The APWU is challenging proposed changes to USPS service standards that would result from a major reduction in the number of mail processing facilities. The Postal Service announced plans to eliminate 252 mail processing facilities on Sept. 14, and one week later published an “advance notice” of the proposed changes in service in the Federal Register. [PDF]

“The APWU vehemently opposes the USPS proposal to eliminate 60 percent of existing mail processing facilities and to make corresponding cuts in service standards,” President Cliff Guffey wrote in a letter dated Oct. 5. [PDF] “If adopted, this proposal would deprive postal customers of needed service, damage the economy, and drive customers away from the Postal Service.

“It is worth noting that the proposal acknowledges what the Postal Service has repeatedly denied regarding the closure and consolidation of mail processing facilities: Slashing the mail processing network will result in drastic cuts in service to the American people,” Guffey wrote.

The APWU is encouraging locals to write to legislators and point out the effect the service changes would have on residents and businesses in their community. “Bills pending in Congress would make this dramatic cutback in service unnecessary,” said Legislative and Political Director Myke Reid. “We urge union members to continue to ask legislators to support H.R. 1351, which would help provide the Postal Service with financial stability without any cost to taxpayers,” he added.

“The Postal Service cannot eliminate hundreds of mail processing facilities and meet its current service commitments,” said Executive Vice President Greg Bell. “Despite management’s reassurances to community leaders and lawmakers, wholesale facility consolidation would devastate mail service — and that is what the Postal Service is planning.”

In his letter protesting the service changes, Guffey wrote, “The elimination of overnight delivery of first-class mail and periodicals as well as a reduction in the range of two-day delivery would impose a significant hardship on postal customers. And, in addition to the reductions specifically discussed in the proposal, the changes would likely destroy Express Mail and Priority Mail.”

The proposed changes are contrary to the objectives of the Postal Reorganization Act, Guffey asserted, and fail to take into account many of the factors the Postal Service is required to consider when setting service standards.

The law stipulates that changes in service standards must be designed to “enhance the value of postal services to both senders and recipients,” “preserve regular and effective access to postal services in all communities” and “reasonably assure Postal Service customers delivery reliability, speed and frequency consistent with reasonable rates and best business practices,” the letter notes.

“The proposed rulemaking fails to meet these objectives,” Guffey said. The proposal focuses on mail volume and costs, but fails to pay attention to customer needs, he wrote.

The USPS notice states that the proposed reductions in service are necessary to “align the Postal Service’s infrastructure with current and projected mail volumes and to bring operating costs in line with revenues,” and that, “If the Postal Service were to revise service standards as described above, it could significantly improve operating efficiency and lower the operating costs of its mail processing and transportation networks.”

These objectives are not among those listed in law, the union president pointed out. “By designing service standards to meet budget goals rather than service demands, the Postal Service is violating the maxim that businesses cannot cut their way to financial health.

“In doing so, the proposal would degrade existing USPS products; limit the Postal Service’s ability to introduce new products, place the USPS at a distinct competitive disadvantage, and severely hamper its ability to accommodate growth. Consequently, the proposal virtually guarantees continued mail volume declines and further cutbacks in service.”

The USPS notice in the Federal Register invites comments from the public until Oct. 21. If the USPS decides to implement the proposed changes in service standards after the public comment period, it will submit its proposal to the Postal Regulatory Commission for an advisory opinion. It also will publish an additional notice in the Federal Register specifying precisely what changes it intends to make in regulations governing service standards. The review by the PRC and the next notice in the Federal Register will provide an additional opportunity for public comments.