The USPS' plan targets 3,654 post offices for possible closure. Some 2,500 of them would be replaced by what the Postal Service is calling "village post offices," consisting of a postal clerk in local businesses, libraries or town halls.
However, in its Advisory Opinion on the facilities closure plan, the PRC found that the USPS had, in many instances, failed to consider whether postal customers affected by the closures would have convenient access to alternative post offices. "Alternative access must be a presently available, viable and adequate substitute for existing access," wrote the PRC.
Noting that the goal of the USPS' post office closure plan had been to reduce operating costs by "optimizing" the postal network, the PRC found that the USPS lacked sufficient data to accurately determine which if any closures would actually result in significant cost savings.
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"The Commission was unanimous in expressing its concern that the Postal Service's plan did not and could not, because of lack of data and analysis, determine the facilities most likely to serve the greatest number, reduce the greatest costs, or enhance the potential for growth or stability in the system," wrote PRC chairman Ruth Goldway in a press release.
USPS Picking on Small Town America?
If you live in a small town and feel like the Postal Service is out to get you and your post office, you have two powerful protectors: the PRC and federal law.
According to PRC chairman Goldway, the PRC has received more than 160 formal appeals to individual post office closures showing, "how concerned local communities have been with losing access," she said. "With real, practical alternatives available, these communities would be far less likely to feel the loss of a neighborhood post office and would join with the Postal Service in the move to efficient alternatives."
In its Advisory Opinion, the PRC points out that federal law requires the Postal Service to provide a maximum degree of effective and regular postal services in rural areas, communities, and small towns where post offices are not financially self-sustaining. In addition the USPS is prohibited by federal law from closing small post offices simply because they operate at a loss. "No small post office shall be closed solely for operating at a deficit, it being the specific intent of the Congress that effective postal services be insured to residents of both urban and rural communities." -- 39 U.S.C. § 101(b).
Effect of the PRC Opinion
Federal law requires the USPS to submit all plans to discontinue postal services or close postal facilities to the PRC. While the Advisory Opinions issued by the PRC are not legally binding, they can and do sway Congress, which has the ultimate authority to approve or reject the post office closure plan. Lawmakers representing states with large rural populations have long been critical of post office closure plans they fear will leave many of their constituents without adequate mail service.
Even before the PRC issued its critical opinion, the USPS had bowed to pressure from Congress by agreeing to put off any actual post office closures pending final consideration of the Postal
Reform Act of 2011 expected in the spring of 2012.
Part of the Postal Reform Act would take Congress out of the closure approval loop by creating an independent Commission on Postal Reorganization assigned to close unneeded or underutilized post offices and mail processing facilities.
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In March 2011, the PRC in another Advisory Opinion declared that the USPS' had failed to adequately evaluate the impact of its plan to end Saturday mail delivery on rural Americans. The PRC found the alternatives to Saturday mail delivery offered by the USPS to be "inadequate" for many rural postal customers.
The Postal Reform Act would also allow the USPS to move forward with its plan to reduce mail delivery service to 5 days a week, probably by eliminating Saturday delivery.