January 25, 2014
The Environmental Assessment (EA) on the disposal of the historic Atlantic Street Station post office in Stamford, Connecticut, was released a couple of days ago. For a dry, technical document about air quality, construction noise, and traffic issues, it’s a pretty interesting thing to look at. You can see the whole report, including appendices, here; the main part of the EA is here.
The Postal Service never wanted to do an EA on the Stamford post office to begin with. A few months ago, however, a federal judge in Connecticut issued a temporary injunction blocking the Postal Service’s sale of the post office to the Cappelli Organization, a Westchester developer. The Court ruled that the Postal Service had failed to follow its own federal regulations under the National Environmental Protection Act (NEPA).
The Postal Service had claimed a Categorical Exclusion (CATEX) from the requirement do a full EA about the potential impacts of the disposal of the property. The Court ruled, however, that the Postal Service knew about Cappelli’s development plans, which included razing a 1939 addition to the building and constructing two high-rise apartments, and it was clear that they would have a significant environmental impact, making a CATEX inappropriate.
The Postal Service could have fought the Court’s ruling on the NEPA issue (as it is doing on the other counts in the complaint), but that might have taken a very long time, so instead it decided to go ahead with an EA. But to prevent this kind of problem occurring in the future, the Postal Service also filed a notice in the Federal Register announcing that it intended to change its NEPA regulations and broaden the scope of the CATEX. (There’s more on that story here.)
At first glance, the EA report on the Stamford post office seems thorough enough. It even considers environmental impacts of the construction project on “common mammalian species that may be found in the area,” such as Sciurus carolinensis and Rattus norvegicus (gray squirrels and Norway rats), as well as “avian species” like Columbia livia and Sturnus vulgaris (pigeons and starlings).
But when you get into the report a bit further, questions arise about how the EA deals with alternative scenarios and who wrote the report in the first place.
January 24, 2014
BY MARK JAMISON
Accusations that the PMG’s ultimate goal is to privatize the Postal Service are apparently starting to make some of the folks at L’Enfant Plaza a little touchy.
On January 17, the Washington Post ran a story about the new postal counters in Staples that included a quote from Senator Jon Tester of Montana: Donahoe “can say whatever he wants but I think he wants to privatize. And I think there’s plenty of people in Congress who agree with that. I don’t.”
This isn’t the first time Senator Tester has expressed skepticism over the intended direction of the Postal Service. In two hearings held a week apart last September, Senator Tester expressed much the same opinion. At the hearing on September 19, the senator opened his questioning of the PMG like this: “I would say that if the goal is to privatize the Postal Service, then we ought to have a bill to do exactly that and move forward. I think it would be a mistake, but nonetheless we ought to have that debate.”
Postal News Blog recognized the significance of Senator Tester’s remark in the Washington Post article and made it the headline of a blog post. That in turn provoked David Partenheimer, Manager of Media Relations in the Corporate Communications department of the Postal Service, to post this comment on Postal News: “Privatize? Nonsense. The Postal Service has no intention to seek privatization.”
Mr. Partenheimer then proceeded to explain that initiatives like providing postal counters in Staples were solely about access. He also pointed out that the Postal Service lost $5 billion last year, neglecting to mention that operations were profitable and that the loss was solely the result of the retiree healthcare burden. Mr. Partenheimer then suggested that the onus was on Congress “to pass comprehensive legislation to provide a long-term solution to our financial challenges.”
This is the first time in my memory that a senior Postal Service official has chosen to participate in the comment forum on a blog. Not that the Postal Service has been shy about getting its views out into the press. For example, we regularly see letters from District Managers in local papers promoting various Postal Service talking points.
And this isn’t the first time Mr. Partenheimer has responded to things he’s read on postal websites. He contacted Save the Post Office a while back, having taken umbrage at how POStPlan community meetings had been characterized as a waste of time. Mr. Partenheimer tends to see the Postal Service’s intentions and actions through rose-colored glasses. But what else would you expect from a corporate PR professional?
January 23, 2014
According to a short article in yesterday's Federal Times, the Postal Service will file an appeal in the U.S. Court of Appeals today challenging the decision of the Postal Regulatory Commission regarding the exigent rate increase. The article also says that "the mailers alliance" will be appealing the PRC's ruling as well. There's no association with that name, so presumably that's a general reference to the group of mailers and mailers associations that will be joining in the suit.
The Postal Service's appeal comes as no surprise, and it was predicted here the day the PRC issued its ruling. That the mailers would appeal as well was harder to predict, since it seemed that they had come out on the better end of the decision. But immediately after the Commission granted the increase, the mailers started complaining and talking about a lawsuit, so it won't be surprising if the Federal Times is right and the mailers file an appeal today too. [Update: The mailers did appeal. Here's a press release; a list of all those who joined in the suit can be seen on the petition they filed with the court.]
Today is the day, though. The parties have 30 days in which to appeal a PRC decision in the courts, and today is the 30th day since the Commission issued its ruling back on Christmas Eve. In a two-to-one decision (with Commissioner Taub dissenting), the Commission determined that the Postal Service could raise rates by the 4.3 percent it had requested — but only for about 18 months, not permanently. That fell considerably short of what the Postal Service was seeking, but it was still more than the mailers wanted to pay.
The Court of Appeals will probably take several months to make a decision. In the meantime, the rate increase will go into effect on January 26. Overall, rates will go up about 6 percent — 1.7 percent for the "normal" increase under the price cap, plus 4.3 percent for the exigent increase.
The document filed today with the D.C. Court of Appeals will be brief and simply indicate that the Postal Service is appealing. The arguments, testimony, and rebuttals will come later. In the meantime, here’s a little background and a review of what the PRC had to say in its December 24th ruling on the exigent case (which you can find here).
January 19, 2014
The Postal Regulatory Commission is currently reviewing a request from the Postal Service to change delivery service standards for a large portion of Standard mail. The plan is to “load level” the heavy volume of mail that is normally delivered on Monday by delivering some of it on Tuesday. The plan has been presented as a way to "ease the burden" on processing and delivery operations, but documents released this week to the PRC indicate that the plan may have another purpose — preparing the way for ending Saturday delivery.
In the Request, the Postal Service explains the rationale for the plan this way: “By changing the service standard for DSCF Standard Mail, the Postal Service can adjust operations in a manner that will level the load of the DSCF Standard Mail that it delivers throughout the week, thereby removing the disproportionate burden associated with Monday Standard Mail delivery that is currently placed on the Postal Service network.”
The Postal Service says load leveling will have several benefits. First of all, it will “ease the burden currently placed on the network by the convergence of current mail entry patterns and applicable service standards.” More specifically, it will reduce mail processing work hours, cut down on carrier overtime hours, allow for earlier completion of carrier routes, and result in earlier return of mail collected on carrier routes. It will also mean “earlier delivery for customers” (earlier in the day, that is, albeit a day later in some cases) as well as earlier cancelation and processing of collection mail picked up by carriers along their routes.
One of the biggest benefits of the plan isn’t mentioned in the Request for an advisory opinion, and it hasn’t come up in any interrogatories yet either. But it could be the main reason why the Postal Service wants to make this change in service standards: It will make it easier to end Saturday delivery.
That idea actually came up during the PRC’s advisory opinion on five-day delivery in 2010-2011. One of the Commission's main concerns about ending Saturday delivery was that it would create a “peak load problem” — not delivering mail on Saturday would cause a pile up on Monday. This graphic from the advisory opinion shows just what that might look like in terms of Monday mail volumes.