The Postal Regulatory Commission Weighs in on Proposed Changes to the Closing Process

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On May 2, 2011, the Postal Regulatory Commission submitted comments to the Postal Service on its proposed changes to 39 CFR Part 241, which seek to alter postal regulations “to improve the administration of the Post Office closing and consolidation process” as well as apply “certain procedures employed for the discontinuance of Post Offices to . . . the discontinuance of other types of retail facilities operated by Postal Service employees.”  Here's the entire letter, and here are the  highlights:

1. The Commission wrote that the Postal Service’s goal to apply a single set of discontinuance procedures to all kinds of post offices (post offices, stations, and branches) was appropriate, but "the Postal Service’s execution of this goal is lacking in one very significant way: the notification of an opportunity to appeal decisions to the Postal Regulatory Commission." The proposal submitted by the Postal Service "does not provide for uniform procedures with respect to notifying persons served by stations or branches of an opportunity to appeal closing or consolidation decisions to the Postal Regulatory Commission."

2. In a previous report, the Commission made several recommendations regarding the ability of customers to offer their input on discontinuance studies.  In its May 2 letter, the Commission now writes, "It appears that the Postal Service did not adopt many of the Commission’s recommendations."  For example, First, the Commission recommends that "actual notice should be provided to individuals in the vicinity of a facility under consideration for closure. The Postal Service’s current practice is to send questionnaires to P.O. Box customers and carrier delivery customers of the affected facility."  But many retail facilities do not provide delivery services to customers in the vicinity of that location, so this method of notification would not reach those customers.  The Commission urged the Postal Service to make "every reasonable step so that mail users are provided with an opportunity to participate in the discontinuance study process."

3. The Postal Service should expand the methods available for providing and receiving customer input.  At a minimum, "the Postal Service should refer customers to generic comment forms available online for printing, so that customers can develop thoughtful comments without having to go to the specific facility to obtain comment forms,"

4. "The Postal Service should expand the contents of its public notice to include better information on alternatives for customers. The contents should include information such as the distance to alternative facilities, the days of the week and daily hours of alternate facilities, the location of alternate facilities at which P.O. boxes are available, as well as a number to call for questions on curb-side deliveries.  A discussion of alternate access channels and locally available privately operated facilities where access to postal services can be obtained would also be helpful. This additional information will allow customers a reasonable opportunity to weigh how their access to postal services will change if the facility under consideration is closed."

5. "The Postal Service should also develop a consistent methodology for evaluating the potential effect of closing a facility on the community it serves. The Commission recommends that the Postal Service develop detailed guidance for the public on how its local managers will review and apply the “effect on community,” “effect on employees,” “savings,” and “other factors” as part of its discontinuance study process."

6. When a post office is considered for closure, considerations of replacement retail services are only made after a particular facility is slated for closure.  The Commission recommends that "the Postal Service should coordinate discontinuance studies with an examination of the adequacy of potential replacement access points, e.g., a contract postal unit, a community post office, or locations offering stamps on consignment to ensure that citizens are not left without adequate access to retail postal services."

This report from the Postal Regulatory Commission is just one of many letters the Postal Service received in response to its proposed changes in the discontinuance process.  It is not clear how long the Postal Service will take to make a final decision.

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