A proposed rule published by the Postal Regulatory Commission in the September 30 Federal Register seeks to enhance the information provided by the Postal Service’s periodic reports about service performance.
Background
In an earlier advance notice of proposed rulemaking, published in the May 2 Federal Register, the PRC proposed
“… revisions to existing annual and periodic service performance reporting requirements for the Postal Service’s market-dominant products as well as related revisions consistent with the Postal Service Reform Act of 2022.”
That statute, enacted on April 6,
“… imposed requirements on the Postal Service and the Commission that require consideration of changes to [commission rules about USPS service performance reporting]. Specifically, the PSRA directs the Postal Service to develop and maintain a publicly available online ‘dashboard’ that provides weekly service performance data for Market Dominant products. … It also mandates that the Commission provide reporting requirements for this Postal Service dashboard as well as ‘recommendations for any modifications to the Postal Service’s measurement systems necessary to measure and publish the performance information’ located on the dashboard.”
The recent notice of rulemaking is the next step in the process that began last spring. As the PRC explained in its notice:
“… The Commission received a wide range of comments in response to [the notice], both discussing the suggested revisions and proposing additional amendments to the reporting requirements. After reviewing the commenters’ suggestions and analysis, the Commission proposes the following rules.”
Requirements
Much of the commission’s proposal consists of revisions to those parts of the Code of Federal Regulations that codify the requirements it proposes. However, thankfully, the PRC preceded that with a summary of its proposals written in terms easier for readers to follow:
“First, the Commission proposes a provision requiring the Postal Service to report average actual “delivery days” – i.e., days in which Market Dominant products are eligible for delivery – for each Market Dominant product. The Commission finds the metric of average actual delivery days an easier metric to understand for some mailers than the percentage of on-time delivery metric. Under this proposed provision, the Postal Service must also report the following information on dispersion around the average: percent delivered within +1 day of service standard, percent delivered within +2 days of service standard, and percent delivered within +3 days of service standard. These data must be reported for each Market Dominant product at the current District, Postal Administrative Area (Area), and National levels both quarterly in the Service Performance Measurement (SPM) reports and annually in the Annual Compliance Review (ACR) reports.
“Second, the Commission proposes a provision requiring the Postal Service to report point impact data for the top 10 root causes of on-time performance failures for each Market Dominant product (except those included in Special Services) that did not meet its service performance goal pursuant to [regulations]. Balancing the utility of the data with the burden to the Postal Service, the Commission notes that point impact data is useful for isolating significant drivers of delay for products that do not meet their service performance goals while avoiding the additional costs of reporting on products that do. For First-Class Mail products that do not meet their service performance goals, the Postal Service must report the top 10 root causes of failure at both the Area level and National level. For the remaining Market Dominant products that do not meet service performance targets, the Postal Service must report the top 10 root causes of failure at the National level. Reporting must occur annually in the ACR.
“Third, the Commission proposes that the Postal Service report data related to its Site-Specific Operating Plans (SSOPs), by Region and Division (as identified in the SSOPs) and at the National level, both quarterly and annually. … While these new data do not specifically address the performance of the entire postal network, they do provide performance data (i.e., percent on-time performance for each SSOP measurement category, such as “Flat Sequencing System”) subdivided into Regions and Divisions as well as at the National total.
“Fourth, the Commission proposes that Postal Service report the performance of each nonpostal product in the ACR, as required by [regulations]. The Commission proposes that these performance data be disaggregated by District and Area as well as for the Nation on an annual and quarterly basis.
“Fifth, the Commission proposes that the Postal Service report: (a) mail excluded from measurement, disaggregated by reason(s) for exclusion; and (b) mail volumes measured and unmeasured by Full Service Intelligent Mail barcode (IMb). With respect to reporting such mail volumes disaggregated by reason for exclusion, the Commission proposes that the current quarterly report (filed as a spreadsheet attachment to the Postal Service’s quarterly reports on service performance) be modified to include the number of mailpieces excluded from measurement for each exclusion category as well as the percentage of the total exclusions represented by that exclusion category. This additional reporting is warranted because the percentage calculations alone without the supporting volume data do not allow for the evaluation of performance trends over time. The Postal Service must report these data both on a quarterly basis on the same schedule as its Quarterly Reports pursuant to [regulations] (in other words, 40 days after the close of the quarter) and annually in the ACR. Regarding the report on mail volume measured and unmeasured by IMb, for each field in the current form (filed as a spreadsheet attachment to the Postal Service’s quarterly reports on service performance), the Postal Service should also present the same data point from the same period in the previous year.
In addition, the Postal Service should present for each product category:
(1) the percentage of mailpieces in measurement compared to total mailpieces;
(2) the percentage of mailpieces not in measurement compared to total mailpieces;
(3) the percentage of Full-Service IMb mailpieces in measurement compared to total IMb Full-Service mailpieces; and
(4) the percentage of Full-Service IMb mailpieces not in measurement compared to total IMb Full-Service mailpieces. These additional data points will be valuable for mailers and the Commission to evaluate measured and unmeasured mail volumes over time. The Postal Service should report these data on a quarterly basis, 60 days after the close of each quarter, and annually in the ACR. The Commission also proposes codifying the existing requirement that the Postal Service must provide descriptions of the current methodologies used to verify the accuracy, reliability, and representativeness of service performance data for each service performance measurement system 90 days after the close of each fiscal year.Sixth, pursuant to [regulations], the Commission proposes the specific requirements for the Postal Service’s online dashboard of service performance data for each Market Dominant product. The Commission proposes requiring the Postal Service to present service performance results for each ZIP Code, District, and Area, as well as at the National level, updated on a weekly basis. The dashboard should include a 5-Digit ZIP Code lookup feature that allows the user to see the service performance results for their ZIP Code and match their ZIP Codes with the corresponding District and Area. With respect to the specific service performance information available on the dashboard, it must provide the following data (at a minimum): (1) service performance (measured as a percent on-time delivery and average delivery days) by each Market Dominant mail class, product, and applicable service standard by District, Area, Nation, and 5-Digit ZIP Code; (2) service performance (measured as a percent on-time delivery and average delivery days) by Market Dominant mail class, product, and applicable service standard, by time period of the user’s selection, along with the previous two fiscal years; and (3) service performance (measured as a percent on-time delivery and average delivery days) by Market Dominant mail class, product, and applicable service standard based on a selected pair of origin/destination 3-Digit or 5-Digit ZIP Code that a user would choose. The dashboard should improve transparency, promote accountability, provide actionable data, and thus lead to improved service performance. The Commission also proposes that the Postal Service report several other categories of mail on the dashboard: (1) political and election mail; (2) Reply Mail within the First-Class Single-Piece Mail category; and (3) nonprofit mail … .
“Seventh, the Commission proposes to formally codify requirements that will ensure the continuation of the existing auditing program and to consolidate the existing requirements (which are dispersed in multiple orders). Therefore, consistent with the existing auditing program, the Commission proposes to require that: (1) the Postal Service shall continue with its program to provide third-party audits of its service performance measurement systems; (2) for any measure deemed by the auditor to be not achieved or partially achieved, the Postal Service shall continue to include its response explaining the Postal Service’s mitigation plan; (3) the Postal Service shall file each audit report (and its response) with the Commission no later than 60 days after each applicable reporting quarter; and (4) the audit reports shall continue to specifically include inbound and outbound single-piece First-Class Mail International and the Green Card option of the Return Receipt as well as the metrics used to perform the audits and analysis specific to these types of services.”
Whether the proposed rule reflects dissatisfaction with the Postal Service’s current reporting requirements wasn’t clear, but the agency’s weekly press releases touting its service stand in contrast to the more granular data provided to the PRC quarterly and the real experience of commercial mailers and their clients.
Though the USPS has often resisted more stringent reporting, citing the “burden” of developing the data, the agency was readily able to do so during the 2020 elections when it was so ordered by federal courts. Given the sophistication and extent of current USPS data systems, observers readily concluded that resistance to more detailed reporting was not credibly attributable to the related “burden” as much as to a simple institutional unwillingness to disclose the data.
If the commission’s rulemaking succeeds in overcoming the Postal Service’s resistance, ratepayers may have a much better view of actual USPS service performance as a result.
The full text of the PRC’s Federal Register notice can be found at https://www.govinfo.gov/content/pkg/FR-2022-05-02/pdf/2022-09327.pdf. Comments on the proposed rule are due by October 31.
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