PRC Chairman Ruth Goldway is responding to letter from NAPUS requesting a review of USPS post office closings:

Last month, “NAPUS Post Office Preservation Committee Co-Chair, Retired Postmaster Keva Richardson (Thurman, IA) filed a letter with the Postal Regulatory Commission (PRC), which asks the Commission to review USPS plans to close more than 2,000 Post Offices around the country. Specifically, Committee Chair Richardson is asking the PRC to determine if the Postal Service is violating §101(b) of Title 39 of the United States Code, which ensures nondiscriminatory postal services throughout the nation, and helps safeguard small town and rural Post Offices.

The PRC is reviewing Postal practices relating to Post Office suspensions. The PRC is expected to hand down its report on suspensions in the near future.”

March 1, 2011

Keva Richardson
Co-Chair, Post Office Preservation Committee
National Association of Postmasters of the United States
2372 Waubonsie Avenue
Thurman, IA 51654

Dear Ms. Richardson:

This responds to your letter dated February 11, 2011, in which you express concerns of the National Association of the United States’ (NAPUS) Committee on Post Office
Preservation that the Postal Service has not followed appropriate procedures regarding its closing and consolidation processes for post offices, specifically that its efforts to close post offices to cut costs may violate §101(b) of title 39, United States Code. You request that the Postal Regulatory Commission (Commission) review Postal Service plans and open a docket on this issue.

I appreciate you sharing the views of the NAPUS Committee regarding the Postal Service’s plans for possible large-scale closings of small and rural post offices. As you
may know, the law requires the Postal Service to submit plans for proposals involving nationwide changes in service to the Commission for an Advisory Opinion. It is our
responsibility to guard against the possibility that the Postal Service may implement ill-considered cuts that adversely affect postal customers. Please be assured the
Commission is aware that the Postal Service has spoken in the media about an initiative to close 2,000 unprofitable post offices; however, since the Service has not formally submitted their plans to us for review, it would be premature to open a docket at this time for this matter.

It may be helpful for you to know that the Commission has been working in this area, i.e. making recommendations to the Postal Service about improvements to the
closure/consolidation process. Early last year the Commission issued its Advisory Opinion on a Postal Service proposal to consider 3,200 station and branch retail facilities
for possible closure. The list of potential outlet closings decreased during our review to just 162 offices at the time we issued the Opinion. We affirmed the Postal Service’s authority to adjust its retail network but recommended several improvements. The Commission recommended that standardized review procedures should be developed and consistently applied nationwide to all post offices, stations and branches in order to ensure adequate and efficient service levels and comply with statutory guidelines.

We understand the Postal Service is now in the process of updating their entire closure process, and placing needed focus on community notification. While the Postal Service has not submitted a request for us to review any plans nor have we seen the updated process, we have had some initial conversations with the Postal Service and believe the Service is making changes in its procedures to accommodate the Commission’s recommendations that were raised in the Hacker Valley case and the station and branch consolidation initiative.

Your Committee’s concerns about rural and small town post offices are valuable and assist us in fulfilling our obligations. Section 701 of the Postal Accountability and
Enhancement Act (PAEA) requires the Commission to issue a report on the effectiveness of the PAEA and other recommendations for legislation or other measures
to improve the effectiveness or efficiency of the postal laws of the United States. I fully expect the Commission to discuss issues related to the Commission’s appropriate role in post office closings.

I look forward to working with you, the Congress and the Postal Service and all who depend on the mail to chart a course that keeps the mail affordable, efficient and
relevant. If you have any questions or I may be of further assistance, please do not hesitate to contact me.

Sincerely,

Ruth Y. Goldway
Chairman
see letter in PDF format