by Save The Post Office , published March 26, 2015
The Postal Service has made a final determination to close the post office in Yantic, Connecticut, a village in Norwich. Deberey Hinchey, the mayor of Norwich, and Kevin Ryan, a state representative, have filed an appeal on the closing to the Postal Regulatory Commission.
It’s the first appeal filed on a post office closing since July 2013. (Another appeal has recently been filed for a contract post office in Careywood, Idaho.) It will be interesting to see how the PRC, under the new leadership of Acting Chairman Robert Taub, handles the appeal.
Appeals on post office closings are rarely successful. Between April 2012 and November 2013, the PRC ruled on over 200 appeals. Only 17 of them resulted in an order remanding the closing decision back to the Postal Service for further consideration. (The PRC can only remand; it cannot completely overturn a decision to close.)
During that period, most of the PRC orders affirming the Postal Service’s decision were actually decided by a tie vote. Commissioner Tony Hammond was waiting for Senate confirmation, so there were only four commissioners. Mark Acton and Robert Taub consistently voted to affirm the decision to close, and then-Chairman Ruth Goldway and then-Vice-Chairman Nanci Langley consistently voted to remand. (Goldway and Langley, by the way, are Democrats; the other three commissioners are Republicans.)
As we observed in a post in April 2012 reviewing these appeals, it’s always long odds getting a remand out of the PRC — like about one out of twelve. The Yantic case has even less chance of success. The post office has already been closed for over three years.
Suspended for undisclosed reasons
A post office was established in Yantic in 1852. The Post Office Department started leasing a building for the post office on Yantic Road in 1955, the year after it was built, and the Postal Service took it over in 1970. It’s been there since then.
On Monday, Feb. 6, 2012, the Postal Service suddenly suspended the Yantic post office, with no notice to customers, after postal officials noted “deficiencies in safety and security.” A news report on the suspension says, “The Yantic post office will be closed indefinitely for security and safety reasons based on an undisclosed issue that arose last week.”
The post office was open on Monday, with no signs of a problem, and then it was closed on Tuesday. The “undisclosed issue” that led to the suspension was never revealed. Customers, including 223 box holders, were directed to the post office in Bozrah, a couple of miles away, and the Yantic postmaster was transferred to Bozrah to help with the extra business.
On Feb. 16, 2012, a postal inspector filed a report about the security review he had conduced at the post office on Feb. 13, a week after the post office had been suspended.
The report notes several issues: (1) a wood door on the side of the building going into the workroom should be replaced with a solid wood or hollow metal door, with a deadbolt lock; (2) a security light in the rear of the building did not seem to be working; and (3) the floor under the safe was buckling.
The report notes that a number of other safety issues should also be addressed, but it does not identify them. The inspector’s report concludes with, “All issues can be remedied at a minimal cost.”
Included in the Administrative Record filed by the Postal Service with the PRC are several photographs of the building that illustrate some of the problems. They show lead paint on a window sash, exposed wiring, duct tape covering a sharp edge on a doorjamb, an open ash door on the chimney, and so on. They have the look of crime scene photos. All that’s missing is the chalk mark outlining where the body was.
Months after the post office was suspended, the community still didn’t understand why it had closed or when it would reopen. Looking back, the problems don’t seem all that bad, at least not for a building that was almost 60 years old (or older).
So why did the post office close? What was the “undisclosed issue” that prompted the suspension and inspector’s review? Were the problems really so dangerous? Was the cost of repairs so expensive? Was there an issue getting the owner of the building to do something about the problems? Did the Postal Service look for another location where it might move the post office? Or was the Postal Service simply looking to close another post office to save some money, a fairly common thing at the time?
From suspension to discontinuance
It was impossible getting answers to these questions out of the Postal Service. In August 2012 Congressman Joe Courtney wrote a letter to Postmaster Donahoe to express his continued concern about the lack of information. A month later, a USPS representative finally responded to the Congressman. His letter reviews the safety hazards and notes that Yantic customers have been provided retail and box service at Bozrah, 1.2 miles away (that’s as the crow flies; it’s actually over 2 miles by car).
In September 2012, the Postal Service began a discontinuance procedure to close Yantic permanently. A proposal to close was posted on Oct, 6, 2012 (presumably at the Bozrah post office), and 282 surveys were distributed to customers. Of the 56 responses, 33 were unfavorable, 22 expressed no explicit opinion, and one was favorable.
A public meeting was scheduled for Nov. 7, 2012, but Superstorm Sandy caused the meeting to be delayed a week, which may have affected attendance.
About 60 people showed up at the meeting on Nov. 14, 2012, and according to a news report, they were very frustrated and wanted answers. Why had a profitable post office been closed, and why had nothing been done to reopen it for nine months?
The USPS representative at the meeting suggested alternatives like a Village Post Office or a cluster box unit — the types of alternatives that were typically offered at the time, when hundreds of post offices were being closed.
The Yantic post office continued in its suspended state. In May of 2013, the Postal Service issued a revised notice of suspension. The new version provides details about the building conditions, and it also states that the landlord of the building was decease and the building was tied up in probate.
In May 2013, the proposal to close was forwarded to the district manager for review, and in June it was logged in at Headquarters.
On Aug. 2, 2013, a revised proposal to close was posted (presumably at the Bozrah or Norwich post office, since Yantic was closed), and another comment period was opened, but no one submitted comments. It’s not clear if anyone even knew about this second comment period.
In October 2013 Headquarters acknowledged that it had received the official record. Not much seems to have happened for the next fifteen months.
The Final Determination to close
Then on Jan. 26, 2015, the Postal Service made a final determination to close the Yantic post office. A letter instructs the postmaster to post the Final Determination Notice, which invites appeals to the PRC.
Of course, by then the office had been closed for over two years so the Final Determination was posted at the Norwich post office. Perhaps no one even saw it there. The appeal to the PRC was filed not by a regular Yantic customer but by the mayor, who may have been notified by a separate letter (although there’s no such letter in the record).
In its explanation for why the post office is being closed, the Final Determination cites the “deficiencies in safety and security” that had originally caused the post office to be suspended, and it also notes the decline in revenues from FY 2010 through 2014 (even though the post office had been closed half this time).
The Final Determination reviews the comments the Postal Service had received from customers. Concerns included the limited hours at the Bozrah post office, the fact that they weren’t given the option of home delivery, the inconvenience of having to travel the extra distance to Bozrah, and so on.
The Postal Service’s response to almost every concern was the same: Customers would be provided with rural delivery to a cluster box unit or gang rural boxes. The Postal Service also indicated that the hours at Bozrah would be changed to mirror those in Yantic before it closed.
The Final Determination notes that the closure would have several advantages, including the ability to do postal business with the letter carrier, thus alleviating the need to go to the post office, which “saves time and energy.”
The advantages also noted the savings for the Postal Service, which “contributes to stable postage rates.” That’s actually what closing post offices is all about — it helps keep rates down for the big mailers.
The fabric of the Village
The Final Determination also lists several disadvantages of closing the post office. Number one is “the loss of a retail outlet.” That’s one way of putting in.
In their appeal letter, Mayor Hinchey and Representative Ryan put it another way. They write that the post office “was a dominant and integral part of the fabric of the Yantic Village.” Whenever a village post office like this closes, it tears at the fabric of the community. It’s not just a “retail outlet.”
Another disadvantage of the closure is having to meet the carrier at the mailbox. That can be a big problem if it means waiting indefinitely at a cluster box not even near one’s home, but the Final Determination simply says, “It is not necessary to be present to conduct most Postal Service transactions.”
Under “other factors,” the Final Determination notes that there are several other post offices in the area, as well as many “alternate access options” where one can buy stamps. The Postal Service also tried unsuccessfully to set up a Village Post Office.
The “summary” also notes that “there were no suitable alternate quarters available,” but there’s nothing else in the record about efforts to relocate the post office to a new building.
Aside from the inadequate responses to customer concerns and the weak logic of the “advantages” and “disadvantages,” there are several substantive issues with this discontinuance that may come up in the PRC’s consideration of the appeal. Here are some of them.
Where are the savings?
The Postal Service’s analysis of economic savings changed during the process. In the October 2012 proposal, the Postal Service said it would save $1,348,764 over ten years. That number was subsequently revised to $757,855 because the cost of labor was re-evaluated. Here’s how the final calculation breaks down:
It may be noted that the numbers don’t add up (the sum here should be $963,977), and it’s not clear why.
In any case, the key issue here is that the Yantic post office did not cost a lot to run. It had just one full-time employee, and the rent and utilities didn’t add up to much, less than $60,000 over ten years. Nearly all of the savings were associated with the salary of the postmaster who ran the office.
In the “effect on employees” section of the proposal, however, the Postal Service said the postmaster would be moved to another facility. Apparently that’s what happened. The postmaster at Yantic beginning in 2009 was Hazel Alford, and on APP.com she is still listed as the Yantic postmaster. Presumably she’s working at another facility.
The economic analysis derives nearly all the cost savings from the elimination of the postmaster, but if the postmaster continues to work for the Postal Service, where’s the savings?
This was a recurring issue with appeals back in 2011 and 2012, when there were dozens and dozens before the Commission, and then-Chairman Goldway pointed it out many times in her dissenting opinions (see, for example, Pinehurst, Glenoaks, and Waverly).
What about the revenues?
As part of its justification for closing the post office, the original 2012 proposal to close indicated that revenues were on the decline. They had fallen from $482,359 in FY 2008 to $299,312 in FY 2011.
It’s of course not surprising that revenues would decline during this period. That’s when the stock market crashed and the economy went into recession. Postal revenues declined across the board. The problem, in other words, wasn’t simply that people weren’t going to the post office anymore because of the internet. As the Postal Service argued in the exigent rate case, volumes declined primarily because of the economy. These revenues decline should not be considered a valid reason for closing the post office.
The final determination from 2015 covers a different five-year period. It shows the revenues from 2010 through 2014, even though the post office had been closed for half this time. For FY 2013 and 2014, the revenues are thus $0. These numbers are meaningless and do not help make the case for closing the post office.
In their appeal letter to the PRC, the mayor and state representative point out that in the last two and half years of its operation, the Yantic post office brought in $771,400. For the last four full years it was in operation, revenues averaged $400,000 annually. Even in its last full fiscal year, as revenues continued to decline due to the recession, it brought in nearly $300,000.
Clearly, the Yantic post office was a very profitable retail outlet. It cost less than $100,000 a year to operate, and it brought in three or four times that amount. Given the Postal Service’s financial issues, how does it make any sense to close a post office like that?
Plus, there’s the probability that not all of Yantic’s revenues migrated to another USPS source, so the Postal Service probably lost revenue by closing the office, and much of the cost savings wasn’t really saved at all.
This was a recurring issue when the Postal Service was closing hundreds of post offices. For example, in the appeal on the Randolph, Iowa, post office, the Mayor wrote a very detailed letter pointing out that closing the post office would push a local bank, which did $30,000 worth of business with the Postal Service every year, to encourage its customers to use electronic alternatives. Something similar probably happened in Yantic.
An out-of-date study
It is highly problematic closing a post office in 2015 based on a study that was done in 2012. While the final determination has been superficially updated, the actual evidence, such as community feedback on the survey and the public meeting, was gathered in 2012. A lot has changed since then.
For example, at the time of the suspension and then during the discontinuance study — when the survey and meeting gathered public comment — Yantic customers were told that their new post office would be in Bozrah, and that’s where post office boxes were transferred.
But then Bozrah was identified as a Level 6 POStPlan office (Its hours were reduced to six a day in October 2014). As a result, the new administrative post office for Yantic was changed to Norwich.
The Bozrah office was a 2.1-mile drive away from Yantic. The Norwich office is 4.5 miles away. The Postal Service did not do a new survey or hold a new public meeting about the change in administrative offices. The results might have been significantly different.
Considering that Bozrah became a POStplan office, it’s likely that Yantic might have been able to remain open as a POStPlan office as well. At part-time hours with a part-time worker, Yantic would be even more profitable than it had been. It also seems unfair that Yantic would be closed when 13,000 other post offices threatened with closure have remained open under POStPlan.
Irregularities in the record
There are errors and irregularities in the Administrative Record that may be significant. For example, a July 31, 2013 internal USPS memo explains that the proposal to close needs to be reposted because, as noted above, the proposed administrative office, Bozrah, had come under POStPlan and the administrative office was changed to Norwich.
But this memo also says that the proposal needs to be revised for another reason. It states that “the initial Proposal was posted Oct. 6, 2013 through December 7, 2012. The imposed moratorium November 19, 2012 through January 2013 delayed the process of the original posting.”
This is very confusing. The initial Proposal was posted in October 2012, not 2013. That seems to be a typo.
More significantly, the moratorium on post office closings did not begin in November 2012. It began in November 2011. (The Postal Service put a temporary moratorium on post office closings from Nov. 19, 2011, until Jan. 2, 2012. This moratorium was then extended to cover from Dec. 15, 2011, to May 15, 2012.)
So why does this memo cite the moratorium as a reason for reposting the proposal when the moratorium had ended before the discontinuance study began?
There are probably other issues in the Administrative Record that should be examined in this case. Hopefully the petitioners, the Public Representative, and the Commission will give the record a thorough review. Not that this will change the outcome or end up reopening a post office in Yantic.
The loss is not just Yantic’s. The footer to Save the Post Office reminds us of what’s ultimately at stake. In the words of Senator Jennings Randolph of West Virginia: “When the post office is closed, the flag comes down. When the human side of government closes its doors, we’re all in trouble.”