PRC Proposes New USPS Reporting on Flats

March 5, 2019

The Alliance on February 14 provided comments to the Postal Regulatory Commission on the need for stronger oversight of the long-term downtrend in USPS flats productivity.  Partnering with MPA-The Association of Magazine Media, we voiced the concerns of the many nonprofits that mail magazines and other Periodicals.  We urged the PRC to move beyond more data on the problem to actual enforcement of cost control.

A sampling of our comments:

• The information regarding flat-shaped mail that is presented in this year’s Annual Compliance Review confirms and intensifies the conclusions we have drawn repeatedly from ACRs of years’ past: Periodicals’ cost-coverage shortcomings stem from the Postal Service’s continuously deteriorating efficiency in processing flats and a confounding inability (or unwillingness) to reduce flats costs despite repeated concerns raised by the Commission and affected mailers.
• The USPS must be held accountable for its long-standing failure to address flats costs and must implement effective cost-cutting measures to bring the efficiency of its flats operations back to pre-Flat Sequencing System (FSS) levels. Further, with the continuing deterioration in flats productivity, it is more important than ever that the PRC require the Postal Service to set workshare passthroughs at or near 100 percent to promote lowest combined costs.

On March 1, the PRC issued a notice of proposed rulemaking with specific USPS flats data reporting requirements.  It is inviting comments by the end of March.

A summary of the PRC proposal:

The Commission agrees that developing a performance plan is necessary to improve cost and service performance issues. Prior to developing such a plan, the Commission must gather information about cost and service performance issues and analyze this information over time to identify trends and measurable goals. Based on the information received in prior ACD proceedings and in this proceeding, the Commission proposes specific reporting requirements to facilitate measuring and tracking cost and service performance issues related to flats. The Postal Service will be required to annually file data at the national and facility level (when specified). These reporting requirements are designed to provide sufficient information to improve transparency into the cost and service performance issues associated with flats. In addition, the proposed requirements will increase the accountability of the Postal Service related to operational initiatives related to flats.

The Alliance plans to file comments with MPA in support of stronger data reporting on flats by USPS.  We will continue to urge that the PRC focus on the long-term trend of continuously declining USPS flats productivity, and that the regulator take action to reverse the trend significantly, before allowing above-inflation rate increases.  In other words, do not make customers pay for USPS inefficiency.