Introduction
The Postal Service's changes to First-Class Mail service standards in 2000 and 2001 conflict with the Postal Reorganization Act It is essential for the Commission to publish a report outlining these inconsistencies and to recommend that the Postal Service reevaluate its service standards, potentially reinstating two-day service for certain regions.
The Postal Reorganization Act establishes essential policies that govern postal operations, which the Postal Service must adhere to without exception However, in altering First-Class Mail service standards in 2000 and 2001, the Postal Service breached several legal requirements, leading to a decline in the quality of First-Class Mail service that was contrary to the law.
The changes in service standards implicate several statutory provisions and the policies associated therewith Each policy violation individually provides the Commission with jurisdiction, pursuant to 39 U.S.C § 3662, to hear this complaint.
Adequate Postal Services
The Postal Service is obligated to deliver sufficient postal services as mandated by 39 U.S.C § 3661(a) To meet this obligation, it must prioritize the needs of its customers Any alterations to postal services that overlook customer requirements could lead to a violation of this essential duty.
Efficient Postal Services
The Postal Service is mandated to deliver efficient postal services, which necessitates providing optimal service within specific operational guidelines For instance, if the agency identifies that mail intended for two-day delivery must reach its destination promptly, it must adhere to these standards to ensure customer satisfaction and reliability.
The Postal Service's assignment of a three-day delivery standard for mail due by 6 PM undermines efficiency, as two-day service is feasible within existing operational parameters To comply with statutory efficiency requirements, the Postal Service must offer this expedited service, as mere convenience does not justify service delays Allowing mail to remain idle in a postal facility for an additional day is counterproductive and hinders overall delivery efficiency.
The concept of efficiency in section 3661(a) goes beyond internal factors, impacting the public and society at large For instance, if the Postal Service can offer two-day delivery but opts for three-day service, it forces customers to spend more on premium options like Priority Mail or services from competing delivery companies This choice leads to unnecessary expenditure of societal resources on expensive processing and transportation, when basic First-Class Mail could achieve the same results at a lower cost, ultimately resulting in underutilization of the existing First-Class Mail infrastructure.
The efficiency of the Postal Service takes on greater significance due to its monopoly over First-Class letter mail When the Postal Service decides to lower the quality of First-Class Mail service, customers lack access to comparable, reasonably priced alternatives This situation highlights the unique challenges faced by postal customers, emphasizing the critical nature of service quality in a monopolized environment.
The cost of mailing a one-ounce First-Class letter is significantly lower than that of Priority Mail, with some postal customers, particularly the urban poor and elderly on fixed incomes, unable to afford even the basic upgrades for faster delivery This highlights the serious impact that inefficiencies in postal delivery operations can have on vulnerable populations.
Expeditious Transportation and Delivery of Important Letter Mail
The Postal Service prioritizes the efficient collection, transportation, and delivery of important letter mail when establishing its policies for postal services.
The Postal Service is mandated to prioritize the swift transportation and delivery of important letter mail, which must be the foremost consideration in shaping all postal service policies This directive specifically pertains to the establishment and modification of service standards for First-Class Mail Furthermore, no other factors, regardless of their significance, can overshadow the requirement for prompt delivery of essential correspondence The impact of this statute on the current case will be significant.
Section 101(e) interacts with the efficiency requirement in section 3661(a).
The Postal Service should be capable of offering two-day delivery within its operational guidelines; however, if it is only providing three-day service, it indicates a lack of efficiency This inefficiency suggests that the Postal Service may not prioritize the swift transportation and delivery of essential letter mail.
As I will show in section IV, infra, the Postal Service attempted to justify the changes in service standards by asserting that customers prefer consistency
1 The lowest rate for Priority Mail is $3.85.
The claim that slowing mail delivery can enhance consistency is questionable Even if such a notion were valid, the law mandates that the Postal Service prioritize the swift transportation and delivery of essential letter mail above all else.
“Speed” and “expeditious” are similar concepts; “consistency” and “expeditious” are not By law, speed is more important than consistency.
Transportation to Provide Prompt and Economical Delivery of Mail
When choosing transportation methods, the Postal Service prioritizes the timely and cost-effective delivery of mail Additionally, it ensures a fair distribution of mail business among carriers that offer comparable transportation services.
Section 101(f) parallels section 101(e) but specifically addresses transportation methods The Postal Service may breach section 101(f) if it transitions mail from air to surface transportation, resulting in an additional day added to the service standard for First-Class Mail.
Sections 101(e) and 101(f) are crucial to understanding the case at hand, as the Postal Service's decision to shift First-Class Mail from air to surface transportation aimed at increasing consistency However, this shift undermined the priority of expeditious transportation and timely delivery of important letter mail While "speed" and "promptness" are closely related, "consistency" does not equate to "promptness," highlighting a significant oversight by the Postal Service in prioritizing delivery efficiency.
Failure to Request an Advisory Opinion
Overview of Mail Processing
When customers send outgoing First-Class Mail, it is collected by the local post office and typically transported to a larger processing facility, commonly referred to as a processing and distribution center (P&DC) or processing and distribution facility (P&DF).
The Postal Service discontinued Sunday collection services and made significant changes to collection services without seeking an advisory opinion from the Commission, as noted in Docket Nos C2001-1 and C2003-1.
3 processing centers are known as customer service facilities (CSF’s) 4 For brevity, I will use the term P&DC to refer to P&DC’s, P&DF’s, and CSF’s
The Processing and Distribution Center (P&DC) is responsible for managing the incoming and outgoing mail for all post offices within one or more three-digit ZIP Code areas All local post offices in the P&DC's service area send their outgoing mail to and receive their incoming mail from this central facility.
When mail is sent to a ZIP Code outside the service area of the originating facility, it is typically sorted to a destination sectional center facility (SCF), area distribution center (ADC), or automated area distribution center (AADC) An SCF encompasses one or more three-digit ZIP Codes, with the service area of a processing and distribution center (P&DC) often aligning with that of the SCF; for instance, the Suburban Maryland P&DC serves the 208 and 209 ZIP Codes, which are also part of SCF Suburban MD An ADC may consist of multiple three-digit ZIP Codes and generally includes several SCFs; for example, ADC Southern MD incorporates both SCF Southern MD (206 and 207) and SCF Suburban MD (208 and 209) Meanwhile, an AADC specializes in bar-coded letter mail and typically serves fewer SCFs than an ADC.
In the 1992 reorganization, the Postal Service established two main divisions: processing and distribution, and customer service and sales The customer service and sales division encompasses postal retail and delivery functions, including post offices and postmasters, while processing and distribution are managed at P&DCs and P&DFs, each led by a plant manager Although most outgoing mail is handled at these larger facilities, smaller cities may not have the capacity for a designated P&DC or P&DF, leading them to process outgoing mail at local post offices These smaller operations, known as "customer service facilities," utilize similar mechanized and automated equipment as their larger counterparts, with a postmaster overseeing their functions Examples of such facilities can be found in Eureka, California; Mojave, California; and Fairbanks, Alaska.
5 A limited number of examples exist in which a three-digit ZIP Code area is served by more than one P&DC.
6 Some P&DC’s and P&DF’s do not process their own outgoing mail on Saturdays and some holidays Instead, they send their mail to another P&DC for processing under a consolidation
AADC’s are the same size as SCF’s For example, AADC Suburban MD includes only ZIP Codes 208 and 209 — i.e., SCF Suburban MD
Originating Processing and Distribution Centers (P&DCs) sort outgoing mail destined for areas outside the local region to the Automated Data Center (ADC) level An ADC, typically located in a large city, conducts a primary sortation, organizing mail into three-digit or five-digit ZIP Code categories Depending on whether the P&DC also serves the corresponding ZIP Code area, the mail may either undergo further processing at the same P&DC or be transported to the appropriate P&DC for final processing before reaching its destination post office.
Originating facilities usually use the ADC system to sort flats, small parcels and rolls (SPR’s), and letters that cannot be processed on automation
Originating facilities sort bar-coded letters to the AADC level, typically located within a large city’s P&DC Upon arrival, the AADC conducts a primary sortation, organizing the mail to either a three-digit or five-digit level Depending on whether the P&DC serving as an AADC also covers the destination's three-digit ZIP Code area, the mail may be processed further at that P&DC or transported to the appropriate P&DC for final processing Consequently, a significant portion of the mail arriving at an AADC is intended for post offices within the service area of the AADC-designated P&DC.
When outgoing mail is sent to a destination outside the service area of the originating Processing and Distribution Center (P&DC) but within the same general geographic area, the originating facility typically sorts the mail to the Sectional Center Facility (SCF) level rather than the Area Distribution Center (ADC) or Associate Area Distribution Center (AADC) levels.
Certain originating facilities can allocate specific bins on automated letter sorting machines for mail intended for high-volume recipients, like credit-card companies However, these exceptions do not influence the matters being addressed in this proceeding.
The sorting process at the Processing and Distribution Center (P&DC) is designed to efficiently direct mail to the appropriate destination post office In cases where mail volume is significant, such as with the Northern Virginia P&DC, mail destined for the 20912 area is sorted directly to the SCF Suburban MD instead of the ADC Southern MD This approach is implemented because the Northern Virginia P&DC handles enough mail for SCF Suburban MD to warrant a dedicated sorting process.
By bypassing the Automated Data Processing Center (ADC), the Postal Service minimizes the number of sorting instances for mail Originating facilities conduct Sectional Center Facility (SCF) sortation based on area-level agreements, volume, or service standards For instance, even if the Northern Virginia Processing and Distribution Center (P&DC) lacks enough outgoing mail to warrant a holdout for SCF Suburban Maryland, it may still choose to hold the mail back This is because sorting through an ADC could hinder the ability to meet the overnight delivery standard for First-Class Mail, as there would not be enough time for the mail to be processed through both the Southern Maryland P&DC and the Suburban Maryland P&DC for timely delivery.
The SCF, ADC, and AADC in Phoenix, Arizona, operate together within the same processing facility The P&DC in Phoenix efficiently handles mail designated for SCF Phoenix AZ, ADC Phoenix AZ, and AADC Phoenix AZ, demonstrating that these designations are not mutually exclusive.
Service Standards Model
In 2000 and 2001, the Postal Service introduced a new national model for two-day and three-day service standards, marking a significant departure from previous standards This model was developed and implemented with minimal customer consultation, no public advance notice, and without seeking an advisory opinion from the Commission.
The extensive record in this case provides ample explanation of the operation of the new model for service standards The essential characteristics of the model are:
1 The volume of mail and the needs of customers were irrelevant to the Postal Service’s determination of whether the service standard between a city pair would be two days or three days.
2 The availability of air transportation to achieve a two-day delivery standard was irrelevant to the Postal Service’s determination of whether the service standard between a city pair would be two days or three days.
3 Three-day delivery within the same state and three-day delivery for bordering regions became permissible results, as did nonreciprocal service standards.
4 The Postal Service established national clearance times (CT’s) and critical entry times (CET’s) for two-day mail Under a national CT, no originating P&DC may clear its originating two-day mail after the CT The national CT is 02:30 With a national CET, no ADC may require two-day mail destined to that ADC to arrive prior to the CET The CET is 18:00 The CET is the latest time that mail can be planned to arrive at the destination ADC and still be expected to be processed in time to make delivery on the intended delivery day
5 The Postal Service used a computer program to project a drive time by truck between each origin P&DC and destination ADC If the projected drive time was 12.049 hours or less, the Postal Service considered the destination eligible for a two-day service standard If the drive time was 12.05 hours or more, the Postal Service considered the destination eligible for a three-day service standard
6 When the computer-projected truck drive time is more than 12 hours, the Postal Service continues to impose a three-day service standard even if the mail actually is scheduled to arrive at the destination ADC before the CET of 18:00.
7 The projected drive time by truck dictated the service standards, even if the Postal Service used, or continues to use, air transportation to transport the mail.
8 The Postal Service used a projected drive time by truck from the origin P&DC to the destination ADC, even if the originating P&DC performed SCF-level sortation, thus allowing the mail to bypass sortation at the ADC, and even if the mail from the origin P&DC was transported directly to the destination P&DC without a stop at the destination ADC.
9 In some instances, the destination ADC used for the projection of the 12-hour drive time is not the P&DC that actually processes the mail for that destination ADC.
Mail Volume and Needs of Customers Were Not Considered
The Postal Service recently revised the service standards for First-Class Mail, neglecting customer demand for timely two-day delivery Additionally, customer volume, which could indicate service needs, was overlooked during this change in standards.
In Docket No N89-1, the Postal Service determined that a mail volume of at least 0.5 percent from an origin P&DC to a destination ADC is significant enough to qualify for two-day delivery According to PRC Op N89-1 at pages 8–9, my analysis of the volume data, which was provided under protective conditions in USPS-LR-10, supports this assessment regarding the originating P&DC's mail volume.
26 to a destination ADC continues to be noteworthy starting at about 0.5 percent of the originating P&DC’s volume
USPS-LR-15 outlines origin-parent P&DC to destination-ADC pairs that constitute 0.5 percent or more of the originating volume from specific regions, including Washington, Oregon, California, Idaho, Nevada, and Utah This focused approach aligns with the methodology of Docket No N89-1, ensuring a manageable scope for analysis.
Arizona, New Mexico, Colorado, Montana, Wyoming, and New Jersey DFC-LR-
The article presents a spreadsheet detailing three-digit ZIP Code pairs that have experienced a downgrade in service standards While the author lacks the resources to manually merge data from USPS-LR-15 and DFC-LR-1 to assess the number of downgraded ZIP Code pairs exceeding the 0.5-percent volume threshold, they highlight the significance of these changes Specifically, the service standard adjustments for mail destined for San Francisco, located in ADC Peninsula, CA, are noted, along with the corresponding pairs where the volume surpassed the 0.5-percent threshold.
800 DENVER CO 941 ADC PENINSULA CA Yes
808 COLORADO SPRINGS CO 941 ADC PENINSULA CA Yes
820 CHEYENNE WY 941 ADC PENINSULA CA No 8
836 BOISE ID 941 ADC PENINSULA CA Yes
840 SALT LAKE CITY UT 941 ADC PENINSULA CA Yes
852 PHOENIX AZ 941 ADC PENINSULA CA Yes
856 TUCSON AZ 941 ADC PENINSULA CA Yes
870 ALBUQUERQUE NM 941 ADC PENINSULA CA Yes
890 LAS VEGAS NV 941 ADC PENINSULA CA Yes
894 RENO NV 941 ADC PENINSULA CA No
970 PORTLAND OR 941 ADC PENINSULA CA Yes
980 SEATTLE WA 941 ADC PENINSULA CA Yes
8 The service standard from Cheyenne to San Francisco was downgraded from two days to three days circa 1991.
983 TACOMA WA 941 ADC PENINSULA CA Yes
990 SPOKANE WA 941 ADC PENINSULA CA Yes
ZIP Destination ADC Downgraded From
900 LOS ANGELES CA 941 ADC PENINSULA CA No
902 INGLEWOOD CA 941 ADC PENINSULA CA No
907 LONG BEACH CA 941 ADC PENINSULA CA No
910 PASADENA CA 941 ADC PENINSULA CA No
913 VAN NUYS CA 941 ADC PENINSULA CA No
917 INDUSTRY CA 941 ADC PENINSULA CA No
920 SAN DIEGO CA 941 ADC PENINSULA CA No
923 SAN BERNARDINO CA 941 ADC PENINSULA CA No
926 SANTA ANA CA 941 ADC PENINSULA CA No
932 BAKERSFIELD CA 941 ADC PENINSULA CA No
934 SANTA BARBARA CA 941 ADC PENINSULA CA No
936 FRESNO CA 941 ADC PENINSULA CA No
940 SAN FRANCISCO CA 941 ADC PENINSULA CA No
945 OAKLAND CA 941 ADC PENINSULA CA No
949 NORTH BAY CA 941 ADC PENINSULA CA No
950 SAN JOSE CA 941 ADC PENINSULA CA No
952 STOCKTON CA 941 ADC PENINSULA CA No
956 SACRAMENTO CA 941 ADC PENINSULA CA No
The Postal Service may not be meeting the needs of its customers, particularly in the Western states.
Availability of Air Transportation Was Irrelevant
The Postal Service's decision to downgrade service standards overlooked the availability of air transportation The new model specifically aimed to transition two-day mail to surface transportation and eliminated two-day service standards when projected truck drive times surpassed 12 hours.
Declaration of Charles M Gannon (“Declaration”) at ả 27
The Postal Service overlooked the availability of dependable air transportation between certain city pairs, failing to assess options that, while not entirely reliable, could have offered customers a superior service compared to the three-day delivery by truck.
The Postal Service has raised concerns about the reliability of air transportation for two-day mail deliveries; however, this claim does not universally apply to all city pairs While some routes may experience issues, many major population centers in the western states have ample short-haul flights available Given the light nature of passenger baggage, it is unlikely that weight restrictions significantly hinder airlines from transporting scheduled mail.
The Postal Service overlooked the potential of dedicated air transportation as a viable alternative to ground transport, which could enhance speed while replacing unreliable commercial air options Recently, the Postal Service has successfully utilized dedicated air services from FedEx, which now handles a significant portion of the nation's mail Notably, many service standard changes were enacted during the initial phase of the FedEx contract Given the current doubts surrounding the reliability of air transport for faster service compared to the existing three-day standards, it is imperative for the Postal Service to reconsider implementing two-day delivery between key city pairs, leveraging FedEx for this transportation.
Actual Truck Drive Time Was Irrelevant
The Postal Service's delivery model relied on computer-generated drive time projections, which dictated service standards without considering real-world conditions When the system indicated a drive time of 12.05 hours or more, the service standard was automatically adjusted to three days This approach overlooked instances where actual drive times allowed for earlier mail arrivals before the critical entry time As a result, some customers are receiving three-day mail service despite their mail arriving at the destination ADC in time for two-day delivery based on current operational guidelines.
The Postal Service can effectively offer two-day service for First-Class Mail to customers in ADC Los Angeles, CA, and ADC Sequoia, CA, utilizing surface transportation For instance, a truck transporting mail from Reno to the Los Angeles P&DC arrives at 17:40, which is 20 minutes before the cutoff for two-day delivery This demonstrates that actual transportation conditions should take precedence over computer estimations Since reliable transportation exists for timely delivery between Reno and the Los Angeles area, the service standard should reflect a two-day timeframe Further details are discussed in section III.E.
The Postal Service recently altered the delivery standard for mail between San Francisco and San Diego, increasing the timeframe from two days to three days This decision was made without considering the delivery needs of customers in California's fourth-largest city to its second-largest city Instead, the change was based on a computer program's projection of a 12.1-hour drive time, highlighting a disconnect between service standards and customer expectations.
The Postal Service's delivery standards for mail from Northern California to San Diego are questionable, as the projected drive time from Oakland is 11.7 hours, yet it maintains a two-day delivery standard In reality, mail should arrive within two days, as the truck from San Francisco reaches San Diego at 17:30, just before the critical entry time for deliveries Both mail from San Francisco and the North Bay P&DC are transported together, indicating that the infrastructure for two-day delivery already exists In FY 2002, 73% of the mail was delivered in two days, with an average delivery time of just 2.2 days Despite this efficiency, the Postal Service opts for a three-day delivery service, compelling customers to pay more for expedited options like Priority and Express Mail.
Customers in the San Jose area benefit from a two-day mail service to San Diego, despite the truck arriving at 6:30 PM, which is 30 minutes past the critical entry time The estimated drive time of 11.3 hours suggests that the delayed arrival is likely due to a later departure This situation highlights the disconnect between the service standards and actual delivery times in certain California cities.
While a uniform national model offers convenience and simplicity, it is essential for the Postal Service to recognize the diverse circumstances across our nation The implementation of changes in service standards based on this uniformity has resulted in some absurd outcomes, highlighting the need for a more tailored approach.
In 2002, the Postal Service demonstrated a commitment to customer needs by reinstating two-day mail delivery between Reno and Las Vegas, despite a national model that had reduced service to three days.
Continued Use of Air Transportation Was Irrelevant
The Postal Service occasionally opted for air transportation between cities despite a service standard of two days, highlighting the advantages of surface transportation While projecting a truck drive time of over 12 hours, they later revised the service standard to three days but continued to utilize air transport for mail delivery Notably, this downgrade in service standard persisted, exemplified by the route from Miami to Columbia, SC.
The Failure of the National Model in California
Consistency Versus Speed
To attempt to justify slowing mail delivery from two days to three days, the Postal Service asserts that customers prefer consistency to speed PRC Op
The Postal Service previously presented the argument regarding N89-1 at 33 during the Docket No N89-1 proceeding, which was the last Commission review of proposed changes to First-Class Mail service standards.
The Commission previously found the evidence in Docket No N89-1 unconvincing, and over 12 years later, the Postal Service still promotes this outdated view of customer preferences In today's information-driven era, where instant access and speed are paramount, the Postal Service's reliance on outdated assessments is increasingly irrelevant Moreover, their emphasis on consistency over speed contradicts section 101(e), which mandates that the Postal Service prioritize prompt and economical mail delivery.
The term "consistency" in mail delivery can be defined in two ways The first definition states that delivery is consistent when it adheres to the prescribed service standard timeframe For instance, if the standard delivery time between two cities is three days, then perfect consistency occurs when all mail is delivered within that timeframe Alternatively, if half of the mail arrives in two days and the other half in three days, the delivery performance would still be reported as 100 percent on time by the Postal Service.
Customers generally prefer a mix of faster delivery options, such as receiving 50 percent of their mail in two days and the remaining 50 percent in three days, over a complete delivery in three days Their satisfaction increases significantly if 90 percent of the mail arrives in two days, with only 10 percent taking three days There is no evidence to suggest that customers who expect three-day delivery would be unhappy with occasional two-day deliveries at the same cost Ultimately, these customers prioritize timely delivery according to service standards, indicating that they value consistency in their mail delivery experience.
29 service that does not exceed the number of days prescribed by the service standard However, these customers also prefer to receive their mail as quickly as possible.
Many customers are unaware of the Postal Service's delivery standards, leading to a lack of interest in the percentage of on-time deliveries Instead, their primary concern is the speed of delivery, as they prioritize faster service over the achievement of unknown timeframes Ultimately, for most customers, quicker delivery is preferred.
Mail delivery is considered consistent when it meets a specific standard timeframe, such as three days For optimal consistency, all mail should be delivered exactly within this timeframe, achieving a 100 percent success rate This scenario is preferable to a situation where only 50 percent of the mail arrives in two days and the remaining 50 percent in three days, as the latter represents maximum inconsistency Customers who value this definition of consistency would be dissatisfied with a split delivery schedule but would appreciate a service that ensures all mail arrives within the designated three-day period.
The Postal Service's rationale for extending service standards from two to three days hinges on customer preferences aligning with a specific interpretation of consistency While speed is always a priority under one definition, the Postal Service suggests that customers are willing to sacrifice speed for guaranteed delivery within three days However, the Postal Service has not provided sufficient evidence to support this claim.
14 Of course, service standards also must bear some semblance to reality An overnight service standard between New York and Seattle may not be realistic, no matter how much
2 shown that any customers fitting the second definition exist, let alone that these preferences reflect the wishes of the majority of postal customers.
The Postal Service's External First-Class Measurement System (EXFC) data reveals point-to-point delivery performance across districts that experienced service downgrades from two days to three days This information allows for a thorough evaluation of the impact of the revised service standards An analysis of this data is detailed in the Excel file titled “Appendix2.xls,” included as Appendix 2 to the testimony.
Average Number of Days to Delivery
The average delivery time is a key indicator of mail delivery speed and serves as an essential metric for assessing the Postal Service's adherence to established standards.
101(e)’s requirement that the Postal Service give “highest consideration to the prompt and economical delivery of all mail.”
In an analysis of 255 origin-destination pairs, it was found that delivery times increased for 240 pairs, decreased for 14 pairs, and remained unchanged for one pair Overall, the average delivery time was approximately 0.7 days slower, confirming the anticipated trend of slower mail delivery.
On-Time Percentage
The on-time percentage measures the percentage of mail that is delivered within the number of days prescribed by the service standard.
The Postal Service disclosed data exclusively when a district in specific states, including Washington, Oregon, California, Idaho, Nevada, Utah, Arizona, New Mexico, Colorado, Montana, Wyoming, or Texas, experienced a downgrade.
In my analysis of the delivery speed differences outlined in Appendix 2 (Sheet “Carlson Analysis”), I found that the average difference is 0.7 days It is important to note that this average is not weighted according to the volume of mail exchanged between each pair.
Out of 255 origin-destination pairs, the on-time percentage increased in
In a recent analysis of 189 pairs, the on-time delivery percentage improved in only 123 pairs, while it decreased in 64 pairs and remained unchanged in two This increase in on-time performance, however, came at the cost of delivery speed As many customers are unaware of the specific service standards for mail delivery, the Postal Service may be the only entity celebrating this achievement.
When using First-Class Mail for correspondence between Portland, Oregon, and San Diego, both senders and recipients value delivery speed The on-time delivery rate improved from 85.6% within two days in FY 1999 to 87.4% within three days in FY, highlighting the service's reliability and efficiency.
In 2002, the Postal Service celebrated an increase in the percentage of mail delivered "on time," but customers experienced an average delivery delay of 0.8 days This suggests that while the Postal Service may have viewed these statistics as a success, the actual service quality for customers declined.
Variability in Delivery Time
Consistency in mail delivery is influenced by the frequency of deliveries on a given day, where higher variability in delivery times results in lower consistency For instance, if 90% of mail is delivered within three days and only 10% within two days, the variability is minimal compared to a scenario where 50% is delivered in two days and 50% in three days To quantify this variability, I calculated the absolute difference between the percentages of mail delivered in two and three days, assigning a variability score of 80 for the 90/10 split scenario.
50 percent in two days and 50 percent in three days, I assigned a variability number of 0 A variability number of 0 represents the highest possible variability,
27 whereas a high variability number (up to 100) represents the lowest possible variability.
For each of the 255 pairs, I calculated the variability in delivery between two days and three days in FY 2002 and compared it to the variability in FY 1999.
In a study of 255 pairs, variability was observed to increase in 157 pairs, decrease in 96 pairs, and remain unchanged in 2 pairs Despite the intention to reduce variability by slowing mail delivery, the outcome was contrary, as variability actually increased while delivery times also slowed.
An example will help to make the variability calculation intuitive In FY
In 1999, mail delivery from Seattle to Sacramento was predominantly swift, with 60.4% of mail arriving in two days and 18.9% in three days, resulting in a variability number of 41.5 By FY 2002, delivery times became more balanced, with 39.7% of mail delivered in two days and 39.1% in three days, indicating a shift towards more variability, reflected in a much lower variability number of 0.6 This change signifies that mail delivery times have become less predictable compared to the more consistent delivery observed in 1999.
Consistency
Speed of delivery clearly declined Therefore, the Postal Service must hope that consistency improved.
Consistency in mail delivery improved, with 74 percent of pairs showing an increase in on-time deliveries However, customers prioritize speedy delivery, and unfortunately, speed has decreased in 240 out of 255 pairs As a result, many customers are experiencing slower mail delivery than before, leaving them dissatisfied with the current service.
Many customers are unaware of the Postal Service's service standards for mail delivery, making the reported higher on-time percentage largely self-congratulatory For most customers, this statistic holds little significance as they primarily experience delays in their mail delivery.
The Postal Service's efforts to enhance consistency in delivery times were only partially successful, as they managed to reduce variability for just 96 out of 255 pairs, equating to a mere 37.6 percent This slight improvement in a questionable metric resulted in slower delivery for 240 pairs, with variability increasing in 157 pairs.
In a review of 255 pairs, it was found that in 152 instances, the Postal Service delayed mail delivery and increased variability Notably, in 51 of these pairs, which accounts for one-fifth of the total, the Postal Service not only slowed delivery and heightened variability but also decreased the on-time percentage, indicating a failure across all three metrics.
The recent changes in First-Class Mail service standards have resulted in a significant decline in delivery quality and speed Objective data shows that delivery speed decreased in 240 out of 255 service pairs, with nearly 60% experiencing slower delivery times and increased variability Alarmingly, 20% of these pairs saw a reduction in on-time delivery rates, despite an additional day allocated for mail delivery Although the percentage of mail delivered within the new service standards has increased, this is misleading, as most customers remain unaware of these standards and prioritize speed, which has notably diminished Ultimately, the improvements in on-time delivery have come at the cost of delivery speed, underscoring a failure in service quality.
The disparity between customer expectations and the Postal Service's self-assessment is evident in mail delivery statistics from Seattle to Sacramento In FY 1999, 60.4% of mail was delivered within two days, but this figure dropped to 39.7% by FY 2002, indicating a significant slowdown in delivery times Additionally, the variability in delivery performance surged from 41.5 in FY 1999 to 0.6 in FY 2002, highlighting the inconsistency customers faced Despite these challenges, postal managers reported an improvement in on-time delivery percentages, rising from 74.8% in FY 1999, suggesting a disconnect between management perceptions and customer experiences.
This review highlights the necessity for postal managers to prioritize delivery speed, as mandated by sections 101(e) and 101(f) The Postal Service has indicated that recent changes in service standards reflect a preference for consistency over speed, misleading the public into believing that these adjustments enhance overall service quality.
In reality, the changes have significantly diminished the quality of service
Sections 101(e) and 101(f) are designed to ensure transparency in mail delivery speeds, preventing the Postal Service from using ambiguous language that might disguise slower delivery times These regulations mandate that the Postal Service prioritize the prompt and efficient transportation and delivery of essential letter mail.
The Postal Service violated specific regulations by implementing changes to service standards without proper notification to the public, which further worsened the decline in service quality.
Notice to Public of Service Standards
Nevada Reversal
When I filed this complaint, I specifically noted the change in the service standard from two days to three days for mail between Reno and Las Vegas Complaint at ảả 23 and 28 As a result of this change, customers in Las Vegas received three-day mail service to their state capital in Carson City (SCF Reno NV) In 2002, the Postal Service restored a two-day delivery standard, noting in a newspaper article 20 that two-day mail service was possible between Reno and Las Vegas Quotes in the article from Postal Service spokesman Vic Fenimore are revealing First, Mr Fenimore stated, “The three-day standard from Carson City and Reno to Las Vegas didn’t make that much sense to us We lobbied for an exception and we got it.” Second, according to Mr Fenimore, “It doesn’t make sense to have cities in our own state be three-day delivery zones.” The Commission must ask why three-day mail service within California and other states makes any more sense than three-day service within Nevada The
Commission also must ask which other three-day service standards do not make sense.
The restoration of two-day mail service is no doubt due to negative publicity on the front page of the Reno Gazette-Journal 21
Conclusion and Recommendations
In my testimony, I critique the reliance on a 12-hour computer-projected truck drive time as the basis for First-Class Mail service standards, arguing that the decision to eliminate air transportation breaches sections 101(e) and 101(f) by neglecting the priority of prompt and efficient delivery of important letter mail I provide examples of illogical service standards, such as inconsistent standards between cities, the use of pseudo Automated Delivery Centers (ADCs) in California, and cases where mail arrives at the destination ADC before the critical entry time of 18:00 but is still assigned a three-day delivery standard.
The Commission's public report must highlight the procedural and legal shortcomings in the Postal Service's implementation of new service standards Notably, the Postal Service neglected to seek an advisory opinion from the Commission as required by section 3661(b) before enacting these changes Additionally, the Postal Service breached sections 101(e) and 101(f) by not prioritizing the prompt and efficient transportation and delivery of essential letter mail when establishing postal policies and selecting transportation methods.
The Postal Service is failing to comply with section 3661(b) by not offering efficient postal services, particularly in instances where two-day delivery is feasible This lack of efficiency compels customers to resort to costly and ineffective alternatives for urgent mail delivery Furthermore, it appears that the Postal Service is not adequately addressing the needs of its customers in this regard.
21 “Narrower Delivery Zones Slow Western Mail Delivery”, Reno Gazette-Journal, August 3, 2001.
2 service pursuant to section 3661(a), as the Postal Service changed service standards from two days to three days between city pairs whose volume exceeded the 0.5-percent threshold.
Over the past two years, participants have dedicated significant effort to this proceeding, highlighting the need for accountability from the Postal Service While the Postal Service warrants public criticism for its actions, the primary goal of this proceeding should be to guide and support the Postal Service in addressing its issues Therefore, the Commission should recommend that the Postal Service implement specific corrective measures.
1 Restore two-day delivery service in all instances in which existing transportation that is currently in use permits two-day delivery For example, the truck from San Francisco to San Diego arrives at 17:30,
30 minutes prior to the critical entry time for two-day mail This service standard should be changed to two days;
2 Acknowledge problems with interactions between the pseudo-ADC network in California and the nationwide model for service standards and implement service improvements in California;
3 Determine the needs of customers for two-day mail service between cities to ensure provision of adequate service pursuant to section 3661(a);
4 Restore the use of air transportation to provide two-day service where customer need exists;
5 Restore the use of air transportation between city pairs for which service levels — average days to delivery and on-time delivery percentage — declined after the change in service standards.
6 Evaluate whether the FedEx contract presents an opportunity to use
26 to restore two-day delivery between city pairs that exceed the 0.5- percent threshold.
7 Eliminate nonreciprocal service standards unless a compelling operational need justifies them.
8 Eliminate three-day service standards for mail between adjacent areas and within states.
9 Provide service-standard information on collection-box labels.
10 Provide service-standard maps on the Postal Service Web site.
The rapid evolution of the Internet and electronic communications has cast uncertainty on the Postal Service's future; however, it is clear that slowing delivery service will not reverse the decline in First-Class Mail volume The changes made to service standards in 2000 and 2001 were ill-timed and counterproductive The Postal Reorganization Act prohibits the Postal Service from reducing mail delivery speed under the pretense of enhancing service consistency Fast and efficient First-Class Mail service is crucial for the nation, and customers must oppose any efforts to diminish it Section 3662 allows customers to challenge such attempts, and it is hoped that the Postal Service will heed the recommendations arising from this process.