1730 K Street, N.W., Suite 304

Washington, D.C. 20006

(202) 204‑2201

(202) 331‑3759 Fax


                                                                August 20, 2001


Manager, Delivery Operations

U.S. Postal Service

475 LEnfant Plaza S.W.

Room 7142

Washington, D.C. 20260‑2802


Re:      Opposition to Proposed Revision of CMRA Rules


Dear Sir:


I am writing to express my opposition to the proposed revision to the CMRA Rules which would make my keeping an ordinary business address‑‑not having to add a # and number after my suite number designation‑‑contingent on my having 1) a contract for 16 plus hours per month of office time; 2) a live telephone answer backed up by a voice mad; and 3) use of other services as needed.


I am the sole‑owner and sole‑operator of the above‑named business that, for small businesses and individuals, provides answers in the form of business information and locates business resources.


My business is relatively new and because I am trying to establish my business, I do not know in advance of actual usage of office time, the amount of time or services I will need or will use. What I need is flexibility and lots of it. I need flexibility to use office time, flexibility to use office space and flexibility to choose the services I will need or will use.


O.S.I. Management, an on‑demand office service, offers the flexibility my business and I need.


O. S. I. is more than a post office box service and the U.S. Post Office should not equate 0. S. T.'s services to the mailbox service of the Post Office or other mailbox type businesses. 0. S. 1. provides me with office space, a post office box service does not offer office space. O.S.I. allows me to meet with potential clients and to meet with them in a professional business setting, a post office box service does not provide a place where business owners can meet clients or customers; O.S.I. provides professional personnel to answer the telephone, and to answer the telephone in person, and not by way of an answering machine, a post office box service does not offer telephone services or personnel to answer a telephone; O.S.I. allows me to make and receive telephone calls and voice mails in a professional setting, a post office box service does not provide telephone and voice mail services; O.S.I. provides fax, copying and secretarial post office box services and does not offer fax, copying, or secretarial services.


Currently, I usually go to the office once a week, sometimes twice a week 1) to receive, retrieve and return necessary, return telephone calls; 1) to receive and review mail; and 3) to meet with potential clients.  The on-demand flexibility of O.S.I,. allows me to reserve space when I have no need for space, thereby making space available to other O.S.I. service users. At this point when I am trying to build a clientele, I do not need a lot of in‑office time.  I need to meet people and I do that by networking at functions, affairs, and activities out of the office. Requiring me to contract for

16 hours plus of in‑office time when I am trying to grow my business would be detrimental to growing my business.


I conduct an honest, legal business. The hours I use with coupled with the hours I spend networking are the hours it takes to make my business honest and legal.  The number of in‑office hours and out‑of‑office hours I use are the hours I deem necessary for

the success of my business. Fewer hours or more hours with O.S.I. would not make my

business any less honest or legal.


The CMRA Rules mentioned in paragraph one should not be imposed for the reasons stated previously, as well as for the following reasons. The CMRA Rules should not be imposed because to do so permits the postal service to determine what it think is best for small businesses in a conflict of interest posture. The Rules would result in more businesses resorting to post office boxes, hence more money for the postal service. The Rules would force people not needing 16 plus hours of office time to be afforded more time and pay more money than they currently use or pay. The Rules seem designed to require on‑demand office services such as O.S.I. to reduce its clients to accommodate the 16 plus hours of office time. The Rules seem designed to usurp the authority of the Federal Trade Commission to determine deceptive trade practice issues, to usurp the authority of the Small Business Administration which provides guidelines and rules for small businesses and to usurp the authority of the Labor Department which governs number of hours a person can or should work in a given time period. The Rules would put the postal service in the business of dictating the amount of hours entrepreneurs must work and where they must go to do their business.


Thank you for not imposing the proposed Rules.



Evanna Powell