Closure Moratorium

The Postal Service announced this afternoon that there will be a moratorium on the closings of all post offices and mail processing plants for five months — December 15 to May 15. 

That is welcome news indeed, and it will give the Postal Service and Congress time to work out a whole host of issues, including the $5 billion pre-funding to the retiree health insurance fund, service standards concerning post offices and delivery times, and Saturday delivery. 

This is the third time a moratorium has been declared on post office closings since the Postal Reorganization Act of 1970.  Were it not for this moratorium, post offices might have started closing at a dizzying rate come the first of the year.  Over five hundred have closed this year, and nearly a hundred more have already received Final Determinations indicating they were to close in January.  The 3,650 post offices on the Retail Access Optimization Initiative were bracing to hear their fate any day now, with the closures beginning as early as February. 

The moratorium announcement follows on the heels of a December 8 letter from twenty-two Senate Democrats to Congressional leaders asking them to  “include language in the next appropriations to prevent the USPS from closing or consolidating area mail processing facilities or rural post offices for the next six months. This six-month moratorium will give Congress the time needed to enact reforms necessary for the postal service to succeed in the 21st century.”  

Calls for a moratorium have been building for months.  In August, Iowa’s Governor Terry Branstad called for a moratorium on closing post offices, and in early November, Representative Nick Rahall of West Virginia wrote the Postmaster General urging him to declare a moratorium.

The two postmasters associations — NAPUS and the League of Postmasters — joined the call for a moratorium on November 3.  (An earlier post about the efforts of the League is here, and the NAPUS efforts, here.  The letter from NAPUS President Robert Rapoza to Senator Joseph Lieberman, chair of the Committee on Homeland Security and Government Affairs, is here.)

The postmasters associations have been pushing for “service standards” that would deal with the closing of small post offices — rules that would incorporate geographic and demographic considerations in closing decisions — and they succeeded in getting Lieberman’s committee to include an amendment to the postal bill about these standards.  The postmasters asked for a six-month moratorium on closings while the standards could be worked out.  

Then in mid-November, the Postal Service declared what it called a “suspension” on post office closings, to run from November 18 until January 3.  But that wasn’t a real moratorium, it was just for a few weeks, and its purpose was to avoid mailing problems during the peak mail volumes of the holiday season.  (And it didn’t stop a few post offices from closing, due to an emergency suspension or simply in spite of the hold on closings).

Today's announcement means there will be a real moratorium on post office closings and mail processing plant consolidations.  Come January, then, the Postal Service won't be announcing the closure of thousands of post offices on the RAOI list.  The Postal Regulatory Commission can now take some more time, if it so chooses, to work on the Advisory Opinion about the RAOI, which was due out any day now.  And it will take some of the pressure off the PRC to move quickly on the new Advisory Opinion on service standards and plant consolidations.

This moratorium will be the third moratorium on post office closings since the Postal Reorganization Act of 1970.  The first occurred in 1976, following a 1975 GAO report recommending the closure and consolidation of 12,000 rural post offices.  The report led to a storm of reaction, Congressional hearings, and the passage of the Postal Reorganization Act Amendments.  The Act established a commission to study the postal service and imposed a moratorium on closing or consolidating any post office until the commission published its findings.  That moratorium was in effect from September 1976 until March 1977.

In 1998, under congressional pressure, the Postmaster General declared a moratorium on closures and consolidations, and it was in place until 2003.  As a report by the Office of Inspector General explains, the reason for this self-imposed moratorium was "suspicion in Congress that the Postal Service was manipulating the emergency suspension procedure," which was the subject of a 1999 congressional hearing. 

"Save the Post Office" has been calling for a moratorium on closings since June 2011.  It seemed like a pipe dream back then.  Today it's a reality.  

A special thanks to the over 3,000 people who signed the petition calling for a mortorium on closing post offices.  You helped make it happen.

MORE ON THE STORY

Yesterday, the National Association of Postmasters of the U.S. (NAPUS) called for a moratorium on post office closings.  That’s a big deal, and it will give the cause a lot of momentum. 

Calls for a moratorium on post office closing have been growing.  In August, Iowa’s Governor Terry Branstad called for one, and earlier this week Representative Nick Rahall of West Virginia wrote the Postmaster General urging him to declare a moratorium. 

Moratoriums on post office closings are unusual but they aren’t unprecedented.  Back in 1975, a GAO report recommending the closure of 12,000 rural post offices led to a storm of protest, Congressional hearings, a commission to study the Postal Service, and a moratorium on closing or consolidating any post office until the commission published its findings. 

In 1998, under congressional pressure, the Postmaster General declared a moratorium on closures and consolidations because there was suspicion in Congress that the Postal Service was using “emergency suspension” tactics to close post offices illegitimately. 

Yesterday’s call by NAPUS for a moratorium came in a letter from Bob Rapoza, President of NAPUS, sent to key members of the Senate Homeland Security & Government Affairs Committee about the “21st Century Postal Service Act of 2011" (S. 1789), introduced by Senators Lieberman, Carper, Collins and Brown. 

“We urge the Committee,” wrote Rapoza, “to include in the legislation the imposition of a moratorium on post office closings and consolidations, until such time as the retail service standards specified in section 204 can be fully implemented.”

Most of the 21st Century Postal Service Act of 2011 is simply lousy.  It embraces the idea that the Postal Service needs to be radically downsized, it permits ending Saturday delivery in two years, it phases out door-to-door delivery, it backs off of demanding that the Postal Service be refunded from the $50 to $75 billion overpaid in to CSRS, and it would give postal workers health care benefits inferior to what they enjoy now.

Rapoza’s letter also expresses concern over the health care provisions in the Act, which would require some postal retirees to enroll in Medicare Part B, thereby reducing their level of coverage.  He also said NAPUS was “troubled" that the legislation does not include management and supervisory association input in the development of a postal-only health plan.

But in terms of protecting small post offices, the 21st Century Postal Service Act may have something to offer, and it’s better than most of the proposed legislation going around Congress right now.  That’s because the Act contains a passage about “service standards” that are intended “to guarantee accessible postal products and services.”

Yesterday U.S. Rep. Nick Rahall (D-W.Va.) wrote a letter to the Postmaster General urging him to declare a moratorium on closing post offices.  It was the second such call for a moratorium from a high-ranking government official, following Iowa Governor Branstad's request in August.  

Yesterday also brought news of two post offices being studied for closure that do not appear on any list — a small rural post office in Tilly, Arkansas, and a large post office in Harlem.  Apparently the Postal Service is not satisfied with the 4,300 post offices that appeared on the two lists that came out in July, and it’s looking around for even more post offices to close.

Another Call for a Moratorium

Congressman Rahall’s letter to the Postmaster General expresses his concern that the concerns of his constituents are not being seriously considered when the Postal Service studies a post office for closure.  Rahall has received reports that town meetings with postal officials are scheduled at inconvenient times (like during Halloween preparations in Kiahsville), that the post office in Amigo was closed before rural delivery was established, and that there are so many meetings going on — 40 in the Appalachian District — that it raises doubts that the postal service can appropriately manage the public feedback. 

"The public view is that a post office’s fate is predetermined and that a meeting’s purpose is a perfunctory step in the closure process, instead of being used to truly assess legitimate safety and convenience issues, and taking steps to minimize the adverse impact on the community," Rahall wrote. 

The Congressman also pointed out that three of the four criteria used to select a post office for closure study “are financially based and clearly target small facilities that are not heavy revenue producers” – which conflicts with Postal Service's statutory charter requiring it to provide "a maximum degree of effective and regular postal services" to rural communities where post offices are not self-sustaining. 

That law explicitly prohibits small post offices from being closed solely for operating at a deficit, so the Postal Service has been coming up with several other reasons, like the absence of a postmaster (which the Postal Service controls) and proximity to nearby alternative retail facilities (which the Postal Service has developed to replace post offices).

In addition to a moratorium on postal facility closures, Rahall is also asking the Postal Regulatory Commission and the postal service's inspector general to "exercise their oversight authorities to the fullest extent in ensuring these postal closures conform strictly to the spirit of the law." 

New post offices studied for closure: Tilly and Lincolnton

The post offices in Tilly, Arkansas, and on upper Fifth Avenue in Harlem, couldn’t be more different — a tiny rural post office staffed by a postmaster and a postmaster relief, and a big urban station with 33 clerks and carriers.  But they are similar in one important way — they serve populations that are the most hurt when a post office closes.

Yesterday, residents of Witts Spring, Arkansas, were told that their post office was being removed from the RAOI list.  But good news for Witts Spring meant bad news for its neighbor, Tilly, which learned that it would be considered for closure study instead.  The Postal Service has been renting the little building in Tilly since 1980, and the rent is just $600 a year — $50 a month.  The postmaster will presumably be moved to another post office, so there’s no cost savings there.  What can the Postal Service possibly gain by closing this little office?  And how could that savings possibly make up for the damage it will do to Tilly?

The Lincolnton Station is located in New York’s Harlem, at 2266 5th Avenue, at the corner of 138th Street.  There’s going to be a meeting with postal officials on Tuesday, November 22^nd, at the station lobby from 6 p.m. to 8 p.m.  The public is encouraged to attend.  Perhaps postal officials will tell the community what’s going to happen to the station’s 33 employees.  The nearest post office is College Station, a half mile away, but it’s got 14,000 square feet, whereas Lincolnton has 22,000, so there’s probably not enough room for all those displaced workers.  That half mile to the next nearest post office may not seem like much to most people, but a half mile in NYC isn’t a half mile in Arkansas and it will be a long distance for Lincolnton patrons to cover.  And while it’s tough on any community to lose a post office, it’s especially hard on an inner city neighborhood, where so many people walk to the post office and nearby small businesses depend on the foot traffic. 

[CORRECTION: The Lincolnton Station is not being studied for closure: the meeting was at Lincolnton, but it was about the nearby College Station, which is on the RAOI list.)]

These two offices are among a handful first being studied for closure that never appeared on any list.  There’s another in Plattsmouth, Nebraska, which learned a few weeks ago, right out of the blue, that it was being studied for closure.  It’s hard to know what to make of this. 

Many post offices have closed or received final determination notices this year, but almost all of them were initiated for closure study in 2010 or early 2011, or else they appear on the July 27, 2011 list of 727 post offices under closure study outside of the Retail Access Optimization Initiative (RAOI), with its list of 3,650 post offices.  

The Deputy Postmaster General said recently that there would be another list of 4,000 coming soon, but apparently the Postal Service isn’t waiting until then.  It’s not enough that it’s closed 280 post offices this year, issued final determinations for another 300, and has over 4,000 under closure study.  If the Postal Service wants to consider a post office for closure, it doesn’t matter whether it’s on a list or not.  That means no post office is safe.  Yours might get a “proposal to study” notification any day now.

(Photo credits: Plattsmouth NE post office, vintage postcard; US. Rep. Nick Rahall; Kiahsville WV post office; and Lincolnton NYC post office, by Evan Kalish (Going Postal); Tilly AR post office, Google Street Views.)

Day after day, month after month, it’s been nothing but bad news and critical editorials about how much money the Postal Service is losing, why it has to close thousands of post offices, and what Congress—and taxpayers—may need to do to rescue the postal system.  There have also been hundreds of news items about the closing, or impending closure, of so many post offices.  Each one is a sad story about what a loss it will be to the community, the town meeting with postal officials who don’t seem to listen because their decision has already been made, the grief of local citizens who’ve had the post office in their town for a hundred, maybe two hundred years.

Today, finally, an article to raise one’s spirits. 

“Faced with the potential loss of their local post offices,” reports the Iowa Messenger, “a group of area leaders has decided to go on the offensive.”  Forty government officials, including the governor and many mayors, “gathered in Fort Dodge Saturday and decided to ask Congress for a moratorium on future post office closures.”

Yes!  A moratorium on closures!  It's happened twice in the past, in 1976 and 1998.  It could happen again.

The Iowa group, which has named itself Iowans for Post Office Services, is going to send letters to Congress, the National Governors Association and the U.S. Postal Regulatory Commission lobbying for the moratorium.  And there’s more.

The mayor of Randolph, Iowa said citizens in his town have pledged $10,000 to pay for a federal lawsuit against the Postal Service over the potential closing of their post office.  Mayor Vance Trively also suggested that a class action lawsuit should be considered. 

You can sign a petition calling for a moratorium on closing post offices here.  More on the case for a moratorium, here.  

(Photo credit: Luther, Iowa, post office, in Iowa Backroads; meeting of Iowans for Post Office Service)

Maybe it’s time for a moratorium on post office closures, consolidations, and suspensions.  The Postal Service seems to be closing post offices as fast as it can, and communities barely have time to react.  Many have had a post office for over a hundred years, yet they’re given just 60 days to respond to a closure notice.  With emergency suspensions, the study for discontuance takes place after the post office has closed, often with just 24 hours notice.  And when communities protest at public meetings, representatives of the Postal Service don’t seem to listen.  It’s as if the decision has already been made—and it probably has been.  An Advisory Opinion issued by the Postal Regulatory Commission in 2009 said, " the Commission finds that the Postal Service should improve customers' opportunity to offer input. . .  [P]ublic comments often are not sought until after the initial decision to close the facility has already been made."

In its rush to close post offices, the Postal Service is engaging in dubious practices, and the agency responsible for overseeing it, the Postal Regulatory Commission, is investigating accusations that the Postal Service is violating the law.  The Postal Service has shuttered many post offices as  “emergency suspensions” because the lease has terminated, but it often seems this “emergency” could easily have been avoided.  The PRC has filed a formal notice entitled "Investigation of Suspended Post Offices," which questions whether the Postal Service has been suspending post offices without making sufficient effort  to reopen or formally close them.  The chairman of the PRC has testified before Congress about problems with the way the Postal Service is closing post offices. The National Association of Postmasters (NAPUS) has filed a formal complaint with the PRC that the Postal Service is not following the law in its practices concerning closures and consolidations as well, and

We’ve heard plenty about how the Postal Service is running a huge deficit and how it has to close post offices to cut costs.  Some have said the Postal Service should be “blown up” and privatized.  But it is not supposed to matter that some community post offices operate at a financial deficit: those that run in the black are supposed to subsidize those that run in the red. That’s what makes the Postal Service different from a Starbucks or a Gap.  If they have a store that’s losing money, they close it.  But “universal service” means that everyone is supposed to have access to a community post office, without regard for whether it’s profitable or not.

We need a much more thoughtful national discussion about the meaning of universal service and the financial issues facing the Postal Service.  And while we’re having that conversation, the Postal Service should stop closing post offices.  It’s time for a moratorium on closings.  Don’t think it’s possible?

There’s nothing radical about moratoriums on closures.  There have been two moratoriums on post office closings since the Postal Reorganization Act of 1970.

In 1975, a GAO report recommending the closure and consolidation of 12,000 rural post offices led to a "storm of reaction," Congressional hearings, and the passage of the Postal Reorganization Act Amendments.  The Act established a commission to study the postal service and imposed a moratorium on closing or consolidating any post office until the commission published its findings.  That moratorium was in effect from September 1976 until March 1977.

In 1998, under congressional pressure, the Postmaster General declared a moratorium on closures and consolidations, and it was in place until 2003.  As a recent report by the Office of Inspector General explains, the reason for this self-imposed moratorium was "suspicion in Congress that the Postal Service was manipulating the emergency suspension procedure," which was the subject of a 1999 congressional hearing. 

In Canada, there’s been a moratorium on closing rural post offices since 1994.  Like the U.S., Canada is facing similar pressures to privatize the postal system, and a 2009 advisory panel “recommended that the current moratorium on post office closures in rural and small towns be replaced with new rules and procedures, including the ability to replace public post offices with private outlets.”  But in the meantime, the moratorium is protecting 3800 public post offices in rural andsmall one-post-office towns.

It’s Congress that is ultimately responsible for ensuring that the postal system provide “universal service.”  When the Postal Reorganization Act of 1970 transformed the postal system from a government service into a corporate-type independent agency, Congress wanted to ensure that the postal system continued to provide effective postal services to residents of both urban and rural communities. In 1996 Congress amended the Act and established specific requirements for closing a post office to ensure that the USPS consider the effects on the community as well as providing and involving communities in the decision, thus ensuring that closure decisions were made in a fair, consistent manner.  While the nation debates the future of the postal system, it only makes sense that the USPS put a moratorium, as it did back in 1998, on closing hundreds, perhaps thousands, of post offices.

(Photo credits: top to bottom: St Pete Beach Today;  mlive.com; Cleveland.com; Oakland Press; WataugaDemocrat.com)