The Optimization plan as discussed in the PRC’s Public Inquiry Docket

Steve HutkinsUncategorized

This post contains excerpts from USPS filings with the PRC concerning the plan to eliminate evening collections at many post offices. It’s been various identified as Optimized Collections, aka Local Transportation Optimization, aka Regional Transportation Optimization. Most of this material is from the Public Inquiry on DFA.

RESPONSES OF THE UNITED STATES POSTAL SERVICE TO QUESTIONS 1-12 OF CHAIRMAN’S INFORMATION REQUEST NO. 5 (Link to PRC website)

(December 4, 2023)

  1. Please confirm the Optimized Collections Plan is part of an initiative listed in Library Reference USPS-LR-PI2023-4-NP1, Excel file “Cost_Initiatives_DFA_10YrForecastSteps_NP.xlsx

a. If confirmed, please provide the Get It Right (GIR) initiative number of the initiative.

b. If not confirmed, please provide the name of the initiative that encompasses the Optimized Collections Plan, the GIR initiative number for this plan, and any workpapers or validation documentation associated with this plan.

RESPONSE:

Not confirmed. The Optimized Collections initiative was not part of the 2021 list of initiatives set forth in USPS-LR-PI2023-4-NP1. As noted in response to prior information requests in this docket, the DFA Plan is a living plan, and the specific initiatives being pursued to decrease transportation costs, create an effective processing network, and ensure efficient delivery operations are subject to ongoing cycles of evaluation and adjustment. As the Postal Service has moved forward with the Plan, the specific initiatives that are being pursued have evolved based on Postal Service management’s improved understanding of the underlying conditions of our organization, and how to best correct those conditions using modern and precise operating practices.

Optimized Collections is a new initiative that is planned for implementation in FY2024 and in future years as a means to further organize and optimize our transportation network. Our local transportation network is currently characterized by a large number of underutilized and unnecessary trips, due to the fact that the Postal Service currently operates separate trips to pick-up and drop-off mail and packages from delivery units. This leads to underutilization and high costs, particularly on longer local transportation lanes that transport lower amounts of volume. Pursuant to this initiative, the Postal Service would for such lanes pick up originating volume entered the prior day on the same trip that is dropping off the destinating mail for delivery, based on application of the criteria discussed in Question 4. This will serve to reduce the overall number of transportation trips and stops, and to improve utilization, while still allowing the Postal Service to perform successfully within the existing service standards. In addition, eliminating these unnecessary and underutilized trips would also reduce our carbon emissions, and therefore align with our carbon reduction initiatives. Our current inefficient and costly transportation network is unsustainable, and taking these and other steps to address our transportation costs is a critical element of generating the overall level of savings that are needed from self-help operational initiatives in order to achieve financial sustainability.

Optimized Collections is part of the FY2024 GIR process (initiative number 264), but GIR materials related to the initiative are still being developed, and have not been finalized.

2. Please refer to slide 5 of the USPS Presentation, which provides a list of locations for the Optimized Collections Plan. USPS Presentation at 6.

a. Please confirm the Optimized Collections Plan was implemented in Richmond, VA on October 28, 2023. If not confirmed, please explain.

b. Please confirm the four potential expansion locations for the Optimized Collections plan include Columbus, OH; Madison, WI; Oklahoma City, OK; and Santa Clarita, CA. If not confirmed, please explain.

c. If question 2.b. is confirmed, please provide a timeline for each of the potential expansion locations.

d. Please provide a list of any other locations for potential expansion and include the timelines for expansion locations.

RESPONSE:

(a) Confirmed.

(b) – (d) The Postal Service is actively planning to roll out Optimized Collections in Madison, WI, as well as in Green Bay, WI, and Milwaukee, WI. While the Postal Service intends to implement Optimized Collections in other areas (which could include those referenced in the question), no final decisions have been made regarding whether to do so, or the timeline for implementation.

In this regard, while the Postal Service intends to pursue a rapid pace of implementation in recognition of the critical importance of implementing this initiative (for the reasons discussed in the response to Question 1), the Postal Service is pursuing a deliberate, structured, and systematic implementation process for Optimized Collections. Prior to implementing Optimized Collections for any potential geographic area, the Postal Service engages in a comprehensive analytical exercise, employing the criteria discussed in more detail in response to Question 4, to identify which locations are appropriate for optimization, and the resulting changes to the transportation schedule that will be implemented. The Postal Service is currently engaged in this process for the three locations discussed above, which has not yet been completed; the Postal Service intends to complete the process later this month, with implementation planned to occur on January 8, 2024.

3. For each location confirmed in the response to questions 2.a. and 2.b., and any additional locations listed in the response to question 2.d., please provide the information requested in sub-questions a. through c. If the information is not available for any locations, please explain:

a. Facilities affected by the Optimized Collections Plan

b. Collection pick-up times at each facility listed in question 3.a., before and after implementation of the Optimized Collections Plan

c. Impact on transportation of mail between processing centers and post offices

RESPONSE:

See USPS-LR-PI202304-NP5, which provides facility-specific information regarding the implementation of Optimized Collections in Richmond. As discussed in the response to Question 2, the analytical process for Madison, Green Bay, and Milwaukee, WI is still ongoing, and the Postal Service will provide such information when that process is completed.

  1. The following questions seek clarification on the criteria guiding optimization levels for different post offices and delivery units. Please refer to slides 5 and 6 of the USPS Presentation that provide the optimized level breakdown. Id. at 6, 7.

a. Please discuss the criteria used to determine the following optimization levels:

b. Full Optimization (Single Stop – Drop Off/Pick-up Same Time)

c. Hybrid-Optimized (Return Stop – Drop Off, Then Pick-up on Return)

iii. No Optimization (Exceptions)

 Please explain in detail how volume and distance determine the optimization level in the network.

Please discuss the rationale, if any, behind excluding specific post offices from optimization.

RESPONSE:

(a) – (c) As noted in the response to Question 1, the purpose of Optimized Collections is to improve the efficiency of the transportation network by having the same transportation trip in certain circumstances both (1) drop-off destinating mail and packages for delivery, and (2) pick-up originating mail for transmission to the processing network, based on the application of the criteria below. Implementation of this initiative will serve to reduce the overall number of transportation trips and stops (and hence transportation costs), improve utilization, and reduce carbon emissions.

First, if the Postal Service chooses to implement Optimized Collections within a particular geographic area, only those locations that are more than 50 miles from the relevant processing plant (the Local Processing Center in the terminology of the new network structure) will be analyzed to determine whether implementation of Optimized Collections at that location is appropriate. Locations that are within 50 miles of the processing facility, and which therefore require shorter routes to pick-up and drop-off the mail and packages, will continue to receive separate afternoon pick-up transportation. (Note that while the Postal Service is planning to use a criterion of 50 miles for all future geographic areas, including in the locations planned for January implementation, the modeling exercise for Richmond which was completed when the initiative was being considered used a criterion of 25 miles, and the Postal Service implemented this approach based upon that modeling while also adding certain trips to make the initiative there more equivalent to a 50-mile criterion).

Second, for that subset of locations within a particular geographic area in which Optimized Collections is being applied, the Postal Service then determines whether to implement optimization for a particular location, and in what manner. This determination is generally based on volume. Locations with lower volume (1 container of originating volume per day on average) are generally subject to “Full Optimization,” in which the pick-up and drop-off occurs at the same stop on a route; this serves to reduce both the number of trips, and the number of stops. Locations with higher volume (more than 1 container of originating volume per day on average) are generally subject to “Hybrid Optimization,” in which the truck first drops off the destinating volume at all locations on the route on the outgoing leg of the trip, and then proceeds to pick up the originating volume at locations in line of travel of the return leg; this serves to reduce the number of trips.

The Postal Service may also choose to exempt locations from optimization entirely even if they are more than 50 miles from a LPC, based on operational and other considerations such as volume. The Postal Service exempts a location if it has a large amount of volume (7 or more containers of originating volume per day). If a location is exempted, afternoon collection trips will continue to occur. It is important to note that these are the criteria and parameters that are currently being employed. The Postal Service is pursuing this initiative in a deliberate, structured, and systematic way, will monitor any impacts that occur, and may make adjustments as necessary and warranted.

  1. On slide 5 of the USPS Presentation, the Postal Service indicates that it is optimizing the network in “conjunction with logistics career insourcing initiative.” Id. at 6. Please describe the logistics career insourcing initiative and explain the connection between the logistics career insourcing initiative and the Optimized Collection Plan.

RESPONSE:

This refers to an initiative to convert Highway Contract Route (HCR) transportation, which is performed by contractors, to Postal Vehicle Service (PVS) transportation, which is performed by postal employees, for transportation lanes less than 350 miles. The Postal Service engages in modeling to determine the optimal trip schedules for local transportation lanes, which is also used to support HCR to PVS conversion decisions. The implementation of Optimized Collections is considered as part of that modeling exercise.

  1. Please explain whether—and if so—how the Optimized Collection Plan impacts Highway Contract Route and Postal Vehicle Service costs. Please provide relevant documentation in support of the response. If no such documentation is available, please explain.

RESPONSE:

As previously discussed, implementation of this initiative will significantly reduce the costs of the local transportation network, by eliminating unnecessary transportation trips and stops, and improving utilization of the trips that are run, and reducing carbon emissions. While the benefits to our transportation costs from taking these actions is clear, the Postal Service has not yet prepared comprehensive cost savings estimates regarding the initiative.

  1. Please discuss the specific timelines and milestones for the full implementation of the Optimized Collections Plan.

RESPONSE:

Please see the response to Question 2. Similar to our other initiatives discussed in this docket, the Postal Service is pursuing this initiative in a deliberate and systematic fashion. Implementation has occurred in one geographic area, and active planning is currently occurring for the locations referenced in Question 2, with implementation currently planned on January 8. While the Postal Service intends to implement optimized collections in other areas this fiscal year at a rapid pace given how essential this initiative is (for the reasons discussed previously), these deliberations remain ongoing, and no final determinations have been made.

  1. Please discuss how the Optimized Collections Plan will impact the service performance of First-Class Mail. With the response, please include the percentage of Single-Piece First-Class Mail that would be impacted and explain how it will be impacted. Additionally, please discuss the Postal Service’s expectations of how the length of time between customer drop-off or carrier collection of Single-Piece First-Class Mail and the first processing (start-the-clock) scan for those same mail pieces will be impacted by the Optimized Collections Plan.

RESPONSE:

The purpose of the Optimized Collections initiative is to improve the efficiency of the local transportation network under the existing First-Class Mail service standards that were implemented following publication of the DFA Plan. The Postal Service is not changing the “start-the-clock” for First-Class Mail, or changing the application of the current service standards.

The Postal Service does not anticipate material impacts to First-Class Mail service performance from implementation of this initiative. As an initial matter, the Postal Service currently delivers a significant portion of First-Class Mail in advance of our service standards, which reduces risk to our service performance in implementation of this initiative. Moreover, implementation of this initiative will further enhance our operational practices and therefore our ability to improve our service performance generally, including for all First-Class Mail. Under our existing processes, much of our Single-Piece First-Class Mail volume is dispatched from originating delivery units in the evening, creating a compressed volume arrival profile into the processing facility that can put a significant amount of volume at risk of not being processed on time to meet the scheduled dispatch. After implementing Optimized Collections, larger volumes of mail and packages will be available for processing in a late morning or afternoon window, spreading the volume arrival profile into the originating processing facility and removing some processing demand from peak operating hours, thus more effectively utilizing our overall processing capacity within our plants. In addition, while some First- Class Mail would receive originating processing later than it would have been processed in a pre-optimization environment, the Postal Service will continue to assess all aspects of our network and make appropriate adjustments (e.g., network transportation schedules may be adjusted to take advantage of the earlier originating processing window), and otherwise continue to improve the precision of our operating practices throughout the network to ensure strong First-Class Mail service performance under the existing standards.

While short-term impacts to service performance during the execution process may occur, the Postal Service will monitor any impacts that occur, and may make adjustments as necessary and warranted.

In terms of affected volume, it is important to note that this cannot be determined for any particular geographic area until after determinations are made regarding which specific locations will be subject to optimization, based on application of the criteria discussed in Question 4, including whether to create exceptions for a particular location based on operational and other considerations, such as volume. Volume information regarding the percentage of Single-Piece First-Class Mail at facilities in the Richmond region that were subject to optimized collection is being calculated and will be provided to the Commission soon.

  1. Please confirm that the Optimized Collections Plan provides a differentiation in mail services between residents in less densely populated areas, situated at a relatively large distance from S&DCs, and those in more densely populated areas near an S&DC. If confirmed, please explain how this aligns with the requirements outlined in 39 U.S.C. § 403, specifically regarding the prohibition of undue or unreasonable discrimination among users of the mail. If not confirmed, please explain.

RESPONSE:

Not confirmed. As an initial matter, the implementation of Optimized Collections is predicated on distance from a LPC, not a S&DC. It is far from clear that the Optimized Collections Plan—either at its limited current stage of implementation, or at a later stage, when it is implemented more broadly—does or will differentiate between customers situated in densely populated areas and customers situated in less densely populated areas. First, a customer’s distance from an LPC does not necessarily correspond to the population density of the location in which that customer resides. Second, and more importantly, and as discussed in the response to Question 8, the Postal Service does not anticipate adverse impacts to the reasonable expectations embodied in the service standards that apply to all customers: under the Optimized Collections Plan, “day 0” (i.e., start-the-clock) will not change, and we do not anticipate material impacts to First-Class Mail service performance from this initiative.

The Commission analyzes 39 U.S.C. § 403(c) according to a three-part test. For a violation of this statute to occur, certain mailers must be offered less favorable rates or terms and conditions than other mailers; those mailers must be similarly situated; and there must be no rational or legitimate basis for the Postal Service to apply the more favorable rates or terms. See, e.g., PRC Opinion on The Service Standard Changes Associated with First-Class Package Service, Docket No. N2021-2, at 61 (September 29, 2021). As noted above, the Postal Service does not anticipate adverse impacts to the reasonable expectations embodied in the service standards that apply to all customers; thus, the Postal Service does not foresee altered rates, terms and conditions for any mailers under the Optimized Collections Plan. Second, even assuming arguendo that customers situated at varying distances from LPCs would receive differing levels of service within the rates, terms and conditions which will nevertheless continue to apply uniformly, customers residing in different geographical locations are often not “similarly situated”; as such, they may have access to differing types and degrees of service—for example, the delivery modes available to them, the number of Postal Service retail units within their vicinity, the availability of late hours at those retail units, etc.—without falling victim to “undue or unreasonable discrimination” within the meaning of 39 U.S.C. § 403(c). Third, should any such hypothetical differences in service arise, the efficiency gains and cost savings that the Optimized Collections Plan will produce would supply a legitimate basis within the meaning of 39 U.S.C. § 403(c).

It further bears mentioning that the Optimized Collections Plan has thus far been implemented on a limited scale, and that the Postal Service is pursuing this initiative in a deliberate, structured, and systematic way, will monitor any impacts that occur, and may make adjustments as necessary and warranted, including to the extent needed to ensure continued compliance with all legal requirements.

  1. Please explain how the Postal Service intends to balance efficiency with equitable service provision with regard to the Optimized Collections Plan.

RESPONSE:

It is unclear what authority serves as the basis of this question in connection with the concept of “equity” in the context of providing service (as opposed to equitable concepts in setting rates, which are found in 39 U.S.C. §§ 101(d), 404(b), and 3622(d)(1)(E)). To the extent that this question is predicated on considerations of equity embodied in the former version of 39 U.S.C. § 101(f) which predated the passage of the Postal Service Reform Act, Pub. L. No. 117–108, 136 Stat. 1127 (2022), the obligation to consider equity applied only to selecting modes of transportation. Specifically, former U.S.C. § 101(f) provided:

(f) In selecting modes of transportation, the Postal Service shall give highest consideration to the prompt and economical delivery of all mail and shall make a fair and equitable distribution of mail business to carriers providing similar modes of transportation services to the Postal Service. Modern methods of transporting mail by containerization and programs designed to achieve overnight transportation to the destination of important letter mail to all parts of the Nation shall be a primary goal of postal operations.

Putting aside the fact that subsection 101(f) was since amended in material ways and no longer includes the term “equitable,” we note that mode selection is not at issue here because local transportation is involved, and there is not a choice between air and surface modes in this particular context (with possible limited exceptions where service is by local water vessel). Thus, the Optimized Collections Plan does not concern selecting modes of transportation. To the extent, however, that the question is intended to refer to “equity” as a proxy for the prohibition against undue or unreasonable discrimination in 39 U.S.C. § 403(c), and to balance that consideration against the Postal Service’s legitimate interests in reducing costs or increasing efficiency, then as explained in the response to Question 9 above, the Postal Service does not expect the Optimized Collection Plan to cause postal customers to receive less favorable service than other similarly situated postal customers. The Postal Service does, however, anticipate that the Optimized Collection Plan will reduce mail delivery costs and enhance efficiency by eliminating unnecessary, duplicative transportation, which also serves to reduce carbon emissions.

  1. Please discuss the steps the Postal Service has taken and the strategies to be employed to communicate the changes and potential impacts of the Optimized Collections Plan to affected communities and customers, particularly in rural areas. In the response, please include whether publicized collection information, including the pick-up times printed on collection boxes, will be updated at the affected locations to reflect the changes due to the Optimized Collections Plan.

RESPONSE:

The Optimized Collections initiative changes the Postal Service’s local transportation schedule when originating mail is picked up from a retail facility or delivery unit to be taken to the processing network. The Postal Service does not plan for the initiative to impact the schedule for removing mail from collection boxes, and therefore does not plan for the pick-up times on collection boxes to change. As noted above in the response to Question 8, it does not change the “start-the-clock” date, or the applicable service standards. The Postal Service will continue to monitor impacts and will communicate any changes to customers as appropriate.

The Postal Service believes that the term “Optimized Collections” has been misunderstood by some stakeholders and does not accurately capture the operational processes that are contemplated through this initiative. For those reasons, we intend to refer to the initiative as “Local Transportation Optimization” in the future.

  1. The Postal Service reported an increase in high volume mail theft incidents from mail receptacles including blue collection boxes: 38,500 in FY 2022 and more than 25,000 in the first half of FY 2023.1

a. Please confirm that the Optimized Collections Plan increases the accumulation of mail in collection boxes due to the planned decrease in pick-ups. If not confirmed, please explain.

b. Please confirm that the Optimized Collections Plan increases the amount of time for mail to be sitting in collection boxes. If not confirmed, please explain.

c. If either question 12.a. or question 12.b. is confirmed, please explain how the Optimized Collection Plan addresses the increased risk due to accumulation of mail or increased time in collection boxes, given the surge in mail security challenges.

RESPONSE:

Not confirmed. As noted in the response to Question 11, the optimized collection initiative does not affect the schedule for removing mail from collection boxes.

1 See USPS News Release, May 12, 2023, available at

https://about.usps.com/newsroom/national-releases/2023/0512-usps-postal-inspection-service-roll-out-expanded-measures-to-crack-down-on-mail-theft.htm

RESPONSES OF THE UNITED STATES POSTAL SERVICE TO CHAIRMAN’S INFORMATION REQUEST NO. 6 (Link to PRC website)

(December 21, 2023)

  1. The Postal Service explains that the Optimized Collections initiative (Optimized Collection Plan) does not change either the “start-the-clock” for First-Class Mail or the application of the current service standards. See Response to CHIR No. 5, question 8. Please confirm that while the “start-the-clock” for the referenced class of mail does not change, the length of time between customer drop-off and “start-the-clock” may increase, and therefore, the time between customer drop-off and delivery may also increase. If not confirmed, please explain.

RESPONSE:

Not confirmed. The start the clock events for first mile do not change as result of this effort, and thus there is no need to change the Service Performance Measurement Plan. As to whether the start-the-clock in mail processing may be pushed forward as a result, this would depend on a variety of factors, to include:

  • whether there is sufficient cushion in achievement of service standards such that service standards could still be achieved even if mail is retrieved from candidate sites the next day;
  • whether volumes transported from candidate sites prior to optimization implementation miss the processing window in the evening, such that they would be processed the next day anyway; and
  • whether mail processing runs can be accomplished the morning after acceptance and receipt of volumes from candidate sites.

In the end, achievement of service standards requires that all aspects of our operations, including collection, transportation, mail processing and delivery are performing as expected. Adjustments to one aspect of operations can be accounted for by other adjustments, such as transportation or processing schedules, to ensure we meet our service standards. It should also be noted that we were not meeting our service performance goals prior to the initiation of Optimized Local Transportation. This initiative is in its early stages, and thus, it is premature to conclude that the program will result in volumes failing to achieve service standards. By examining the outcome of the initiative and fine-tuning to solve any gaps, the Postal Service expects that achievement of service standards will not be impaired.

2. Please refer to slide 7 of the Postal Service Presentation, which provides two examples of communication with employees and customers regarding the Optimized Collection Plan. See Postal Service Presentation at 8.

  1. Please describe how the communications with customers were distributed or conveyed to the affected customers.
  2. Please provide copies of any additional materials and communications the Postal Service has prepared to make customers of affected post offices aware that mail, including payments, will be postmarked the following day and may take longer to reach the intended recipients than it did before the change.

RESPONSE:

(a) The customer communication reproduced in the referenced presentation was provided as a means of responding to customer inquiries at a retail facility or the customer call center.

(b) No additional materials have been provided at this time. As discussed in the response to CHIR No. 5, the Optimized Local Transportation initiative changes the Postal Service’s local transportation schedule when originating mail is picked up from a retail facility or delivery unit to be taken to the processing network. From a customer standpoint, the Postal Service does not plan for the initiative to impact the pick-up times on collection boxes, the “start-the-clock” date, or the applicable service standards. The Postal Service also does not anticipate material impact to service performance. The Postal Service has been assessing how the changes to transportation may affect the application of the postmark that is applied to mail when that mail is cancelled in automation (the initiative has no impact on the application of the postmark at the retail counter). The Postal Service is continuing to assess this issue and will communicate with customers as appropriate as the initiative is rolled out.

3. Please confirm the Postal Service considered requesting an advisory opinion from the Commission prior to the implementation of the Optimized Collection Plan.

  1. If confirmed, please explain why the Postal Service determined seeking an advisory opinion was not necessary. If applicable, please discuss why the Buchanan factors for a change in the nature of service would not be met by these proposed changes.
  2. If not confirmed, please explain why the Postal Service has not considered seeking an advisory opinion. Please also discuss whether the Postal Service will evaluate whether these changes to the local transportation schedule require seeking an advisory opinion from the Commission, and if the Postal Service plans to seek one in the future.

RESPONSE:

(a) – (b). Confirmed that the Postal Service has evaluated whether a request for an advisory opinion is required pursuant to 39 U.S.C. § 3661(b) in relation to this initiative. The Postal Service is committed to complying with all statutory, regulatory, and contractual requirements as we move forward with implementing initiatives under the DFA Plan. Therefore, as a matter of course, we assess whether any initiative being pursued pursuant to the DFA Plan requires that the Postal Service seek an advisory opinion from the Commission, based on consideration of the factors established in Buchanan v. U.S.P.S., 508 F.2d 259 (5th Cir. 1975). The Postal Service has concluded that this initiative does not require a request for an advisory opinion at this time. As noted in the response to Question 8 of CHIR No. 5, the purpose of the initiative is to improve the efficiency of the local transportation network under the existing First-Class Mail service standards that were implemented following publication of the DFA Plan, and which were the subject of prior advisory opinion proceedings. The Postal Service is not changing the “start-the-clock” for First-Class Mail or changing the application of the current service standards. The Postal Service also does not anticipate material impacts to First-Class Mail service performance from implementation of this initiative.

Moreover, at this point in time, the initiative has only been piloted in one region (Richmond). Indeed, even if a nationwide service change proceeding were deemed necessary here, its initiation would be premature at this juncture, with only limited, localized implementation. The Commission itself has suggested that pilot testing is an appropriate way to gather information in anticipation of the potential for a nationwide service change proceeding. See PRC Advisory Opinion Docket No. N2021-1 at 99 (“The Commission finds the lack of testing to be problematic as data suggest that mail processing is dynamic and requires timely execution to provide reliable service performance.”).

Moving forward, the Postal Service is proceeding with the roll-out of the initiative in a deliberate and structured manner, will closely monitor its progress, and will comply with all applicable legal requirements.

4. The Postal Service provides “volume information regarding the percentage of Single- Piece First-Class Mail at facilities in the Richmond region subject to optimized collection.”

a. Please also provide analogous volume information regarding the percentages for Market Dominant and Competitive mail products or groups of products, in the Richmond region subject to Optimized Collection Plan. If any of this information is not available by product or a group of products, please explain.

b. For each Market Dominant mail class and product within the class (excluding Special Services) as well as for Competitive products or groups of products please provide an estimate of the total volume at facilities in the Richmond region that are collected on a “Fully Optimized” and “Hybrid Optimization” route. See Supplemental Response at 5. If this information is not available for any products or groups of products, please explain.

RESPONSE:

(a) For Market Dominant mail products (which is single-piece First-Class Mail) in the Richmond area, below is the September 2023 density test data by optimization status.

For competitive products, data were collected in October 2023 based on retail entered and carried picked up volume. Please see the materials filed under seal in USPS LR-PI2023-4-NP6. It should be noted that these data would change as a result of changes in scope, for instance, the use of a different radius.

(b) For Single Piece First-Class Mail in the Richmond area, below is the breakdown by volume.

Screenshot

For Competitive products, please see the materials filed under seal in USPS-LR- PI2023-4-NP5. It should be noted that these data would change as a result of changes in scope, for instance, the use of a different radius. 5. Please confirm that the Postal Service has estimated the volume of (a) ballot mail and (b) remittances that will be impacted by the Optimized Collection Plan. If confirmed, please provide all available estimates separately for (a) and (b). If not confirmed, please explain.

RESPONSE:

Not confirmed. As an initial matter, all mail may have importance to senders, regardless of content and service standards do not apply on the basis of content contained in First-Class Mail. The methods of density testing used to estimate volumes subject to Optimized Local Transportation do not enable disaggregation by product subtype. Thus, while the Postal Service can estimate the percentage (for example) of First-Class Mail that will travel on currently optimized routes, it is not possible, with any degree of accuracy, to distinguish within that percentage between remittances, ballot mail, and other product subtypes. Nevertheless, the Postal Service has processes in place for the proper handling and timely delivery of ballot mail, as demonstrated during past election cycles, which are not impacted by this initiative.

  1. Please discuss whether during the 2024 election cycle, to ensure the timely processing of ballot mail, the Postal Service is planning to provide supplemental transportation to support to post offices impacted by the Optimized Collection Plan.

RESPONSE:

As an initial matter, Postal Service does not anticipate that the Optimized Local Transportation initiative will impact the timely processing or delivery of ballot mail. Nevertheless, consistent with longstanding policies and procedures, the Postal Service will deploy extra transportation resources to connect Election Mail to its intended destination or the next stage in Postal Service processing as needed. The Postal Service will also deploy extraordinary measures around Election Day, including, but not limited to, expedited handling, extra deliveries, and special pickups as used in past elections, to connect blank ballots entered by election officials to voters, or completed ballots returned by voters entered close to or on Election Day to their intended destination.

As also described in response to other questions (particularly question 5), the Postal Service is proceeding with the roll-out of the initiative in a deliberate and structured manner, and we are closely monitoring its progress, including any potential impact on Election Mail, not just ballot mail.

  1. Please discuss whether the Postal Service considered alternative transportation options to maintain current levels of service when evaluating the Optimized Collections Plan. In the response, please provide the results of the analysis and any relevant documentation, if available.

RESPONSE:

The Postal Service first notes that the status quo, which is essentially the alternative to the Optimized Local Transportation Plan, resulted in local transportation inefficiencies that need to be rectified. The Postal Service considered implementing local transportation to support the Regional Processing Center operation and associated Sorting and Delivery Centers with, and without Collection Optimization. Furthermore, several Collection Optimization scenarios were evaluated to assess transportation and processing benefits and potential impacts to volumes prior to implementation. For more information see the materials filed under seal in USPS-LR-PI2023-4-NP6.

RESPONSES OF THE UNITED STATES POSTAL SERVICE TO CHAIRMAN’S INFORMATION REQUEST NO. 20 (Link to PRC website)

(March 22, 2024)

  1. Please refer to the Postal Service’s Response to Chairman’s Information Request (CHIR) No. 11,1 in which the Postal Service states that it is committed to fulfilling its role in the calendar year (CY) 2024 election cycle, and it plans to implement extraordinary measures2 closer to the General Election, consistent with its efforts undertaken in previous election cycles. Response to CHIR No. 11, question 8. Please also refer to a Government Executive news article, which discusses the Postal Service’s “Optimized Collection,” part of its Delivering for America (DFA) Plan, that “will require mail to sit overnight at post offices instead of being collected each evening for transportation to a processing center.”3 It describes service problems experienced in Richmond, Virginia, which was the first area to roll out the “Optimized Collection” and which led to “just one morning drop off and pick up of mail at post offices for more rural facilities.” Id. Please further refer to an Associated Press news article, which reports that the top elections official in Richmond, Virginia urged “city residents to consider alternatives to mailing in absentee ballots for …[the] presidential primary amid reports of mail delivery problems.”4
  2. Please confirm whether the extraordinary measures that the Postal Service is planning to implement for the CY 2024 election cycle will 1 Responses of the United States Postal Service to Questions 1-13 of Chairman’s Information Request No. 11, February 20, 2024 (Response to CHIR No. 11). 2 For example, for the November 2022 General Election, the Postal Service implemented the following extraordinary measures for ballot mail: [E]xpedited handling, extra deliveries, and special pickups as used in past elections, to connect blank ballots entered by election officials to voters, or completed ballots returned by voters entered close to or on Election Day to their intended destination (e.g., Priority Mail Express, Sunday deliveries, special deliveries, running collected ballots to Boards of Elections on Election Day, etc.). These procedures may deviate from standard policies and procedures, including those found in the Postal Operations Manual and other Handbooks. FY 2022 Analysis at 44 (citing United States Postal Service, 2022 General Election Extraordinary Measures Memorandum, September 29, 2022, at 2, available at https://about.usps.com/what/government-services/election-mail/2022-general-election-extraordinary-measures.pdf).

3 Government Executive, As USPS Institutes Network Reforms, Mail Delivery Hits a 3-year Low, February 22, 2024, available at https://www.govexec.com/management/2024/02/usps-institutes-network-reforms-mail-delivery-hits-three-year-low/394388.

4 The Associated Press, Registrar encourages Richmond voters to consider alternatives to mailing in absentee ballots, February 28, 2024, available at https://apnews.com/article/richmond-virginia-mailin-absentee-ballots-ce48f71b982ffc87754065a6abdb2d3e.

b. If part a. is confirmed,

i. Please explain in detail what initiatives under the DFA Plan other than “Optimized Collection” these extraordinary measures will override.

ii. Please explain when these extraordinary measures will begin and end.

iii. Please explain whether these extraordinary measures will be implemented in all geographic locations.

c If part a. is not confirmed, please explain in detail why these extraordinary measures will not override initiatives under the DFA Plan and what the Postal Service plans to do to ensure the timely delivery of Election Mail and Political Mail during the CY 2024 election cycle despite the negative effects of DFA initiatives such as “Optimized Collection” on service performance.

RESPONSE:

This information request appears to be based on a broad and unsubstantiated premise that “initiatives under the DFA Plan” will have “negative effects” on service performance. As the Postal Service has articulated multiple times, most recently in response to Chairman’s Information Request No. 7 in Docket No. PI-2023-4, while there may be impacts on service performance during the roll-out of the Delivering for America Plan, those impacts will be temporary and the Postal Service is committed to minimizing the disruptions that occur, and the Delivering for America Plan is intended to create a modern, precise, and efficient network, capable of reaching our ambitious service performance goals in a systematic, cost-effective, and financially sustainable manner, while reducing carbon emissions.

The Postal Service is committed to the secure, timely delivery of the nation’s Election Mail. In 2024, just as we have in previous elections, the Postal Service will fulfill its role in the electoral process when public policymakers choose to utilize the mail as a part of their election system or when voters choose to utilize our services to participate in an election. We will employ a robust and proven process to ensure proper handling and delivery of all Election Mail, including ballots.

The Postal Service engages in extensive outreach to election officials to educate them on our best practices recommendations, including mail preparation guidance and information about our visibility tools. The Postal Service also has processes and procedures in place regarding Election Mail that we implement throughout an election year, such as the daily “all clear” process and trying to ensure that every return ballot mailed by voters receives a postmark. Closer to Election Day, we undertake “extraordinary measures” beyond our normal course of operations when appropriate to accelerate ballots in the days immediately leading up to and following the general election.

As clarification, we generally undertake extraordinary measures for ballots that would not otherwise make it to their destination by a state’s ballot return deadline under our normal operations and applicable service standards. The need to undertake extraordinary measures is not due to failures of Postal Service operations, but instead because the ballots were entered into the mailstream at a point where, under normal Postal Service business practices, they would not make it by the state’s return deadline. Finally, your reference to the reported statements of election officials in Virginia provides an opportunity for the Postal Service to reiterate our clear, limited role in elections. The Postal Service is responsible for processing, transporting, and delivering the nation’s Election Mail. The Postal Service is not responsible for determining the extent to which the mail is used for participating in elections, the design of ballots or return envelopes, counting ballots, or setting state election deadlines including dates to request (if required by the state) or return a ballot. Election officials are responsible for administering elections and for advising voters as they deem appropriate.

a. We do not anticipate that Local Transportation Optimization (previously referred to as Optimized Collections) will affect the timely processing or delivery of ballot mail, or other Election Mail. Consistent with longstanding policies and procedures, the Postal Service will deploy extra transportation resources to connect Election Mail to its intended destination or the next stage in Postal Service processing as needed. As LTO is currently being evaluated in a handful of locations nationwide, we are deploying specific activities at the optimized facilities in those locations to avoid any unintended impact on ballot mail during the initial rollout of the initiative. In addition to the activities specific to optimized sites, and as with previous general election cycles, the Postal Service will deploy extraordinary measures around Election Day to connect blank ballots to voters or to ensure completed ballots reach their intended destination.

b. i. As explained above, the extraordinary measures are focused on ballots entered too close to election day to make it to their destination by a state’s ballot return deadline under our normal service standards. The activities in areas where Local Transportation Optimization is being evaluated are not intended to “override” LTO, but instead to avoid any unintended impact on ballot mail during the initial rollout of the initiative.

b. ii. The activities at LTO sites will take place for the four days leading up to the election through the State’s ballot acceptance deadline in that location. During that period we will run extra transportation at those sites that we would not otherwise run in order to provide additional assurance that ballots will be delivered consistent with, or better than, our service performance standards. As in previous years, the extraordinary measures will be implemented closer to Election Day. This year, they will start nationwide on October 21, 2024, and will be in place as applicable through November 26, 2024.

b. iii. The activities at LTO sites will take place in locations where LTO is in place. The extraordinary measures will be implemented nationwide, including at LTO sites.

c. Please see above

ORDER DIRECTING POSTAL SERVICE TO SHOW CAUSE OR FILE A NATURE OF SERVICE PROCEEDING REGARDING CERTAIN DELIVERING FOR AMERICA PRC Order No. 7061  (Link to PRC website)

(April 26, 2024)

The Postal Service also announced a new initiative called Optimized Collections, which later was referred to as Local Transportation Optimization (LTO), for implementation in FY 2024.10 Under this initiative, collection mail received throughout the day will be held overnight at some locations to reduce the number of trips and associated costs. Response to CHIR No. 5, question 1. The Optimized Collections initiative was first implemented in Richmond, VA on October 28, 2023. Id., question 2.a. The Postal Service asserts that by implementing this initiative, it is not changing the “start-the-clock” for First-Class Mail, it is not changing the application of current service standards, and it does not anticipate material impacts on First-Class Mail service performance from implementation of this initiative. Id., question 8. Furthermore, the Postal Service stated that it does not expect the initiative to cause some postal customers to receive less favorable service than other similarly situated postal customers. Id., question 9.

9 Responses of the United States Postal Service to Questions 1-4 of Chairman’s Information, Request No. 4, October 23, 2023, question 4.a. (Response to CHIR No. 4); see Responses of the United States Postal Service to Questions 1-5 of Chairman’s Information Request No. 7, March 15, 2024, question 1 (Response to CHIR No. 7) (for a description of the types of operations performed at each type of facility).

10 Responses of the United States Postal Service to Questions 1-12 of Chairman’s Information Request No. 5, December 4, 2023, questions 1, 11 (Response to CHIR No. 5).

RESPONSES OF THE UNITED STATES POSTAL SERVICE TO QUESTIONS 1-17 OF CHAIRMAN’S INFORMATION REQUEST NO. 10 (Link to PRC website)

(May 8, 2024)

  1. Please confirm that the process for handling Election mail and ballots will be different in locations where DFA Plan initiatives (such as the Local Transportation Optimization initiative) have been implemented compared to locations unaffected by DFA Plan initiatives? See OIG Report at 9. If confirmed, please describe the difference in handling procedures, and provide a list of locations where DFA Plan initiatives will be operational during the CY 2024 election cycle.

RESPONSE:

Confirmed. In all locations where LTO is implemented, the Postal Service has engaged and will engage in the same key activities discussed in the referenced OIG report. As explained in the Postal Service’s management response to that audit, “the Postal Service has developed a uniform policy that will apply to all LTO sites, for both primary elections and the general election.” As explained in response to Chairman’s Information Request No. 20, Question 1 in Docket No ACR2023 and in response to Chairman’s Information Request No. 6, Question 6 in this docket, the Postal Service will deploy extra transportation resources, including the hub and spoke efforts described below, to connect Election Mail to its intended destination or the next stage in Postal Service processing as needed.

As LTO is currently being evaluated in a handful of locations nationwide, we are deploying specific activities at the optimized facilities in those locations to avoid any unintended impact on ballot mail during the initial rollout of the initiative. The activities at LTO sites will take place for the four days leading up to the election through the State’s ballot acceptance deadline in that location. The extra transportation resources referenced previously include, but are not limited to, transportation to centralized hub locations from spoke Post Offices to facilitate postmarking and delivery of ballots to Boards of Elections or processing plants as applicable.

UNITED STATES POSTAL SERVICE RESPONSE TO THE ORDER TO SHOW CAUSE REGARDING CERTAIN DELIVERING FOR AMERICA INITIATIVES (ORDER NO. 7061) (Link to PRC website)

(May 16, 2024)

  1. An Advisory Opinion Request for the RPDC/LPC Network and LTO Initiatives at This Time Would Be Premature

As explained below, neither the RPDC/LPC network initiative nor the LTO initiative has yet given rise to a change in the nature of postal services within the meaning of Section 3661. Both initiatives have been geographically limited in scope; impacts are local and are attributable to exogenous disruptions and transitory errors in execution; both remain in an initial phase of experimentation and data gathering, consistent with the Commission’s repeated advice; and effective dates for their nationwide implementation have yet to be determined.

  1. The RPDC/LPC Network and LTO Initiatives Have So Far Been Geographically Limited in Scope

The Commission states that “transformation activities” have been initiated “in RPDCs in nine areas: Richmond, Atlanta, Portland, Boise, Charlotte, Chicago, Houston, Jacksonville, and Indianapolis.” Order No. 7061, at 3. The Commission therefore recognizes the limited geographic scope of the initiative to date. It should be noted, moreover, that in these locations, transformation activities have not progressed to the same extent; indeed, only in Richmond have the planned networks of RPDCs and LPCs been finalized.

RESPONSES OF THE UNITED STATES POSTAL SERVICE TO COMMISSION INFORMATION REQUEST NO. 1 (Link to PRC website)

(June 24, 2024)

  1. Please refer to a timeline of the Local Transportation Optimization (LTO) initiative provided in a January 2024 National Association of Postal Supervisors Board Memo.2 Please also refer to the Postal Service Response to Show Cause, which lists site locations where collections have been optimized and states that no additional locations are currently planned for optimization after July 2024. See Postal Service Response to Show Cause at 19. Please provide the most recent up-to-date site timeline, including dates and sites where the LTO initiative has already been implemented.

RESPONSES:

Below is an updated site timeline of current and planned LTO implementations:

Screenshot

The Postal Service has not finalized any further LTO locations beyond those identified above, and no LTO implementations will take place from September to November 2024.

2 National Association of Postal Supervisors, Board Memo 11-2024: S&DC; Presentation Update, January 29, 2024, at 24, titled “Local Transportation Optimization – 20024 Site Timeline,” available at https://naps.org/files/galleries/Board_Memo_011-2024_S_DC_Presentation_Update.pdf.

RESPONSES OF THE UNITED STATES POSTAL SERVICE TO COMMISSION INFORMATION REQUEST NO. 1 (Link to PRC website)

(July 1, 2024)

6. Please refer to the Postal Service Response to Show Cause where the Postal Service states that it: “has been conducting operational and pilot tests for both the [RPDC/LPC] and LTO initiatives, consistent with the Commission’s recommended approach for changes in the nature of postal services, evaluating the results and making necessary adjustments before determining whether it is necessary to seek an advisory opinion.” Postal Service Response to Show Cause at 4

  1. Please provide all metrics and performance targets used in evaluation of the performance of the RPDC/LPC pilot test initiative.
  2. Please provide all metrics and performance targets used in the evaluation of the performance of the LTO pilot test initiative.
  3. Please provide a list of all locations where RPDC/LPC and LTO pilot tests are currently being conducted. For each location, please indicate the start date of the pilot test, the stage of the pilot test, and the anticipated end date of the pilot test for that location.
  4. Please provide a list of any locations where further pilot tests are planned and the anticipated start date of the pilot test for each location.
  5. Please indicate whether any pilot test locations have experienced a change in operational status due to the DeJoy Letter referenced in questions 2 through 4, and for each location describe that change in operational status along with the duration of the change.
  6. Please provide any data collection plans developed for the RPDC/LPC and LTO pilot test initiatives.
  7. Please provide any official timeline for data collection and evaluation of the RPDC/LPC and LTO pilot test initiatives. With your response, please include the estimated duration of the pilot test phase for each initiative and indicate the dates when the Postal Service anticipates having the results of each active pilot test to be publicly announced.
  8. Please describe all “necessary adjustments” made to the RPDC/LPC initiative as a result of data collection and evaluation conducted as a part of the pilot test.
  9. Please describe all “necessary adjustments” made to the LTO initiative as a result of data collection and evaluation conducted as a part of the pilot test.
  10. Please describe any alternative operational plans considered in areas where performance targets established as part of the pilot test were not achieved for either the RPDC/LPC or LTO initiatives.
  11. Please describe all standards and evaluation criteria that denote success or failure of the pilot test. In your response, please indicate how those standards justify expansion or replication of RPDC/LPC and LTO initiatives. If no specific success or failure criteria exist, please describe how the success or failure of the pilot tests is to be determined.
  12. Please provide all other available documentation where the Postal Service has referred to the RPDC/LPC and LTO initiatives as “pilot tests.”
  13. Please provide any plans or documentation that indicate the duration of the pilot test status for the RPDC/LPC and LTO initiatives.
    1. Please confirm that the Postal Service has a specific deadline to determine whether to terminate or expand the pilot test for the LTO initiative. If there is no such a deadline, please explain.
    2. Please confirm that the Postal Service has a specific deadline to determine whether to terminate or expand the pilot test for the RPDC consolidation initiative. If there is no such a deadline, please explain.

RESPONSE:

  1. For the RPDC/LPC network initiative, performance data for the 13 RPDC regions identified by Question 2 above are reviewed daily. The Postal Service also conducts extensive, site-specific research into the causes of any observed service declines. While such causes vary in kind and degree from region to region, the Postal Service has identified issues with personnel availability, facility and machine functionality, on- time transportation, transportation routing design, and exogenous shocks (e.g., power outages and adverse weather) as among the most frequently occurring causes of service disruptions.

The Postal Service also considers these factors as part of a region’s planned rollout. For example, when rolling out an RPDC region, the RPDC may be completed before the LPCs within its service area are fully operational; in such cases, operations envisioned for those LPCs may be temporarily housed in that area’s RPDC, and the analysis of personnel availability, facility and machine functionality, trips-on time, and etc., serves both to mitigate transitional service disruptions and to inform long-term planning for the RPDC/LPC network’s future state.

Through these efforts, as demonstrated in our financial statements, we are removing hundreds of millions of dollars in transportation costs and achieving improved productivity at our processing sites.

b. As with the RPDC/LPC network initiative, the Postal Service tracks and analyzes service performance data in areas where the LTO initiative has been implemented. In addition, the Postal Service tracks modeled savings by analyzing the metrics of estimated cost, miles driven, number of trips, number of legs within trips, truck capacity utilization by leg, driver hours, and layover hours.

c. Please see the responses to Questions 2, 3, and 4 above, as well as the responses to ChIR 9, Questions 1-2 in the instant docket.

d. Please see the responses to Questions 2, 3 and 4 above.

e. The May 20 Letter of Postmaster General and Chief Executive Officer Louis DeJoy to Chairman Gary Peters, referenced above, did not cause any current or planned RPDC, LPC or LTO locations to undergo a change in operational status.

f-g. Please see the responses to subparts a. and b. above.

h. Evolutions in RPDC/LPC network design and functionality, consistent with the process of data gathering, operational adjustment and continuous improvement envisioned by the DFA Plan, can be tracked from the response to ChIR 1, submitted on July 19, 2023 in the instant docket, to the Postal Service’s response to ChIR 9, submitted on May 3, 2024 in the instant docket. For example, in one deviation from the original network design, LPCs are now intended to perform processing operations on parcels. Furthermore, efforts to mitigate service declines coincident with RPDC/LPC activations have been described at length in the instant docket and elsewhere. See, e.g. the Postal Service’s Response to ChIR 9, Question 7.

i. As noted in response to ChIR 5 in the instant docket, submitted on December 4, 2023, when the LTO initiative was first piloted in Richmond, locations at 25 miles of driving distance from processing facilities were deemed eligible for optimized A.M. dispatches. Subsequently, that criterion was changed to 50 miles of driving distance. Furthermore, as is apparent from the Supplemental Response to Question 3 of ChIR 5 in the instant docket, submitted on February 9, 2024, the Postal Service has largely adopted the “hybrid” approach to A.M. dispatches (in which the truck first drops off destinating volume at all locations on the route on the outgoing leg of the trip, and then proceeds to pick up originating volume at locations in line of travel of the return leg) as the predominant mode of optimization. Finally, the Postal Service has begun renegotiating transportation contracts to better reflect the reduction in layover hours enabled by the LTO initiative—an adjustment that has yielded significant cost savings.

j. Please see the responses to subparts h. and i. above. The Postal Service is focused on improving the RPDC/LPC network and LTO initiatives, not formulating “alternative operational plans.” The current phase of operational testing, in other words, has served to refine these initiatives, which collectively present the most viable option for achieving reliable performance within service standards while advancing financial sustainability.

k. As noted in response to subpart j. above, the Postal Service is focused on improving the RPDC/LPC network and LTO initiatives. The measure of success over time will be reliable performance within service standards and financial sustainability through revenue gains and reductions in cost.

l. In the instant docket and elsewhere, the Postal Service has consistently and repeatedly characterized the DFA Plan’s network transformation project as a structured process, one conducted with careful deliberation over a course of years, in which region-by-region rollouts are monitored closely and adjustments made as necessary and appropriate. See, e.g., Response to ChIR 1, Question 1; Response to ChIR 5, Questions 1 and 2; Response to ChIR 5, Question 8; Response to ChIR 7, Question 1; Response to ChIR 9, Question 4; Docket No. ACR 2023, Response to ChIR 1, Questions 8, 15 and 17; Docket No. ACR 2023, Response to Commission Information Request 1, Question 1; Docket No. ACR 2023, Response to ChIR 16, Question 8. This practice of localized testing and adjustment prior to (and with a view towards) implementation on a wider scale is consistent with the “operational or pilot testing” recommended time and again by the Commission. See Docket No. N2021-1 Advisory Opinion, July 20, 2021, at 2, 99; Docket No. N2021-2 Advisory Opinion, Sept. 29, 2021, at 80.

m. The LTO and RPDC/LPC network initiatives are key components of a 10-year plan. Within that framework, no hard deadlines for these initiatives have been established; indeed, such deadlines would be at odds with the practice of localized testing and adjustment described above.

RESPONSES OF THE UNITED STATES POSTAL SERVICE TO COMMISSION INFORMATION REQUEST NO. 1 (Link to PRC website;  CIR 1 USPS Resp. Public Attachments)

(August 14, 2024)

  1. The Postal Service has implemented the Local Transportation Optimization (LTO) initiative in select locations in FY 2024.3 In the following questions, please discuss how SPM is affected by, or responds to, this operational change.

a. Please specify how the Collection Profile is affected by, or responds to, a change in transportation schedule and frequency from the delivery unit to the processing facility assigned to perform cancellation.

b. Please specify how the First Mile Sampling Profile is affected by, or responds to, a change in transportation schedule and frequency from the delivery unit to the processing facility assigned to perform cancellation.

c. Please specify how the Retail Profile is affected by, or responds to, a change in transportation schedule and frequency from the delivery unit to the processing facility assigned to perform cancellation.

d. Please explain how the First Mile Profile is affected by, or responds to, a change in the transportation schedule and frequency of transportation from the delivery unit to the local processing facility assigned to perform cancellation.

3. For the locations where the LTO initiative has been implemented, please provide the FY 2023 and FY 2024 Quarters 1 and 2 First Mile Profile results and supporting data.

RESPONSE:

a. Changes in transportation schedules and frequencies from the delivery unit to the processing facility assigned to perform cancellation have no impact on how the Collection Profile is measured.

b. Changes in transportation schedules and frequencies from the delivery unit to the processing facility assigned to perform cancellation due to LTO have no impact on how the First Mile Sampling Profile is measured.

3 See Docket No. PI2023-4, Responses of the United States Postal Service to Questions 1-12 of Chairman’s Information Request No. 5, December 4, 2023, questions 1, 11.

c. Changes in transportation schedules and frequencies from the delivery unit to the processing facility assigned to perform cancellation due to LTO have no impact on how the Retail Profile is measured.

d. Changes in transportation schedules and frequencies from the delivery unit to the processing facility assigned to perform cancellation due to LTO have no impact on how the First Mile Profile is measured.

e. For this question, the Postal Service interprets the reference to “First Mile Profile results” to mean the First Mile Impact on overall service performance in the applicable district. In FY 2023 and FY 2024 Quarter 1 and Quarter 2 First Mile Impact for district level LTO sites is provided below.