Post office closings

Yesterday the Postal Service provided the Postal Regulatory Commission with some lists and other material for the annual compliance report.  They include the post offices that were closed and suspended during fiscal year 2012 (October 1, 2011 to September 30, 2012), as well as information about retail revenue sources and Contract Postal Units (CPUs) and Village Post Offices (VPOs).

You can download the lists from the PRC website here.  To make access simpler, we’ve posted the lists on Google Docs, where you can see them in the original spreadsheet form but also as tables and maps.

Retail Revenue Channels

The Postal Service has provided a table that shows the sources for retail revenues.  Because the big mailers are not considered “retail," the retail revenues account for only a portion of the agency’s total revenues — about $17 billion out of $65 billion.  The big mailers take their mail to pre-sort companies or directly to USPS Bulk Mail Entry Units.  “Retail” therefore applies to the average customer — individuals, small businesses, etc.

The following table indicates the “channels” through which the Postal Service takes in its retail revenues.

The Postal Service likes to say that people aren’t using the traditional brick-and-mortar post office like they used to, but the traditional post office continues to be the main source of retail revenue.  As the table shows, while post office retail is down 3.6% since last year, post offices still account for over 60% of retail revenues

The only significant source of retail revenues aside from the post office is PC Postage, which refers to vendors and authorized providers who print their own shipping and postage labels, such as Click-N-Ship, PayPal Ship Now, eBay's Shipping Label, and Dymo Stamps.  Retail revenues from PC Postage have naturally increased along with the rise of e-commerce — and thanks to promotional efforts by the Postal Service.

Stamp sales by retail partners account for a mere 7 percent of retail revenues.  That’s despite the fact that there are about 32,000 post offices (not including contract units) and over 63,000 retail partners.  Plus, revenues from those partners are virtually flat since last year, with an insignificant increase of 0.2 percent — despite all the effort the Postal Service has put into its USPS Everywhere campaign. 

In fact, now when you go to the USPS “find locations” page, the default for “location types” is not post offices, but “post offices and approved postal providers.”  The Postal Service is doing everything it can to encourage customers to look for alternatives to its network of post offices.

It will be interesting to see how post offices revenues fare over the next couple of years as hours are reduced at 13,000 small rural post offices and larger urban offices are relocated to inconveniently located annexes.  

Getting closing lists out of the Postal Service is like, well, pulling teeth.  Over the past several months, hundreds of post offices have closed, gone into emergency suspension, or received a Final Determination notice indicating they’ll close in 60 days.  But try to find a list of all of these post offices on the USPS website.  One gets the impression that the Postal Service would prefer that the public not have access to this data. 

It’s not as if the information is really secret.  Every community that sees its post office close or that gets a Final Determination knows about it, and there’s usually at least one local news article when a post office closes.  But in a very real sense, most closures take place below radar, and it’s difficult to see what’s happening at a national level.  In the UK, where they’ve closed over 7,000 post offices, something similar has gone on.  They call it “the secret closure programme.”

To make things more transparent, Save the Post Office has been tracking the closings, but it’s been difficult.  The Postal Service turned down a request made under the Freedom of Information Act for materials about the closings.  (Actually, it didn’t turn down the request outright – it just said that the information would cost $650, plus photocopying.)  Compiling data from a variety of sources like news reports is time consuming and prone to error.  The USPS website itself has incorrect information, and important pages are not updated often enough.

Yesterday, we had some good news in the list department.  In response to a request from the Chairman of the Postal Regulatory Commission (PRC), the Postal Service submitted several lists containing information about post office closings and suspensions.  Chairman Ruth Goldway made the information request (see #28) a couple of weeks ago as part of the information gathering required for the PRC’s annual compliance report.

The lists can be accessed in an Excel document (with five sheets) on the PRC website here, and there’s a description of the lists he re.  The lists are readily available on the Save the Post Office website as well (links below).  (Note that the new lists have several errors and anomalies, some of which have already been identified by Going Postal.)

Goldway has requested seven lists.  Five were submitted yesterday, and two more are forthcoming.  Below are links to each list, along with a few comments (not provided by the Postal Service):

a. Post Offices Closed After 1/1/2011: This list contains 430 post offices that closed during 2011. 

That’s considerably more than the 280 USPS VP Dean Granholm indicated had closed as of October 13, and somewhat shy of the 500 that Postmaster General Donahoe said had closed as of mid-November.  It’s also many more than Save the Post Office was able to identify as of just a few weeks ago, when we published a list of 320. 

b. Post Offices Under Suspension as of 1/1/2012: This list contains 227 post offices — some suspended as recently as June 2011, and others as far back as 1986 — which were still suspended as of the first of the year.  

The list does not indicate the reason for the suspension, but it certainly illustrates how suspensions can go on forever, which amounts to a de facto discontinuance, without due process.  Most of these post offices were suspended during 2008 to 2010.  In March of 2011, the Postal Service gave the PRC a much longer list of about 330 post offices that remained under suspension.  Many of those have apparently re-opened or closed permanently after a formal discontinuance process.  Chairman Goldway mentioned at a meeting of the PRC in January that about 200 suspended offices had closed or were being studied for closure.

c. Post offices Suspended after 1/1/2011: This list contains 211 post offices that were suspended during 2011, as well as two that were suspended in early 2012. 

Like list (b), it does not indicate the reason for suspension, nor does it say what the current status of these post offices are.  A search of news articles about these suspensions suggests that many, if not most, were due to weather-related problems, like Hurricane Irene, the flooding in the Midwest, tornados, and so on, and most of them eventually re-opened.  In some cases, however, the Postal Service chose not to find a new location, and essentially used the natural catastrophe as an opportunity to suspend and subsequently close the post office.  The post office in Reading, Kansas, for example, was destroyed by a tornado in May, and three months later, the town learned the Postal Service was studying the post office for permanent closure.

Word comes from Arkansas today that a dozen post offices, as well as a couple of others we'd heard about previously, have been removed from the list of those in the state being studied for closure under the Retail Access Optimization Initiative.  That's brings to nearly a hundred the number of post offices removed from the RAOI (most of them in Alaska).  

There were 179 Arkansas post offices on the RAOI list, so over 90% remain in jeopardy.  Plus, there are 29 Arkansas post offices on the "non-RAOI" list of 727 offices under closure study (released the day after the RAOI).  Of those, at least 16 have closed or received final determination notices.  

Information continues to trickle in about closings and final determination notices, but it remains difficult to produce complete lists.  As October comes to an end, several more non-RAOI post offices have closed, but no post office on the RAOI list has received a final determination notice yet.  That could change over the coming weeks, since many closure studies got started in early August and they should be completing the 60-day comment period soon.  Final decisions may take only a few days more.

In the meantime, appeals keep coming in at the Postal Regulatory Commission.  They're up to about 150 for the year — about 65 through August, plus 43 in September and 42 in October.  With nearly 600 closings (including final determinations) so far this year, that's a rate of about 25%, which would mean hundreds of appeals over the coming months.  The PRC has posted a "Help Wanted" notice for ten attorneys to help process the "influx" of appeals.

If you have information about a closing or a post office being removed from consideration, please let us know.

ARKANSAS POST OFFICES OFF THE RAOI LIST AS OF OCT. 31, 2011

ARKANSAS POST OFFICES AS OF OCT. 31, 2011

[black = closed; brown = final determination posted; green = no longer under closure study]

(Photo credit: Witts Springs post office)

It takes a lot of imagination to destroy an institution as big and durable as the U. S. Postal Service, but the executives in L'Enfant Plaza keep coming up with bold new ideas for doing just that.

Today the Postal Service published its “Final Rule” on “amending its regulations to improve the administration of the Post Office closing and consolidation process.”  The new rules change the definition of ‘‘consolidation’’ and the policy on staffing post offices.  The result will be that thousands of small rural post offices — those offices where one person holds down the fort — will be run by an officer-in-charge on temporary assignment or a non-career PM-replacement with less expertise and training than a postmaster.  The goal, as usual, is cost-savings, and the result, as usual, will be to diminish the quality of service offered by the Postal Service and to send it deeper into its downward spiral.

In July, the Postal Service amended 39 CFR 241 "to improve the administration of the Post Office closing and consolidation process."  These changes permitted a closure study to be initiated at headquarters (“top down”) instead of in the field, streamlined the discontinuance process so that a post office can be closed in less than five months instead of about nine, and granted stations and branches the same closing procedure used for main post offices (the same rules about notifying the patrons, holding public meetings, and providing the right to appeal a closure).

When it made these changes, the Postal Service deferred a decision on two key passages .  These involved the meaning of “consolidation” and the question of whether or not a post office needs to be managed by a postmaster.  Today’s Final Rule addresses those two issues.

Redefining "consolidation"

In the past, the term “consolidation” applied to changing the status of a post office from a main post office to a station or branch, as well as to changing the status of a USPS-operated facility into a “contract postal unit” (CPU).  The Final Rule issued today changes the definition of “consolidation” so that, starting December 1, 2011, the term will apply only to converting a USPS-operated retail facility into a contracted unit.

That means the Postal Service can, at will, simply decide that a main, independent post office is now a secondary branch or station.  To the general public, for whom “a post office is a post office is a post office,” whether it’s a main post office or a station or a branch, the change may not seem significant, but it will have many implications that will be felt by postal employees and the public.

The National League of Postmasters and National Association of Postmasters of the U.S. (NAPUS) have argued that the new procedures “erase” the concept of “consolidation” from 39 USC § 404(d) by regulation, when such a change should require Congressional action.  The Postal Service claims it has the right to make the change on its own.  A second objection is that the redefinition would make it easier to close a post office that has lost its “main post office” status, but the Postal Service says that since, as of July, the closing process is the same for all facilities — post offices, stations, and branches — that concern is not relevant.  A third issue may be that the new policy makes it easier to turn a USPS-operated facility into a contract postal unit, but that’s not quite clear yet and it’s not addressed in the Final Rule.

It any case, it is not likely that the postmasters associations and communities who watch their post office turned into a station or branch are going to see it as a non-issue.  It’s the Postal Service, after all, that has spent the last several years arguing with the Postal Regulatory Commission (PRC) that stations and branches are secondary, subsidiary types of facility, not entitled to the statutory protections of a main post office.  Now the Postal Service wants to say it’s no big deal if it turns a post office into a station or branch because there’s essentially no difference. 

Closing procedures are not the only issue.  There are rules governing post offices, for example, that don’t apply to a station or a branch, like hours of operation.  And there’s also the issue of community identity – having a main post office in your town is different from being a branch of some other town’s post office.

The new regulations are also somewhat ambiguous about what’s involved with “consolidating” a post office into a contracted postal facility staffed by non-USPS personnel.  The regulations seem to suggest that there’s a natural progression from main post office to branch or station to contractor-operator facility, as if the services they provide and the training required for managing them were basically the same.  By blurring the difference between a post office and a branch, the Postal Service may also be blurring the distinction between a facility owned and operated by the Postal Service and a contracted facility owned and operated by non-USPS personnel.  The same kind of elision is at work when the Postal Service says a community can replace its post office with a “village post office,” which is not a post office at all. 

Staffing a Post Office

The second change in the regulations involves the staffing of post offices.  The postmasters associations believe that the law requires a main post office to be staffed by a postmaster.  They argue that the Postmaster Equity Act (2003) precludes changing 39 CFR 241.1 in a way that would permit a post office to be be managed by someone other than a postmasster. 

The details of the objections posed by the League and NAPUS are explained in the document they prepared back in the spring, when the Postal Service first proposed the change:  “In law, a post office is managed by a postmaster, plain and simple. The proposed regulations conflict with that law. The Senate Committee Report that accompanied the Postmaster Equity Act (Report 108-112) underscores the legal requirement that a post office is managed by a postmaster: ‘Postmasters are the manager-in-charge of the nation’s individual post offices.’  In addition, the report states that postmasters ‘are accountable for postal operations and services, including retail operations and community relations.’ The regulation does not and cannot confer these responsibilities on ‘another type of postal employee.’”

Yesterday the Postal Service announced that twenty-one post offices in Alabama would be closing in November and December, and today there’s word that some in Arkansas are closing as well, so it looks like the Postal Service is working its way through the alphabet.   Next week we’ll probably hear about closings in Arizona, California, and Colorado. 

It’s only been a couple of weeks since Save the Post Office published a table summarizing the closings and final determinations for 2011.  It may seem too soon for an update, but a lot has happened in the past few days, so here's an updated table:

The table reflects several recent developments:

First, earlier this week Postal Service Vice President Dean Granholm told Bloomberg Businessweek — in an excellent article by Angela Greiling Keane — that the Postal Service has already closed 280 post offices this year and another 300 have received final determination notices.  That was a total surprise — about 200 more than Save the Post Office had estimated.  Although we’ve not been able to identify all of these post offices, we’ve updated the table to reflect Granholm’s revelation.  

Then yesterday, the Postal Service released the list of post offices in Alabama that have received final determination notices and will be closing in November and December.  That too was a surprise because it represents a closure rate much higher than anticipated. 

Nearly all of the twenty-one Alabama post offices on yesterday’s list come from the “non-RAOI” list of 727 post offices slated for closure study that the Postal Service released on July 27, 2011, the day after the Retail Access Optimization Initiative (RAOI) was announced.  There are 30 Alabama post offices on this non-RAOI list.  At that rate, about two-thirds of the non-RAOI post offices may close.  We’ve therefore increased the number of these post offices that will close or receive final determination notices by the end of the year from 283 to 441.

ALABAMA POST OFFICE CLOSINGS

(Black flags: closed.  Brown: final determinations issued. List view here.)