The LEAGUE is concerned that the Postal Service is trying through regulation to accomplish what it has not been able to accomplish through legislation. They are trying to get the unfettered ability to close as many small rural Post Offices as it wants without taking in to account all the reasons they are there, to serve the needs of rural America. The Postal Service has filed formal notice through the Federal Register of a proposed change to the Discontinuance (closing) process for Post Offices found in 39 Code of Federal Regulations (CFR). This is different from US Code Title 39 which is law; these are Postal Service regulations and do not need legislative approval or a bill to change. It is simply a regulation change and not law. The Post Office will seek comments (written) for thirty days. They will review those comments and make their determinations on whether to change these regulations and change the face of rural America.
You can read between the lines and figure out where this is going. Unless we get our Representatives to intervene these regulations will most likely be changed and regardless of the nice spin being placed on this proposal it is not good for rural America.
One of the changes would propose applying the discontinuance process to all Postal Service operated retail facilities. This means the process would, to some extent include stations and branches where currently only independent Post Offices are covered under the formal closing process. The problem is this change also means they can convert an independent Post Office to a station or branch without consolidating or closing which they have to do at the present time. Its underlying intent is to try and finesse post office closing procedures and to try to change them to stations and branches that do not have a full closing process. By doing so they also leave the office open to easier closing since there are no appeal rights for station and branches. This would open the door to thousands of Post Offices being run without a Postmaster in charge and easier closings in the future.
The second changes the requirement that a District Manager must initiate the study of a USPS-operated facility for possible discontinuance. It allows this study to be initiated by a responsible Vice President. So no longer will the District Manager that hopefully has a good feel for community needs, unique circumstances and direct accountability for service be the only one to initiate the study. Instead someone sitting at a desk with a spreadsheet, with absolutely no knowledge of the community except numbers, could start the closing process. If that approach is taken it does not give the District Manager many choices in this environment.
This next change makes it even more questionable, one of which would allow a responsible Vice President or Area Manager of Delivery Programs Support to decide that a community meeting is no longer required. This is not acceptable in our eyes nor should it be for the citizens in America. Why would this ever be considered when you are talking about the possible end of a community?
Another change is a reduction in time requirements from 90 to 60 days for the waiting period after posting of a final determination to close. The Post Office argues that the regulations they currently use are greater then what is required by Title 39. The League’s response is that it has been that way for good reason. It provides ample opportunity for customer feedback when such an important event to a community is being considered. Cutting 30 days just so they can save time and rush the closing does not say much for our universal service requirement.
There are more changes including more circumstances that prompt a decision to study closing an office. These include earned workload below the minimum established level for the lowest non-bargaining (EAS) employee grade, insufficient customer demand, declining volumes and local population trends that we will need to discuss. Using these guidelines almost any Post Office could be closed at any time, for any reason.
This is a time for us to work very close with our NAPUS Postmasters. Bob Rapoza and I will be working together on this proposal and you can rest assured that we will be doing all we can here with the PRC, Congress and the use of every available means possible to protect Postmasters, Post Offices and the communities we serve.
Many of you have just returned from Washington DC with fresh contacts for Congress, use them. While we need your enthusiastic support please remember, while you are on the clock or on USPS property or using a USPS phone you are the voice of the USPS and must speak with the USPS voice. When you are off the clock, at home, or on a personal phone you may share your concern for your CUSTOMERS with congress.