‘Closures’ Report Reveals Inconsistencies

(This article by then-Executive Vice President Cliff Guffey appeared in the March/April 2010 issue of The American Postal Worker magazine.)

Call it what you will, shuttering retail Postal Service facilities reduces public service, and the public has been watching.

 Late last year, the Congressional Research Service issued a report titled “Post Office and Retail Facility Closures: Overview and Issues for Congress.” The study chronicles customer-service-reduction efforts, beginning with the original notification on May 15 that postal managers would evaluate more than 3,100 offices for possible closure, and documents activities through the announcement in November that only 241 offices were being considered for consolidation. (A USPS notice posted Dec. 14 — after the OIG report was issued — trimmed the list to 168 offices.)

Because the Congressional Research Service is a non-partisan division of the Library of Congress, I find it noteworthy that the study repeatedly reminds members of Congress of Title 39 of the Code of Federal Regulations. The report cites a provision of Section 403(b), which emphasizes the USPS obligation to offer public access to its essential services: The provision says, “Congress assigned the USPS the general duties to: establish and maintain postal facilities of such character and in such locations that postal patrons throughout the Nation will, consistent with reasonable economies of postal operations, have ready access to essential postal services.”

This passage interests me because the USPS maintains that its proposals take into consideration alternatives for public access to postal services — but often the alternatives the USPS offers are non-postal contract facilities.

A Different Perspective

When the Postal Service announces its intent to close a station or branch, it often tries to blur the distinction between USPS facilities and private-contractor facilities. The Postal Service considers Contract Postal Units (CPUs) “postal facilities,” even though they do not provide USPS services exclusively. Furthermore, staffers at CPUs are not postal professionals: They are not subject to the extensive training and screening our members receive. In fact, they don’t even have to fly the flag.

The Postal Service’s blurred vision seems to improve, however, when the USPS seeks to cut the number of stations and branches. Suddenly, stations and branches — all flying the flag and selling nothing but U.S. Postal Service products and services — are no longer “post offices.” Instead, the Postal Service says they are just pieces of bigger post offices. It’s no big deal to close down a neighborhood station or branch, postal management reasons, with other offices a mile or two away.

USPS: Rules Don’t Apply

The Federal Code and other regulations outline strict procedures for the closure of a Post Office. But the Postal Service attempts to persuade the Postal Regulatory Commission (PRC), the Government Accountability Office and other agencies that the rules don’t apply to stations and branches because they are not full-fledged “post offices.”

It is important to note that the Postal Regulatory Commission has publicly rejected the USPS rationale for the differences between its treatment of “post offices” and “stations and branches.”

And, as the Congressional Research Service paper points out, even the USPS acknowledges that the public makes no such distinction. Quoting a high-ranking postal official, the report says, “These important facility designations and administrative relationships often do not matter to members of the general public. In the common vernacular, virtually every postal facility offering retail services is referred to as a ‘post office.’ ”

The Postal Service claims financial hardships from operating particular facilities, without pinpointing the causes or explaining how much it will save by shutting it down. As the report to Congress notes:

“The USPS has cited financial duress as an impetus for the possible closure of 241 post office branches and stations. However, the USPS has not said how much money it may save from this undertaking. Congress may wish to ask the USPS what its projected savings are and when these savings might be realized.”

The Big Picture

The Congressional Research Service report notes that Congress does not have to simply follow management’s lead. If “the root cause for the USPS’s movement to shutter branches and stations is its financial troubles,” Congress has options, such as “raising the USPS’s statutory debt cap, and lowering the USPS’s annual payment to its future retiree health benefits fund.”

And in a bullet point that echoes APWU criticism, the report says: “Additionally, the PRC has found that the USPS carries some types of mail at postage rates that are below their costs. Congress may wish to examine the reasons for these disparities and consider policies to ameliorate them.”

President Burrus has been forcefully making this point for several years. Rates fund service . When rates are structured to subsidize wealthy contractors instead of the service to the public — service begins to lag. It’s lagging big time.

Think of rates and services as the water that fills a big fish bowl. As long as the water (revenue driven by rates) is replenished, the fish are safe. But once you start siphoning off water, diverting revenue into profits for outside companies, the fish struggle. If the bowl is not refilled, the fish in the bowl (the service itself) will die.

Inherent in time-honored postal law is the assumption that some areas of the United State provide profitable markets for postal services, while others do not, and that the former should subsidize the latter. It is this principle that enables the Postal Service to offer universal service. The USPS obligation to provide universal service is the reason current law forbids the USPS from closing “small post offices solely for operating at a deficit.”

To paraphrase the report cited above, it looks like the USPS and Congress will have to devise some means to address possible complaints about equity.

These and other issues have been bought to the “Congressional Front” because of the efforts of APWU members, in most cases working with the affected members of the public. You must continue the fight. One way is to get involved in the next round of congressional elections: Make sure that those you support will support you!