The Mid-Hudson Local of the APWU filed a Complaint today with the Postal Regulatory Commission requesting that the Commission order the Postal Service not to proceed with the consolidation of 55 mail processing plants that were previously scheduled for 2014.  The Mid-Hudson P&D in Newburgh, New York, is one of those plants.

The Complaint's full title summarizes its theme: "Complaint of Mid-Hudson Area Local and Consumers of USPS Regarding Failure to Revise and Update Information to the Unions & Consumers on the AMP Study for Mid-Hudson P. & D. Center, N.Y."

The Mid-Hudson Local makes a number of important points in its Complaint: 

• The AMP study done in 2011 on the Mid-Hudson facility is outdated and inaccurate.  For example, savings that were to be achieved by the consolidation have been achieved in other ways, such as using new low-wage postal support employees (PSEs). 

• The Postal Service failed to provide all evidence collected from the public in December of 2011 and did not accurately represent the public’s concerns and comments. 

• The Postal Service has refused to provide un-redacted copies of the completed AMP feasibility study with supporting data, as required by a recent NLRB Ruling. 

• The Postal Service did not conduct a “true study on the adverse affects of closings or consolidations of the plants on small and large businesses within the communities.”

• Management has hidden the costs of moving mail and equipment from one location to another, especially over the 50-mile radius.

• Communities potentially affected were not provided with adequate public notice of the new accelerated plan announced just a few weeks ago.

• The PRC was not given the opportunity to comment on the latest consolidation plan, which essentially nullified the plan that the Commission did review last year.

The Complaint argues that because of these problems in the process, the Postal Service should hold a new meeting about the Mid-Hudson plant, provide a new cost-savings analysis based on updated data, and share un-redacted reports with the union.  Until these things are done, argues the Complaint, the PRC should “direct the Postal Service to stop any further AMP implementations.”

“The USPS has continued to keep the employees, the unions, the customers, the community and the PRC in the dark as to the adverse effects of all the closings and consolidations,” says the Complaint.  “We are being used as pawns so that pressure is placed on Congress to do their job and release the USPS from PAEA requirements to pay into the health plan fund 75 years in advance, and to attempt to recoup the overpayments made over the years that have not been returned to the USPS.  This is being done at the detriment of the communities and the workers.”

It will be interesting to see how the PRC handles the Mid-Hudson Local’s Complaint.  Last year, the Commission spent many months studying the Postal Service’s Network Rationalization plan.  It was a challenging task, partly because of the complexity of the mail-processing network, but largely because the Postal Service kept changing the plan, even while the Commission was reviewing it.

One of the main changes in the plan was the Postal Service’s decision to implement the consolidations in two phases.  Phase 1, which encompassed 140 plants, began last summer and is underway right now.  Phase 2, which included 89 plants, was to have taken place in early 2014.  But now the Postal Service has changed the plan yet again and moved 71 plants on the phase-2 list up to 2013.

That basically means that the PRC rendered an advisory opinion on a plan that was not the one currently being implemented.  Much of the data the Postal Service provided the PRC about cost savings and other aspects of Network Rationalization are therefore no longer applicable and accurate.

The PRC’s advisory opinion on the plan was issued after the Postal Service began the implementation process, which suggested that postal management didn’t much care what the Commission said.  Now the Postal Service is ignoring one of the advisory opinion's main recommendations, namely that the Postal Service should take the time to see how the phase-1 consolidations are going before it proceeds to phase 2.  

In speeding up the consolidations, the Postal Service is doing just the opposite of what the Commission recommended.

The PRC’s review of Network Rationalization also found that a significant number of consolidations could take place without having a detrimental effect on service standards, specifically on overnight delivery.  The Commission seemed to be suggesting that the Postal Service might be better off just doing the phase-1 consolidations and not proceeding with phase 2 at all.  The Postal Service is ignoring that recommendation as well.

Given how little the Postal Service seemed to care about the Commission’s advisory opinion last year, it’s not surprising it would be disregarding PRC recommendations again.  As a result, it's hard to imagine the PRC will take a very active role at this stage of the game. 

Still, the Mid-Hudson Local deserves kudos for taking this initiative and for giving the PRC an opportunity to revisit Network Rationalization.  Maybe the Commission will seize the moment and raise some important questions about why the consolidations are being speeded up and what adverse effects that may cause.   

But if you’re looking for the Commissioners to put a stop to the accelerated consolidation plan, don’t hold your breath.

UPDATE: The APWU Red Bank Local has filed a similar complaint with the PRC concerning the consolidation of the Monmouth P&D Center in New Jersey.

(Photo credits: Mid-Hudson P&D; Mid-Hudson postal workers at a rally in 2011.)