NATIONAL
TELECOMMUNICATIONS AND INFORMATION ADMINISTRATION
UNITED STATES
DEPARTMENT OF COMMERCE
WASHINGTON,
D.C.
Response to
Request for Comments:
Section 105(a)
of the Electronic Signatures in Global and National Commerce Act
Communications
with respect to this document should be addressed to:
Kirsten
Envall
Public
Affairs Manager
United
Parcel Service
316
Pennsylvania Avenue, S.E.
Suite
300
Washington,
D.C. 20003
(202)
675-3362
NATIONAL
TELECOMMUNICATIONS AND INFORMATION ADMINISTRATION
UNITED STATES
DEPARTMENT OF COMMERCE
WASHINGTON,
D.C.
Response to
Request for Comments:
Section 105(a)
of the Electronic Signatures in Global and National Commerce Act
United
Parcel Service (UPS) respectfully submits these comments in response to the
March 2, 2001 Request for Comments on Section 105(a) of the Electronic
Signatures in Global and National Commerce Act (ESIGN). (Docket No. 010222048-1048-01) Section 105(a) requests the Secretary of
Commerce to conduct an inquiry and report to Congress on the effectiveness of
delivery of electronic records to consumers as compared with the delivery of
written records via the United States Postal Service and private express mail
services.
UPS
is the world’s largest package distribution company. In 2000, UPS delivered 3.5 billion packages and documents, and
earned $29.8 billion in revenue. On
average, UPS delivers 13.6 million packages and documents each day, or
approximately six to seven percent of the U.S. gross domestic product
(GDP). UPS serves every address in the
United States and more than 200 countries and territories worldwide with
approximately 359,000 employees.
UPS
supports ESIGN and the concepts it advances, and believes that it will
facilitate electronic commerce in ways not yet imagined. UPS sees many potential opportunities as
ideas and technology mature and ESIGN is fully implemented. These opportunities may take many years to
take shape, and we see our company as being at the forefront of their
development -- incorporating them into our existing products and services and
leading to the creation of new ones.
UPS
is an enabler of global commerce, providing the infrastructure that allows trade
to move in an efficient and reliable manner.
We blend three flows of commerce in the marketplace: the movement of
goods, information and funds to provide total supply chain solutions to our
customers. We use technology to enhance
each of these three flows of commerce.
The delivery of physical goods is our core business, and we see that
continuing as we move forward. The
development of the “virtual world” will not replace the physical delivery of
goods, but rather will both coexist and enhance each other. The development of electronic commerce has
allowed UPS to offer “value added” services that enhance our core business of
package delivery.
UPS’s
core business is the movement of physical goods in a door-to-door transaction
(as opposed to mailbox-to-mailbox). We
offer different levels of service, many with time-definite delivery and
money-back-guarantees. Our services
range from Next Day Air Early A.M. (guaranteed delivery by 8:30 a.m.) to our
regular ground service, and can meet a wide range of customer needs.
The
proliferation of the Internet has enhanced package volume at UPS and allowed
new goods to enter our system both in terms of business-to-business and
business-to-consumer transactions. Zona
Research found that during the 1998 holiday season, UPS delivered 55 percent of
all goods ordered over the Internet.
The
development of electronic document delivery has allowed UPS to develop new
products that utilize technology. UPS
Document Exchange is a suite of products that enables users to immediately ship
over the Internet anything that can be contained in a digital file, including
documents, images and software. UPS
OnLine Courier is the most popular of these products. It provides secure document delivery by providing up to 128-bit
encryption, password only access, instant delivery notification and allows the
sender to recall or cancel delivery of the file. UPS OnLine Courier allows the transmission of files up to 70 MB
in size.
This
electronic product provides significant time and cost savings versus physical
delivery. In addition, electronic
documents are more portable than physical (paper) documents, and the amount of
business conducted by mobile workers is growing. UPS meets the needs for mobile, portable documents through access
to UPS OnLine Courier from wireless or portable web-enabled devices.
While
the market demand for UPS Document Exchange and similar products has not yet
developed, we see them as having real potential in the financial services, legal
and medical fields. We continue working
to develop demand for this product.
Almost
as important as the movement of physical goods is the information about
them. UPS tracks every package moving
through our system in real-time and makes that information readily available to
our customers. UPS invests
approximately $1 billion a year in technology to build and enhance systems that
provide thorough, timely and accurate information about each package moving
through our system. Technology allows
UPS to provide information-based, value-added services to our customers, which
compliment our core business of package delivery.
The
UPS website, www.ups.com,
receives approximately 40 million hits per day, 4 million of which are online
tracking requests. By tracking a UPS
package on the Internet, the customer is able to receive instantaneous
information about their package. It is
also much cheaper for UPS to provide tracking information via the website
versus our telephone customer service lines.
UPS
provides customers with Web-enabled tools to help them solve their
transportation and logistics needs.
Customers can download UPS OnLine Tools from the UPS website and imbed
our services into their own website or desktop. Some of the functionalities UPS OnLine Tools provides include:
UPS Tracking, UPS Signature Tracking, UPS Rates and Service Selection, UPS Time
in Transit, UPS Address Validation, and UPS Shipping. There are approximately 50,000 users of UPS OnLine Tools.
Information
can also create internal efficiencies at UPS, which in turn benefit our
customers. For international shipments
entering the United States, UPS collects basic information about each shipment
and electronically transmits that data to U.S. Customs. Customs is able to analyze the information
and determine which shipments to clear and which shipments to inspect – before
the packages arrive in the U.S. As a
result, we are able to fulfill our obligations to Customs while maintaining our
service commitments to our customers.
Electronic
information can also trigger other automated business processes (such as
billing or inventory management), thereby reducing costs and improving
responsiveness and quality. UPS has
pioneered efforts to equip business with the information that enhances
inventory control and other business planning and business operations
software.
The
UPS Capital Corporation, a wholly owned subsidiary of UPS, provides financial
products and services that enable growing businesses to expand operations,
market to new accounts, improve inventory, accelerate cash flow, lease new
equipment, expand working capital, and reduce risk. UPS Capital Corp. offers C.O.D. enhancement services,
distribution finance, equipment leasing, electronic invoicing and payment,
global trade finance and insurance solutions.
These financial services work in tandem with our package delivery and
information-based services to provide total solutions to our customers.
* * * * * * * *
UPS
seeks to integrate three flows of commerce to help customers solve their
transportation and logistics needs: the movement of goods, information and
funds. The development of electronic
commerce, including tools like electronic document exchange and electronic
signatures, enables UPS to add value to existing products and services, and to
develop new products and services that enhance these three flows of commerce.