NAPUS Interrogatories and Responses


The National Association of Postmasters has submitted two extensive lists of questions and requests for further information. 


Group 1: Questions #1 – #22

[The original document is here.]

1. NAPUS asks for a list of the 2,000 post offices that had earned workload of 2 hours or less per day, and annual revenue less than $27,500.

2. Which of these 2,800 post offices is located in a rural area (based on the census data)?

3. Which of the 2,800 were managed by an on-site Postmaster, rather than a non-Postmaster?

4. NAPUS asks about the inconsistency between Boldt’s testimony that the RAO initiative is not designed to achieve a predetermined operating cost savings, and the statement by USPS spokeswoman Cathy Yarosky that “The projected savings, if every one of the 3,653 offices were to close, is $200 million annually.” NAPUS also asks how these savings were calculated.

5. How many of the 2,800 candidate post offices have been “temporarily suspended”?

6. How many of the 2,800 have been part of the delivery unit optimization (DUO) initiative?

7. Has the USPS  transmitted reduction-in-force (RIF) notices to any of the Postmasters, or managers-in-charge of the 2,800 candidate post offices? If so, how many were distributed?

8. How many post office boxes and general deliveries are located within the 2,800 candidate post offices? How many of these boxes are provided without cost, and how many are revenue-producing? What is the total revenue attributable to the boxes located in the 2,800 candidate post offices?

9. 39 USC 101(b) requires the Postal Service to provide a “maximum degree of effective and regular postal services to rural areas, communities, and small towns where post offices are not self-sufficient? How does this definition differ from “effective and regular service,” as stated in section 231 of Handbook PO-101

10. On Table 1, which purports to show declining visits to the post office, what does the “y- axis” represent? Could you please provide a definition for “point of sale” (POS) location?

11. How does the Postal Service define “customer visit? Does it only include post office visits in which a financial postal transaction takes place?

12. How does the USPS collect customer interaction data for non-financial postal transactions, including customer inquiries and collection of accountable mail?

13. Please list the operations, transactions, services and products that Village Post Offices would be required to provide under contract to the USPS.

14. How many “non-personnel units” exist? Does the USPS calculate revenue for these units? If so, how and please provide the revenue and expense data per location?

15. With reference to the statement regarding the trend for retail revenue and USPS statements that postal customers are surging towards alternative postal retail access, please reconcile with the FY 2010 Household Diary Study, filed with the PRC on July 7, 2011, which states “Even with the continued availability of mail-related products and services through alternative modes (such as Internet orders), in-person visits to postal facilities remain stable.”

16. More on Table 1. For each of the measured years, please provide the number of POS locations surveyed, and differentiate between urban, suburban and rural/small town locations.

17. Do the 2,800 candidate post offices have less than 2 hours per day earned workload and annual revenue of $27,500 or less? Or does each of the 2,800 candidate post offices fulfill just one of the two measurements?

18. Table 3. How was the sample 748 retail locations selected that is referred to in note 1? How was the sample 481 retail locations selected that is referred to in note 2? In each of the samples, please differentiate the percentage revenue collected among post offices, stations and branches, retail annexes, and contract postal units.

19. Please refer to USPS-T1, page 11, line 8. Of the 13,494 retail facilities, how many were independent post offices, and what percentage is located in rural areas or small towns? Please explain why the USPS did not have location data for the remaining facilities?

20. Table 5. Referring to note 1 (lines 8 and 9), please explain the difference between geographic coordinate distance and driving distance?

21. Please refer to USPS-T1, page 3, footnote 3. Please provide details on how “earned workload” is calculated? Please explain how “window service activity” is measured.

22. Please refer to USPS-T-1, page 15, line 3 and 4, relating to the Small Office Variance (SOV) tool. For the 52-week period ending July 2011, please answer the following questions.

  • On what basis was 2 hours of earned workload per day determined as the threshold for identifying post offices for the discontinuance feasibility study?
  • Does the 2 hours of earned workload represent the totality of work conducted at the candidate post offices? If not, please explain.
  • Please enumerate how many of the 2,800 candidate post offices utilized window automation, through either IRT or POS?
  • For those candidate post offices that did not use IRT or POS, how were the number and value of transactions (both financial and non financial) calculated?
  • Could you explain how the following post office functions were valued through SOV and the basis of those valuations: 
Building and ground maintenance, where there was no contractor retained; Servicing free post office boxes (i.e., no residential delivery available); Delivery of packages
o Multiple scans of parcel mail; Parcel return service; Premium forwarding


Group 2: Questions #23 – #41

[The original document is here.]

23. You state in your testimony that the Retail Access Optimization initiative will “examine the feasibility of discontinuing operations at Post Offices, stations and branches within the retail network.” Moreover, you state: “Approximately, 3,650 candidate facilities will be examined.” Please confirm that the RAO examination has already started. When will the first examined post offices be posted for proposed closures? Please explain why the Postal Service commenced the RAO initiative prior to receiving the required advisory opinion.

24. Please explain the different contracting and regulatory authorities under which the Postal Service may enter into an agreement with a Contract Postal Unit (CPU), in contrast to a Village Post Office?

25. Regarding the VPO, please differentiate the “bidding process” for a CPU, as compared to the bidding 
process for a VPO? Please explain who would be responsible for identifying and soliciting potential 
VPO contractors, and how does this differ from identifying and soliciting potential CPU vendors? 

Please confirm that a CPU shares postal revenue, while a VPO would receives a flat-rate payment. Is there an established payment for a VPO? If so, what is the payment? If not, how is that amount determined, and who determines the payment? 

Please explain the distinctions in administration and oversight of a post office, station/branch, CPU and VPO. Please include the customer complaint process and complaint resolution process for each type of facility.

Are there any restrictions on what types of commercial enterprises may be designated a VPO? If so, please explain.

29. Will VPOs accept or distribute letter mail or parcels? If so, what training will the acceptance and distribution personnel receive, and who will train?

30. Will a VPO be required to provide space for post office boxes? If not, where would the post office boxes be located and how we they be secured?

31. At the conclusion of a VPO contract, or if a VPO contract is terminated, how will the USPS assure continuation of service to the impacted community?

32. Please refer to USPS-T-1, page 6, Table 6 and page 7, Table 2. Does the data in Table 2 apply solely to communities served by the POS locations referenced in Table 1. If not, please apply the data to the POS locations.

33.Within the communities served by the 2,800 candidate post offices, please indicate the percentage of postal customers who used alternative venues for postal transactions for the most recent five years, if available.

34. Please explain the process for filling a vacant Postmaster position, and enumerate 
the circumstances under which a Postmaster vacancy would not be filled. Please identify the post offices that are currently suspended for which there is a 
Postmaster vacancy. Is a post office considered vacant if an officer-in-charge is managing the facility? Please indicate the specific criteria and threshold for concluding that there is 
“insufficient customer demand.” Please indicate the specific criteria and threshold for concluding that there is 
available “alternative access channels.” Please indicate who determines that there exists “alternative access channels.”

Please compare the parameters of the initial feasibility study conducted pursuant to the RAO, and compare with the pre-proposal study conducted in conformance to Handbook PO-101, section 22.

36. Please confirm that only one meeting would occur on a specific candidate facility, and that meeting would cover both stages. Please indicate the duration or timeline of the “initial feasibility stage. If there is no time limit, is there a requirement for community meetings at 
particular increments (e.g., annually) for a candidate post office?

37. Please refer to Handbook PO-101, section 25 (Community Meeting) and reference the previous question. Is a separate community meeting required for each candidate post office within the initial feasibility stage and/or the post proposal stage, or would the USPS conduct joint meetings to cover multiple facilities? 

Please refer to Handbook PO-101. Please explain the distinction between the communications with customers and stakeholders that are initiated pursuant to the pre- proposal investigation, as compared to the communications that take place at the proposal stage. 

Please refer to Handbook PO-101, section 321.1 and 321.2. Please explain the distinction between the items evaluated in each of the two sections. 

40. Please refer to Handbook PO-101, section 321.2.

  • Please explain how the USPS evaluates the importance of a post office, as the sole representative of the government, to a community
  • Please explain how the USPS evaluates the importance of a post office as the focal point of the community
  • Please explain how the USPS evaluates the economic impact that the presence of a post office has on the community
  • Please explain how the USPS evaluates the social impact, including communal cohesion, that the presence of a post office has on a community
  • Please explain how the USPS evaluates the presence of a post office to vulnerable populations, such as senior citizens and mobility impaired citizens
  • Please explain how the USPS evaluates the degree to which a community utilizes broadband digital communications

41. Please refer to POIR 1, question 8. Who would make the assessment of the ability of remaining postal facilities to absorb the increased retail traffic resulting from the discontinuance of a facility?

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