By Steve Hutkins
The Postal Service has been publishing announcements about post office discontinuances in Postal Bulletin since 1880. The publication is the official record for post office changes. But not anymore.
In the September 8, 2022, issue of the Bulletin (page 10), in the section where recent discontinuances are normally listed, one finds the following note:
Due to the extensive number of offices on the Discontinuance List, the changes will not be published in this Postal Bulletin. Instead, the link at the end of this article will take you to a document which includes the Post Offices which have been suspended for years. Customers in these communities are being served by nearby offices.
The listings in this document represent the administrative action of the Postal Service™ officially closing these offices. To access the list of affected Post Offices, visit postalpro.usps.com/POB_22606.
This link to the PostalPro website goes to a list of 57 discontinuances that did not make it into Postal Bulletin simply because there were too many of them.
That makes 85 discontinuances that did not get a notice in Postal Bulletin. For these offices, PostalPro — a resource website used mostly by business mailers — has become the new location of the official record.
The suspension backlog
These post offices are all facilities that had been closed for an emergency suspension several years ago — many of them, over ten years ago. They are part of a backlog of over 660 long-term, unresolved suspensions that had developed as of 2016 (as discussed here). The Postal Service has been working to clear up the backlog— at the urging of the Postal Regulatory Commission in its annual compliance reports as well as two Public Inquiry dockets — but progress has been slow.
In 2017 the Postal Service closed the books on over 300 suspensions, but the following year it turned its attention elsewhere and little progress was made until 2022. (For more info, see our Suspension Dashboard. The most recent update on the fate of the backlog of 660 is here.)
In May 2022, the Postal Service explained to the Commission that the effort to resolve these suspensions had been hampered by the pandemic and organization changes made in 2020, but it was now prepared to resume its efforts. At that point the backlog consisted of about 450 suspensions.
The Postal Service told the Commission that it had identified “170 sites that qualify for swift official Discontinuance.” There really wasn’t much left to do: almost all of these offices had gone through the entire discontinuance process — except for the announcement in Postal Bulletin. (More info here; a list of the 170 is here.)
The Postal Service planned to complete this project by the end of September 2022. Over this past summer, it discontinued 126 of these 170 post offices, as well as a couple of others that weren’t on the list. For 43 of them, the closings were announced, as usual, in several issues of Postal Bulletin. But for 85, there was no listing in the Bulletin.
A list of the 128 discontinuances from FY 2022 is here. Here’s a map, with separate layers for those that did appear in Postal Bulletin and those that did not.
Cutting printing costs
PostalPro has been publishing post office changes that appear in Postal Bulletin for many years, but this is the first time the PostalPro list has completely replaced the Postal Bulletin listing.
The change in policy was first noted by Bill McAllister in Linn’s Stamp News. Surprised by the announcement in the Sept. 22 issue of Postal Bulletin about the change, McAllister asked the Postal Service for more information.
USPS spokesman David Partenheimer explained that “increasing printing costs” led the Postal Service to devise an “alternative format” when the list of post office changes gets too large to print — those that exceed three pages or 27 changes. Instead of being listed in the Bulletin, they will be listed on PostalPro.
The new format doesn’t just apply to lists of discontinuances. Partenheimer told Linn’s that mail labeling items and even policy articles would fall under the new policy. “Otherwise,” he said, “our printing costs and page count would be too high.”
This explanation for omitting the discontinuances from Postal Bulletin is dubious at best.
Space at a premium
The Sept. 22 issue of the Bulletin would have had 28 discontinuances — just one more than the new, self-imposed limit of 27 changes, but enough to justify omitting all of the announcements.
As for the Sept. 8 issue, here’s the digital version (best viewed as full page using the link on the bottom right):
This issue consists of 48 pages. Listing 57 discontinuance would have taken about 7 pages. While this is obviously over the new 3-page limit, the issue managed to find space for the following:
- 1 full page for a large image advertising a forthcoming stamp honoring women’s rowing;
- 2 pages promoting a forthcoming series of Snowy Beauty Stamps;
- 9 pages listing the numbers for Missing, Lost, or Stolen Money Order Forms;
- 6 pages of information about overseas mail, including a 4-page list of numbers;
- 7 pages with more stamp announcements, and
- 9 pages listing pictorial postmarks and first day of issues.
There’s also plenty of white space on many pages that a layout editor might have made better use of.
It’s hard to understand how all these contents were deemed more important than announcing post office discontinuances. Providing information about the establishment and discontinuance of post offices, site location changes, and other post office changes, was one of the original purposes of the Bulletin in the 19th century, and this remains one of its main functions.
It’s also not clear why the long lists of money orders, overseas mail, and stamp announcements — all more than three pages — were published in spite of the new policy.
In any case, if space were really a problem, the Postal Service could have spread out the list of 57 discontinuances over three issues. The announcements are not exactly time-sensitive, given that these post offices closed many years ago. It was entirely under the control of postal management to determine when the final announcements were made in Postal Bulletin.
It’s also worth noting that while the Sept. 8 and Sept. 22 issues both have 48 pages, there doesn’t seem to be a new policy about going beyond that. The Oct. 6 issue has 56 pages and the Oct. 20 issue has 60 pages.
The PostalPro listings are easy to view and download — if you can find them — but they are not comprehensive. Most notably, 304 discontinuances that appeared in the August 17, 2017 issue of Postal Bulletin (also part of the backlog of 660) do not appear at all on the PostalPro website. For that reason alone, PostalPro cannot be seen as anything like an official record, and it is no substitute for Postal Bulletin.
A different explanation for not publishing an “extensive number” of discontinuances in the Bulletin is suggested by comments made by the Postal Service in its FY 2016 Annual Compliance Report. There the Postal Service explains why it had been holding off announcing hundreds of discontinuances (on those long-term suspensions) in the Postal Bulletin:
Retail discontinuance actions often elicit questions and concerns from stakeholders, both at the federal and local level, and confusion can arise whenever a large scale effort to discontinue retail units, even those that are in longstanding suspended status, are announced. Further, clearing the backlog of suspensions could have complicated efforts at the federal level to secure necessary consensus on ongoing legislative reforms under consideration. Consequently, action on clearing the backlog of suspensions was essentially deferred in FY 2016.
As of the end of FY 2016, 264 suspended facilities had undergone the retail discontinuance process to its conclusion, except for publication of the announcement of the discontinuance in the Postal Bulletin under Handbook PO-101 § 422.34.
In other words, even though the Postal Service had completed the discontinuance process on 264 post offices, management held off the Postal Bulletin announcement because of what it would look like and how it might affect efforts to achieve postal reform.
One therefore has to ask if the decision not to publish long lists of discontinuances in the Postal Bulletin has less to do with managing printing costs and more to do with managing public perception.
The Postal Bulletin notices represent the official record of discontinuances, the final step in a 30-step process to close a post office (explained in this PRC order). Policies about the announcements are mentioned several times in the Handbook PO-101: The Discontinuance Guide (see, for example, section 422.34).
More importantly, federal regulations actually require the Postal Bulletin announcement. 39 CFR § 241.3 — “Discontinuance of USPS-operated retail facilities” — states that “the official closing date of the office must be published in the Postal Bulletin and effective, at the earliest, 60 days after the first day that Final Determination was posted.” (emphasis added)
The regulations do not give the Postal Service the authority to announce a discontinuance someplace other than in Postal Bulletin.
The fact that some post offices did not rate a notice in the Postal Bulletin, as unprecedented as it may be, should not come as a complete surprise. The Postal Service has a long history of not following regulations for suspensions and discontinuances (as discussed in this OIG report).
That’s especially true for long-term, unresolved emergency suspensions. The mere fact that a post office could be held in the limbo of an emergency suspension for a decade or more — not open, but not officially closed — is itself inconsistent with the spirit, if not the letter, of the federal regulations on suspensions and discontinuances.
The Bulletin as archive
Discontinuance notices have been published in Postal Bulletin since its first issue, on March 4, 1880. Prior to 1919 the publication was called the Daily Bulletin of Orders Affecting the Postal Service. (There’s more about the history of the publication here.)
As of 1895, there were more than 70,000 post offices. In 1896, rural free delivery reduced dependence on post offices, and over the next two decades 20,000 closed. They continued to close at a fairly steady pace —about 200 a year — until 2014, when discontinuances essentially came to a halt, except for those involving the long-term suspensions.
There are now about 31,000 post offices, so over the past 120 years something on the order of 40,000 post offices have been discontinued. It’s reasonable to presume that an effort was made to include every one of these discontinuances in the Bulletin.
That is just one of the reasons the Bulletin is so valuable. According to historian Tony Wawrukiewicz (writing in the Postal History Journal), the Postal Bulletin “is an incredible resource for a person who wishes to understand POD operations and policies, locations for its services, types and rates for services, processes by which it functions, etc. In other words it is a voluminous source of research information.”
One can now search the archives of the Bulletin to find information about any discontinuance from 1880 to 2016, a task made easier by the digitized Postal Bulletin project, for which Wawrukiewicz was the main contributor. For more recent issues, the Postal Service maintains this site.
But of course you won’t be able to find the 85 discontinuances from Sept. 8 and Sept. 22 because they didn’t appear in the Bulletin.
There are still over 250 long-term suspensions on the backlog list, 79 of them from the 2016 list of 660. Hopefully, the Postal Service will complete the discontinuance process for these post offices sooner rather than later, and hopefully the final discontinuance notices will be published in the Postal Bulletin and not just PostalPro. And hopefully, should the Postal Service embark on a plan to close hundreds or thousands of post offices — as promised by the 10-year plan — it will not omit the discontinuances from Postal Bulletin.
As a matter of fact, there’s nothing preventing the Postal Service from publishing the notices on the 85 offices omitted from Postal Bulletin in future issues. Maybe the PRC could encourage the Postal Service to do just that, if for no other reason that it would ensure the Postal Service is in compliance with 39 CFR § 241.