Relocation, relocation, relocation: The new M.O. for closing post offices

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The Postal Service may no longer be talking about closing thousands of post offices, but it has been busy “relocating” them.  In dozens of cities across the country, a downtown post office is being closed and the building, often a historic landmark, is being sold.  According to the Postal Service, however, the post office isn't actually "closing."  Because a new, smaller office will be opened somewhere else in the community, the Postal Service says it is just "relocating retail services."  

The distinction may seem just a matter of semantics, but it allows the Postal Service to go through a quick relocation procedure, which has minimal requirements for notification, public comment, and appeals, instead of a lengthy, complicated discontinuance procedure.  In taking the easy route to closing post offices this way, the Postal Service is causing all kinds of problems.

Complaints about the relocations have prompted the USPS Office of Inspector General to initiate an audit investigation.  One of the aims of the audit is "to look specifically at whether the Postal Service is providing affected customers enough information about relocation plans to enable those customers to fully understand and react to their potential impact.” 

The OIG is also in the middle of another audit that involves these relocations.  This one, which began last summer, is looking into the disposal and preservation of historic postal properties.  The two audits are related because the Postal Service typically replaces the historic post office with a new retail facility elsewhere in town. 

The audit on relocations is due out in January.  If you’ve had experience with a relocation process, your input would be very valuable.  You can still submit comments on the OIG's website here.

The audit on historic properties was initially due out last October, but it’s been postponed until next year, perhaps as late as March.  The only explanation for the delay the OIG has offered is the government shutdown, but that lasted only two weeks, which wouldn’t quite explain a delay of several months.  Perhaps the investigation is proving more complicated than the OIG expected.  

There's also some mystery about why the announcement on the historic properties audit keeps appearing and disappearing on the OIG website, but an archived version with some of the initial comments can be found here.  While you're waiting for the OIG's report, you can take a look at my report to the OIG on the preservation and disposal of historic post offices, which can be found here.

 

Discontinuances discontinued

Until last year, it looked as thought the Postmaster General might follow through on his plan to close half the country’s post offices.  In 2009, the Postal Service announced an initiative to close several thousand stations and branches, and in 2011, it announced a second initiative to close 3,700 post offices, most of them small, rural offices. 

As it turned out, however, the Postal Service ended up closing far fewer post offices.  According to the USPS 10-K reports, there were about 115 closures in FY 2010, 360 in 2011, 240 in 2012, and 120 in 2013.  That’s about two hundred a year, around twice the annual average for the previous four decades. 

Over the past couple of years, the closings have slowed down even more than these numbers suggest.  According to Postal Bulletin, there have been 153 discontinuances since December 2011, when the Postmaster General declared a six-month moratorium on closures.  Only ten discontinuances were done in 2013.  Almost all of the closures of the past two years have been based on discontinuance studies from 2011.  (A list made using announcements in Postal Bulletin is here.)

One finds the same thing by comparing a list of 70 post offices that closed during FY 2013, which appeared in Postmasters Advocate, the publication of the League of Postmasters, with the discontinuances listed on the USPS Postmaster Finder.  At least 80 percent of the 2013 closings involved final determinations issued in 2011.  (A table based on the Advocate list is here.)

All of which is to say, since December 2011, not many post offices have gone through a discontinuance review and been issued a final determination to close.  It's also not likely that we will see a lot of post office closings in the near future.  The Postmaster General told a Senate committee in September that there would no closings while Congress debated postal reform, and who knows how long that will go on?

Instead of closing post offices, the Postal Service has adopted two other approaches to trim the costs of its retail network.  The first was POStPlan, which is reducing hours at 13,000 small post offices and replacing their career postmasters with part-time workers.  As of this date, over 8,500 small offices have had their hours cut (a list is here), and another 4,500 will see their hours cut over the next year.  

For larger post offices, the Postal Service has taken a second approach.  Rather than discontinuing the post office completely, the Postal Service is relocating retail services to a new, smaller location.  From the point of view of citizens and customers, the closure is still a closure, but for the Postal Service, it’s just a relocation.

 

Inventory of the relocations

Over the past three years, the Postal Service has gone through the relocation procedures for something like 80 post offices.  (That doesn't include five more facilities announced for relocation review today, all in Houston.)  The Postal Service hasn’t published a list of the relocations, and there’s very little information on the USPS.com website about them, but there are hundreds of news stories on the individual relocations.  Based on the news, then, we’ve put together a list of the relocations.  Here’s what it shows.  

Some 55 of the relocation decisions involved buildings owned by the Postal Service; the other 25 involved leased spaces.  Of the owned buildings, 43 are historic properties (over fifty years old).  Eleven or twelve of them have been sold; the rest are listed for sale or remain unlisted.

In about 58 of the 80 relocations, the Postal Service has yet to close the post office and relocate.  It has simply gone through the process of meeting with elected officials, gathering public comment, and issuing a decision to relocate.  In some cases, a year or two or even more may go by between the completion of the decision-making process and the actual relocation itself. 

In about 50 instances, the public participation process was conducted with the new location "yet to be determined."   In 47 of the 80 relocations, the Postal Service still has not identified the new location.  The public has thus been excluded from that important part of the conversation.  The Postal Service also defers consideration of what will happen to the historic building after it's sold, and the public does not have much opportunity to offer input on that question either.  The post office just gets sold to the highest bidder, and whether it turns into a hamburger joint, or real estate office, or film production office, is apparently not the public’s business.

 

Challenging the relocations at the PRC and in court

Several communities have appealed the Postal Service's relocation decision to the Postal Regulatory Commission, but the Commission considers relocations to be outside of its jurisdiction.  The PRC has dismissed appeals on several controversial relocations, including those in Ukiah, Venice, Santa Monica, the Bronx, and Berkeley

To clarify matters, in January 2012 the PRC revised its regulations on appeals to state that relocations are not subject to appeals.  When it tried to define "relocate," however, the Commission ran into problems.  If the new post office was on the other side of town, was it a relocation or a case of one post office being discontinued and a new one opening?  If retail services were moved to a currently existing post office, was that a relocation or was the post office being discontinued?  Could two post offices be relocated to one new location or would one of them need to go through a discontinuance?  

The Postal Service and other stakeholders could not agree on the answers to such questions, so the Commission deferred the matter until a later date.  That was nearly two years ago, and since then nothing has been done to resolve the issues.  The Commission has thus been dismissing appeals on relocations without having a working definition of the key term.

The issues are further complicated by the fact that some closures are described by the Postal Service and PRC as a “realignment” or “rearrangement” of retail services, and the word “relocation” often comes up in this context.  In these instances, the Postal Service goes through a traditional discontinuance procedure, but then when the case comes up for appeal at the PRC, the Postal Service argues it’s outside the Commission’s jurisdiction because the closure was simply part of a realignment or rearrangement of retail services, not an actual "closure."  The Commission often agrees, and the case is dismissed. 

The PRC’s interpretation of the law on relocations, rearrangements, and realignments is currently being challenged in the U.S. Court of Appeals by attorney Elaine Mittleman on behalf of Venice, California, which was "relocated," and her own community, Pimmit, Virginia, which was "rearranged."  (The Mittleman brief is here.)  A related appeal has also been filed challenging the PRC’s dismissal of the Bronx appeal, another case of a "relocation," this one with the future location yet-to-be-determined.  (There's more about the issue here.)

The court has yet to decide if it even has the authority to review PRC decisions on post office closures, so it may be some time before there is legal action on the relocations. 

 

The purpose of the regulations on relocations

One of the main problems with the relocations is that the regulations the Postal Service claims to be following were never intended for this purpose.  They were added to the Code of Federal Regulations in 1998, during a period when the Postal Service was expanding, not downsizing, and they were supposed to increase the opportunity for public participation, not reduce it.

The regulations on relocations are contained in 39 CFR 241.4, which is entitled “Expansion, Relocation, and Construction of Post Offices.”   A first version of the regulations (the interim rule) was published in the Federal Register in May 1998; the revised version (the final rule) was published in September 1998.  Additional information about the relocation process can be found in a USPS handbook entitled “Community Relations Regulations for U.S. Postal Service Facilities Projects.” 

The Interim Rule explains that the new regulations were intended “to build into the facility project planning process specific opportunities and adequate time for the community to be a partner in the decision-making process and to have its views considered.”  The Final Rule describes the Postal Service’s priorities for facilities projects: “The first consideration is expansion of the present facility; next is relocation to another building; and last is new construction.”  The Community Relations Regulations handbook says that the new regulations represent “a major policy change that will have a long-term impact on the way the Postal Service acquires new or expanded facilities.” 

As these passages suggest, the new regulations were supposed to encourage input from the public about how the Postal Service’s presence in the community should grow when current facilities became inadequate.  They were intended to cover expanding current facilities and opening new facilities to replace those that had become too small.  They were never intended to serve as a means to facilitate the closing of major downtown post offices and replacing them with small retail outlets. 

That’s why the regulations for public participation in relocation decisions are not as stringent as those for a regular discontinuance.  Expanding a facility or relocating to a bigger one or building a new one is, generally speaking, an improvement, and such actions are much less likely to provoke opposition than the closing of a post office, which nearly always means a degradation of services.

This was precisely the point made by the petitioner in the Ukiah appeal: “The language and context of 39 CFR 241.4 clearly show that it is intended to apply to situations where an existing post office is too small or otherwise unsatisfactory and must be moved to a new location.  That is not the case in Ukiah, where the Main Post Office is unchallenged as having an excellent location and the consolidation into the Orchard Avenue Post Office is proposed only for alleged and substantial economic reasons.”

The Postal Service has been using the relocation procedures as the easy way to close post offices.  This has led to a considerable amount of confusion and frustration among customers.  The average person is incredulous when told that the post office isn’t really “closing,” it’s just being “relocated.”  How do you “relocate” a historic building that’s been serving as a post office for decades?  There may be a new post office opening somewhere else, but the old post office is obviously being closed. 

Saying that the post office is simply being relocated — and that the laws covering post office closures don’t apply — appears to many people to be a legal maneuver designed to minimize public participation and avoid appeals at the PRC.  

 

Concerns falling on deaf ears

One of the worst problems associated with the relocations is how much harm they are doing to the Postal Service’s reputation and brand.  The relocations are infuriating citizens across the country and doing inestimable damage to customer good will.

Considering that the whole purpose of the federal regulations on new construction and relocations was to make people feel that they were part of the decision-making process, it makes no sense to leave a community feeling that postal managers could care less what it wants.  But that's exactly what's been happening.

In Ukiah, California, one resident concluded that that the regulations requiring public participation are “meaningless because the Postal Service has no obligation to listen to what is said, let alone answer any important questions that might cast doubt on the wisdom of the undertaking.”

In La Jolla, California, elected officials and several groups worked very hard to stop the sale of their historic post office.  After trying to deal with the Postal Service for over a year, Leslie Davis, the chair of the task force to save the post office, observed that the Postal Service “behaved like an arrogant bully.  They have been dismissive, aloof, secretive and cocky.”  The Postal Service’s efforts at “communication” with the public have been “just for show,” said Davis.  “This is why people mistrust the system.”  (A news report earlier this week updating things in La Jolla says that “the USPS remains reticent to deliver news of its plans or time frame.”)

In Berkeley, California, the epicenter of the controversy over post office relocations, Mayor Tom Bates describes what his city has gone through  this way .  “It was really just an incredible maze of red tape and misinformation — wrong information and deception.”  The mayor has asked the Postal Service on several occasions where it is planning to relocate the Berkeley main post office but has received no response.

 

Notifying the public

The relocation process described in 241.4 is supposed to begin by notifying the public, elected officials, and, in the case of leased properties, the lessor.  The Postal Service is required to post a notice in the lobby and send a press release to the local news media.  The notice is supposed to state the date, time, and location of the public meeting, at least seven days in advance.

If the Postal Service were truly interested in partnering with the public, it could do more to notify them, like putting a copy of the notice in post office boxes and mailing it to everyone in the ZIP code area served by the post office, but the Postal Service always does the minimum.  Sometimes it barely does that. 

It’s not possible to determine when the Postal Service has notified the local news media and when it hasn’t.  You can find hundreds of press releases on USPS.com, going back several years, but only a half dozen of them are about relocations.  In many of the 80 relocation decisions we’ve examined, the news report came out after the meeting with elected officials, not before. 

There have been many complaints about how the Postal Service failed to get the word out on the upcoming meeting.  In some cases (e.g., Old Chelsea and College Station in New York City), the notice was posted in the lobby in an out-of-the-way location where people weren’t likely to see it.  

In the Bronx, Borough President Ruben Diaz Jr. wrote the Postal Service saying he was “appalled” over the barely publicized public hearing and postal officials’ perfunctory effort in reaching out to “community stakeholders, including elected officials,” instead sneaking in an inconvenient daytime hearing that seemed “designed to minimize public input during this important process.”

In March 2013, Postal Service real estate specialist Joseph Mulvey, who's been overseeing many of the relocations in the Northeast, asked to be put on the regular agenda of the Manhattan Borough Board to give a presentation about the relocation of not one but three important post offices in New York —  Old Chelsea, Peter Stuyvesant, and Triborough Station.  It took complaints from elected officials and the APWU to get the Postal Service to hold separate meetings in all three neighborhoods.

Just this week, Mr. Mulvey tried once again to get in under the radar on the relocation of Harlem’s College Station by giving a presentation at a regular meeting of the Economic Development Committee of the Manhattan Community Board.  These meetings are rarely attended by the public, and considering that it’s the busy holiday season, very few people were likely to attend the meeting.  When the Community Board learned the significance of the presentation, it told the Postal Service that the public would need to be properly informed, and it crossed Mr. Mulvey off its agenda, which was already packed with renewals of restaurant licenses.

And just today, the Postal Service gave a presentation at a meeting of the Houston City Council and revealed plans to relocate five post offices, all in buildings owned by the USPS.  The Postal Service representative told the City Council, "At this point in time we’re just looking at public input for the idea of a possible relocation.”  It's unlikely that the City Council realized that this would be the public's only opportunity for meeting with the Postal Service and that the postal rep had just avoided holding separate meetings in the five communities.  Also, the tone of "just looking for input" downplays what's really happening in a disingenuous way that's unfortunately typical of Postal Service representatives.

 

The public meeting

The regulations state that before the public hearing a postal representative must “personally visit one or more of the highest ranking local public officials,” and during the visit explain the need for the relocation and the process for gathering public input. 

It’s not possible to determine how often these personal meetings have taken place, but it appears that in many cases, the first face-to-face meeting with elected officials has been the occasion of the public meeting itself, not before.  Elected officials are often led to believe that the meeting with postal representatives would be just the first step and that additional meetings would come later.  They rarely understand that the regulations don’t require more than one meeting.

The regulations state that a postal representative should “attend, or conduct, one or more public hearings to describe the project to the community, invite questions, solicit written comment, and describe the process by which community input will be considered.”  In almost all of the 80 cases on the list, the Postal Service participated in only one public meeting, and in some cases, a request for another meeting was explicitly rejected.

The regulations say that the Postal Service can ask to be put on the agenda of a regular meeting of an elected body or hold a separate hearing.  The Postal Service prefers the easier route, just giving a presentation at a regular meeting of a town board.  While this may conform to the legal requirement, such meetings are not often well attended, and many people who might otherwise have wished to express their views about the future of their post office end up not attending.

In Reading, Massachusetts, the Postal Service provided a minimum of public notice about the regular town meeting at which the relocation would be discussed.  The agenda allotted a half hour on the issue, and there probably won’t be another opportunity for the public to weigh in.   “Nearly a half dozen” people attended the meeting on the Palmer Square post office in Princeton, even though that post office is widely used, an historic building, and much valued by the community.

The Postal Service treats the public meetings simply as a requirement that needs to get checked off its to-do list.  There's little interest in what the public has to say.  In Coralville, Iowa, elected officials objected to the Postal Service’s plan to relocate retail services to an inconveniently located carrier annex.  When the Postal Service said it was sticking to the plan, a City Councilor said he wasn’t surprised by the decision.  “I felt at the public input meeting they weren’t taking our concerns seriously, " he said.

In Ukiah, California, hundreds of people showed up for the meeting about the relocation of their historic post office, but the Postal Service came unprepared and unwilling to share information.  One resident said that the Postal Service "should be ashamed coming here with the information they have."  A member of the city council pointed to the lack of transparency as one of the main reasons people were so angry, and another member of the council said it appeared to him that "postal officials were not in Ukiah with the intent to listen to the public and perhaps change their recommendation, but to announce that the decision had already been made."

 

Public comments

The regulations say that the Postal Service can make a decision fifteen days after the public meeting.  That means the comment period can last as little as fifteen days, and that’s often exactly how long the Postal Service gives people. 

A member of the Historical Commission in In Reading, Mass., asked for an extension on the public comment period because the Commission wouldn’t be meeting before the period ended.  The Postal Service said no, adding that there would be other opportunities to comment.  But the only time one can comment later is during the appeals period.

There’s rarely any need for the Postal Service to hurry things along.  In most of the 80 relocation cases, the Postal Service has yet to find a new location and complete the process, even though the comment periods closed months and months ago.  The Postal Service could easily be taking comments and keeping its options open, but it wants to get the process over as quickly as possible.

Sometimes so much time passes between the public comment period and the actual relocation itself that no one can even remember that a comment period happened.  When the Postal Service relocated the post office in Washington Heights, New York, elected officials felt "left in the dark" because they hadn't been informed, but it turned out that the public meeting had taken place on December 14, 2010, well over two years before the relocation took place.  

The Postal Service seems to have relocated the Greeley Square post office in New York without telling anyone about it at all.  A spokesperson simply said, "“We relocated the retail station because a new lease could not be negotiated with the landlord." 

In Stamford, Connecticut, the Postal Service did the relocation process in 2010, and then proceeded to close the post office — with no new location in place — three years later. 

Another problem with the public comments is that no one gets to see them except the Postal Service.  In its final decision notices the Postal Service will sometimes summarize the comments, but it does not make them available to the public, which makes it impossible to judge whether they've been given a fair hearing.

 

A done deal

It’s not just that the comment period is relatively brief and that most customers probably don’t even realize they can submit comments.  The larger problem is that when there are a lot of comments opposing the relocation, they’re simply ignored.  As often as not, it was clear before the public comments were gathered that a decision had already been made.

There have been several cases where the chronology of events suggests that the Postal service had already made a final decision to relocate even before the public participation process was completed — sometimes, even before it began.

In Derby, Connecticut, for example, the Postal Service listed the post office for sale on its “Properties for Sale” website in January or February of 2013, and then announced in March that it would be doing a relocation study.  (Soon after this fact was observed on Save the Post Office, the listing on the Derby post office was removed from the USPS-CBRE website.)

In Dana Point, California, word about relocating the post office appeared in the media in February 2013, by which time negotiations were already underway with a Texas-based real estate development company to buy the building.  The Postal Service held the public meeting on the relocation in April.

In Thousand Oaks, California, the Postal Service began installing post office boxes at the carrier annex, the new site for the Newbury Park post office, well before the public meeting took place.  A postal official later said this was a mistake and that construction would stop until the public participation process was completed.  One resident of Newbury Park said he had decided to stop using the Postal Service when he learned that the capital improvements for retail at the annex were already made prior to the formal process even being completed.  “There is no way," he said, "that USPS people involved could have made ‘inadvertent’ mistakes having gone through the same process so many times before.”

A related problem is giving the community false explanations for why the relocation is necessary.  In New Canaan, Connecticut, the Postal Service told the community it had to relocate the post office because efforts to renew the lease had failed, but the landlord told the media that “his firm thought it had negotiated a deal with the U.S. Postal Service for the Post Office to remain in the current space on Pine Street.  Then, the firm received a call one day that the Postal Service reconsidered.”  Turns out the Postal Service had decided it wanted a smaller space. 

The same thing happened with the Peter Stuyvesant post office in New York City.  The Postal Service announced that it had to relocate because it could not work out a lease renewal with the landlord, "but a rep for the owner said it was actually the Postal Service’s decision to leave because of a desire to downsize."  The conflicting explanations were a source of much contention at the public meeting on the relocation.

 

Appeals in name only

While appeals on post office discontinuances are heard by the Postal Regulatory Commission, appeals on relocation decisions are directed to the USPS Vice President of Facilities.  This means that no outside agency reviews the decision, and the person considering the appeal may have already been involved in making the decision to begin with. 

When the PRC reviews a discontinuance appeal, the Postal Service must produce the administrative record, which is posted on the PRC’s website.  It includes all the official notices to customers, public comments, questionnaires, a cost-savings analysis, and other internal USPS documents.  In a relocation procedure, there’s no requirement that the Postal Service produce the administrative record, and it never does.  That’s one of the reasons why it’s impossible to determine when notices were posted, what comments were submitted, whether the financial angle makes sense, and so on.

In some cases, like Berkeley, elected officials had to file a FOIA request to get some of these records.  Sometimes the Postal Service refuses to produce the record even after a FOIA request, as it did in the case of Ukiah.  Congressman Mike Thompson even wrote the Postmaster General asking to see documents related to the Ukiah appeal, and he too was turned down.

Appeals to the PRC on post office closures rarely succeed, but appeals on relocations never get anywhere.  In every case we’ve seen documented, the Postal Service’s Facilities VP Tom Samra has affirmed the decision to relocate.  The appeals process seems futile.

In a news report earlier this week, the vice-chair of the Save Our La Jolla Post Office Task Force, Joe LaCava, is quoted saying that it’s an appeal process “in name only.”  “There’s no legitimacy to it, no ability to go to a higher authority if USPS rejects (the appeal),” LaCava said.  “The process (seems to be) driven more by the private consultants that help them in these real estate transactions than it is by the USPS’s mission and its role in our local neighborhoods.”

 

A new location "yet-to-be-determined"

The regulations on relocations are about giving the public input into the process, but in most cases, the Postal Service has gone through the process without having identified a new location.  This only magnifies the impression that the closure is really a closure, not simply a relocation, and it also raises the question, what happens if the Postal Service approves the relocation but then doesn’t come through with a new location?  Wouldn’t that mean the relocation was actually a discontinuance after all?

In Stamford, Connecticut, the Postal Service went through a relocation procedure in 2010, and then three years later, it closed the post office without having found a new location.  An appeal was immediately filed with the PRC, claiming that the relocation was a de facto discontinuance. The Postal Service quickly changed its story and said the post office had been closed because of an emergency suspension over unsafe building conditions, but it was clear that the closure was part of the relocation plan.  The PRC has yet to rule on whether it will hear the case or dismiss the appeal, and the sale is tied up in federal court because the Postal Service did not do an adequate environmental impact review.

In Berkeley, the Postal Service has said that it’s possible it would lease back space in the historic post office building and keep a post office there, but Berkeley's mayor isn't buying it.  “This is playing semantic games with the public trust and contributes to public distrust of government," says Mayor Bates.  “If the Postal Service has a place to relocate the retail postal service other than 2000 Alston Way (its current location), it should be required to make it known prior to moving ahead with a scam relocation.”

The relocation regulations do not require that the new site be known when the public meeting occurs, but by conducting the process without having selected the site, the Postal Service deprives the community of an opportunity to comment about it.  That problem was one of the main concerns voiced by PRC Chairman Ruth Goldway when she issued a concurring opinion on the dismissal of the Berkeley appeal.  Her comment is worth quoting in full:

“Decisions to relocate a post office can be wrenching on a community. The Postal Service should undertake a thorough and balanced review, particularly when the building is historic and part of the civic fabric of the community.  A decision to sell a building prior to identifying a relocation site bifurcates the community input and significantly reduces the ability of the Service and the community to evaluate the impact of relocation.

“The process the Postal Service is currently employing appears to cause needless confusion in the affected communities, as evidenced by the appeals filed with the Commission, and damages its relations with the customers it is trying so hard to retain. The process would be improved if the Postal Service identifies the new post office location contemporaneously with announcing its decision to relocate the existing post office.”

 

Bifurcating relocations and NHPA

The Postal Service not only fails to include the new location in the deliberations; it bifurcates the relocation process in another way — by refusing to address questions about the fate of the historic post office building. 

Even though the regulations described in 39 CFR 241.4 clearly reference the importance of following the requirements of the National Historic Preservation Act when doing relocations, the Postal Service claims that it is exempt from NHPA requirements and follows them only on a voluntary basis.  It also argues that NHPA comes into play only when it’s time to dispose of the building, not as part of the relocation decision.  As a result, all the concerns expressed by the community about the future of the historic property are deemed premature during the relocation process.

The National Trust for Historic Preservation has repeatedly criticized the Postal Service for taking this position, arguing (as it did in the case of La Jolla) that changing the use of a post office to another purpose is clearly an “adverse effect” under NHPA and that the consultation process should begin as soon as the Postal Service initiates the process of considering a relocation and sale.

NHPA also came up recently when the sale of the post office in Stamford, Connecticut, was challenged in federal court.  In issuing an injunction to stop the sale, the court said that the sale of the building did constitute an adverse effect and that additional procedural steps, aside from consultation with the SHPO, would be required, “such as notification of the Council on Historic Preservation and the solicitation of public comment.”  The question of whether or not these steps should have been taken during the relocation process was not at issue, but the Postal Service would obviously avoid a lot of problems if it did more to incorporate NHPA considerations into the relocation process.

 

Two-for-one relocations

Another problem with some relocations is that the Postal Service relocates two post offices to the same new location.  Common sense would tell you that one of the post offices had to be discontinued, but not according to the Postal Service.  Both post offices just got “relocated.”

Relocating two post offices into one new location is actually a scenario that’s described in the final rule on 39 CFR 241.4, which contains the following passage: “There may be instances where the facility project rule issued today governs a project that is also covered by the discontinuance rules.  For example, if two post offices are both housed in substandard buildings in a rural area that has experienced significant population loss, the Postal Service may consider consolidating the post offices and relocating all operations to a single new building convenient to both affected areas.  In that situation, the Postal Service would comply both with the discontinuance rules at 39 CFR 243.1 with respect to the closing/consolidation decision and with this facility project rule with respect to the decisions about selecting or building a new facility.” 

This passage makes it very clear that when two post offices are relocated to one new location, at least one of them must go through a discontinuance procedure.  The Postal Service has ignored this provision in the regulations on several occasions.

In February of this year, for example, the Postal Service relocated retail services at the Main Post Office on Kellogg Street in downtown Saint Paul, Minnesota, to a new location a few blocks away, at the U.S. Bank Building at on East Fifth Street.  The following month, the Postal Service also closed St. Paul’s Uptown Station, located in the historic Hamm Building on St. Peter Street.  Its retail services were also relocated to the U.S. Bank Building.  In neither case did the Postal Service do a discontinuance study.

In Rochester, New York, the Postal Service closed the Midtown Station on East Broad Street (which replaced the now demolished Midtown Plaza a block away) and the Federal Building Station on State Street.  Retail services at both post offices were relocated to a new location on West Main Street (where there are likely to be issues over the lack of parking).  

Back in 2011, the Postal Service made plans to consolidate two post offices in Bellevue, Washington, into one new location.  A postal official attended a City Council meeting to deliver the news, and that was probably the extent of public participation.   The Midlakes office on 2nd Place eventually relocated to 38th Street.  The plan also called for closing the main post office on Bellevue Way and moving it to the new location as well, but that hasn’t happened yet.  If and when it does, there's not likely to be another meeting about it.  The Postal Service will take the meeting took place in 2011.

 

Abandoning downtown

Once the retail services have been relocated, there are often new problems to deal with.  In ten of the 33 completed relocations, the new location has been a carrier annex on the outskirts of town.  These facilities function as annexes because it’s easy for postal trucks to get in and out, but they were never intended to serve as retail post offices.  They are out of the way, typically in industrial zones, and difficult to reach by public transportation or on foot.

That’s not only a matter of inconvenience for seniors, pedestrians, and people with disabilities.  Moving a postal facility to an annex or a new space that’s not in the downtown area hurts the local economy.  The Community Relations guidebook on relocations and new construction recommends finding new locations in downtown areas, and there are several federal laws and executive orders that encourage federal agencies to locate and remain downtown.

For example, Executive Order 12072, issued by President Carter, directs agencies to “give serious consideration to the impact a site selection will have on improving the social, economic, environmental, and cultural conditions of the communities in the urban area.”  Along similar lines, Executive Order 13006, issued by President Clinton, directs federal agencies not only to locate their operations in established downtowns, but also to give first consideration to locating in historic properties within historic districts. 

In Northfield, Minnesota, over a thousand people signed a petition opposing the move of the post office from a historic building downtown to a carrier annex, but to no avail.  In Norwich, Connecticut, city officials opposed the Postal Service’s decision to close and sell the historic Main Street post office and move retail services to the postal distribution center three miles outside of the urban center.  According to a local news report, “Norwich might not get a full hearing on their arguments.  Because the Postal Service considered it merely a transition from one Norwich facility into another, the city was not given any input or a public hearing ahead of time on the decision.

While the Postal Service often says it wants to stay downtown, that’s not always what happens.  In Camas, Washington, downtown merchants were very disappointed to see the post office leave the city’s core.  “You’re losing a major part of the downtown that draws a lot of people,” said the executive director of the Camas-Washougal Chamber of Commerce.  “You hate to see anything go that takes away from the walking traffic downtown.”

 

More problems with the new locations

Another problem with the new locations has been inadequate parking.  The new Bethesda post office, for example, has not been well received for that reason, and Congressman Christopher Van Hollen wrote the Postmaster General to complain: “The USPS’ misrepresentation of its policies and stated priorities has become the source of the community’s outrage at the misguided selection of this location.”  Earlier this week, the Postal Service informed elected officials that the search for a new location has yielded no results.

A few days ago, there were also news reports about a similar problem with the new location of the Santa Monica post office in the carrier annex.  Most customers seem to agree that the biggest problem about the new site is the parking.  “It sucks,” said one Santa Monica resident.  “It’s dangerous.”  Congressman Henry Waxman also wrote the Postmaster General to complain about the problem, an issue he had raised long ago when he appealed the closing to the PRC.

The parking issue has already come up in West Hollywood, where the Postal Service hasn’t even identified the new location yet.  Mayor Jeff Prang told postal officials, “If you look at the area around the West Hollywood post office for the best location to put a public counter and parking, it would be where you are right now.  It seems counterintuitive to spend money on rents in this area. Parking in this area is very expensive and very rare.”

Just this week, there's a news report that the Postal is going ahead with the relocation of the Coralville, Iowa, post office to a carrier annex.  Congressman Dave Loebsack appealed to the Postal Service but to no avail.  Concerns about the new location included its lack of parking, sidewalk accessibility, and public transportation.  “It’s really not a good location, and it’s really inconvenient for residents, especially the elderly,” Fausett said. “It’s really disappointing.”  

 

Resolutions about the relocations

The Community Relations guide on relocations tells postal officials, “Depending on circumstances, it is a good idea to ask the town to adopt a resolution in support of the project or at least to obtain a copy of the town minutes reflecting the reception given the Postal Service's presentation.”

The fact that the Postal Service might expect to get a town resolution supporting the project is further evidence that the relocation regulations were never intended for replacing large downtown post offices with small retail facilities.  One could hardly expect elected officials to pass resolutions supporting such projects.  In fact, just the opposite is happening.

In Lakewood, New Jersey, the Township Committee was adamantly opposed to the relocation because it would affect thousands of residents, many of whom do not drive and would be unable to make the trip to the replacement post office.  The deputy mayor called for a resolution formally condemning the Postal Service for lack of consideration, and the mayor called for a resolution lifting the requirement that the town use the Postal Service for town business.

In South Gate, California, the city passed an ordinance intended to stop the relocation of its post office by limiting alterations to the historic building. 

The city council of Iowa City passed a resolution encouraging the Postal Service to consider alternative site selection criteria that would expand location options closer to downtown rather than a shopping plaza inaccessible for pedestrians.

In Northport, New York, the relocation of the post office was widely opposed by residents and elected officials, including representatives of Senators Schumer and Gillibrand.  The Huntington Town Board unanimously approved a resolution to write a letter to congressional leaders opposing the Northport closure.

In Berkeley, the city passed a new zoning ordinance that would, as the Wall Street Journal explains, “restrict the use of the post office and adjacent government buildings to government agencies or public uses like a theater.”  Berkeley may become an example to other communities, and we may see more such resolutions. 

 

For further reading

If you'd like to read more about the relocations, there are dozens of articles about what's happened in individual communities on Save the Post Office, archived here.  The database of relocations also contains links to a couple of hundred news articles, many of which provide more details about the relocation problems.  Just click on the links to the articles to read more.  You can see the database with additional details here.

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