Manufacturing Emergencies: An open letter to the PRC on post office suspensions

November 26, 2012


[The following letter was recently sent to the Postal Regulatory Commission and Chairman Goldway in response to issues arising from the implementation of POStPlan.]

Dear Chairman Goldway,

I am writing to you directly but I hope you will share these comments with the other commissioners.

As you are aware, I was very critical of the decision in the POStPlan docket, not because the PRC failed but because the consequences of what was the ultimate result of the Commission’s legal responsibility fell far short of what would be the real world consequences. I think we are now seeing just how duplicitous the Postal Service can be as we witness emergency suspensions and office closures that are inextricably part of the POStPlan process.

There have been many issues that have arisen in the face of the implementation of this program.  I was heartened to see your call for information from the public, although I think the reality is that without a specific investigatory design much of what comes in will be anecdotal.  That’s a consequence of the system.  Your willingness to follow through is admirable.

The two issues I want to address here are the two most common reasons given for emergency suspensions, lease or building issues and lack of personnel to staff an office. Both are, at base, fallacious and constitute an ongoing example of how the Postal Service uses stilted interpretations to evade its responsibilities under the law.           

The PRC already has a long history with respect to suspensions based on building or lease issues.  PI2010-1 was opened just to address these issues, and I would refer the PRC to the comments I submitted in that docket.  The Postal Service has a long history of being abusive during lease negotiations. The tactics we are seeing today have been used for a long time.  The difference is that now they are part of a concerted effort to close post offices.           

As a postal lessor I was told that the Postal Service typically begins the renegotiating process about half way through the final term of a lease, generally from two and a half years to a year before termination.  This logically would give sufficient time to resolve ongoing issues related to the physical condition of a building or, if negotiations failed, to allow time for the identification and acquisition of suitable alternatives. Realistically in the latter instance the Postal Service has never been particularly enthusiastic about finding alternatives, but as the Commission has seen in many appeal cases, communities are often more than willing to locate alternative facilities.        

By shortening the negotiating process and by turning the negotiations over to CBRE, an outside contractor with a limited understanding of postal issues and perhaps with incentives that may not coincide with good faith efforts to renew leases, the Postal Service has cynically created “emergency” situations.  Given the circumstances, we should be very skeptical of any suspension related to a failure to negotiate a lease.

We should also look very carefully at suspensions related to unsuitable building conditions.  We should ask, how long has the condition actually existed and what previous attempts has the Postal Service made to address the condition?  I think the Commission will find that in many cases the condition cited as making a building unsuitable or unsafe has existed, unaddressed, for a significant period.  The condition may actually warrant not using a particular site, but is it an emergency if it is only being addressed now when other agendas are at hand?       

We should also be very careful in examining exactly what conditions the Postal Service is claiming make the building unsafe or unsuitable.  Are the conditions as described by the Postal Service accurate?  Are remedies demanded by the Postal Service reasonable or are they excessive, designed to create the circumstances of a suspension?  The behavior of the Postal Service merits skepticism.

Nothing stays these couriers: Postal workers deliver during Sandy

November 17, 2012

While nearly everything was shut down by Superstorm Sandy — airports, trains, subways, schools, businesses, and most of the federal government — the Postal Service was still up and running.  Postal workers were still out there delivering the mail, even on Monday, the day the storm hit.  The Postal Service’s unofficial creed — “Neither snow nor rain nor heat nor gloom of night stays these couriers from the swift completion of their appointed rounds” — took on a whole new level of meaning during those tragic days.

Postal workers didn’t just keep delivering the mail.  They also contributed to the relief effort.  For example, in upstate New York postal workers collected food contributions, gathering canned goods and other items left in mailboxes on their routes.  

The response of postal workers to the storm demonstrates how important the Postal Service is to the welfare and security of the country.  The Postal Service isn’t just a business, and it’s not just a bulk mail delivery network.  It’s something much more than that. 

Postal workers are an essential part of every community in the country.  Even though they may be feeling demoralized by all the downsizing, by the failures of Congress and postal leadership, and by the very real threats to their jobs and their families, they are out there doing their jobs, everyday, rain or shine, Sandy or not. 

As the images in this slideshow so dramatically illustrate, postal workers feel a special dedication to their jobs.  There's a postal worker in Keyport, New Jersey, for example, who delivers to a senior citizen high-rise that had to be evacuated.  He kept track of where everyone was going so he could continue delivering their social security checks.  “I know they needed them,” he said.  “Just being out there and showing the folks that something in town was working, and sharing information with them, that was important.”

As a resident of Brick, New Jersey puts it in one of these slides, “You have the greatest letter carriers.  While my husband and I were walking in the muck in our house, we heard this pounding on our door.  It was the letter carrier handing me my medicine!  I want to find out who he is. I want to take him to dinner. I love the Postal Service.” 

The postal worker who shared the slideshow had this to say: “This is who we are.  This is not just those impacted by a horrific storm.  This is the face of every American community, and it shows how truly essential postal workers are to the people we serve every single day.  This is what our forefathers had in mind when they said they said the post office was meant to bind this nation together.  This is you.  This is me.  This is all of us.”

Network Rationalization Update, with detailed schedule of changes

November 17, 2012

The Postal Service has published an updated list of the processing facilities that will be impacted by Phase 1-B of the Network Rationalization plan, which begins after the New Year.

Phase 1-A was implemented this past summer.  Though it was originally planned to include 48 plants, about 40 ended up being consolidated. The Postal Service took a break from the consolidations to avoid causing problems during the election and the holiday mailing season.  Phase 1-B, with 81 facilities, will begin in January 2013.  Phase 2 — if it’s ultimately implemented at all — would take place in 2014 and include about 100 plants.

The Postal Service’s letter to the Mail Handlers union is here, along with a pdf version of the basic list.  A more detailed list, with a complete schedule of all the planned changes, is available on Google Docs as a more user-friendly spreadsheet, here.  (You can download the original USPS spreadsheet here.)

A preliminary examination of the updated list indicates that there are a few changes from the list that was published back in May.  At that time, there were 92 facilities in phase 1-B (winter 2013).  The updated list shows 81 facilities.  

While there may be some errors here, as best as we've been able to determine, 16 facilities previously planned for consolidation in 2013 have been removed from the list.  Presumably they have been postponed until 2014.  There are 7 or 8 facilities that were postponed from phase 1-A (summer 2012)  to phase 1-B (winter 2013).  A couple initially planned for phase 2 (2014) may have been moved up to 2013.   Here's how the updated list differs from the May list.  Please note, this is entirely unofficial and there may be a few mistakes.  If you see one, let us know.

DROPPED FROM 2013 (Phase 1-B)
ADDED TO 2013 (Phase 1-B)
Facility (former phase)
Bakersfield, CA
Eau Claire, WI
Elizabethtown, KY
Gaithersburg Suburban, MD
Grenada, MS
Hazard, KY
Hot Springs Natl Pk, AZ
McAlester, OK
Memphis, TN
Montgomery, PA
Pasco, WA
Redmond, WA
Roswell, NM
Somerset, KY
St Cloud, MN
Wenatchee, WA
Bloomington, IL (2012)
Gaylord, MI (2012)
Kilmer, NJ  (2014)
Mansfield, OH (2012)
San Diego, Midway, CA (2012, 2014)
Waltham, NW Boston, MA (2012)
Quincy, IL  (2012)
Rockford, IL  (2012)
Southeastern, PA  (2012)
Suburban MD Annex (2014)
Terre Haute, IN  (2012)

Overall, it appears that the Postal Service has scaled down its phase-1 plans.  In the list released last May, there were 140 facilities — 48 in phase 1-A (summer 2012) and 92 in phase 1-B (winter 2013).  It now looks as though both stages of phase 1 will encompass about 127 facilities.  (You can see the original list here, and those that have been implemented, here.)

Phase 2 of the plan was to have included 89 facilities.  If those that aren't showing up on the new phaase 1-B list are being moved to 2014, that number will be more like 102 — unless some facilities aren't going to be consolidated at all.

It's still possible that phase 2 will never happen.  The Postal Regulatory Commission's advisory opinion basically recommended against it, at least until the Postal Service could see the effects of phase 1 and do some Post-Implementation Reviews.  

Since the Postal Service first announced the Network Rationalization initiative in December 2011, it has changed the plan several times.  The list originally had over 250 plants, but then several facilities were removed after the AMP studies were completed in February 2012.  Then in May 2012 the Postal Service released a revised plan with the two phases, 140 in phase 1 and 89 in phase 2.  Now it looks as though phase 1 has been pared down to 127.  If the consolidations stop there, Network Rationalization will have accomplished about half of the original plan.  

As for the total savings, the debate over the numbers has never been resolved.  The Postal Service's own estimates have been revised downward several times, but it has always maintained the plan would result in significant savings.  The PRC advisory opinion expressed considerable skepticism about the market research on revenue losses, and without a reliable estimate for the losses incurred by slowing down the mail, it's really impossible to say how much the plan will save.  

It's clear, however, that the plan will never save anything like the original estimate of $3 billion.  Yet the Postal Service's website nonetheless continues to cite that number.  Whether that's a clerical error, wishful thinking, or willful misinformation, who knows?

POStPlan becomes a reality: Hours cut at hundreds of offices today, thousands more after the holidays

November 17, 2012

After nearly two years of planning — going back to early 2011, when the Postal Service first proposed changing the rules about staffing post offices without postmasters and redefining "consolidation" — today POStPlan became a reality.  November 17 is the official implementation date for the first group of 500 post offices on the list.  Starting Monday, they'll be open six, four, or just two hours a day.  Over the next few months, thousands more will see their hours cut.  For 13,000 small towns across America, having the post office open a full eight hours a day will soon become a thing of the past.  

The Postal Service has been issuing weekly updates on the progress of POStPlan Implementation.  You can download a spreadsheet with the most recent data from the USPS website here.  An online Google doc spreadsheet is here; a Fusion table, here; and a map, here.  As of November 15, here’s where things stand.

Of the 13,000 post offices set to be reviewed under POStPlan, 5,932 are currently being studied, and a decision has been made to reduce the hours at 2,784 of them.  In only eleven cases has the Postal Service decided to proceed with a discontinuance study: Knoxboro, New York; Hayesville, Iowa; Seville, Georgia; Paoli, Colorado; Lees Creek, Ohio; Perks, Illinois; Fowlerton, Indiana; New Trenton, Indiana; Collins, Wisconsin; Gracey, Kentucky, and Cerulean, Kentucky.  There's no explanation yet on why these were selected for closure rather than reduced hours.

Over four thousand meetings have already taken place, and another thousand will take place over the next three weeks.  The following table breaks things down in more detail.

Meetings Held/Scheduled
Implementation Date Set

To avoid causing problems during the busy holiday mailing season, the Postal Service has declared a moratorium on implementing POStPlan for the period November 18 to January 12.  The public meetings, however, will continue through much of this period, except for December 8 through January 6.

The Postal Service has said it will not implement POStPlan at an office so long as a full-time postmaster is in place, so it has begun with offices where there is a vacancy.  

About 2,200 POStPlan offices had a postmaster vacancy when POStPlan was announced last May.  Around 2,000 POStPlan postmasters probably took the retirement incentive in July.  (A total of 4,000 postmasters retired, but the Postal Service hasn't provided a breakdown, so that's just a guess.)  Some 1,600 POStPlan postmasters probably transferred to a new position a few months ago (the first list of openings came out on May 25).  Another couple of thousand, maybe more, transferred to a position that opened up thanks to the retirements (the second list came out at the end of August).

That adds up to something like 8,000 offices with a postmaster vacancy.  Some 6,000 are currently under review, so another two thousand or more will be added to the implementation list sometime soon.

The Postal Service has repeatedly said that it would take two years to implement POStPlan, and that the process would be "gradual."   But not too gradual, it seems.  By next June, it would appear that over 8,000 post offices will have had their hours reduced — over 60 percent of the 13,000 offices on the list.  

Implementation may slow down at that point, since there won't be many postmaster vacancies opening up — until September 2014, when all those POStPlan postmasters who haven't moved to a new position will lose their jobs and the last of the offices will see their hours cut.  

The Postal Service just posted a loss of nearly $16 billion for the fiscal year.  Over $11 billion of it was due to the health care prefunding mandate; the remaining $5 billion was due to declining mail volumes.  The Postal Service says POStPlan will save about $500 million a year – about 3 percent of this deficit.  Considering how the Postal Service ballparked its numbers and didn't include anything for lost revenue due to shorter hours, even that estimate of annual savings is probably optimistic.  The actual savings will more likely be around $300 million — less than 2 percent of the deficit.  

So there you have it.  Some 13,000 communities suffer the loss of their postmaster and see the hours at their post office cut to a few hours a day, and for what?  So the Postal Service can make a virtually unnoticeable dent in its deficit.  

One can't help but wonder, could the travesty of POStPlan have been avoided if Congress had simply eliminated the unnecessary health care prefunding mandate and returned the FERS overpayments?  Looks like we'll never know the answer to that one.

(Photo credit: Post offices in New Trenton, Indiana, and Fowlerton, Indiana, both among the 11 post offices that will be studied for discontinuance.)


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