The USPS Office of Inspector General is preparing an audit report about the sale of historic post office buildings.  The objective of the study is “to review the Postal Service’s process and plans for the disposal and preservation of historic properties.”

The OIG poses two main questions: “Do you think the Postal Service follows proper procedures when disposing of historic buildings?  Also, considering its financial constraints, what should the Postal Service’s role be in maintaining historic assets?”

The OIG invites comments from the public, so here’s a good opportunity to weigh in.  Just go to the OIG website and share your thoughts and experiences, especially if you have had a historic post office close in your area.  [The OIG website no longer has the announcement, but it is archived here.]

 

The problem

The OIG’s audit provides a welcome opportunity to examine how and why the Postal Service is selling post offices.  There aren’t many other ways to question what’s going.

The Postal Service, though it prides itself on listening to its customers, has proved to be deaf to the protests of communities where post offices are being sold.   It seems to view legal requirements that it conduct a public participation process simply as an obstacle to be overcome.  It goes through the motions of the legal procedures without any regard for their true goal — to ensure that the Postal Service partner with communities on the decisions that affect them.

Instead, the Postal Service makes a decision first, then pretends to listen to what people have to say.  Public meetings and comment periods turn into an exercise in bad faith, and when communities and their attorneys complain about the Postal Service’s failure to follow the law, postal officials deny any wrongdoing.

The Postal Regulatory Commission, the agency charged with “regulating” the Postal Service, has taken itself out of the picture.  The Commission has dismissed several appeals on the closures and sales, saying that “relocations” of post offices are out of its jurisdiction, and it won’t go near anything related to enforcing the National Historic Preservation Act (NHPA).

That leaves communities few options.  They can lobby their elected officials, but the Postal Service doesn’t listen to them either.  Another alternative would be to take the Postal Service to court, but that takes a lot of time, money, and legal expertise.

It’s probably being overly optimistic to think the OIG’s audit will have any effect on stopping the fire sale of historic post offices, but perhaps it will provide an opportunity to examine some of the key issues.  Perhaps the OIG can encourage the Postal Service to be more forthcoming about what it’s up to and to take more responsibility for preserving its historic properties.

 

The rationale

It became clear early in 2011 that the Postal Service had embarked on a plan to sell off some of its assets, particularly older post offices.  Save the Post Office started blogging about the sales in spring 2011, when several sales were already taking place, such as Greenwich, Connecticut, and Palm Beach, Florida.

When the Postal Service explains why it is selling post offices, it usually says that because of declining mail volumes and changes in customer habits, many post offices have developed “excess capacity.”  And because the Postal Service is losing so much money each year, it’s necessary to sell off these big buildings and move to smaller quarters.

That explanation does not tell the whole story, however.  The unused space in post offices has several causes besides declining mail volumes.  It’s also due to the fact that the Postal Service has been consolidating mail-processing work, and workers are being transferred from downtown post offices to carrier annexes and other facilities, usually on the outskirts of town.  The excess capacity has also been caused by drastic reductions in the workforce over the past few years, a consequence of automation and outsourcing to pre-sort companies via workshare discounts.

In other words, the Postal Service has created this excess space in post offices.  It’s not simply due to declining volumes.  The Postal Service has privatized much of its mail processing operation, thus creating empty space in its facilities, and now it wants to privatize the facilities themselves by selling post offices to private-sector businesses.

In any case, the Postal Service put several historic post offices on the market in 2011, and in July 2011, it hired CBRE, the world’s largest corporate real estate company, as its exclusive real estate agent.  By then it was clear that the Postal Service had big plans to sell a significant number of historic post offices.

In June 2012, the National Trust for Historic Preservation recognized the problem and named America’s Historic U.S. Post Office Buildings to its 2012 list of America’s 11 Most Endangered Historic Places.  Several publications have taken note, including the Wall Street Journal, USA Today, and the New York Times, as well as foreign news media, like Liberation and the Guardian.

Numerous citizen groups have formed to fight the sales in their communities, appeals have been filed with the PRC, a lawsuit has been filed in DC district court, and a major postal law firm has been retained by a national citizens group.  Elected officials in Washington have also tried to stop the sales.  Congressman Henry Waxman filed an appeal on Santa Monica with the PRC, Congresswoman Susan Davis has proposed legislation that would help communities and non-profits buy their post offices, and several senators and congressmen, as well as mayors and state legislators, have appealed to the Postal Service to stop the sale of post offices in their districts.

The momentum challenging the sell-off may be growing, but we appear to be a long way from stopping the sales.  The leaders of the Postal Service always seem to think they know better than anyone else what’s in the best interest of the postal system and the country it’s supposed to serve.

 

The plans

The OIG says that it’s going to review the Postal Service’s plans for the disposal of its historic properties.  It will be interesting to see if the Postal Service even acknowledges that it has such a plan.  Management would probably prefer that the sales be viewed as proceeding on an ad hoc basis.  If there were an actual plan, a written report sitting on someone’s desk in L’Enfant Plaza, the public would expect to see it.

The Postal Service’s annual report to Congress contains a paragraph that refers to “generating revenue through the disposal of excess properties.”  It says, “To date, we have reviewed over 4,000 facilities, resulting in the identification of over 600 buildings earmarked for disposal.”

That’s about all the Postal Service has had to say about its plans to sell post offices.  When the New York Times asked for more details, the Postal Service said that most of the 600 were not even buildings that the agency owned; many were leased properties.  But the Postal Service does not use the term “disposal” for leased properties, and that bit of dissembling is unfortunately typical of how the Postal Service deals with the media and the public.

Thus far, the Postal Service has been very vague and evasive about how many post offices it might sell, and it has refused requests by the media to provide a list of which post offices are currently being sold or reviewed for sale.  When reporters ask the Postal Service which post offices may be sold, they are typically referred to the USPS-CBRE website, which lists a few of the facilities for sale, but not all, and there are many more post offices obviously in the process of being sold.

Hopefully, the OIG will ask the Postal Service to provide details about its plans: Which historic post offices have been sold over the past couple of years?  Which ones are currently on the market?  Which ones are now being reviewed for sale?  Which ones are likely to be reviewed for sale over the next year or two?  How many of the 600 facilities already earmarked for disposal are historic buildings?  What were the criteria for selecting these buildings for disposal?  How many other post offices will be reviewed for disposal over the next few years, and how many of them might be historic properties?

 

The inventory

The Postal Service has not published an inventory of its historic properties, so it’s difficult to know which post offices might be at risk.  In its announcement about the audit, the OIG says that as of December 2012, 998 postal buildings were on the National Register.

That number probably comes from the USPS Postal Facts, but we’ve been unable to verify it.  Last year the Postal Service shared an ad-hoc list of all the post offices on or eligible for the National Register.  It identified 523 post offices on the National Register, with another 449 listed as status unknown.  That adds up to something near 998, but nearly half of them with status unknown.  The Postal Service’s list also shows 1,519 as eligible but not on the Register.  (This list is here.)

In examining the Postal Service’s list, we found that nearly a hundred post offices identified as on the National Register had been sold, so we produced our own list of 437active post office buildings owned by the Postal Service that are on the National Register.  That list is here, and an interactive map is here.

The National Register data base is huge, with over 80,000 listings.  (This list is here.)  A search for post offices produces a list of about a thousand, but over half of them appear to be no longer active as post offices, and they’re not owned by the Postal Service anymore.

Overall, then, there are probably around 430, maybe as many as 500, active post offices on the National Register.  It’s doubtful that there are 998, as indicated on the Postal Facts page.

There are many more historic post offices that have not been nominated to the National Register.  The Postal Service’s list shows about 2,550 post offices as on or eligible for the National Register by virture of the fact that they were built over 50 years ago, a general benchmark for nomination to the Register.   The list shows 13 as disposed of, but when we examined it more closely, we found that as many as 387 had been sold, so that there are probably around 2,140 active post offices on or eligible for the National Register.

As these conflicting numbers indicate, it’s not easy getting an accurate inventory of historic post offices, as discussed in this previous post.  The lists we’ve developed are obviously not official, and they have numerous errors.  It would therefore be very helpful if the OIG asked the Postal Service to produce an up-to-date list of all the currently active post offices that are on the National Register and that are eligible for it.  It also would be very useful to see a list of post office buildings on the National Register that are no longer active post offices.

 

The numbers

In its announcement on the audit, the OIG states, “Over 50 of these historic buildings have either been sold or are on the market to be sold.”   That number probably comes from Save the Post Office, which seems to be the main source compiling such information.

The OIG’s statement suggests that the 50 or so historic buildings sold or on the market are all on the National Register, but that’s not quite right.  About 22 of them are on the Register; another 36 or so are eligible but have not been nominated.  A list and map of those sold recently, on the market, or under review, are here.

Just to put the numbers in historical context, consider this:

In 1971, when the Postal Service was created out of the Department of the Post Office, the GSA transferred title on something like 2,781 postal facilities to the control of USPS. (You can see the list here, and download it here.)

The Postal Service still owns nearly all of them.  The USPS owned facilities lists show that about 2,550 post offices have been occupied since 1971.

That would mean, very roughly, that over the past forty years about 230 post offices built before 1971 have been sold.  Most of them were probably built during the New Deal, so they were over fifty years old when they were sold and would have been eligible for the National Register.

On average, then, over the past four decades the Postal Service has probably sold about six historic post offices a year.  That estimate is roughly in line with the fact that there are about 550 former post offices on the National Register, which were probably sold off over a period of 70 or 80 years — about seven a year.

If the Postal Service has been selling post offices at the rate of six or seven a year, you can why it is so alarming that nearly sixty of them have been sold recently or will be sold soon, especially when you consider that the list just keeps growing, some 600 post offices have been “earmarked for disposal,” and many more could soon be reviewed for disposal.

 

The complaints

The OIG plans to examine the whether or not the Postal Service has been following proper procedures when it sells historic post offices.  In fact, as the OIG should discover, there’s a lot of evidence to suggest that the Postal Service has not been following the legal requirements on closing post offices, relocating retail services, and selling historic properties.

One of the main goals of the legislation concerning these procedures is to ensure that the public and interested government and non-governmental agencies have an opportunity to comment and partner on the decision-making.

But time and again, the Postal Service has shown that it doesn’t really care what anyone thinks.  If postal management wants to close a post office and sell the building, that’s what will happen.  The process is simply a hurdle, not an opportunity to work with communities.

Citizen groups and elected officials have repeatedly criticized the Postal Service for its lack of transparency, unresponsiveness, and downright arrogance.  There have been numerous cases where it was clear that the Postal Service had made a final decision even before the community could have input.

In Derby, Connecticut, the Postal Service listed the post office for sale on its “Properties for Sale” website in January or February of 2013.  It then announced in March that it would be doing a relocation study.  The decision to sell the building was obviously made before the Postal Service had even begun the relocation procedure.  Soon after this fact was observed on Save the Post Office, the listing on the Derby post office was removed from the USPS-CBRE website.  (There’s more on Derby here.)

This past March, the postmaster in Redlands, California, put a note in customers’ post office boxes saying, “Effective April 1, 2013 Brookside Station Post Office will no longer accept renewals on your PO box unit.  Brookside Station is preparing for closure in the near future.  All services will be transferred to our main office located at 404 New York Street in Redlands.”  But as of April 1, the Postal Service hadn’t even begun a discontinuance process on the historic Redlands post office.  (There’s more on the Redlands case here.)

In Reading, Massachusetts, the Postal Service provided a minimum of public notice about the regular town meeting at which the relocation would be discussed.  The agenda allotted a half hour on the issue, and there probably won’t be another opportunity for the public to weigh in.  (There’s more on Reading here.)

In La Jolla, California, elected officials and several groups worked very hard to stop the sale of their historic post office.  After trying to deal with the Postal Service for over a year, the chair of the task force to save the post office observed that the Postal Service “behaved like an arrogant bully.  They have been dismissive, aloof, secretive and cocky.”  (More on La Jolla here.)

In the Bronx, the Postal Service made little effort to notify customers that there would be a meeting about the proposed relocation of retail services.  That provoked an angry letter from the Bronx Borough President and seventeen other elected officials, saying they were “appalled” that the Postal Service had made a final decision on selling the Bronx post office rather than pursuing engagement with community stakeholders and elected officials.  (More on the Bronx sale here.)

 

The process

The Postal Service was given authority to sell post offices when the GSA transferred title to the newly created Postal Service back in 1971.  But just because it has the authority to sell buildings doesn’t mean that the Postal Service can do whatever it wants.  There are several statutes and regulations, as well as presidential orders, that control how post offices are closed and how federal properties are managed and disposed of.

The Postal Service seems to have managed to violate most of these laws and regulations.  It has repeatedly displayed bad faith in conducting the public participation process, and while it makes an effort to follow the letter of the law, it completely misses the spirit.  The modus operandi of postal management is always the same: decide first, consult later.

Attorneys for the National Trust have complained on several occasions about how the Postal Service has been doing the closures.  The OIG quotes the Trust’s announcement about putting the historic post office on its endangered list as follows: “The lack of a transparent and uniform national process from the Postal Service — one that follows federal preservation laws when considering disposal of these buildings — is needlessly placing the future of many historic post office buildings in doubt.”

The National Trust has looked into some of the legal problems in the way the Postal Service has been doing the sales.  Its letter to the Postal Service about the Berkeley post office provides a good overview.  There’s more in letter to the Postal Service written by the Advisory Council on Historic Preservation about the Venice post office.

Additional legal problems with the Postal Service’s failure to follow proper procedures have been identified by attorney Elaine Mittleman, who has brought a suit against the Postal Regulatory Commission concerning its decision on the Venice appeal.  At the heart of the suit is the Postal Service’s failure to follow Section 106 of the National Historic Preservation Act (NHPA) in its handling of a famous mural inside in the post office.

The National Post Office Collaborate, a group fighting the sale of the post offices in the Bronx, Berkeley, and elsewhere, has hired the law firm of Ford & Huff, and its appeal letter on the Bronx post office identifies even more problems with the way the Postal Service is conducting the closures and sales.

Hopefully the OIG will review the documents produced by all of these attorneys as it examines how the Postal Service is or is not following legally mandated procedures.  Here’s a summary of some of the alleged violations.

 

The violations

1. In order to sell a post office, the Postal Service must first close it, and there are federal regulations concerning the closure of post offices.  The Postal Service claims that if it plans to reopen a new retail facility somewhere else, it’s not really closing the post office so it doesn’t have to follow the regulations on a discontinuance (39 CFR 241.3).  Instead, it need only follow the less stringent relocation procedures (39 CFR 241.4), which deals with the “Expansion, relocation, and construction of post offices.”

But 241.4 contains a passage that states that when the relocation also involves a historic property covered under the National Historic Preservation Act, the Postal Service needs to follow the discontinuance procedures because in these special cases it’s important to follow the procedures that result in greater community participation.  This issue is all explained in more detail in this post on the Bronx relocation.

2. Even though it’s obvious that the relocation decision and decision to sell are part of the same process, the Postal Service has been segmenting the process into two steps.  The Postal Service then claims that step one, relocating the retail services out of the post office, has no adverse effect on the historic property.  Only step two, the actual transfer of the property to a buyer, could have such an effect, so the Postal Service only needs to deal with the requirements of Section 106 of NHPA when it sells the building.

But NHPA regulations clearly state that a “change of the character of the property’s
 use … that contribute[s] to its historic significance” is an adverse effect.  It should be obvious that closing the post office within a post office building is a change in the property’s use, so the Section 106 consultation process should begin as soon as the Postal Service announces a relocation plan.

3. Delaying implementation of Section 106 in this manner also violates the NHPA in that the federal agency is supposed to consult with relevant parties like the Advisory Council on Historic Preservation early in the process.  Section 106 states that “the agency official shall ensure that the section 106 process is initiated early in the undertaking’s planning so that a broad range of alternatives may be considered during the planning process for the undertaking.”  By waiting until a relocation decision is already a done deal, the Postal Service renders the Section 106 requirements irrelevant.

4. One of the main goals of Section 106 is to ensure that a wide variety of alternatives are considered in order to avoid, minimize, and mitigate harm to the historic building.  The Postal Service has shown no interest in considering alternatives, like leasing out the extra space in the building.

5. The transfer or sale of a historic post office building should be subject to a preservation covenant so that the building is protected after it passes out of federal hands, but the Postal Service has argued that only murals within the building that can’t be moved are of concern.  In the absence of a covenant and a third party able to monitor and enforce the covenant, there is the potential for an adverse effect on the property.

6. Section 111 of the NHPA states that federal agencies should consider adaptive use, lease, or exchange before outright transfer of a historic property out of federal control.  The Postal Service seems interested only in one option — selling the building — and may thus be in violation of this section as well.

7. Executive Order 12072 states, “Federal space shall conserve existing urban resources,” and it goes on to say that “procedures for meeting space needs in urban areas shall give serious consideration to the impact a site selection will have on improving the social, economic, environmental, and cultural conditions of the communities in the urban area.”  Closing down a historic post office clearly has deleterious effects on the urban fabric, thus putting the Postal Service in violation of this executive order.

8. Executive Order 13006 directs federal agencies not only to locate their operations in established downtowns, but also to give first consideration to locating in historic properties within historic districts.  In many cases, the Postal Service has relocated retail services from a downtown post office to a carrier annex on the outskirts of town, and one of the main concerns has been the impact of relocations on the downtown economic activity.

9. Executive Order 13287 “directs federal agencies to increase their knowledge of historic resources in their care and to enhance the management of these assets.”  It also “encourages agencies to seek partnerships with state, tribal, and local governments and the private sector to make more efficient and informed use of their resources for economic development and other recognized public benefits.”  The Postal Service has done almost nothing to fulfill these obligations.

10. The Postal Service has not complied with the National Environmental Protection Act, which requires that federal agencies consider the environmental effects of their actions.  The Postal Service has avoided the requirement to prepare an Environmental Impact Statement (EIS) when it plans a particular sale by simply declaring that the sale will not have a “significant” impact, even though potential impacts include social and economic considerations, like harm to local businesses.

The Postal Service has also avoided doing an EIS on the cumulative impacts of doing a large number of sales across the country.  Last year, the Postal Service conducted a “Programmatic Environmental Assessment” (PAE) of various aspects of the consolidations of mail processing plants.  As part of the PAE, the Postal Service needed to consider the cumulative impacts of closing several historic processing plants and numerous historic post offices.  But the Postal Service declared a Finding of No Significant Impact (FONSI), and therefore did not proceed to do an EIS.  (That issue is discussed in this previous post.)

11. Another aspect of the sales involves the works of art inside the post offices, such as the murals and sculptures commissioned during the New Deal.  While the GSA transferred title to the buildings to the Postal Service, the art remained subject to the obligations and requirements of a public trust.  The Postal Service claims to take particular care of the murals and other art work in posts offices, but it has not been fulfilling its obligation to ensure public access to the art after a building is sold.  For example, when it transferred ownership of the Venice post office to a film producer, there was insufficient effort to ensure that the mural would be made available to the public on a regular basis.

 

The broker

Another aspect of the sales that needs to be further explored further is the role of the Postal Service’s real estate broker, CBRE.  The OIG has already done a review of the Postal Service’s contract with CBRE, but it focused primarily on the leases.  The OIG should look into the sales as well.

The Postal Service has provided contradictory information about the role of CBRE on these sales.  In one news article about the controversial sale of the Berkeley post office, both the Postal Service and CBRE told a reporter that “when CBRE handles the transactions, it does not advise the Postal Service which facilities to put on the market.”

But another news article describes CBRE “as an advisor on which properties should be sold.” Dismissing any possible conflict of interest CBRE may have in performing its services, a USPS spokesperson said, “They’re just giving advice, it’s up to us if we want to take it.”

It’s obviously a matter of some interest whether or not CBRE is advising the Postal Service on which properties to sell.  CBRE makes a sizable commission off each sale, and when the Postal Service relocates retail services to a new space, CBRE makes a commission on the new lease as well.  CBRE thus has a double incentive to see more relocation-and-sale deals take place, so it’s not exactly unbiased if its role includes recommending which post offices to sell.

There’s also been a lack of transparency about the contract with CBRE, which itself has never been made public.  This has led to a number of accusations about a conflict of interest because the chairman of the board of CBRE is Richard Blum, husband of Senator Dianne Feinstein.  A blog post about this has recently gone viral and led to a number of efforts to fact check the accusations.

 

The money

In order to provide some background for why the Postal Service is selling historic post offices, the OIG states, “Last year, the Postal Service lost $15.9 billion, more than three times the amount lost in 2011.”  In this context, then, the OIG poses the question, “considering its financial constraints, what should the Postal Service’s role be in maintaining historic assets?”

It’s unfortunate that the OIG slants the case for selling post offices this way.  The Postal Service obviously faces “financial constraints,” but citing the loss of $15.9 billion in 2012 is very misleading, as the OIG knows well.  That $15.9 billion includes over $11 billion in payments to the Retiree Health Benefits Fund (RHBF), as well as adjustments to the long-term workers compensation fund.  And it’s not just for one RHBF payment but for two, since the Postal Service skipped the 2011 payment.  Like the misleading meme that the often repeated by postal officials that the agency is losing $25 million a day, the big loss in 2012 is not an accurate indication of the Postal Service’s true financial situation.

As the OIG has documented in numerous early audits and reports, the Postal Service actually has huge surpluses in its retirement funds.  If these surpluses had been cited instead of the $15.9 billion loss from last year, it would have cast the sale of historic post offices in an entirely different light.  It would show that the sales have very little to do with solving a financial problem.

Most of the Postal Service’s historic post offices are relatively modest buildings, worth less than a million dollars.  For example, several historic post office are currently listed on the USPS-CBRE “Properties for Sale” website: Northfield, Minn., at $795,000; Norwich, Conn., at $499,000; Villa Park, Ill., at $450,000; and Camas, Wash., at $564,000.  These four average $543,500.

Most historic post offices aren’t very large.  These four average 13,060 square feet, somewhat less than the average of 18,700 square feet for the 2,530 post offices on or eligible for the National Register.  The average sale price for these four post offices is $42 per square foot.  While a few have proven to be worth much more — like the New Deal post office in Palm Beach, Florida, which went for $3.7 million — $42/sf is probably a reasonable average.

At an average size of 18,700 sf, and an average selling price of $42/sf, selling all 2,530 historic post offices would bring in about $2 billion.  Even at twice that price per square foot, selling all the historic post offices might bring in $4 billion.

These post offices would need to replaced by facilities in leased space.  If lease costs averaged $3,000 a month, the total cost over ten years would be nearly $1 billion; over forty years, $4 billion.  Over the long term, the one-time revenue from selling the buildings would be canceled out by the cost of leasing.

Or look at it this way.  According to the PRC’s annual compliance report, the Postal Service is losing $1.5 billion every year because it undercharges for some types of mail.  The losses for just one or two years are in the same ballpark as the total revenue that selling every historic post office would bring in.

Selling all those post offices would do immeasurable harm to 2,500 communities,. For the Postal Service, it’s just a line on its financial statement.

 

The GSA

The OIG’s audit will apparently consider not only the disposal of historic properties but also the possibility of preserving and maintaining them.  It would certainly be a welcome result if the OIG were actually to recommend to the Postal Service that it stop selling off its historic assets and explore alternatives.

The Postal Service should look to the General Services Administration as a model for how it could be dealing with historic properties.  The Postal Service owns many more historic buildings than the GSA but shows much less interest in preserving them.

The GSA owns more than 400 historic buildings that are listed or eligible for listing in the National Register, and more than 800 buildings that are at least 50 years old.  The Postal Service says it owns a thousand post offices on the National Register (as discussed above, a more accurate number might be 430), and it owns about 2,500 buildings that are at least 50 years old.

Even though the Postal Service’s historic properties far outnumber the GSA’s, the GSA has a large staff devoted to historic preservation, with offices all over the country, while the Postal Service employs only a federal preservation officer and a historian.

The GSA website devotes many pages to historic properties.  It has a Center for Historic Buildings, a historic preservation library, a portfolio of its historic properties, variety of other resources.  The Postal Service has nothing like this.  There’s a page on the New Deal murals, and that’s about it.  Someone interested in historic post offices, murals in particular buildings, and the like, would need to turn elsewhere.  Even the Postal Museum offers almost nothing about historic post office buildings.  It’s been left to post office aficionados like Evan Kalish and Jimmy Emerson to do most of the photographic documentation.

The GSA takes pride in the size and significance of its historic building portfolio, and it has become a national leader for compliance with the NHPA and other stewardship directives. The Postal Service seems more interested in evading compliance than anything else.

 

The possibilities

The Postal Service probably possesses more historic buildings than any other government agency or private business.  It could and should take a lead role in preserving the government’s historic assets.

The Postal Service should put some money into maintaining historic post offices, rather than letting them fall into disrepair.  Pointing to a deficit artificially exacerbated by those unnecessary payments into the RHBF is no excuse.  These buildings, and the communities they service, deserve better.

The Postal Service website should have a section documenting all of its historic assets — the buildings, the murals, and the other artwork.  There should be photos, historical background, and other materials for further research.  It should be a resource for academics, architects, and history buffs.

The Postal Service should boast about its legacy of post offices and use it as a marketing tool.  It could issue a stamp series that features historic buildings and another that features the New Deal murals.  It could put on exhibits in its historic buildings, offer space to artists, and encourage people to appreciate the buildings as architectural monuments.

The Postal Service could work with communities to nominate as many of the buildings to the National Register as possible.  It should hire more preservationists, historians, and architectural experts.  It should sponsor scholarly research and do things like work with the FDR library to put on an exhibit about New Deal post offices and murals.

The Postal Service should recognize that historic preservation is good business. As this report about the economic impacts of historic preservation by the Advisory council on Historic Preservation explains, preserving architectural landmarks makes good economic sense.  The report shows how historic preservation creates jobs, enhances property values within the historic district, contributes to tourism, and helps revitalize downtown commercial districts.

The laws and executive orders cited above recognize the economic value of historic preservation, and one of their main goals is to help maintain vibrant downtowns.  Yet it seems to be part of the Postal Service’s standard m.o. to close downtown post offices and open replacement offices in out-of-the-way carrier annexes and strip malls.  That’s not good for downtown businesses, and it drives customers away from the Postal Service itself.  The Postal Service should be contributing to the revitalization of city centers, not undermining the effort by closing downtown post offices.

 

The symbols

A couple of decades back, the National Register Bulletin devoted an issue to historic post offices and how to nominate them to the National Register.  It begins with the following passage:

“Post offices constitute the most common form of Federal government buildings in the nation.  Located in large cities, small towns, and rural areas, post offices provide an important presence of the Federal government in communities. They play an essential role in facilitating communication and promoting economic development, reducing the isolation of rural locales, and disseminating products and ideas across geographical areas. Historically, in times of economic stress, the construction of post offices has stimulated local economic recovery and provided work.

“Many post offices are significant civic monuments that beautify the cities and towns in which they are located.  Architecturally, post offices have served as symbols of the Federal government’s authority, conveyed regional historical themes, and exemplified high art forms.”

Unfortunately, the leaders of today’s Postal Service do not seem to grasp the import of these words.  They look at historic post offices and just see a source of some quick cash.  They don’t seem to understand the symbolic value of the architectural inheritance they’re supposed to be stewarding.

The Postal Service’s 2013 Postal Facts brochure has a page about historic post offices and the murals and sculptures produced during the New Deal.  This page did not appear in previous issues of Postal Facts, so apparently someone in the Postal Service has started to pay a little more attention to its legacy assets.

The page begins, “The Postal Service is very proud of its history — its foundation — and has worked hard to preserve it.  Numerous postal buildings are listed with the National Historic Register and many others house works of art from the Postal Fine Arts Collection.”

Paying lip service to this history is hypocritical.  If the Postal Service really did take pride in postal buildings and the art within them, it would not be selling the buildings to the highest bidder and arranging covenants on the murals that allow people to see them a few times a year (as it did in Venice).

Post offices are civic monuments and symbols of the government’s prestige.  Transferring ownership of these buildings into private hands — turning them into restaurants and real estate offices and clothing boutiques and film studios — is a travesty, pure and simple. It’s a violation of the public trust, and given the relatively small amount of money the sales generate, it’s totally unnecessary.

 

The dismantling

It’s important to recognize that selling post offices is not happening in isolation.  It’s just another aspect of the process of privatization that’s been going on ever since the Postal Service was created in 1971.

The dismantling takes many forms: outsourcing work to private suppliers, transferring processing operations to presort companies, “partnering” with competitors like FedEx and Pitney Bowes, replacing full-time career employees with part-time temporary workers, downsizing the workforce, authorizing private businesses to do retail postal business, encouraging customers to do their business at locations other than post offices, and so on.  Selling off real property is one of the more obvious forms of privatization because it so blatantly transfers assets from public to private hands.

Unfortunately, some people have let their opposition to Big Government turn into opposition to anything that reminds people that the government can do great things, like building beautiful post offices.  Some of these people are in Congress, where they have used their power to put the Postal Service in a financial bind that helps postal officials justify dismantling an infrastructure that took centuries to build.

It’s not likely that the OIG will be able to do much to stop the process — if it has any interest in doing so — and the sale of historic post offices will probably continue.  But at least the OIG is examining the issues.

The OIG’s audit has an estimated report date of October 10, 2013.  One wonders how many historic posts offices will be sold by then.

The documents

At this point, the file of materials concerning the sale of historic post offices has grown quite fat.  It contains letters to the Postal Service from government officials and legal firms; legal briefs; letters from citizen groups and postal officials; government reports; federal regulations and executive orders; articles in the media, and much else.  A working bibliography is here.

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