By Steve Hutkins
In February 2022 the Postal Regulatory Commission opened a Public Inquiry docket to address the issue of post offices that have been under emergency suspension for an extended period of time without being resolved by reopening them or closing them permanently. Such suspensions become de facto discontinuances without having gone through a discontinuance process that provides opportunity for public comment.
The inquiry was intended to examine “issues impeding the Postal Service’s progress in resolving the suspended post offices in a timely manner” and to consider “procedures or courses of action for how the Postal Service may expeditiously resolve suspended post offices.” The Commission received comments from the Postal Service, the PRC’s Public Representative, and me.
My comments argued that the Postal Service and the Commission should work together to create a suspension dashboard that would keep the public up to date on all the suspensions in real time, with information about the alternative location for postal services during the suspension, when to expect the suspension to be resolved, the status of any discontinuance process that’s underway, and so on. Such a dashboard would also provide transparency about suspensions and discontinuances in general. To illustrate what the dashboard could show, I created a prototype, available here. In his comments, the Public Representative also recommended that the Postal Service create a dashboard and share more information online.
No further action was taken on the public inquiry for over a year. Then a couple of weeks ago, for reasons unknown, the Commission finally responded to the comments by issuing an Information Request asking the Postal Service to describe the extent to which it is “considering creating and maintaining a publicly-available dashboard of suspended post offices.”
The “marginal utility” of a dashboard
Last week, the Postal Service responded. Not surprisingly, the agency said it “does not currently plan to create a public-facing dashboard showing the discontinuance status of suspended Post Offices.”
According to the Postal Service, “the proposed dashboard would duplicate information that the Postal Service already provides.” The Postal Service cites three ways it provides this information — PostalPro, reports to the Commission, and USPS.com. For many reasons, these are all inadequate and do not do the job of a public-facing dashboard.
PostalPro Industry Alerts: The PostalPro website is intended for business mailers and not user-friendly for the general public. It’s difficult finding the suspension notices on the site amidst all the other types of industry alerts, which include short-term closures for weather-related problems and alerts that don’t involve post offices at all. The archive of alerts covers only 2021 and 2022, and it’s doubtful that it contains all the suspensions that occurred during those two years. These alerts are organized by month (so one would need to know when the suspension occurred), they often do not contain the reason for the suspension, and they don’t contain any information about the status of when the office might reopen or be studied for discontinuance.
Reports to the Commission: As with the alerts on PostalPro, it’s very difficult finding suspension reports on the PRC website unless one knows where to look. If one searches for “suspension” in the main search box on the homepage of the website, nothing shows up. The annual reports of suspensions during the fiscal year contain very little information, not even the address of the office, the date of the suspension, or the reason for it, and since they’re filed annually, they do not provide up-to-date information on the status of the suspension. (Several of the offices listed on the end-of-year 2022 report have since reopened.)
USPS.com: The Postal Service says that “the public can access information on individual Post Offices, including the suspension status of each suspended Post Office, on USPS.com.” It’s not clear what the Postal Service is referring to here. There’s a page on the website with the latest service alerts (like on PostalPro), but it doesn’t provide the status of suspended offices. Press releases archived on the news page announce some (not all) suspensions when they first occur, but don’t provide updates on their status. On the Find USPS Locations page, one can search a city or zip code and find nearby post offices, with their hours and location, but suspended offices typically do not appear in a search. It’s as if they never existed, rather than been temporarily closed.
The Postal Service clearly has no interest in creating a suspension dashboard. It concludes its brief response to the information request by saying, “the Postal Service questions the marginal utility of such a project, especially in light of the costs (some of them recurring) that it would entail.”
This is not very convincing. The Postal Service has the relevant information for a dashboard readily at hand, and in the context of the USPS budget, the cost would be minimal.
Clearing the backlog
The PRC’s Annual Compliance Determination (ACD) for FY 2022 contains a discussion of post office suspensions that took place during the fiscal year and the status of the backlog of 665 long-term suspensions from 2016 that prompted the public inquiry. As the Commission explains, the number of number of unresolved suspensions tripled from FY 2012 to FY 2015, prompting the Commission to require quarterly reports on their status. Progress on resolving the suspensions was hampered by organizational restructuring and the pandemic, then resumed in 2022. At this point, 79 remain unresolved.
Of the 665 suspensions in the FY 2016 backlog, about 480 ultimately have ended with a discontinuance. In most cases, the Postal Service had completed most of the discontinuance process years ago except for the last couple of steps, but the discontinuances were not officially completed with an announcement in the Postal Bulletin until 2017, 2018, and 2022. (For a while last year, it looked as though the Postal Service would skip this final step altogether. More on that here and here.)
On average, for the 480 suspensions ending with a discontinuance, it took almost eight years to go from suspension to discontinuance.
About a hundred of the 665 suspended offices were reopened. For most of these, the suspension occurred in 2015 and 2016 and the reopening occurred in 2016 and 2017, so they were not as long-term as most of the offices on the backlog list. Only a handful of the offices with very long-term suspensions have eventually been reopened.
As for the 79 suspended offices from the backlog that remain suspended, the Postal Service told the Commission that it plans to revolve 40 of them through the discontinuance process, assemble a team to review the others, and to resume public meetings (which had been paused during the pandemic) to discontinue those suspended post offices that cannot be reopened or relocated.
Given that these suspensions took place several years ago, it’s unlikely that many, if any, will be reopened. For the 665 suspensions on the backlog list, about 560 — 84 percent — will wind up ending with a discontinuance.
The new backlog
Here’s a table drawn from the ACDs over the past several years showing the number of suspensions and discontinuances annually. (Note that the number of suspensions at the end of one fiscal year is not always the same as the number at the beginning of the following year due to USPS data base issues, errors, and other reasons.)
From 2017 through 2022, about 725 post offices were suspended. Most of them were resolved by reopening the post office, often within months (after building repairs were done or a safety issue corrected), but about 300 of these offices were still under suspension at the end of FY 2022. In other words, while the Postal Service was clearing the 2016 backlog, a new backlog was developing.
This chart shows the number of suspensions that remained unresolved at the end of each fiscal year. As you can see, the number jumped significantly from 2012 to 2015, which prompted the Commission to require quarterly reports on the Postal Service’s progress toward resolving the suspension backlog from 2016. While the Postal Service has resolved all but 79 of these older suspensions, at the end of FY 2022 there were still 381 unresolved suspensions. On average, these suspensions are five and half years old.
There’s been an unofficial moratorium on closures since POStPlan reduced hours at some 12,000 small, rural post offices as an alternative to closing them. Aside from the discontinuances of offices on the 2016 backlog list, the Postal Service has not discontinued any post office since 2014. The Postal Service’s annual reports for the compliance reviews often point out that that there were no post office closures during the year. But this is misleading. During each of those years, offices were closed by suspension, and many of them will eventually be discontinued. In fact, there were probably an average of 40 or 50 closures each year from 2017 through 2022.
A thousand suspensions
Here are a map and a list of just over a thousand suspensions — the 665 from 2016, 300 unresolved suspensions from 2016-2022, and a few miscellaneous. View on Google Docs here.
Reasons for Suspensions
As for the causes of all these suspensions, the Commission has not required the Postal Service to provide a reason for every suspension, but by cobbling together various lists, we’ve been able to identify the reason for about 840 suspensions. The causes break down as follows:
Lease-related causes are by far the most common cause for a suspension. As for what caused the lease issue, for 270 suspensions, the lists say, “Lease Terminated by Lessor.” In only 18 cases do the lists say “Lease Terminated Postal Service.”
In many cases, it was not quite so clear cut who was responsible for the decision to terminate or not renew the lease, as indicated by news articles about the suspensions. In fact, it was the lease issue that led to a Congressional hearing and the Commission’s earlier public inquiry docket on suspensions in 2010.
In any case, when a lease issue causes a suspension, it’s rare for the post office to reopen. Of the 375 suspensions known to have been caused by a lease issue, only 31 have reopened.
Population data was available for 735 offices on the list of a thousand. More than 7.5 million people live in zip codes that have been impacted by these suspensions.
Nearly all the suspended post offices are small and rural. Over 70 percent of the zip codes are at least 90 percent rural.
Virtually all the suspended offices are in leased properties. It’s very rare for a post office in a property owned by the Postal Service to remain suspended for an extended period of time. If there’s damage to the building or a safety issue, the Postal Service can correct the problem without waiting on (or arguing with) the lessor.
The average size of the suspended offices is about 2,200 square feet — typical for rural offices in leased spaces. The owned properties, by contrast, average more than 12,000 square feet (that’s not including all the large post offices that are also processing centers).
About 300 of the suspended offices were main post offices, 180 were stations or branches, and 490 were remotely managed post offices (RMPOs), i.e., those that had their hours reduced under POStPlan. Based on data provided in the POStPlan docket, the average distance between the RMPOs and their Administrative Post Office was over 11 miles, and that’s probably typical for suspended post offices in general.
Suspensions and discontinuances to come
According to the Delivering for America 10-year plan, sometime over the next year or two the Postal Service will begin implementing an initiative to “optimize” the retail network by closing post offices. How many will be impacted remains to be seen. But it could be thousands.
The new Sorting & Delivery Centers being created right now will consolidate carriers from as many as 6,000 post offices and leave a lot of excess space behind in each office. In the node studies the Postal Service conducts of its facilities, excess space is often one of the reasons a facility is earmarked for relocation or closure. If the post office is in a leased property, the excess space may lead to an issue over renewing the lease, which in turn will lead to more emergency suspensions.
The problem of long-term suspensions and de facto discontinuances is not going away, and it’s likely to get worse.
A suspension dashboard won’t solve all the problems associated with suspensions and discontinuances, but it would provide some much-needed transparency and help customers whose post office has been suspended. It’s too bad the Postal Service dismissed the proposal with a cursory comment, and it’s doubtful the Commission will do anything more on the matter.
Perhaps one day Congress will require a suspension dashboard, just as it directed the Postal Service to create a service performance dashboard as part of postal reform legislation. In the meantime, to learn more about emergency suspensions, see our Suspension Dashboard.
(Featured Image: Former post office in Export, PA, suspended in 2008, discontinued in 2022)
For an earlier review of suspensions and discontinuances, see this previous post from 2018: