PRC Dismisses Complaint on Changes in San Francisco Retail Hours, Chairman Goldway writes dissenting opinion

prc_3Before Commissioners: Ruth Y. Goldway, Chairman;
Mark Acton, Vice Chairman; and Robert G. Taub

Complaint on Changes in Retail Hours Docket No. C2014-1

1. The Postal Service’s Motion to Dismiss is granted.
2. The Complaint Erratum filed by Douglas F. Carlson on May 8, 2014 is dismissed.
By the Commission.
Shoshana M. Grove Secretary
Chairman Goldway, Dissenting:

PRC Chairman Ruth Y. Goldway

PRC Chairman Ruth Y. Goldway

The Commission should not dismiss this Complaint Erratum but instead should evaluate it through the 39 U.S.C. § 3662 complaint process to determine whether it identifies a nationwide or substantially nationwide change in service.

In my opinion, the Complaint Erratum raises instructive questions about the procedures the Postal Service is using to change operating hours throughout its retail network, not just in San Francisco.

The Postal Service has eliminated from its operations manual a requirement for customer feedback to determine if a change in service hours should be considered. I am concerned that diminishing this opportunity for customer input could result in inadequate or inefficient service to Postal Service customers. It is also troubling that according to the Complaint Erratum, the Postal Service does not appear to be following its own procedures regarding posting notice of changes 30 days in advance.

Removing an opportunity for local customer input is shortsighted. The language in the operations manual does not set forth any requirements and does not prescribe any specific requirement or guidance for obtaining customer feedback. Customers can not be assured that their views will be elicited when service changes are considered. I urge the Postal Service to institute more definitive procedures for obtaining customer input before determining that changes in hours are reasonable.

It is noteworthy that the customer surveys, meetings, and input the Commission called for in its Advisory Opinion on the Postal Service’s POStPlan (reviewing and adjusting post office retail service hours) have improved acceptance of that Plan in affected communities.

Another concern raised by the elimination of this language is what data postmasters will use to determine whether there has been a change in customer needs. Although the language in question did not require the use of quantitative data in making these decisions, it did at least suggest that Window Operations Survey reports be used as a basis for the determination.

The Complaint Erratum states that hours will be decreased in twenty-five stations and branches in the San Francisco district. This may signal a broader pattern that may have regional or national consequences. We do not know. The Commission does not have sufficient information as yet to make a fact-based determination.

A key function of the Commission is to ensure the transparency and accountability of the Postal Service. The types of information needed to assess whether there has been a nationwide change in service are in the hands of the Postal Service. An individual or small business should not be expected to undertake the significant burden of procuring this information alone. Therefore, it is incumbent on the Postal Service to be forthcoming with this information, and the Commission to obtain such information before dismissing a complaint.

More information might have presented a clearer picture of the issues raised by the complaint, such as: 1) how the language that was eliminated had been incorporated into decisions on retail hour changes and the actual impact of eliminating that language; 2) the number of retail facilities nationwide where decreases in retail hours have been implemented; and, 3) how often the policy of providing 30 day notice is not followed.

Click Here for PRC Order #2136

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