The Case for Consolidation: Overview of the Postal Service’s Request for an Advisory Opinion


On Monday, December 5, the Postal Service submitted to the Postal Regulatory Commission (PRC) a request for an Advisory Opinion on the proposed changes in service standards associated with the consolidation of the mail-processing network.  The plan would close 252 facilities, put around 35,000 employees out of work, and save the Postal Service an estimated $2.1 billion a year.  It would also slow down the mail, particularly First-Class, which would be delivered in two or three days instead of one-to-three.  Delivery of periodicals would slow down as well.

Because it would have a “nation-wide” impact on the mail system, the Postal Service is required by law to submit its plan to the PRC for an Advisory Opinion.  But the PRC’s opinion is just that, an opinion, and the Postal Service is not required to take it.  The PRC, in other words, does not rule on whether or not the plan can be implemented.  According to comments made by PRC Chairman Ruth Goldway at a meeting of the PRC earlier in the week, the Postal Service has already indicated “it intends to move forward with service-standard changes regardless of what our [the commissioners’] views are” (podcast, at 42:30).

The Request itself is just over 15 pages long, but it is accompanied by testimony from thirteen witnesses (most of them employees at postal headquarters), as well as 36 “library references” — documents like Excel tables with data related to the testimonies.  The entire presentation is several hundred pages, and it will take a lot of work for participants in the case to analyze it, pose interrogatories to the witnesses, and construct critiques. 

This is a much more thorough and detailed presentation than that which the Postal Service presented for the Retail Access Optimization Initiative to close 3,650 post offices.  That one started with just one USPS witness presenting testimony, and most of the library references were filed later in the case, in response to information requests and interrogatories.  The fact that the Postal Service gave the service standards much more attention is just one indication of the magnitude and significance of the network “rationalization.”

Following is a summary of the Request and the witness testimonies.  The complete docket, N-2012-1, is here.


The Request [pdf]

The Request briefly outlines the nature of the service changes, the statutes that give the Postal Service the authority to make them, and a rationale for making them in the first place.  The Postal Service does not contest the fact that an Advisory Opinion is required.  The changes it is proposing will clearly have nation-wide impacts (one of the criteria that set the process in motion).  In fact, the Request states explicitly, “The service changes described in this request potentially affect every sender and recipient of mail served directly by the United States Postal Service, and are likely to affect most of them.”

As reported in the media already, “The most significant revisions would eliminate the expectation of overnight service for significant portions of First-Class Mail and Periodicals. In addition, the two-day delivery range would be modified to include 3-digit ZIP Code origin-destination pairs that are currently overnight, and the three-day delivery range also would be expanded.”

The Request does not elaborate, but the description of the plan published in the Federal Register in September explains that 40% of First-Class mail is currently delivered overnight, about 25% is delivered in two days, and the rest in three.  According to the new service standards, about half the mail would arrive in two days and the other half in three days.  In other words, instead of a 1-to-3 day window, it would become 2-to-3 days.  Delivery of periodicals would also slow down: Instead of a 1-to-9 day window, the new standard would be 2-to-9 days.  

The Request provides a general rationale for its plan, and as usual, the Internet gets most of the blame for declining mail volumes and revenues: “In recent years,” says the Request, “the Postal Service has experienced steady and precipitous declines in mail volume, driven largely by accelerated diversion of First-Class Mail and other communications to electronic media, and exacerbated by the current economic recession.”

The Request cites statistics that have become familiar to those who have been reading news accounts about why the Postal Service needs to close post offices: “Since 2006, total mail volume has fallen by about 45 billion pieces, or almost 21 percent.  In First-Class Mail, volume has declined even more significantly.  After a First-Class Mail peak in 2001 at 104 billion pieces, it has since fallen by about 30 billion pieces, or 29 percent. The decline in single-piece First-Class Mail has been even more precipitous, falling 52 percent over the same time period.”  (The Request does not mention that most of these declines can be attributed to the recession, as the Postal Service has argued in its case for an exigent rate increase.)

The Request says that Postal Service estimates that the service changes it is proposing will save approximate $2.1 billion a year.  It’s interesting to note that in September, when the plan was first announced, the Postal Service told the media the plan would save $3 billion.  It’s not clear why the anticipated savings have been reduced by nearly a third. 

The Request proceeds to address some legal concerns that the plan has raised.  The Request states that “even if the availability of overnight First-Class Mail service were eliminated altogether, [the Postal Service] would continue to meet its obligation to provide expeditious delivery of important letter mail” through Express Mail and Priority Mail.  (Needless to say, the difference between a First-Class stamp and these faster modes of delivery is considerable, but that’s not discussed.)

As for discriminating against rural communities and small towns — something prohibited by statute — the Request says, “The proposed changes do not diminish service in rural communities and small towns to any degree greater than in urban and suburban areas.”  That is not to say, however, that everyone will be affected equally: “achievement of such a goal is not inherently possible.”

The Request notes that according to the code of federal regulations (39 C.F.R. § 3001.72, section 3661(b) ), the Postal Service is required "to file its advisory opinion request not less than 90 days before the scheduled implementation of the planned service changes."   That would mean the changes could be implemented as early as March 5.  Other regulations and procedures come into play, however, which require comment and notification periods, so the Request says, “No service changes associated with this Request will be implemented earlier than some time in the first half of April 2012.”

One of the more interesting passages in the Request is the following: “The statutory scheme governing operation of the Postal Service permits the agency to make rational adaptations to market and fiscal realities, while still fulfilling its public service obligations. That scheme does not require that long-standing products, service features, and operational practices be maintained primarily for the purpose of preserving a tangible link to an iconic past, or to perpetuate a nostalgic image of the agency or its employees.” 

That rhetorical flourish will require some serious unpacking, but for now, suffice to say, it’s not likely the 35,000 postal workers who are going to lose their jobs are thinking about an “iconic past” or “nostalgic image.”  The only thing they’re going to be nostalgic for is their friggin’ jobs.  As for the rest of the country, they’re likely to feel a pang of nostalgia all right — for the days when the mail was delivered promptly.


The Witnesses

Accompanying the Request is testimony from thirteen witnesses.  Here’s a brief rundown, with a few parenthetical remarks commenting on the summaries.


1. David Williams: Service standard changes [pdf]

David E. Williams, Jr., is Vice President of Network Operations.  The purpose of his testimony is “to describe the nature of the changes in services that the Postal Service proposes to implement in fiscal year 2012.”

“The most significant revisions,” says Williams, “would eliminate the expectation of overnight service for significant portions of First-Class Mail and Periodicals and, for each of these classes, modify the two-day range to include pairs that are currently overnight and enlarge the three-day delivery range.”  (For an analysis of the new standards, see Alan Robinson's September post in Courier Express & Postal Observer, the source of the following table.)

Williams notes that the consolidation process has been underway for some time: “The Postal Service has also been eliminating excess capacity in mail processing facilities utilizing the AMP review process.”  As of today, 114 plants have been consolidated, and 11 studies are ongoing.  As a result of these efforts, says Williams, since 2006 a total of $7.9 billion has been saved in the cost of mail processing operations. 

(It’s not quite clear how the consolidation process got this far without the Postal Service requesting an Advisory Opinion and why the Postal Service decided it could not proceed further without asking for the Opinion; perhaps a threshold of “nation-wide” impact was reached at some point.  Williams only notes that “at the time of the filing of the Request in this docket, the Postal Service was in the process of applying its USPS Handbook PO-408 guidelines to examine the feasibility of consolidating the operations of those plants into approximately 200 such facilities, and making corresponding changes to its transportation network.”  This is similar to what happened with the process of closing post offices, which was well along by the time the Postal Service finally requested an Advisory Opinion in July 2011.)

Williams’ testimony focuses primarily on the service standards themselves — how the delivery times will slow down, how mail entry will change, etc.  If you’re a mailer concerned about the changes, this is the place to start.


2. Stephen Masse: The financial context [pdf]

Stephen Masse is Vice President, Finance and Planning.  He’s been with the Postal Service since 2009, and before that he worked for BAE.  The purpose of his testimony is “to provide the financial context” for the Network Rationalization Plan.  It’s Masse’s job, in other words, to show how bad the financial situation of the Postal Service is.

Masse trots out the usual numbers.  Total mail volume is down 21% since 2006, and down 13% in 2009 alone.  First-Class is down 29% since peak in 2001.  Masse doesn’t explain that the drop in total volume is primarily due to the recession, and he doesn’t mention that three-fourths of decline in First-Class happened after the recession started.  But the testimony includes the following chart:

As you can see,  the steep drops started in 2008.  Single-piece first class was declining at about 4% a year before the recession, but that accelerated to 16% a year in 2008, and hasn’t gotten much better since.  First-Class overall was declining at less than 1% a year before the recession hit. 

Masse’s forecasts are dismal, of course, and hard to argue with since they’re speculative and no one knows what’s going to happen with the economy.  But the Postal Service is now talking about First-Class dropping from 74 billion pieces in 2011 to 39 billion pieces in 2020.  That is even worse than the worst-case scenario projected by the Boston Consulting Group (BCG) in a study commissioned by the Postal Service (published March 2010).  BCG suggested First-Class would drop to about 53 billion, and its worst case was about 44 billion.  (Masse provides no explanation for why the projections have gotten worse, so maybe one of the participants in the Advisory Opinion process will ask him about that.)

Following the volume discussion, Masse goes into the dollars and cents.  According to the numbers in Masse’s table (p. 6), the Postal Service has posted a net loss of $25.3 billion for the five years 2007 – 2011.  (The losses would have been $30 billion if the prefunding payment to the Retiree Health Benefits Fund had not been deferred for 2011.) 

The table also shows, however, that during that time period, about $20.8 billion went to the retiree health benefits fund.  If those payments had not been mandated by Congress, the total losses for 2007 to 2011 would be about $4.5 billion — less than a billion a year, or about 1.3% of annual revenues.  Not bad if you consider the Postal Service was experiencing a recession that drove car sales down 30% and new housing starts down 70%.  Plus, if the payments had not been necessary, the Postal Service would have needed to borrow only a third of its statutory borrowing limit of $15 billion, and we'd be nowhere near the precipice.

Needless to say, Masse paints a much different picture using the same numbers, and concludes that by October 2012, “the Postal Service is forecasted to have only a half-day of cash remaining.” 

The network rationalization initiative, Masse says, will save $2.6 billion, but it will also lead to revenue declines — “an annualized revenue loss of up to $1.3 billion, and an annualized contribution loss of up to $0.5 billion.”  So a half billion is subtracted from the $2.6 billion, leading to the $2.1 billion net savings.  (The difference between “annualized revenue loss” and “annualized contribution loss” is not clear, but we’ll be hearing more about that as the PRC process proceeds.)


3. Emily Rosenberg: Evaluating the processing network [pdf]

Emily R. Rosenberg is Manager of Network Analytics, within the Network Operations group at Postal Service headquarters.  She joined the Postal Service in 2007 to work on mail processing plant consolidation initiatives.  The purpose of her testimony is “is to provide an overview of the systematic step used to evaluate and model the Postal Service’s mail processing network in support of the initiative to rationalize the network and propose related service standard changes.”

The testimony explains how “the overnight service standard requires that delivery point sequencing (DPS) of letter mail take place within a very short window of time” — basically four hours, between 1:30 and 5:30 a.m.  To process 400 million pieces of mail during that time span requires a lot of Delivery Bar Code Sorter (DBCS) equipment that doesn’t get used much the rest of the day.  In order to put this equipment to better use requires extending the four-hour window, which necessitates relaxing the service standards.

The testimony goes into more detail about what this would mean in practice.  It’s basically a cost-benefit analysis of expanding the operating windows and travel time between the collection points, mail processing centers, and delivery units.  It gets very technical, but by the end, Rosenberg is able to recommend how many processing facilities would be necessary — 199 — and what kind of equipment they would need. 


4. Frank Neri: Improving the processing infrastructure & transportation [pdf]

Frank Neri is Manager of Processing Operations in Network Operations at Postal Service HQ.  He’s been with the USPS since 1984.  The purpose of his testimony is “to provide an overview of mail processing operations” and to describe how improvements can be to “the mail processing infrastructure and network, transportation network, and service standards.”

Neri explains how the “excess capacity” in the postal system developed: “When mail was increasing, state-of-the-art automated mail processing equipment was deployed to enable more efficient processing.”  Workshare arrangements led to bypassing postal processing and transportation operations, and First-Class mail has declined by 25% since 2006.  So now there’s considerable excess processing capacity.”  

(Neri doesn’t elaborate, but he’s noting that the Postal Service has outsourced a lot of its processing work through “workshare arrangements” with private companies, like pre-sort and trucking businesses.  In other words, there are too many postal workers not simply because the mail volume is down, but also because they have been replaced by workers in the private sector.)

Neri explains the flow of mail — incoming and outgoing — for the various processing categories (letters, flats, and parcels).  Then he gets into the service standards for each, and how this translates into hour-by-hour operations.

Basically, savings would be realized because there would not only be fewer facilities and fewer employees, but also for other reasons.  For example, the mail containers would be filled to capacity, which would make more efficient use of air and ground transport.  The processing equipment would also be better utilized, and there would be fewer redundancies in the processes.


5. Dominic Bratta: Reduced maintenance requirements [pdf]

Dominic L. Bratta is the Manager of Maintenance Planning and Support assigned to the Headquarters Maintenance Operations Group.  Bratta has been with the Postal Service since 1982, mostly in various maintenance management positions.  The purpose of this testimony is to describe how the Network Rationalization plan would reduce maintenance support requirements.   This provides some of the cost savings estimates in Smith’s testimony.

The testimony describes the types of maintenance — building infrastructure (heating and plumbing, etc.), services (cleaning, etc.), repairs, supplies, and so on.  As you might expect, consolidating a plant means “significant maintenance personnel would no longer be needed.”  (It’s closed.)  There are other efficiencies to be gained by consolidation, and the testimony describes them in some detail.  The testimony does not discuss the actual numbers, which are provided in associated Library References. 


6. Cheryl Martin: Effects on the transportation network [pdf]

Cheryl D. Martin is Manager of the Surface Transportation Operations group in the Office of Network Operations in HQ, and she’s been with the Postal Service since 1981.  The purpose of her testimony is provide an overview of the current transportation network and to discuss how it will increase in efficiency and decrease in costs with the Rationalization plan.

Martin explains how the Postal Vehicle Service (PVS) transports large containers of mail between mail processing facilities, and to and from airports, post offices, stations, and branches.  The Postal Service also contracts with more than 12,000 private suppliers for highway transport, which, “on average,” is less expensive than PVS. 

The testimony provides details about this transportation network, and then explains how it will operate with greater efficiency if the network is rationalized.  There’s a nifty diagram to illustrate how this works:

The reduction in the number of nodes in the network means fewer trips.  (The diagram shows the nodes approximately equidistant from each other and does not reflect actual distances or consider frequency of the different trips.  The diagrams are just to make a general point about why consolidation reduces the number of trips.)  Also, as noted in other testimony, another benefit from consolidation is that the trucks will operate at or near capacity, so they’re not driving around half full.

In order to estimate the benefits of a rationalized network, Martin analyzed a subset of routes.  She estimates that “plant-to-plant transportation could be reduced by approximately 24.71 percent.”  The plant-to-post-office transportation system benefits in a similar way, and there are more of those cool diagrams.  Another subset was analyzed, and the number of miles driven is reduced by “approximately 13.68 percent in the rationalized network.”

Martin notes that additional cost savings will be realized by transferring more transportation responsibilities to the private contractors.  (That comment is not explained in much detail, and Martin will probably be questioned about it.  It’s not clear why more of the transportation work will be done by private truckers.  Perhaps because they cover longer distances, and that’s mostly what will be left after the consolidations?)

Martin then discusses air transportation.  It’s interesting to learn that while First-Class mail will generally slow down with the Network Rationalization plan, 124 million pounds of First-Class mail will actually need to be diverted to more expensive air transport rather than surface.  Martin explains why: “In the current mail processing environment, the Postal Service has until 6:00 p.m. on the day prior to delivery to ensure that First-Class Mail with a three-day service standard arrives at the destination mail processing facility. In the rationalized mail-processing environment, First-Class Mail with a three-day service standard must arrive at the destination processing facility by 8:00 a.m. on the day prior to delivery.  Because the surface transportation window for this particular mail class will be decreased by several hours, the Postal Service will need to divert a portion of this mail volume from surface to air transportation to ensure timely delivery.”


7. Pritha Mehra: Effects on commercial mail entry 

Pritha N. Mehra is Vice President of Mail Entry and Payment Technology.  The purpose of Mehra’s testimony is “to provide an overview of the commercial mail entry channel” and to provide some insights on how “commercial customers” may be impacted.  The testimony also discusses measures the Postal Service will take to “mitigate these impacts.”

This testimony provides an overview of how commercial mail enters the system at Business Mail Entry Units (BMEUs), Detached Mail Units (DMUs) located at mailer plants, and designated Retail/Associate Office (AO) units.  

Mehra discusses some of the concerns about the rationalization plan that were submitted to the Postal Service after it was described in the Federal Register in September.  The concerns include the extra distance a mailer would need to go to get to an entry unit, loss of workshare discounts, potential changes in mail preparation and separation requirements, and so on.

The testimony proceeds to describe the mitigation efforts that will be undertaken, such as providing customers plenty of time to prepare for the changes, making sure there’s good communication with mailers, and so on.  The discussion is somewhat technical and pertains primarily to bulk mailers.


8. Kevin Rachel: Effects on employees 

Kevin B. Rachel is the Manager, Collective Bargaining and Arbitration in the Labor Relations department.  He’s been with the Postal Service for over 32 years.  The purpose of his testimony is to discuss how the Postal Service intends to reduce and realign its complement of employees under the initiative.

Rachel says the Postal Service has approximately 110,000 employees in the mail-processing network. These employees serve as managers, supervisors, technical experts, clerks, maintenance workers, motor vehicle operators, and mail handlers.  Those employee positions that are likely to be affected by the Network Rationalization Initiative are described in some detail.

Rachel also explains the steps in the process for reassigning employees: “First, management will look to reassign bargaining unit employees within the same craft and installation.  If that is not possible, then management will look to reassign outside the craft, but within the installation.  If that is not possible, management will look to reassign within the craft, but outside the installation. Finally, if this cannot be achieved, management will look to reassign outside the craft, and outside the installation.”  There’s more about the contract provisions on notification, reassignment, excessing, maximum distances to the receiving facility, the RIF process, early retirement, etc. (see pages 6 – 13, here.)

Rachel says the Postal Service “anticipates a significant reduction in employees” as a result of the initiative, accomplished through a variety of means — voluntary movement utilizing eReassign; normal attrition over the next several years; reductions in non-career employees; VER, RIFs, etc.  Rachel does not venture a particular number, saying only, “As the initiative proceeds and as the review of specific facilities for possible closure continues, the potential impact to complement will become more clear” (p. 15).

(It’s noteworthy that in reviewing the Request and the testimonies, it is impossible to find reference to an estimate of how many workers will lose their jobs.  The media has widely reported the figure of 35,000 jobs.  That means one in three workers in the processing network would find themselves out of work.  That estimate can be verified simply by considering how the Postal Service can envision a savings of $2.6 billion (before deducting lost revenue).  Figure a half billion dollars will be saved in fuel, maintenance, rent, and all non-employee costs.  Divide the remaining $2.1 billion by $60,000 (ballpark for an average salary with benefits) and you end up with exactly 35,000 employees.


9. Marc Smith: Calculating cost savings 

Marc A. Smith has been with the Postal Service since 1987 as an Economist in the Cost Attribution group of Finance.  The purpose of his testimony is to assist in calculating the annual cost savings that the Rationalization initiative will yield.  The testimony is similar to Bradley’s, and it breaks down the savings as follows (Table 11, p. 26).

The testimony provides details about each category of cost savings, and Smith outlines some areas where we can see the workforce reduced.

Smith states that that positions for non-supervisory maintenance of mail processing equipment (LDC36) “will fall from 15,320 to 11,877, or by 3,443 positions.”  In addition, “administrative non-supervisory positions (LDC 39) will decline from 1,645 to 1,239 or by 406 positions.” There would also be a reduction of 309 supervisor positions.  In addition, Smith cites witness Bratta’s estimate that no longer needing processing at the inactive facilities would enable reductions of building maintenance and custodial staff of 620 and 2,073 respectively, as well as 216 supervisor positions.  These numbers add up to 7,067 positions, so there are about 28,000 positions unaccounted for in these calculations. 

Besides savings in labor costs, the testimony also reviews savings in other areas.  The big ones are fuel, parts and supplies, and rents and proceeds from the sale of buildings.  About 90 percent of the space associated with the Inactive sites is owned, while 10 percent is rented.  Of the 252 buildings in the study — 209 owned buildings and 43 leased buildings — the Postal Service would be able to fully vacate only 93 buildings.  Selling off buildings would bring in one-time revenue of $448 million, and save $16.8 million in annual lease costs.  But there would also be one-time capital costs of $121 million.

The testimony contains lots more data explaining the cost-savings in each of the categories in the summary table.  There’s also a lengthy appendix describing savings related to labor costs.  These involve annual leaves, holiday leave, workman’s comp, pension benefits, and so on.  There’s also an attachment that breaks down the costs for running all the USPS processing plants: $13.8 billion.


10. Michael Bradley: The methodology for calculating savings [pdf]

Michael D. Bradley is a Professor of Economics at George Washington University who does research on postal economics.  He has provided testimony to the PRC many times before (he dates himself by referring to the PRC by its pre-2006 name, the “Postal Rate Commission,” presumably because that’s what it was called back when he was testifying on earlier cases).   Professor Bradley lists several of his publications, and he is clearly well published in the field.

The purposes of his testimony are “to discuss the methodology the Postal Service will employ in identifying the changes in cost that would be caused by the proposed change in service standards, to calculate the resulting cost changes in the areas of mail processing labor and transportation and to compute and to present the overall change in cost.” 

Bradley notes that while the proposed changes will allow the Postal Service to gain efficiencies and reduce cost in some areas, it will incur additional costs in other areas.  The description of the analytic methodology is complicated, and it contains equations like this:

(We’ll leave it to the experts to deal with the higher math, but this means roughly, “If you’re a worker in the processing network, you have a one-in-three chance of being screwed.”)

The following table breaks down the $2.6 billion in cost savings the Network Rationalization process should yield:


11. Rebecca Elmore-Yalch: Consumer research [pdf]

Rebecca P. Elmore-Yalch is a Senior VP at ORC International (ORC), “one of the oldest and most respected full-service custom marketing research firms in the United States.”  The purpose of Rebecca’s testimony (why she’s referred to in the third-person by her first name, when everyone else uses last names, is curious) is to conduct market research to determine how the proposed change would impact consumers and businesses.

The methodology of the research is described in great detail, and critics of the Rationalization plan will probably examine it closely.  It included eighteen focus groups, in-depth interviews (IDIs), surveys, and questionnaires with a variety of postal customers (small business, home-based business, consumer, etc.) in a variety of industries (construction, agriculture, etc.).  The goal was to examine the “likelihood that a change to First-Class Mail service standards would cause changes in the volume they send” as well as in how they send items (by what class of mail).

The study concludes with several tables and a ton of data about how people’s behavior might change as a result of the Network Rationalization.  In almost every category, there would be a decline in mail volume and revenue.  Check out pages 50-52 of the testimony for the details. 


12. Gregory Whiteman: Evaluating consumer responses [pdf]

Gregory M. Whiteman is the Manager of Market Research for the Postal Service, and he’s been with the post office since 1969.  The purpose of his testimony is “to provide (1) an assessment of the qualitative reactions of both consumers and commercial organizations to the proposed changes to service standards for First-Class Mail and Periodicals, along with other associated operational changes resulting from the Network Rationalization initiative, based upon our qualitative market research and (2) the estimated volume and revenue impact from our quantitative market research.”

Whiteman directed witness Elmore-Yalch in her study.  Her testimony presented the methodology; he presents the results, some of which are not available to the public.

“The most substantial finding concerning the changes to service standards from focus groups and IDIs was that most consumers and small commercial organizations said that changes to the First-Class Mail and Periodicals service standards would have a limited impact on their mailing behavior and their use of the internet as an alternative to mail.  Most said they would easily adapt, especially by mailing earlier than they do now.” (p. 4)  

“Overall, we conclude,” writes Whiteman, “that the impact on volume, revenue and contribution from the changes in the service standards will be a reduction of 2.9 billion pieces or 1.7 percent of total volume, producing a loss in revenue of $1.3 billion or two percent, and a loss in contribution of $499 million or two percent, using FY2010 volume, revenue, and contribution data” (p. 7).  (As noted above in connection with Masse’s testimony, it’s not clear how “loss in revenue” differs from “loss in contribution,” so more on that to follow.)


13. Susan LaChance: Communications [pdf]

Susan M. LaChance has served as Vice President of Consumer and Industry Affairs at Postal Service headquarters since January 2011.  The purpose of her testimony is “to describe the customer outreach processes that have been utilized to provide insight during the development of the network rationalization service changes” and to “describe the Postal Service’s communications plan for informing postal customers” about the changes.

This testimony is mostly PR about what a good job the Postal Service does to communicate and how it will inform customers about the service changes. There’s likely to be plenty of testimony at the PRC about aspects of the “communication” issue.  According to news reports about the consolidation studies that have already begun, many communities aren’t very happy about how they’ve been notified of proposed AMP consolidations, and many feel that there comments aren’t really being considered seriously — the same thing that’s happened with the closing of post offices.

There is one interesting detail in LaChance’s testimony.  After the Postal Service published its proposal in the Federal Register in September, it received 4,200 comments from members of the public.  Media reports have said that most of the comments were negative. 

If you’d like to see the comments, however, you’re going to have to take a trip to our nation’s capital.  As stated in a footnote, “Copies of these comments are available for public viewing for the duration of this docket by appointment in the USPS Library on the 11th floor at Postal Service headquarters, 475 L’Enfant Plaza SW, Washington DC 20260. Appointments can be arranged by telephone at (202) 268-2906” (p. 9). 

One wonders why the Postal Service doesn’t seem very interested in sharing the public’s comments with the public.  It probably spent a lot of money on the market research by ORC, but when it comes to all the free comments, well, apparently they don’t count for much.  Hopefully someone involved in the PRC Advisory Opinion will ask for a copy.

That completes this summary of the witness testimony.  We’ll get to the 36 library references in a future post.

(Photo credits: College Point, Queens NY P&DC; Stamford CT P&DC and New Jersey L&DC (Evan Kalish); Hutchinson KS plantUSPS sort & delivery processFSS machineMCA truckmail ready for BMEUmail handlerfocus group cartoonfocus group cartoon; Postal Service headquarters.)