July 16, 2001
475 L’Enfant Plaza, SW – Room 7142
Washington, D.C. 20260-2802
We are responding to the USPS CMRA Reg. It is not appropriate to consider any OBC part-time clients as CMRA clients. They should not be lumped into the same category as mailbox clients of companies such as Mail Boxes Etc. The two industries have different NAICS (formerly SIC) codes. Our industry is defined as Lessors of Non-Residential Buildings (Code 531120) and Mail Boxes is defined as Mail Receiving Businesses (Code 561439); thus, the Federal government recognizes these as fundamentally different types of businesses.
Further, our part-time clients use services far beyond the scope of a mailbox service, such as a receptionist, live telephone answering, 24 hour voice mail, secretarial and word processing support services, catering for meetings, and the like. Our clients who use part-time offices are building their businesses to the point where they can take a full-time office, or, conversely, they may have downsized from a full-time office at the center. No such transitions are possible at a mailbox service.
Also, we would like to request an additional 30-day extension to allow for adequate comment time by others who are affected, such as our clients.
cc: Goldberg & Associates
888 16th Street, NW – Suite 700
Washington, DC 20006-4103
(and fax: 202.835-8293)