Though spun to appear as improving service performance, the Postal Service has announced a proposal to further reduce service standards so it can eliminate afternoon collections nationally. The announcement preceded a planned webinar to discuss the proposal in advance of filing for an advisory opinion from the Postal Regulatory Commission. Though the USPS is overtly committed to going through the advisory opinion process, it’s well known that the resulting opinion is not binding and that, as has happened with previous opinions, the USPS will implement its plan as intended.
Details
The Postal Service provided an accompanying “fact sheet” that expanded the agency’s positive spin on its proposal while offering few specifics. Regarding the reduction of afternoon collection runs, now retitled euphemistically as “regional transportation optimization,” the USPS stated:
“Consolidation of delivery and collection activities: for Post Offices far from regional hubs, pick-up and drop-off of mail will occur primarily in the morning. This consolidation will provide flexibility in our transportation scheduling, bring a significant amount of mail volume into USPS plants sooner to begin processing earlier, and reduce local transportation costs, carbon emissions, and truck trips through American neighborhoods.”
It also claimed, without explanation, that some mail will actually get better service:
“We will expand our reach in the transportation network, which enables mail and packages to travel further within a day between our processing plants, thereby improving service expectations. For example, a piece of First-Class Mail that is currently traveling 22 hours through the transportation network, has a 4-day service standard. In the future, 22 hours of network travel time will have a 3-day service standard.”
More positive spin presented other purported “facts”:
“Within our network, for certain areas, all local mail will receive a 3-day commitment, at the slowest. In some instances, we will achieve a 2-day standard. … Delivery for approximately 75% of First-Class Mail will not be impacted by the refinements to our current service standards, and around two-thirds of mail will be delivered in 3 or less days. All First-Class Mail and USPS Ground Advantage will continue being delivered within 5 days. Our other products, like Marketing Mail and Periodicals, will also see improved service standards, with the day ranges for those products being shorter overall than they are today.
“These changes position us to better utilize our existing ground network, streamlining our approach to delivering both mail and packages efficiently and on time, while enabling us to adhere to the Postal Service Reform Act of 2022 mandates on the continued transportation of letters and packages within an integrated network. The refinements to our existing service standards will enhance service reliability, improve the daily reach of mail when traveling through the network, and are projected to reduce costs by approximately $3 billion annually. These changes are a crucial step toward achieving financial sustainability while upholding our mission to serve every U.S. household at least 6 days per week.”
The 2022 law
DeJoy cleverly now cites elements of the 2022 law which he advocated as the reasons compelling these changes.
The USPS previously had the operational latitude to move time-sensitive mail, like First-Class Mail and some Periodicals; premium package products like Priority Mail; and deferred service products like Parcel Post, in separate mailstreams, with the related attributable and institutional costs being assigned accordingly. The legislative “mandate” that DeJoy engineered – that all mail (market-dominant and competitive) must be in a single “integrated network” – impacts cost attribution.
DeJoy wants to grow package volume, so the cost attribution pattern of an “integrated network” can enable more advantageous pricing for competitive USPS package services. This was recognized somewhat obliquely by one of the “facts”:
“… our package and mail products will benefit across the board. The service standards we set for First-Class Mail are also aligned with all of our other products.”
Six-day delivery of all mail also was not codified before DeJoy agreed to it being part of the 2022 law. Doing so pleased the carriers’ unions but – in the face of declining volume – committed the USPS to retaining a level of service to an expanding delivery network being supported by less mail revenue.
Collection mail
The proposal about “optimization” of collections epitomizes DeJoy’s fixation on “efficiency” at the expense of service. Essentially, his proposal defines mail from ratepayers served by post offices more than fifty miles from the Regional Processing and Delivery Center as not qualified for the same service available to customers of closer post offices; an afternoon collection run to those distant offices isn’t “efficient.” However, in another creative move, DeJoy obscures the decrease in service by reframing how the deferred mail would move. By arguing that it would get into the mailstream “earlier” (i.e., in the morning) than if it had been in that afternoon’s collection, he overlooks that – absent the more “efficient” collection regime – that mail would have been in the mailstream the previous day – when it was actually mailed. In turn, by redefining the day of mailing, he can continue to claim the mail gets the same service.
Despite the obvious, the USPS “fact sheet” states:
“Overall, more mail will move quicker than before, and the vast majority of mail will keep the same service standard. While some end-to-end products may experience an additional day, the efficiency of the new network is expected to advance much of this volume. Additionally, no First-Class Mail will be delivered later than 5 days within the continental United States. … These changes are designed to save costs, maintain or improve service levels for most mail and packages, and allow for volume advancement whenever possible. …”
Service
As for service for those offices losing their afternoon collections, the USPS glosses over the issue in its “fact sheet”:
“How will these changes affect rural areas? USPS will maintain its commitment to universal service, ensuring reliable delivery to all communities regardless of distance.”
In an interview with The Washington Post, DeJoy admitted his proposal would result in different levels of service, stating “customers within 50 miles of the Postal Service’s largest processing facilities [will get] faster delivery service.” Justifying this as another necessary step in his Plan to fix problems he says he inherited from his predecessors, DeJoy added:
“At the end of the day, I think some portion of the mail showing up 12 hours later, I think it’s a price that had to be paid for letting this place be neglected. You look around every other country, [delivery] is longer, it’s much more expensive. We’re trying to save the Postal Service – not figuratively, not to advocate for something. We’re trying to literally save the Postal Service.”
How members of Congress will react to this isn’t yet known, but DeJoy was characteristically dismissive of whatever response they might have. As the Post reported:
“DeJoy in an interview shot back that lawmakers were ‘out of their league’ with their critiques of the agency. “They don’t understand the business. Nobody knows what it takes to compete with FedEx and UPS and drives billions of dollars of cost out of here that’s in the critique business. Even though it’s Congress, they don’t know,’ DeJoy said.”
DeJoy obviously did not see any irony in his comments. He’s barely any more educated about “the business” now than he was in 2020, and even at that he likely knows only what his inner circle of sycophants wants him to know. More worrisome, it’s his perspective that informs the USPS governors in their decision-making on matters like filings with the PRC.
The Postal Service offers no explanation for how actual service performance will improve by deferring the collection of some mail or expanding its more “efficient” ground transportation network.
In its 2021 filing to reduce service standards for First-Class Mail and some Periodicals, the USPS claimed that the standards then in place were “unattainable” and so, without any efforts to improve operational discipline, declared they had to be changed. (We now know that part of the motive for the reduction was to allow greater use of ground transportation, the mode favored by PMG DeJoy.) Apparently, even with the use of more ground transportation, the relaxed service standards are still unachievable so, rather than finding ways to make his network perform better, DeJoy wants ratepayers to again accept slower service:
“All First-Class Mail and USPS Ground Advantage will continue being delivered within 5 days.”
In effect, mail that may now be receiving better than 5-day service could be delivered more slowly and still be within DeJoy’s commitment. Presumably, ratepayers would be consoled because the reduced service is more “efficient.”
Perhaps the most obsequious element of the Postal Service’s announcement was its invocation of environmental considerations. Claiming the elimination of afternoon collection runs “contributes to reduced carbon emissions and truck trips through American neighborhoods” is a transparently self-serving attempt to sanctify a simple reduction in service.
The process
The Postal Service has scheduled a pre-filing webinar on September 5 to provide more details and receive input from participants; preregistration is required. All commercial mail producers and their clients have a reason to do so; the registration link is https://usps.zoomgov.com/webinar/register/WN_Z3Xd09nNR1uf20GyKfRKnQ. Registration closes September 3 or when capacity is reached.
After digesting the input it receives – though likely without making substantive changes – the Postal Service would make its formal filing with the PRC. In turn, the commission would establish a procedural schedule including for notices of intervention; submission of comments, interrogatories, and responses; and other steps. Barring any extension, the PRC must issue its opinion no later than 90 days after the USPS filing, making the agency’s guarantee somewhat pointless:
“The Postal Service would not implement the proposed service standard changes any sooner than 90 days after a request for an advisory opinion is filed with the Commission (which would occur following the pre-filing conference), meaning any implementation of the proposed service standards would not occur until the next calendar year.”
If history is any guide, the USPS will disregard the PRC’s opinion entirely and do what it plans to do anyway.
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