On July 27, 2011, the US Postal Service submitted a request to the Postal Regulatory Commission for an Advisory Opinion about its Retail Access Optimization Initiative (RAOI), and the PRC opened Docket No. N2011-1, which will contain all of the testimony and related documents for the case.
N2011-1 is likely to go down in history as one of the most important dockets ever to be considered by the PRC. The outcome of this process may determine the fate of the brick-and-mortar post office in America.
Here’s where we are as of August 8, 2011.
The Postal Service has requested an Advisory Opinion, and its first witness, James J. Boldt, has presented testimony elaborating on the plan. The chairman of the PRC, Ruth Y. Goldway, has submitted a list of materials she wants the Postal Service to provide as part of this “discovery” phase of the proceedings. The PRC has designated Tracy Ferguson as the Public Representative, and she too has provided a list of things she wants from the Postal Service. There’s also a Limited Participant named David Popkin, who has submitted a request for still more information. The Postal Service has replied to some of Popkin’s requests, but not the others. There’s also an issue of two documents that the Postal Service does not want made available to the public.
We can now see the argument that the Postal Service is making to defend its RAO Initiative, and we can also begin to see what shape the challenge to that plan may take.
The Postal Service has released two lists, the RAOI list of 3,653 post offices that will be studied for closing, and a list of 727 post offices already under study. In order to explain how it embarked on the closings without asking for the Advisory Opinion until now, the Postal Service is saying that these 727 were “locally-initiated proposals” developed on an “ad hoc” basis—i.e., there was no plan coming from Headquarters ("the plan is we have no plan"). Of course, that does not explain how the Postal Service could say, as recently as July 14, when it published changes to the closing procedures in the Federal Register, that concerns about such a plan were “speculative and premature." It has obviously been preparing the RAO initiative for some time.
The Postal Service is not going to wait to hear the Advisory Opinion before initating the closing process on the RAOI post offices. It says that there's no actual change in service until the post office closes, so it can do its studies while the PRC does its Opinion.
Thanks to its new computer system and the revisions to the closing procedures recently announced by the Postal Service, the process to close a post office now takes 138 days — less than five months. It used to take nine months. That means we’re going to see some post offices on the RAOI list closing before the end of the year.
According to testimony to the Postal Regulatory Commission given by James J. Boldt, National Manager, Customer Service Operations, and the man directing the closure process, USPS field managers were advised on July 26, 2011, to begin feasibility studies of the post offices on the RAOI list. You can start counting to 138 from there.
Over the coming days and weeks, patrons of these post offices will begin seeing notices in their post offices announcing that the 60-day comment period has begun, surveys will be distributed, a public meeting will be scheduled, etc. That’s followed by a couple of weeks during which the Postal Services reviews the information that’s been gathered and makes a decision. Boldt says final determination notices could begin being posted in late October, and some post offices on the list could be closed before the end of the year. Representatives of the postal service have also told this to the media.
In the meantime, many of the 727 post offices already initiated for closure will continue to be closed. Since the beginning of the year, about two hundred post offices have been closed, but that pace will pick up considerably over the coming months.
The Postal Service’s case is presented, so far, in two documents, the Request for the Advisory Opinion and Boldt’s testimony. The crux of the argument is, as anticipated a few weeks ago on this website, that there are many alternative access outlets where people can do postal business, and these are a legitimate alternative to the post office. The Postal Service is therefore not causing a significant degradation of service — it is not violating its universal service obligation — by closing thousands of post offices.
So far, it seems that the main issues are how much postal patrons will be inconvenienced if their post office closes — how far away is the nearest postal facility? — and how much money the Postal Service will save by closing a post office that isn’t making much money.
The social and economic value of the post office to a town or neighborhood does not seem to be on the table. There seems to be no discussion going on, at least so far, about what role a post office plays in a community. But last year the PRC did commission a study on the “social value” of postal services, including post offices, so it has material about this subject in its files, and local politicians and others will be called to give testimony about this topic as well.
For more details, here are summaries (with a little commentary) about the contents of the docket. (You can find these pages listed on the sidebar "PRC Advisory Opinion" as well.)
- The USPS Requests an Advisory Opinion
- The Testimony of James J. Boldt for the USPS
- The PRC responds to the request for an Advisory Process
- Presiding Officer’s Information Request No. 1
- Interrogatories of the Public Representative
- Interrogatories of the Limited Participant and USPS Responses
- Issues over the two documents under seal