Posts - Save the Post Office

DeJoy rebuffs USPS regulator considering more ‘proactive’ role in postal oversight

Steve HutkinsMay 27, 2023News

USPS is falling short of some of its financial goals, as part of a broader vision for the agency to “break even” by 2030, as outlined in its 10-year Delivering for America Plan.

But DeJoy, speaking Monday at the National Postal Forum in Charlotte, North Carolina, said USPS has cut projected losses for the decade by more than half, and is no longer the “haphazard, bureaucratic organization” he saw on his first few days on the job.

“The Delivering for America Plan is not a plan for the unachievable. It is a plan for dramatic change in how we perform our service, that if executed in time and with care, will lead to long-term success for the organization,” DeJoy said.

DeJoy said USPS, to keep its reform goals within reach, must implement dramatic changes to correct for years of inaction on postal issues from its regulator, the Postal Regulatory Commission, and Congress.

He said this inaction has “made it difficult, if not impossible, for our employees to serve effectively.”

“We must implement dramatic change, because the time for more subtle or incremental change has long ago passed, necessitating the transformational changes we need today,” DeJoy said.

“These dramatic changes must be done at a pace, and with a tenacity that is rarely seen, and rarely necessary, in government or private industry,” he added.

Postal Service provides an implementation update on the S&DC plan

Steve HutkinsMay 25, 2023Blog, Featured

A couple of weeks ago, the Postal Service shared a presentation with the management associations and unions showing the implementation status of the Sorting & Delivery Center plan as of May 4, 2023.

According to the presentation, 18 S&DCs will be launched in June and September of this year. With the half dozen S&DCs that have already been established, there will be 24 S&DCs by the end of fiscal year 2023.

The presentation shows 22 post offices will lose their carriers to S&DCs in June, and 29 more in September. Another eight will give up their carriers in February 2024, in what the presentation calls “wave 2.” With the 23 post offices that lost their carriers in November and February, the total number of spoke offices will soon be 82, with about 1,080 routes relocated to the S&DCs.

Here are a list and map of these 82 spoke offices and 24 S&DCs, based on the May 4 presentation. (View on Google Docs and Google Maps.)

The May 4 presentation shows a few spoke offices that have not appeared on previous lists: Rose Station in Terre Haute, IN; the Donaldson and Sheridan Stations in Tulsa, OK; and the Downtown Station in Waco, TX.

The presentation says that implementation of several S&DCs has been postponed or cancelled because none of their spoke offices passed what’s called a Financial Rigor Test. These include the S&DCs in Columbia, SC; Morgantown, WV; Owensboro, KY; Rockford, IL; Stockton, CA; and Williamsport, PA. The presentation does not explain what the FRT uses as criteria, but it says that these facilities are “still being modified with all the S&DC equipment updates.”

North Altanta Branch S&DC with 30-minute reach in green

In some cases, the presentation provides incorrect data. For example, a table shows the distance between the new S&DC at the North Atlanta Branch post office (in Atlanta, GA) and the Dunwoody Branch spoke office as 18 miles; Google says it’s 7.3 miles. The presentation shows the distance to the Briarcliff Branch spoke as 16 miles; Google shows it as 2.3 miles. A map in the presentation shows that the Google numbers are correct.

Just getting started

In its Two-Year Report to Congress on the implementation status of Delivering for America, the Postal Service says it is currently looking at a hundred more potential S&DC sites. At the Postal Forum this week, the Postmaster General said he expected to deploy over 400 in the next three years.

Those 400 S&DCs would take on carrier operations from as many as 6,000 spoke offices, with over a 100,000 carriers relocated from post offices to S&DCs. That’s an average of 15 spokes and 250 routes per S&DC.

So far, the S&DCs are averaging just 3 or 4 spokes and 45 routes. Each of these S&DCs has many more post offices within a 30-minute drive, the maximum reach according to the plan. Apparently the Postal Service just wants to get the S&DCs established. More spokes can be added later.

The average distance between the S&DCs and post offices is 8 miles, and the drive time averages 15 minutes. When the plan is fully implemented, this average will increase to about 11 or 12 miles and 20 minutes, as discussed in this previous analysis. The averages are low now because the Postal Service is starting off with post offices, especially those with a lot of routes, that are relatively close to the S&DC.

Bryan TX Post Office, now an S&DC

For example, the College Station post office sent 68 routes to the S&DC in Bryan, Texas, just 7 miles away, and the Bridgeport, Conn., office sent 61 routes to the Fairfield Carrier Annex (which is presumably the Commerce Station), just 3 miles away.

Since July 2022, when the Postal Service began sharing details about the Sorting & Delivery Center initiative, it has identified about 40 potential S&DCs and 280 post offices that could give up their carriers and become “spoke” offices. A complete list of all of these facilities is here.

Over the past several months, most of these facilities have dropped off the update lists for reasons the Postal Service has not explained. Some have failed the Financial Rigor Test, whatever that is, some may have run into local political opposition, and others may have been postponed until the S&DC can be prepared for the carriers.

Whatever the reason, with just over a thousand routes being relocated in the first year of S&DCs, the Postal Service is a long way from the goal of transferring 100,000 routes to S&DCs.

No reduction of retail services

One detail in the May 4 presentation is worth noting. At the bottom of the slide that provides an overview of the plan’s goals — a slide that has been used on previous presentations — a footnote has been added saying, “Retail & PO Box Operations remain at the Spoke Sites and are not impacted by S&DC Operations.” The Postal Service also emphasizes this point in the two-year progress report on the Delivering for America plan.

Athens S&DC (Source: USPS presentation at Postal Forum)

At the House hearing on May 17, the Postmaster General was asked by Vermont Congresswoman Becca Balint about her constituents’ concerns that relocating carriers will be followed by cuts to post offices.

In reply, the PMG began explaining the rationale for the S&DC plan. Pressed by Balint for an answer, he finally said, “Rolling out this network will not result in reduction of retail services.” (video at 1:54) The Postmaster General has thus testified, under oath and on video, that the S&DC plan will not reduce retail services.

It will be useful to remember this moment when, sometime over the next year or two, the Postal Service starts cutting retail hours and closing post offices — both of which are explicitly identified as elements of the Delivering for America plan — because of all the excess space created by removing carrier operations. Clerk positions are already being eliminated at spoke offices due to the S&DC plan, which is bound to affect retail services.

Dramatic change, executed rapidly

The Postmaster General recently told the Board of Governors that “more aggressive action” is coming soon. At the Postal Forum this week, the Postmaster General boasted about the progress he’s made implementing the Delivering for America plan, but he emphasized the need for “dramatic change.” His “biggest initiative” — transforming the processing and delivery network — is just beginning.

“We must now execute rapidly on our plans to deploy our network,” said DeJoy. “This is the only way to achieve the service and cost improvements necessary for us to fulfill our mission to rescue this organization.”

While DeJoy pushes forward with his effort to save the post office, he has been openly hostile to those who want to learn more about the plan than he wants to reveal at any given moment.

The Postal Service is formally opposing the Postal Regulatory Commission’s public inquiry into the network transformations, claiming the Commission lacks the legal authority to conduct such an inquiry. If the Commission denies the Postal Service’s motion to shut down the inquiry, the case may end up in the DC Circuit Court of Appeals.

At the House hearing a couple of weeks ago, the Postmaster General complained that the Commission’s interference “is going to put this whole plan in jeopardy.” At this week’s Postal Forum, DeJoy went after the PRC again, describing it as “confused and confusing,” and lacking “an understanding of the developing crisis and an unwillingness to address the issues presented.”

The Postmaster General does not want anyone — Congress, stakeholders, the PRC, postal employees, or the public – to get in his way. But if his plan can’t withstand the scrutiny of the Commission’s public inquiry, one has to wonder why. What’s in the plan that the public will find so objectionable that it could sink the whole thing?

— Steve Hutkins

To learn more about network transformation, visit our S&DC dashboard.

The Post Office Can Bring People-Centered Public Banking to Every ZIP Code

Steve HutkinsMay 24, 2023Blog, News

Inequality.org: The need for a public banking option is urgent. Nearly 10 million households, a disproportionate number of whom are people of color, are unbanked or underbanked in the United States.

Unbanked or underbanked households must pay expensive fees for non-bank financial services to access their own money for paying bills, cashing checks, remittances, rent, and ATM withdrawals — costing upwards of $2,400 annually.

The widely trusted U.S. Postal Service has a long history of postal banking and is physically located in every community, making it the sensible option to provide a public banking solution. But this requires a good faith effort, done well.

A new report, “Banking Fair: The Promise and Urgency of Doing Postal Banking Right,” by the Save the Post Office Coalition, Take On Wall Street, and Americans for Financial Reform Education Fund, calls for a public banking option to be restored within USPS.

The Post Office has a long history as a public service institution, despite the seeds of privatization sown by Republican presidents and Congress since 1970. Up until the 1960s, many relied on the trusted postal savings system over private banks after banking scares in the early 1900s.

“Banking Fair” provides an eye-opening analysis of how USPS leadership is thwarting efforts to revive a postal banking option by halting a new check-cashing program won by advocates in 2021. They are also refusing to roll out the additional financial services — bill payment, wire transfers, and low-fee ATMS — that the USPS Inspector General has already deemed legal for the agency to provide.

The paper outlines the weaknesses with the current state of the USPS check-cashing pilot program, which has stalled at four post offices that serve wealthier zip codes, faced gratuitous legal challenges by the conservative Postal Regulatory Commission — a Trump-era holdover — had little marketing to let people know the product exists, and only covers checks below $500 for a hefty $5.95 fee.

Postal Service creates a dashboard on post office suspensions, but it’s not for the public

Steve HutkinsMay 23, 2023Blog, Featured

The USPS OIG has released a report about the Postal Service’s handling of post office suspensions, and in particular the problem of suspensions that don’t get resolved within a reasonable period of time. Among the IG’s findings is that the system used for tracking suspensions has “data reliability issues.” To help address this problem, the Postal Service told the IG that it is developing a suspension dashboard. Unfortunately, the public won’t be able to see it.

The objective of the IG’s investigation was to assess the effectiveness of the Postal Service’s plans to resolve a backlog of suspensions that, by the end of fiscal year 2016, included over 650 post offices. Several of the suspensions had gone unresolved for many years, even though the Postal Service’s policy “requires a post office suspension be resolved by either re-opening or permanently closing the facility, which is typically completed between 180 to 280 days.”

Since 2020, the Postal Service has been providing the Postal Regulatory Commission with plans for resolving the suspensions, but the IG’s report says it could not find sufficient documentation to support implementation of the plans that were reported to the public.

The IG also found that there were “data reliability” problems with the system used to track suspensions. The tracking forms were often incomplete and did not have the required information within 90 days of the suspension on whether to restore service, secure another space, or take other necessary corrective action.

The IG also did field visits to the twenty-five oldest suspensions to observe the physical condition of the building and confirm their current suspension. The IG found that the Postal Service’s suspension status information was inaccurate on all twenty-five sites.

As one example of inaccurate data, the IG cites the Norristown, GA, post office, which was suspended in 2005 and is still suspended. The IG points out that the building no longer exists — the report includes a photo of the remains of a brick structure — which would indicate that the office is permanently closed, not merely suspended. In response, the Postal Service pointed out that the IG had the wrong address. (The old post office and general store is shown at the top of this post, and it does still exist at 718 US 221 in Norristown, as seen on Google Street Views). It should be noted, however, that just because a building no longer exists does not mean the post office has closed permanently — that can only happen by completing a discontinuance process.

As another example of data reliability problems, the IG’s report says that the post office in Layton, NJ, which was suspended in 1984, is currently open, whereas the tracking system shows it as still suspended. In reply, the Postal Service pointed out that the IG had the wrong office. The correct office is the former Wallpack Center post office, a few miles away from Layton.

Former post office and general store, Wallpack Center, NJ in 2011. Source: Wikimedia

It’s not clear if these confusions over locations are due to errors in the Postal Service’s data base or to mistakes made by the IG, but they are not surprising. The Postal Service typically doesn’t provide the addresses of suspended post offices when it shares lists of suspensions with the PRC, and it can be difficult to determine the correct addresses of offices — as well as other data, like the cause for the suspension — for post offices suspended many years ago.

To help remedy the tracking problem, the IG recommended that the Postal Service “develop and implement formally documented quality assurance processes over the data in the post office suspension tracking system.”

In its response, dated May 1, 2023, the Postal Service said it is “currently developing and implementing an assurance processes dashboard over the Post Office suspension tracking system.” The target date for implementation is October 31, 2023.

The fact that the Postal Service is creating a dashboard to help track suspensions is noteworthy.

In February 2022 the Postal Regulatory Commission opened a Public Inquiry docket to address the backlog of suspensions, and I submitted comments recommending that the Postal Service and the Commission should work together to create a suspension dashboard that would keep the public up to date on all the suspensions in real time.

A few weeks ago, after the docket sat dormant for over a year, the PRC finally got around to following up on the inquiry by issuing an information request asking the Postal Service to describe the extent to which it is “considering creating and maintaining a publicly-available dashboard of suspended post offices.”

The Postal Service responded on May 3, 2023 — a couple of days after it told the IG that it was developing a suspension dashboard — that it “does not currently plan to create a public-facing dashboard showing the discontinuance status of suspended Post Offices…. The Postal Service questions the marginal utility of such a project, especially in light of the costs (some of them recurring) that it would entail.”

When the Postal Service submitted this response to the Commission’s information request, it was actually already working on a suspension dashboard, but it did not mention this to the Commission.

The IG’s report says that the Postal Service’s new suspension dashboard is intended “to help inform other Postal Service Headquarters’ stakeholders of the status of suspended post offices.”

It’s not clear who these stakeholders are, but they won’t include the general public or the people whose post office has been suspended. Perhaps the Commission can ask the Postal Service what its internal dashboard will contain and what would be involved in making some version of it available to the public.

— Steve Hutkins

To learn more about emergency suspensions, visit our suspension dashboard.

Suspension Dashboard

Postal Service announces plans to remove & relocate processing equipment

SteveMay 21, 2023Blog, Featured

The Postal Service has informed the unions that it’s implementing a plan “to remove and/or relocate an undefined number” of sorting machines and other types of mail process equipment, starting in August 2023 and continuing into fiscal year 2024.

The Postal Service is asking for volunteer maintenance personnel to perform the equipment removals and relocations. Preference will be given to workers at those facilities scheduled to have a machine removed and to those who are trained on the equipment.

The Postal Service says the volunteers may need to travel to other parts of the country for up to three weeks. If a particular project takes longer, a new team will rotate in. Volunteers must provide their own work clothes, hard hats, and safety equipment.

The list of equipment includes the full range of sorters and machines, including Automated Delivery Unit Sorters (ADUS), Advanced Facer Canceler Systems (AFCS), Automated Flat Sorting Machines (AFSM), Automated Parcel Bundler Sorters (APBS), Small Delivery Unit Sorters (SDUS), Delivery Bar Code Sorters (DBCS), Single Induction Package Sorters (SIPS), Robust Bulk Universal Sorters (RBUS), and so on.

Layout of Richmond VA RPDC (Source: USPS presentation)

The project is set to begin in August 2023 in Atlanta, Georgia, followed by Charlotte, North Carolina. These are the locations of the two new Regional Processing & Delivery Centers (RPDCs), so perhaps equipment from the regions’ P&DCs will be relocated to the new RPDCs in Palmetto (Atlanta metro), and Gastonia (Charlotte metro). The RPDCs are described as multi-functional and able to handle every phase of the processing operation for all types of mail, so they’ll need a wide variety of sorting equipment.

The equipment removals may also refer to clearing out space in processing centers so that they can be repurposed as Sorting & Delivery Centers (S&DCs) and changing the type of equipment so they can function as a Local Distribution Centers (LDCs).

Over 200 processing centers could eventually see equipment removed or relocated, but the Postal Service has not released a list of those facilities that will be losing their equipment and those that will be gaining them. The notification to the unions simply says that additional sites will be identified but they have not yet been determined.

Handbook PO-408, which provides the guidelines for doing Area Mail Processing (AMP) studies, describes a consolidation in terms of moving employees and equipment from one processing center to another, so it’s not clear why AMP studies have not been conducted before making arrangements to move equipment this summer.

Package sorting machine

In a recent USPS report to Congress (required by the Postal Reform Act), the Postal Service stated: “We will fulfill all applicable internal guidelines set forth in Handbook PO-408 and comply with all other applicable regulatory or statutory requirements in connection with our consolidations in Atlanta, Charlotte, Chicago, Indianapolis and Memphis.”

According to the Handbook, the AMP process begins with a feasibility study to determine “whether there is a business case for relocating processing and distribution operations from one location to another. An AMP feasibility study must be conducted when a new facility project incorporates operations from two or more offices.”

Moving equipment to the new facilities in Charlotte and Atlanta would seem to fall squarely within the requirements of the guidelines. If the relocation of equipment is going to get started in August, AMP studies would need to begin very soon. The AMP studies conducted back in 2011 and 2012 each took several months.

Since there’s been no sign of an AMP study for the consolidations in Charlotte and Atlanta, it’s likely that the Postal Service believes the equipment relocation project does not require one. It would be interesting to hear why.

— Steve Hutkins

Previewing the first wave of Regional Processing & Distribution Centers

A progress report on S&DC conversions and plant consolidations

The Postal Service launches new service performance dashboard

SteveMay 19, 2023Featured, News

The Postal Service just launched its new service performance dashboard, a requirement of the Postal Reform Act. You can find it here.

As specified by the Act, the dashboard contains weekly, monthly, and quarterly data, which can be disaggregated by type (First Class, Marketing, Single-piece, Pre-sort, etc.). One can search for incoming and outgoing mail from any ZIP code, or even between two ZIP codes.

The search results compare the current period with the targets and with the same period last year (but only going back to the beginning of fiscal year 2022 on Oct. 1., 2021).

The performance results are presented with two metrics — average days to deliver and the percent of the volume delivered on time (and with one extra day as well).

One can also download the results of a search to a csv table, and there’s a helpful documentation page explaining the dashboard’s features and key terms.

The dashboard does have at least one problem, though. When you search for the delivery data between two ZIP codes, the dashboard tells you the percent of the mail delivered on time, but it doesn’t tell you the service standard used to determine the percentage. So you learn, say, that 90 percent of the mail is delivered on time, but you don’t know how many days “on time” would be. (You can find the service standard using the map in this Washington Post article.)

Another problem is that while one enters a ZIP code to get the data, the scores are not for the ZIP code itself but for the district. When the dashboard was being developed with the Postal Regulatory Commission, the Postal Service argued against reporting at the ZIP code level due to the cost, so the compromise was to have users enter ZIP codes while the results are for the district.

Anyway, the dashboard looks great, it’s very easy to use, and it’s a significant improvement over the other ways the Postal Service shares performance data.

The USPS press release is here. Senator Gary Peters’ statement is here.

DeJoy says USPS regulator’s network consolidation probe puts financial targets in ‘jeopardy’

Steve HutkinsMay 18, 2023Blog, News

Federal News Network: Postmaster General Louis DeJoy is telling lawmakers that the Postal Service, facing larger financial losses than expected this year, can still achieve its long-term financial goals — if its regulator and Congress don’t interfere with plans to overhaul its delivery network.

“We need to move, and we can get back on track with this. I see where targets of money are for us to get, just by improving our operational performance and growing our business, but we’re behind. We’re not happy with it,” DeJoy told members of the House Oversight and Accountability Committee on Wednesday.

DeJoy told the government operations subcommittee that USPS still can dig out of a long-term financial hole and break even by 2030, as envisioned in his 10-year Delivering for America reform plan.

But he warned lawmakers that the Postal Regulatory Commission’s scrutiny of the agency’s network consolidation plans “is going to put this whole plan in jeopardy.”

The PRC launched a public-inquiry proceeding in April on USPS plans to bring mail processing and delivery operations under one roof, by creating Sorting and Delivery Centers across the country.

PMG DeJoy trashes PRC at House hearing, says it “actively participated in the destruction” of the Postal Service

Steve HutkinsMay 17, 2023Blog, Featured

At today’s hearing of the Subcommittee on Government Operations and the Federal Workforce, Congresswoman Summer Lee (PA-12) asked the Postmaster General some excellent questions about the Postal Service’s plan to consolidate carriers into Sorting and Delivery Centers. Lee observed that the plan “will certainly have major effects on local communities,” and she questioned whether postal leadership is hearing the concerns being raised by communities and postal workers.

Lee asked the Postmaster General why the Postal Service did not consult with the public before releasing the Delivering for America plan, particularly the part about restructuring the delivery network. DeJoy replied that the Postal Service has complied with the laws regarding community engagement during the rollout of the 10-year plan. “I can’t tell you,” he said, “how much communications we’ve had with Congress and the stakeholders.”

Rep. Summer Lee (PA-12)

Lee noted that the Postal Regulatory Commission recently opened a formal public inquiry “to get more transparency and learn more about the impact on the postal community, yet the Postal Service recently filed an objection and asked that the inquiry be withdrawn.”

“Why,” asked the Congresswoman, “is the Postal Service objecting to this inquiry meant to ensure that you actually engage with stakeholders?”

The Postmaster General replied that “it’s our position that the Postal Regulatory Commission has overstepped its authority” — which, in a nutshell, is the argument put forth in the Postal Service’s motion opposing the public inquiry (more on that here and here). The PMG went on to make this comment:

“We’re an independent organization, and we are charged with the mission of saving the organization, not the Postal Regulatory Commission. The Postal Regulatory Commission sat over and watched the destruction of the organization over the last fifteen years and actively participated in the destruction of the organization over the last fifteen years. What we’re trying to do is save the organization. What goes on and why they do the things they do I am yet to figure out, and I’m a pretty smart guy.”

The Congresswoman followed up with this question: “If your objection is dismissed, will you commit to participating in stakeholder forums and pledge not to take any further steps to block or delay such a forum?”

DeJoy did not respond directly, and he did not make such a commitment. Instead, he went on about how management has communicated extensively with all stakeholders with a reasonable amount of description for the massive changes he’s making. “At the end of the day,” he said, “we’re not affecting service… Service is better now because of the things we have done within the plan… We just have to fix the chaos that has been established over the past fifteen years.”

DeJoy then went on to stress the importance of moving forward with his plan, “and that’s why interference from the Postal Regulatory Commission is not helpful. It is going to put this whole plan in jeopardy.”

DeJoy’s repeated references to what’s gone on over the past fifteen years are about the 2006 Postal Accountability and Enhancement Act, which limited the Postal Service’s ability to raise prices (the price cap regime), turned the Postal Rate Commission into the Postal Regulatory Commission, and greatly expanded the oversight role of the Commission. In his opening statement at the hearing, DeJoy criticized PAEA for its “defective pricing model,” and added that the PRC “exacerbated” the problem with its interpretation of PAEA when the Postal Service asked for an exigent rate increase during the recession. DeJoy believes PAEA and the PRC have thus helped create the “chaos” that he must now fix in order to save the post office.

Sometime over the next few days, the Commission will issue a ruling on the Postal Service’s motion to reconsider its order creating a public inquiry on the DFA plan. DeJoy’s comments today probably won’t help the Postal Service’s case. And his refusal to commit not to take further steps to block the inquiry can only mean one thing. Rather than cooperating, the Postal Service is planning to take the Commission to court.

— Steve Hutkins

The hearing can be seen in its entirety here; Congresswoman Lee’s comments begin here.

PRC Initiates Public Inquiry Proceeding to Gather Information on Changes to the Postal Network

The USPS is challenging the PRC’s authority to open a public inquiry on the DFA plan

Mailers defend the PRC’s public inquiry into Delivering for America

Morrison, Tenn., post office suspended over lease issue

Steve HutkinsMay 17, 2023News

Southern Standard: On Tuesday, the United States Postal Service announced the suspension of the Morrison Post Office as of May 20. Beginning May 22, Morrison postal consumers are encouraged to use the Manchester Post Office at 1601 Hillsboro Blvd. or Smartt Post Office at 5174 Manchester Hwy. in Smartt. Morrison P.O. Box customers will keep their existing P.O. Box number and 37357 ZIP Code….

Since May of last year, the shaky state of the Morrison Post Office was bound up in an issue related to the fact that the Post Office leases rather than owns the property…. According to the Tennessee Comptroller of the Treasury, the property the Morrison Post Office is on is reportedly owned by Greeter Properties in Murfreesboro, but there was no contact information found for Greeter Properties and the address listed was for a law firm which may have been a registered agent for Greeter Properties. Noble Law PLLC did not respond by press time.

Ed. note: The Morrison office almost closed a year ago over the lease issue, so the Postal Service has known for a long time that it would probably not be keeping the office open, yet it notified customers of the suspension only five days in advance.

Pay Cuts Have Rural Letter Carriers ‘Scared’ and ‘Outraged’

Steve HutkinsMay 16, 2023News

Government Executive: Thousands of letter carriers at the U.S. Postal Service are starting to see new schedules that have reduced their hours and cut their pay, causing significant anxiety within the workforce.

The changes are part of a revamping of the pay structure for rural employees, a process that has been years in the making and subject to a series of delays. The new work schedules were slated to go into effect last month, but were repeatedly pushed back as the Postal Service sought to iron out kinks.

The National Rural Letter Carriers Association has filed a national grievance on the plan, saying USPS has withheld details on the data that underlies the new hour and pay calculations. The new system was developed in conjunction with the union after an arbitrator in 2012 said the two sides should come together to create a structure that better adapts to the mailing agency’s evolving business conditions.

Mailers defend the PRC’s public inquiry into Delivering for America

Steve HutkinsMay 13, 2023Blog, Featured

On April 20, the Postal Regulatory Commission opened a Public Inquiry docket to examine the Postal Service’s Delivering for America plan, particularly the initiative to relocate carriers from post offices to large Sorting & Delivery Centers. On May 5, the Postal Service filed a motion arguing that the PRC should reconsider its order creating the docket because the regulator lacks the authority to create such a “far-flung inquiry.”

Yesterday, two groups of mailers filed comments opposing the Postal Service’s motion. The mailers argue that the Commission was operating well within its authority to open the inquiry, and it needs to go forward.

One of the comments was submitted by the Association for Postal Commerce (PostCom) and the Alliance of Nonprofit Mailers (ANM). The other was filed by the National Postal Policy Council, the Major Mailers Association, and the News/Media Alliance.

The mailers’ arguments

In their comments, PostCom and the ANM note that during the inquiry the Postal Service would be able to file objections to specific information requests, but the Postal Service objects “to providing the Commission and the public with any information regarding the implementation of the Delivering for America plan.” The Postal Service “objects to even engaging with its regulator.”

PostCom/ANM proceed to refute the Postal Service’s argument that the Commission did not cite any statute that would provide a legal basis for the inquiry. The mailers state that “39 U.S.C. § 503 provides the Commission broad authority to gather information in support of its role as the Postal Service’s regulator.” If it’s important that the Commission cite such statutes, PostCom says, it can correct this omission by issuing another order with the citation.

In its motion, the Postal Service cited numerous precedents involving regulators exceeding their authority. PostCom/ANM say these cases are irrelevant because the Commission hasn’t issued any rule changes or taken any other action, aside from opening a docket to make inquiries.

A large section of the PostCom/ANM comments focuses on the history of the Commission itself and how Congress envisioned the scope of its authority. While the earlier Rate Commission was limited in its authority, Congress expanded this authority when it created the Regulatory Commission with PAEA in 2006.

Finally, PostCom/ANM contest the Postal Service’s claim of a “deliberative process privilege” — a reference to the USPS argument that “premature review has the potential to interfere with the deliberative process of the Postal Service and intrude upon the prerogatives of the Postal Service, and our Governors.”

According to PostCom/ANM, the DFA plan is no longer “predecisional,” and the S&DC initiative is not simply a “plan.” It’s being implemented already, with the opening of the first S&DC in Athens, Georgia, in November 2022 and several others in February 2023, with another phase of conversions scheduled for June 2023 and September. As the commenters observe, “These conversions effect changes encompassing 15 S&DCs and about 65 post offices and 600 routes.”

The comments from National Postal Policy Council, the Major Mailers Association, and the News/Media Alliance also argue that “opening a public inquiry to educate itself regarding what appears to be a major restructuring of postal processing and delivery facilities is a reasonable and prudential action well within the regulator’s discretion.” The contention that the Commission lacks statutory authority even to initiate this proceeding, say NPPC et al, “is meritless.”

Like PostCom, NPPC argues that “It is difficult to take seriously the notion that S&DCs are in the ‘early stages’ of ‘strategic and operational planning.’” As the mailers point out, those plans were “sufficiently decisional” to enable the Postal Service to commit nearly $7.6 billion to proceed with the creation of the new processing and delivery network.

The NPPC comments conclude by observing that “the vesting of operational authority in postal management and the Governors is not an excuse for evading the oversight necessary to permit the regulator to fulfill its responsibility to serve as a check to ensure that the Service acts in compliance with the law and does not abuse its legal monopoly over the essential mail side of its business. It is difficult to understand how the Commission can fulfill its responsibilities based on the little information that the Postal Service has deigned to share to date about network changes.”

What happens next?

Now that the Commission can consider both sides of the matter, it will soon issue an order responding to the Postal Service’s motion to close down the public inquiry. My guess is that the Commission will deny the motion and remind the Postal Service that it can object to any particular information request posed by participants in the docket. The Commission may also modify its order creating the public inquiry by identifying parameters that limit what kinds of information requests will be considered.

If the inquiry goes forward, the information requests will probably come at a fast pace — PostCom submitted its first request within days after the inquiry began — and they will cover a wide range of topics that the Postal Service doesn’t want to discuss. These include details about the new costs incurred by the plan — for new facilities, repurposing processing centers, additional carrier routes, etc. — and the projected cost savings the plan will achieve — which will involve eliminating thousands of clerk positions, downgrading postmasters, reducing retail window hours, and closing post offices.

Revealing details about such topics will make it difficult for the Postal Service to control the narrative about the Delivering for America plan. So rather than fighting over each information request, one by one, the Postal Service may prefer to appeal the Commission’s order to the D.C. Circuit court.

It’s not clear what would happen then. Would the Commission put the public inquiry on hold while the appeal is being heard — which could take a year before a ruling is issued — or would it proceed to issue information requests in the meantime? And if it does issue those requests, will the Postal Service agree to respond or will it say it’s not participating in the inquiry while the appeal is pending? If the Postal Service doesn’t provide adequate responses, would the Commission issue subpoenas, as it has the authority to do?

That may seem like an unlikely scenario, but in its motion for reconsideration the Postal Service issued this warning: “An attempt to use the Commission’s subpoena power as a legal basis to initiate Docket No. PI2023-4 would be mistaken.” In other words, subpoenas will be challenged in court.

The Chevron twist

Another interesting aspect of this controversy involves the eventual decision of the Supreme Court on a current case involving the Chevron doctrine. This refers to the 1984 case Chevron v. Natural Resources Defense Council, in which the Court said a government agency’s interpretation of a statute should be given deference if Congress has not spoken directly on the issue and the agency interpretation is reasonable.

Over the coming months, it’s possible, perhaps likely, that the Supreme Court will overturn Chevron, which will significantly reduce the power of government agencies to interpret and implement laws passed by Congress — a goal of anti-regulatory conservatives since the New Deal expanded the authority of government nine decades ago.

In the past, both the Postal Service and the PRC have had occasion to invoke Chevron to help make their case. For example, in a 2016 Public Inquiry into the interpretation of terms involving post office closings, the Postal Service argued that it, not the Commission, was entitled to deference. In 2020, when mailers challenged the authority of the Commission to change the rate system, the Commission argued that it was entitled to deference on the question.

If the DFA public inquiry goes to court, it’s possible that the Postal Service and the Commission will both argue that they’re entitled to Chevron deference. It’s not certain who would win that argument. On the other hand, if Chevron has been overturned, the D.C. Circuit would need to offer its own interpretation of what the scope of the Commission’s authority actually is.

This week the House Subcommittee on Government Operations will hold a hearing to “bring transparency to the progress and impacts of the Postmaster General’s transformative 10-year plan.” Perhaps the Postmaster General will be asked why he’s trying to shut down the PRC’s own effort to provide transparency on the DFA plan.

— Steve Hutkins

To learn more about the transformation of the processing and delivery networks, check out our S&DC dashboard.

Previous posts on the Public Inquiry docket:

PRC Initiates Public Inquiry Proceeding to Gather Information on Changes to the Postal Network

The USPS is challenging the PRC’s authority to open a public inquiry on the DFA plan

The USPS is challenging the PRC’s authority to open a public inquiry on the DFA plan

Steve HutkinsMay 5, 2023Blog, Featured

The Postal Service has just filed a motion with the Postal Regulatory Commission challenging the Commission’s authority to open a public inquiry docket on the Delivering for America plan. “The Postal Service … respectfully requests that the Commission reconsider and withdraw Order No. 6488 [which opened the docket], as it is based on a material error of law.”

According to the Postal Service, “Order No. 6488 creates a ‘forum’ to delve into ‘issues related to the Postal Service’s Delivering for America Strategic Plan’ without identifying a legal basis that allows the Commission to conduct such a far-flung inquiry. The Order has no limiting principles grounded in the Commission’s authority, and instead permits the Commission, as well as any interested party, to inquire into any and all aspects of the Plan, and hence—given the breadth of the Plan—upon the Postal Service’s strategic initiatives generally. This includes matters that the Commission has previously recognized are outside of its jurisdiction.”

The Postal Service goes on to describe the various ways stakeholders and the public have had an opportunity to comment on the DFA plan and then observes:

“With these extensive options, it is not clear what further opportunities for input the stakeholders feel are missing, beyond wanting granular information about certain strategic initiatives before the Postal Service is ready or required to reveal it. If stakeholders have not been engaged in the proceedings to date related to the initiatives that have properly been made public, it is not because of a lack of opportunity. The public’s right to information is not unlimited, and they are not entitled to scrutinize pre-decisional deliberations or various types of sensitive management matters. The Commission should use established mechanisms to ensure adequate oversight, consistent with its past decisions and its statutory authority. An open-ended PI docket that encompasses review of all possible initiatives under the Plan is wholly unnecessary, unwarranted, and contrary to the Commission’s statutory authority.”

One of the main motives for the inquiry was to provide more transparency about the DFA plan. The Postal Service turns this justification on its head and says the inquiry will lead to less transparency: “Moreover,” states the motion, “using a PI docket to essentially audit the Postal Service’s internal planning and deliberations is not only unjustifiable, but could disincentivize transparency if our efforts to share strategic information at early stages simply generates intrusive and inappropriate oversight by the Commission.”

The motion runs to 27 pages, and it cites numerous statutes, precedents, and previous orders by the Commission. It’s fashioned simply as a “motion for reconsideration” of the order creating the public inquiry docket, but it reads more like the foundation for a legal case.

It’s noteworthy that the motion is signed by Thomas J. Marshall, the USPS General Counsel and Executive Vice President, along with six other attorneys. That’s not typical for a motion before the PRC. Nor is it typical for the Postal Service to warn the Commission against subpoenaing information. As the motion states, “An attempt to use the Commission’s subpoena power as a legal basis to initiate Docket No. PI2023-4 would be mistaken.”

Should the Commission deny the motion and keep the docket open, it’s likely, perhaps inevitable, that the Postal Service will challenge the decision in the D.C. Circuit court. A lawsuit would, of course, take a long time to resolve — certainly more than a year, if previous cases are any indication.

If the Commission grants the Postal Service’s motion, there will be no public inquiry into the DFA plan. If the Postal Service takes the Commission to court, it will have much the same effect.

Shutting down a public inquiry into the Delivering for America plan does not reflect well on the Postal Service, to say the least.

— Steve Hutkins

PRC Initiates Public Inquiry Proceeding to Gather Information on Changes to the Postal Network

A Thousand Post Office Suspensions in Review

Steve HutkinsMay 5, 2023Blog, Featured

By Steve Hutkins

In February 2022 the Postal Regulatory Commission opened a Public Inquiry docket to address the issue of post offices that have been under emergency suspension for an extended period of time without being resolved by reopening them or closing them permanently. Such suspensions become de facto discontinuances without having gone through a discontinuance process that provides opportunity for public comment.

The inquiry was intended to examine “issues impeding the Postal Service’s progress in resolving the suspended post offices in a timely manner” and to consider “procedures or courses of action for how the Postal Service may expeditiously resolve suspended post offices.” The Commission received comments from the Postal Service, the PRC’s Public Representative, and me.

My comments argued that the Postal Service and the Commission should work together to create a suspension dashboard that would keep the public up to date on all the suspensions in real time, with information about the alternative location for postal services during the suspension, when to expect the suspension to be resolved, the status of any discontinuance process that’s underway, and so on. Such a dashboard would also provide transparency about suspensions and discontinuances in general. To illustrate what the dashboard could show, I created a prototype, available here. In his comments, the Public Representative also recommended that the Postal Service create a dashboard and share more information online.

No further action was taken on the public inquiry for over a year. Then a couple of weeks ago, for reasons unknown, the Commission finally responded to the comments by issuing an Information Request asking the Postal Service to describe the extent to which it is “considering creating and maintaining a publicly-available dashboard of suspended post offices.”

The “marginal utility” of a dashboard

Last week, the Postal Service responded. Not surprisingly, the agency said it “does not currently plan to create a public-facing dashboard showing the discontinuance status of suspended Post Offices.”

According to the Postal Service, “the proposed dashboard would duplicate information that the Postal Service already provides.” The Postal Service cites three ways it provides this information — PostalPro, reports to the Commission, and USPS.com. For many reasons, these are all inadequate and do not do the job of a public-facing dashboard.

PostalPro Industry Alerts: The PostalPro website is intended for business mailers and not user-friendly for the general public. It’s difficult finding the suspension notices on the site amidst all the other types of industry alerts, which include short-term closures for weather-related problems and alerts that don’t involve post offices at all. The archive of alerts covers only 2021 and 2022, and it’s doubtful that it contains all the suspensions that occurred during those two years. These alerts are organized by month (so one would need to know when the suspension occurred), they often do not contain the reason for the suspension, and they don’t contain any information about the status of when the office might reopen or be studied for discontinuance.

Reports to the Commission: As with the alerts on PostalPro, it’s very difficult finding suspension reports on the PRC website unless one knows where to look. If one searches for “suspension” in the main search box on the homepage of the website, nothing shows up. The annual reports of suspensions during the fiscal year contain very little information, not even the address of the office, the date of the suspension, or the reason for it, and since they’re filed annually, they do not provide up-to-date information on the status of the suspension. (Several of the offices listed on the end-of-year 2022 report have since reopened.)

USPS.com: The Postal Service says that “the public can access information on individual Post Offices, including the suspension status of each suspended Post Office, on USPS.com.” It’s not clear what the Postal Service is referring to here. There’s a page on the website with the latest service alerts (like on PostalPro), but it doesn’t provide the status of suspended offices. Press releases archived on the news page announce some (not all) suspensions when they first occur, but don’t provide updates on their status. On the Find USPS Locations page, one can search a city or zip code and find nearby post offices, with their hours and location, but suspended offices typically do not appear in a search. It’s as if they never existed, rather than been temporarily closed.

The Postal Service clearly has no interest in creating a suspension dashboard. It concludes its brief response to the information request by saying, “the Postal Service questions the marginal utility of such a project, especially in light of the costs (some of them recurring) that it would entail.”

This is not very convincing. The Postal Service has the relevant information for a dashboard readily at hand, and in the context of the USPS budget, the cost would be minimal.

Clearing the backlog

The PRC’s Annual Compliance Determination (ACD) for FY 2022 contains a discussion of post office suspensions that took place during the fiscal year and the status of the backlog of 665 long-term suspensions from 2016 that prompted the public inquiry. As the Commission explains, the number of number of unresolved suspensions tripled from FY 2012 to FY 2015, prompting the Commission to require quarterly reports on their status. Progress on resolving the suspensions was hampered by organizational restructuring and the pandemic, then resumed in 2022. At this point, 79 remain unresolved.

Of the 665 suspensions in the FY 2016 backlog, about 480 ultimately have ended with a discontinuance. In most cases, the Postal Service had completed most of the discontinuance process years ago except for the last couple of steps, but the discontinuances were not officially completed with an announcement in the Postal Bulletin until 2017, 2018, and 2022. (For a while last year, it looked as though the Postal Service would skip this final step altogether. More on that here and here.)

Former post office in Northrop, MN, suspended in 1988, still suspended as of 2022

On average, for the 480 suspensions ending with a discontinuance, it took almost eight years to go from suspension to discontinuance.

About a hundred of the 665 suspended offices were reopened. For most of these, the suspension occurred in 2015 and 2016 and the reopening occurred in 2016 and 2017, so they were not as long-term as most of the offices on the backlog list. Only a handful of the offices with very long-term suspensions have eventually been reopened.

As for the 79 suspended offices from the backlog that remain suspended, the Postal Service told the Commission that it plans to revolve 40 of them through the discontinuance process, assemble a team to review the others, and to resume public meetings (which had been paused during the pandemic) to discontinue those suspended post offices that cannot be reopened or relocated.

Given that these suspensions took place several years ago, it’s unlikely that many, if any, will be reopened. For the 665 suspensions on the backlog list, about 560 — 84 percent — will wind up ending with a discontinuance.

The new backlog

Here’s a table drawn from the ACDs over the past several years showing the number of suspensions and discontinuances annually. (Note that the number of suspensions at the end of one fiscal year is not always the same as the number at the beginning of the following year due to USPS data base issues, errors, and other reasons.)

Suspensions & Discontinuances 2013-2022 (Source: PRC ACD Reports)

From 2017 through 2022, about 725 post offices were suspended. Most of them were resolved by reopening the post office, often within months (after building repairs were done or a safety issue corrected), but about 300 of these offices were still under suspension at the end of FY 2022. In other words, while the Postal Service was clearing the 2016 backlog, a new backlog was developing.

This chart shows the number of suspensions that remained unresolved at the end of each fiscal year. As you can see, the number jumped significantly from 2012 to 2015, which prompted the Commission to require quarterly reports on the Postal Service’s progress toward resolving the suspension backlog from 2016. While the Postal Service has resolved all but 79 of these older suspensions, at the end of FY 2022 there were still 381 unresolved suspensions. On average, these suspensions are five and half years old.

Chart by Visualizer

There’s been an unofficial moratorium on closures since POStPlan reduced hours at some 12,000 small, rural post offices as an alternative to closing them. Aside from the discontinuances of offices on the 2016 backlog list, the Postal Service has not discontinued any post office since 2014. The Postal Service’s annual reports for the compliance reviews often point out that that there were no post office closures during the year. But this is misleading. During each of those years, offices were closed by suspension, and many of them will eventually be discontinued. In fact, there were probably an average of 40 or 50 closures each year from 2017 through 2022.

A thousand suspensions

Here are a map and a list of just over a thousand suspensions — the 665 from 2016, 300 unresolved suspensions from 2016-2022, and a few miscellaneous. View on Google Docs here.

Reasons for Suspensions

As for the causes of all these suspensions, the Commission has not required the Postal Service to provide a reason for every suspension, but by cobbling together various lists, we’ve been able to identify the reason for about 840 suspensions. The causes break down as follows:

Chart by Visualizer

Lease-related causes are by far the most common cause for a suspension. As for what caused the lease issue, for 270 suspensions, the lists say, “Lease Terminated by Lessor.” In only 18 cases do the lists say “Lease Terminated Postal Service.”

In many cases, it was not quite so clear cut who was responsible for the decision to terminate or not renew the lease, as indicated by news articles about the suspensions. In fact, it was the lease issue that led to a Congressional hearing and the Commission’s earlier public inquiry docket on suspensions in 2010.

In any case, when a lease issue causes a suspension, it’s rare for the post office to reopen. Of the 375 suspensions known to have been caused by a lease issue, only 31 have reopened.

Facility profiles

Population data was available for 735 offices on the list of a thousand. More than 7.5 million people live in zip codes that have been impacted by these suspensions.

Nearly all the suspended post offices are small and rural. Over 70 percent of the zip codes are at least 90 percent rural.

Former post office in Boneville, GA, suspended in 2007, still suspended EOY2022

Virtually all the suspended offices are in leased properties. It’s very rare for a post office in a property owned by the Postal Service to remain suspended for an extended period of time. If there’s damage to the building or a safety issue, the Postal Service can correct the problem without waiting on (or arguing with) the lessor.

The average size of the suspended offices is about 2,200 square feet — typical for rural offices in leased spaces. The owned properties, by contrast, average more than 12,000 square feet (that’s not including all the large post offices that are also processing centers).

About 300 of the suspended offices were main post offices, 180 were stations or branches, and 490 were remotely managed post offices (RMPOs), i.e., those that had their hours reduced under POStPlan. Based on data provided in the POStPlan docket, the average distance between the RMPOs and their Administrative Post Office was over 11 miles, and that’s probably typical for suspended post offices in general.

Suspensions and discontinuances to come

According to the Delivering for America 10-year plan, sometime over the next year or two the Postal Service will begin implementing an initiative to “optimize” the retail network by closing post offices. How many will be impacted remains to be seen. But it could be thousands.

The new Sorting & Delivery Centers being created right now will consolidate carriers from as many as 6,000 post offices and leave a lot of excess space behind in each office. In the node studies the Postal Service conducts of its facilities, excess space is often one of the reasons a facility is earmarked for relocation or closure. If the post office is in a leased property, the excess space may lead to an issue over renewing the lease, which in turn will lead to more emergency suspensions.

The problem of long-term suspensions and de facto discontinuances is not going away, and it’s likely to get worse.

A suspension dashboard won’t solve all the problems associated with suspensions and discontinuances, but it would provide some much-needed transparency and help customers whose post office has been suspended. It’s too bad the Postal Service dismissed the proposal with a cursory comment, and it’s doubtful the Commission will do anything more on the matter.

Perhaps one day Congress will require a suspension dashboard, just as it directed the Postal Service to create a service performance dashboard as part of postal reform legislation. In the meantime, to learn more about emergency suspensions, see our Suspension Dashboard.

(Featured Image: Former post office in Export, PA, suspended in 2008, discontinued in 2022)

For an earlier review of suspensions and discontinuances, see this previous post from 2018:

Post Office discontinuances and suspensions: A decade in review

Two-Thirds of Rural Mail Carriers Are Being Hit With A Massive Pay Cut Calculated By An Algorithm

Steve HutkinsApril 22, 2023Blog, News

Aaron Gordon, Vice: “It’s crazy to me,” a rural carrier in Maryland who asked to remain anonymous to avoid retaliation told Motherboard. His annual salary was slashed by $9,000 and he has to work an extra day for every two-week pay period. “I’ll be working more and making less all while doing the exact same work.”

The pay cuts were initially scheduled for early April, but have been pushed back each pay period since for unspecified reasons, according to posts and comments on websites and forums dedicated to rural postal workers. The target of their ire is RRECS, or the Rural Route Evaluated Compensation System. It was designed to more efficiently calculate the number of hours a worker needs to deliver mail on their given route, but flaws in its implementation have resulted in most workers unintentionally under-reporting the time it takes to deliver the mail, resulting in pay cuts.

In a statement, USPS spokesperson David Coleman said, “The compensation system for rural letter carriers is a nationally negotiated pay system codified in the parties’ National Agreement. The current modifications to the compensation system were the result of a previous interest arbitration proceeding and mandated by an interest arbitrator. The parties worked jointly for years to implement these new provisions and will continue to share data and information throughout the implementation process.” The union that represents rural carriers, the National Rural Letter Carriers Association, did not respond to a Motherboard request for comment.

Rural Letter Carriers Complain About Dramatically Reduced Pay

Steve HutkinsApril 21, 2023News

David Dayen, The American Prospect: A new payment system that is estimated to reduce base pay for most rural letter carriers, for some by thousands of dollars, has led to widespread threats of quitting and concern about whether the mail will get delivered in rural America.

The U.S. Postal Service intended to begin implementing the new system, known as the Rural Route Evaluated Compensation System, or RRECS, on Saturday, despite a grievance filed by the National Rural Letter Carriers’ Association union (NRLCA) seeking a 60-day delay and a release of the data that went into it. “We know and the USPS knows that there are errors that need to be corrected,” the NRLCA stated last week in a message to members. “The USPS’s position is to implement and correct the errors later” (emphasis in original).

The effective date for RRECS, which has been in the making for more than a decade, was recently delayed to April 8 and then to April 22. There are rumors that it has been delayed again for one more pay period, but since it was established by a binding arbitration ruling, at some point RRECS will govern rural letter carrier pay. Schedules were posted in some post offices with the new changes this week.

A preliminary review of the new system from the NRLCA found that two-thirds of all rural letter carriers are on track to lose at least one hour per week, and 44 percent will lose four hours or more. About 14 percent of carriers would gain hours. The changes can add to days worked while reducing hours on those days, which can reduce opportunities for overtime.

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