The APWU filed a complaint with the Postal Regulatory Commission on June 12 seeking to stop the Postal Service from implementing Phase 1 of its consolidation plan, which calls for the USPS to consolidate 48 mail processing plants this summer and to lower service standards effective July 1. The USPS cannot implement the changes without first obtaining an advisory opinion from the commission, the complaint says.
Federal law requires the USPS to seek an advisory opinion from the PRC whenever it plans to make nationwide changes in service, but the commission doesn’t expect to issue a formal opinion on the plan until close to Labor Day.
Noting that “the Postal Service case is extremely lengthy, technical and complex,” the APWU complaint [PDF] alleges that the USPS failed to submit the plan to the PRC far enough in advance of the July 1 implementation date.
The complaint points out that the Postal Service has made numerous revisions to its plan, as well as to the testimony of USPS witnesses in support of the consolidation plan and projections for savings.
The USPS announced a modified, two-stage version of its network consolidation plan on May 17, and filed a formal notice of the revised plan on May 25. In addition to the consolidation of 48 Processing and Distribution Centers by the end of August, Phase 1 calls for another 92 plants to be consolidated or closed in 2013. Phase 2 calls for an additional 89 plants to be consolidated by the end of 2014, for a total of 229 – half of the nation’s mail processing centers. The PRC was considering an earlier version of the plan when the USPS announced a revised timetable, along with changes to plans for service standards reductions and revised projections for savings.
Under the modified plan, overnight delivery of first-class mail will be limited to “intra-SCF” [sectional center facility] mail beginning July 1. Periodical mail will also be slowed. Beginning in 2014, overnight delivery of first-class mail would be available only to large presort mailers and periodical mail will be further slowed.
The complaint also contends that the service cuts scheduled for July 1 are unnecessary, unsupported by the evidence, and in violation of federal law that establishes criteria for service.
At a June 7 hearing on the modified plan, the APWU asserted that the Postal Service justify the plan by relying on testimony and evidence presented to the commission about the earlier version of the plan.
“Given the complete lack of analysis and evidence, there appears to be no justification for management’s claims of an estimated $1.2 billion in savings from Phase 1 of the plan,” APWU counsel told the panel.
“The Postal Service is attempting to make an end-run around the requirement to seek an opinion from the PRC before implementing a nationwide change in service,” APWU President Cliff Guffey said. “This is a disservice to the American people, who rely on the USPS to deliver mail, medicine and packages in a timely manner.”
The commission is currently considering four separate USPS proposals to cut service, including its proposal to downgrade service standards and a proposal to reduce the hours at approximately half of the nation’s post offices.
In May, in response to stiff opposition to a plan the USPS presented in October 2011, the Postal Service announced it would implement the consolidations over a two-year period. The USPS projects savings of $1.2 billion per year during Phase 1 and $2.1 billion after Phase 2, but the Postal Service cannot support the projected savings, the union noted at the hearing.