Postal Regulatory Commission Submitted 6/29/2012 8:18:10 AM Filing ID: 83295 Accepted 6/29/2012 UNITED STATES OF AMERICA POSTAL REGULATORY COMMISSION WASHINGTON, DC 20268-0001 Valassis NSA Docket No. MC2012-14 Docket No. R2012-8 COMMENTS OF NATIONAL NEWSPAPER ASSOCIATION, INC. IN RESPONSE TO NOTICE OF INQUIRY NO. 1 NOTICE OF FILING REDACTED COPY (June 29, 2012) Pursuant to the Commission’s Notice of Inquiry No. 1, National Newspaper Association (NNA) hereby provides information from the newspaper industry on the potential impact of the proposed Negotiated Service Agreement under review. NNA distributed two surveys to community newspapers. One was sent to its member newspapers. The other was distributed to a wide newspaper audience through state associations of newspapers. Responses to both surveys indicate that significant potential harm to newspapers exists both among small businesses and larger newspapers. NNA is making application for confidential treatment of certain information in the spreadsheets. This filing is the redacted copy of the two surveys under seal. Respectfully submitted, Tonda F. Rush KING & BALLOW PO Box 50301 Arlington, VA 22205 Sara DeForge Hough NATIONAL NEWSPAPER ASSOCIATION June 29, 2012 RespondentIDCollectorIDStartDate EndDate IP Address Email AddressFirst Name LastName Custom Data Does your newspaper operate in aThis market survey where is primarilyValassis forRed newspapers Plum/marriage that carrymail advertising pre-printed appears? inserts (either in the newspaper or a TMC/shopper) from durable or semi-durable goods advertisers? A list of nationally-known advertisers who may be eligible for the Valassis discounts appears here. Please check all that are presently in your paper or that have been in the paper over the past 2 years. If you do not see your advertiser on this list, please add any advertisers that might qualify for this category. Groceries and restaurants/fast food do not count as durable/semi-durable. If your advertiser draws more than half its revenue from groceries or food, it would not be eligible for the Valassis discounts. If your advertiser is local or regional (with businesses in fewer than 30 states) it would not be eligible for the Valassis discounts. If you are not sure, please list it and we will check it out. Yes No No, but it hasAbercrombie been in theAce & market FitchHardware inAdvance the past AutotwoAT&T years Parts WirelessAutoZone Barnes & Noble This survey is primarily for newspapers that carry pre-printed inserts (either in the newspaper or a TMC/shopper) from durable or semi-durable goods advertisers? A list of nationally-known advertisers who may be eligible for the Valassis discounts appears here. Please check all that are presently in your paper or that have been in the paper over the past 2 years. If you do not see your advertiser on this list, please add any advertisers that might qualify for this category. Groceries and restaurants/fast food do not count as durable/semi-durable. If your advertiser draws more than half its revenue from groceries or food, it would not be eligible for the Valassis discounts. If your advertiser is local or regional (with businesses in fewer than 30 states) it would not be eligible for the Valassis discounts. If you are not sure, please list it and we will check it out. Bass Pro Bed Bath & BestBeyond Buy Brooks BrothersBurlington CoatCostco FactoryDick's SportingFamily Goods DollarGap This survey is primarily for newspapers that carry pre-printed inserts (either in the newspaper or a TMC/shopper) from durable or semi-durable goods advertisers? A list of nationally-known advertisers who may be eligible for the Valassis discounts appears here. Please check all that are presently in your paper or that have been in the paper over the past 2 years. If you do not see your advertiser on this list, please add any advertisers that might qualify for this category. Groceries and restaurants/fast food do not count as durable/semi-durable. If your advertiser draws more than half its revenue from groceries or food, it would not be eligible for the Valassis discounts. If your advertiser is local or regional (with businesses in fewer than 30 states) it would not be eligible for the Valassis discounts. If you are not sure, please list it and we will check it out. H.H. GreggHome DepotJ.C. PenneyJo-Ann FabricsK-Mart Kohl's Limited BrandsLowe's Macy's This survey is primarily for newspapers that carry pre-printed inserts (either in the newspaper or a TMC/shopper) from durable or semi-durable goods advertisers? A list of nationally-known advertisers who may be eligible for the Valassis discounts appears here. Please check all that are presently in your paper or that have been in the paper over the past 2 years. If you do not see your advertiser on this list, please add any advertisers that might qualify for this category. Groceries and restaurants/fast food do not count as durable/semi-durable. If your advertiser draws more than half its revenue from groceries or food, it would not be eligible for the Valassis discounts. If your advertiser is local or regional (with businesses in fewer than 30 states) it would not be eligible for the Valassis discounts. If you are not sure, please list it and we will check it out. Michaels Nordstrom Office DepotO'Reilly AutomotiveRadio ShackRite-Aid Sam's ClubSears Sherwin-Williams This survey is primarily for newspapers that carry pre-printed inserts (either in the newspaper or a TMC/shopper) from durable or semi-durable goods advertisers? A list of nationally-known advertisers who may be eligible for the Valassis discounts appears here. Please check all that are presently in your paper or that have been in the paper over the past 2 years. If you do not see your advertiser on this list, please add any advertisers that might qualify for this category. Groceries and restaurants/fast food do not count as durable/semi-durable. If your advertiser draws more than half its revenue from groceries or food, it would not be eligible for the Valassis discounts. If your advertiser is local or regional (with businesses in fewer than 30 states) it would not be eligible for the Valassis discounts. If you are not sure, please list it and we will check it out. Sports AuthorityStaples Target TJX Toys R Us Tractor SupplyTrue Value Verizon WirelessFoot Locker This survey is primarily for newspapers that carry pre-printed inserts (either in the newspaper or a TMC/shopper) from durable or semi-durable goods advertisers? A list of nationally-known advertisers who may be eligible for the Valassis discounts appears here. Please check all that are presently in your paper or that have been in the paper over the past 2 years. If you do not see your advertiser on this list, please add any advertisers that might qualify for this category. Groceries and restaurants/fast food do not count as durable/semi-durable.If you lost If your theIn advertisertherevenue past twofrom draws years, the more advertisers haveIn thanthe you past half movedyou twoit schecked revenue years, a newspaper havein from Question you groceries or movedTMC/shopper 2, approximately or a food,newspaper itINTO would how theor notTMC muchmail? be OUT eligible gross of annualthe for mail?the revenueValassis If so, please would discounts. itstate cost the your If yourprimary paper? advertiser reason. is local or regional (with businesses in fewer than 30 states) it would not be eligible for the Valassis discounts. If you are not sure, please list it and we will check it out. Williams-SonomaWalgreens WalMart Others? Other (pleaseOpen-Ended specify) yes Responseno Yes In the past two years, have you movedIf the a Valassis newspaper discounts or TMC were OUT to of take the effectmail? forIf so, your please advertisers state the named primaryIf thein Question reason.Valassis 2,discounts what would were be to the take most effect, likely would result? it have any effect upon your future use of the mail? If so, please describe. No Other (pleaseWe specify) would loseWe thewould business keepWe wouldthe and business itkeep Nothingwould the buthurt business have theOther companyto comments?anywaysteeplyOther and/or discountwithout (please our further Open-Endedthe news specify) advertising, discountingcoverage Response which would hurt the company and/or our/news coverage Does your newspaper (orIf your your newspaper groupDo if you group were request owned) no longerthat have NNA able fewer file to your serve than information 500your employees? community Whatwith the would or Postal had best to Regulatory drastically describe yourcutCommission costs, viewpoint what in about aeffect confidential this would Valassis/USPS it file,have which on the would proposal? local make news it available unavailable to your to the readers? public or other companies, but available to attorneys? Yes No Open-EndedYes ResponseNo Other Other (pleaseIt is specify) fair competitionIt is unfair competition from the government Yes Yes Yes Yes Yes Yes No Yes Yes No Yes Yes Yes Yes No Yes Yes Yes No Yes No Yes Yes Yes Yes Yes Yes Yes Yes Yes No Yes Yes Yes Yes No Yes Yes No No Yes Yes No No No Yes Yes Yes No Yes Yes Yes Yes Yes Yes Yes Yes No Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No Yes Yes No Yes Yes Yes Yes Yes Yes Yes Yes No Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No Yes Yes Yes No Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No Yes No Yes Yes Yes Yes No Yes Yes Yes Yes Yes Yes No Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes What would best describe your viewpoint about this Valassis/USPS proposal?Please provide identifying information.