USPS to Bronx: Drop dead — the GPO must go

June 13, 2013

The Postal Service has decided to go ahead with the sale of the historic Bronx General Post Office.  Tom Samra, Vice President of Facilities for the USPS, has issued his “Final Decision for Relocation of Retail Services in Bronx, New York.”  (A copy is here.)

The Bronx GPO is on the National Register of Historic Places, it's an official New York City landmark, and it's the largest of 29 Depression-era post offices in the city.  As David Dunlap wrote in the New York Times, the post office has been "a centerpiece of life in the borough for more than 75 years, and a monumental gallery of the work of Ben Shahn, one of America's leading Social Realist artists."  Needless to say, the plan to sell the Bronx GPO has received a lot of attention.

The Postal Service announced its decision to close the Bronx GPO, sell the building, and relocate retail services on March 14, 2013.  As required by federal regulations, a thirty-day period for appeals followed.  The Postal Service received a lot of them.  There were twenty-one letters from individual citizens, plus letters from the Executive Director of the Bronx River Art Center, the President of the East Bronx History Forum, and the National Trust for Historic Preservation. 

The Office of the Bronx Borough President filed an appeal as well.  This one was signed by nine New York City Council members, ten New York State Assembly members, six New York State Senate members, and three members of the U.S. House of Representatives.  An appeal was also submitted by the law firm of Ford & Huff, acting on behalf of Bronx activist Julio Pabon and the National Post Office Collaborate, a Berkeley-based citizens organization fighting to save historic post offices.  (More about that here.)

The appeals were not enough to change Mr. Samra’s mind.  His five-page Final Decision briefly addresses the concerns expressed in these appeals, then concludes: “While the Postal Service is not insensitive to the impact of this decision on its customers and the Bronx community, the relocation of the Bronx GPO is in the best interest of the Postal Service.”

Several of the appeals argue that the Postal Service did not follow the procedural requirements described by the National Historic Preservation Act (NHPA), the National Environmental Policy Act (NEPA), and the statutes and regulations governing the closure of post offices.  Mr. Samra says the Postal Service has correctly followed all of the proper procedures so far, and it will continue to do so as the process continues.  But there’s plenty of reason to doubt that.


Relocation vs. Discontinuance

Normally when the Postal Service wants to close a post office, it must go through a lengthy discontinuance process, but the Postal Service says that it doesn’t need to do that for the Bronx GPO because it’s not really “closing” the post office.  It will be opening another retail facility somewhere close by, so in fact it’s merely “relocating” the post office.  That's what the Postal Service said when it sold the Venice post office, and that's what it's saying as it moves forward on selling the post offices in Santa Monica, La Jolla, Berkeley, Ukiah, and elsewhere.

That’s not just a word game.  It’s a legal distinction. The requirements for a discontinuance are outlined in 39 U.S.C. 404(b), and they’re described in more detail in 39 CFR 241.3 and the USPS Discontinuance Guide.  The relocation procedures are described in 39 CFR 241.4.  

As a look at these regulations shows, the requirements for a relocation are much less stringent and time consuming than for a discontinuance.  That’s because the impacts on the community are usually less significant when the post office is simply moving.  Of course, when the post office being “relocated” is a historic landmark building that plays a crucial role in the life of the community, things are a lot more complicated, but the Postal Service still maintains that it just needs to go through a simple relocation procedure, not a full discontinuance process.

Mr. Samra’s Final Decision makes a big point out of the fact the Postal Service is following the relocation procedures outlined in CFR 241.4, but that may not be the case.  There's a passage in these regulations that says if the relocation involves a property that is a historic building, the Postal Service should be following the more rigorous requirements of a discontinuance. 

The Postal Service delivers the last mile, almost: Changing modes of delivery

June 10, 2013

The Postal Service helps out FedEx and UPS by providing “last mile” delivery of their parcels, and two recent studies argue that the Postal Service should privatize its retail and mail processing networks and instead "concentrate on what it does best” — last mile delivery. 

But mail delivery ain't what it used to be.  More and more, the Postal Service is leaving the last stretch of the last mile to its customers. 

If you’re used to getting the mail delivered to your curbside mailbox, you can look forward to going down the block to pick up the mail at a cluster box unit.  If you get your mail at the door, you may need to put up a mailbox at the curb, or you too may be traveling to the nearest cluster box.  “Centralized delivery” is the wave of the future.

In January the Postmaster General announced that the Postal Service would be switching over to more centralized delivery points (i.e., cluster boxes) to improve delivery efficiency.   “We’ll be looking at some centralized delivery, rolling that out across the country – no major push, but starting to move on that,” said Donahoe.  The PMG said the expansion of centralized delivery would take time, but it would start this year.

“It’s an opportunity to save some money and also provide better service,” said the PMG, “especially with parcel lockers that we’ll be installing at the same time.”  That’s a reference to the Postal Service’s new “GoPost” automated parcel delivery lockers, as discussed in this excellent post on Going Postal.

The amount of money that could be saved by changing modes of delivery is considerable.  The Postal Service currently spends about $25 billion to deliver mail to more than 150 million homes and businesses.  The average annual costs for city delivery are $353 for door delivery, $224 for curbside, and about $160 for centralized.  For rural delivery, the costs are $278, $176, and $126, respectively.

A study on “Modes of Delivery” done by the USPS OIG showed that the Postal Service could save more than $4.5 billion a year by shifting 35 million homes and businesses from door-to-door to curbside.  It could save another $2.8 billion by shifting 52 million homes and businesses from curbside to a cluster boxes.  If the door-to-door delivery points were shifted to centralized instead of curbside, it would save another $2.2 billion. 

Congress seems ready to go along with the conversion plan.  Congressman Darrel Issa’s proposed legislation already has a provision pushing centralized delivery, and Senator Tom Carper says Issa’s idea to shift mail delivery from door delivery to cluster boxes may be included in some manner in the final bill.


A plan without a plan

For new residential developments, the Postal Service can use whatever mode of delivery it wants, and that usually means cluster boxes.  As a USPS spokesperson explains, “Where the builder used to have a choice on type of delivery, we’re choosing for them – or at least moving in that direction.”

The Postal Service is also looking to change the mode of delivery whenever it can.  As a postal spokesperson told Post & Parcel in late January, the first areas to experience a change to cluster boxes will be business parks, industrial buildings, and shopping malls where mail carriers currently go business-to-business to drop off mail. 

For residential neighborhoods, the Postal Service isn’t supposed to change the mode of delivery without the customer’s permission.  According to the “agreement clause” in section 631.6 of the Postal Service’s Postal Operations Manual, a customer's signature must be obtained before conversion from one mode of delivery to another.   

In April 2012, the Postal Service revised the POM to give itself more authority to determine the mode of delivery when adding new delivery points.  But the passage about the agreement clause is still in the POM, and there's nothing in the revised POM saying that the Postal Service can unilaterally convert the mode of delivery for existing addresses.  

Nonetheless, one postal manager in St. Louis recently sent a letter to the St. Louis Apartment Association (SLAA) stating the following: "The Postal Service has revised the POM giving the USPS the autonomy to make changes to current mode of delivery.  The Postal Service is not currently unilaterally changing any current modes of delivery.  But it now has the authority to do so."  

That manager may have it wrong about the POM, but his letter to the apartment association is another example of how the Postal Service is pushing current residences to convert to centralized delivery.  His letter says that the Postal Service will pay for conversion to cluster box units now, but owners who pass up the offer risk having to pay for it themselves later.

The Postal Service is also finding other ways to convert current delivery points to cheaper modes of delivery.  Under some circumstances, the Postal Service can change delivery for existing residences even without the owner's permission, like when the safety of letter carriers is a concern. The dangerous dog rationale for ending door-to-door delivery seems to be occurring with increasing frequency.

It's clear that the Postal Service is, as the PMG put it, “rolling out” more centralized delivery.  There’s obviously a plan behind all this, but the Postal Service has yet to file a request for an advisory opinion from the Postal Regulatory Commission.  Eventually, there will be so many news stories about delivery conversions that it will become clear that the Postal Service is making a change in service on a nationwide scale and it will have to submit a request for an advisory opinion.  In the meantime, the conversions are taking place on what is supposedly an ad-hoc basis, as if there were no plan in place.

In a previous post back in January, we noted several news reports about places where the mode of delivery was being changed.  Here are a dozen more.

Relocating the Peter Stuyvesant Post Office: What happened to partnering with the public?

May 30, 2013

The Postal Service is shutting down New York City’s Peter Stuyvesant Station at 432 East 14th Street and relocating retail services about a block away.  When it does a relocation like this, the Postal Service is supposed to follow section 241.4 of the Code of Federal Regulations on “Expansion, relocation, and construction of post offices."  But it appears that the law doesn’t count for much when the Postal Service is looking to save a few dollars on the rent.  It doesn’t look like customers matter much either.

The Peter Stuyvesant post office is located in a building that the Postal Service has been leasing since 1952.  It was constructed for the Department of the Post Office according to its specifications.  The building is old enough to be listed on the National Register of Historic Places.

The long-term lease on the property ended in February 2013.  The Postal Service’s notice about the relocation of Peter Stuyvesant Station says, “We have been unable to reach agreement with the landlord on a new lease.” 

There may be another explanation.  A representative of the owner, Benenson Capital Partners, says that the Postal Service informed him that it didn’t need such a large space anymore, and that’s why it wasn’t renewing the lease.  (He told this to postal employees, Town & Village Blog, and me.)  In any case, the Postal Service negotiated a one-year lease extension to give it time to find a new location and do the necessary renovations. 

As required by CFR 241.4, the Postal Service proceeded to inform elected officials about the planned relocation and to get feedback from the public.  Then it was time for the community to wait for the decision and, if necessary, to appeal.  The Postal Service has yet to inform elected officials or the public about its decision, but it has definitely made one.  It has already made arrangements to move to the new space.  

Yesterday Jonathan Smith, president of New York Metro Area Postal Union, received a letter from the Postal Service stating that the Postal Service had found a new location for Peter Stuyvesant Station at 333 East 14th Street.  The letter says the move will take place once the renovations are completed, probably February 2014 (when the current lease expires).

Union officials immediately contacted elected officials about the letter to Smith and possible violations of CFR241.4.  Today Mr. Smith received another letter from the Postal Service.  This one provides a copy of an "Employee Update, Service Talk" that is "being provided" to employees of the Peter Stuyvesant Station.  The service talk says that the Postal Service has made a determination to proceed with the relocation, and in accordance with CFR241.4, it will be notifying elected officals and giving the community an opportunity to appeal.

The service talk itself is dated yesterday, May 29; the cover letter to Mr. Smith is dated May 30.  It's not clear at this point if the Postal Service prepared the service talk before or after union officials contacted elected officials about yesterday's letter to Smith.   

Either way, the Postal Service will have a hard time explaining how the community's input can be meaningful if it has already made arrangements to move to 333 East 14th Streeet.  The federal regulations on relocations are intended to ensure that the community has time and opportunity "to be a partner in the decision-making process."  The Postal Service seems to have forgotten its partner. 


Fun with numbers: The Postal Service is losing $25 million a day, and other spurious memes

May 29, 2013

Yesterday the Postal Service released its preliminary financial report for April 2013.  The line on controllable operating expenses shows that the Postal Service basically broke even for the month.  It lost $1 million — less than 0.02 percent of April's revenues. 

For the first seven months of fiscal year 2013, the Postal Service has lost $131 million (0.3 percent of total revenues), compared to about twice that loss during the same period last year.  Total volumes are down 0.6%, but revenues are up 0.8% for the year to date.

That looks pretty good, but brace for the headlines.  They’ll say the Postal Service lost $900 million in April and nearly $4 billion for the year so far.  You’ll have to read deeper down in the news articles to learn that those numbers include the amount owed to the Retiree Health Benefits Fund (RHBF), which accounts for over 80 percent of the losses this year.

When reports like the April financial statement come out, the Postal Service, privatization advocates, and many members of Congress are quick to put the worst spin on the numbers.  That’s usually because they want to justify an agenda — downsizing the unionized workforce, eliminating facilities, reducing services, and privatizing as much of the system as possible through outsourcing, workshare discounts, and selling off assets.

In order not to make things too complicated for the general public — most of whom think the post office runs on tax dollars — the Postal Service likes to keep things simple.  So it sticks to repeating a few basic factoids: the agency is losing $25 million a day, it lost $16 billion last year, mail volumes are down 25 percent, and the taxpayer is headed for a bailout.

The numbers are supposed to be dramatic proof that people aren’t using the post office like they used to, and there are too many postal workers and too many postal facilities.  The only solution is cut, cut, cut.  As a closer look reveals, however, these numbers are misleading.  Rather than clarifying the situation, they obscure it.


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