Postal Service's refusal for want of a "PMB" designation to deliver a piece of international mail.)

It has been conservatively estimated that these "Procedural Revisions" will mean $1 Billion in direct costs (new stationary and business cards, contacting all customers, etc.) to small businesses during the initial six-month compliance period.

"The primary reason for the new regulations," claims Inspector Tom Hall of the postal inspection service, "is increased security for the mail and to protect the American public -- both businesses and consumers -- from criminals."

This is a rather peculiar position in as much as providers estimate that less than 1% of private mail boxes are used for fraudulent purposes. (Inspector Hall, when challenged on the proportionality of this solution, admitted that he had no actual statistics at all on the extent of criminal use.)

Further, this compilation of personal data on more than two million people at over 10,000 CMRA locations around the country will open up vast new opportunities for the latest criminal enterprise: identity theft. By breaking and entering or even simply bribing an employee, a genuine criminal could gain access to all the information needed to get credit in the name of every one of a CMRA's customers.

And then there are battered women and other victims of stalkers. Long advised to provide themselves with some small measure of protection by utilizing PMB's, they will now be stripped of even this modest defense. Inspector Hall offered no "secondary" reasons for the measure, though privacy advocates could easily supply several.

One might think the CMRA's themselves would be up in arms over this whole situation.

One would be wrong.

"We do applaud them for addressing the issue," said Karen Gajewski, a public relations manager at Mail Boxes, Etc. "We, however, certainly feel that it is unfortunate that so many honest business people and consumers have to go through such trouble to comply."

Perhaps Ms. Gajewski is so sanguine because she assumes that, since the burden falls equally on all providers it will not disproportionately impact her company. If so, her naivete is breathtaking. People do not pay $15 or $20 dollars a month to have access to xerox machines and office supplies. They have private mail boxes because they want privacy. Under the new circumstances, they may as well use a home address. This postal "Procedural Revision" will destroy her entire industry.

But it's an ill wind, they say, that blows no good. And the dark cloud carried in on this bureaucratic breeze, indeed, has one, bright, shining, silver lining.

The kind of people who have private mail boxes are the same kind of people who have routine access to the internet. This clumsy move by the post office will undoubtedly hasten PMB users' transition to conducting all of their business via the burgeoning marketplace called "e-commerce" -- which eliminates the mail entirely.

Postal Bulletin 21994 may also sound the death knell for the post office.

Tim O'Brien is the Executive Director of the Libertarian Party of Michigan.