The U.S. Postal Service today asked the Postal Regulatory Commission (PRC) to expedite consideration of the Postal Service’s plan to make its operations more efficient, reduce costs and ensure the long-term affordability of mail.

The request filed with the PRC calls on the Commission to issue its non-binding advisory opinion on planned Postal Service network and service standard changes by mid-April 2012. The current moratorium on the closing of any Post Office or mail processing facility expires on May 15, 2012. The Postal Service voluntarily agreed to the moratorium in response to congressional requests in the hope it would help facilitate the enactment of comprehensive postal legislation.

The Postal Service had laid out a carefully designed plan to return to profitability while meeting the changing needs of its customers. The plan includes reducing the number of mail processing facilities from 460 today to fewer than 200 by 2013 and revising mail delivery service standards. The network changes will provide more predictable and reliable service and is part of a broader effort to stabilize the Postal Service finances and continue to provide affordable, universal service for generations to come.

The PRC issued a schedule last week that guarantees the Commission will not issue its non-binding advisory opinion until July 10, 2012, at the earliest. The Postal Service would like to move forward with its planned network and service standard changes with the benefit of the PRC’s advisory opinion, which it would need to have well before May 15.

The Postal Service believes that more than four months, from Dec. 5, 2011 to mid-April 2012, is adequate time for the PRC to evaluate and comment on these proposed operational changes.

The request filed with the PRC is available at www.prc.gov.
]]> http://www.postalnewsblog.com/2012/01/19/uspsasks-prc-to-accelerate-review-of-network-and-service-cuts/feed/ 4 http://www.postalnewsblog.com/2011/12/23/prc-advisory-opinion-finds-usps-proposal-for-retail-closures-lacks-proper-analysis/ http://www.postalnewsblog.com/2011/12/23/prc-advisory-opinion-finds-usps-proposal-for-retail-closures-lacks-proper-analysis/#comments Fri, 23 Dec 2011 20:11:32 +0000 brian http://postalnews.com/postalnewsblog/?p=449 Washington, DC –The Postal Regulatory Commission today issued its Advisory Opinion in Docket N2011-1 on the Postal Service’s Retail Access Optimization Initiative (RAOI), a program that identified more than 3,600 post offices and other retail facilities for possible closure this year.

The Postal Service is required to ask the Commission for an Advisory Opinion on any change in nationwide service it proposes. The Commission found that the RAOI is likely to affect access to postal services.

The Commission’s primary finding is that the RAOI was not designed to optimize the network. The Commission recommends the use of modern optimization tools and techniques to better maximize net retail revenues while fulfilling statutory service obligations.

Ruth Goldway, Chairman of the PRC explained: “The Commission was unanimous in expressing its concern that the Postal Service’s plan did not and could not, because of lack of data and analysis, determine the facilities most likely to serve the greatest number, reduce the greatest costs, or enhance the potential for growth or stability in the system. We agree that the Postal Service access network should be right-sized but found that the RAOI was not the proper approach to meet that goal.”

The Commission was unable to develop reliable cost savings estimates because the Postal Service does not collect facility-specific revenue and cost data, or separate retail costs from other operational costs. The Commission found that such data should be available for use in comprehensive facility closing plans.

The Commission review also included examination of an updated Postal Service process to evaluate facilities for closure. While acknowledging significant improvements, the Commission identified methods for enhancing the process to ensure meaningful public participation.

Specifically, the Commission recommends that training for local managers responsible for implementing the process include: (1) the statutory requirements applicable when evaluating a retail postal facility for closure, (2) more robust processes for obtaining and evaluating relevant community information, and (3) information on how other Postal Service initiatives may impact service in the affected area.

A core concern of the Commission is the question of suitable alternative access. Many current alternatives offer only a limited array of services, such as stamp sales and post office boxes. The Commission believes that alternative access for sites being closed must be presently available, viable and an adequate substitute for existing access.

“More than 160 appeals of decisions to close individual post offices, not related to the RAOI, have come before the Commission recently. In each case, we have seen how concerned local communities have been with losing access. With real, practical alternatives available, these communities would be far less likely to feel the loss of a neighborhood post office and would join with the Postal Service in the move to efficient alternatives,” commented Chairman Goldway.

Dear DMA Member,

Your Business is Being Threatened.

On Monday, the United States Postal Service (USPS) told the Postal Regulatory Commission (PRC) that it will pursue its request for exigent – above inflation – postage increases. These increases would be above and beyond the already scheduled 2.1 percent increase set to take effect on January 22, 2012.

DMA believes that the future of the US Mail depends upon forward thinking. Rather than digging up the past, USPS should be looking forward and right-sizing its network, transportation, and employee complement. DMA immediately urged the PRC to reject the USPS’ plan, which relies upon old data and failed logic to support driving postage higher. This is not the time to drive more mail from the system.

On your behalf, DMA has already fought – and won – this battle once in 2010. Now we’re gearing up to win it for you once again. DMA successfully opposed the previous exigent case on the grounds that the circumstances didn’t warrant an exigent rate hike and that such a hike would in fact drive more mail out of the system at a time when USPS should be removing excess capacity.

Every step of the way, DMA has kept its members up to speed on the fast-moving postal debate. Our very own Direct from Washington e-newsletter delivers comprehensive information weekly. You have also had the opportunity to speak directly with postal policymakers through our “Postal Perspectives” Webinar Series, which focuses on the tough decisions and significant changes that must be made to improve the fiscal health of the USPS. These informal conversations with the policymakers at the center of the postal debate give you the opportunity to hear exactly what the experts are thinking about the future of USPS.

In addition to fighting rate increases at the PRC, DMA has been working hard to make sure that postal legislation in Congress safeguards the interests of all DMA members. We continue to work closely with key policymakers – on both sides of Capitol Hill, and both sides of the political aisle – and our efforts are really paying off.

• Just yesterday afternoon, the Senate Homeland Security and Government Reform Committee voted to send the “21st Century Postal Service Act” to the Senate floor. When this bipartisan bill was introduced last week, it failed to properly protect catalog products from steep and immediate postage increases. DMA worked with key leaders in the Senate to create a provision that safeguards catalogs appropriately before the bill was passed out of the Committee.
• DMA was also successful in fighting two proposed amendments that would have required USPS to create a national “Do Not Mail” program. Because of our efforts, these amendments were not even considered by the Committee.
• We are also fighting to defend the lifeblood of nonprofit mailers. DMA was able to keep a harmful provision that would have slashed the nonprofit rate preference from being introduced in the Senate. We are also fighting hard to have a similar provision removed from legislation being considered in the House.

We are not resting on our laurels. Instead, we will take to Capitol Hill next week for a special DMA Postal Hill Day on November 17 in Washington, DC. A host of DMA catalogers and DMANF nonprofit mailers will join DMA’s Government Affairs team in meetings with senior Congressional staff leading the way on postal reform in Congress.

We encourage you to join the hundreds of DMA members that have already taken “DMAAction” to support our efforts in Washington. Visit our DMAAction website today to learn how you can tell Congress to safeguard the interests of the mailing community!

Sincerely,

Linda Woolley

EVP, Washington Operations

Direct Marketing Association

Currently, the Commission is engaged in crucial deliberations regarding the future of the United States Postal Service, including the number of its post offices, the level of service it will provide and its future financial stability.

Immediately prior to joining the PRC, Taub served as Special Assistant to United States Secretary of the Army John McHugh. Earlier, Taub worked in the U.S. House of Representatives, including service for a decade as Chief of Staff to then Congressman McHugh. He has extensive expertise with postal policy and was instrumental in developing the 2006 Postal Accountability and Enhancement Act. Taub also served for 12 years on the U.S. House of Representative’s Oversight & Government Reform Committee in a series of senior positions, including service as Staff Director of its former Postal Service Subcommittee.

Commissioner Acton was nominated to his first term by President George W. Bush in November of 2005 and subsequently nominated for a second term by President Barack Obama in May of 2011. He was elected by his fellow commissioners to serve a one-year term as Vice Chairman this past December. Prior to his appointment, Acton served as Chief of Staff at the former Postal Rate Commission, assisting in managing all aspects of agency operations since 2002.

Chairman Goldway said, “I am very pleased to welcome back Mark Acton whose diligence and sense of fairness have contributed to the widespread acceptance of Commission decisions. And I am enthusiastic in welcoming Robert Taub whose proven combination of professionalism and devotion to postal issues will add to our strength as an independent agency.”

The word has it that the USPS will be submitting its network realignment as a major service change to the PRC in mid September. My understanding is that the PRC will have around 90 days to make recommendations to the USPS but has no authority to prevent the USPS from implementing the changes.

via PostCom: Postal News and Information from Around the World.

All interested persons are hereby notified that notices of intervention in this proceeding shall be due on or before August 19, 2011. Responses to discovery shall be due within 7 days.The hearing to receive the Postal Service’s direct case shall begin September 8, 2011.

Intervenor evidence must be submitted by September 16, 2011.

The hearing to receive intervenor evidence shall begin October 3, 2011.

Unless the Postal Service elects to submit surrebuttal evidence, briefs shall be due October 14, 2011, and reply briefs shall be due October 21, 2011.

If the Postal Service elects to submit surrebuttal evidence, that evidence is due by October 11, 2011.

The hearing to receive the surrebuttal evidence shall be October 17, 2011.

If surrebuttal evidence is submitted, briefs shall be due October 26, 2011, and reply briefs shall be due November 2, 2011.

Order_No_778

The Commission will hold public, on-the-record hearings to analyze and cross-examine the Postal Service’s proposal and supporting evidence. During the process, mail users and interested members of the public may offer supporting or opposing views, both informally and as part of more formal, technical presentations. The Commission will also solicit public comments through its website. The Service cannot implement the changes until 90 days after filing the request.

“The Advisory Opinion process is the opportunity for the public’s concerns over the process to be heard, and for the Postal Service to be given the direction it needs to continue to provide good service to the nation,” said PRC Chairman Ruth Goldway. “The Commission supports the Postal Service’s efforts to become more efficient, but with regard to post offices, significant changes must be done within the framework of the legal requirement to provide universal service.”

The public is invited to share their views via the Commission web site, www.prc.gov, by clicking the “contact PRC” tab to access a convenient online customer service form. To participate more formally in the process and to file documents to be included in the online public record, interested parties should click the “Filing Online” tab and follow the appropriate instructions.

072811_Commission to Review Postal Services Post Office Closings Plan_1948.pdf (application/pdf Object).

U.S. Senator Susan Collins, Ranking Member of the Senate Homeland Security and Governmental Affairs Committee, today urged the Postal Regulatory Commission (PRC) to consider Congressional intent as it determines how closely proposed rate hikes must be linked to an exigent circumstance to warrant an increase above the rate of inflation.

The 2006 postal reform law, which Senator Collins authored, capped postal rate increases at the rate of inflation, but allowed a narrow exception for extraordinary or exceptional circumstances such as a terrorist attack or catastrophic natural disaster.

Senator Collins’ committee has jurisdiction over the U.S. Postal Service. In January, she filed an amicus brief urging the U.S. Court of Appeals for the District of Columbia Circuit to uphold the PRC’s unanimous decision to reject the Postal Service’s requested rate hikes, which on average, would have increased rates by four to six percent. The Court of Appeals largely agreed with the PRC’s and Senator Collins’ position, but remanded to the PRC the narrow question of how close the causal link must be between a proposed rate increase and the exigent circumstances used by the Postal Service to justify the increase.

"The economy and technology are affecting the Postal Service and, indeed, most businesses. But in writing postal reform legislation in 2006, my intention was not to permit rate increases above the inflation-based cap as relief from chronic, ordinary, or unexceptional circumstances and general Postal Service red ink," said Senator Collins. "I urge the PRC to require that the nexus between the exigent circumstances and the proposed rate hike be close. This is necessary to preserve the stability and predictability of rates that the 2006 law sought to establish.

"Excessive rate increases coupled with service cutbacks will only drive customers away. The Postal Service needs to redouble its efforts to cut costs, develop new services to increase volume, re-invent its business model, and work with the Administration to remedy an overpayment to the federal retirement fund. I will continue to press the Administration and the Postal Service on these vital reforms."

Murray Comarow: "As all postal governors are corrupt and stupid, I was pleased to have them monitored by the PRC commissioners who are honest and sage. It appears that I was wrong about the PRC, since Congressman Issa proposes two more bodies to help manage the USPS: the Commission on Postal Reorganization and an Authority modeled on the D.C. Control Board. Kudos to Issa. The other 16 self-supporting government agencies struggle along with only one government board. How foolish. Each should have four. That would make them more businesslike." [EdNote: Gosh. Do you think he's gotten his tongue out of his cheek?]

via PostCom: Postal News and Information from Around the World.

The Postal Service has estimated that making the move to a five-day schedule would yield a net annual cost reduction of $3.1 billion, based on extensive market research and financial estimates provided to the PRC last year. The PRC’s advisory opinion concluded a five-day street delivery schedule would only achieve $1.7 billion in net annual savings.

In its report to Congress, USPS said the $1.4 billion discrepancy results from:

• The PRC’s unwillingness to recognize about $760 million in savings from increased letter carrier productivity and efficiency under a five-day schedule.
• The PRC’s failure to account for more than $260 million in highway transportation and mail processing economies associated with one less day of street delivery.
• The Commission’s summary dismissal of testimony by market research experts to reach its conclusion that the Postal Service estimate of annual revenue loss resulting from the change was understated by $386 million.

The Postal Service report says the total impact of transitioning to a five-day delivery schedule will significantly improve its financial stability. “No other single action the Postal Service could take operationally will result in such large costs savings,” it says.

The Postal Service report also disputes the PRC claim that the five-day delivery proposal did not sufficiently take into account the needs of customers in rural and remote areas. USPS contends its extensive market research considered the views of rural customers and incorporated them into its implementation plan.

Finally, the report says the PRC hasn’t fulfilled its core function in the nonbinding advisory process, which is to address whether the proposed service changes would be consistent with governing statutory policies.