National Association of Postmasters of the United States (NAPUS) submits the following comments in support of the Postal Service’s July 6 request of the Postal Regulatory Commission to approve a rate adjustment due to “extraordinary or exceptional circumstances:

It would be shameful if those who argue for furloughs would have the unintended consequence of advocating against our veterans.

Since enactment of PL 109-435, global and domestic economic conditions have deteriorated sharply. In fact, 2005 was the last year in which the United States Gross
Domestic Product (GDP) exceeded 3%. While the normal business cycle experiences economic waxing and waning, the ongoing financial turmoil is quite different. As of yet,
our country is still languishing in a unrelenting recession. In fact, over the past three years, the Congress and two successive Administrations felt the necessity to take drastic
steps, attempting to stabilize the economy. As illustrated by falling mail volume and revenue decline, the Postal Service is not immunized from these dire economic
circumstances. Furthermore, the statute does not state that the circumstances must be unique to the Postal Service to prompt an exigent rate case.

A number of intervenors have commented that the private-sector institutions were able to ride out the recession through retrenchment, radical structural and pruning labor costs.
For the most part, these private-sector profit-maximizing strategies are unavailable or improper in a governmental public service agency. The Postal mission is to maximize
service to the American public. Moreover, the Postal Service must comply with a series of statutes and regulations (e.g., veterans’ preference, pre-funding retiree health benefits,
fully funding retirement benefits, and the universal service obligation); those who urge the Postal Service to freeze, furlough and fire are exempt from these requirements.
A number of intervenors and commenters have suggested that the Commission should reject the Postal Service’s request, since the federal agency has not exercised such cost-cutting strategies as freeze, furlough and fire. Those who have associated with these views have a total disregard for the impact on the service provided to the American
public, the affect on the postal workforce, and the long-term implications for the future of the Postal Service’s universal service obligation.

The intervenors seem to overlook the huge decline in postal employment over the past decade. The agency has shed more than 164,000 positions and this represents an almost
21% decline since fiscal year 2000. The Commission should recognize that “Reductions-in-Force”, within the federal government, are subject to various statutes, which among
other safeguards, protecting former members of the U.S. Armed Forces. It would be shameful if those who argue for furloughs would have the unintended consequence of
advocating against our veterans.

Unlike private sector companies that have undergone recession-necessitated retrenchments and initiated sizeable layoffs, the Postal Service provides a vital and
constitutionally mandated public service. Moreover, profit-driven entities, by their very nature, may be dismissive of the public-service aspect of their mission, if they have one at all. For the Postal Service, however, public service is its raison d’être; and, any action that undermines its core mission needs to be considered unfavorably.

NAPUS is concerned that the recently announced hiring freeze is undermining the capability of front-line postal managers and their employees to deliver quality services to
the mailing public. This compounds a major problem that is being experienced throughout the country, a concerted strategy to close statutorily protected Post Offices
through the abuse of the Post Office suspension process. (Last year, the Commission initiated an investigation of this abuse – PI2010-1.) In response to POIR-4, in the present
docket, the Postal Service disclosed that, beginning in fiscal year 2010, the agency estimates that 3,248 Post Offices will be without a Postmaster; the number of Postmaster
vacancies almost doubled over the past year. Additionally, in fiscal year 2010, 12% of all Post Offices would be without a Postmaster and foreshadows Postal efforts to suspend
(aka to close) those Post Offices.

Commission denial of the requested rate adjustment, in NAPUS’ view, would compel the Postal Service to wield its cost-cutting axe against service provided to American citizens,
small businesses and rural America. These are the prime constituency for which the universal service obligation was established.

NAPUS suggests that the Commission consider degradation of postal service standards (e.g., delivery standards, postal window hours, customer service, etc.) in its assessment of
the exigent rate request. To do otherwise, would force the Postal Service into noncompliance, which would only come to light when the Commission issues its ACR for
2011.

NAPUS urges the Commission to approve the Postal Service rate increase, which is necessitated by “extraordinary and exceptional circumstances.” We believe that the
current economic conditions are of such magnitude that the request is justified and that the Postal Service has striven to reduce costs, including cuts that Postmasters continue to
believe are harmful to customer service. Rejection of the Postal Service request will result in a cascade of service reductions that will utterly destroy our Postal Service.

read full document submitted to Postal Regulatory Commission