In the July 14 issue of Mailers Hub News we initiated an award – the bull trophy – that would be given to the Postal Service when it makes an announcement that is no more than transparent spin, or issues a proposal that is egregiously self-serving, and thus worthy of being equated to what the trophy animal produces.
We’re making the second such award this week for a September 9 proposal filed with the Postal Regulatory Commission as part of Docket PI2025-6. In the filing, the USPS announced changes it was making to its service performance measurement plan:
“The Postal Service’s SPM Plan documents the current state of the Postal Service’s SPM system. The current SPM system, however, does not reliably account for extraordinary events in a way that permits the Postal Service to quantify their effect on service performance scores. …”
The Postal Service went on to cite examples of wildfires, hurricanes, and other natural disasters, as well as mercury spills and low employee availability in processing centers, as examples of events that disrupt operations and logistics and, therefore, impair service.
Despite the short-term or localized nature of such occurrences, the USPS argues their impact on service performance is wider, and thus might unfairly impact how service is perceived by the public based on the current rules for service measurement:
“While service performance results that include mailpieces affected by extraordinary events accurately reflect service times experienced by impacted mail users, they do not fairly reflect the Postal Service’s true performance but rather performance that is skewed by events outside of the Postal Service’s control. If such results indicate reduced service performance, it is unclear using the current SPM system to what extent such results are attributable to the Postal Service and what is attributable to events beyond the Postal Service’s control. Because the Commission and the public are chiefly interested in evaluating how the Postal Service ordinarily performs (i.e., whether its regular operations are effective), the results would more accurately, reliably, and representatively reflect Postal Service regular operational performance if they focused on mail unaffected by extraordinary events beyond the Postal Service’s control. …
“For these reasons, the Postal Service intends to exclude from measurement certain mailpieces affected by extraordinary events that materially disrupt the timely collection, processing, transportation, and/or delivery of mail:
- Mailpieces that originate or destinate in a three- or five-digit ZIP Code area experiencing disruption;
- Mailpieces that would ordinarily be processed in one facility but, as a direct or indirect result of disruption at that facility, are processed in another facility;
- Mailpieces that are processed in a facility where operations are disrupted as a direct or indirect result of disruption at that or another facility; and/or
- Mailpieces that require significant diversion from ordinary transportation routes or methods because of the disruption.lpieces that require significant diversion from ordinary transportation routes or methods because of the disruption.
“In all cases, the salient criterion is whether the extraordinary event not only affects postal operations, but whether it impairs the Postal Service’s ability to perform at normal service levels to such a degree that reported service performance results would be unrepresentative. …”
Excuses
In his 10-Year Plan, former postmaster general Louis DeJoy described the service standards then in effect as “unattainable,” and so began a process that has repeatedly relaxed service standards and modified service measurement rules to make attainment of service targets (or the appearance it) easier. However, even with the eased standards and other exemptions to measurement, service today continues to underperform compared to what his predecessors provided with an “inefficient” network. Nonetheless, with this latest proposal, DeJoy’s devoted apostles still at USPS HQ are continuing the process of lowering the bar on service.
Though natural disasters and facility impairments might be temporary disruptions to postal operations, it’s difficult to accept the Postal Service’s assertion that they meaningfully impact the overall functioning of the agency’s network of hundreds of facilities or that, as a result, they visibly worsen the homogenized data that’s based on service in fifty states over a 365-day period.
Moreover, given its propensity to lay blame elsewhere and excuse itself for its own failures, it would seem unwise to provide the Postal Service with the equivalent of a blank check to use whenever it needs an excuse for why it can’t meet its own decrepit service targets.
Disruptions are normal and common. Facilities lose power, transportation is impeded by traffic accidents and construction, rain and snow impact highways, processing machinery fails, employees call-in sick, etc, etc. Though the USPS (and, before it, the Post Office Department) have dealt with such events for decades and never sought a waiver from service expectations, one seems now needed, not as a means to improve service, but rather only how it appears to be, using clever calculations and more exceptions to measurement.
Aside from the obviously self-serving nature of the proposal, there are no objective criteria that would be used in its operation. What is “normal” performance – the baseline before allowance for “extraordinary events”? Is it 100% attainment of published standards, or actual performance over a specific period of time? Is it a national figure, or does it vary based on area, district, or facility?
If there is a “disruption,” what defines it? When does an event rise to that level that it should generate a free pass for the USPS for however long it wants to use it? Arguably, almost anything could be labeled a “disruption,” including deficient supervision of operations and poor employee performance. In the amorphous context of the Postal Service’s proposal, should such conditions be used to yield unspecified forgiveness for falling short on service?
Ratepayers know that stuff happens that will briefly impact USPS service here or there for some reason. However, they also know that USPS service performance is poor and that it keeps trying to find ways to make it look better than it is. To institutionalize self-defined excuses for service failures is not supportive of achieving real improvement.