Complaint About Postal Services, 52718-52720 [2011-21415]
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52718
Federal Register / Vol. 76, No. 163 / Tuesday, August 23, 2011 / Notices
Weeks of August 22, 29,
September 5, 12, 19, 26, 2011.
PLACE: Commissioners’ Conference
Room, 11555 Rockville Pike, Rockville,
Maryland.
STATUS: Public and Closed.
DATE:
Week of August 22, 2011
There are no meetings scheduled for
the week of August 22, 2011.
Week of August 29, 2011—Tentative
Tuesday, August 30, 2011
8:55 a.m. Affirmation Session (Public
Meeting) (Tentative)
Final Rule: Enhancements to
Emergency Preparedness
Regulations (10 CFR parts 50 and 10
CFR part 52) (RIN—3150–Al10)
(Tentative)
This meeting will be webcast live at
the Web address—https://www.nrc.gov.
9 a.m. Information Briefing on
Inspections, Tests, Analyses, and
Acceptance Criteria (ITAAC),
Related Activities (Public Meeting)
(Contact: Aida Rivera-Varona, 301–
415–4001)
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the Web address—https://www.nrc.gov.
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the week of September 5, 2011.
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the week of September 19, 2011.
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Week of September 26, 2011—Tentative
Tuesday, September 27, 2011
9 a.m. Mandatory Hearing—Southern
Nuclear Operating Co., et al.;
Combined Licenses for Vogtle
Electric Generating Plant, Units 3
and 4, and Limited Work
Authorizations (Public Meeting)
(Contact: Rochelle Bavol, 301–415–
1651)
This meeting will be webcast live at
the Web address—www.nrc.gov.
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The schedule for Commission
meetings is subject to change on short
notice. To verify the status of meetings,
call (recording)—(301) 415–1292.
Contact person for more information:
Rochelle Bavol, (301) 415–1651.
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The NRC Commission Meeting
Schedule can be found on the Internet
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The NRC provides reasonable
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contact the Office of the Secretary,
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or send an e-mail to
darlene.wright@nrc.gov.
August 18, 2011.
Rochelle C. Bavol,
Policy Coordinator, Office of the Secretary.
[FR Doc. 2011–21626 Filed 8–19–11; 4:15 pm]
BILLING CODE 7590–01–P
POSTAL REGULATORY COMMISSION
[Docket No. C2011–2; Order No. 808]
Complaint About Postal Services
Postal Regulatory Commission.
Notice.
AGENCY:
ACTION:
San Francisco, in its
municipal capacity, has filed a formal
complaint alleging that there
deficiencies in the Postal Service’s
delivery of mail to residents of certain
multi-unit buildings, and that the Postal
Service is therefore not acting in
conformance with statutory
requirements. This document identifies
the grounds for the complaint, reviews
key developments, and addresses
certain procedural matters, including
authorization of settlement negotiations.
DATES: The settlement coordinator’s
report is due September 15, 2011.
ADDRESSES: Submit comments
electronically by accessing the ‘‘Filing
Online’’ link in the banner at the top of
the Commission’s Web site (https://
www.prc.gov) or by directly accessing
the Commission’s Filing Online system
at https://www.prc.gov/prc-pages/filingonline/login.aspx. Commenters who
cannot submit their views electronically
should contact the person identified in
the FOR FURTHER INFORMATION CONTACT
section as the source for case-related
SUMMARY:
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information for advice on alternatives to
electronic filing.
FOR FURTHER INFORMATION CONTACT:
Stephen L. Sharfman, General Counsel,
at 202–789–6820 (case-related
information) or DocketAdmins@prc.gov
(electronic filing assistance).
SUPPLEMENTARY INFORMATION:
I. Introduction
II. Postal Service Pleadings
III. Statutory Alternatives for Commission
Action
IV. Analysis and Written Determination
V. Ordering Paragraphs
I. Introduction
A. Procedural Context
The instant Complaint was filed with
the Commission on May 18, 2011.1 It
involves two statutory claims about the
mode of delivery the Postal Service
provides to residents of single-room
occupancy buildings (SROs) in San
Francisco, California.
The impetus for the Complaint stems
from three developments that span more
than 5 years. The first was a growing
concern, on the part of the City and
County of San Francisco (San Francisco
or Complainant) about the reliability
and security of mail delivery to
residents of SROs. Delivery to SROs
generally occurs under Postal Service
regulations specifying the ‘‘singlepoint’’ mode of delivery for hotels,
schools and similar places. This means
a letter carrier typically leaves a mail
bag at or in the building, such as at the
doorstep, in the lobby or at a central
desk.2 Building management is
responsible for delivering the mail to
residents and for handling other tasks,
such as forwarding. This contrasts with
centralized delivery, where a letter
carrier delivers mail pursuant to a
regulation covering the residents of a
multi-unit building, such as an
apartment building, via individual,
locked mailboxes.3
2006 ordinance. The second
development was San Francisco’s
adoption, in 2006, of an ordinance
aimed at addressing its concerns about
SRO mail delivery. Complaint at 2. The
ordinance required SRO owners to
install (by the end of 2007) individual,
secure, Postal Service-compliant
mailboxes for each resident. San
Francisco asserts that prior to adoption
of the ordinance, there was at least one
conversation with a Postal Service
employee indicating that installation of
Postal Service-approved mailbox
installations in SROs would result in a
1 Complaint of the City and County of San
Francisco, May 18, 2011 (Complaint).
2 See POM § 615.2 (single-point delivery).
3 See POM § 631.45 (centralized delivery).
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Federal Register / Vol. 76, No. 163 / Tuesday, August 23, 2011 / Notices
switch from single-point delivery to
centralized delivery.
Following adoption of the ordinance,
some SRO owners installed individual
mailboxes and the Postal Service
apparently began delivering mail to
residents of these SROs via centralized
delivery. However, this practice was
later reviewed (as part of a broader
evaluation) and found to be contrary to
the postal regulation that establishes
single-point delivery as the appropriate
mode of delivery for SROs. The Postal
Service informed a city official that it
would continue to deliver mail via
centralized delivery to SROs where
individual mailboxes had been
installed, but would use single-point
delivery for all others, including those
that installed individual mailboxes in
the future. See id. Exh. 1 at 1–2.
Federal lawsuit. The third
development was San Francisco’s filing
of a Federal lawsuit in 2009. The
grounds, in brief, were that the Postal
Service’s post-ordinance actions raise
constitutional questions and regulatory
(title 39) issues.4 The court dismissed
the regulatory issues (finding them
within the Commission’s purview), but
retained jurisdiction over the
constitutional claims. At this point, the
record shows that the Federal lawsuit is
still pending. A lengthy discovery phase
is nearing an end; dispositive motions
are to be heard by October 13, 2011; and
a trial date has been set for January 9,
2012. See Answer of the United States
Postal Service, August 8, 2011, Exh. 1
(Answer).
B. The Commission’s Section 3662
Jurisdiction
Commission jurisdiction over formal
complaints is set out in section 3662(a).
This section provides:
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Any interested person * * * who believes
the Postal Service is not operating in
conformance with the requirements of the
provisions of sections 101(d), 401(2), 403(c),
404a, or 601, or this chapter (or regulations
promulgated under any of those provisions)
may lodge a complaint with the Postal
Regulatory Commission * * *.
39 U.S.C. 3662(a).
San Francisco generally claims that
there are deficiencies in the Postal
Service’s delivery of mail to most SRO
residents in California, and that these
deficiencies cause harm to the affected
residents and to San Francisco.
Complaint at 1. For purposes of
establishing Commission jurisdiction, it
relies on two of the provisions
identified in section 3662: sections
401(2) and 403(c). Section 401(2) grants
4 City of San Francisco, et al. v. United States
Postal Service, N.D. Cal. (1964).
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the Postal Service, as one of its general
powers, the authority to adopt, amend,
and repeal any rules and regulations
necessary to the execution of its
statutory functions, to the extent such
rules and regulations are not
inconsistent with title 39. 39 U.S.C.
401(2). Section 403(c) states that in
providing services under title 39 ‘‘the
Postal Service shall not, except as
specifically authorized in this title,
make any undue or unreasonable
discrimination among users of the
mails, nor shall it grant any undue or
unreasonable preferences to any such
user.’’ 39 U.S.C. 403(c).
C. The Nexus Between Complainant’s
Assertions and Section 3662
Jurisdiction
The asserted link to section 401(2).
San Francisco’s reading of postal
regulations leads it to conclude that
mail delivery to residents of SROs
should be provided under centralized
delivery regulations, rather than under
regulations for single-point delivery,
assuming the SRO has individual,
locked mailboxes. It maintains that the
Postal Service erroneously classifies
SROs under the delivery regulation for
hotels and schools, and is therefore
failing to enforce its own regulations.
Complaint at 16.
The asserted link to section 403(c).
San Francisco asserts that the Postal
Service’s decision to use single-point
delivery for residents of SROs reflects
their socioeconomic status, especially
relative to apartment dwellers, and
unfounded assumptions about the
transience of SRO residents, and
therefore unduly discriminates against
SRO residents and grants an undue
preference to apartment dwellers in
violation of 39 U.S.C. 403(c). Id. at 12.
II. Postal Service Pleadings
On June 7, 2011, the Postal Service
filed a motion seeking dismissal of
count 1 of the two-count Complaint.5
The basis was lack of jurisdiction under
section 401(2). The Postal Service did
not seek dismissal of count 2, stating
instead that the Complainant arguably
set out a claim with respect to undue
discrimination. Id. at 2. The
Complainant filed an opposition to the
Motion.6 The Commission granted the
Motion, in part, by striking allegations
in count 1 that correspondence between
the San Francisco Postmaster and a city
5 Motion of United States Postal Service for
Partial Dismissal of the Complaint, June 7, 2011
(Motion).
6 City and County of San Francisco’s Answer in
Opposition to Motion of United States Postal
Service for Partial Dismissal of the Complaint, June
15, 2011.
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52719
official had not been adopted pursuant
to Federal rulemaking procedures.7 This
disposition led to the filing of the Postal
Service’s Answer on August 8, 2011.
In its Answer, the Postal Service
serially addresses each paragraph,
providing responses that admit, deny,
disclaim sufficient knowledge to the
assertion, or state no response is
needed. With respect to points central to
the Complaint, it denies that San
Francisco has alleged any ‘‘deficiencies’’
in mail delivery service and that ‘‘the
socioeconomic circumstances of
delivery customers matter when making
decisions about the appropriate mode of
delivery.’’ Answer at 1–2. The Postal
Service also denies the applicability of
POM 631.45, contending the controlling
regulation is POM 615.2, Mail
Addressed to Persons at Hotels, Schools,
and Similar Places. Id. at 4. It adds that
San Francisco has not made any
showing, as required under POM 631.6
(Conversion of Mode of Delivery) that
conversion to another mode of delivery
is warranted. Id.
Significantly, the Postal Service also
states that it ‘‘would not object to
delivering mail at those locations by
placing it into a locked receptacle
* * *.’’ Id. at 3.
III. Statutory Alternatives for
Commission Action
The Commission has two affirmative
alternatives for handling a section 3662
complaint under section 3662(b). One is
to begin proceedings upon a finding that
the complaint raises material issues of
fact or law. 39 U.S.C. 3662(b)(1)(A)(i).8
The other alternative is to issue an order
dismissing the complaint. 39 U.S.C.
3662(b)(1)(A)(ii). Action under either
alternative is to be taken within 90 days
and supported by a written statement
setting forth the basis for the
determination. 39 U.S.C. 3662(b)(1) and
3662(b)(1)(B).
IV. Analysis and Written Determination
The parties recognize that the Postal
Service’s current delivery practices do
differentiate between residents of many
SROs in San Francisco and apartment
dwellers. Thus, the current issue before
the Commission is whether the
pleadings indicate that there are
material questions of fact and law on
this point.
In its Complaint, San Francisco
concludes that in light of the parties’
inability to resolve their dispute during
mediation associated with the Federal
7 Order Granting, in Part, Postal Service Motion
To Dismiss Count 1, July 29, 2011.
8 The statute does not specify the precise nature
of the proceedings.
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Federal Register / Vol. 76, No. 163 / Tuesday, August 23, 2011 / Notices
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lawsuit, it believes that additional steps
to settle this matter prior to the filing of
this Complaint would have been futile.
Complaint at 15–16. However, as
referenced above, the Postal Service
Answer contains what appears to be a
good faith offer to address the concerns
that initially motivated this controversy
by providing a new delivery option for
residents of most SROs in San
Francisco: delivery of the mail to a
locked receptacle, with management
continuing to be responsible from that
point. The Commission views the Postal
Service’s offer as an attempt to
appropriately balance the concerns of
the Complainant (for more security and
reliability in mail delivery) and the
Postal Service (for efficiency and
effectiveness, including the cost
implications of adding numerous
delivery points at an especially critical
financial time).9
The Commission therefore defers
action on this Complaint and directs
that the parties begin settlement
negotiations based on the Postal
Service’s offer. Pursuant to 39 U.S.C.
505, the Commission designates James
Waclawski as officer of the Commission
(Public Representative) to represent the
interests of the public. The Public
Representative shall also serve as
settlement coordinator. The
Commission strongly believes that all
concerned would be best served by a
negotiated settlement of this matter. It
directs the Public Representative to file
a report on the progress of settlement
within 30 days of the issuance of this
order.
V. Ordering Paragraphs
It is ordered:
1. The Commission defers its decision
on whether the Complaint of the City
and County of San Francisco presents
material questions of fact and law,
pending settlement discussions between
the parties.
2. The Commission directs the
Complainant and the Postal Service to
immediately engage in settlement
negotiations with the goal of
expeditiously resolving this controversy
based on the Postal Service’s offer.
3. The Commission, pursuant to
section 505, appoints James Waclawski
to serve as Public Representative in this
proceeding and to serve as settlement
coordinator.
4. The Commission directs the
settlement coordinator to file a report
within 30 days of the date of this order.
5. The Commission directs the
Secretary of the Commission to arrange
9 San Francisco states that 18,000 San Franciscans
live in SROs. Id. at 6.
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16:33 Aug 22, 2011
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for publication of this order in the
Federal Register.
By the Commission.
Shoshana M. Grove,
Secretary.
[FR Doc. 2011–21415 Filed 8–22–11; 8:45 am]
BILLING CODE 7710–FW–P
POSTAL REGULATORY COMMISSION
[Docket No. A2011–47; Order No. 805]
Post Office Closing
Postal Regulatory Commission.
Notice.
AGENCY:
ACTION:
This document informs the
public that an appeal of the closing of
the Francitas, Texas post office has been
filed. It identifies preliminary steps and
provides a procedural schedule.
Publication of this document will allow
the Postal Service, petitioners, and
others to take appropriate action.
DATES: Administrative record due (from
Postal Service): August 30, 2011;
deadline for notices to intervene:
September 12, 2011. See the Procedural
Schedule in the SUPPLEMENTARY
INFORMATION section for other dates of
interest.
SUMMARY:
Submit comments
electronically by accessing the ‘‘Filing
Online’’ link in the banner at the top of
the Commission’s Web site (https://
www.prc.gov) or by directly accessing
the Commission’s Filing Online system
at https://www.prc.gov/prc-pages/filingonline/login.aspx. Commenters who
cannot submit their views electronically
should contact the person identified in
the FOR FURTHER INFORMATION CONTACT
section as the source for case-related
information for advice on alternatives to
electronic filing.
FOR FURTHER INFORMATION CONTACT:
Stephen L. Sharfman, General Counsel,
at 202–789–6820 (case-related
information) or DocketAdmins@prc.gov
(electronic filing assistance).
SUPPLEMENTARY INFORMATION: Notice is
hereby given that, pursuant to 39 U.S.C.
404(d), on August 15, 2011, the
Commission received a petition for
review of the Postal Service’s
determination to close the post office in
Francitas, Texas. The petition was filed
by Carolina Jalufka (Petitioner) and is
postmarked August 6, 2011. The
Commission hereby institutes a
proceeding under 39 U.S.C. 404(d)(5)
and establishes Docket No. A2011–47 to
consider Petitioner’s appeal. If
Petitioner would like to further explain
her position with supplemental
information or facts, Petitioner may
ADDRESSES:
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Sfmt 4703
either file a Participant Statement on
PRC Form 61 or file a brief with the
Commission no later than September 19,
2011.
Categories of issues apparently raised.
Petitioner contends that the Postal
Service failed to consider the effect of
the closing on the community. See 39
U.S.C. 404(d)(2)(A)(i).
After the Postal Service files the
administrative record and the
Commission reviews it, the Commission
may find that there are more legal issues
than those set forth above, or that the
Postal Service’s determination disposes
of one or more of those issues. The
deadline for the Postal Service to file the
applicable administrative record with
the Commission is August 30, 2011. See
39 CFR 3001.113. In addition, the due
date for any responsive pleading by the
Postal Service to this notice is August
30, 2011.
Availability; Web site posting. The
Commission has posted the appeal and
supporting material on its Web site at
https://www.prc.gov. Additional filings
in this case and participants’
submissions also will be posted on the
Commission’s Web site, if provided in
electronic format or amenable to
conversion, and not subject to a valid
protective order. Information on how to
use the Commission’s Web site is
available online or by contacting the
Commission’s webmaster via telephone
at 202–789–6873 or via electronic mail
at prc-webmaster@prc.gov.
The appeal and all related documents
are also available for public inspection
in the Commission’s docket section.
Docket section hours are 8 a.m. to 4:30
p.m., eastern time, Monday through
Friday, except on Federal government
holidays. Docket section personnel may
be contacted via electronic mail at prcdockets@prc.gov or via telephone at
202–789–6846.
Filing of documents. All filings of
documents in this case shall be made
using the Internet (Filing Online)
pursuant to Commission rules 9(a) and
10(a) at the Commission’s Web site,
https://www.prc.gov, unless a waiver is
obtained. See 39 CFR 3001.9(a) and
3001.10(a). Instructions for obtaining an
account to file documents online may be
found on the Commission’s Web site or
by contacting the Commission’s docket
section at prc-dockets@prc.gov or via
telephone at 202–789–6846.
The Commission reserves the right to
redact personal information which may
infringe on an individual’s privacy
rights from documents filed in this
proceeding.
Intervention. Persons, other than
Petitioner and respondent, wishing to be
heard in this matter are directed to file
E:\FR\FM\23AUN1.SGM
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Agencies
[Federal Register Volume 76, Number 163 (Tuesday, August 23, 2011)]
[Notices]
[Pages 52718-52720]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-21415]
=======================================================================
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POSTAL REGULATORY COMMISSION
[Docket No. C2011-2; Order No. 808]
Complaint About Postal Services
AGENCY: Postal Regulatory Commission.
ACTION: Notice.
-----------------------------------------------------------------------
SUMMARY: San Francisco, in its municipal capacity, has filed a formal
complaint alleging that there deficiencies in the Postal Service's
delivery of mail to residents of certain multi-unit buildings, and that
the Postal Service is therefore not acting in conformance with
statutory requirements. This document identifies the grounds for the
complaint, reviews key developments, and addresses certain procedural
matters, including authorization of settlement negotiations.
DATES: The settlement coordinator's report is due September 15, 2011.
ADDRESSES: Submit comments electronically by accessing the ``Filing
Online'' link in the banner at the top of the Commission's Web site
(https://www.prc.gov) or by directly accessing the Commission's Filing
Online system at https://www.prc.gov/prc-pages/filing-online/login.aspx. Commenters who cannot submit their views electronically
should contact the person identified in the FOR FURTHER INFORMATION
CONTACT section as the source for case-related information for advice
on alternatives to electronic filing.
FOR FURTHER INFORMATION CONTACT: Stephen L. Sharfman, General Counsel,
at 202-789-6820 (case-related information) or DocketAdmins@prc.gov
(electronic filing assistance).
SUPPLEMENTARY INFORMATION:
I. Introduction
II. Postal Service Pleadings
III. Statutory Alternatives for Commission Action
IV. Analysis and Written Determination
V. Ordering Paragraphs
I. Introduction
A. Procedural Context
The instant Complaint was filed with the Commission on May 18,
2011.\1\ It involves two statutory claims about the mode of delivery
the Postal Service provides to residents of single-room occupancy
buildings (SROs) in San Francisco, California.
---------------------------------------------------------------------------
\1\ Complaint of the City and County of San Francisco, May 18,
2011 (Complaint).
---------------------------------------------------------------------------
The impetus for the Complaint stems from three developments that
span more than 5 years. The first was a growing concern, on the part of
the City and County of San Francisco (San Francisco or Complainant)
about the reliability and security of mail delivery to residents of
SROs. Delivery to SROs generally occurs under Postal Service
regulations specifying the ``single-point'' mode of delivery for
hotels, schools and similar places. This means a letter carrier
typically leaves a mail bag at or in the building, such as at the
doorstep, in the lobby or at a central desk.\2\ Building management is
responsible for delivering the mail to residents and for handling other
tasks, such as forwarding. This contrasts with centralized delivery,
where a letter carrier delivers mail pursuant to a regulation covering
the residents of a multi-unit building, such as an apartment building,
via individual, locked mailboxes.\3\
---------------------------------------------------------------------------
\2\ See POM Sec. 615.2 (single-point delivery).
\3\ See POM Sec. 631.45 (centralized delivery).
---------------------------------------------------------------------------
2006 ordinance. The second development was San Francisco's
adoption, in 2006, of an ordinance aimed at addressing its concerns
about SRO mail delivery. Complaint at 2. The ordinance required SRO
owners to install (by the end of 2007) individual, secure, Postal
Service-compliant mailboxes for each resident. San Francisco asserts
that prior to adoption of the ordinance, there was at least one
conversation with a Postal Service employee indicating that
installation of Postal Service-approved mailbox installations in SROs
would result in a
[[Page 52719]]
switch from single-point delivery to centralized delivery.
Following adoption of the ordinance, some SRO owners installed
individual mailboxes and the Postal Service apparently began delivering
mail to residents of these SROs via centralized delivery. However, this
practice was later reviewed (as part of a broader evaluation) and found
to be contrary to the postal regulation that establishes single-point
delivery as the appropriate mode of delivery for SROs. The Postal
Service informed a city official that it would continue to deliver mail
via centralized delivery to SROs where individual mailboxes had been
installed, but would use single-point delivery for all others,
including those that installed individual mailboxes in the future. See
id. Exh. 1 at 1-2.
Federal lawsuit. The third development was San Francisco's filing
of a Federal lawsuit in 2009. The grounds, in brief, were that the
Postal Service's post-ordinance actions raise constitutional questions
and regulatory (title 39) issues.\4\ The court dismissed the regulatory
issues (finding them within the Commission's purview), but retained
jurisdiction over the constitutional claims. At this point, the record
shows that the Federal lawsuit is still pending. A lengthy discovery
phase is nearing an end; dispositive motions are to be heard by October
13, 2011; and a trial date has been set for January 9, 2012. See Answer
of the United States Postal Service, August 8, 2011, Exh. 1 (Answer).
---------------------------------------------------------------------------
\4\ City of San Francisco, et al. v. United States Postal
Service, N.D. Cal. (1964).
---------------------------------------------------------------------------
B. The Commission's Section 3662 Jurisdiction
Commission jurisdiction over formal complaints is set out in
section 3662(a). This section provides:
Any interested person * * * who believes the Postal Service is
not operating in conformance with the requirements of the provisions
of sections 101(d), 401(2), 403(c), 404a, or 601, or this chapter
(or regulations promulgated under any of those provisions) may lodge
a complaint with the Postal Regulatory Commission * * *.
39 U.S.C. 3662(a).
San Francisco generally claims that there are deficiencies in the
Postal Service's delivery of mail to most SRO residents in California,
and that these deficiencies cause harm to the affected residents and to
San Francisco. Complaint at 1. For purposes of establishing Commission
jurisdiction, it relies on two of the provisions identified in section
3662: sections 401(2) and 403(c). Section 401(2) grants the Postal
Service, as one of its general powers, the authority to adopt, amend,
and repeal any rules and regulations necessary to the execution of its
statutory functions, to the extent such rules and regulations are not
inconsistent with title 39. 39 U.S.C. 401(2). Section 403(c) states
that in providing services under title 39 ``the Postal Service shall
not, except as specifically authorized in this title, make any undue or
unreasonable discrimination among users of the mails, nor shall it
grant any undue or unreasonable preferences to any such user.'' 39
U.S.C. 403(c).
C. The Nexus Between Complainant's Assertions and Section 3662
Jurisdiction
The asserted link to section 401(2). San Francisco's reading of
postal regulations leads it to conclude that mail delivery to residents
of SROs should be provided under centralized delivery regulations,
rather than under regulations for single-point delivery, assuming the
SRO has individual, locked mailboxes. It maintains that the Postal
Service erroneously classifies SROs under the delivery regulation for
hotels and schools, and is therefore failing to enforce its own
regulations. Complaint at 16.
The asserted link to section 403(c). San Francisco asserts that the
Postal Service's decision to use single-point delivery for residents of
SROs reflects their socioeconomic status, especially relative to
apartment dwellers, and unfounded assumptions about the transience of
SRO residents, and therefore unduly discriminates against SRO residents
and grants an undue preference to apartment dwellers in violation of 39
U.S.C. 403(c). Id. at 12.
II. Postal Service Pleadings
On June 7, 2011, the Postal Service filed a motion seeking
dismissal of count 1 of the two-count Complaint.\5\ The basis was lack
of jurisdiction under section 401(2). The Postal Service did not seek
dismissal of count 2, stating instead that the Complainant arguably set
out a claim with respect to undue discrimination. Id. at 2. The
Complainant filed an opposition to the Motion.\6\ The Commission
granted the Motion, in part, by striking allegations in count 1 that
correspondence between the San Francisco Postmaster and a city official
had not been adopted pursuant to Federal rulemaking procedures.\7\ This
disposition led to the filing of the Postal Service's Answer on August
8, 2011.
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\5\ Motion of United States Postal Service for Partial Dismissal
of the Complaint, June 7, 2011 (Motion).
\6\ City and County of San Francisco's Answer in Opposition to
Motion of United States Postal Service for Partial Dismissal of the
Complaint, June 15, 2011.
\7\ Order Granting, in Part, Postal Service Motion To Dismiss
Count 1, July 29, 2011.
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In its Answer, the Postal Service serially addresses each
paragraph, providing responses that admit, deny, disclaim sufficient
knowledge to the assertion, or state no response is needed. With
respect to points central to the Complaint, it denies that San
Francisco has alleged any ``deficiencies'' in mail delivery service and
that ``the socioeconomic circumstances of delivery customers matter
when making decisions about the appropriate mode of delivery.'' Answer
at 1-2. The Postal Service also denies the applicability of POM 631.45,
contending the controlling regulation is POM 615.2, Mail Addressed to
Persons at Hotels, Schools, and Similar Places. Id. at 4. It adds that
San Francisco has not made any showing, as required under POM 631.6
(Conversion of Mode of Delivery) that conversion to another mode of
delivery is warranted. Id.
Significantly, the Postal Service also states that it ``would not
object to delivering mail at those locations by placing it into a
locked receptacle * * *.'' Id. at 3.
III. Statutory Alternatives for Commission Action
The Commission has two affirmative alternatives for handling a
section 3662 complaint under section 3662(b). One is to begin
proceedings upon a finding that the complaint raises material issues of
fact or law. 39 U.S.C. 3662(b)(1)(A)(i).\8\ The other alternative is to
issue an order dismissing the complaint. 39 U.S.C. 3662(b)(1)(A)(ii).
Action under either alternative is to be taken within 90 days and
supported by a written statement setting forth the basis for the
determination. 39 U.S.C. 3662(b)(1) and 3662(b)(1)(B).
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\8\ The statute does not specify the precise nature of the
proceedings.
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IV. Analysis and Written Determination
The parties recognize that the Postal Service's current delivery
practices do differentiate between residents of many SROs in San
Francisco and apartment dwellers. Thus, the current issue before the
Commission is whether the pleadings indicate that there are material
questions of fact and law on this point.
In its Complaint, San Francisco concludes that in light of the
parties' inability to resolve their dispute during mediation associated
with the Federal
[[Page 52720]]
lawsuit, it believes that additional steps to settle this matter prior
to the filing of this Complaint would have been futile. Complaint at
15-16. However, as referenced above, the Postal Service Answer contains
what appears to be a good faith offer to address the concerns that
initially motivated this controversy by providing a new delivery option
for residents of most SROs in San Francisco: delivery of the mail to a
locked receptacle, with management continuing to be responsible from
that point. The Commission views the Postal Service's offer as an
attempt to appropriately balance the concerns of the Complainant (for
more security and reliability in mail delivery) and the Postal Service
(for efficiency and effectiveness, including the cost implications of
adding numerous delivery points at an especially critical financial
time).\9\
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\9\ San Francisco states that 18,000 San Franciscans live in
SROs. Id. at 6.
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The Commission therefore defers action on this Complaint and
directs that the parties begin settlement negotiations based on the
Postal Service's offer. Pursuant to 39 U.S.C. 505, the Commission
designates James Waclawski as officer of the Commission (Public
Representative) to represent the interests of the public. The Public
Representative shall also serve as settlement coordinator. The
Commission strongly believes that all concerned would be best served by
a negotiated settlement of this matter. It directs the Public
Representative to file a report on the progress of settlement within 30
days of the issuance of this order.
V. Ordering Paragraphs
It is ordered:
1. The Commission defers its decision on whether the Complaint of
the City and County of San Francisco presents material questions of
fact and law, pending settlement discussions between the parties.
2. The Commission directs the Complainant and the Postal Service to
immediately engage in settlement negotiations with the goal of
expeditiously resolving this controversy based on the Postal Service's
offer.
3. The Commission, pursuant to section 505, appoints James
Waclawski to serve as Public Representative in this proceeding and to
serve as settlement coordinator.
4. The Commission directs the settlement coordinator to file a
report within 30 days of the date of this order.
5. The Commission directs the Secretary of the Commission to
arrange for publication of this order in the Federal Register.
By the Commission.
Shoshana M. Grove,
Secretary.
[FR Doc. 2011-21415 Filed 8-22-11; 8:45 am]
BILLING CODE 7710-FW-P