Though spun to appear as improving service performance, the Postal Service has announced a proposal to further reduce service standards so it can eliminate afternoon collections nationally. Though the USPS is overtly committed to going through the advisory opinion process, it’s well known that the resulting opinion is not binding and that, as has happened with previous opinions, the USPS will implement its plan as intended.
The Release
In its August 22 press release, the USPS stated, in part:
“The Postal Service is proposing key improvements and adjustments to optimize service and reduce cost, including:
• Transitioning from 3-Digit to 3-Digit ZIP Code standards to more precise 5-Digit to 5-Digit ZIP Code standards. ...
• Adjusting pick-up and drop-off times of volume between post offices and processing plants, when the post offices are far away from the regional hubs. ...
• Expanding daily reach for most classes of mail and packages when traveling through the network; resulting in faster delivery expectations for some mail pieces. ...
• Recognizing the significant volume reduction of Single-Piece First-Class Mail and making the long overdue adjustments required, while committing to a 3-day delivery standard for local Single-Piece First-Class mail, and in some instances even achieving a 2-day standard. … Depending on location, time, and distance, expected time to deliver will increase for some ZIP code pairs.
“The proposed changes will maintain the existing 1-5 day service standards for First-Class Mail and are designed to enable the Postal Service to make optimal use of its updated and developing ground network. The streamlined processes for the integration of both mail and packages, will ensure efficiency and timeliness by enabling an integrated delivery network that avoids duplication and complexity. The refinements within the existing service standards are projected to enhance service reliability and predictability, crucial aspects of the Postal Service’s commitment to universal service.
“Moreover, these modifications are anticipated to yield significant cost reductions for the Postal Service, with an estimated saving of approximately $3 billion annually. This aligns with the organization’s mandate to be financially self-sufficient, while continuing to deliver to every address across the nation.”
Postmaster General Louis DeJoy, who has already driven other reductions in service standards through previous advisory opinion filings, repeated his well-known allegation that:
“… our service requirements, facilities infrastructure, business rules and operating practices have continued to reflect a Postal Service designed for three decades ago.”
The 2022 Law
DeJoy cleverly now cites elements of the 2022 law which he advocated as the reasons compelling these changes.
The USPS previously had the operational latitude to move time-sensitive mail, like First-Class Mail and some Periodicals; premium package products like Priority Mail; and deferred service products like Parcel Post, in separate mailstreams, with the related attributable and institutional costs being assigned accordingly. The legislative “mandate” that DeJoy engineered – that all mail (market-dominant and competitive) must be in a single “integrated network” – impacts cost attribution.
DeJoy wants to grow package volume, so the cost attribution pattern of an “integrated network” can enable more advantageous pricing for competitive USPS package services. This was recognized somewhat obliquely by one of the “facts”:
“… our package and mail products will benefit across the board. The service standards we set for First-Class Mail are also aligned with all of our other products.”
Six-day delivery of all mail also was not codified before DeJoy agreed to it being part of the 2022 law. Doing so pleased the carriers’ unions but – in the face of declining volume – committed the USPS to retaining a level of service to an expanding delivery network being supported by less mail revenue.
Collection Mail
The proposal about “optimization” of collections epitomizes DeJoy’s fixation on “efficiency” at the expense of service. Essentially, his proposal defines mail from ratepayers served by post offices more than 50 miles from the Regional Processing and Delivery Center as not qualified for the same service available to customers of closer post offices; an afternoon collection run to those distant offices isn’t “efficient.”
However, in another creative move, DeJoy obscures the decrease in service by reframing how the deferred mail would move. By arguing that it would get into the mailstream “earlier” (i.e., in the morning) than if it had been in that afternoon’s collection, he overlooks that – absent the more “efficient” collection regime – that mail would have been in the mailstream the previous day – when it was actually mailed. In turn, by redefining the day of mailing, he can continue to claim the mail gets the same service.
Service
In an interview with The Washington Post, DeJoy admitted his proposal would result in different levels of service, stating “customers within 50 miles of the Postal Service’s largest processing facilities [will get] faster delivery service.” Justifying this as another necessary step in his Plan to fix problems he says he inherited from his predecessors, DeJoy added:
“At the end of the day, I think some portion of the mail showing up 12 hours later, I think it’s a price that had to be paid for letting this place be neglected. … We’re trying to save the Postal Service – not figuratively, not to advocate for something. We’re trying to literally save the Postal Service.”
How members of Congress will react to this isn’t yet known, but DeJoy was characteristically dismissive of whatever response they might have. As the Post reported:
“DeJoy in an interview shot back that lawmakers were ‘out of their league’ with their critiques of the agency. “They don’t understand the business. Nobody knows what it takes to compete with FedEx and UPS and drives billions of dollars of cost out of here that’s in the critique business. Even though it’s Congress, they don’t know,’ DeJoy said.”
DeJoy obviously did not see any irony in his comments. He’s barely any more educated about “the business” now than he was in 2020, and even at that he likely knows only what his inner circle of sycophants wants him to know. More worrisome, it’s his perspective that informs the USPS governors in their decision-making on matters like filings with the PRC.
The Postal Service offers no explanation for how actual service performance will improve by deferring the collection of some mail or expanding its more “efficient” ground transportation network.
In its 2021 filing to reduce service standards for First-Class Mail and some Periodicals, the USPS claimed that the standards then in place were “unattainable” and so, without any efforts to improve operational discipline, declared they had to be changed. (We now know that part of the motive for the reduction was to allow greater use of ground transportation, the mode favored by PMG DeJoy.)
Apparently, even with the use of more ground transportation, the relaxed service standards are still unachievable so, rather than finding ways to make his network perform better, DeJoy wants ratepayers to again accept slower service:
“All First-Class Mail and USPS Ground Advantage will continue being delivered within 5 days.”
In effect, mail that may now be receiving better than five-day service could be delivered more slowly and still be within DeJoy’s commitment. Presumably, ratepayers would be consoled because the reduced service is more “efficient.”
Notably as of Postal Quarter III (April-June) 2024, the USPS is meeting none of its service standards for First-Class Mail on a nationwide basis, and less than 15.5% of its district scores for fiscal 2024 to-date have hit the corresponding targets.
Perhaps the most obsequious element of the Postal Service’s announcement was its invocation of environmental considerations. Claiming the elimination of afternoon collection runs “contributes to reduced carbon emissions and truck trips through American neighborhoods” is a transparently self-serving attempt to sanctify a simple reduction in service.
The Process
The Postal Service had a pre-filing webinar on September 5, and filed its formal request for an advisory opinion on October 4.
Overall, the filing reflected what was announced in August and was another thinly veiled promotion for the PMG’s 10-Year Plan, presenting more rosy promises for improvements as more of The Plan’s elements are implemented. As with any promotional material, benefits are defined in the context of the advocate’s perspective, and any negative impacts are explained away. Regardless, the essence of the proposal is clear: reduce service and spin it in a way that makes it sound like a good thing.
Though the PMG has told legislators that changes to the processing network will be deferred until after the election, the filing makes it clear that the service standard changes will be implemented early next year:
“… the Postal Service would not implement the service standard changes within the scope of this Request any sooner than 90 days after the filing of this Request.”
As noted earlier, the Postal Service is requesting an advisory opinion solely to conform with a legal requirement. Though it claims it will consider the opinion, it likely will repeat past practice and do exactly what it plans to do, so ratepayers should expect the planned reductions in service and related changes to take effect the first weekend in January 2025.
Leo Raymond is Owner and Managing Director, Mailers Hub.
This article originally appeared in the November/December, 2024 issue of Mailing Systems Technology.
