It’s going to be a busy week in our nation’s capital. On Tuesday, the Senate Homeland Security and Governmental Affairs Committee, chaired by Joseph Lieberman, will hold an emergency hearing to prevent a USPS shutdown. NAPUS says “this is the first time in recent memory that the full Committee, rather than its Postal Subcommittee, will convene a postal hearing.”
Then on Thursday, the Postal Regulatory Commission (PRC) will hold its first public hearing on the Retail Access Optimization Initiative (RAOI), and James Boldt, the man running the operation for the USPS, will be cross-examined by the Commissioners, the Public Representative, and several “intervenors,” like NAPUS and the APWU.
You know it's going to be a big week when the New York Times finally acknowledges there's postal news. Needless to say, the Times gets nearly everything wrong, but what do you expect when the paper has practically ignored the story for months?
In order to bring lawmakers up to speed, the Congressional Research Service (CRS) recently put out a report entitled “The U.S. Postal Service: Common Questions about Post Office Closures.” It’s a ten-page white paper packed with information about how the closure process works, how many post offices are likely to close, what laws are relevant to closures, and what bills are currently in Congress.
According to its website, “CRS has been a valued and respected resource on Capitol Hill for nearly a century. CRS is well-known for analysis that is authoritative, confidential, objective and nonpartisan. Its highest priority is to ensure that Congress has 24/7 access to the nation’s best thinking.”
That may be so, but there’s a lot of important information missing from the CRS report, so for those lawmakers who haven’t been reading the postal news websites, “Save the Post Office” has prepared a special report we call “Post Office for Dummies.” We’ll go through the sections of the CRS report, one by one.
Chapter One: What is a post office?
When it comes to the U.S. postal system, you can’t take anything for granted. There are actually people who don’t know what a post office is, who never even go to a post office. Many of them are probably in Congress. Even the leaders of the Postal Service don’t seem to know what a post office is.
As the CRS report explains, there are five types of postal facilities: post offices, branches, stations, community post offices (CPO), and contract postal units (CPU). The first three provide the full range of postal services, while the contract units are postal counters in a private business or community building — they provide only some postal services, and they are not staffed by postal workers.
That seems straightforward enough, except for the fact that the Postal Service says a station or a branch is not really a post office, at least not when it comes to the rules for closing one. For years now, the Postal Service has maintained that the law says the full nine-month closing procedure applies only to a main post office, so it’s justified in applying an abbreviated four-month procedure (with no right to appeal) to closing a station or branch. The PRC says that’s nonsense and stations and branches are post offices entitled to the full closing procedure.
If that’s not complicated enough, now the Postal Service wants to open up a contract unit in convenience stores and call it a “Village Post Office,” even though they provide very few postal services, even fewer than a traditional contract postal unit. These places are not post offices. They basically just sell stamps, which you can buy at Wal-Mart, Staples, CVS, and thousands of other places — oh, and they are not post offices either.
So, for those lawmakers who are having trouble with all these distinctions, here’s the thing to keep in mind. If you see a flag flying outside, it’s probably a post office. No flag, probably not. That’s because a post office is not a private business — it’s part of the federal government. And while some members of Congress are going to be saying over and over again that the Postal Service must act “like a business,” a post office is not a business. It’s a government institution, and it serves American citizens, not customers. Also, there’s another way to figure out if what you’re dealing with is a post office or not. Ask if they do local postmarks — it’s a small thing, but it’s what gives a community a sense of identity and it’s what separates post offices from their simulacra. No postmarks at the Village Post Office.
It’s really not that complicated. Most people know what a post office is. It’s just the executives and lawyers in the Postal Service who are confused.
Chapter Two: How Many Post Offices Are There?
Who’s counting? Well, the Postal Service for starters. And they don’t like how the numbers add up. There are just too many post offices. They’re not the only ones who think that way. So do the GAO, the USPS OIG, the Cato Institute, the American Enterprise Institute, and Darrel Issa.
There are about 32,000 post offices (27,000 main offices and 4,800 stations and branches), plus about 3,700 contract units. As the CRS report notes, the number has declined gradually since 1970, when there were 4,000 more post offices. On the other hand, the number of places where you can do postal business just keeps going up and up, and now the Postal Service boasts 100,000 locations — most of them in places like Wal-Mart, Staples, CVS, Sam’s Club, etc.
The Postal Service claims it’s simply responding to what it was told to do in 2006 by the Postal Accountability and Enhancement Act (PAEA), which encouraged the Postal Service to expand access to postal services. But now the Postal Service is saying it’s done such a good job with expanded access that it can close thousands of post offices. It says customers actually prefer these alternatives. So it wants to close 4,400 post offices, on top of about 50 it has already closed by “emergency suspension,” on top of a couple of hundred others it has closed under an earlier 2009 initiative, plus odds and ends initiated on an “ad hoc” basis.
Chapter Three: How Many Post Offices Might the USPS Close?
That’s the ten thousand dollar question. The Postal Service has been trying to get the ball rolling on closing a significant number of post offices for many years, and it’s hard to say how things will play out.
In 2009 the Postal Service launched what it called the Stations and Branches Optimization and Consolidation Initiative (SBOC). That didn’t turn out so well. They started with a list of 3,200 post offices, but the list kept getting smaller and smaller, eventually dwindling to about 160, of which about 140 have closed. Mostly what the Postal Service came away with was a strong rebuke from the PRC for the way it was mishandling the closing process.
The Postal Service calls its new closure program the “Retail Access Optimization Initiative,” and the page on its website where 3,652 post offices are listed as potentially closing is entitled “Expanded Access Study List.” Don’t feel you’re a dummy if it seems weird to close thousands of post offices and call it “expanded access” and “access optimization.” You obviously just need to spend more time in postal world.
In addition to the RAOI list, there’s another list of 727 non-RAOI post offices that had been initiated for closure before the RAOI. They aren’t part of a plan — they were initiated for closure “in the field,” on an “ad hoc, isolated” basis. (By the way, the CRS report mistakenly observes that these non-RAOI post offices came under the SBOC. Not true. The SBOC ended in 2010, and the post offices on the non-RAOI list are almost entirely main offices, not stations and branches.)
How many of these 4,379 post offices might actually close? If you want to make people feel that there’s nothing to worry about, you mention the SBOC as a precedent and imply that maybe just a few hundred will close. That’s what the Washington Post did, and the CRS report does pretty much the same thing.
However, if you’ve been reading the postal news, you know this time around, the Postal Service means business, and it is really going to close thousands of post offices. Indeed, the Postal Service will not rest until it’s replaced as many post offices as it possibly can with postal counters in your local Wal-Mart and supermarket. Remember, the Postmaster General has said he expects 16,000 post offices to close over the next six or seven years.
So how many post offices might the USPS close? More than you can possibly imagine.
Chapter Four: What Authority Does the USPS Have to Close Post Offices?”
For some odd reason, this section of the CRS report begins by noting that before it became the Postal Service in 1970, the Department of the Post Office had “a reputation for incompetence and corruption” and was viewed as “an agency riddled with patronage and scandal.” That obviously has nothing to do with the Postal Service’s authority to close post offices. It’s just there to remind everyone how much better off we are since the post office became a “marketized” government corporation, half-way down the road to privatization. Given the mess the Postal Service now finds itself in, however, that’s a pretty debatable proposition, and your position on the matter is probably more a matter of ideology than facts.
As for the Postal Service’s authority to close thousands of post offices, well, that’s still an open question. There are passages in Title 39 and the PAEA that suggest it has considerable authority to do what it wants, and there are other passages that suggest its scope is limited. The key line that you’re going to hear over and over again is the passage in Title 39 that says the Postal Service cannot close a post office solely for economic reasons. Of course, there's really no other reason to close a post office, so the Postal Service has been lobbying Congress to change the law, and in the meantime, it's been going through all sorts of contortions to present other reasons explaining why it wants to close a post office.
Over the next few weeks, lawmakers, the PRC, and the Postal Service will be citing the relevant passages in the law and putting their own spin on what they mean and what the framers of the acts probably intended. Some of those framers are still around, so we’ll probably hear what they were thinking back then.
Chapter Five: What is the post office closure process?
There are so many stages to closing a post office and so many rules to follow, it’s almost impossible to keep track of them, and the Postal Service has a handbook called the Post Office Discontinuance Guide on how to do it. It’s important to get it right, because errors in the process provide one of the main grounds for appealing a closing decision.
The CRS report outlines the main steps in procedures and it reviews the criteria for deciding whether or not a closure is appropriate, but it skips over a couple of important matters. First, it doesn’t go into the fact that the Postal Service recently revised the procedures before embarking on its current closing initiatives so that it would be easier and faster to close post offices — just over four months instead of nine, with a broader range of criteria to initiate a closing, and so on. These changes in procedure have provoked legal challenges by the two associations of postmasters, and they will probably be reviewed as part of the PRC’s Advisory Opinion.
Second, the report doesn’t say much about all the shenanigans employed by the Postal Service to close post offices. For example, the Postal Service has intentionally left postmaster positions open and filled them with an officer-in-charge, and it’s now using the vacancies it created as an excuse to initiate a closure study. Similarly, the Postal Service has manufactured problems with the leases for post offices where it rents space, and then used that as an excuse to close hundreds of post offices as “emergency suspensions” — a practice now under investigation by the PRC. And speaking of leases, the Postal Service has been pressuring lessors to put easy-out clauses in the lease so that it can walk away without owing a lot of money when it wants to close a post office before the lease ends. We’re going to see a lot of that over the coming months.
Chapter Six: When Might the Post Office Closure Process Begin?
Haven’t been reading the news lately? It’s already begun. There are post offices closing every day, nearly 240 since the beginning of the year, about one a day. And since many of those 727 non-RAOI post offices were initiated for closure several months ago, the pace is going to pick up dramatically.
As for the RAOI post offices, the CRS report says that the “the USPS has not provided a timeline that explains when it will begin and conclude the process.” But that’s wrong. In his PRC testimony on July 27, James Boldt said, “field managers throughout the country are engaged in RAO Initiative related activity.” In other words, the process had already begun as of July 27, and many communities on the RAOI list have already received questionnaires and notices inviting comment, and many public hearings are already being scheduled.
Boldt went on to say, “We anticipate this process will continue to be initiated by field personnel on a rolling basis over a ten-week period.” By the end of September, then, the Postal Service hopes to have initiated the closing process for all of the post offices on the RAOI list. Given that it now takes 138 days to close a post office, the first of the RAOI post offices will start closing in December, and they will be closing all winter. That will be on top of the 727 non-RAOI post offices whose time is up, so both lists will converge as the year ends.
We could see post offices closings at a rate never seen before in history, something on the order of a hundred a week. Given that the PRC will issue an Advisory Opinion that is non-binding, the only thing that will prevent that from happening is an act of Congress. And with Issa and the Tea Party playing a key role in the process, what are the chances of that happening?
Chapter Seven: How many postal employees may lose their jobs?”
The CRS report notes a news report that said the USPS anticipated 4,500 employees would be “affected” by the RAOI closure, but did not clarify how many would lose their positions. But it doesn’t take a lot of math to get an estimate: divide the $200 million cost savings anticipated by closing the 3,650 post offices on the RAOI list, and that’s $56,000 per post office. Subtract $5,000 to $10,000 for annual rent, and you’re left with $46,000 – $51,000 — a ballpark range for the salary of one postal worker. So we’re talking about one lost job for each of those 3,640 post offices, and don’t forget to add in the 727 non-RAOI post offices, which means maybe four or five thousand jobs will be lost. That’s a lot of people who are going to be more than simply “affected.”
Chapter Eight: What Current Legislation Carries Provisions Related to Post Offices?
There are several bills before Congress right now, and it doesn’t look like any of them have enough votes in both houses to pass, so we’ll probably end up with a compromise that will make no one happy. But before that happens, lawmakers will push things to the brink like they did with the debt ceiling a few weeks ago, so that we enter full crisis mode and no one can think straight.
That’s a winning strategy if you’re someone like Darrel Issa, who wants to make the most radical changes in the postal system — and who has just launched a new website called “Saving the Postal Service” that features a clock ticking down to “Postal Default.” It’s like the timer on a hijacked nuclear bomb in a terrorist movie, and if superhero Darrel doesn’t type in the code, the whole place is going to blow up. It’s the kind of gimmick that leads to irrational decisions – and it’s paid for with taxpayer dollars.
Suffice to say that Issa’s bill is a total disaster and deserves no consideration by anyone remotely interested in preserving post offices. The bills proposed by Susan Collins and Thomas Carper, which may eventually be combined into a bi-partisan effort, are much better in many ways, but they don't do much to protect post offices. Following up on the PAEA, both require the Postal Service to deliver a plan to Congress about expanded access to postal services through contract units, the internet, kiosks, etc., and their goal is to broaden the Postal Service's authority to replace post offices with these alternatives.
Albio Sires’ bill looks better, since it would revise Title 39 to remove cost savings as a criterion for closing a post office and forbid the Postal Service from using lease problems as a way to declare an “emergency suspension.” There’s another bill by Stephen Lynch, not mentioned in the CRS report, probably because it doesn’t deal with post office closings per se.
You can read summaries of the bills’ key provisions with respect to post office closures on page nine of the CRS report, and there’s also a good discussion in this New York Times article from July 21.
Chapter Nine: Conclusion
The DummiesTM series is all about "Making Everything Easier," and we hope "Post Office for Dummies" will help lawmakers understand post office closings a little more thoroughly than the CRS report. If it doesn't succeed, at least the price was right. The CRS report was paid for with tax dollars — the CRS budget is over $100 million a year — while "Post Office for Dummies" comes to you absolutely free.