The Denver Business Journal's Amy Bryer is critical towards the way that the Denver Post and Rocky Mountain News are citing their combined circulation to advertisers. The method, while legal by the rules of the Audit Bureau of Circulations, could be viewed as violating "the spirit" of the guidelines regarding circulation count. Bryer states that the newspapers include "bulk" copies delivered to places like hotels and restaurants as their overall circulation, even though the end-reader may pay as little as $0.00 for a copy. While most newspapers also include these same figures in their own circulation counts, Bryer believes that the fact that the bulk distributions of these papers is making up more than 10% of their total circ (actually around 13%), that something is out of whack.

As the average consumer slowly and surely drops their newspaper subscription and low-paid or unpaid circ such as those described above probably stays static, will the ABC be forced to make changes to their guidlines in this area?