Francitas is a small town in south Texas. It’s had a post office since 1911, but no longer. The Postal Service isn’t interested in providing Francitas with a post office anymore, nor with much else either.
Since 2011, the town has been hit with two final determinations to close the post office, had the hours reduced to two a day under POStPlan, seen window services stopped by emergency suspension, and then watched the post office close completely, with no replacement services in place. Since Thanksgiving, the people in Francitas have had to drive almost 20 miles round-trip to La Ward to do postal business. Now they have to make that drive just to get their mail.
This is what passes these days for “a maximum degree of effective and regular postal services to rural areas, communities, and small towns where post offices are not self-sustaining.”
Closing, round one
The first time the Postal Service tried to close Francitas was in 2011. Even though the law says a post office can’t be closed solely for operating at a deficit, the proposal to study the office for closure states that the workload had declined to the point that “the maintenance of an independent office at Francitas may not be warranted.”
After holding a community meeting and reviewing written comments that expressed a variety of concerns — loss of community identity, the dependence of senior citizens on the post office, the long driving distance to other post offices — the Postal Service issued a final determination to close Francitas. Like all of the final determination notices issued back in 2011, this one states that the closing “will not adversely affect the community," even though everyone in town said otherwise.
The Postal Service estimated that the closure would save $19,896 annually — the cost of a postmaster salary and benefits (around $30,000), minus the cost (around $10,000) of replacement services for a rural carrier to deliver the mail to homes and a cluster box unit (whichever individuals preferred). There was no savings on the rent because the Postal Service owns the module unit and just pays a modest fee to lease the land.
Carolina Jalufka and Raymond Salinas, two residents of Francitas, appealed the decision to close Francitas to the Postal Regulatory Commission. In December of 2011, the Commission issued an order affirming the final determination. The Commissioners actually split on the ruling, two to two, as they did many times during 2011 and 2012, but according to PRC’s rules, that meant the Postal Service’s decision was affirmed. (The legitimacy of that PRC policy is now being questioned in a lawsuit working it was through DC circuit court.)
In their dissenting opinions on the case, Commissioners Ruth Goldway and Nanci Langley noted that there were inaccuracies in the cost savings analysis because the Postal Service used the salary of a career postmaster even though the office had been managed by a postmaster relief since 2008.
With the final determination affirmed, the post office should have closed almost immediately, but there was a moratorium on post office closings in effect from December 2011 to May 2012, so Francitas got a reprieve.
Then came POStPlan
When the moratorium ended, the Postal Service changed its approach. Instead of mass closures, there would be mass reductions of hours. Francitas was on the list of 13,000 post offices set to have its hours reduced under POStPlan, from a regular work day (8 to 3) to just two hours a day.
Surveys were sent out again, and on October 10, 2012, another meeting was held, at the Francitas Volunteer Fire Department. The Postal Service distributed a piece of paper indicating that the probable new hours of operation would be 8 a.m. to 10 a.m.
This sort of flyer is apparently being handed out at POStPlan meetings across the country. It’s a good example of how the Postal Service is using POStPlan as a publicity tool to spread its message.
The flyer contains has a graph showing a dramatic drop in “customer retail visits” to post offices. Visits are down 27 percent, from 1.28 billion in 2005 to 0.93 billion in 2011. The graph makes it look like there won’t be anyone going to the post office in a couple of years.
The graph is labeled “retail visits” because it refers only to visits when customers buy something. Total visits to the post office — which includes activities like checking your post office box — are actually going up, according to the most recent household diary survey.
The piece of paper also has a picture of a cute little Village Post Office and an explanation of what that is. There’s no reference, however, to the Postal Service’s commitment (made to the PRC during the POStPlan advisory opinion) not to use VPOs as a replacement for post offices. In any case, there are apparently no plans to put a VPO in Francitas.
Finally, the piece of paper shows distances to three nearby post offices. Those distances are apparently as the crow flies, however, and Google maps shows that the driving distances are considerably longer than the Postal Service states. Plus, all three of these post offices are also having their hours reduced under POStPlan.
And then went POStPlan
The employee who had been running the Francitas post office said it wasn’t worth a long commute to work just two hours a day, so in early November she gave notice that she’d be leaving. On November 19th, Francitas began its new hours, and the Postal Service sent someone over from another office to cover the shift. That lasted three days.
The Postal Service then declared an emergency suspension because of a lack of qualified personnel to run the office, and on Friday, the day after Thanksgiving, the window was closed and retail services suspended. Mail delivery to the post office boxes continued, however, and customers were able to enter the lobby and get their mail. If they needed to mail a parcel or do other retail services, they had to go to La Ward.
In January, the Postal Service found someone else to work the office, a retired gentleman who was mostly just interested in helping out the community. He was given two days of orientation, followed by about eight hours’ worth of hands-on training (rather than the 24 hours he was told to expect). He was then left by himself to run the Francitas post office, without even a working telephone to call for assistance (the office had been closed since November).
A couple of days later, a supervising postmaster came for a visit, ridiculed him for being a slow learner, and said that if he couldn’t handle the job, to just say so. Not surprisingly, the fellow quit.
Closing, the second time around
That was mid-February. About a month later, Carolina Jalufka, the woman who had filed the appeal back in 2011, went to pick up her mail one day and saw a notice in the lobby saying that the Postal Service had issued a final determination to close the Francitas post office. The notice, dated February 22, concludes with a paragraph explaining that final determinations can be appealed to the Postal Regulatory Commission within 30 days. The end of that appeals period was just a few days away, so Carolina quickly filed her second appeal with the PRC.
The notice, by the way, was posted high up in a glass case, where it was not likely to be seen and almost impossible to read. The Postal Service probably hoped that the 30 days for appeals would pass without anyone discovering it. Copies were not placed in post office boxes, and when Carolina asked for a copy, she was initially turned down and had to press further before getting one.
When it decided to close Francitas a second time, the Postal Service didn't go through another discontinuance study. There was no notice to customers of a proposal to study for discontinuance, no solicitation of public comments, no public meeting, no effort to follow any of the procedures described the Postal Service’s Discontinuance Handbook.
The second final determination notice is simply a copy of the 2011 final determination. The only difference is the date at the bottom and the signature. The Postal Service didn’t even bother correcting the postmaster savings that the commissioners had questioned in their dissenting opinions back in 2011 when the first discontinuance was appealed.
Those numbers are even more wrong now. The Postal Service had figured about $30,000 for labor costs, but with the POStPlan hours and wages, it would have cost less than $10,000 a year to operate Francitas — about the same amount that the Postal Service had estimated replacement services would cost. In other words, closing Francitas won’t save anything.
While the final determination notice provides the same rationale for closing the office as the 2011 notice, the local news item on the closing quotes a Postal Service representative saying, "We were unable to find a person to work a two-hour-a-day schedule so on February 22 we posted a notice that the office will be closed on March 26." The spokesperson added that the Postal Service planned to deliver the mail to a cluster box unit, which it expected to be installed by March 26.
A post office can be suspended when there’s a lack of qualified personnel to run it, and a suspension can be cause to initiate a discontinuance study, but a staffing problem does not constitute a legal justification for closing a post office permanently. There’s nothing in 39 CFR 241.3 that suggests the Postal Service can issue a final determination because of a lack of qualified personnel, and there’s no reference to that explanation in the final determination.
The second appeal
Anyway, Carolina’s second appeal to the PRC contains numerous criticisms of the Postal Service’s discontinuance process: inadequate notification of the public, misinformation about the problem of finding personnel to run the office, incorrect data about the distances to other post offices, and more.
On March 22, the Commission opened the docket on the second appeal. Three days later it received another letter from Carolina asking that the closure — set for March 26 — be delayed. The letter also points out that while the community had been told it would be getting a cluster box unit to replace the post office, no unit had been installed, and a request for rural route delivery had been denied. The post office was about to be closed with no viable alternative in place.
The Commission responded immediately to the request by issuing an order telling the Postal Service to keep the Francitas office open while the appeal was heard. As the Commission reminded the Postal Service, its “customary practice is to maintain operations at a post office for which a final determination has been issued pending the disposition on appeal.”
Two days later the Postal Service decided not to fight the appeal and withdrew the final determination. No explanation was provided.
What’s next?
Now Francitas is in limbo. By withdrawing the final determination, the Postal Service seems to be saying that it has decided to keep the post office open. But the post office remains closed under an emergency suspension, and it doesn’t look like the Postal Service has any plans to reopen it.
Perhaps the Postal Service realized that it had not followed proper procedures with doing the discontinuance, so it plans to try again, which means that Francitas could end up getting a third final determination to close.
Or perhaps the Postal Service will just leave Francitas under suspension and not do anything more. Now that the PRC has its eye on the case, that would be difficult, but it’s not unheard of. There are many post offices currently under suspension that were suspended many years ago.
Most likely, the Postal Service will finally get around to installing the cluster box unit it promised (rural delivery to individual homes is no longer an option). That might be fine with Francitas. As Carolina says, "We just want our mail."
But if that happens, it will mean that that the post office has closed completely, and that can’t happen without going through a discontinuance study, issuing a new final determination, and going through another appeals process. It will be difficult conducting such a process in good faith with the outcome a foregone conclusion.
There’s always the possibility that the Postal Service will reopen the post office in Francitas. That, after all, is what was promised with POStPlan. When Mr. Jeffrey Day, the Postal Service's witness for POStPlan, testified for the advisory opinion process, Chairman Goldway expressed concern that it would be difficult to find people to work two hours a day and suspensions would result. Mr. Day assured the Commissioners that the Postal Service had plenty of experience staffing post offices with part-time workers and that wouldn’t happen.
Whatever happens, the folks in Francitas aren’t going to just drop the matter and continue driving to La Ward everyday for their mail. They’re getting a hard lesson in how the Postal Service operates, but they're not giving up.
As the late, great Texan Molly Ivans once said, "What you need is sustained outrage… There's far too much unthinking respect given to authority." And there’s plenty of reason for outrage in Francitas.
UPDATE: On April 9, 2013, the Postal Service filed a document with the PRC showing that it delcared an emergency suspension on the Francitas post office for lack of qualified personnel to run the office. The suspension notice is dated March 26, 2013, and it says the office is suspended as of that same date. The Postal Service thus suspended Francitas a few days after the final determination was appealed to the PRC. Also, even though the Postal Service informed the local news media in February that the office would be closing on March 26, customers were not officially informed until the day of the suspension.
(Photo credits: Francitas post office lobby and exterior)
