Postal Regulatory Commission Chairman Ruth Goldway in a letter to Postmaster General Patrick Donahoe wrote:
During service performance consultations earlier this year, you discussed the internal Postal Service schedule for improving the process of reviewing retail facilities to evaluate whether closing them was appropriate. You explained that new procedures would be developed and then applied to a substantial number of facilities nationwide. You also assured the Commission that should the process indicate that closing a significant number of existing retail outlets appeared justified, the Postal Service would file a request with the Commission for an advisory opinion under 39 U.S.C. 3661 prior to closing those facilities.
Consistent with that schedule the Postal Service published proposed rules in the Federal Register on March 31, 2011 (76 FR 17794), and as you may know, the Commission submitted timely comments. During this period, numerous articles have appeared in the press identifying facilities in a number of states that have been closed, or that have been evaluated for potential closing, or shortly will be evaluated for potential closing. The Commission has received an increased number of post office closing appeals, hundreds of inquiries from citizens, and has had communications with concerned members of Congress. Thus, it appears that the Postal Service may already be engaged in a nationwide change in service without prior notification to the Commission as title 39 requires. A prompt request for an advisory opinion on the impacts of closing retail facilities appears to be the best way to address these concerns . .