Earlier this week the Postal Service shared a list with the Postal Regulatory Commission identifying 170 post offices that were “temporarily” suspended several years ago and that will soon be closed permanently.
The list was submitted as part of the PRC’s Public Inquiry into what can be done to push the Postal Service to clear up a backlog of over 400 long-standing, unresolved emergency suspensions.
In its filing with the PRC, the Postal Service explains that the effort to resolve these suspensions has been hampered by the pandemic and organization changes made in 2020, but it is now prepared to proceed. The Postal Service says it has “identified 170 sites that qualify for swift official Discontinuance,” and it plans to complete this project by the end of September 2022.
Not that there has been anything “swift” about the discontinuance process on these post offices. Six of the suspensions occurred more than 20 years ago, 63 occurred more than 10 years ago, and with a couple of exceptions, they all occurred at least five years ago.
When an emergency suspension first take place, whether it’s due to a problem renewing the lease (the most common cause), unsafe conditions or damage to the building, the Postal Service almost always reassures the community that the closure is only “temporary.”
After a suspension occurs, the Postal Service is required to reopen the office by fixing the problem that led to the suspension (relocating if necessary), or it can decide that the suspension is a reason to initiate a discontinuance process.
The law doesn’t put a time limit on this process, so the Postal Service can start the discontinuance process by posting a proposal to close and perhaps proceeding to the required public meeting and circulating the customer questionnaires, and then put the process on hold. There’s currently a backlog of 425 unresolved suspensions. A few of these offices may be reopened, but most are headed for discontinuance.
For 32 of the 170 offices now slated for discontinuance, the Postal Service has completed 29 of the 30 steps in the process, and all that remains is publishing a notification in Postal Bulletin. For the other 138, the Postal Service hasn’t made a final decision (although it’s clear what that decision will be), so the final determination notice has not yet been posted.
The notice contains a paragraph at the end explaining that customers have 30 days to file an appeal with the PRC. Normally this notice would be made available for inspection at the post office being closed, but when a post office has already closed by suspension, it can only be posted at other nearby post offices.
It’s not very likely, then, that anyone will come upon a final determination notice at a post office a few miles away from the one that was suspended and learn that it’s now possible, after five or ten years, to file an appeal. Most likely, the people in these communities will not even become aware that the Postal Service has, at long last, made a final determination to close the post office.
If there’s no appeal, the administrative record documenting how the suspension and discontinuance process was conducted never becomes public. That’s unfortunate, especially considering that the process for many of these closures was surely flawed (as discussed in this 2018 OIG report), which could provide grounds for an appeal.
The PRC has shown little interest in how the Postal Service has conducted the discontinuance process on these long-standing suspensions. The focus has instead been on just getting the Postal Service to clear the backlog so that it is not “out of compliance” with the law governing discontinuances. The Commission will probably be content to see that progress is being made.
The Postal Service’s list of the 170 offices identified for discontinuance is here. More details about these offices can be found on this table, derived from the “Save the Post Office” Suspension Dashboard. There’s more about the suspension backlog and the dashboard in comments that I filed earlier this week for the PRC’s Public Inquiry, here. See also the comments filed by the PRC’s Public Representative, here.