February 28, 2012
BY MARK JAMISON
"These men combine to bring about as much financial stress as possible, in order to discredit the policy of government and thereby secure a reversal of that policy, so they may enjoy unmolested the fruits of their own evil doings. I regard this contest as one that will determine who shall rule this free country — the people through their chosen representatives, or a few ruthless and domineering men whose wealth makes them peculiarly formidable because they hide behind the breastworks of corporate organization." — Theodore Roosevelt
IN 1947 A NUMBER OF NUCLEAR SCIENTISTS got together and unveiled a public relations device known as the Doomsday Clock. It was a symbolic clock face, and the nearer the hands came to midnight, the closer we were coming to nuclear disaster. The clock was initially set at 11:53, and over the years the hands have been moved, sometimes nearer to 12:00, sometimes backing away, in response to the world’s geopolitical situation.
If such a clock existed to represent the fate of the United States Postal Service, the second hand would be finishing its last few clicks before the clock chimed midnight and disaster struck. The actions of Postmaster General Donahoe and the USPS Board of Governors have methodically ensured that we would be reaching this moment with an ever-increasing sense of eventuality.
Over the past few years the leadership of the Postal Service has offered numerous predictions regarding the financial status of the organization, each more dire than the previous. Usually the predictions have been accompanied by a set of Draconian prescriptions intended to “save” the patient.
It has become a predictable exercise. The PMG announces another huge loss and anticipates even greater losses down the road, and then he claims he must be given the power to radically alter the nature of postal services so that he can pursue a more successful business model.
At each juncture, when the public or politicians have questioned Mr. Donahoe’s plan, he has responded with new, even more dire predictions and even more radical solutions. He has been goaded on by two Republican Congressman, Darryl Issa and Dennis Ross. Like villains in an old B-movie, they have licked their chops and curled their mustaches at the prospect of the destruction of several hundred thousand public-service, good-paying, union jobs.
Playing foils to Issa and Ross are Senators Susan Collins and Tom Carper. They fill the role of the “responsible” parties because they have shepherded previous legislation through the sausage grinder, legislation that has turned out be about as useful as Neville Chamberlain’s claim to have achieved “Peace in our time.” The PAEA that they designed can take much of the credit for the huge deficit the Postal Service now unnecessarily faces.
The various associations of business mailers have chimed in as a cheering section. They view the Postal Service as their personal lapdog, and they act as though the sole purpose of the postal system is to provide them with low rates and guarantee their profits.
Sadly, the mechanisms that are designed to provide oversight and regulation of the Postal Service have no real teeth. The management structure of the Postal Service, from the BOG down through the executive corps, faces nothing that would ensure real accountability. They do as they please.
AT THIS POINT I AM CONVINCED that in a very real sense Mr. Donahoe has won. Regardless of what political or legislative actions may take place over the coming weeks and months, Mr. Donahoe has already done so much damage to the image and brand of the Postal Service, it will be impossible to undo it. He has so thoroughly undermined the organization’s morale and so completely polluted the dialogue with misrepresentations and visions of doom, that it would be nearly impossible to get the stink of a rotting corpse off the Postal Service.
Congress, for its part, will not be able to act swiftly or forcefully enough to prevent at least a significant part of Mr. Donahoe’s agenda from being implemented. No Capraesque miracle is going to stop the PMG and save the post office. There's no Jimmy Stewart or Gary available for a heroic climax.
February 28, 2012
The USPS is looking at closing the White River Junction, VT Processing and and Distribution Center, which would result in the loss of hundreds of jobs for the area. In addition, the changes would deteriorate the delivery service for people all across the area. At the public hearing in White River Junction, members of the community spoke about the importance of the Post Office as a public good, and expressed their support for postal workers. For more information, go to savewhiteriverpdc.blogspot.com. This video was produced by the media committee of the Vermont Workers' Center: www.workerscenter.org/media
February 23, 2012
The Postal Service has announced its decisions on the mail processing plants it's been studying for consolidation. The APWU has the list of which plants are closing and which will remain open here.
The list shows 264 plants that were being studied. The Postal Service determined that 223 could be consolidated, entirely or in part (a few workers might remain). Some 35 were disapproved for consolidation and will remain open; another six are still under study.
The Postal Service says 40 of the facilities slated for closure did not even go through an AMP study process because they were annexes or mail processing operations within "customer service facilties," which can be closed without a study. While no public meeting is required for these plants, the Postal Service is inviting customers to provide feedback. There's more information on the USPS FAQ page.
(If you have more information, like when you've heard a plant might close or the reasons for the decision, please hit the contact link at the top and send a note.)
The closings could begin as soon as May 19, a few days after the moratorium ends on May 15. It’s going to be a very stressful week, to say the least, and the Washington Post tells us that the Postal Service is increasing security at the plants. (It's good to know that the consolidation plan is already generating extra work for some sectors of the workforce.)
There are about 150,000 workers in the network of processing plants, and over half of them may be affected by the closings. As many as 35,000 positions will eventually be eliminated by the consolidation plan, mostly through “attrition” — workers quitting or retiring because they can’t move the family or don’t want to make a long commute (like 50 miles — or more). The USPS FAQ sheet says about 30,000 will be career employees, and the other 5,000 will be non-career posittions.
The Postal Service isn’t waiting to hear what the Postal Regulatory Commission (PRC) has to say about the Network Rationalization plan. The PRC’s Advisory Opinion is due out in late summer, probably August or September, but the Postal Service plans to get started on the consolidations as early as May.
It’s disconcerting that the Postal Service is in such a rush to begin closing the plants, especially considering that it has only itself to blame for when the Advisory Opinion will be ready. The Postal Service could have submitted the Request for an Opinion four months earlier.
In August, the Postal Service was already briefing “outside parties” (like industry stakeholders) about the plan, and as of late September, it intended to submit the Request in October. But for some unknown reason, the Request was not submitted until December 5. Perhaps one day we will learn the cause for that delay.
When the PRC announced its Procedural Schedule indicating that the Opinion wouldn’t be done until around August, the Postal Service filed a request to accelerate the schedule. The PRC turned down that motion because moving too quickly would endanger due process.
In the reply to the Postal Service’s motion to speed things up, the Public Representative noted that the Postal Service itself had delayed submitting the request. “The Postal Service’s need for the Commission to abandon prudence and hastily issue an advisory opinion is not, however, supported by the Postal Service’s actions. The Postal Service notes that it briefed outside parties on August 9, 2011 about the network rationalization. Likewise the Postal Service has produced documents in discovery demonstrating that it intended, as late as September of 2011, to submit an advisory opinion request to the Commission in October of 2011. However, the Postal Service did not file its request until December 5, 2011.”
It’s not clear why the Postal Service is now in such a hurry and why it wants to close so many plants in such a short time. It’s a sure formula for chaos in the mail system, and delays in delivering the mail will be inevitable, probably much worse than the change in service standards for First-Class mail that's already part of the plan.
Perhaps the Postal Service wants to increase pressure on Congress to pass legislation, perhaps management really believes its own hype about how dire the situation is, or perhaps they just want to amp up the sense of emergency to help further their agenda.
Whatever the reason, the Postal Service is basically thumbing its nose at the PRC and saying it doesn’t really care what the Advisory Opinion says. Many of the plants will be closed before the Opinion even comes out.
The PRC is the nation’s regulatory agency for the Postal Service, and it’s supposed to be ensuring that the Postal Service is in compliance with the law. The Postal Service is essentially saying it doesn’t care about the law. Let’s hope some of our legislators in Washington have a greater respect for the laws they make.
February 21, 2012
The Postal Service juggernaut keeps rolling on with its downsizing plans, and it seems prepared to crush whatever stands in its way — postal workers, post offices, communities, history. There doesn’t seem to be anyone or anything that can stop it — not Congress, not the unions, not the Postal Regulatory Commission. Perhaps it’s time for the People of the United States to take the U.S. Postal Service to court.
The opportunity for a legal case presented itself just a few days ago when the Postal Service released its Environmental Assessment (EA) of the potential impacts of the Network Rationalization initiative, the plan to consolidate 250 processing plants. The EA minimizes the potential effects of everything the Postal Service is planning to do, and the case, as they say, looks ripe for judicial review.
The FONSI Scheme
The EA was done pursuant to the National Environmental Policy Act (NEPA), which requires government agencies about to embark on an action that could have significant environmental impacts to conduct a thorough review prior to making decisions.
On February 10, the Postal Service released the environmental assessment describing the impacts of the plan. It’s called the Programmatic Environmental Assessment (PEA). You can find a pdf of the PAE here. (Note: It’s long — 170 pages plus appendices — and may take a while to download.)
Based on the results of the PEA, the Postal Service has issued a Finding of No Significant Impact (FONSI), indicating that the Network Rationalization plan will not have a significant impact on the environment.
A finding of “no significant impacts” is pretty amazing when you consider that the PAE encompasses everything from air quality to socioeconomic factors, and when you also consider that the scope of the PAE is not limited to the plant consolidation plan. NEPA requires agencies to consider the "cumulative effects" of a proposed action and the other related actions being proposed because effects may be exacerbated when they interact with each other.
The PAE thus considers several components of the USPS 2010 Action Plan, “Delivering the Future,” such as previous plant closings (AMPs), the Retail Access Optimization Initiative (RAOI) to close 3,652 post office, eliminating Saturday delivery, enhanced alternate sites like the Village Post Office, and disposition of “excess buildings.”
That’s a lot to consider, but the PAE still does not go as far as it should have. At the same time it was doing the PAE, the Postal Service was preparing its Five-Year Plan, and the new business plan goes much further than the 2010 Action Plan. Just in terms of post offices, for example, closing all 3,652 post offices in the RAOI would save $200 million, but the Business Plan indicates a savings of $2 billion in the retail network. That could only come from closing many thousands of post offices — probably 15,000, the number mentioned several times by the Postmaster General. The PAE does not even begin to consider the impacts of that component of the Five-Year plan. (More on the business plan here.)
According to NEPA, the agency doing the environmental review can come to one of three conclusions: (1) the action is a “categorical exclusion” (i.e., it’s so minor there won’t be any significant impacts, like installing energy efficient lighting); (2) there will be a significant environmental impact, in which case the agency must proceed to prepare an Environmental Impact Statement (EIS); or (3) the impacts are uncertain, in which case the agency must prepare an environmental assessment (EA). (There’s more about all this in the Citizen’s Guide to the NEPA.)
The Postal Service has gone down the third path, and the PAE, having reviewed the impacts, says the Network Rationalization plan, even combined with the RAOI and other actions, will not have a significantly adverse effect on the environment.
The Postal Service has thus issued a “Finding of No Significant Impact." The FONSI's main purpose is to show why the impacts will be negligible or at least not significant enough to merit a full Environmental Impact Statement. That would have taken a lot of time and effort, and even more important, it would have given the public an opportunity to get involved in a very considerable way, with a draft EIS, scoping meetings, public comment periods, expert testimony, and a final EIS.
The FONSI means that the environmental review of the Postal Service’s plans will have been very minimal, and the public will have essentially been excluded from any serious involvement with the process.