Congressional Letter Comments on PRC Rulemaking

For someone who rejects outside involvement in how he conducts business, Postmaster General Louis DeJoy has, through his policies and attitudes, managed to attract the very kind of external oversight he dislikes.

Another letter

The latest example is a May 23 letter to the Postal Regulatory Commission from four members of the House Committee on Oversight and Accountability: Jamie Raskin (MD 8th), Raja Krishnamoorthi (IL 8th), Gerald Connolly (VA 11th), and Kweisi Mfume (MD 7th).  In their letter, the representatives offered their “comments on the advance notice of proposed rulemaking on the statutory review of the system for regulating rates and classes for market dominant products,” adding:

On Tuesday, April 9, 2024, the Postal Service filed notice of proposed price hikes pending approval by the Postal Regulatory Commission (the Commission).  The proposal is to increase first-class Forever stamp prices from 68 cents to 73 cents.  This marks the sixth time since March 2021 that the Postal Service has increased postage rates.  This rate hike, if implemented, comes at a time when postal delivery performance and mail and package volumes are experiencing historic lows.  We believe that this trajectory is setting the Postal Service on a course that threatens its future as an effective, efficient, and vital American institution.

The graph below, developed from data supplied by the Postal Service, demonstrates the increasingly steep rise in first-class postage rates.  In particular, we note that the increase becomes more severe following the start of Postmaster General DeJoy’s ten-year ‘Delivering for America’ plan.  The mail that most individuals are likely to send is currently meeting its performance standard 81% of the time.  The Postal Service’s own target is 92%.

The trend of increasing postal prices multiple times per year, along with the decline in postal delivery performance that followed the implementation of Delivering for America plan, are clearly at odds with the statutory objectives and factors for regulating the mail, as established in 39 USC. § 3622(b) and 39 USC § 3622(c), respectively. “Among the statutory objectives are requirements to ‘maintain high quality service standards’ and ‘establish and maintain a just and reasonable schedule for rates and classifications.’  The statutory factors the Postal Service must consider include ‘the effect of rate increases upon the general public, business mail users, and enterprises in the private sector of the economy engaged in the delivery of mail matter other than letters.’

“The Commission’s research has shown that the Postal Service’s performance has failed to meet its targets.  In 2023, the Commission found that more than half of all market dominant products failed to meet their targets in fiscal year (FY) 2023.  The Commission notes that it directed the Postal Service to ‘take corrective action’ to improve performance and that the Commission developed directives designed to ‘elicit information and data from the Postal Service regarding service performance’ and how the Postal Service plans to restore that service in FY 2024.

“Additionally, the Postal Service’s total mail volume has continued to decline steadily since Postmaster General DeJoy first took office in 2020.  This decline includes volume losses in the First-Class Mail, the First-Class Single Piece Mail, and even the shipping and package categories.  In 2020, total mail volume was at 129.17 billion units, but by 2023 that number fell to 116.15 billion units, resulting in a 10% drop in mail volume.  Mail volume is directly correlated to the economic health of the Postal Service.  We know this because, in the midst of these significant and continuous declines, the Postal Service reported a $6.5 billion net loss for FY 2023, and it is expected to see a similar loss for FY 2024.  We are concerned with the extent to which the pace of these postage price changes may contribute to volume declines in excess of earlier projections on total mail volume.

“It is imperative that the Postal Service meet its service delivery standards, curb excessive mail volume declines, and prevent the Postal Service from entering unrecoverable financial peril, or else put at risk the livelihood of the millions of Americans who rely on the Postal Service for their medication, social security checks, mail-in ballots, and veterans’ benefits.  We request that you consider these issues seriously as you review the system for regulating rates and classes for market dominant products.”

Observations

To Congress, it must be somewhat irritating that, despite having shed its management of the Post Office Department in 1970, it still is recurringly drawn into postal matters.  Presumably, the 54-year-old Postal Service should have by now become capable of running the nation’s postal system without needing attention from Congress.  Of course, in fairness to all concerned, the America of 1970 isn’t what America is in 2024, especially regarding how people shop, communicate, and use the post.

Nonetheless, legislators lately have become increasingly aware of the distress of ratepayers – because of Postmaster General Louis DeJoy’s not-so-“judicious” pursuit of higher prices while failing to keep service levels anywhere near where they were under his often-derided predecessors.

Most executives who would be leaders of an enterprise the size and national significance as the Postal Service would long ago have understood the need for attention to his or her many constituencies, knowing that their support (or lack thereof) can impact both short- and long-term success. DeJoy, however, seems intent on offending everyone, demonstrating an indifferently adversarial attitude that only he doesn’t see as impeding achievement of whatever accomplishments he wants to leave as his legacy.  Nonetheless, at this point, the level of legislators’ interest in the Postal Service – notably its rates and service – should be a sign that the PMG needs to amend his approach.  If he doesn’t want “interference” from legislators (or the PRC or anyone else), he might want to get the message soon.

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