Are USPS transportation policies still causing mail delays?

SteveBlog, Slideshow

This week there have been several significant revelations about the operational changes that took place over the summer, their impact on service performance, and the Postal Service’s plan to eliminate 64 million work hours.

  • According to an OIG report released yesterday, the Postal Service embarked on this plan — which involves 57 strategies to transform every aspect of postal operations — without doing any analysis of the potential service impacts. Plus, “documentation and guidance to the field for these strategies was very limited and almost exclusively oral. The resulting confusion and inconsistency in operations at postal facilities compounded the significant negative service impacts across the country.”
  • The OIG concurred with the Postal Service’s position that an advisory opinion by the Postal Regulatory Commission was not required before making these operational changes, but it acknowledges that “upcoming court decisions could change this analysis.” Indeed, federal judges in four cases – Washington v TrumpNew York v USPS, Pennsylvania v DeJoy, NAACP v USPS— have ruled that an advisory opinion should have been requested.
  • In August, the Postmaster General told the Senate that the removal of collection boxes, which caused widespread concern over the summer, was “a normal process that has been around 50 years” and that over the past decade, about 3,500 have been removed annually. According to a June 26, 2020, presentation given by Headquarters (submitted as an exhibit in New York), the Postal Service has a “collection box optimization” plan to remove over 7,400 boxes each quarter during FY 2021, for a total of 29,618 removals in a single year. It’s not clear why the Postmaster General didn’t mention this to Congress.
  • As over 700 sorting machines were being removed from processing plants, the Postmaster General told Congress that the Postal Service was simply eliminating under-utilized machines and making room for all the packages, but a July 7th teleconference cites another reason: cutting down on work hours would “Reduce 1658 full time equivalent employees.” The Postmaster General didn’t tell this to Congress.
  • When West Virginia Senator Joe Manchin contacted the Postal Service this summer about reports that signs were going up at post offices with new, reduced hours of operation, he was told that the signs were incorrectly posted because of a “misunderstanding” between District officials and local postmasters. But in the July 7th teleconference, at which the Postmaster General gave remarks, postal leadership said it plans to “align retail hours/operations to customer demand” by reducing full window service hours at 12,000 post offices. It’s not clear why the Postmaster General didn’t tell this to Congress.
  • According to an excellent article in yesterday’s Washington Post, the on-time service performance is “most erratic” in key swing states, making them more vulnerable to mail slowdowns and endangering millions of votes in states with firm ballot deadlines. The article has some great maps based on service performance reports the Postal Service has made public in response to the court’s ruling in Jones v DeJoy, which can be found here.
  • And one final revelation: The Postal Service is still putting restrictions on late and extra trips from processing centers, and the number of such trips is way below normal. This may be the main reason service performance continues to suffer.

There’s a lot to unpack in all the court documents, WaPo article and OIG report, but for now, let’s focus on the issue of transportation policy. 

Over the past three months, the on-time scores for First Class Mail have dropped from about 92 percent — the annual average for FY 2019, and the average before operational changes in July — to an average of about 85.6 percent. There was some improvement after the low points of July-August, but the “new normal” seems to be about 6 percent below the “old normal.” When the quarterly results are posted next month, the fourth quarter of 2020 (July-Sept) may be the worst since the Postal Service first started reporting service performance data back in 2009.

What is going on with these performance scores? If the Postmaster General put a pause on the operational changes that caused problems over the summer, why haven’t things gotten back to where they were before?

In response to court orders in New York v USPS, the Postal Service has shared data on late and extra trips from processing centers. One exhibit shows the number of late trips per day and another shows the extra trips per day during this period. Here are a couple of charts based on that data (we’ve added up the daily trips to produce weekly numbers).

As the charts show, the number of late and extra trips never returned to normal. They continue to be as low as they were when the operational changes were implemented in July. How could that be? Weren’t we told that all these changes were on pause until after the election?

On August 14, the Postmaster General acknowledged to employees that his recent transformation initiative has, unfortunately, “had unintended consequences that impacted our overall service levels.” On August 18, the Postmaster General issued a statement saying he was putting a pause on the initiatives to change operations until after the election.

Most people probably thought that included in these initiatives were the changes to transportation policies. But his statement doesn’t mention transportation. It only says retail hours at post offices will remain unchanged, mail processing equipment and collection boxes will not be removed and no mail processing facilities will be closed.

In fact, the transportation guidelines drawn up by Vice Present of Logistics Robert Cintron on July 11 are still in effect. The goal of these “Cintron Guidelines” was to clarify instructions to the Area Vice Presidents about the new policies, which were being shared in teleconferences on June 26, July 7, and July 10. While not explicitly banning late or extra trips, the Cintron Guidelines mirrored Headquarters’ emphasis on sharply restricting approval for these trips “to eliminate unplanned extra transportation” and to ensure that “trips must depart on time.”

In testimony in New York v USPS on October 15, Cintron explained the origin, goals and some of the specific details of the guidelines. At one point he was asked by the plaintiffs’ attorney, “So it’s fair to say then that the Cintron guidelines remain in effect at the Postal Service?” His answer: “They do.” A little later, Cintron repeated that “we have not rescinded the guidelines.”

If the Cintron Guidelines are the reason extra and late trip numbers remain low, it obviously raises another question: Are these transportation policies causing the problems with service performance we are continuing to see? 

The charts above show that there is clearly a correlation between service performance and the number of late and extra trips, but correlation is not causation. There could be other explanations.

The Postal Service has cited many causes for the mail delays that we’ve seen over the past several weeks. In a letter to the court in Jones v USPS, the Postal Service states that “the delivery of mail has lately been complicated by factors beyond the Postal Service’s control, including, but not limited to, the COVID-19 pandemic (which has caused continuing employee availability problems and a significant decrease in, e.g., the availability of commercial flights to transport First-Class Mail by air), wildfires in the West, and hurricanes in the South.”

The letter also cites the lack of availability of commercial flights to transport First-Class Mail by air, the volume build-up from the Labor Day Holiday (for week of Sept. 7), and the opening of the Great Lakes and Chicago Surface Transfer Center.

Not included in the list of possible explanations is the fact that the Postal Service is continuing to implement the new transportation policies articulated in the Cintron Guidelines. But the plaintiffs in New York v USPS are making exactly that argument.

In the statement of facts the plaintiffs submitted this week, they note that “the use of late and extra trips by USPS is still at one-third to one-quarter of what it was prior to the illegal operational changes in July 2020. Defendants have offered no good reason as to why this number would still be so low, particularly given that they have been under order of this Court and a number of other courts to stop any prohibition on late/extra trips and have committed (and been ordered to commit) to authorizing and encouraging late trips for the delivery of Election Mail and other mail.”

To help establish that the low trip numbers have caused the delays, the plaintiffs have introduced testimony from Justin Grimmer, Professor of Political Science at Stanford University, whose research focuses on statistical methods to study US elections, political communication, the Congress, and social media.

Grimmer reviewed the on-time service performance data and confirmed what everyone already knows: “the policy limiting the number of ​Extra ​and ​Late trips ​resulted in first-class mail delays across all postal service Areas.” More importantly, Grimmer also examined why the decline in service scores persisted even after the Postal Service “suspended all other initiatives other than the policy limiting the number of Extra or Late Trips.”

Since the Postal Service has explained the performance problem by pointing to staffing issues arising out of the pandemic, Grimmer looked at the service data and staffing levels (as discussed in the testimony provided by John Prokity, USPS Manager of Workforce Planning, Insights & Analytics), and he could not find a correlation.

Coincidentally, there are some charts in yesterday’s OIG report that seem to support Grimmer’s analysis. The charts illustrate availability for mail processing employees, city carriers, and customer service employees from March through August. Availability dips for a few days in late May and early July (Memorial Day and July 4th weekends, prime vacation periods), but otherwise it has been consistently about 3 percent below the same period last year. There was no significant drop in employee availability in mid-July, when service performance and the number of trips both declined significantly.

Grimmer concludes his declaration as follows: “Using the data provided by the USPS on first-class Service Scores, I find the policy limiting the number of ​Extra ​and ​Late trips​ continued to delay mail as recently as October 3rd. I also found that the changes in staffing levels cannot explain the decrease in Service Scores that correspond with the policy change.”

Attorneys for the Postal Service will no doubt challenge this conclusion, but it will be up to the Postal Service to provide a better explanation for why the performance problems persist and why the new transportation policies weren’t suspended.

Because of the urgency of the matter, with voting by mail already underway, the plaintiffs in New York v USPS have filed a motion to expedite their lawsuit, and the plaintiffs in Pennsylvania v DeJoy have asked the court to assign former Inspector General and Board of Governor member David C. Williams to be a special monitor.

The plaintiffs in Pennsylvania argue that “the appointment of an independent monitor who is familiar with the Postal Service’s operations is both appropriate and necessary to ensure Defendants’ compliance with the injunction in this case and to enable the Postal Service to improve its performance.”

In a second letter on the issue, the plaintiffs state, “Plaintiffs have no interest in subjecting USPS to unnecessary oversight. And if service had truly improved following this Court’s injunction, they would not have made this request for a monitor. But it has not, and USPS’s failures at least raise serious concerns about whether the changes implemented in July have truly been rolled back.”

The USPS has filed a letter opposing the request. The Court has not yet ruled on the request for a monitor.

(Update: Judge McHugh has rejected the plaintiffs’ request to assign a independent monitor in Pennsylvania v DeJoy.)

(Photo: Banner hung in Portland OR processing center, Twitter, Sept. 7, 2020)