August 08, 2011

West Virginia Congressional Delegation Warns Postmaster General on Impact of Proposed Consolidations on West Virginia

BECKLEY, W.Va. – U.S. Representative Nick Rahall (D-W.Va.) Monday announced that all five Members of West Virginia’s Congressional Delegation have joined together to voice concerns to the Postmaster General about the potential closure of 150 post offices across the State and urged a careful examination of the proposal that takes into account the broad impact on the community and mail delivery services in addition to the cost savings to the Postal Service.  

“Forcing rural communities in our State to make do with less is contrary to the spirit of the law, as well as the practical reality that rural areas depend more heavily on the Postal Service.  In many cases, their local post office is the only convenient and realistic option for safely retrieving and sending mail -- whether a monthly benefit check, vital prescription medication, or a routine business transaction.  It's inconvenient, to say the least, to have to drive to the next town, 20 miles into the hills, just to pick up your daily mail,” the Members wrote in a letter to the U.S. Postmaster General.

In the letter initiated by Rahall, and joined in by Senators Jay Rockefeller and Joe Manchin (both D-W.Va.) and Representatives Shelley Moore Capito and David McKinley (both R-W.Va.), the lawmakers expressed their deep concerns about the impact such postal disruption would have on rural communities.  

“The potential closures would affect roughly one in five postal facilities in our State, and follow an aggressive schedule of Area Mail Processing studies to consolidate distribution and processing operations.  These additional potential closures threaten to further disrupt postal services in our State, inconveniencing and burdening businesses and residents alike,” the lawmakers wrote.

The 150 retail post offices in the State being studied for closure are among the roughly 3,700 nationwide that the Postal Service recently announced are being considered for discontinuance studies, the first step in the closure process for a postal facility.    

There are already 31 discontinuance studies underway in the USPS Appalachia District, which covers most of West Virginia and southwest Virginia, as well as three studies to consolidate mail processing operations in Martinsburg, Wheeling, and Bluefield.  

“These postal facilities act as community centers and gathering spots and can be the heart of communities.   We find it deeply ironic that when public meetings are held about closing postal facilities in some West Virginia communities, there is such a big turnout that the only place available to host such meetings is the local post office,” the Delegation wrote.

The Delegation also wrote to the Chairman of the Postal Regulatory Commission, which exercises regulatory oversight of the Postal Service, noting the statutory protections for rural post offices and local frustrations with the public comment process.         

“We must ensure the opportunity for public comment and participation during this closure process.  Residents in the communities we represent too often feel the public meetings and comment periods organized by the Postal Service are perfunctory, and that decisions have already been made before community input is considered,” the Members wrote.  “We urge you to ensure that the Postal Service thoroughly considers how to protect vulnerable populations from the negative impacts of a post office closure and that its policies and procedures comport with the law.” 

In their letter, the West Virginia lawmakers called for comprehensive cost-benefit analyses, incorporating not just the foot traffic and financial balance sheets for each post office, but also the impact of a closure on the community, on postal workers, and on mail delivery services.  

Federal law requires the Postal Service to "provide a maximum degree of effective and regular postal services to rural areas, communities, and small towns where post offices are not self-sustaining," declaring that "no small post office shall be closed solely for operating at a deficit.”

Copies of the delegation’s letters are attached; full texts of the letters are below:

August 8, 2011

The Honorable Patrick R. Donahoe
Postmaster General
United States Postal Service
475 L'Enfant Plaza, Southwest
Washington, DC 20260-0010 

Dear Postmaster General Donahoe:

We are very concerned about the United States Postal Service’s (USPS) announcement to study 150 post offices, branches, and stations for closure in the State of West Virginia.  

The potential closures would affect roughly one in five postal facilities in our State, and follow an aggressive schedule of Area Mail Processing studies to consolidate distribution and processing operations.  These additional potential closures threaten to further disrupt postal services in our State, inconveniencing and burdening businesses and residents alike.

In the Postal Service's statutory charter, the Congress was explicit in prohibiting the closure of a postal facility solely for fiscal reasons.  The law recognizes that some postal facilities in profitable markets would subsidize postal services in less profitable markets.  The Congress required the Postal Service to "provide a maximum degree of effective and regular postal services to rural areas and towns where post offices are not self-sustaining," declaring that "no small post office shall be closed solely for operating at a deficit.”  

The law also sought to ensure that there would be "postal facilities of such character and in such locations, that postal patrons throughout the Nation will, consistent with reasonable economies of postal operations, have ready access to essential postal services."  

And, yet, the financial condition of the Postal Service is the primary catalyst for these closure studies, targeting smaller, rural post offices where foot traffic and revenues are, not surprisingly, less than their more profitable counterparts.      

Forcing rural communities in our State to make do with less is contrary to the spirit of the law and to the practical reality that rural areas depend more heavily on the Postal Service because they often lack alternative means like the Internet for conducting postal businesses.  In many cases, their local post office is the only convenient and realistic option for safely retrieving and sending mail -- whether a monthly benefit check, vital prescription medication, or a routine business transaction.  Mail theft is also a problem in rural areas, requiring residents to have mail boxes at the local post office.  It's inconvenient, to say the least, to have to drive to the next town, 20 miles into the hills, just to pick up your daily mail.

In addition, these postal facilities act as community centers and gathering spots and can be the heart of communities.   We find it deeply ironic that when public meetings are held about closing postal facilities in some West Virginia communities, there is such a big turnout that the only place available to host such meetings is the local post office.      

We urge you to make every effort to raise public awareness about the opportunities for public comment on affected post offices, and to listen closely to concerns.  The Postal Service is required to consider the impact on the community, on mail delivery services, and on postal workers as well as the financial condition of a post office in considering a discontinuance study.  We ask that you provide a timeline that explains when the closure process may begin and end in West Virginia, as well as whether the process will occur all at once or in phases. 

In addition, for the purposes of these studies, we would appreciate your explaining how the Postal Service defines "maximum degree of effective and regular postal service," as well as "prompt, reliable, and efficient services to all areas" under the law.  As of right now, our belief is that the potential closure of 150 postal facilities is grossly inconsistent with the straight forward mandates to ensure effective and regular postal services in rural areas. 

Thank you in advance for thoughtful and timely response.

Sincerely,

Nick Rahall, II                                                            
Shelley Moore Capito                                                 
David McKinley 
Joe Manchin
John D. Rockefeller IV          

August 8, 2011

The Honorable Ruth Y. Goldway
Chairman
Postal Regulatory Commission
901 New York Avenue, NW, Suite 200
Washington, DC 20265 

Dear Chairman Goldway:

As the Postal Regulatory Commission (PRC) solicits public comments for its advisory opinion on the U.S. Postal Service’s (USPS) plan to consider closing nearly 3,700 post offices nationwide, we would appreciate your consideration of our concerns on behalf of the residents and businesses in West Virginia that would be impacted by the potential closure of 150 post offices in our State.

The potential closures would affect roughly one in five postal facilities in West Virginia and follow an aggressive schedule of Area Mail Processing studies to consolidate distribution and processing operations in the State.  These additional potential closures threaten to further disrupt postal services in our State, inconveniencing and burdening businesses and residents alike. 

The law recognizes that postal facilities in profitable markets would subsidize postal services in less profitable markets.  The Congress required the Postal Service to "provide a maximum degree of effective and regular postal services to rural areas, communities and small towns where post offices are not self-sustaining," declaring that "no small post office shall be closed solely for operating at a deficit.”  

And, yet, the financial condition of the Postal Service is the primary catalyst for these closure studies, targeting smaller, rural post offices where foot traffic and revenues are, not surprisingly, less than their more profitable counterparts.  The Postal Service’s filing with your Commission lists 2,825 post offices that earn less than $27,500 per year, which tend to be located in rural areas. 

Forcing rural communities in our State to make do with less is contrary to the spirit of the law.  The practical reality is that rural areas depend on the Postal Service because they often lack access to alternative means like the Internet for conducting postal businesses.  

In many cases, closing the local post office in rural areas creates an undue burden on seniors and lower-income working families. These customers rely on the post office as the only convenient and realistic option for purchasing money orders, and safely retrieving and sending mail -- whether a monthly benefit check, vital prescription medication, or a parcel pickup or mailing for a routine business transaction.  Mail theft also is a problem in rural areas, requiring residents to have mail boxes at the local post office.  It's inconvenient, to say the least, to have to drive to the next town, 20 miles into the hills, just to pick up your daily mail.

In addition, these postal facilities act as community centers and gathering spots and can be the heart of communities.   We find it deeply ironic that when public meetings are held about closing postal facilities in some West Virginia communities, there is such a big turnout that the only place available to host such meetings is the local post office.

Village Post Offices may work in some rural communities, as the Postal Service has proposed, but not in all.  The Postal Service must be mindful in conducting its discontinuance studies that Village Post Offices and other contract postal units cannot provide a full range of services like a traditional post office.  Such contract postal units will inevitably lead to degradation in postal services for communities. 

We must ensure the opportunity for public comment and participation during this closure process.  Residents in the communities we represent too often feel the public meetings and comment periods organized by the Postal Service are perfunctory, and that decisions have already been made before community input is considered. Public input is especially important in considering whether alternative access channels, such as a Village Post Offices, are really feasible and practical for some communities.  The Postal Service should be urged to not rely too heavily in assuming one alternative access channel will work for everyone.

We must also ensure comprehensive cost-benefit analysis in considering a postal closure, incorporating not just the foot traffic and financial balance sheets for each post office, but also the impact of a closure on the community, on postal workers, and on mail delivery services.  Residents should know the potential cost savings within a state when postal facilities are closed, and when that savings is expected to be realized.  They should be able to comment on whether the potential savings warrants the disruption and inconvenience to the community.   Certainly, rural post offices should not be closed in order to finance post offices in more profitable areas. 

We urge you to ensure that the Postal Service thoroughly considers how to protect vulnerable populations from the negative impacts of a post office closure and that its policies and procedures comport with the law.

Sincerely,

Nick Rahall, II                                                            
Shelley Moore Capito                                                 
David McKinley 
Joe Manchin
John D. Rockefeller IV