July 16, 2001
Manager
Delivery Operations
475 L’Enfant Plaza, SW – Room 7142
Washington, D.C. 20260-2802
Dear Sir:
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.
Sincerely,
Ali Abbasi,
President
cc: Goldberg & Associates
888 16th Street, NW –
Suite 700
Washington, DC 20006-4103
(and fax: 202.835-8293)