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June 1 2010 09:17 AM

For quite awhile now, the U.S. Postal Service (USPS) has been turning up the volume in its messages to Congress that help is needed to address the issue of USPS funding of its retirement-related obligations. The Postal Service's focus, however, has not been limited to retirement obligation funding alone. In fact, its real focus has been to convince Congress of the need to overturn the Postal Accountability and Enhancement Act of 2006 (PAEA) and to create a new postal statute that gives the USPS a freer hand.

The Postal Service, at all levels, has done little to hide its disdain for PAEA. Most particularly, the USPS has bridled at the requirements in the law for capping prices for market-dominant products at the annual rate of inflation, the imposition of rules designed to ensure transparency and accountability, and the positioning of an external regulator with even a minimal of power to shape and direct the Postal Service's schedule of products and prices.

The concern is that the Postal Service is giving Congress only its part of the story. The other part is that it has passed up an abundant number of opportunities to avoid many of the straits in which it now finds itself. Here, for instance, is a short list of what the Postal Service could have done and chose instead not to do:

$ The Postal Service could have prepared itself for the decade long transformation that has marked how this nation communicates and does business. Instead, it sought comfort in the prognostications of feather merchants who assured them that, as in the case of the telephone and telegraph, there really was no danger to future mail volume and revenue.

$ The Postal Service could have explored and exploited every opportunity to ride the coming digital wave to empower the Postal Service to retain its relevance in the exchange of information and the transaction of commerce.

$ The Postal Service could have sought to use the flexibility provided by PAEA to re-engineer its products and services to better comport with the needs of a changing market.

$ The Postal Service could have moved quickly to bring to market an array of new products and services that more closely matched the needs of a changing market.

$ The Postal Service could have moved aggressively to restructure its physical network to more closely match the changing demand for postal services with available resources. Instead, it allowed itself to be cowed by the mere threat of possible congressional disapproval.

$ The Postal Service could have move more affirmatively with its employees and their representatives to address expeditiously wasteful work place rules.

$ The Postal Service could have mounted a much more affirmative stance to press home to Congress' attention the inequities associated with an over-funding of retirement-related expenses. That task, however, was left to the initiative of its Inspector General.

The USPS clearly had it within its means to make every element noted above a cause celebre. Instead, it has shown only the vigor to move forward with proposals to lessen the number of days of mail delivery and to raise postal rates beyond what ordinarily would be allowed under the 2006 postal act.

In short, instead of taking actions that could have spared its customers pain, it has chosen to exact the kind of pain a wise business would seek to avoid. Customers are being made the victims of the Postal Service's unwillingness to move smartly and with dispatch.

Postal customers are now the pawns in a struggle to absolve the Postal Service of its responsibilities and liberate the USPS from any real measure of public and political accountability and competitive restraint.

One can only hope that the Postal Regulatory Commission has a clear appreciation for what's gone on, what's going on, and what's at stake. The PRC will be facing its first real threshold test to demonstrate whether the confidence Congress invested in it was worth while. When the USPS files for its first-ever exigency rate case, the Commission will have to determine whether or not the "extraordinary or exceptional circumstances" test has been fully satisfied. Any rush to judgement for the sake of some overshadowing political expediency will only further undermine the viability of the postal accountability act by punishing postal customers rather than protecting them from a statutorily protected monopolist.

The Commission needs to keep its eye on the ball. Its mission in life is not to ensure the fiscal viability of the Postal Service, nor is its mission to safeguard the nation's universal mail delivery system. Those responsibilities belong to the Governors. Congress gave the Commission an entirely different, but still important, mission.

It has been said that the business model of the Postal Service is broken. Broken, itt may be. It wasn't, however, the customers of the Postal Service who broke it, and they shouldn't be held accountable to fix it.