The Postal Regulatory Commission has told the US Postal Service that it can’t approve and certify the rate adjustments for market-dominant services scheduled to take effect next month. The PRC, in an order issued today, gave the USPS until next Thursday, March 12, to file an amended rate adjustment notice.
The PRC’s order was sharply critical of the USPS filing:
The Postal Service’s initial filing in this proceeding contained many errors and inconsistencies and lacked information required by title 39 and the Commission’s regulations.
The Commission is troubled by the large number of uncommon errors and omissions in the Postal Service’s initial filing, as well as the initial filing’s failure to comply with several statutory and regulatory requirements. A filing that is incomplete and riddled with errors makes it virtually impossible for the public to provide meaningful comments and for the Commission to complete its review within the statutory time period required by 39 U.S.C. § 3622(d)(1)(C) and the Commission’s implementing regulations. Given all of these issues, the Commission may consider appropriate action to help better ensure that future rate case filings are complete, that they comply with all applicable laws and regulations, and that interested persons are provided a timely opportunity to provide meaningful comments.
The PRC gave this summary of its objections to the USPS filing:
This Order discusses the planned price adjustments for the Standard Mail, Periodicals, and Package Services classes. As currently proposed, prices for the Standard Mail, Periodicals, and Package Services classes do not comply with certain statutory and regulatory requirements and are therefore remanded to the Postal Service for further action.
In section II of this Order, the Commission determines that the unequal commercial and nonprofit discounts in the Standard Mail class violate the requirement that disparities between commercial and nonprofit discounts must be justified. The Postal Service did not provide a justification for the proposed unequal nonprofit and commercial dropship discounts. The Commission also finds that the Postal Service failed to adequately justify the proposed disparity for nonprofit and commercial presort discounts. In addition, the Commission finds that several Standard Mail workshare discounts exceed 100 percent and have not been adequately justified in accordance with 39 U.S.C. § 3622(e). In section II, the Commission also finds that the Postal Service must revise the Standard Mail billing determinants in accordance with 39 C.F.R. § 3010.23(d). The Commission also encourages the Postal Service to address other pricing issues when revising Standard Mail rates in order to send more efficient pricing signals.
In section III of this Order, the Commission explains that the Postal Service incorrectly adjusted several billing determinants associated with Flats Sequencing System (FSS) prices for Periodicals bundles, sacks, and pallets and failed to provide the Commission with the data necessary to calculate the actual average price increase for the Periodicals class. As a result, the Commission is unable to make the finding required under 39 U.S.C. § 3622 and 39 C.F.R. § 3010.11 that the proposed Periodicals price adjustment is consistent with applicable law.
In section IV of this Order, the Commission explains that it does not have the information necessary to calculate the average price increase for the Package Services class. As a result, the Commission is unable to make the finding required under 39 U.S.C. § 3622 and 39 C.F.R. § 3010.11 that the proposed Package Services price adjustment is consistent with applicable law.