Postal Service Performance and Customer Satisfaction Reporting, 49190-49215 [E9-22680]

Agencies

• POSTAL REGULATORY COMMISSION

[Federal Register Volume 74, Number 185 (Friday, September 25, 2009)]
[Proposed Rules]
[Pages 49190-49215]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E9-22680]



[[Page 49189]]

-----------------------------------------------------------------------

Part III





Postal Regulatory Commission





-----------------------------------------------------------------------



39 CFR Part 3055



Postal Service Performance and Customer Satisfaction Reporting; 
Proposed Rule

Federal Register / Vol. 74, No. 185 / Friday, September 25, 2009 / 
Proposed Rules

[[Page 49190]]


-----------------------------------------------------------------------

POSTAL REGULATORY COMMISSION

39 CFR Part 3055

[Docket No. RM2009-11; Order No. 292]


Postal Service Performance and Customer Satisfaction Reporting

AGENCY: Postal Regulatory Commission.

ACTION: Proposed rule.

-----------------------------------------------------------------------

SUMMARY: The Commission is proposing rules to address Postal Service 
reporting on service performance measurement and customer satisfaction. 
This proposal implements new statutory provisions. Comments will assist 
the Commission in developing final rules.

DATES: Initial comments due October 26, 2009. Reply comments due 
November 24, 2009.

ADDRESSES: Submit comments electronically via the Commission's Filing 
Online system at https://www.prc.gov.

FOR FURTHER INFORMATION CONTACT: Stephen L. Sharfman, General Counsel, 
202-789-6820 and stephen.sharfman@prc.gov.

SUPPLEMENTARY INFORMATION: 

Regulatory History

72 FR 72395 (December 20, 2007).
73 FR 39996 (July 11, 2008).
73 FR 73664 (December 2, 2008).
73 FR 39996 (July 11, 2008).

I. Introduction
II. Background
III. Statutory Provisions
IV. Service Performance Measurements Reporting
V. Special Services Measurement Systems
VI. Reporting of Customer Satisfaction
VII. Supporting Information
VIII. Designation of Public Representative
IX. Solicitation of Comments
X. Ordering Paragraphs

I. Introduction

    This rulemaking is part of the series of rulemakings initiated by 
the Postal Regulatory Commission (Commission) to fulfill its 
responsibilities under the Postal Accountability and Enhancement Act 
(PAEA), Public Law 109-435, 120 Stat. 3218 (2006). The proposed rules 
described herein seek to establish reporting requirements for the 
measurements of level of service and degree of customer satisfaction 
afforded by the Postal Service in connection with each market dominant 
product. The reporting of level of service and customer satisfaction 
are required by 39 U.S.C. 3652(a)(2)(B) as part of the Postal Service's 
annual report to the Commission. This is a necessary part of the 
Commission's implementation of a modern system of rate regulation for 
market dominant products that ensures service is not impaired as a 
result of the greater flexibility provided to the Postal Service under 
the PAEA and the rate cap requirements, and it supports an important 
part of the Commission's reporting responsibilities. See 39 U.S.C. 3622 
and 3651.
    The Commission recognizes that these proposed rules are being 
published at a time when the Postal service is experiencing 
unprecedented fiscal challenges. The proposed rules are designed to 
maximize transparency using data sources that either exist now, or are 
in active development. The proposed reporting requirements are written 
with a long-term goal in mind, i.e., to allow the Commission to perform 
its regulatory functions under the PAEA and to meet the statutory 
reporting requirements cited above, and are not necessarily based on 
the capabilities of existing measurement systems. The Commission 
recognizes the transitional needs of the Postal Service and accepts its 
request to develop and utilize internal measurement systems relying on 
barcode technology. Total compliance with the reporting requirements 
will not be possible until the Intelligent Mail barcode (IMb)-, Red 
Tag/DelTrak-, and Delivery Confirmation-based measurement systems 
provide reliable, representative data. In some instances, new or 
enhanced measurement capabilities may be required.
    In the short term, the Commission accepts that the Postal Service 
cannot wholly comply with these reporting requirements because specific 
measurement systems have not been fully developed or deployed. As long 
as the indicators already in place demonstrate adequate service levels, 
the Commission will allow the Postal Service to proceed diligently to 
develop a plan for eventually being able to supply the required 
information, and periodically to demonstrate progress in implementing 
its plan. If a new requirement in these proposed rules is viewed by the 
Postal Service as particularly onerous, or involves costly new data 
collection that does not appear to add needed transparency, the Postal 
Service is requested to identify it and attempt to quantify its 
incremental cost.
    To assist commenters to visualize the scope and extent of 
information required, illustrative data reporting charts are included 
as section VII--Supporting Information.

II. Background

    The first part of this rulemaking addresses reporting of the level 
of service (or the service performance measurements) associated with 
each market dominant product. Development of the reporting requirements 
is the final step in a four-step process for incorporating measurements 
of level of service into the modern system of rate regulation for 
market dominant products. The previous steps established service 
standards, identified service performance measurement systems, and 
established performance goals.
    The establishment of service standards is a direct result of the 
requirements of 39 U.S.C. 3691, which require the Postal Service, in 
consultation with the Postal Regulatory Commission, to establish by 
regulation a set of modern service standards for market dominant 
products. Initial consultations between the Commission and the Postal 
Service concluded on November 16, 2007, with the Commission providing 
the Postal Service with comments addressing the Postal Service's 
service standards proposals.\1\ The Postal Service completed this task 
by publishing as a final rule Modern Service Standards for Market-
Dominant Products, December 19, 2007 (Service Standards).\2\
---------------------------------------------------------------------------

    \1\ Comments of the Postal Regulatory Commission on Modern 
Service Standards for Market Dominant Products, November 16, 2007. 
The consultations are described as ``initial'' because of the 
ongoing nature of consultations that are necessary to transition 
from a set of standards to an operational measurement system 
encompassing performance goals (see uncodified Sec.  302(b)(1) of 
the PAEA) and reporting mechanisms (see U.S.C. 3652).
    \2\ 72 FR 72216 (December 19, 2007) (to be codified at 39 CFR 
parts 121 and 122).
---------------------------------------------------------------------------

    In June 2008, the Postal Service identified service performance 
measurement systems by providing the Commission with a draft of its 
Service Performance Measurement plan (Plan).\3\ The Plan presents the 
various measurement systems the Postal Service proposes to use to 
measure the standards presented in the Service Standards document 
identified above.\4\

[[Page 49191]]

The Postal Service submitted the Plan for the Commission's ``review, 
feedback, and concurrence.'' \5\ In response, the Commission initiated 
Docket No. PI2008-1 to consider the Postal Service's Plan and to 
solicit public comment. This process culminated with the Commission 
issuing PRC Order No. 140, Order Concerning Proposals for Internal 
Service Standards Measurement Systems, November 25, 2008 (Order No. 
140). This order completed the second step in the process by approving 
the approaches that the Postal Service proposes to take in developing 
internal measurement systems for various classes of mail.\6\
---------------------------------------------------------------------------

    \3\ The Commission published the Plan in Docket No. PI2008-1, 
Second Notice of Request for Comments on Service Performance 
Measurement Systems for Market Dominant Products, June 18, 2008 
(Order No. 83). The draft published in Order No. 83 was the last 
draft in a series of drafts provided by the Postal Service to the 
Commission.
    \4\ An objective in designing service performance standards is 
for the Postal Service to provide ``a system of objective external 
performance measurements for each market-dominant product as a basis 
for measurement of Postal Service performance.'' 39 U.S.C. 
3691(b)(1)(D). However, ``with the approval of the Postal Regulatory 
Commission an internal measurement system may be implemented instead 
of an external measurement system'' for individual products. 39 
U.S.C. 3691(b)(2). In the Plan, the Postal Service proposes various 
internal, external, and hybrid (containing both internal and 
external elements) measurement systems to measure the performance of 
its mail products.
    \5\ Letter from Thomas G. Day, Senior Vice President, United 
States Postal Service, to Dan G. Blair, Chairman, Postal Regulatory 
Commission, June 3, 2008.
    \6\ Approval was provided with the exception of the measurement 
systems for several Special Services where the Commission directed 
the Postal Service to propose a remedial plan by June 1, 2009. The 
Postal Service submitted remedial proposals on May 15, 2009. See 
Letter from Thomas G. Day, Senior Vice President, Intelligent Mail 
and Address Quality, United States Postal Service, to Dan G. Blair, 
Chairman, Postal Regulatory Commission, May 15, 2009 (May 15, 2009 
Letter from Thomas G. Day).
---------------------------------------------------------------------------

    The PAEA directed the Postal Service, in consultation with the 
Commission, to develop and submit to Congress a plan for meeting 
service standards. Congress directed, inter alia, that the plan 
establish performance goals. The Postal Service posted its FY 2009 
targets on its Rapid Information Bulletin Board System (RIBBS) Web page 
at https://ribbs.usps.gov/targets/documents/tech_guides/Targets.pdf.
    The Postal Service's Plan included proposals for both annual and 
quarterly reporting of service performance measurements. The Commission 
solicited comments on service performance reporting when it considered 
the Postal Service's proposals for measurement systems. However, in 
Order No. 140, the Commission limited its considerations of those 
comments in anticipation of the instant rulemaking, which specifically 
addresses reporting requirements.
    The fourth and final step in the process, and the subject of this 
rulemaking, is for the Commission to issue rules specifying the 
reporting of service performance. The Commission incorporates many of 
the elements proposed by the Postal Service in its Plan and the ideas 
presented in the comments on reporting measurements into the rules now 
proposed. Interested persons are encouraged to take a fresh look at the 
proposals presented by the Commission in this rulemaking and provide 
comments. Interested persons are asked to reiterate and amplify their 
comments where specific areas identified in previous comments are not 
sufficiently addressed to assure that all relevant issues are 
adequately considered.\7\
---------------------------------------------------------------------------

    \7\ In Order No. 140 at 36-46, the Commission briefly reviewed 
the Postal Service's reporting proposals and the associated 
comments. The Commission indicated issues that would be appropriate 
for consideration in this rulemaking, and issues that appear beyond 
the scope of what the Commission would find necessary for its needs 
in reporting service performance measurements. Commenters are asked 
to review and consider this material prior to submitting comments in 
this docket.
---------------------------------------------------------------------------

    The second part of this rulemaking concerns the reporting of 
customer satisfaction. This part introduces new material that 
previously has not been addressed by the Postal Service or the 
Commission. Interested persons also are asked to comment on this 
material.
    In Order No. 140, the Commission identified areas within the 
Special Services measurement systems that required improvement. The 
Postal Service has submitted proposals for modifications to these 
measurement systems which are discussed separately in section V.--
Special Services Measurement Systems of this Rulemaking.

III. Statutory Provisions

    Section 3652(a)(2) of title 39 requires that the Postal Service 
include in an annual report to the Commission an analysis of the 
quality of service ``for each market-dominant product provided in such 
year'' by providing ``(B) measures of the quality of service afforded 
by the Postal Service in connection with such product, including--(i) 
the level of service (described in terms of speed of delivery and 
reliability) provided; and (ii) the degree of customer satisfaction 
with the service provided.'' In complying with this requirement, the 
Commission has authority to ``by regulation, prescribe the content and 
form of the public reports (and any nonpublic annex and supporting 
matter relating to the report) to be provided by the Postal Service * * 
*.'' 39 U.S.C. 3652(e)(1).\8\ The Commission also is to have access to 
``supporting matter'' in connection with any information submitted 
under this section. 39 U.S.C. 3652(d).
---------------------------------------------------------------------------

    \8\ The Commission's authority is continuing as it has further 
authority to initiate proceedings to improve the quality, accuracy 
and completeness of data whenever it shall appear that ``the quality 
of service data has become significantly inaccurate or can be 
significantly improved.'' 39 U.S.C. 3652(e)(2)(B).
---------------------------------------------------------------------------

    Section 3622 of title 39 provides that the Commission by regulation 
establish ``a modern system for regulating rates and classes for 
market-dominant products.'' The quality of service, and its reporting, 
forms an integral part of many of the objectives and factors set forth 
in this section. Reporting on quality of service allows assessment of 
whether the Postal Service is meeting the objective of maintaining the 
``high quality service standards established under section 3691.'' 39 
U.S.C. 3622(b)(3). It furthers the objective of increasing ``the 
transparency of the ratemaking process.'' 39 U.S.C. 3622(b)(6). It 
allows assessment of the factors addressing value of service, and by 
association with the proposed measurement systems, the value of 
intelligent mail. 39 U.S.C. 3622(c)(1), (8), and (13). Finally, it is 
important in relation to the rate cap requirements of 39 U.S.C. 
3622(d)(1)(A) when analyzing whether quality of service is impacted in 
order to comply with rate cap requirements.
    Section 3651(b)(1)(A) of title 39 requires that the Commission 
report to the President and Congress on an annual basis estimates of 
the costs incurred by the Postal Service in providing ``universal 
service.'' Describing the quality of service afforded a product, both 
anticipated and actual, is a necessary element in analyzing what 
service is being provided at a given cost. The Postal Service is to 
provide the Commission with such information that may, in the judgment 
of the Commission, be necessary in completing this report. 39 U.S.C. 
3651(c).

IV. Service Performance Measurements Reporting

A. Overview

    The Postal Service proposes in its Plan and the Commission adopts 
for this rulemaking a two level system for reporting service 
performance consisting of an Annual Report provided at a high level of 
aggregation and four Quarterly Reports which provide information at a 
more detailed level. As stated in the Postal Service's Plan at 12:

    In accordance with Sec.  3652 of the Postal Accountability and 
Enhancement Act, the Postal Service is required to report measures 
of the quality of service on an annual basis. The Postal Service's 
proposal for service measurement goes far beyond annual reporting 
and will instead provide quarterly reporting for all market-dominant 
products, almost entirely at a district level.

    Section 3652(a)(2) of title 39 requires, among other things, an 
annual analysis of the quality of service ``for each market-dominant 
product * * *.'' The Postal Service acknowledges this

[[Page 49192]]

requirement and specifically states that it will go beyond what it 
perceives as the minimum requirement and provide quarterly reporting 
for all market dominant products. See Plan at 12. However, the specific 
data items identified in the Postal Service's Plan propose reporting at 
a higher level of aggregation, at the class level. This deviation from 
what appears to be required was challenged by many commenters in Docket 
No. PI2008-1.\9\ This rulemaking proposes reporting requirements by 
product as urged in these comments, which also is consistent with the 
Commission's interpretation of the statutory requirements of Sec.  
3652(a)(2). To facilitate review of the proposed rules, the most recent 
market dominant product list appears in Table VII-1--Market Dominant 
Product List as of August 10, 2009 to this rulemaking.
---------------------------------------------------------------------------

    \9\ See comments of Pitney Bowes, Discover Financial Services, 
Post/Com/DMA, McGraw-Hill, and Valpak summarized in Order No. 140 at 
39-40.
---------------------------------------------------------------------------

    The proposed rules intend to require reporting for all market 
dominant products, but also include exceptions for when reporting is 
not practicable. For example, in the area of negotiated service 
agreements, the rules allow the Postal Service to utilize exceptions to 
reporting on individual negotiated service agreements if the Postal 
Service can demonstrate that substantially all components of a specific 
agreement are already included in the measurement of other 
products.\10\
---------------------------------------------------------------------------

    \10\ Nonpostal products are another category of products that 
may require special consideration. At this time, nonpostal products 
are not specifically addressed by this rulemaking other than 
reserving space for future use.
---------------------------------------------------------------------------

    As discussed in Order No. 140, several mailers request some form of 
shape-based reporting.\11\ The Postal Service opposed these suggestions 
contending that this is not required for the Commission to carry out 
its PAEA regulatory responsibilities. Although the Commission is not 
opposed to consideration of shape-based reporting if the need can be 
demonstrated at some future date, the rules proposed in this rulemaking 
do not reflect shape-based reporting, per se. However, by adhering to 
the statutory requirement to report by product, as discussed above, it 
should be noted that significant, although imperfect, shape-based 
reporting will be accomplished.
---------------------------------------------------------------------------

    \11\ See comments of BAC, DFS, MOAA, NPPC, PSA, PostCom/DMA, 
Time Warner, Publishers Clearing House, and Valpak and the response 
of the Postal Service summarized in Order No. 140 at 40-41.
---------------------------------------------------------------------------

    The Postal Service proposes in its Plan to report two types of 
measurements for First-Class Mail, Standard Mail, Periodicals and 
Package Services: (1) On-time service performance, and (2) service 
variance. On-time service performance represents the percentage of 
mailpieces delivered within the applicable service standard for those 
mailpieces. Service variance represents the cumulative percentage of 
mailpieces delivered within the applicable service standard plus 1 day, 
2 days, or 3 days.\12\ The Postal Service proposes to report on-time 
service performance both on an annual and a quarterly basis, and 
service variance only on a quarterly basis. The proposed rules adopt 
these reporting elements.
---------------------------------------------------------------------------

    \12\ In Docket No. PI2008-1, several mailers expressed an 
interest in expanding service variance or ``tail-of-the-mail'' 
reporting. See Order No. 140 at 43-44. However, the Commission is 
not convinced that additional reporting was justified.
---------------------------------------------------------------------------

    For Special Services, the Postal Service proposes an index to 
report as a single number the performance of all Special Services 
products, provided on an annual basis. It proposes providing additional 
performance detail on a quarterly basis. This rulemaking specifies 
reporting at the product level (or, in limited circumstances, down to a 
component of a product for products requiring increased visibility) as 
required by 39 U.S.C. 3652(a)(2).\13\ The rules propose reporting the 
percentage of time that each product (or, in limited circumstances, a 
component of a product) meets or exceeds its applicable service 
standard.
---------------------------------------------------------------------------

    \13\ The Commission is open to consideration of the use of an 
``index'' at or below the product level if its use can be justified.
---------------------------------------------------------------------------

    The Postal Service proposes in its Plan reporting service 
performance on an annual basis at the National level.\14\ On a 
quarterly basis, reporting for domestic First-Class Mail, Standard 
Mail, domestic Package Services, and Post Office Box Service within 
Special Services is proposed at the Postal Administrative Area and 
District levels, and reporting for international First-Class Mail, 
Periodicals, and international Package Services is proposed at the 
Postal Administrative Area level. This rulemaking generally adopts 
these reporting levels.\15\
---------------------------------------------------------------------------

    \14\ It is unclear in the Plan, but assumed by the Commission, 
that the Postal Service contemplated providing National level 
information on a quarterly basis.
    \15\ The Postal Service proposed additional Administrative Area 
and District level reporting for certain electronic Special Services 
that will not be adopted at this time. The Commission recognizes 
that this level of reporting may be required in the future, but 
finds it prudent to await further development of the Special 
Services measurement systems.
---------------------------------------------------------------------------

    Within the Standard Mail class only, the Postal Service proposes in 
its Plan separate quarterly reporting for Destination Entry and for 
End-to-End mail. The Commission notes that the Postal Service also 
specifies different service standards for End-to-End and for 
Destination Entry mail within the Periodicals and Package Services 
classes. See Service Standards. Because the Postal Service and the 
Commission recognize service performance differences between 
Destination Entry and End-to-End mail in all of the aforementioned 
classes, the Commission carries this distinction forward in the 
proposed reporting requirements. This rulemaking incorporates this 
distinction not only for Standard Mail, but also for the Outside County 
Periodicals, Bound Printed Matter Flats, Bound Printed Matter Parcels, 
and Media Mail/Library Mail products.
    Depending upon the class of mail and whether the mail is 
Destination Entry or End-to-End mail, and based on consideration of the 
entry facility and the origination/destination ZIP Code pairs, among 
other factors, the Postal Service specifies a vast array of service 
standards. See Table IV-1.

                      Table IV-1--Service Standards
------------------------------------------------------------------------
                                       Service standard ranges (days)
            Mail class             -------------------------------------
                                        End-to-end     Destination entry
------------------------------------------------------------------------
First-Class Mail..................                1-5                N/A
Periodicals.......................               1-20                1-8
Standard Mail.....................               3-22               2-10
Package Services..................               2-20                1-8
------------------------------------------------------------------------


[[Page 49193]]

    For domestic First-Class Mail, the Postal Service proposes in its 
Plan to separately report overnight, 2-day, and a single aggregation of 
3, 4, and 5-day mail. This rulemaking adopts the First-Class Mail 
overnight, 2-day, and 3/4/5-day reporting groups proposed by the Postal 
Service.
    In Docket No. PI2008-1, the Commission received comments which 
suggest further disaggregation of the 3/4/5-day report group proposed 
by the Postal Service.\16\ The proposal suggests two smaller groups, 
mail subject to the 3-day service standard and mail subject to the 4 
through 5-day service standards. The intent appears to be to segregate 
mail that either only leaves, only enters, or that never transverses 
the contiguous United States. The 4/5-day service standard group 
theoretically then could be used as representing service performance 
for noncontiguous United States mail. This conceivably could provide 
increased visibility into the service performance of mail traveling, 
for example, between Alaska or Hawaii and the contiguous United States.
---------------------------------------------------------------------------

    \16\ See Comments of PostCom/DMA summarized in Order No. 140 at 
41.
---------------------------------------------------------------------------

    The Commission studied this suggestion, but decided against its 
adoption. The Commission notes that the 3-day service standard for 
First-Class Mail also is applicable to certain mail that is sent 
between the contiguous United States and certain ZIP Codes in Alaska, 
Hawaii, or Puerto Rico, i.e., noncontiguous United States mail. Thus, 
disaggregating mail subject to the 4/5-day service standards from mail 
subject to the 3/4/5-day service standard group does not create a 4/5-
day group that is representative of noncontiguous United States mail.
    As displayed in Table IV-1, the domestic products within the 
Periodicals, Standard Mail, and Package Services classes are subject to 
a wide range of applicable service standard days. The Postal Service 
proposes in its Plan to aggregate all service standard days and report 
one measurement for the domestic products within each of these 
classes.\17\
---------------------------------------------------------------------------

    \17\ The Postal Service's proposal to separately report 
Destination Entry and End-to-End Standard Mail is recognized above.
---------------------------------------------------------------------------

    The multitude of applicable service standards within the above 
classes raise issues concerning the appropriate level of aggregation/
disaggregation of service standard days. Mail that is subject to 
shorter duration service standards is subject to different mail 
handling in terms of facilities encountered and transportation received 
than mail subject to longer duration service standards. Too high a 
level of aggregation results in lost visibility into service 
performance disparities between mail subject to different handling and 
service standards. Reporting by individual service standard day could 
be a solution, which would vastly improve visibility based on these 
differences. However, it also would raise measurement reliability 
issues due to the sparse volume of mail subject to certain longer 
service standards. Producing reliable measurements, providing 
sufficient visibility into service performance due to differences in 
handling and service standards, and the feasibility of implementing 
measurement systems at this time, all must be balanced when proposing 
reporting rules.
    For annual reporting, this rulemaking adopts the Periodicals, 
Standard Mail, and Package Services reporting levels proposed by the 
Postal Service. The Commission balances this overview level of 
reporting by proposing expanded reporting requirements in certain areas 
to provide improved visibility within the quarterly reports. For 
quarterly reporting, this rulemaking adopts the Postal Service's 
proposed service standard aggregations for Periodicals, and the Bound 
Printed Matter Flats, Bound Printer Matter Parcels, and Media Mail/
Library Mail products within Package Services. It proposes improvements 
in reporting visibility for all products within Standard Mail and the 
Single-Piece Parcel Post product within Package Services. For these 
products, the rules propose aggregating the multiple service standards 
for each product into two separate groups based on the mail facilities 
encountered and the transportation received. Specific proposals for 
aggregating service standard days appear within the discussion of the 
individual rules below.

B. Annual Reporting

1. General Considerations
    This rulemaking proposes to incorporate the rules for annual 
reporting of service performance measurements (or achievements) into 
new subpart A--Annual Reporting of Service Performance Achievements of 
part 3055--Service Performance and Customer Satisfaction Reporting of 
the Commission's rules of practice and procedure. The rules proposed 
for incorporation into subpart A appear after the signature of this 
order. Table VII-2--Illustrative Annual Report Data Reporting Charts in 
section VII provides a visualization of the annual data reporting 
elements proposed by the rules through illustrative examples of data 
reporting charts. A rule-by-rule description of subpart A follows.
    Section 3055.1 specifies the general requirement for the Postal 
Service to file a report on service performance measurements as part of 
its annual compliance report. See 39 U.S.C. 3652(a)(2)(B)(i).
    Section 3055.2 describes the contents of the annual report of 
service performance achievements. Paragraph (b) of this section directs 
the reader to specific reporting requirements applicable to each 
product within a specific class or group. Paragraphs (c) through (g) of 
this section direct the Postal Service to describe the service 
standards, performance goals, measurement systems, and statistical 
methodologies for each product. In the first report produced, the 
Postal Service will create a baseline description of service 
performance measurement. The Commission recognizes that the initial 
report will require significant effort on the part of the Postal 
Service. However, subsequent annual reports will require the Postal 
Service only to replicate the previous report incorporating changes 
from year to year. Paragraph (h) of this section requires the 
identification of each product, or component of a product, granted an 
exception from reporting pursuant to Sec.  3055.3, along with a 
certification that the rationale for originally granting the exception 
remains valid.
    Particular attention should be focused on paragraphs (i) and (j) of 
Sec.  3055.2. A significant amount of data will be produced pursuant to 
the annual and quarterly reporting rules. The data will be provided at 
various levels and forms of aggregation, and provided over different 
periods of time. Paragraphs (i) and (j) of this section in effect 
require the Postal Service to demonstrate how it performs each 
aggregation/disaggregation of data, both between and among the various 
reports, and over the various timeframes. The goal is to provide 
independent parties the information necessary to be able to replicate 
the aggregations/disaggregations made by the Postal Service between and 
among the various reports, and over the various timeframes. For 
example, this should include the ability to aggregate the data provided 
in the quarterly reports up to the level of data provided in the annual 
reports. It also should include the ability to aggregate data provided 
at the District level, to the Postal Administrative Area level, and to 
the National level. The Commission expects that data will be provided 
in electronic

[[Page 49194]]

format (Excel files are anticipated at this time), with electronic 
links and formulas that can be followed in order to duplicate the 
Postal Service's aggregation methodologies. This would include 
providing volumes and other weighting factors as necessary to perform 
the required calculations.\18\
---------------------------------------------------------------------------

    \18\ See comments of AMEE and MMA suggesting the inclusion of 
volume data, summarized in Order No. 140 at 42.
---------------------------------------------------------------------------

    For some products, the measurement of service performance may be 
cost prohibitive, or a measurement of service would not be meaningful 
because of the nature of the product. In other instances, the product 
might be in the form of a negotiated service agreement, which, in fact, 
is merely a grouping of other products already being measured. Section 
3055.3 provides an avenue for the Postal Service to seek an exception 
from the general requirement to report on the service performance in 
these instances.
    Section 3691(b)(1)(D) of title 39 has as an objective for the 
Postal Service ``[t]o provide a system of objective external 
performance measurements for each market-dominant product * * *.'' 
However, ``with the approval of the Postal Regulatory Commission an 
internal measurement system may be implemented * * *.'' 39 U.S.C. 
3691(b)(2). Order No. 140 approved the approach that the Postal Service 
is undertaking to implement most of its measurement systems. This 
approval is subject to continuous review as the Postal Service's 
systems are developed and implemented to assure that robust measurement 
systems are eventually put into place. Section 3055.4 of the proposed 
rules implements the above title 39 requirements. It requires that the 
Postal Service obtain Commission approval prior to using internal 
(including hybrid) measurement systems to obtain data for the purpose 
of reporting service performance measurements. This requirement is 
applicable to both the annual and quarterly service performance 
measurement reports.
    Section 3055.5 requires the Postal Service to apprise the 
Commission of all changes to measurement systems, service standards, 
service goals, and reporting methodologies. The Commission may 
institute a proceeding to consider change proposals if it appears that 
the changes might have a material impact on the accuracy, reliability, 
or utility of the reported measurement, or if the changes might have a 
material impact on the characteristics of the underlying product.
    Section 3055.6 requires the Postal Service to include within its 
proposals for new or modified market dominant products, proposals for 
service performance measurement systems, service standards, service 
goals, data reporting elements, and data reporting methodologies.
    Section 3055.7 directs the Postal Service to conduct a special 
study, every 2 years, to evaluate final delivery service performance in 
certain locations. The measurement systems that the Postal Service 
proposes do not appear to capture information on delivery performance; 
for example, from the processing facility in Anchorage, Alaska to the 
outer reaches of Alaska; from Honolulu to the neighbor islands of 
Hawaii; or from San Juan to more distant locations in the Caribbean 
district. A special study appears appropriate for providing visibility 
into these areas.
2. First-Class Mail
    Section 3055.20 specifies the annual reporting requirements for all 
products within the First-Class Mail class. For the Single-Piece 
Letters/Postcards, Bulk Letters/Postcards, Flats, and Parcels products, 
reporting of on-time service performance is to be disaggregated by mail 
subject to the overnight, 2-day, and 3/4/5-day service standards as a 
percentage rounded to one decimal place.\19\ For the Outbound Single-
Piece First-Class Mail International and the Inbound Single-Piece 
First-Class Mail International products, on-time service performances 
are to be reported at the National level as a percentage rounded to one 
decimal place.
---------------------------------------------------------------------------

    \19\ The 3/4/5-day service standard is an aggregation of the 3-
day, 4-day, and 5-day service standards. The Postal Service is 
required to demonstrate how it performs this aggregation, along with 
other similar aggregations appearing within other mail classes when 
describing its data reporting methodologies.
---------------------------------------------------------------------------

3. Standard Mail
    Section 3055.21 specifies the annual reporting requirements for all 
products within the Standard Mail class. In all instances, on-time 
service performances are to be reported at the National level for each 
Standard Mail product as a percentage rounded to one decimal place.
4. Periodicals
    Section 3055.22 specifies the annual reporting requirements for all 
products within the Periodicals class. In all instances, on-time 
service performances are to be reported at the National level for each 
Periodicals product as a percentage rounded to one decimal place.
5. Package Services
    Section 3055.23 specifies the annual reporting requirements for all 
products within the Package Services class. In all instances, on-time 
service performances are to be reported at the National level for each 
Package Services product as a percentage rounded to one decimal place.
6. Special Services
    Section 3055.24 specifies the annual reporting requirements for all 
products within the Special Services group. In all instances, the 
percentage of time that each product within Special Services meets or 
exceeds its performance objective is to be reported at the National 
level as a percentage rounded to one decimal place.
7. Nonpostal Products
    Section 3055.25 is reserved for specific reporting requirements 
concerning nonpostal products once these products are added to the 
market dominant product list.

C. Quarterly Reports

1. General Considerations
    This rulemaking proposes to incorporate the rules for quarterly 
reporting of service performance measurements into new subpart B--
Periodic Reporting of Service Performance Achievements of Part 3055--
Service Performance and Customer Satisfaction Reporting of the 
Commission's rules of practice and procedure. The rules proposed for 
incorporation into subpart B appear after the signature of this Order. 
Table VII-3--Illustrative Quarterly Report Data Reporting Charts 
provides a visualization of the annual data reporting elements proposed 
by the rules through illustrative examples of data reporting charts. A 
rule-by-rule description of subpart B follows.
    Section 3055.30 specifies the general requirement for the Postal 
Service to file a quarterly report on service performance measurement 
within 40 days of the close of each fiscal quarter.
    Section 3055.31 specifies the contents of each quarterly report. 
Paragraph (b) of this section directs the reader to specific reporting 
requirements applicable to each product within a specific class or 
group. Paragraph (c) of this section requires identification of each 
product, or component of a product, granted an exception from reporting 
pursuant to Sec.  3055.3, along with a certification that the rationale 
for originally granting the exception remains valid. Finally,

[[Page 49195]]

paragraphs (d) and (e) of this section direct the Postal Service to 
demonstrate how it aggregates/disaggregates data to different reporting 
levels.\20\
---------------------------------------------------------------------------

    \20\ For further discussion on aggregation/disaggregation, see 
the discussion of Sec.  3055.2, paragraphs (i) and (j) of this 
section above.
---------------------------------------------------------------------------

    Section 3055.32 requires the Postal Service to independently report 
delivery factors when used in computing End-to-End service performance. 
The hybrid measurement system (proposed by the Postal Service for 
measuring a majority of Postal Service products by volume) measures 
End-to-End service performance in two steps. In the first step, a mail 
processing factor is developed, which measures the time from the start-
the-clock event to the last recorded mail processing scan. In the 
second step, a delivery factor is developed which measures the time 
from the last recorded mail processing scan to actual delivery. The 
generation of delivery factors raises measurement and statistical 
issues that must be examined to understand the overall measurement 
results. Section 3055.32 provides visibility in this area.
2. First-Class Mail
    Section 3055.45 specifies the quarterly reporting requirements for 
all products within the First-Class Mail class. In all instances, on-
time service performances and service variances are to be individually 
reported for each First-Class Mail product as a percentage rounded to 
one decimal place.
    For the Single-Piece Letters/Postcards, Bulk Letters/Postcards, 
Flats, and Parcels products, the rule proposes reporting at the 
District, Postal Administrative Area, and National levels. Reporting 
also is to be disaggregated by mail subject to the overnight, 2-day, 
and 3/4/5-day service standards.
    For the Outbound Single-Piece First-Class Mail International and 
Inbound Single-Piece First-Class Mail International products, the rule 
proposes reporting at the Postal Administrative Area and National 
levels.
3. Standard Mail
    Section 3055.50 specifies the quarterly reporting requirements for 
all products within the Standard Mail class. In all instances, on-time 
service performances and service variances are to be reported at the 
District, Postal Administrative Area, and National levels for each 
Standard Mail product as a percentage rounded to one decimal place.
    Each Standard Mail product can be considered either Destination 
Entry or End-to-End mail. The Postal Service has established 2-day 
through 10-day service standards for Destination Entry mail. 
Destination Entry mail is separated into two groups for reporting 
purposes. The rule proposes reporting an aggregation of mail subject to 
the 2-day through 4-day service standards and an aggregation of mail 
subject to the 5-day through 10-day service standards.\21\ The Postal 
Service has established 3-day through 22-day service standards for End-
to-End mail. End-to-End mail also is separated into two groups for 
reporting purposes. The rule proposes reporting an aggregation of mail 
subject to the 3-day through 5-day service standards and an aggregation 
of mail subject to the 6-day through 22-day service standards.\22\
---------------------------------------------------------------------------

    \21\ Destination Entry 2-day through 4-day service standard mail 
roughly coincides with DDU and DSCF entered mail. Destination Entry 
5-day through 10-day service standard mail roughly coincides with 
DBMC and BMC entered mail.
    \22\ End-to-End 3-day through 5-day service standard mail 
roughly coincides with SCF turnaround, ADC turnaround, and intra-BMC 
area mail. End-to-End 6-day through 22-day service standard mail 
roughly coincides with all other End-to-End mail subject to greater 
transportation needs.
---------------------------------------------------------------------------

4. Periodicals
    Section 3055.55 specifies the quarterly reporting requirements for 
all products within the Periodicals class. In all instances, on-time 
service performances and service variances are to be reported at the 
Postal Administrative Area and National levels for each Periodicals 
product as a percentage rounded to one decimal place.
    The Postal Service has established 1-day through 8-day service 
standards for Periodicals mail. The proposed rule requires the 
reporting of an aggregated number representing mail subject to the 1-
day through 8-day service standards for each of the Periodicals 
products.
    Performance reporting for the Outside County Periodicals product is 
to be further disaggregated by Destination Entry and End-to-End mail.
5. Package Services
    Section 3055.60 specifies the quarterly reporting requirements for 
all products within the Package Services class. In all instances, on-
time service performances are to be reported for each Package Services 
product as a percentage rounded to one decimal place. For reporting 
purposes, the Package Services products are separated into three 
groups: (1) Single-Piece Parcel Post; (2) Bound Printed Matter Flats, 
Bound Printed Matter Parcels, and Media Mail/Library Mail; and (3) 
Inbound Surface Parcel Post (at UPU rates).
    The Postal Service has established 2-day through 20-day service 
standards for the Single-Piece Parcel Post product.\23\ The rule 
proposes dividing the multiple Single-Piece Parcel Post service 
standards into two groups. It requires the reporting of an aggregated 
number representing mail subject to the 2-day through 4-day service 
standards and an aggregated number representing mail subject to the 5-
day through 20-day service standards.\24\ Reporting is to be provided 
at the District, Postal Administrative Area, and National levels.
---------------------------------------------------------------------------

    \23\ The Commission is assuming that Single-Piece Parcel Post 
mail is treated as End-to-End mail for the purpose of service 
standards.
    \24\ The 2-day through 4-day service standard mail roughly 
coincides with SCF turnaround and intra-BMC area mail. The 5-day 
through 20-day service standard mail roughly coincides with all 
other Single-Piece Parcel Post mail subject to greater 
transportation needs.
---------------------------------------------------------------------------

    The Bound Printed Matter Flats, Bound Printed Matter Parcels, and 
Media Mail/Library Mail products can be considered either Destination 
Entry or End-to-End mail. The Postal Service has established 1-day 
through 8-day service standards for Destination Entry mail. The rule 
proposes reporting an aggregation of all Destination Entry mail subject 
to the 1-day through 8-day service standards. The Postal Service has 
established 2-day through 20-day service standards for End-to-End mail. 
The rule proposes reporting an aggregation of all End-to-End mail 
subject to the 2-day through 20-day service standards.
    The rule proposes reporting a single service performance number for 
Inbound Surface Parcel Post (at UPU rates). Reporting is to be provided 
at the Postal Administrative Area and National levels.
6. Special Services
    Section 3055.65 specifies the quarterly reporting requirements for 
all products within the Special Services group. In all instances, the 
percentage of time that each product within Special Services meets or 
exceeds its performance objective is to be reported at the National 
level as a percentage rounded to one decimal place.
    Additional reporting is proposed for several of the 28 services 
that form a part of the Ancillary Services product to provide improved 
visibility. Separate reporting is proposed for Certified Mail and 
Return Receipt because of the importance of these services to customers 
and their substantial contribution to Ancillary Services'

[[Page 49196]]

revenue. Separate reporting is proposed for Delivery Confirmation 
because of the Postal Service's reliance on this service as part of its 
measurement system for parcels. Separate reporting is proposed for 
Insurance because of consumer interest in the performance of this 
service.
    Additional reporting also is proposed for the Post Office Box 
Service product. In addition to reporting at the National level, 
reporting also shall be provided at the District and Postal 
Administrative Area levels.
    In Order No. 140, the Commission identified areas within the 
Special Services measurement systems that required improvement. In 
section V.--Special Services Measurement Systems that follows, the 
Commission analyzes the Postal Service's proposals for improving 
certain Special Services measurement systems and provides further 
detail on reporting requirements for these services.
7. Nonpostal Services
    Section 3055.70 is reserved for specific reporting requirements 
concerning nonpostal products once these products are added to the 
market dominant product list.

V. Special Services Measurement Systems

    In Order No. 140, the Commission reviewed the Postal Service's Plan 
to use various measurement systems for measuring service performance 
for market dominant products. The Commission generally agreed with the 
approach that the Postal Service proposed for most products, except for 
certain products that fell within Special Services.
    On a general level, the Commission's recommendation for Special 
Services was ``that the Postal Service determine the attributes of each 
[special] service including the customer's reasonable expectations of 
what is being purchased, and then design measurement systems 
considering these parameters.'' Order No. 140 at 34-35.
    The Commission specifically commented on Special Services that 
include a barcode scan. The proposed measurement systems for Special 
Services that include a barcode scan were limited to only measuring the 
time between when delivery information was collected to when 
information was made available to the customer. This did not appear to 
be representative of the services that a customer had purchased or 
would expect, when considering that the proposed measurement systems 
would not pick up failures such as not scanning a mailpiece at delivery 
or attempted delivery, or a failure of the scanning equipment itself.
    The Commission used Delivery Confirmation to demonstrate its 
specific concerns with the various barcode scan measurement systems. 
The Commission concluded that ``[a]t a minimum, the Postal Service must 
incorporate into its proposed measurement systems for Delivery 
Confirmation and other similar electronic systems a factor for the 
volume of services purchased versus the volume of services successfully 
completed.'' (Footnote omitted.) Id. at 34. The expectation is for this 
recommendation to be incorporated into all applicable barcode scan-
based systems.
    The Commission also focused on Certified Mail, Post Office Boxes, 
and Return Receipt in part because they account for nearly 70 percent 
of overall Special Services revenue. Id. at 33. The concerns with 
Certified Mail paralleled the concerns for Delivery Confirmation as 
presented above. The measurement approach proposed for Post Office 
Boxes was found acceptable. Id. at 35. Finally, the Commission 
expressed concerns with the proposed measurement system for Return 
Receipt. The Postal Service proposed to only measure electronic Return 
Receipt by using the same measurement system as it proposed for 
Delivery Confirmation. However, the vast majority of Return Receipt 
service is provided through delivery of the green Return Receipt card, 
which the Postal Service did not propose to measure in any way.
    Order No. 140 concluded by approving the measurement approaches for 
Post Office Box Service, Insurance claims processing, Postal Money 
Order inquiry processing, and Address List Services. However, because 
of the concerns summarized above, it directed the Postal Service to 
``proceed with external measurement of service performance for 
Certified, Return Receipt, and Delivery Confirmation or develop an 
alternative internal measurement system by June 2009.'' Id.
    The Postal Service responded to the Commission's concerns on May 
15, 2009 in a letter from Thomas G. Day, Senior Vice President, 
Intelligent Mail and Address Quality, United States Postal Service, to 
Dan G. Blair, Chairman, Postal Regulatory Commission.
    Because of the similarities of the proposed measurement systems for 
Certified Mail and Delivery Confirmation, the Postal Service address 
both systems together. The Postal Service proposes to modify the 
measurement systems as suggested by the Commission.

    Accordingly, the Postal Service has modified its methodology for 
calculating on-time delivery-related information availability for 
Certified Mail and Delivery Confirmation services. In the 
denominator for calculating the percentage of pieces for which 
delivery-related information was made available within the 24-hour 
service standard, the Postal Service will include all pieces for 
which the delivery information service was purchased, irrespective 
of whether there is a delivery-related scan corresponding to each 
acceptance scan. The numerator will include only those pieces for 
which there was both a delivery scan and availability of delivery 
information within 24 hours of that delivery scan. Thus, for the 
universe of pieces for which there is an acceptance scan, the 
service measurement performance score will reflect the percentage of 
such pieces for which delivery-related information is obtained, and 
then provided to the sender within 24 hours. A failure to obtain 
delivery scan will be regarded as a Certified Mail or Delivery 
Confirmation service failure.

See May 15, 2009 Letter from Thomas G. Day, Attachment at 3. (Emphasis 
omitted.)
    The Commission finds that the Postal Service's modified approach to 
measuring Certified Mail and Delivery Confirmation service is an 
improvement over its original proposals and should produce results that 
more accurately measure the expectations of customers purchasing the 
services. The Commission reiterates its expectation that the proposed 
solutions for Certified Mail and Delivery Confirmation service are to 
be incorporated into all similar barcode scan-based systems, where 
applicable.
    The Postal Service proposes two systems for measuring the hard-copy 
green card Return Receipt service. First, it proposes to undertake an 
annual special study by employing ``an external vendor to periodically 
test transit times from induction to delivery for hard copy Return 
Receipt cards, using anonymous dropper/reporters who would drop the 
cards in collection boxes and other induction points throughout the 
postal network to simulate the deposit of Return Receipt green cards 
being mailed back to senders.'' Id. at 6. Second, it ``proposes to 
qualitatively measure hard copy Return Receipt customers' experiences 
versus their expectations.'' Id. at 8. This is proposed to be done 
through modification of existing Postal Service customer surveys.
    It is noted that the Postal Service expresses concerns with 
implementing a green card Return Receipt service measurement system. 
First, it cites significant costs associated with making adjustments to 
existing systems or to

[[Page 49197]]

developing external measurement systems. Second, the Postal Service 
examines the feasibility of applying barcodes to the green cards, but 
dismisses this idea because it might cause a fundamental change in the 
product with cost and fee implications. Third, it examines an EXFC-
based approach, but determines that the approach that it eventually 
proposes is more streamlined and economical. Finally, it discusses 
problems with the potential lag times involved in providing the 
service, and the inability of the Postal Service to ensure that the 
green cards are properly completed.
    The Commission still finds the Postal Service's proposals for 
measuring the green card Return Receipt service lacking by not 
measuring the service expectations of a customer purchasing the 
service. The proposal to measure green card transit times by dropping 
green cards into the system does little more than measure the transit 
time of a First-Class Mail card. This information is readily available. 
The Postal Service proposal to survey customer satisfaction with green 
card Return Receipt service is a measure of customer satisfaction and 
not service performance. Reporting of customer satisfaction is reported 
separately under the PAEA.
    Two sections in the Domestic Mail Manual appear particularly 
applicable to the expectations of customers purchasing green card 
Return Receipt:

    The mailpiece may not be opened or given to the recipient before 
the recipient signs and legibly prints his or her name on the 
delivery receipt (and return receipt, if applicable) and returns the 
receipt(s) to the USPS employee.

DMM section 508.1.1.7(b).

    A notice is left for a mailpiece that cannot be delivered. If 
the piece is not called for or redelivery is not requested, the 
piece is returned to the sender after 15 days (5 days for Express 
Mail, 30 days for COD) unless the sender specifies fewer days on the 
piece.

DMM section 508.1.1.7(f).

    Paragraph 508.1.1.7(b) specifies what action the purchaser of the 
service expects from the Postal Service when presenting a mailpiece to 
a potential recipient. Simplistically, the recipient does not obtain 
possession of the mailpiece prior to the Postal Service employee 
obtaining a signature on the green card. Paragraph 508.1.1.7(f) 
specifies what action the purchaser of the service expects from the 
Postal Service if a signature cannot be obtained. It also places time 
constraints (not including transit times) on the performance of the 
service that also can be used in a measurement system.
    The Commission recommends that the Postal Service develop a 
measurement system taking the above into consideration. An EXFC-based 
system would appear appropriate. Outgoing EXFC mail could be seeded 
with green Return Receipt cards. After mailing, a Postal Service 
employee would present the mailpiece to the potential recipient for 
signature. If a signature is obtained, the Postal Service employee 
would deposit the green card into the mail system for return to the 
sender. The original sender would record return of the green card and 
verify that it has been signed, if and when the card is received. If a 
signature is not obtained within the applicable timeframe, the Postal 
Service employee would return the unsigned mailpiece to the original 
sender. The original sender would record return of the mailpiece, if 
and when the mailpiece is received. A 25- to 30-day time limit could be 
placed for all events to occur; otherwise, a service failure would be 
recorded. On a quarterly basis, the Postal Service could report: (1) 
The number of EXFC seed mailpieces sent; (2) the percentage of green 
cards properly completed and returned (passing); (3) the percentage of 
green cards not properly completed, but returned (failure); (4) the 
percentage of mailpieces returned without a green card signature 
(passing); and (5) the percentage of the time the service receives a 
passing grade. This would be with respect to the applicable time limits 
as discussed above. On an annual basis, the Postal Service would report 
the percentage of the time the service receives a passing grade as part 
of the Ancillary Services score.
    Many variations of the Commission's suggestion are possible. The 
Postal Service is instructed to provide a response, or suggestions of 
its own, in its reply to this rulemaking.

VI. Reporting of Customer Satisfaction

A. General Considerations

    This rulemaking proposes to incorporate the rules for reporting of 
customer satisfaction into new subpart C--Annual Reporting of Customer 
Satisfaction of Part 3055--Service Performance and Customer 
Satisfaction Reporting of the Commission's rules of practice and 
procedure. The rules proposed for incorporation into subpart C appear 
after the signature of this Order. Table VII-4--Illustrative Customer 
Satisfaction Data Reporting Charts provides a visualization of the 
annual data reporting elements proposed by the rules through 
illustrative examples of data reporting charts. A rule-by-rule 
description of subpart C follows.
    Section 3055.90 specifies the general requirement for the Postal 
Service to file a report on customer satisfaction as part of its annual 
compliance report, unless more frequent reporting is specifically 
requested. See 39 U.S.C. 3652(a)(2)(B)(ii).

B. Section 3055.91--Customer Access to Postal Services

    Measuring customer access to postal services is an important aspect 
of customer satisfaction and a critical aspect of evaluating universal 
service. Section 3055.91 requires providing information covering four 
areas of customer access. First, it requests information on the number 
and types of post offices servicing the public. This also includes 
information on the number of post offices closed and the number of post 
offices subject to emergency suspensions during the year. This 
information is to be disaggregated by the types of post offices as 
appearing in the Postal Service's Annual Report. Second, it seeks 
information pertaining to the number and type of delivery points 
accessed by the Postal Service. Third, it requests information 
pertaining to the number of collection boxes accessed by the Postal 
Service. Finally, it seeks information on customer wait time in line 
for retail services.\25\
---------------------------------------------------------------------------

    \25\ Statistics on wait time in line are of general interest and 
are to be reported separately as required by this section. It is 
understood that these statistics may be obtained through the Mystery 
Shopper Program, or other similar surveys, and also reported 
elsewhere.
---------------------------------------------------------------------------

    The rules propose reporting of customer access to postal services 
on an annual basis. While this frequency of reporting may suffice given 
a long-term outlook, customer access is currently a high visibility 
issue. News reports appear almost daily concerning potential post 
office closings and the removal of collection boxes. This has generated 
significant consumer and congressional interest evident by frequent 
inquiries received by the Commission. As with any data reporting 
requirement, the Commission also is aware that reporting requirements 
impose costs on the postal system. Additional systems may have to be 
put in place to obtain and report the requested customer access data 
items if such systems do not already exist.
    As a compromise to obtaining current information and limiting long-
term costs, the Commission suggests that in the short term, the Postal 
Service provide customer access data items on a quarterly basis. Once 
the current decline in mail volume ebbs and the Postal Service reaches 
its new state of equilibrium, annual reports should

[[Page 49198]]

suffice. This compromise would provide the Commission with the 
immediate information that it needs to be responsive to consumers and 
Congress without imposing undue costs or unnecessary burden on the 
Postal Service in the long run. The Commission seeks comments from the 
Postal Service and others on how best to keep the Commission apprised 
of these issues such that the Commission can fulfill its 
responsibilities in a knowledgeable manner.

C. Section 3055.92--Customer Satisfaction Surveys

    The Postal Service regularly solicits feedback from its customers 
through a series of customer satisfaction surveys. The Postal Service 
has asserted that it intends to redesign its Customer Satisfaction 
Measurement Survey to meet the requirements of the PAEA and to generate 
customer satisfaction data on a product-by-product basis.\26\ Any 
enlightened business will find it good practice to stay current on its 
customers' preferences and needs, including how its customers perceive 
existing product offerings and services. Properly obtaining and 
analyzing information from customers will prove extremely valuable in 
evaluating customer satisfaction as required by the PAEA, and as a 
necessary good business practice. Because product offerings and 
services along with customer perceptions will change over time, the 
form and content of customer satisfaction surveys also must change over 
time. Given the Commission's independent perspective and its role in 
providing an alternative avenue o