The Summer 2022 newsletter from Community and Postal Workers United (CPUW) has articles about the “Dump DeJoy” campaign, the crisis of understaffing, and providing non-postal government services at local post offices,. Read the newsletter here.
Earlier this week the Postal Service shared a list with the Postal Regulatory Commission identifying 170 post offices that were “temporarily” suspended several years ago and that will soon be closed permanently.
The list was submitted as part of the PRC’s Public Inquiry into what can be done to push the Postal Service to clear up a backlog of over 400 long-standing, unresolved emergency suspensions.
In its filing with the PRC, the Postal Service explains that the effort to resolve these suspensions has been hampered by the pandemic and organization changes made in 2020, but it is now prepared to proceed. The Postal Service says it has “identified 170 sites that qualify for swift official Discontinuance,” and it plans to complete this project by the end of September 2022.
Not that there has been anything “swift” about the discontinuance process on these post offices. Six of the suspensions occurred more than 20 years ago, 63 occurred more than 10 years ago, and with a couple of exceptions, they all occurred at least five years ago.
When an emergency suspension first take place, whether it’s due to a problem renewing the lease (the most common cause), unsafe conditions or damage to the building, the Postal Service almost always reassures the community that the closure is only “temporary.”
After a suspension occurs, the Postal Service is required to reopen the office by fixing the problem that led to the suspension (relocating if necessary), or it can decide that the suspension is a reason to initiate a discontinuance process.
The law doesn’t put a time limit on this process, so the Postal Service can start the discontinuance process by posting a proposal to close and perhaps proceeding to the required public meeting and circulating the customer questionnaires, and then put the process on hold. There’s currently a backlog of 425 unresolved suspensions. A few of these offices may be reopened, but most are headed for discontinuance.
For 32 of the 170 offices now slated for discontinuance, the Postal Service has completed 29 of the 30 steps in the process, and all that remains is publishing a notification in Postal Bulletin. For the other 138, the Postal Service hasn’t made a final decision (although it’s clear what that decision will be), so the final determination notice has not yet been posted.
The notice contains a paragraph at the end explaining that customers have 30 days to file an appeal with the PRC. Normally this notice would be made available for inspection at the post office being closed, but when a post office has already closed by suspension, it can only be posted at other nearby post offices.
It’s not very likely, then, that anyone will come upon a final determination notice at a post office a few miles away from the one that was suspended and learn that it’s now possible, after five or ten years, to file an appeal. Most likely, the people in these communities will not even become aware that the Postal Service has, at long last, made a final determination to close the post office.
If there’s no appeal, the administrative record documenting how the suspension and discontinuance process was conducted never becomes public. That’s unfortunate, especially considering that the process for many of these closures was surely flawed (as discussed in this 2018 OIG report), which could provide grounds for an appeal.
The PRC has shown little interest in how the Postal Service has conducted the discontinuance process on these long-standing suspensions. The focus has instead been on just getting the Postal Service to clear the backlog so that it is not “out of compliance” with the law governing discontinuances. The Commission will probably be content to see that progress is being made.
The Postal Service’s list of the 170 offices identified for discontinuance is here. More details about these offices can be found on this table, derived from the “Save the Post Office” Suspension Dashboard. There’s more about the suspension backlog and the dashboard in comments that I filed earlier this week for the PRC’s Public Inquiry, here. See also the comments filed by the PRC’s Public Representative, here.
170 suspended post offices, to be discontinued by Sept. 2022
In February the Postal Regulatory Commission opened a Public Inquiry docket to invite comments about the large backlog of long-standing, unresolved post office suspensions. Here are the comments I submitted today. (Comments were also submitted by the PRC’s Public Representative and the Postal Service.)
Pursuant to Order No. 6101, I respectfully submit these comments for the Commission’s Public Inquiry concerning the resolution of suspended post offices. My comments focus on one step the Commission could take that might help address some of the issues associated with unresolved emergency suspensions. The Commission could work with the Postal Service to create a suspension dashboard that contains information about the post offices under suspension and their status in any discontinuance process that has been initiated. Such a dashboard would not be burdensome to set up and maintain, it would improve transparency and accountability, it would help communities and customers whose post office has been suspended by making important information readily accessible, and it might incentivize the Postal Service to resolve the backlog of suspensions and avoid future backlogs. My comments consider what information the dashboard could contain and describe a prototype I have created on my website, savethepostoffice.com.
I have been following post office suspensions and discontinuances on savethepostoffice.com since 2011. The site includes articles about more than 150 suspensions, discussions of issues concerning suspensions and discontinuances, and many lists and maps inventorying suspensions and closures. I have also contributed comments on previous Commission dockets concerning suspensions and closings.
Over this past decade, one of the main issues regarding post office closures has been emergency suspensions. In many cases, it appeared to local communities and other observers that the Postal Service was using the suspension provision to close post offices without going through a lengthy discontinuance process and without making a good faith effort to solicit public comment. As the Commission has previously stated, the Postal Service may be circumventing post office discontinuance requirements, such as obtaining and considering customer input, “by suspending post offices and allowing them to simply remain suspended without any action.”
This is not a new problem. In 1999 Congress held a hearing about post office closures and suspensions. Howard Foust, the President of NAPUS, presented a Congressional committee with a list with over 500 offices “under temporary emergency suspension,” 220 of which were over five years old. “That does not sound like temporary to me,” Foust told Congress. People affected by the suspensions, he testified, “have concluded that the Postal Service has elected to circumvent the Postal Reorganization Act procedure for closing a post office by using the suspension ploy.”
The Commission has been tracking suspensions for many years as part of its annual compliance review and to follow up on its 2010 Public Inquiry docket on suspensions. As of the end of FY 2016, there was a backlog of 662 suspensions, many going back ten years or more. The Commission has repeatedly and consistently encouraged the Postal Service to clear this backlog. Some progress has been made. Approximately 456 of the suspensions from FY 2016 have been resolved, nearly all by discontinuing the post office. But at the same time, new suspensions have been added to the backlog list. At the end of FY 2021 there was a backlog of 425 suspended offices.
According to Order No. 6101, the Commission seeks to expedite the resolution of this backlog out of “concern regarding the apparent lack of commitment by the Postal Service in addressing and resolving” them. Order at 3. The Commission offers no specific suggestions about how resolving the suspensions might be expedited, and it’s not clear what steps would be within the Commission’s authority. According to the USPS Discontinuance Guide, the Commission has no role when the Postal Service suspends a particular post office, and its role in the discontinuance process for individual post offices is limited to responding to appeals. The Commission has not identified any penalties it might impose on the Postal Service for failure to clear this backlog or for using the suspension provision to conduct de facto discontinuances.
Congress has addressed the suspension issues on several occasions. In 1999 Representative Earl Blumenauer introduced H.R.670 (S.556). It included a provision that was intended to prevent the Postal Service from misusing the right to suspend services by guaranteeing that suspensions would last no longer than 180 days.
In 2016 Senators Claire McCaskill and Jerry Moran introduced S.3452, the Post Office Discontinuance Accountability Act. It addressed the problem of long-term suspensions by requiring the Postal Service to either proceed with a discontinuance procedure or restore service within 180 days after a suspension occurs. If the post office were still suspended after a year, the Postal Service would be required to offer additional opportunities for public input, including an in-person meeting. The bill would also prohibit suspending a post office due solely to a lease expiration, which remains the most common cause for a suspension and was one of the main topics of the Commission’s 2010 Public Inquiry docket.
In 2018, Senator McCaskill introduced a new version of her suspension bill, S.1204. It added a provision that would have allowed a person served by a post office to file an appeal to the Commission if it has been suspended for more than one year, and it also required the Postal Service to consult with the Commission about revisions of Handbook PO-101 regarding suspensions.
Also in 2018, Senator Thomas Harper introduced S.2629 – Postal Service Reform Act of 2018. While not focused primarily on suspensions, this bill contained a section (213) that encompassed many aspects of the suspension process. It addressed long-term suspensions by requiring the Postal Service to host a second public meeting if service has not been restored after 180 days and a third meeting if service has not been restored after one year.
Earlier this year, Congresswoman Cynthia Axne of Iowa introduced a bill that would require the Postal Service to create a suspension dashboard. H.R.6355, The Postal Suspension Transparency Act, responds to concerns from Axne’s constituents who had experienced a suspension and to a recent OIG report on suspensions. It would “require the Postal Service to establish a website providing information on post offices experiencing emergency suspensions, and for other purposes.” H.R.6355 is specific about what this “public-facing dashboard” would contain for each suspended office:
- A street address
- The date on which the relevant emergency suspension for such covered post office took effect
- The reason for such emergency suspension
- Alternative services available, including how to request curbside delivery
- The location of, and hours of operation for, the nearest facility providing retail access to postal services
- To the extent practicable, the estimated date on which operations at such covered post office will resume
The bill indicates that the dashboard should be interactive and enable a user to search, filter, sort and download the data. Noting how much people depend on the post office and how important it is for facility closures to be quickly addressed, Congresswoman Axne describes the legislation as “a commonsense way to make sure the Postal Service is keeping everyone informed in the event of unforeseen disruptions.”
Service Disruption Alerts
The Postal Service already maintains a section on its website about recent service disruptions alerts. There are notices about the most recent disruptions, state by state, as well as a national map and a spreadsheet list. The spreadsheet contains the following information:
- Name of post office
- Date of disruption
- Date of last update
- Affected ZIP code areas
- Reason for disruption
- Projected resume date for operations
- Operations impacted (including retail)
- Location where operations have been moved
These service disruptions usually involve weather events like hurricanes and earthquakes, but in some cases the causes are like those that can lead to a suspension, such as safety issues and structural damage. Some of the post offices on the service disruption report are described as having been suspended, and some appear on the suspension lists shared with the Commission. But most of the offices on the disruption alert spreadsheet are not on the suspension lists, and most of the offices on the suspension lists are not on the disruption list. Consequently, it’s not clear when a “disruption” becomes a “suspension” and vice versa. In any case, the disruption alert spreadsheet is another model for what data a suspension dashboard might include.
In addition to the service alert page, the Postal Service maintains a Find USPS Locations website, which has a page for each post office containing its address, retail services, hours of operation, and location map. The site does not indicate if a post office has been suspended. Instead, suspended offices are typically removed from the site completely. In some cases, however, the PO Locator shows offices as still in operation even though they appear on the suspension lists.
The Administrative Record
Another source of ideas for a suspension dashboard is the administrative record that the Postal Service develops during the discontinuance process. As part of the process, this record must be made available to the public, and when an appeal is filed over a discontinuance, the Postal Service is also required by 39 CFR § 3021.21 to file the administrative record with the Commission.
The administrative record typically includes several components, many of which may also be included in the proposal that initiates a discontinuance study.:
- The post office’s location and hours of operation
- A list of nearby post offices, with their addresses and hours from the USPS Find Locations page and a map, particularly the office where boxes were relocated, with distances to these other locations
- Photographs of the post office exterior
- The number of post office boxes in use
- A summary of the concerns expressed at the community meeting and comments submitted in writing, along with the USPS responses
- A discussion of the advantages and disadvantages of the proposal to discontinue
- Potential effects of a closure on community
- Potential effects on postal employees
- Economic savings, with annual lease costs, renewal dates and options, as well as basic data about revenue, workload and transactions
- Notice of the right to appeal to the Commission
The proposal to discontinue and the administrative record must be made available to the public for inspection by posting them in the retail facility under study and at other facilities “likely to serve a significant number of customers of the facility under study.” PO-101 at 25. In the case of a suspension, the proposal must also be posted at the installation providing alternative services. Given the difficulties of making these materials available for suspended post offices, an online dashboard would be a very useful way to share this record.
A Prototype Dashboard
To illustrate what a suspension dashboard could look like, my website offers a prototype. It contains some of the information called for by H.R.6355, as well as the kind of information found on the USPS service disruption alert page and the administrative record for discontinuances. The dashboard includes all the data on the suspension spreadsheets the Postal Service has been providing the Commission, combined with data from other sources, including a list provided in the POStPlan docket, the USPS Facilities Reports on leased properties, and other publicly available sites. It contains the following:
- Name of the office
- Address of the office
- Date of suspension, reason for suspension, dates for the proposal and community meeting, and the stage in the reopening or discontinuance process (from the lists provided by the Postal Service to the Commission);
- A photo of the exterior (usually from Google Street Views)
- A link to a Google map showing the location of the office
- A link to a Google map showing post offices in the surrounding area
- Distances in drive time and miles to the nearest post office (based on the Google map)
- Distance to the Administrative Post Office (based on data shared in the POStPlan docket)
- POStPlan level (if applicable)
- Workload if POStPlan (if applicable)
- Number of post office boxes in use (also from the POStPlan docket)
- Population data on total pop and rural pop from the census
- Lease data from the facilities reports
- Community profile information from Wikipedia
- Census data from a zip code website
This prototype dashboard contains some inaccuracies and is incomplete in several respects. In some cases, the post office’s address on the dashboard may be incorrect because the suspension reports provided to the Commission do not always have enough information to determine the correct address, especially for suspensions that happened many years ago. Without a specific address, it is not possible to accurately identify the office, measure distances to alternative offices and do other spatial analysis, as suggested by Order 6101 at 4. The data on workload and distances to an Administrative Post Office were available only for the small offices covered by POStPlan. The census data on population, downloaded from the US Census website, was not available for every ZIP code, apparently because the Census uses ZIP Code Tabulation Areas. The Postal Service’s spreadsheet for the suspensions that occurred after FY 2016 does not include information about the date when the proposal was submitted, the date of the public meeting, and the stage of the discontinuance process — information that was included in the spreadsheet on the FY 2016 list. The dashboard consequently lacks this important data. Finally, the dashboard does not contain any information about the alternate access facilities provided to customers of the suspended offices. While typically included in press releases and posting notices at local facilities, this information was not readily available for the 450 suspensions.
Despite these problems, the dashboard provides a model for how the information could be presented. Like the USPS Find Locations site, it has a page for each office. As required by Representative Axne’s bill, there’s a table that can be searched, filtered, sorted and downloaded. As one would find in a proposal to discontinue, the dashboard includes maps showing the surrounding post offices, distance and drive times to these other facilities, as well as information about boxes in use, lease costs, and so on.
There is also a national map with all the suspensions. It has four layers, based on when the suspension took place and the categories in Commission Order 6101 at 27: (1) FY1984-FY2012 (i.e., pre-POStPlan suspensions); (2) FY2013-FY2016; (3) FY2017-2020; and (4) FY2021. Together, the first two layers contain the 206 suspensions remaining from FY 2016 and before; the third layer consists of those suspensions that took place after FY 2016, and the fourth layer, the recent suspensions.
The dashboard includes all the 453 offices suspended at the end of FY 2021, as cited in Order 6104, which was based on a library reference filed with the FY2021 ACR on December 29, 2021. This list was subsequently updated on February 11, 2022, with a list showing 425 offices suspended at the end of FY 2021. The update list shows one office that had not appeared on the December 29 list, bringing the total on the dashboard to 454  This includes 207 suspensions from FY 2016 and before, plus 247 from after FY 2016. The dashboard shows 30 offices have been reopened and 424 remain suspended.
The dashboard does not include suspensions that may have occurred but that do not appear on the two suspension lists provided by the Postal Service. For example, according to a USPS news alert, the post office in Sandia, TX was suspended due to safety concerns on October 9, 2020. According to a news article, the Bay Station Post Office in Brooklyn, NY closed due to a fire in February 2021 and remained closed a year later. According to a USPS Industry Alert, the post office in Powhatton, KS was suspended due to safety concerns on June 14, 2021. According to a USPS news release, the post offices in Tangipahoa, LA and Boutte, LA were suspended due to safety issues following Hurricane Ida on September 7, 2021, and they did not reopen until March 28, 2022. These suspensions all occurred during FY2021 and all but Bay Station appear on the disruption alert list, but none of them appears on the suspension lists provided to the Commission, and they haven’t been included on the dashboard.
The Commission states that it “welcomes comments with any data analysis related to suspended post offices, including, but not limited to, the spatial analysis of suspended post offices.” Order 6101 at 4. In addition to the maps showing the locations of the suspensions and the maps showing nearby post offices, the dashboard contains a spreadsheet with a wide range of data, much of it available for spatial analysis. The following statistics are derived from this table. The numbers are approximations and, except where noted, encompass all 454 offices on the dashboard.
- Approximately 20 percent of the suspensions took place between fiscal years 1984 and 2012, 27 percent during FY 2012-2016, 22 percent during FY 2017-2020, and 30 percent during FY 2021.
- Lease-related issues are identified as the cause for 46 percent of the suspensions; safety issues, 29 percent; building damage, 8 percent; natural disasters, 5 percent; no qualified personnel, 3 percent; building closed by lessor, 2 percent; miscellaneous and other reasons, 7 percent.
- The dashboard shows that all 30 steps of the discontinuance process have been completed for 33 offices. Another 136 have reached step 29.
- For the 424 offices still suspended at the end of fiscal year 2021, the average length of the suspension (as of September 30, 2021) was 5.7 years, with 19 suspensions over 15 years old, 66 suspensions over 10 years old, and 209 over 5 years old.
- The dashboard shows the required community meeting date for 189 offices. Approximately 64 took place more than ten years ago.
- Based on data from Postmaster Finder, which provides the date established for 127 of the suspended post offices, approximately 102 were established before 1900.
- Approximately 288 of the suspensions occurred at POStPlan offices. That’s 77 percent of the 372 unresolved suspensions that have taken place since POStPlan was implemented in 2012. Approximately 43% of the POStPlan offices were Level 2, 46 percent were Level 4, and 12 percent were Level 6. For context, under POStPlan, 13,161 offices were downgraded, and of these, 15% were Level 2, 52% were Level 4, and 33% were Level 6.
- According to calculations derived from Google maps, the average distance to the post office nearest the suspended office was 5.2 miles, the average drive time, about 8 minutes. For the 250 post offices where the ZIP code population was 100% rural (and for which data were available), the average distance was 6.7 miles and average drive time, 9.3 minutes.
- Many of the nearby post offices reflected in these distances are POStPlan offices open only part of the day. The table shows that the average distance to the Administrative Post Office (APO) open 8 hours a day was about 10.8 miles. That is similar to the average distance to an APO on the full POStPlan list, 10.2 miles.
- Each POStPlan office had, on average, 89 post office boxes. For all the POStPlan office, there were 26,400 boxes in use. Some of these boxes were relocated to other post offices, but many were not.
- Of the 372 suspensions for which the Zip code had a corresponding Census Zip, 250 occurred in ZIP areas that were 100 percent rural, with an average population of 635 and a total population of about 158,000. The total population for all these 372 suspension areas was 2.7 million, with an average population per ZIP code of 7,359.
- For the 314 offices for which data were available in the USPS facilities reports for 2015, the average annual lease cost was $15,627. For the 193 offices in communities that were 100 percent rural, the average annual cost was $5,341.
While none of the bills proposed in Congress to address suspensions has become law, they provide suggestions for how to avoid de facto closings via suspensions and prevent large backlogs of unresolved suspensions.
For example, as suggested by S.3452, when a suspension reaches a certain age, the Commission could direct, or strongly encourage, the Postal Service to hold another round of public input, through written comments and meetings. This would ensure that a discontinuance is not based on out-of-date information, and the additional requirement might incentivize the Postal Service to avoid long-term suspensions in the future.
As suggested by S.1204, appeals to the Commission should be encouraged, even for offices under suspension. The Postal Service is supposed to advise communities of their right to appeal, but it has historically limited this notification to independent post offices, not stations and branches and not suspended offices, for which it claims an appeal would be premature. But nothing prevents customers from appealing suspensions, and in the past, two such appeals had important results. In its order on Hacker Valley, West Virginia, the Commission denied the Postal Service’s motion to dismiss the appeal as premature and initiated a public inquiry to develop a more complete record on emergency suspensions. In its order on Climax, Georgia, the Commission agreed that an appeal was premature but directed the Postal Service to submit periodic status reports, and the post office was eventually reopened. If even a few of the communities now experiencing a suspension were to file appeals, the results could be equally significant. It’s not clear from the material shared with the Commission if, how, when, and where customers have been notified of their appeal rights. The Commission should ensure that the communities impacted by suspensions are aware of this right.
Finally, as suggested by H.R. 6355, the Commission should work with the Postal Service to create a suspension dashboard as described in the bill, along the lines of the prototype on savethepostoffice.com. As this prototype illustrates and as discussed above, there are many gaps in the data thus far provided by the Postal Service. It would therefore be useful if the Commission requested more information about the offices currently under suspension, including the following:
- A list of all the offices suspended at the end of FY 2021 showing the full address for each: street address, state and zip.
- For the suspensions since FY 2016, a list showing if and when a proposal to discontinue was posted, when a public meeting was held, and what stage has been reached in the discontinuance process.
- As suggested by Rep. Axne’s bill, a list showing the alternate access facilities, at least for the more recent suspensions.
The Postal Service may object that responding to such requests is too burdensome, but it has ready access to most, if not all, of this information in its Discontinuance Tracking System and other facility databases. In any case, a more significant burden has fallen on the customers and communities whose post offices have been suspended. The Postal Service should at least be able to provide more information about the suspended offices.
The Commission is in the process of creating a dashboard for service performance. In Order No. 6104 establishing the Public Inquiry on this dashboard, the Commission explains that “Congress has encouraged federal agencies to improve the quality and accessibility of their data. The Commission is required to comply with the OPEN Government Data Act, and the Commission looks to open data policies for guidance on transparency initiatives.” The Commission also states that it is interested in hearing comments about “What, if any, other dashboards should the Commission develop that are consistent with the Commission’s statutory authorities.”
A suspension dashboard would clearly be consistent with the Commission’s statutory authority, and it would be an excellent way to improve the quality and accessibility of suspension data and to respond to the OPEN Government Data Act.
An easily accessible and comprehensive suspension dashboard would provide individuals in communities impacted by a suspension with important information about the status of the suspension and/or discontinuance, the locations of alternative facilities, and the date and location for upcoming community meetings. By including elements of the administrative record, the dashboard would make it much easier for the public to access the kind of information that gets posted during a discontinuance review — information that is especially difficult to find when the post office has been suspended. The dashboard would also make the suspension information already being shared with Commission as part of the annual compliance review much more accessible. As it is, locating the key spreadsheets on the Commission’s website is a challenge, and there are so many versions and corrections it’s very difficult to know which is the most recent and reliable. The dashboard would ensure that there’s an accurate, up-to-date listing of the impacted offices, and it would address the problem of inconsistencies between iterations of the suspension lists, the service alert list, the Find Locations website and news releases, as discussed above. The dashboard would also pre-empt the need for the Commission to respond to any ad-hoc information requests it receives from the public or from Congress about specific suspensions.
A suspension dashboard would increase transparency and accountability and encourage the Postal Service to expedite the resolution of the backlog of suspensions. As the Commission observed in 2011 concerning the first public inquiry into suspensions, “While no specific action was taken as a result of the public inquiry docket, it has brought the issue to the attention of the Postal Service and the general public. As a result of the Commission’s increased transparency and accountability of the Postal Service on this issue, the Postal Service now appears to be monitoring the practice of its local officials to ensure that the emergency suspension process is being used only as intended and that facilities that were previously suspended on a seemingly indefinite basis are reviewed in a timely manner for potential closure or other appropriate action.”
As we have seen over the past decade, the Postal Service has not improved its suspension practices to a satisfactory degree. Suspended offices are not being reviewed and resolved in a timely manner. More transparency and accountability are necessary. A dashboard won’t solve all the problems, but it would help.
 Docket No. PI2022-1, Notice and Order Providing an Opportunity to Comment on the Postal Service’s Process for Resolving Suspended Post Offices, February 3, 2022 (Order No. 6101). https://www.prc.gov/docs/120/120836/Order_6101.pdf
 Archived at https://www.savethepostoffice.com/tag/emergency-suspensions/. One of my inventory articles was cited in United States Postal Service: A Sustainable Path Forward: Report from the Task Force on the United States Postal System, December 2018 at 15 (footnote 51). https://home.treasury.gov/system/files/136/USPS_A_Sustainable_Path_Forward_report_12-04-2018.pdf
 See Initial Comments on the Commission’s Jurisdiction Over Post Office Closings (Feb. 4, 2016) and Initial Comments Regarding the Commission’s Section 701 Report (June 14, 2016). https://www.prc.gov/docs/94/94905/Hutkins%20re%20PI2016-2.pdf; https://www.prc.gov/docs/96/96200/Hutkins_Comments_on_701_Report.pdf
 Order No. 6101 at 20, quoting Order No. 335 at 3, Docket No. PI2010-1, Notice and Order Providing an Opportunity to Comment, November 9, 2009. https://www.prc.gov/docs/65/65562/Order_No_335.pdf
 Guidelines for the Relocation, Closing, Consolidation or Construction of Post Offices, Hearing before the International Security, Proliferation, and Federal Services Subcommittee (October 7, 1999). https://www.govinfo.gov/content/pkg/CHRG-106shrg61701/html/CHRG-106shrg61701.htm
 See Docket No. ACR 2017, Library Reference USPS-FY17-33, December 29, 2017, folder “USPS.FY17.33.Files,” Excel file “Post.Office.FY2017.xlsx,” Tab “Suspended Start of FY17.” https://www.prc.gov/dockets/document/103288 Available at https://tinyurl.com/2p946mtw.
 See Docket No. ACR 2021, Responses of the United States Postal Service to Questions 1-21 of Chairman’s Information Request No. 11, February 11, 2022, ChIR 11 Response Attachments, Tab “Suspended End of FY21.” https://www.prc.gov/dockets/document/120910. Available at https://tinyurl.com/y8rjjrus.
 United States Postal Service, Postal Service-Operated Retail Facilities Discontinuance Guide, Handbook PO-101, October 2012. See Docket No. ACR2020, Responses of the United States Postal Service to Questions 1- 26 of Chairman’s Information Request No. 3, January 22, 2021, “ChIR.3.Response.Attachments.zip,” folder “ChIR 3 Question 13,” PDF file “ChIR.3.Q.13.Handbook.PO_101.pdf.” https://www.prc.gov/dockets/document/115895/. Available at http://www.savethepostoffice.com/wp-content/uploads/2022/05/Handbook.PO_101.pdf
 H.R.670 – Post Office Community Partnership Act of 1999, Feb. 10, 1999. https://www.congress.gov/bill/106th-congress/house-bill/670
 S.3452 – Post Office Discontinuance Accountability Act of 2016, Sept. 28, 2016. https://www.congress.gov/bill/114th-congress/senate-bill/3452/
 Docket No. P12010-1, Order No. 335, Notice and Order Providing an Opportunity to Comment, November 9, 2009. https://www.prc.gov/docs/65/65562/Order_No_335.pdf
 S.1204 – Post Office Discontinuance Accountability Act of 2018, May 23, 2017 https://www.congress.gov/bill/115th-congress/senate-bill/1204/
 S.2629 – Postal Service Reform Act of 2018, April 9, 2018 https://www.congress.gov/bill/115th-congress/senate-bill/2629/
 H.R.6355 – To require the Postal Service to establish a website providing information on post offices experiencing emergency suspensions, and for other purposes, Jan. 6, 2022 https://www.congress.gov/bill/117th-congress/house-bill/6355
 United States Postal Service, Office of Inspector General, Report No. SM-AR-18-007, U.S. Postal Service Emergency Suspension Process, September 24, 2018. https://www.uspsoig.gov/sites/default/files/document-library-files/2018/SM-AR-18-007.pdf
 “Rep. Axne Unveils Bill to Boost Public Transparency at the U.S. Postal Service” https://axne.house.gov/media/press-releases/rep-axne-unveils-bill-boost-public-transparency-us-postal-service
 The Residential Service Disruption page is available at https://about.usps.com/newsroom/service-alerts/residential/welcome.htm. The latest service alert spreadsheet is at https://about.usps.com/newsroom/service-alerts/msureport.xls. The report as of May 3, 2022, is at https://tinyurl.com/y65wczsy
 The May 3, 2022, disruption report contains 349 post offices. For approximately 97 of them, the disruption occurred during FY 2021 and included “no retail.” Approximately 18 of these offices appear on the suspension list as suspended during FY2021. (See ACR2021, Responses of the United States Postal Service to Questions 1-21 of Chairman’s Information Request No. 11, February 11, 2022, ChIR 11 Response Attachments, Tab “Suspended During FY21.” Available at https://tinyurl.com/y8rjjrus.) Over 90 offices thus experienced a disruption of retail services but were not classified as suspended.
 At least 25 offices that show as still suspended on the February 11, 2022, suspension list appear as open on the USPS Find Locations page. It’s not clear if this is because the Locator site has not been updated, the suspended office had not been identified correctly, or some other reason.
 The Postal Service takes the position that appeal rights apply to “Post Offices only,” not stations and branches, and the notice of appeal rights is typically not included in the final determination posting. Handbook PO-101 at 22.
 For data on POStPlan levels, workload, and distance to APO, see Docket No. N2012-2, Library Reference USPS-LR-N2012-2/11, Summary Updated.xls, July 19, 2012. https://www.prc.gov/dockets/document/83663. Available at https://tinyurl.com/47pd48xj.
 See USPS Leased Facilities Reports, available at http://about.usps.com/who-we-are/foia/leased-facilities/report.htm. The dashboard uses a 2015 version of these reports, archived at https://tinyurl.com/mr39w784.
 The addresses come from various sources, including a list on PostalPro, at https://postalpro.usps.com/service-hubs-and-facilities/facilityfile (available at https://tinyurl.com/ms2b9syv), the POStPlan Summary Updated list, the USPS Facilities Reports, and Google searches.
 According to Wikipedia, there are approximately 42,000 ZIP Codes and 32,000 ZCTAs. The reason that there is not one ZCTA for every ZIP Code is that only populated areas are included in the Census data, and thus ZIP Codes that only serve PO Boxes have no corresponding ZCTA. https://en.wikipedia.org/wiki/ZIP_Code_Tabulation_Area
 See Docket No. ACR2021, Library Reference USPS-FY21-33, December 29, 2021, folder “USPS.FY21.33.Files,” Excel file “PostOfficesFY2021.xlsx,” tab “Suspension Summary.” https://www.prc.gov/dockets/document/120538. Available at https://tinyurl.com/4ammxhuv.
 See ACR2021, Responses of the United States Postal Service to Questions 1-21 of Chairman’s Information Request No. 11, February 11, 2022, ChIR 11 Response Attachments, “ChIR No. 11 Q 3,” Tab “Suspended End of FY21.” https://www.prc.gov/dockets/document/120910. Available at https://tinyurl.com/y8rjjrus. For details about the discrepancies between the lists of December 29, 2021 and February 11, 2022, see the USPS response to Question 2. https://www.prc.gov/docs/120/120910/ChIR%20No.%2011.Responses.pdf
 The German Village Finance post office, suspended on May 30, 2019, did not appear on the Dec. 29, 2021 list, but it does appear on the Feb. 11, 2022, update.
 The February 11 update shows 425 as still suspended, but two of them — Kenmore, MA and Glendale, KY — have reopened. The Kenmore, MA post office appears on the Feb. 11, 2022 list as suspended at the end of FY2021, but a USPS press release indicates it reopened at a new location on March 2, 2021. https://about.usps.com/newsroom/local-releases/ma/2021/0302-postal-service-is-back-in-kenmore-square.htm. The Glendale, KY office appears on the Feb. 11 list as still suspended, but I’ve been informed by email that it was reopened in FY 2022.
 “Sandia, TX, Post Office Temporarily Suspends Operations,” USPS News, October 9, 2020. https://about.usps.com/newsroom/local-releases/tx/2020/1009-sandia-tx-po-temporarily-suspends-operations.htm
 “Sheepshead Bay Post Office still closed a year after fire,” Brooklynpaper.com, April 19, 2022. https://www.brooklynpaper.com/sheepshead-bay-post-office-still-closed-a-year-after-fire/
 “Tangipahoa and Boutte Post Offices to Resume Operations Monday, March 28,” USPS News, March 25, 2022. https://about.usps.com/newsroom/local-releases/la/2022/0325-tangipahoa-and-boutte-post-offices-to-resume-operations-march-28.htm
 See ACR2021, Responses of the United States Postal Service to Questions 1-21 of Chairman’s Information Request No. 11, February 11, 2022, ChIR 11 Response Attachments, “ChIR No. 11 Q 3,” Tab “Suspended During FY21.” Available at https://tinyurl.com/y8rjjrus.
 For a description of these steps, see Order 6101 at 11 and Attachment at 1.
 See https://about.usps.com/who/profile/history/postmaster-finder.htm. A list of the offices with their established date is available at https://tinyurl.com/44ypbwa6.
 For data on POStPlan levels, workload, and distance to APO, see Library Reference USPS-LR-N2012-2/11, Summary Updated.xls, July 19, 2012. https://www.prc.gov/dockets/document/83663. Available at https://tinyurl.com/2mbe7en2.
 Docket No. A2013-3, Order No. 1852, Climax GA, October 22, 2013. https://www.prc.gov/Docs/88/88074/Order%20No.%201852.pdf
 In comments submitted for the 2010 Public Inquiry on suspensions, the Public Representative recommended that the Commission treat suspensions older than ten months as discontinued and ripe for review and that future suspensions be treated as discontinuances unless there was a demonstrable emergency. See Initial Comments of the Public Representative, Docket No. PI2010-1, March 2, 2010, at 18. https://www.prc.gov/docs/66/66983/PI2010%201%20PR%20Initial.pdf
 The issues associated with gaining access to the Postal Service’s records about suspensions and discontinuances were discussed by the Public Representative in the 2010 Public Inquiry. See Initial Comments of the Public Representative, Docket No. PI2010-1, March 2, 2010, at 12-13.
 The Postal Service is also required, by the Postal Service Reform Act of 2022, to develop and maintain a publicly available dashboard to track service performance. https://www.congress.gov/bill/117th-congress/house-bill/3076
 Docket No. PI2022-2, Order No. 6104, Notice and Order Providing an Opportunity to Comment on the Service Performance Dashboard, February 10, 2022, at 5. https://www.prc.gov/docs/120/120889/Order%20No.%206104.pdf
 Postal Regulatory Commission, Section 701 Report: Analysis of the Postal Accountability and Enhancement Act of 2006, Sept. 22, 2011. https://www.prc.gov/sites/default/files/reports/701_report-092211.pdf
(Photo: Former post office in McLeod, ND, suspended April 10, 2009, over a lease issue. Google Street View)
In the run-up to the election in November 2020, the iconic USPS blue boxes suddenly became controversial. It appeared that the Postal Service was removing a lot of collection boxes just when they would be needed most — to handle all the ballots being sent by mail due to the pandemic. Images of trucks carting away blue boxes went viral. People feared the removals were part of a plan to sabotage the election.
The Postal Service said the removals were just business as usual — the routine culling of underperforming boxes. As the Postal Operations Manual explains, collection boxes are regularly examined for volume, usually once a year over a two-week period. To justify its location, a collection box must average 25 pieces a day. Boxes failing the test may be relocated to a potentially higher volume location or taken out of service. (There’s more background on box removals here.)
On August 18, 2020, under pressure from Congress and several lawsuits, the Postal Service announced that it would not remove any more boxes until after the election.
A few days later, Postmaster General DeJoy testified at hearings in the House and Senate. On August 21, he told the Senate that removing collection boxes was “routine” and a “normal process that has been around for 50 years.” Due to all the “excitement,” however, he promised to postpone further removals.
During these hearings, the Postmaster General did not reveal that just a few weeks earlier, in late June and early July, he and his leadership team had held meetings about a plan to save billions of dollars by cutting 64 million workhours through a variety of initiatives, such as eliminating overtime and reducing hours at post offices. Details about this “Do It Now” plan, including slide presentations given at the meetings, were made public as evidence submitted in lawsuits against the Postal Service, including Pennsylvania v DeJoy and New York v Trump. (Three of the presentations can be found at the end of this post.)
A presentation at a meeting at postal headquarters on June 26, 2020, shows that the workhour reduction plan called for removing 30,000 “low volume and multiple pickup boxes” — 7,405 per fiscal quarter. The Postal Service projected that this “Collection Box Optimization” plan would allow it to cut carrier time by 7.5 minutes per day per box for a total savings of $18 million in FY 2021. (The slide doesn’t show the projected savings for FY 2022, after all 30,000 boxes were removed, but the annual savings would be $48 million, about $1,600 per box.)
According to an OIG report about the workhour reduction plan, “From FY 2015 through August 31, 2020, the Postal Service removed 15,779 collection boxes” — an average of about 2,630 removals a year. At that rate, removing 30,000 boxes — over 20 percent of the country’s 140,000 boxes — would take nearly twelve years. Had the optimization plan been implemented, this would have happened in just twelve months.
It’s possible that the removals that caused so much alarm in August 2020 were anything but “routine” and in fact represented the beginning of the large-scale “optimization” plan.
The FOIA request
On August 20, 2020, amidst the furor over box removals, Robert Bracco, an individual using the muckrock.com FOIA request website, filed a request asking the Postal Service to provide data “pertaining to the existence, addition, removal, or relocation of USPS collection boxes inside the United States and territories created or altered after 8/15/2019.”
On March 25, 2022 — nineteen months after the request was filed, and after seventeen follow-up messages inquiring on the status of the request — the Postal Service finally responded. It provided three lists of collection box locations in service in December 2019, 2020 and 2021. The lists make it possible to track additions and removals over this two-year period.
The totals derived from the FOIA lists are similar to those reported by the Postal Service to the Postal Regulatory Commission as part of its annual compliance review, which also came out last week. The numbers from the two sources differ slightly because the Postal Service uses the fiscal year calendar, which begins October 1, while the FOIA lists are essentially for the calendar years.
According to the PRC report, there were 1,455 boxes fewer boxes at the end of FY 2020 and 783 fewer at the end of FY 2021. According to the FOIA lists, there were 1,179 fewer boxes at the end CY 2020 and 947 fewer at the end of CY 2021. Either way, the reports show that during 2020 and 2021 the Postal Service ended up removing far fewer boxes than it had culled in previous years.
The Postal Service hasn’t commented on the existence of the plan to remove 30,000 boxes. As postal officials told the OIG, “the collection box removals made in 2020 were part of a long-standing process and handled no differently than in previous years.”
The Postal Service also hasn’t explained why it slowed the pace of removals in 2021. Perhaps postal leaders decided that generating more controversy over collection boxes just wasn’t worth the cost-savings, especially at a time when postal reform legislation was in the works and the Postmaster General continued to be under fire, for one reason or another.
What the lists show
The lists provided to Muckrock show all the collection boxes in service at three points in time: December 20, 2019; December 4, 2020, and December 10, 2021.
In many instances the lists show duplicate addresses. That’s because at many locations, like outside a busy post office, there may be two, three, even four boxes. Out of the 140,000 or so boxes nationwide, about 14,000 are at these multiple-box locations. (I haven’t done a count, but it looks like about 9.000 locations have two boxes and 2,000 have three or four.) Most of the removals occurred at locations where there was only the one box, but some took place where there were multiple boxes, leaving at least one box at that location.
The FOIA lists also show that that the Postal Service added hundreds of locations each year (relocating boxes that were underperforming elsewhere), so it’s important to distinguish between removals and net decreases.
It may be worth noting in this regard that the Postal Service is supposed to report to the PRC not only the number of boxes in service at the beginning and end of the fiscal year but also the number of boxes added and removed (39 C.F.R. § 3055.91(c)). The Postal Service has been reporting only the start and end numbers for each year, not the added and removed numbers, but for some reason the Commission has not asked for these other numbers, nor has it asked for the kind of detailed lists that Mr. Bracco requested. (See ACD Report, p. 212-214.)
In any case, the FOIA lists enable one to determine not only the total numbers for boxes added and removed but also the exact locations where the changes took place.
Counts, Lists & Maps
Here’s a chart summarizing the numbers derived from the FOIA lists.
Collection Boxes in 2020 and 2021
Boxes in service on 12/20/2019
Added during CY 2020
Removed during CY 2020 from locations with 1 box
Removed during CY 2020 from locations with multiple boxes
Net change 12/20/2019 to 12/4/2020
Boxes in service on 12/4/2020
Added during CY 2021
Removed during CY 2021 from locations with 1 box
Removed during CY 2021 from locations with multiple boxes
Net change 12/4/2020 to 12/10/2021
Boxes in service on 12/10/2021
Total added in CY 2020 and CY 2021
Total removed from locations with 1 box
Total removed from locations with multiple boxes
Total removed in CY 2020 and CY 2021
Total net change from 12/20/2019 to 12/10/2021
Over this two-year period, the net decrease in boxes was about 2,120, but in fact more than 3,250 were removed — 2,500 of them at locations where no box remained.
A spreadsheet showing the three FOIA lists, along with the lists of additions and removals derived from those lists, is here. You can download the original FOIA lists here. A list of the 2,500 locations where the box was removed leaving no box in place is here (you can sort and filter by state, zip, etc.).
Here’s a map showing the locations where 2,500 boxes were removed with no box remaining, with the markers in blue indicating those removed during 2020 and green for those removed in 2021. (If you click on a marker and then click on the “right-turn” sign next to the address, it will go to a map of the location; if you zoom in, go to street views and look around, you might find the box before it was removed — unless it was removed before the street view image was taken.)
Here’s a map showing the locations where 1,129 boxes were added, with the markers in yellow indicating those added during 2020 and purple for those added in 2021.
By the way, if you’re looking for a collection box near you, the USPS Locator website will direct you to boxes in service, along with their collection times, for any zip code or address. Just limit your “collection type” to “Collection Boxes.”
(Photo: USPS collection boxes, apparently removed form the streets of New York, CNN)
The spring 2022 newsletter from Community and Postal Workers United (CPWU) has articles about opposition to the Postal Service’s deal to purchase up to 148,000 mail delivery trucks from Oshkosh Defense, 90% of them powered by gasoline fueled combustion engines; the postal workers’ protest in Denver when PMG DeJoy visited; and President Biden’s recent nominations to the USPS Board of Governors. Read the newsletter here.
When the Postal Service considers closing a post office, it must go through a lengthy discontinuance process, with 30 steps of administrative review and opportunities for public input. But when there’s an emergency, like unsafe building conditions after a weather event, the Postal Service can close a post office on a moment’s notice. Even when there’s not an obvious emergency, like an issue over renewing the lease, the Postal Service may invoke a suspension to close the post office.
Whatever the cause, after an emergency suspension takes place, the Postal Service is required to follow up by correcting the problem — having the building repaired, moving to a new location, etc. — or by proceeding to a discontinuance process to study closing the office permanently. But the law does not require the Postal Service to complete this process within a definite time frame. As a result, some post offices end up in the limbo of suspension for many years, and a large backlog of unresolved suspensions develops.
In the late 1990s, the backlog grew to over 500 suspensions, and the issue became the subject of a Congressional hearing. But the problem persisted. As of fiscal year 2012, there were about 200 offices under suspension, many of them going back several years.
In 2012 the Postal Service implemented POStPlan, which reduced hours at 11,000 post offices as an alternative to closing them. But post offices continued to close by emergency suspension. Over the next four years, the number of suspended offices in the backlog increased from 211 to 662.
The Postal Regulatory Commission treats these suspensions as a “customer access” issue in its annual compliance reviews, and it has repeatedly encouraged the Postal Service to resolve the cases, one way or another. Over the past five years, the Postal Service has managed to close the books on 450 of the suspensions. Nearly all of them ended with a final determination to discontinue the post office permanently.
At the same that it was resolving older suspensions, however, the Postal Service was adding new ones to the list. At the end of fiscal year 2021, there were about 450 suspended offices — 206 from FY 2016 or before and about 240 occurring since FY 2016.
Last month the PRC opened a Public Inquiry docket to examine how the the resolution of these suspensions might be expedited, with particular emphasis on the older cases. The inquiry is not about individual post office suspensions or closings. Rather, it will examine “issues impeding the Postal Service’s progress in resolving the suspended post offices in a timely manner” and consider “procedures or courses of action for how the Postal Service may expeditiously resolve suspended post offices.”
The Commission has indicated that it’s also interested in “data analysis related to the suspended post offices, including, but not limited to, the spatial analysis of the suspended post offices.” The inquiry will also consider what might be done to prevent backlogs from developing in the future.
In its quarterly and annual updates on the suspensions, the Postal Service provides the Commission with lists of the suspended offices. The updates contain information about when and why the offices were suspended and, at least in the case of the older suspensions, their current status in the discontinuance process. The lists are helpful, but they don’t provide much information — not even the address of the post office.
To provide a clearer picture of the suspensions and to lend some transparency to the process of resolving them as it unfolds, we’ve created a Suspension Dashboard. It includes a page for each of the 450 suspended offices, with information about its suspension status, community demographics and facility data. The dashboard also provides the address for the suspended office and, when possible, a street view of the building.
The dashboard should make it easier to review the hundreds of suspensions in the current backlog. It may also be useful in developing the kind of analysis that the Commission has invited. A few initial observations, for example:
- About 90 suspensions took place between fiscals years 1984 and 2012, 123 during 2012-2016, 96 during 2017-2020, and 129 during 2021.
- About 285 of the post offices were part of POStPlan, 255 of them open 2 or 4 hours a day. The average distance to the nearest post office (often another POStPlan office open just a few hours) was about 7 miles, and the distance to the administrative post office (open 8 hours a day) was about 12 miles.
- More than 200 of the suspensions were due to lease-related issues; 134 due to safety and health concerns; 36 due to building damage, and 23 due to a natural disaster.
- Of the 366 suspensions for which zip-code census data was readily available, 250 occurred in rural communities, with a total population of about 160,000. The total population for all of these zip codes was 2.7 million.
The information on the dashboard is based primarily on USPS filings with the PRC, but it’s been cobbled together from various lists, census data, Wikipedia and whatever one can find Googling around. Many of the suspensions happened so long ago it’s difficult to learn much about them. The dashboard is therefore incomplete and it has many inaccuracies and missing data points. If you see mistakes, have more information, or want to share a photo, please use the contact form here.
To learn more:
“U.S. Postal Service Emergency Suspension Process,” USPS OIG, Sept. 24, 2018
“Post Office discontinuances and suspensions: A decade in review,” Save the Post Office, Feb. 26, 2018
An archive of posts about suspensions on Save the Post Office is here.
The Winter 2022 newsletter from Communities and Postal Workers United has articles about the effort to “Dump DeJoy,” letter carriers resisting delivery after dark, and a new type of post office being piloted in Canada. Read the newsletter here.
BY STEVE HUTKINS
Last week the Postal Service published its service performance reports for the first quarter of fiscal year 2022 (Oct-Dec 2021). This is our first opportunity to see any details about how on-time delivery has been going since Oct. 1, 2021, when the USPS introduced lower service standards for First Class mail and began a historic shift from using planes to trucks for transporting mail long distances.
The on-time scores are much improved over the first quarter of last year — one of the worst in modern postal history — but they are well below the targets promised by the Postal Service last summer when the changes in standards were reviewed by the Postal Regulatory Commission for an Advisory Opinion.
Under a provision in the postal reform bill that just passed the House and that’s now heading to the Senate, we may not have to wait for quarterly on-time data in the future. Section 201 of the bill requires the Postal Service to maintain a website dashboard with data on a weekly rather than quarterly basis. (The USPS already has a dashboard with quarterly data, as does the USPS OIG; the PRC is inviting comments about its beta dashboard. There’s been a dashboard with weekly reports on the STPO website for nearly a year.)
A new dashboard like this will make USPS on-time delivery data more transparent and accessible, so mailers and the public will have a better idea of how the Postal Service is performing. Unfortunately, whatever good the dashboard may provide in the way of transparency will be undermined by what the postal reform bill does with regard to delivery speed itself. Another section of the bill essentially ratifies the slowdown that DeJoy implemented in October as part of his 10-year plan.
Revising the transportation clause of “Postal Policy”
Title 39, which created the Postal Service in 1970, begins with a section entitled “Postal Policy” — 39 U.S. Code § 101. It’s only 400 words or so, but it’s like the Preamble to the Constitution, and it’s probably the most frequently quoted passage in the history of postal legislation:
The United States Postal Service shall be operated as a basic and fundamental service provided to the people by the Government of the United States, authorized by the Constitution, created by Act of Congress, and supported by the people. The Postal Service shall have as its basic function the obligation to provide postal services to bind the Nation together through the personal, educational, literary, and business correspondence of the people.
Section 101 proceeds to say (in part f) that when selecting modes of transportation, the Postal Service “shall give the highest consideration to the prompt and economical delivery of all mail.” That means using planes when appropriate.
Since 1970, the Postal Policy section has been revised only once — in 2008, a minor modification was made regarding how the Postal Service made contracts with airlines. Section 208 of the reform bill will change the language of the transportation passage in Section 101 in a much more significant way. The revised version would read as follows, with the new phrases in italics:
In selecting modes of transportation, the Postal Service shall give highest consideration to the prompt, economical, consistent, and reliable delivery of all mail in a manner that increases operational efficiency and reduces complexity. Modern methods of transporting mail by containerization and programs designed to achieve cost-effective overnight transportation to the destination of important letter mail to all parts of the Nation shall also be a primary goal of postal operations.
As discussed in this previous post, these phrases — “consistent,” “reliable,” “operational efficiency” and “cost effective” — were all key words repeatedly invoked by the Postal Service in its testimonies for the Advisory Opinion on changing service standards. And that phrase “reduces complexity” refers specifically to the Postal Service’s argument that “surface transportation is generally less operationally complex than air transportation: the former requires fewer ‘touches'” (Advisory Opinion, p. 67).
It’s interesting to note that a report by the Congressional Research Service offers a different interpretation of Section 208. CRS suggests that it refers to the acquisition of the next-gen delivery fleet, which will be more economical and reliable than the current fleet of aging trucks.
But that interpretation doesn’t hold up. The report about the legislation from the House Oversight Committee explains that Section 208 “would make minor adjustments to the considerations the Postal Service must make when deciding which modes of transportation should be used to deliver mail. Specifically, the section would add the requirement that transportation not only be prompt and economical but also consistent and reliable.” In other words, the issue is not old trucks versus new but the mode of transportation — ground or air.
Section 101 of Title 39, and particularly the transportation passage, came up frequently during the PRC’s Advisory Opinion process. Intervenors in the docket, including the APWU and postal advocate Douglas Carlson, argued that slowing the mail by shifting to trucks constituted a violation of Section 101. The Postal Service disagreed. The Commission found merit and flaws in both sides of the argument and did not come to a clear conclusion on the matter.
The issue may become moot. Section 208 of the reform bill will make it much easier for the Postal Service to justify using trucks instead of planes. Having bent the law when it slowed down the mail, the Postal Service will be able to say that the new law has codified its new transportation policy.
Making the mail more “reliable”
When the Postal Service presented the PRC with its plan for relaxing service standards for First Class mail and shifting to ground transportation, it gave two justifications. One was that using trucks would save money, about $170 million a year (after factoring in over $100 million in lost revenue caused by slower delivery times).
After reviewing the plan in detail, the Commission said it was “not able to confirm the cost benefits in future years of implementation,” and the projected cost savings weren’t very significant anyway — just “3.4 percent of total transportation costs for FY 2020 and less than a quarter of one percent of the total FY 2020 operating expenses of $82 billion” (Advisory Opinion, p. 109).
The PRC may review the actual cost savings when it does its annual compliance review in January 2023. The USPS Inspector General may do an audit before then. It’s possible a full accounting may never take place.
The second justification for slowing First Class mail was that lower service standards and the more predictable behavior of ground transportation would make it possible for the Postal Service to make delivery more “reliable.” The metric for reliability was on-time service performance — the percent of mail volume that meets the service standards.
In recent years the Postal Service has achieved about 92 percent on-time for First Class mail, with the exception of single-piece mail traveling long distances, which typically scores around 80 percent. DeJoy’s plan was going to fix all that. The Postal Service said it would achieve or surpass on-time scores of 95 percent in all categories of First Class. Mail delivery would be more “reliable.”
In his testimony and cross-examination of USPS witnesses, Mr. Carlson examined how the speed of delivery was impacted by various factors (the “root causes” for delays), not just the mode of transportation. He argued that shifting to trucks would not improve performance to the extent the Postal Service claimed. The Commission did its own analysis and came to the same conclusion: The Postal Service “should consider a 95 percent on-time target as aspirational, due to the highly dynamic factors involved in the postal mail network” (Advisory Opinion, p. 5).
For the rest of this year, the 95 percent target will not even be “aspirational.” In its FY 2021 Annual Report to Congress, the Postal Service states that its target for First Class composite is 91 percent. It now says that it will meet or exceed 95 percent “once all elements of the plan are implemented.”
The Postal Service did not mention any such caveats during the Advisory Opinion process. Vice President Robert Cintron testified to the PRC that “we expect to set service performance targets at 95 percent once the new service standards are in place, and we expect to meet or exceed them consistently upon implementation of our proposed service standard changes during all times of the year.” It’s not clear what elements of the 10-year plan have yet to be implemented before the USPS will be able to reach 95 percent.
(Update: In a footnote to a filing today with the PRC, submitted after this post was published, the Postal Service says it never said that changes in service standards would alone be enough to reach 95 percent. As evidence it points to a Federal Register notice on August 11, 2021, in which it denies ever claiming that it would reach this target “instantaneously with the service standard change.” But this Notice came out three weeks after the Advisory Opinion was completed. The Postal Service also explains what else it will need to do to reach 95 percent: “For example, the Postal Service will aim to meet operating plans, will seek better utilization rates for its surface transportation network, will aggregate and consolidate loads at origin locations, will pair certain dispatches with package volumes, and will more optimally route and transfer via hubs and surface transportation centers.” The Postal Service did not offer this explanation during the Advisory Opinion process.)
Service Performance for Q1 FY2022
The service performance reports published last week provide district-by-district data for each of the categories of First Class mail — single-piece and presort, with delivery standards of 1, 2, 3, 4 and 5 days. Note that before the changes in standards, the categories were 1, 2 and 3-5 days (with 99 percent of 3-5 day mail being 3-day), so the reports have a composite figure to make comparisons with the past possible. Here’s a summary of the scores on the national level. (The single-piece report is here; the presort is here.)
|Single-Piece First Class|
|FY 2022 Original Target||N/A||95.0||95.0||95.0||95.0||95.0|
|FY 2022 Revised Target||N/A||90.3||90.0||90.0||90.0||90.00|
|Q1 FY2021 (SPLY)||N/A||81.5||N/A||N/A||N/A||54.6|
|FY 2021 Annual||N/A||86.4||N/A||N/A||N/A||63.2|
|FY 2020 Annual||N/A||91.5||N/A||N/A||N/A||78.8|
|FY 2019 Annual||N/A||92.0||N/A||N/A||N/A||80.9|
|Presort First Class|
|FY 2022 Original Target||95.0||95.0||95.0||95.0||95.0||95.0|
|FY 2022 Revised Target||94.75||93.0||90.5||90.5||90.5||90.50|
|Q1 FY2021 (SPLY)||91.3||84.7||N/A||N/A||N/A||78.0|
|FY 2021 Annual||93.4||88.3||N/A||N/A||N/A||80.9|
|FY 2020 Annual||94.7||92.8||N/A||N/A||N/A||89.9|
|FY 2019 Annual||95.5||94.1||N/A||N/A||N/A||92.0|
Overall, the Postal Service is doing just about the same as during the pre-pandemic years — which is not saying much given that 40 percent of First Class mail has been slowed down by 1 or 2 days. In any case, the Postal Service is clearly failing to reach its original goal of 95 percent — the metric of “reliability” used to justify slowing the mail.
The new service performance reports also contain on-time scores for each USPS district. During the first quarter under the new standards, the composite on-time score (presort and single-piece for all service standards combined) dropped in two-thirds of the 67 districts compared to the same quarter in FY 2020. In some districts, the scores fell by 10 percent. (See the table at the end of this post.)
For more context, here’s a graph showing service performance for First Class mail composite (pre-sort and single-piece for all service standards). The scores since May 2021 were submitted as an exhibit in Pennsylvania v Louis DeJoy. Earlier scores were submitted in Vote Forward v. DeJoy.
On-time performance began calendar year 2020 at around 92 percent (the norm for years previous). Scores dropped when DeJoy made operational changes in the summer of 2020, recovered somewhat, then plummeted in November and rose again in April 2021. During the fall of 2021 scores hovered around 91 percent, but they’ve fallen off the past few weeks. During the week ending Feb. 4, 2022, the composite score was 84.6 percent. In the 87 weeks since DeJoy became Postmaster General, scores have achieved 92 percent in only three weeks.
Geographic disparities in delivery times
Another metric for looking at service performance is average days to delivery — a number derived by factoring in mail volumes and variance data (the percent of mail delivered 1, 2 or 3 days after the service standard).
Before the service standards were changed, the average days to delivery for First Class mail was about 2.55 days; under the new standards, that was expected to rise to 3 days, an increase of about 19 percent — a key number in the Postal Service’s calculations for how much business it would drive away by slowing the mail.
The increase in average delivery times was expected to vary considerably place to place, as explained by a witness for the APWU and by me during the Advisory Opinion process (and by the Washington Post as well). Generally speaking, as I explained in my testimony and brief, when the Postal Service shifts to ground transportation, the western part of the country experiences a larger increase in delivery times than the rest of the country because distances are longer and dependence on planes is greater. So some areas of the country are seeing increases of only 11 or 12 percent while others are seeing increases of over 30 percent. (See the table on the district data at the end of this post.)
In my brief I argued that these geographic disparities were a form of discrimination against some users of the mail in violation of 39 U.S.C. § 403(c). The Commission concluded that the geographic disparities caused by the new service standards would not violate this anti-discrimination provision because the proposed changes were “reasonable” — they would save money and make the mail more “reliable.” At the same time, the Commission observed that if the Postal Service were proven wrong in its predictions, “the rational basis for the proposal may prove illusory” (Advisory Opinion, p. 179).
Based on the service performance reports for the first quarter of FY2022, First Class mail is not becoming more reliable, and the rational basis for the changes in service standards is looking rather illusory.
It’s too soon to say if these scores are the new normal under the new standards, but the fact is that 40 percent of First Class mail is now taking one or two more days to deliver. Slower mail is now simply a fact of life. If Congress passes a postal reform bill with Section 208, it will codify DeJoy’s shift to using trucks instead of planes, and slower mail will become a matter of law as well.
Service Performance on the District Level
The following table summarizes the data in the service performance reports for Q1 FY2022 compared with Q1 FY2020 (i.e., Oct.-Dec., 2019, which was a “normal” quarter in that it was before the pandemic began). These reports can be found on the PRC website here; for easier access, they’re posted on Google Docs here. The on-time scores and average days for delivery are volume-weighted composites of all categories of First Class mail — presort and single piece, with service standards of one-to-five days. Note that these numbers are my calculations based on the USPS data; they do not appear in any USPS reporting.
The columns can be sorted by clicking on the arrows in the headers. To return to the original format, with districts categorized by area, refresh your browser. To find the USPS district for a particular zip code, a list can be found here. A map of the districts can be found here. Service standards maps are on Postal Pro and on the Washington Post.
|District||Area||Service Perf Q1 FY2020||Service Perf Q1 FY2022||Service Perf Percent Change||Average Days to Delivery Q1 FY 2020||Average Days to Delivery Q1 FY 2022||Average Days to Delivery Percent Change|
|Greater South Carolina||Capital Metro||92.62%||84.01%||-9.30%||2.51||3.05||21.13%|
|Northern Virginia||Capital Metro||89.27%||85.48%||-4.25%||2.7||3.2||18.34%|
|Western New York||Eastern||93.69%||90.80%||-3.09%||2.47||2.82||13.98%|
|GREAT LAKES AREA||AREA||90.52%||87.47%||-3.37%||2.6||3.01||15.63%|
|Central Illinois||Great Lakes||90.22%||87.50%||-3.01%||2.71||3.02||11.20%|
|Greater Indiana||Great Lakes||91.73%||90.01%||-1.87%||2.59||2.96||14.62%|
|Greater Michigan||Great Lakes||91.53%||89.88%||-1.81%||2.44||2.84||16.09%|
|Northern New England||Northeast||90.50%||87.94%||-2.82%||2.5||3.02||20.42%|
|Northern New Jersey||Northeast||91.50%||90.14%||-1.49%||2.58||3.27||27.10%|
|Salt Lake City||Western||92.01%||92.09%||0.09%||2.78||3.5||25.80%|
Here’s a map of the USPS locations that are serving as Fulfillment Centers for packing, labeling, and sorting the free Covid tests being sent out by the federal government. The list of sites comes from a Memorandum of Understanding between the USPS and National Postal Mail Handlers Union.
A provocative new feature length documentary, “The Great Postal Heist”, releasing January 25, 2022 (on DVD and streaming), takes the ultimate deep dive into the United States Postal Service, its controversies, and the political corruption that surrounds it.
Featuring interviews with Ralph Nader, Richard Wolff, former Rep. Blake Farenthold (R-Texas), Rep. Stephen Lynch (D-Massachusetts), and additional historians, legislators, and several rankings of USPS workers, “The Great Postal Heist” is the explanation of USPS that the American people deserve.
For the past two years, USPS has found itself in the middle of the nation’s biggest disagreements, from mail-in election ballots to the question of privatization in the face of giants like Amazon & FedEx taking control of our mailboxes.
Filmmaker and son of a postal clerk, Jay Galione, has collected the most extensive video history of USPS’ staff blowing the whistle on a toxic workplace culture, the corruption of upper level management and senior office holders, and how Congress’ control of USPS and The Postal Accountability and Enhancement Act (PAEA) of 2006 has largely sabotaged any chance USPS had of showing its profitability.
A from-then-till-now chronological deep dive, the documentary covers the history of the “going postal” tragedies of the 1980s, through to the role of President Bush’s 2006 PAEA, and the concerning conflicts of interest around USPS property ownership and Senator Diane Feinstein’s husband.
Evan Kalish has photographed more than 10,000 post offices all across America. Back for its sixth year, the 2022 “Postlandia Calendar of Post Offices and Places” celebrates a dozen new photogenic and historic post offices from around the United States. This year’s selections include one-of-a-kind post offices in California, New England, Appalachia, the Pacific Northwest, and more. More info here. Order the calendar here.
On her show on Nov. 19, Rachel Maddow focused on President Biden’s changes to the USPS Board of Governors “that apparently are finally going to clear the way to getting rid of that guy,” Postmaster General Louis DeJoy. She also talked with Illinois Congressman Raja Krishnamoorthi about his hope that the new Board will relieve DeJoy of his duties. Full transcript here.
First Class: The U.S. Postal Service, Democracy, and the Corporate Threat, the new book by historian Christopher Shaw, is hot off the presses. Shaw’s examination of the essential role of the Post Office in American society should have a profound impact on shaping the postal narrative and the direction of national policy.
On December 9, Shaw will be discussing the book in a virtual event hosted by City Lights on Zoom. Register here.
From the Foreword by Ralph Nader
“The preventable plight of our U.S. Postal Service is an important issue for all Americans. When President Donald J. Trump’s donor and henchman Louis DeJoy became postmaster general in 2020 and proceeded to dismantle the agency, millions of citizens participated in demonstrations that revealed a deep civic commitment to preserving the people’s post office. While DeJoy triggered a crisis that immediately threatened the presidential election process, attacks on the Postal Service have been an ongoing problem for decades. The anti-postal campaigns of corporate interests have remained a continuing source of frustration to those of us who have observed the Postal Service’s decline due to unimaginative management, a deck stacked to favor profit-driven entities such as FedEx and UPS, and unfair financial obligations imposed by Congress.”
The fight over the future of the U.S. Postal Service is on. For years, corporate interests and political ideologues have pushed to remake the USPS, turning it from a public institution into a private business—and now, with mail-in voting playing a key role in local, state, and federal elections, the attacks have escalated. Leadership at the USPS has been handed over to special interests whose plan for the future includes higher postage costs, slower delivery times, and fewer post offices, policies that will inevitably weaken this invaluable public service and source of employment.
Despite the general shift to digital communication, the vast majority of the American people—and small businesses—still rely heavily on the U.S. postal system, and many are rallying to defend it. First Class brings readers to the front lines of the struggle, explaining the various forces at work for and against a strong postal system, and presenting reasonable ideas for strengthening and expanding its capacity, services, and workforce. Emphasizing the essential role the USPS has played ever since Benjamin Franklin served as our first Postmaster General, author Christopher Shaw warns of the consequences for the country—and for our democracy—if we don’t win this fight.
Praise for First Class
“The Postal Service is the crown jewel of the American experiment, our most efficient, trusted and beloved public service. With First Class: The U.S. Postal Service, Democracy, and the Corporate Threat, Christopher Shaw makes a brilliant case for polishing the USPS up and letting it shine in the 21st century.”—John Nichols, national affairs correspondent for The Nation and author of Coronavirus Criminals and Pandemic Profiteers: Accountability for Those Who Caused the Crisis
“Democracy in action … government that literally delivers … a service that puts the ‘united’ in the United States. These aren’t throw-away cliches—they’re the essence of our U.S. Postal Service. ‘So we must kill it!’ That’s the perverse intent of a handful of corporate profiteers and their corrupt congressional enablers. How do we stop them and expand the beneficial work of this extraordinary public service? Christopher Shaw shows us the way. Read on … and act!”—Jim Hightower, syndicated columnist and radio commentator
“The ‘Save the Post Office’ movement has long needed a definitive manifesto, and now it has one. Christopher Shaw’s First Class shows how special interests and anti-government, anti-union ideologues have promoted a scarcity myth—the country can’t afford a first-class postal system—to justify cost-cutting measures like outsourcing, closing post offices and slowing down the mail. Piece by piece, an essential national infrastructure is being dismantled without our consent. Shaw makes an eloquent case for why the post office is worth saving and why, for the sake of American democracy, it must be saved.”—Steve Hutkins, founder/editor of Save the Post Office and Professor of English (retired) at New York University
“In gripping detail, Christopher W. Shaw’s First Class tells you who’s trying to sabotage the national treasure that is the U.S. Postal Service and why (hint: corporate greed). Shaw’s clarion call to protect the postal service explains what’s at stake for our communities, our democracy, and our economy. While he celebrates USPS history, Shaw’s gaze is primarily forward-looking. In a time of community fracture and corporate predation, he argues, a first-class post office of the future can bring communities together and offer exploitation-free banking and other services.”—Robert Weissman, president of Public Citizen
“Shaw’s excellent analysis of the Postal Service and its vital role in American Democracy couldn’t be more timely. As the current postmaster general is about to implement a ten-year plan that will eliminate all airmail service, greatly reduce delivery times, and cut hours and available services at post offices, it is important to be reminded that a fully functional postal service is essential for elections, for delivery of life-saving medicines, for assistance when communities are dislocated in times of disaster and for rural community identity First Class should serve as a clarion call for Americans to halt the dismantling and to, instead, preserve and enhance the institution that can bind the nation together.”—Ruth Y. Goldway, Retired Chair and Commissioner, U.S. Postal Regulatory Commission, responsible for the Forever Stamp
“The United States Postal Service has been targeted for privatization (read: dismantlement) by conservative Republicans for decades. In his new book, Shaw convincingly explains why this would have tragic consequences for the future of democracy itself. … Shaw’s prose is fresh and accessible, and his arguments are cogent and convincing. Reading this book will give readers a new appreciation for the value of the humble post office.”—Booklist
“Christopher Shaw makes the case for the importance of the Postal Service to democracy in the United States. He argues compellingly that we should be looking to rebuild it, rather than tear it down and privatize it.”—Dean Baker, co-founder of the Center for Economic and Policy Research and author of Rigged
“Christopher W. Shaw’s First Class: The U.S. Postal Service, Democracy, and the Corporate Threat makes a passionate but well-argued case for a healthy USPS. Shaw organizes his methodical argument around decades of attacks on the USPS; in doing so, he effectively refutes the flawed (and often anti-democratic) cases for privatization and deregulation. The USPS is essential for a democratic American society; thank goodness we have this new book from Christopher W. Shaw explaining why.”—Danny Caine, author of Save the USPS and owner of the Raven Book Store, Lawrence, KS
“Christopher Shaw reveals the U.S. Postal Service’s historic contributions to the welfare of all Americans, from operating an essential communication and transportation network, to pioneering public banking, to functioning as a linchpin of elections. While the Postal Service’s enemies assert its inevitable demise, Shaw presents hope for a rejuvenated public service that plays an integral part of a democratic future.”—RoseAnn DeMoro, former Executive Director of National Nurses United
About the Author
Christopher W. Shaw is an author, historian, and policy analyst. He has a Ph.D. in History from the University of California, Berkeley, and is the author of Money, Power, and the People: The American Struggle to Make Banking Democratic (University of Chicago Press, 2019) and Preserving the People’s Post Office (Essential Books, 2006). His research on the history of banking, money, labor, agriculture, social movements, and the postal system has been published in the following academic journals: Journal of Policy History, Journal of Social History, Agricultural History, Enterprise & Society, Kansas History, and Journalism History. Shaw was formerly a project director at the Center for Study of Responsive Law. He has worked on a number of policy issues, including the privatization of government services, health and safety regulations, and electoral reform. He has appeared in such media outlets as the Associated Press, National Public Radio, Washington Post, Christian Science Monitor, New York Post,Village Voice, Philadelphia Inquirer, and Buffalo News, among others. He lives in Berkeley, CA.
Named by The Atlantic as one of the hundred most influential figures in American history, and by Time and Life magazines as one of the most influential Americans of the twentieth century, Ralph Nader has helped us drive safer cars, eat healthier food, breathe better air, drink cleaner water, and work in safer environments for more than four decades. Nader was instrumental in the creation of the Occupational Safety and Health Administration (OSHA), the Environmental Protection Agency (EPA), the Consumer Product Safety Commission (CSPC), and the National Highway Transportation Safety Administration (NHTSA). Many lives have been saved by Nader’s involvement in the recall of millions of unsafe consumer products, including defective motor vehicles, and in the protection of laborers and the environment. By starting dozens of citizen groups, Ralph Nader has created an atmosphere of corporate and governmental accountability. Nader’s recent books include Breaking Through Power with City Lights, Unstoppable, and The Good Fight. His Animal Envy, A Parable was published by Seven Stories Press in the fall of 2016. Nader writes a syndicated column, has his own radio show, and gives lectures and interviews year round.
The Fall 2021 newsletter from Communities and Postal Workers United has articles calling on the 21 Attorneys General who oppose slowing down the mail to file for an injunction; the APWU rally to “Dump DeJoy, Bounce Bloom” on Sept. 23; Chicago letter carriers stand against late start times and delivery in the dark; and an event in Seattle on Oct. 1 to protest the nationwide planned slowdown of First-class mail. Read the newsletter here.
BY TIM BOND
As part of its Delivering for America plan, the Postal Service has promised to “procure and deploy more than 185 new package sorters.” This statement has remained somewhat vague in the messaging materials, but the Postal Service recently invited the media to the Seattle Processing & Distribution Center for a first-hand look at one of the new sorting machines in operation.
The Seattle P&DC lies in South Seattle and is a major sorting facility in the northwest U.S. Comprising almost a million square feet, the facility sorts all mail destined for zip codes 98001-98297. It is also the sort facility for most mail originating in the area (a nearby annex sited closer to the airport handles outgoing Priority Mail).
The new package sorter at the Seattle P&DC, which is currently set up to sort only outgoing packages, is capable of sorting packages to 100 different destinations. The operation can handle packages up to approximately 24 by 18 by 12 inches in size. Larger packages are sorted elsewhere in the facility.
Employees unload packages on to a conveyor, ensuring the barcode is face up for the scanner. The packages then pass through a scanner that can read the barcode in any orientation. From there, packages travel down the conveyor belt and are automatically dropped into the appropriate bin or sack for the destination sort facility. Read More