Last May, the Postal Regulatory Commission issued a press release about a task it was assigned by Congress.

“As adopted by the Joint Explanatory Statement accompanying the Consolidated Appropriations Act, 2022, the House of Representatives Report 117-79 states:

Despite its generalized service performance claims, the volume of market-dominant mail that is excluded from the Postal Service’s measurement process continues to justify questions about whether those claims are representative.

Because the USPS measurement process relies on pieces bearing an intelligent mail barcode, documentation from mail preparers, and processing over automated equipment, any mail not meeting one of those basic requirements reduces the volume of mail potentially eligible for measurement, even before other reasons for exclusion apply.

In a February 25 filing with the Postal Regulatory Commission, Mailers Hub joined with nine other industry groups (American Catalog Mailers Association, Association For Mail Electronic Enhancement, ANA—Association Of National Advertisers, Continuity Shippers Association, Envelope Manufacturers Association, International Mailers Advisory Group, Major Mailers Association, National Association Of Presort Mailers, and Printing United Alliance) to support a Package Shippers Association recommendation to eliminate the statutory “appropriate share” provision.

Appropriate share

The Private Express Statutes can be traced back to 1792 when Congress, empowered under the Constitution to “establish post offices and post roads,” granted the federal government sole authority over the carriage and delivery of letter mail.  That authority, now codified in 18 USC 1693-1696 and 39 USC 601-606, originally enabled the Postal Service to suspend the statutes if that would be in the public interest.

The USPS implemented an exception in 1979, for example, to allow private companies, notably Federal Express and United Parcel Service, to carry “extremely urgent” letters outside the mail subject to conditions including payment of postage.  (The PES apply only to “letters,” so the private carriage of other matter – like newspapers and packages – is open to non-USPS providers.)  That authority ended in 2006.

One segment of the November 3 Mailers Technical Advisory Committee meeting’s focus group session on Customer Experience, Product Solutions, and Innovative Business Technology featured Sharon Owens, USPS VP for Pricing and Costing.

In her presentation, Owens sought to explain trends in the Consumer Price Index, on which the price cap on market-dominant rates is based, and the factors that determine the additional pricing authorities derived from the Postal Regulatory Commission’s November 2020 decision.

As everyone involved in commercial mail production realizes, we’re heading into a second atypical fall mailing season.  Supplies of the essential raw material – paper – are tight, trucking companies are busy moving backlogged shipments from ports, drivers are still in short supply, and companies are struggling to find workers despite high unemployment.

Concurrently, the Postal Service is reworking its processing and logistics networks – consolidating some operations while adding annexes and installing package sorting equipment – and planning to move more mail by truck and reduce its service commitments.

The Postal Service’s 10-year Plan, released March 23, optimistically assumes package volume will grow and provide a critical source of revenue to offset the Plan’s projected $160 billion loss over the period.

However, as we first reported last April, the continuing trend of competitive product contracts seems to not support the agency’s rosy expectations.  According to data available from the Postal Regulatory Commission website, from January 1, 2020, through August 13, 2021, 48% more competitive product (CP) contracts with the USPS were terminated (426) than were approved (287).

 By late June, the Postal Regulatory Commission likely had received more comments than it had expected about the Postal Service’s proposal to change the service standards for First-Class Mail and some Periodicals.

Aside from the briefs and statements of position from the eleven intervenors in the case, plus the commission’s “public representative,” the PRC also got comments from other groups and interested parties, including from 478 individuals from all over the country.  (Whether there was a coordinated campaign behind those isn’t clear; many of the comments didn’t follow a pattern.)

On June 22, 2021 Mailers Hub submitted its Statement of Position, regarding First-Class Mail and Periodicals Service Standards Changes, before the Postal Regulatory Commission. 

In the two-page statement, the author - Leo Raymond, Managing Director of Mailers Hub - candidly and emphatically summarized the failings in the proposed changes, as well as the rationale behind them. Citing the "appalling abandonment of the customers that they should be striving to retain", the subordination of the role of the Postal Service as a service, and the clear connection between more costly, slower service and a loss in mail volume, he urges the PRC to advise the USPS against these changes. 

Part of the Postal Regulatory Commission’s process for considering a Postal Service request for an advisory opinion – like the one now before it regarding changes to USPS service standards – is the opportunity for intervening parties to ask questions of Postal Service witnesses, based on their written testimony.

Last month, as an intervenor in the case, Mailers Hub submitted questions to three USPS witnesses: Logistics VP Robert Cintron; Stephen Hagenstein, Director, Logistics Modeling and Analytics; and Acting Budget Director Curtis Whiteman.  Some were about vehicle utilization and dispatch times, while others focused on the reasons for the changes that were proposed.  After some debate over what constitutes a “question” (the number that can be submitted is limited at 25), the USPS witnesses filed their responses on June 1.

Clearly Louis DeJoy did his reading – reports by the Office of Inspector General, GAO studies, and such – and probably Envisioning America’s Future Postal Service, the 10-year plan developed by the Boston Consulting Group and released by then-PMG Jack Potter in March 2010.  All of that, plus what he’d been told by his circle of selected advisors and his own strong opinions, likely influenced what eventually emerged in his own 10-year Plan, also released in March (2021).

However, unlike Jack Potter or, for that matter, any of the PMGs who’ve led the USPS over the past two decades, Louis DeJoy has no real, first-hand knowledge of the Postal Service or the businesses of its customers.  Holed-up in his office at L’Enfant Plaza, he’s spent scarcely any time learning about the mailing business or the connected industries that take messages from concept to recipients’ mailboxes.

A major focus of the Postal Service’s 10-year Plan, issued March 23, is the need to downgrade service standards for First-Class Mail because the current standards, which haven’t been met for several years, are “unattainable.” The Plan recites various reasons for this situation, including failures in air transportation and in compliance with facility operating plans.

The fundamental absence of operating discipline in USPS processing facilities was highlighted in two audits published in mid-April by the Postal Service’s Office of Inspector General: Delayed Mail at the Lehigh Valley, PA Processing and Distribution Center, issued April 12, and Delayed Mail at the North Houston, TX Processing and Distribution Center, released April 13.

On April 21, the USPS filed its Request for an Advisory Opinion on Changes in the Nature of Postal Services, seeking the Postal Regulatory Commission’s input on changes to the service standards for First-Class Mail and time-sensitive Periodicals. The fifteen-page filing was accompanied by direct testimony from five witnesses and eight “library references” containing supporting data.

Proposal

For anyone reading a novel, or watching a play, television show, or movie, a requirement applies that the individual participate in the story by setting aside any logical analysis, in favor of accepting the premise of what’s being presented. This voluntary engagement is referred to as “suspension of disbelief,” a term coined by Samuel Coleridge in 1817, based on one used by the Roman poet Cicero centuries earlier.

Of course, the story need not be purely fictional; in The Crown, for example, the characters and general plot are factual, but “suspension of disbelief” is necessary to accept that events and dialogue occurred as re-enacted. For the viewer, how the writers and actors present the story can shape perceptions of the factual background and, in turn, the conclusions the viewer reaches about the history being portrayed.

Readers old enough to remember the Soviet Union also remember how skilled it was at saying nothing – about anything – no matter what.  If something happened, regardless of whether it was visible to the outside world, it simply wasn’t acknowledged.  A natural disaster?  Never happened.  The disappearance of an important figure?  He’s fine.  A bomber crash into a village?  No bomber, nothing happened.

If outsiders posed a question about any event, the basic answer, if there was one, was denial, deflection, or obfuscation.  The Soviets never admitted to anything going wrong, to any internal failures, or to any event or condition that might break the illusion they so ardently projected or that might provide an outsider a peek into what’s really going on.

Over the past few months, and especially over the recent holiday season, there were many occasions on which a postal customer – a representative of a commercial mailer, a mailer’s client, or just a retail customer – delivered a message of dissatisfaction about service (to put it nicely) to a frontline postal employee.

Whether a retail window clerk, a city or rural carrier, an employee at the local BMEU or DMU, a customer service rep, or a call-taker at the Business Service Network, that person neither had anything to do with the reasons for the customer’s dissatisfaction and likely had little to go on to offer an explanation or information about the reported service problem.

On January 26, speaking to the virtual meeting of the Mailers Technical Advisory Committee, Postmaster General Louis DeJoy gave a broad overview of his developing plans to get the Postal Service back on track after months of worsening service that culminated in a historically bad holiday season.  As transcribed from his recorded remarks:

“... Calendar Year 2020 has been a tough year for the nation and a tough year for the United States Postal Service.  The causal circumstances continue to plague us in early 2021.  As a result, the consequences to many Postal Service customers have been significant, and we acknowledge the impacts our service decline has had on your businesses and our responsibility to restore.

In the wake of the Postal Regulatory Commission’s issuance of a final rule amending the rate-setting process, rumors began to circulate that the Postal Service would seek higher rates by mid-2021 and that the increases would be over 7%.

These stories may have some relationship to facts but are not entirely factual or accurate. Just the same, given that rumors travel faster than facts, it’s important that commercial mail producers have the necessary information to convey to their clients – who may already have heard the rumors.

Once upon a time, there was a company that was given an exclusive charter to build and operate a railroad between two cities that were quite far apart.  That charter required certain levels of service to the cities and to each town along the route and, in exchange, afforded the company the exclusive right to carry certain types of freight and passengers.  To be sure the fares the company charged weren’t excessive, an independent panel was established to review the company’s income and costs.

For decades, the railroad thrived, with more passengers and freight every year.  Even though it was the only railroad allowed to operate the route, the company’s customers still were satisfied with its fares and service.

As many people know, the third rail in a subway system is the one that’s electrified to provide power to the train motors; touching it would be fatal.  In politics, a “third rail” is an issue that’s equally dangerous and that, if tackled by a politician, can be fatal to the person’s political career.  Changing the social security system is often cited as a “third rail.”

The USO