Presiding Officer’s Information Request No. 1


[PRC Advisory Opinion Document Summary]

On July 28, 2011, Ruth Y. Goldway designated herself to serve as Presiding Officer for the USPS Retail Access Optimization Initiative, Docket No. N2011-1, effective immediately.  Within a few days, Goldway had prepared the “Presiding Officer’s Information Request No. 1.”  It asks for a lot of material, to be provided no later than August 9, 2011. 

[The document is here.]

Here’s what Goldway has requested:

1. A copy of all demographic, economic, and geographic data that will be used to develop profiles for evaluation of each candidate facility.  (There may be an issue here: I thought I read that the Postal Service would not be using demographic data to make its decisions.)

2. Confirmation that revenue, as it is considered a criterion to identify candidate facilities, does not include revenue from business mail entered using permits issued at a different facility, and does not include revenue from mail delivered to or through the facility, including post office boxes, caller service, or street delivery.  (This may refer to the fact that calculations about a post office’s revenues include only those brought in at the facility, which does not give a full picture, since most mail is bulk mail introduced at a few large urban facilities.  Many people have pointed out the unfairness of this mode of calculation in determining the economics of a given post office.)

3. More information about how the Postal Service is calculating “economic savings.”  The USPS Handbook PO-101 Postal Service-Operated Retail Facilities Discontinuance Guide refers to “economic savings to the Postal Service” as a component of a proposal to discontinue a facility.  Goldway asks that the Postal Service to describe the calculation of “economic savings” it anticipates from closing post offices, including all the common one-time or annual expenses or savings included in the calculation.  She also asks the Postal Service to provide a date that an estimate of the economic savings, by facility, from discontinuation of the candidate facilities will be available.  (The issue of cost-savings is crucial, since it is difficult to determine how much the Postal Service actually saves in closing a post office.  It no longer has to pay rent or maintenance on an owned building, but labor costs are more difficult to evaluate.  Sometimes there are other costs to consider, like the cost on walking away from a lease with a couple of years left.)

4. An estimate of the percentage of revenue from discontinued facilities that would be captured by other facilities in close proximity, including retail over-the-counter transactions and post office box rental revenue.  If the Postal Service anticipates this percentage to vary by facility, please explain, and please explain the methodology used to estimate the overall percentage or any variance from that percentage.

5. More information on whether and how non-revenue customer transactions will be recognized.

6. The “Change Suspension Discontinuance Center” (CSDC) program mentioned in the filing, as well as the source data or database for the CSDC program, including data for all facilities that were considered in developing the list of candidate facilities.

Preservation of convenient access is an important consideration within the initiative.  The following questions seek to clarify the availability, use, and convenience of those affected postal facilities that remain open and other alternate access channels.

7. Please explain how the Postal Service will estimate the effect of the initiative on the capacity of remaining facilities that are in the proximity of a discontinued facility to absorb additional retail transactions; and to absorb additional post office box demand.

8. Please confirm that no candidate facilities and none of the alternative access sites were under suspension as of July 27, 2011.

9. More information about the “Village Post Office.” What does the term mean?  How is it different (if it is) from a CPU, particularly with respect to any difference in product or service offerings?  How many Village Post Offices deso the Postal Service currently have and anticipates having operational in 6 and 12 months?  By what methods does the Postal Service plan to initiate and finalize agreements for the creation of Village Post Offices?

10. More information about plans for the Automated Postal Centers (APCs) as a way of providing alternative retail access.

11. The data files used to calculate nearest post offices. The Postal Service has provided a chart showing “proximity to the nearest Post Office [that] is based off of geographic coordinate distance, rather than driving distance.”  In other words, the Postal Service is measuring distance “as the crow flies,” rather than actual driving miles and time.  So Goldway asks for a data file with the actual driving distances to the nearest alternate retail location for each facility under consideration.

12. Information about alternative retail outlets.  The Postal Service witness had indicated that alternative access includes nearby approved shippers and stamp consignment locations in addition to full service alternatives.  So Goldway asks for information about the number of occurrences where the five nearest locations are approved shippers or stamp consignment locations (not full service alternatives); and the Postal Service’s anticipated action when none of the five nearest locations are full service.

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