Issues over the two documents under seal


[PRC Advisory Opinion Document Summary]

Two documents have been provided to the PRC that are "under seal," i.e., not available for public review: (1) Material Related to Postal Location “Nearest- Neighbor” Calculation and Results, and (2) Material Related to Revenue Distribution and Single Stamp Sale Analyses.

The Postal Service explains that these materials should be kept private as a matter of “good business practice.”  These documents contain “commercial information of the Postal Service, such as facility-specific walk-in-revenue at thousands of facilities throughout the country, as well as disaggregated walk-in revenue for selected locations.”  Were this information to become public, “the Postal Service considers it quite likely that it would suffer harm. Revealing Postal Service facility-specific walk-in-revenue as well as disaggregated walk-in revenue would enable competing companies to use the information to assess market potential for establishment of competing mail and parcel stores. The Postal Service considers it highly probable that, if this information were made public, local competitors would take advantage of it.”

The Postal Service provides a “hypothetical”: “Facility-specific financial information or disaggregated walk-in revenue concerning a particular location is revealed to the public. A nearby private commercial mail receiving agency reviews the information, and determines that a discontinuance will affect enough potential customers at the postal location to justify an advertising campaign targeted at existing Postal Service customers. The private company directs advertising for its mailbox and shipping services to existing Postal Service customers, thereby causing the Postal Service to lose business to the competitor.”

Limited Participant Popkin has filed a motion (July 28, 2011) to have this material made public.  With respect to the Nearest Neighbor file, he says, “By not providing an explanation of what Nearest Neighbor Calculations show or why they should be nonpublic, I am not able to evaluate the Postal Service’s request nor can I believe that the Commission can.”

With respect to the revenue calculations file, he says, the Postal Service should be required to provide the revenue bracket that each of the facilities lie in so that participants will be able to evaluate the accuracy of the listing of facilities subject to evaluation.

In response to Popkin’s motion, the Postal Service says (Aug. 4, 2011) reiterates what it said in its initial filing, namely that public disclosure of a revenue range for the facilities on the list “would add nothing to the consideration of the issues raised in this docket, and would likely cause commercial harm to the Postal Service as the Notice describes.”

 (While it may be understandable why the Postal Service would want to keep some of this revenue information private, it seems strange to keep the data about Nearest Neighbor out of the public eye, given that it’s all easily available on the USPS post office locator and Google maps.  In fact, on my website, you can easily see how far other facilities are from any given post office.)

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