A Complaint gives the PRC another crack at POStPlan

December 3, 2012

The post office in Great Cacapon, West Virginia, is on the POStPlan list, and in January its hours will be reduced to six a day.  A nonprofit organization named AdvoCare has filed a formal Complaint with the Postal Regulatory Commission challenging the Postal Service’s decision to cut the hours. 

The Complaint finds several faults with how POStPlan is being implemented, but its main point is that the Postal Service is presenting communities with a false choice.  The survey says customers must choose between having the window hours reduced or having the post office undergo a discontinuance study, but it is clear that the study can lead to only one outcome — a Final Determination to close the office.  By making the outcome a fait accompli, the Postal Service turns a discontinuance study into an empty gesture and abrogates its responsibilities under Title 39.  Communities are left with no real choice at all.

Given that the Commission's advisory opinion has already given the green light to POStPlan, it’s not likely that the Complaint will have much of an impact on the Postal Service's plans to cut hours at 13,000 post offices.  But the Complaint raises some serious issues with POStPlan that weren’t addressed during the PRC’s advisory opinion process, so it will be interesting to see what happens now that the plan is back before the Commission.

The AdvoCare Complaint is here; the Postal Service’s Motion to Dismiss the complaint is here, and AdvoCare’s Response to the Motion to Dismiss, here.

 

Standing room only

Because there’s a postmaster vacancy at the Great Cacapon post office, it was among the first offices being reviewed under POStPlan.  Hundreds of people responded to the survey, and over 150 attended the public meeting in October.  It was standing room only, and no one was very happy about seeing the hours reduced and their fill-in postmaster leaving.

The post office has been operated by Rick Dunn, a supervisor from neighboring Berkeley Springs, for quite some time — long enough for the folks in Great Cacapon to come to appreciate his services.  As reported in the local news, many small businesses use the post office just because Dunn is so knowledgeable.  "He knows the answer to everything I've ever asked,” said one customer.  “If he has to leave, I won't send packages through the post office anymore."

Dunn has helped out seniors, shut-ins, and the entire community.  One resident said Dunn had called in a wellness check on a senior he hadn't seen in a few days. It turned out the man needed medical attention, and Dunn may have saved his life.  The people in Great Cacapon know that it's not likely they'll get the same sort of attention from the part-time worker who replaces Mr. Dunn when the hours are reduced in January.  

One of the people at the meeting was Keith DeBlasio, the director of a nonprofit called AdvoCare, which works on reducing crime through criminal justice reform.  Mr. DeBlasio was so disturbed by what he heard at the meeting — and by the lack of responsiveness of postal officials he contacted after the meeting — that he decided to submit a formal Complaint to the PRC. 

Mr. DeBlasio may not be an expert on postal matters, and he probably wasn’t a close follower of the evolution of POStPlan over the past year, but his Complaint seems to have struck a nerve.   The Postal Service has filed a very thorough Motion to Dismiss, packed with precedents and quotations, that runs to twenty-three pages.  (The Postal Service's Request for an Advisory Opinion was only ten pages, and the testimony of the Postal Service's only witness, Mr. Jeffrey Day, was twenty-four.)

The Motion to Dismiss is also surprisingly aggressive in its tone, especially when you consider that POStPlan has already been approved by the PRC.  Perhaps the Postal Service is concerned that the Complaint will give the Commission a second chance to examine some important questions about the legitimacy of POStPlan

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

November 26, 2012

BY MARK JAMISON

[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
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?

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