Thursday, October 29, 2009

Postal Service Relies on Incomplete Data, Discriminates Against Underserved Communities

APWU Testimony on Station Closings

APWU Web News Article #135-09, Oct. 29, 2009

An analysis of the postal stations and branches being considered for closure shows that the USPS study process “discriminates against communities with high percentages of low-income, minority and transit-dependent residents,” according to recent testimony submitted to the Postal Regulatory Commission (PRC) by the APWU. In addition, the union asserts, the Postal Service uses incomplete data to support its conclusions.

In testimony submitted to the PRC on Oct. 21, economist Anita B. Morrison and APWU steward Michael T. Barrett enumerated significant deficiencies in the Postal Service’s methodology in selecting stations for closure. The national union has intervened in proceedings before the commission, which is preparing to issue “an advisory opinion” on the station-and-branch initiative.

Morrison’s testimony [PRC 10-21-09 Morrison - PDF] provided statistical evidence that the USPS plans would most severely impact communities where the postal services are needed the most — low-income neighborhoods where computer use is relatively low and where residents are especially dependent on public transportation.

More than three out of four stations — 287 of 371, or 78 percent — under consideration for closure have median household incomes below the national average, Morrison testified, and 41 percent have incomes below $20,000. These households are most likely to be affected by the inconvenience and cost of accessing more distant post offices, she said.

Pointing out that post offices in more well-to-do areas were less likely to be considered for closure, Morrison wrote: “This suggests that the process favors postal stations in more affluent neighborhoods.”

She also noted that “closure of a branch post office can have significant negative impacts on local business districts,” particularly in walkable neighborhoods that are critical to reducing America’s dependence on cars.

Morrison criticized the Postal Service’s procedures for gathering public input. “USPS currently gathers information from interested stakeholders without a specified forum for sharing initial feedback with the public,” she wrote. “In addition, the feedback represents a reactive rather than pro-active approach. Expanding the methods of soliciting feedback and adding other affordable feedback options could greatly improve this process.”

Incomplete Data

Testimony by Michael Barrett, of the Buffalo (NY) Local, [PRC 10-21-09 Barrett - PDF] asserts that the USPS uses incomplete data to support its conclusions, and overlooks information that would offer a more accurate indication of cost savings and the impact of closures on nearby stations and branches.

“The current analysis of cost savings performed by the Postal Service is cursory at best,” Barrett said. Many transactions currently performed at stations slated for closure will migrate to other postal facilities, he said, and so will the costs associated with them.

In addition, he noted, “The Postal Service calculates the total salary and fringe benefits costs associated with employees of stations or branches under study and considers this entire total to be savings to the Postal Service.” These costs will continue at other facilities, he said, and must be considered in USPS evaluations.

The data necessary to more accurately measure these costs is readily available to the USPS using current resources, Barrett testified.

USPS studies fail to accurately analyze the ability of nearby facilities to accommodate the migrating business, he said. “Where a neighboring station or branch does not have sufficient space for a separate box section dedicated to the closed station or branch,” Barrett’s testimony noted, “the closing will initially turn the entire volume of arriving box mail into Undeliverable As Addressed (UAA) mail. ... It is obvious from the UAA costs reported [by the USPS] that these additional processing costs are not insignificant.”

This should be accounted for in each USPS discontinuance study,” the APWU steward testified. “Yet despite the ready availability of the information needed to determine the additional processing costs,” the Postal Service does not appear to consider them at all.

Commenting on the testimony, Assistant Clerk Craft Director Mike Morris said, “Barrett and Morrison made important points about the consequences of USPS plans to close hundreds of stations and branches. We should share these conclusions with elected officials and other community leaders.”

Morris and APWU Vice President Cliff Guffey are coordinating the APWU’s response to the Postal Service’s Stations and Branches Initiative. A “tool kit” [PDF] to assist locals fighting the closure of stations and branches is available in the “Members Only” pages at

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