513 Eastern Blvd · Essex, MD 21221 · 410-780-3303 · FAX 410-780-2616

The Honorable Alan M. Wilmer, Chair

Linda M. Shuett, Vice-Chair
Members of the Standing Committee on Rules of Practices and Procedures
C/O Sandra F. Haines, Reporter
2011-D Commerce Park Drive
Annapolis, Maryland 21401

November 19, 2020

RE: Definition of “Newspaper”

Dear Rules Committee:

As the owner and publisher of East County Times, I urge the Rules Committee to legalize my free
newspaper. By that I mean, give my journalistic enterprise the same legal standing as my larger
corporate rivals. The origins of my paper date back to 1962 with the founding of the Essex Times, and
I've personally carried the community publishing torch in Eastern Baltimore for the last decade and a
half. If readers didn't read us, and advertisers didn't get results, we wouldn't be in business today.

Our success comes from being free -- sharing more news and information with more readers -- and
getting better results at a better price for our advertisers. The attached handout shows how legal
advertisers could get the same benefits our community and commercial advertisers can legally take
advantage of today – three to four times the audited circulation for one quarter the price.

What is at issue here today is the fact that well established, free community newspapers are currently
discriminated against by law from publishing legal advertising. The law says we must be punished --
and our potential advertisers must be punished, and our community must be punished -- because we
choose not to nickel and dime all our readers with an extra price per copy for our print edition. All the
while, free is what all of us are doing on the web.

Everyone inside our industry knows that advertising already accounts for at least 80% of the revenues at
all newspapers -- including those squeezing a few extra shekels out of readers. The small difference is
that we go 100% -- just like the other independent publishers calling for change. That model brings a
larger, loyal readership -- and that is independently measured. We can show that with third-party audits,
a level of verification that was never provided by Postal Standards. Today, hardly anybody is even using
the Postal classification referenced under Maryland law.

In closing, I pose three sincere questions back to this Committee:

1) After all these years, how could I still be in business if nobody read -- and advertisers didn't get
results in my paper?
2) Why should the East County Times, our employees, our community and prospective advertisers be
punished because we choose to share our paper free of charge -- and not nickel and dime our
communities?

3) Why should my paper need to qualify for Federal Postal standards that are an endangered species,
and nobody under Maryland law is actually checking for compliance? I already have an independent
audit of circulation that far exceeds measures even hoped for when that dusty language was written
decades ago.

Thank you for this opportunity.

Sincerely,

George Wilbanks
Publisher

Member: MDDC - Maryland • Delaware • DC Press Association

MACPA - Mid-Atlantic Community Papers Association
AFCP - Association of Free Community Papers
IFPA - Independent Free Papers of America