The National League Of Postmasters filed the following testimony with the Postal Regulatory Commission (PRC) addressing the USPS Retail Access Optimization Initiative.
Highlights of the testimony:
…. the minimal imagined savings to the Postal Service are a critical factor in evaluating a proposal that essentially produces a drastic reduction in availability and service. I know that the Postal Service has said that they will be able to serve rural America just as well if not better once all these post offices are closed, but that is truly nonsense. I suggest that the real proposition here is that the Postal Service is under financial stress and its urban-based leadership wants to back off from providing rural America the type of service it provides today, in order to concentrate its focus on providing service to large urban and suburban areas.
The postal network we have developed over many generations provides not only mail delivery but an essential governmental presence in every community and corner of the nation. I am convinced that in rural areas this federal presence goes as much to act of binding the nation together, as does the actual delivery of mail, and has been a significant factor in the success of the American system. As Mr. Jamison quite correctly points out, this network has truly served to bind the nation together, and dissolving and dismantling this important piece of our national infrastructure would be a tragic mistake. I would add that it could perhaps be a fatal mistake. This proceeding is the first step in that process.
While this proceeding is technically only focused on the 3,650 post offices that are currently on the chopping block, it is no secret that a much larger group—up to half of the post offices in the country—are waiting in the wings for their turn. That includes every small rural post office in the country. Whether they too will take their place on the chopping block will, in large part, depend upon how the Commission reacts in this Docket, and how clearly and strongly the Commission crafts its advisory opinion.
Consequently, I believe that the Commission must look to the larger picture in this proceeding, and consider the effect on a community and its economy when it loses its post office. Importantly, I also believe the Commission must look to the much larger cumulative effect on rural America if many thousands of small rural communities lose their post offices.
The Postal Service is more than a business. It is here to bind the nation together and to serve rural America by giving it the maximum degree of effective and regular service. Congress made that perfectly clear—a fact the Postal Service ignores— when it adopted the Postal Reorganization Act of 1970, the Postal Reorganization Act Amendments of 1976, and the Postal Accountability and Enhancement Act of 2006
…the way in which the Postal Service is treating these community meetings raises very serious questions about the integrity of the Postal Service‘s effort in this initiative, and whether the Postal Service is seriously conducting these meetings with the goal of gathering information to understand and meet the needs and desires of these communities. Widespread information from the field indicates that in too many cases the ―community meetings‖ are simply canned briefings designed for public relations purposes, in order to create the illusion that the Postal Serviced is taking into account the needs of these communities and is following both the spirit and letter of the law. That truth of the matter is that the Postal Service is not taking into account the needs of the communities, and thus is not honoring the spirit of the law nor, in many cases, the letter of the law.
Of the 3,650 post offices recommended for review as part of the RAO Initiative, a significant portion are rural post offices. The primary purpose of the RAO Initiative is to reduce costs. As the Postal Service finally acknowledged on the day of Witness Boldt‘s cross-examination, the closing of these 3,650 offices is not the billion dollars that the Postal Service originally alleged, but estimated to save less than $200 million, or less than 3/10s of one percent of the Postal Service‘s operating budget. One could ―save more than that by playing with the rounding functions in the Postal Service‘s budget.
The Postal Service is charged with providing universal service, including a maximum degree of regular and effective service to rural America. This Commission is charged with enforcing that mandate. The Postal Service is not doing that, and is not even trying to seriously perform its duty to gather information about the needs and desires of local communities and factor that information into its decisions.
I believe every participant in this proceeding wishes and wants in their heart the best for our nation‘s Postal Service. But the more important issue before the Commission in this docket is what is best for America and all of its citizens, especially those most vulnerable and dependant on their Post Offices.
Rebuttal Testimony of Mark Strong on behalf of the NLPM (PDF) and Rebuttal Testimony of Mayor Donald Hobbs on behalf of the NLPM (PDF) .
NAPUS Postmasters Provide Expert Testimony on Retail Access Optimization Initiative
On Monday, NAPUS National Vice President Curt Artery and NAPUS Retired West Virginia Postmaster Rita Zilinski submitted formal testimony to the Postal Regulatory Commission regarding the USPS request for an advisory opinion on its Retail Access Optimization Initiative (PRC Docket Number N2011-1). The USPS seeks PRC advise on whether its plans to review approximately 3,600 postal retail facilities, including 2,800 post offices, complies with established law.
NAPUS focuses its testimony on two specific aspects of USPS post office discontinuance plans. First, VP Artery, a hands-on expert on post office operations, highlights the misuse of the small office variance tool (SOV) as an inaccurate measure of post office workload. Artery’s criticism is pivotal to the USPS initiative, since one of the two criteria for reviewing a post office for closure is having two or less workhours, as determined by the SOV. Second, Retired Postmaster Zilinksi, an authority on the relationship between a rural community and their post office, establishes the importance of rural postal facilities to the area they serve. In addition, she shows how the discontinuance of a rural post office can have a significantly negative impact on postal access and mail security in rural areas. To view their testimony, link here
Closing a post office forces postal customers in many small towns or rural communities, like the ones I served, to receive their mail through a highway contract route via a single family mailbox erected in front of their residence or at the end or a rural road, or by a neighborhood delivery collection box unit (NDCBU). NDCBUs are key-operated mail receptacles, so-called cluster boxes that are installed at a designated area. The mail receptacles usually are not sheltered or illuminated, making them vulnerable to theft and weather.