Market Dominant Products, 8330-8334 [2021-01500]
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Federal Register / Vol. 86, No. 23 / Friday, February 5, 2021 / Proposed Rules
(2) Jet skis and vessels without
mechanical propulsion are prohibited
from the parade route.
(3) Vessels less than 10 feet in length
are prohibited from the parade route
unless capable of safely participating.
(4) Vessels found to be unsafe to
participate at the discretion of a present
law enforcement officer are prohibited
from the parade route.
(5) Northbound vessels in excess of 65
feet in length without mooring
arrangement made prior to the date of
the event are prohibited from entering
Seddon Channel, unless the vessel is
officially entered in the Gasparilla
Marine Parade.
(6) Vessels not officially entered in
the Gasparilla Marine Parade may not
enter the parade staging area box within
the following coordinates: 27°53′53″ N,
082°27′47″ W; 27°53′22″ N, 082°27′10″
W; 27°52′36″ N, 082°27′55″ W;
27°53′02″ N, 082°28′31″ W.
(7) Designated representatives may
control vessel traffic throughout the
enforcement area as determined by the
prevailing conditions.
(8) Persons and vessels may request
authorization to enter, transit through,
anchor in, or remain within the
regulated areas by contacting the COTP
St. Petersburg by telephone at (727)
824–7506, or a designated
representative via VHF radio on channel
16. If authorization is granted, all
persons and vessels receiving such
authorization must comply with the
instructions of the COTP St. Petersburg
or a designated representative.
(d) Enforcement Period. This rule will
be enforced from 9 a.m. to 6 p.m. on
April 17, 2021.
Dated: January 13, 2021.
Matthew A. Thompson,
Captain, U.S. Coast Guard, Captain of the
Port St. Petersburg.
[FR Doc. 2021–02172 Filed 2–4–21; 8:45 am]
BILLING CODE 9110–04–P
POSTAL REGULATORY COMMISSION
39 CFR Part 3030
[Docket No. RM2021–2; Order No. 5816]
Market Dominant Products
Postal Regulatory Commission.
Advance notice of proposed
rulemaking.
Enhancement Act (PAEA) particularly
related to maximizing incentives to
increase efficiency and reduce costs,
maintaining high-quality service
standards, and assuring financial
stability (including retained earnings).
This advance notice informs the public
of the docket’s initiation, invites public
comment, and takes other
administrative steps.
DATES:
Comments are due: April 15, 2021.
Reply comments are due: May 17,
2021.
Submit comments
electronically via the Commission’s
Filing Online system at https://
www.prc.gov. Those who cannot submit
comments electronically should contact
the person identified in the FOR FURTHER
INFORMATION CONTACT section by
telephone for advice on filing
alternatives.
ADDRESSES:
FOR FURTHER INFORMATION CONTACT:
David A. Trissell, General Counsel, at
202–789–6820.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Introduction
II. Background
III. Substantive Areas for Further Refinement
IV. Administrative Actions
V. Ordering Paragraphs
I. Introduction
Pursuant to 39 U.S.C. 3622(d)(3), the
Commission issues this advance notice
of proposed rulemaking to seek input
from the public about what additional
regulations promulgated by the
Commission may be necessary to
achieve the objectives of the Postal
Accountability and Enhancement Act
(PAEA) 1 over the longer-term,
particularly related to maximizing
incentives to increase efficiency and
reduce costs, maintaining high-quality
service standards, and assuring financial
stability (including retained earnings).
II. Background
In Docket No. RM2017–3, the
Commission found that the existing
Market Dominant ratemaking system
did not achieve the PAEA’s objectives
during the 10 years following the
PAEA’s enactment.2 The Commission’s
AGENCY:
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ACTION:
The Commission is initiating
a review seeking input from the public
about what additional regulations
promulgated by the Commission may be
necessary to achieve the objectives of
the Postal Accountability and
SUMMARY:
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1 Public Law 109–435, 201, 120 Stat. 3198, 3204
(2006).
2 See Docket No. RM2017–3, Order Adopting
Final Rules for the System of Regulating Rates and
Classes for Market Dominant Products, November
30, 2020, at 2 (Order No. 5763); see also Docket No.
RM2017–3, Revised Notice of Proposed
Rulemaking, December 5, 2019, at 7 (Order No.
5337); Docket No. RM2017–3, Notice of Proposed
Rulemaking for the System for Regulating Rates and
Classes for Market Dominant Products, December 1,
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findings were premised in part on the
existing ratemaking system’s inability to
assure financial stability (including
retained earnings), maximize incentives
to reduce costs and increase efficiency,
and maintain high-quality service
standards. See Order No. 4257 at 3–5,
274–275. During the PAEA era, the
existing ratemaking system was
inadequate, which resulted in an
accumulated deficit,3 maximum use of
the Postal Service’s borrowing authority
and a sharp decline in capital
investments,4 operational efficiency
increases and cost reductions that were
insufficient to achieve overall financial
stability and/or retained earnings,5 and
reduction of the high-quality service
standards that were set in 2007.6
In response, the Commission
modified the ratemaking system’s
design to encourage and enable the
Postal Service to address its complex
challenges by making prudent pricing
and operational decisions. See Order
No. 5763 at 285. Among other changes
made, the modified rules provide
additional rate authority to address two
underlying drivers of the Postal
Service’s net losses that are largely
outside of its direct and near-term
control: (1) The increase in per-unit cost
resulting from the decline in mail
density for each fiscal year under
subpart D of 39 CFR part 3030 of this
chapter; and (2) the statutorily
mandated amortization payments for
particular retirement costs under
subpart E of 39 CFR part 3030 of this
chapter. See id. These principled
adjustments to the price cap made by
the Commission in Docket No. RM2017–
2017, at 26 (Order No. 4258); Docket No. RM2017–
3, Order on the Findings and Determination of the
39 U.S.C. 3622 Review, December 1, 2017, at 3–5,
274–275 (Order No. 4257).
3 See Order No. 4257 at 171–172 (describing how
the consecutive net losses resulted in an
accumulated deficit).
4 The Postal Service lacks shareholders and
instead must finance capital investments through
revenue or through borrowing. Order No. 4258 at
48–49. Therefore, as consecutive years of net losses
resulted in an accumulated deficit, the Postal
Service relied heavily on its borrowing authority,
deferred capital investments, and increased its cash
reserves. See id. at 46–52.
5 Order No. 4257 at 222, 274–275 (summarizing
that while some cost reductions and efficiency
gains were achieved post-PAEA, they were
insufficient to achieve financial stability in the
medium term and long term).
6 Id. at 273. The two major service standard
changes in the first 10 years after the passage of the
PAEA were reviewed by the Commission, prior to
implementation, in Docket Nos. N2012–1 and
N2014–1. The ‘‘Network Rationalization’’ initiative
implemented by the Postal Service included
changes to the service standards for First-Class
Mail, Periodicals, USPS Marketing Mail, and
Package Services. The ‘‘Load Leveling’’ initiative
included changes to the service standards for USPS
Marketing Mail. Id. at 264–273.
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3 are necessary to achieve the objectives
of the PAEA, in conjunction with each
other, and are focused on vital near-term
improvements.
However, the objectives of the PAEA
related to maximizing incentives to
increase efficiency and reducing costs as
well as assuring financial stability
(including retained earnings) set forth
ambitious goals that are difficult to
achieve instantaneously or
simultaneously. See 39 U.S.C.
3622(b)(1) and (5). These goals must
also be achieved in conjunction with
other priorities over time, such as
maintaining high-quality service
standards. See id. section 3622(b)(3).
Consistent with the Commission’s
findings in Docket No. RM2017–3,
Docket No. RM2021–2 is initiated to
explore whether additional regulatory
changes may be necessary to promote
longer-term financial stability, increased
efficiency and cost reductions, while
maintaining high-quality service
standards, and if so, how to best design
these potential changes. See Order No.
5763 at 166. The Commission invites
any interested party to submit
comments on the following topics and
asks the following questions to initiate
a meaningful dialogue with
stakeholders.
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III. Substantive Areas for Further
Refinement
A. Incentive Regulation
Performance-based regulation is a
broad concept referring to a regulatory
system that applies incentives to
promote targeted behavior by the
regulated entity.7 More specifically, a
performance incentive mechanism
(PIM), also referred to as a targeted
performance incentive (TPI), is used by
regulators to set a target for acceptable
performance by the regulated entity in
a specific area and attach financial
consequences to ensure compliance. See
Zarakas, supra. This rulemaking is
initiated to explore whether and how to
introduce any potential modifications to
the design of the ratemaking system that
would further enhance (i.e., maximize
over the longer-term) the Postal
Service’s incentives to increase
efficiency and reduce costs. Achieving
such efficiencies could benefit the
Postal Service by improving its longerterm financial viability and could
benefit the ratepayers by leading to
improved service performance. At the
7 See William Zarakas, A New Face for PBR:
Aligning Incentives in the Electric Utility
Ecosystem, PUB. UTILS. FORT., December 2017
(Zarakas), available at: https://www.fortnightly.com/
fortnightly/2017/12/new-face-pbr?authkey
=e0a4230ee85eb602f123c1e633c0e5b5260f9bd3f
297c094c055e7868e5a4589.
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same time, the Commission remains
mindful that further enhancing the
Postal Service’s incentives to increase
efficiency and reduce costs may weaken
the incentive to maintain high-quality
service standards. The Commission also
acknowledges that ratepayers may have
different preferences with respect to the
speed and/or the consistency of delivery
service for Market Dominant products.
Accordingly, to explore possible
enhancements to the Market Dominant
ratemaking system overall, through the
introduction of direct financial
consequences (such as an upward or
downward adjustment to rate authority)
using a PIM or a different method, the
Commission raises the following
discussion points:
1. Whether additional regulatory
changes are needed to further enhance
the Postal Service’s incentives to
increase efficiency and reduce costs
while maintaining high-quality service
standards. Why or why not?
2. How to identify and evaluate
potential types of regulatory changes
that would introduce direct financial
consequences that would further
enhance the Postal Service’s incentives
to increase efficiency and reduce costs
while maintaining high-quality service
standards? Are there any financial
consequences that can be drawn from
other postal systems or other regulated
industries that should be considered?
3. How to identify and evaluate
potential types of regulatory changes
other than the connection of direct
financial consequences that would
further enhance the Postal Service’s
incentives to increase efficiency and
reduce costs while maintaining highquality service standards? Are there any
non-financial incentives that can be
drawn from other postal systems or
other regulated industries that should be
considered?
B. Mechanism for a Financial Incentive
The Commission is interested in
exploring whether a regulatory
mechanism connecting direct financial
consequences with increasing efficiency
and reducing costs and maintaining
high-quality service standards would
benefit the Market Dominant ratemaking
system, and how to connect the Postal
Service’s behavior with the financial
incentive introduced. The Commission
acknowledges that every proposal has
tradeoffs and that it is impossible to
refine the connection to a level of
absolute precision.8 This rulemaking
8 See Nat’l Ass’n of Broadcasters v. F.C.C., 740
F.2d 1190, 1210 (D.C. Cir. 1984) (‘‘But
administrative action generally occurs against a
shifting background in which facts, predictions, and
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8331
does not aim for this level of precision.
Generally, the Commission seeks to
identify an amount of a financial
incentive that is both meaningful to the
Postal Service (i.e., would actually
motivate it to engage in the desired
behavior) and would neither be
excessive to the ratepayers nor threaten
the financial integrity of the Postal
Service.
Preliminarily, the Commission is
interested in exploring whether and
how to introduce a financial incentive
by modifying the Postal Service’s
authority to adjust its rates. Adjustments
to rate authority could be upwards
(increase rate authority), downwards
(reduce rate authority), or both. See
Zarakas, supra. An upward PIM would
reward superior performance, whereas a
downward PIM would penalize
unsatisfactory performance. The PIM
may be designed to operate
simplistically: For instance, a specific
upward or downward incentive is either
provided or not provided, based on the
observed performance. On the other
hand, a more nuanced PIM could be
designed to provide a particular tier of
financial incentive based on the
observed performance: For instance,
progressively increasing rewards or
penalties.9 If any commenters have a
basis for connecting particular
requirement(s) with particular
amount(s), they may include such
proposals in their response to this
Order.
One potential method to develop a
PIM for both upward and downward
adjustments would be to set a ‘‘deadband’’ around historical performance.10
This type of PIM would trigger a penalty
when actual performance falls below the
lower target (unsatisfactory
performance) and trigger a reward when
actual performance exceeds the upper
target (superior performance).11 The
lower and upper targets could be
derived by measuring the standard
deviation(s) from historical
policies are in flux and in which an agency would
be paralyzed if all the necessary answers had to be
in before any action at all could be taken.’’).
9 See Synapse Energy Economics, Inc., Melissa
Whited, Tim Woolf, & Alice Napoleon, Utility
Performance Incentive Mechanisms: A Handbook
for Regulators, Prepared for the Western Interstate
Energy Board, March 9, 2015 (2015 PIM Handbook),
at 43–44 (demonstrating quadratic versus step
functions).
10 See 2015 PIM Handbook at 38; Paul L. Joskow,
Incentive Regulation in Theory & Practice:
Electricity Distribution & Transmission Networks,
January 21, 2006 (2006 Joskow), at 8, available at:
https://economics.mit.edu/files/1181.
11 See 2015 PIM Handbook at 38; see also 2006
Joskow, supra at 8.
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performance.12 Actual performance
within the dead-band (a neutral zone)
would not result in a direct financial
consequence.13
Therefore, to develop a mechanism
that would balance simplicity with
optimal refinement, the Commission
raises the following discussion points:
1. How to identify the percentage of
rate authority that would provide a
meaningful incentive(s) to the Postal
Service, while also not leading to
excessive rate increases for mailers nor
threatening the financial integrity of the
Postal Service?
2. How to identify data and methods
available to develop a connection
between the amount of the financial
incentive(s) at stake with the observed
performance (i.e., the change(s) in or
level(s) of efficiency, costs, and/or
service standards)?
3. How to identify the relative
advantages of applying incentives as
upward adjustments (increasing the
amount of rate authority(ies)),
downward adjustments (reducing the
amount of rate authority(ies)), a
combination mechanism (both), or
another method?
4. How best to administer the chosen
method?
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C. Operational Efficiency-Based
Requirement
The Commission intends to explore
whether and how to translate the broad
policy goals of the PAEA—incentivizing
the Postal Service to increase efficiency
and reduce costs—into a specific PIM.
For purposes of evaluating the Postal
Service’s operational efficiency, total
factor productivity (TFP) is a highly
comprehensive metric.14 The
Commission intends to further explore
whether TFP or an alternative metric is
capable of producing sufficiently
reliable, accurate, and transparent
results that would be appropriate for use
as a potential benchmark on which to
condition rate authority. While the
Commission’s preliminary expectation
is that there is not a practical way to
refine TFP to focus on only Market
Dominant products (see Order No. 5337
at 134), the Commission would
welcome any comments proposing a
basis for doing so. There have been
some changes in the TFP methodology
12 See 2015 PIM Handbook at 38; see also 2006
Joskow, supra at 8.
13 See 2015 PIM Handbook at 38.
14 See Docket No. RM2017–3, Northwest Postal
Consulting (NWPC) for the Postal Regulatory
Commission, Report 1, Adequacy of the Postal
Service’s TFP Model, Final Report, March 27, 2017,
at 2 (NWPC Report 1) (opining that the Postal
Service’s TFP Model contains significant levels of
detail regarding different aspects of Labor, Capital,
Materials, Mail Volume, and Possible Deliveries).
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over the years, and TFP results have
been revised after-the-fact on
occasion.15 Accordingly, the
Commission intends to review how
these changes impact reliability and
accuracy over time. While there is not
necessarily a reason to believe that the
Postal Service would attempt to
influence TFP results by making
unreasonable business decisions (see
Order No. 5337 at 135), the Commission
also intends to further explore how TFP
could be refined methodologically to
produce results that are adequately
safeguarded against manipulation. A
critical step to enable this study of TFP
is to require the Postal Service to file the
documentation and linked workpapers
containing all formulae for its TFP
methodology.16 Therefore, this Order
imposes a deadline for the Postal
Service to file this information of
February 16, 2021.
The Commission intends to explore
whether TFP can be refined to better
focus on efficiency gains within the
Postal Service’s control or whether an
alternative metric should be developed.
The Postal Service has used the
Deliveries per Total Workhours
(DPTWH) as an alternative efficiency
metric in its annual reports to Congress
and to develop its Integrated Financial
Plan.17 The Commission has expressed
15 Compare, e.g., United States Postal Service,
USPS Annual Tables, FY 2017 TFP (Total Factor
Productivity), February 28, 2018, Excel file ‘‘table
annual 2017 public (2017 cra).xlsx,’’ tab ‘‘Tfp–52’’
(updating FY 2016 TFP result to 1.262) with United
States Postal Service, USPS Annual Tables, FY 2016
TFP (Total Factor Productivity), March 1, 2017,
Excel file ‘‘table annual 2016 public (2016
cra).xlsx,’’ tab ‘‘Tfp–52’’ (reporting FY 2016 TFP
result as 1.260). While the Postal Service did not
provide an explanation for the updated FY 2016
TFP result, Commission analysis identified updated
source data for FY 2016. Additional technical
changes to the TFP are detailed in the NWPC Report
2 filed by the Commission in conjunction with
Order No. 5337. See generally Docket No. RM2017–
3, Northwest Postal Consulting (NWPC) for the
Postal Regulatory Commission, Report 2,
Comparison of Postal Service Productivity
Measurement: Before and After PAEA Enactment,
March 27, 2017, at 8–11 (NWPC Report 2).
16 By way of background, the TFP workpapers
filed by the Postal Service contain hardcoded
inputs and outputs rather than displaying the
formulae used and links to related spreadsheets.
Compare, e.g., United States Postal Service, USPS
Annual Tables, FY 2019 TFP (Total Factor
Productivity), February 27, 2020 with 39 CFR
3050.2(c).
17 See Docket No. ACR2019, Library Reference
USPS–FY19–17, December 27, 2019, United States
Postal Service FY 2019 Annual Report to Congress,
at 34 (FY 2019 Annual Report). DPTWH is
calculated by multiplying the total possible
deliveries by the number of delivery days and
dividing that product by total work hours. FY 2019
Annual Report at 34. ‘‘Starting in FY 2021, the
DPTWH metric will no longer be tracked as a
corporate indicator.’’ Docket No. ACR2020, Library
Reference USPS–FY20–17, December 29, 2020,
United States Postal Service FY 2020 Annual
Report to Congress, at 52 (FY 2020 Annual Report).
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concerns with the underlying
methodology, finding that DPTWH is
less comprehensive than TFP for
purposes of measuring productivity
because DPTWH isolates workhours
(labor) and because DPTWH does not
recognize a major workload component:
The collection, processing, transporting,
and sequencing for delivery of mail.18
However, it may be possible to develop
an alternate methodology that is easier
to calculate, understand, and apply than
TFP but still comprehensive enough to
reflect overall efficiency gains. If the
Postal Service proposes that the
Commission use a metric other than
TFP for a PIM, then it shall file a
detailed public explanation of the
methodology along with its comments.
Some of the sources of inefficiency
(and the potentially resulting lost
opportunities to reduce costs and
improve service performance) are
known in theory but difficult to correct
in practice. The following examples are
not intended to exhaustively detail
these types of issues and instead are
intended to promote thoughtful
engagement and exploration of the
potential challenges and opportunities
to enhance the design of the Market
Dominant ratemaking system.19
For instance, while the Postal Service
acknowledges that it must better align
labor with volume, it has stated that this
has been difficult to put into practice.20
During a given day, there are periods of
higher workload (peaks) and lower
workload (valleys or off-peaks). More
staff are needed to handle peaks,
whereas, during the valleys, fewer staff
are needed. These peaks and valleys do
not naturally align with the traditional
Postal Service labor structure, which
operates in three tours, or 8-hour cycles,
per day.21 Therefore, Postal Service
18 See Docket No. ACR2010, Annual Compliance
Determination, March 29, 2011, at 39; see also
Docket No. ACR2013, Review of Postal Service FY
2013 Performance Report and FY 2014 Performance
Plan, July 7, 2014, at 25.
19 Extremely detailed discussions of issues related
to specific processing (referred to as pinch-points)
may be found in a number of other proceedings.
See, e.g., Docket No. ACR2015, Annual Compliance
Determination, March 28, 2016, at 165–180; Docket
No. ACR2016, Annual Compliance Determination,
March 28, 2017, at 165–170; Docket No. ACR2017,
Annual Compliance Determination, March 29,
2018, at 175–181; Docket No. ACR2018, Annual
Compliance Determination, April 12, 2019, at 215–
222; Docket No. ACR2019, Annual Compliance
Determination, March 25, 2020, at 161–174 (FY
2019 ACD).
20 See, e.g., Docket No. ACR2019, Library
Reference USPS–FY19–29, December 27, 2019, PDF
file ‘‘FY19–29 Service Performance Report.pdf,’’ at
7, 30.
21 Tour 1 is from 11:00 p.m. to 07:00 a.m.; Tour
2 is from 07:00 a.m. to 3:00 p.m.; Tour 3 is from
3:00 p.m. to 11:00 p.m. United States Postal Service,
Office of the Inspector General, Report No. 20–144–
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management must plan carefully to
minimize inefficient outcomes, such as
insufficient staff during peaks or overstaffing during valleys.22 Additionally,
inefficient staffing may lead to mail
failing to clear operational checkpoints
as expected, which may lead to other
negative effects such as the use of
overtime hours or additional contract
transportation to ‘‘catch-up’’ and/or late
delivery.23
As another example, while the Postal
Service acknowledges that it must better
encourage preparation of the mail by
mailers and/or mail service providers so
as to facilitate more efficient handling
by the Postal Service, existing practices
do not maximize this opportunity.24 For
instance, certain ways of preparing mail
for presentation to the Postal Service are
more likely to result in bundle
breakage.25 Increased bundle breakage
R20, Transportation Network Optimization and
Service Performance, June 5, 2020, at 15, available
at: https://www.uspsoig.gov/sites/default/files/
document-library-files/2020/20-144-R20.pdf (OIG
Rep. No. 20–144–R20).
22 See Docket No. N2010–1, Advisory Opinion on
Elimination of Saturday Delivery, March 24, 2011,
at 115–126 (Docket No. N2010–1 Advisory
Opinion); see also OIG Rep. No. 20–144–R20 at 15–
16 (finding insufficient management staff working
during Tours 1 and 3); United States Postal Service,
Office of the Inspector General, Report No.
19XG013NO000–R20, U.S. Postal Service’s
Processing Network Optimization and Service
Impacts, October 15, 2018, at 17–18, available at:
https://www.uspsoig.gov/sites/default/files/
document-library-files/2020/19XG013NO000R20.pdf (OIG Rep. No. 19XG013NO000–R20)
(finding employee availability issues contributed to
lower productivity, higher costs, and slower service
performance).
23 For example, if inefficient staffing leads to
failure to complete origin processing by the
applicable target time of day, the affected mail may
miss its scheduled transportation. While the Postal
Service may try to mitigate the downstream effects
by catching-up during transit or destination
processing, the Postal Service acknowledges that
these types of delays often require extraordinary
action to deliver the affected mail within the
applicable service standard. FY 2019 ACD at 109
(The Postal Service asserts that if a mailpiece
misses its scheduled transportation, then generally
that mailpiece will not be delivered within the
expected timeframe absent ‘‘extraordinary measures
at substantial cost, such as extra transportation
along with clerk and carrier overtime at the delivery
point.’’) (quoting Docket No. ACR2018, Responses
of the United States Postal Service to Questions 1–
9 of Chairman’s Information Request No. 13,
February 21, 2019, question 2).
24 See, e.g., United States Postal Service, Office of
the Inspector General, Report No. 20–088–R20, Cost
Reduction Initiatives for Mail Products, Report
Number, August 3, 2020, at 1, available at: https://
www.uspsoig.gov/sites/default/files/documentlibrary-files/2020/20-088-R20.pdf (OIG Rep. No. 20–
008–R20) (finding that the Postal Service personnel
did not regularly record mail preparation quality
issues, report such issues to Postal Service
management for updates to the guidance provided
to mailers, or otherwise communicate with mailers
concerning correction).
25 See, e.g., OIG Rep. No. 20–088–R20 at 5–9
(detailing that mailpieces that are relatively thinner,
shrink-wrapped, bundled using rubber bands or
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tends to reduce the ability to process the
affected mail using machines and
increase the likelihood that the affected
mail will undergo manual processing
instead. Manual processing is less
efficient (slower and more costly) than
machine processing.26 Increased manual
processing may lead to mail failing to
clear operational checkpoints as
expected, which may lead to other
negative effects such as the use of
overtime hours to ‘‘catch-up’’ and/or
late delivery.27
Generally, the Commission aims to
select targets that are outcome-oriented,
consistent with the policy goals of the
PAEA, objectively measureable and
verifiable, readily interpretable, and
achievable. Because the Commission is
particularly focused on promoting the
Postal Service’s longer-term financial
viability, the Commission is interested
in selecting a metric(s) and target(s) for
the PIM that would be consistent with
ancillary benefits such as increasing the
opportunities for reducing costs and
improving service performance.
Moreover, the Commission intends to
consider potential safeguards to
incorporate into the PIM, to ensure that
results are adequately safeguarded
against manipulation and that selection
of a shorter-term target would not
perversely incentivize behavior that
would be detrimental in the longerterm.
Therefore the Commission raises the
following discussion points:
1. How to identify possible
refinements to TFP to increase its
reliability, accuracy, and
representativeness as a measure of
efficiency gains within the Postal
Service’s control?
2. How to identify alternative
potential metric(s) other than TFP that
could be developed or refined as an
accurate, reliable, and representative
measure of efficiency gains within the
Postal Service’s control? Should the
Commission consider industry-wide,
economy-wide, or similar comparative
strings, or presented in sacks tend to break more
often than mailpieces that are relatively thicker, not
shrink-wrapped, bundled using polypropylene
(plastic) straps, or presented on pallets).
26 See, e.g., OIG Rep. No. 20–088–R20 at 6
(estimating that for FYs 2018–2019, broken bundles
could have increased bundle processing costs by
$96.9 million).
27 For example, if bundle breakage triggers
manual processing of the affected mail, the affected
mail may miss its applicable time target to clear the
next processing operation. See, e.g., Docket No.
ACR2019, Library Reference USPS–FY19–29,
December 27, 2019, PDF file ‘‘FY19–29 Service
Performance Report.pdf,’’ at 19. The Postal Service
may try to use overtime hours to speed up manual
processing in an effort to deliver the affected mail
within the applicable service standard. See, e.g.,
OIG Rep. No. 20–088–R20 at 8.
PO 00000
Frm 00025
Fmt 4702
Sfmt 4702
8333
benchmarks for efficiency? Are there
any metrics that the Commission can
learn from in adjacent industries, other
sectors, or other posts?
3. How to identify potential target(s)
for efficiency gains?
4. How to identify potential metric(s)
and target(s) related to efficiency gains
to promote the longer-term financial
viability of the Postal Service, such as
by increasing the opportunities for cost
reduction and/or improved service
performance?
5. How to identify potential
safeguards designed to minimize
manipulation by the operator and
prevent the operator from engaging in
behavior that would be detrimental over
the longer-term?
D. Service Standards-Based
Requirement
Additionally, the Commission intends
to explore whether and how to translate
the policy goal of the PAEA to maintain
high-quality service standards into a
specific PIM. This goal is intended to
encourage the maintenance of highquality service standards established
pursuant to 39 U.S.C. 3691, and to hold
the Postal Service accountable for
consistently achieving those standards.
See Order No. 4257 at 261.
The first aspect underlying this goal is
referred to as ‘‘service standards,’’
which are the stated days-to-delivery for
different types of mail. See id. at 250.
Service standards are comprised of a
delivery day range and business rules.28
With respect to service standards, the
Commission is interested in whether
introducing direct financial
consequences linked to maintenance of
the existing service standards would
enhance the system, and if so, how to
calibrate that mechanism. See Order No.
5763 at 170.
The second aspect underlying this
goal implicitly requires consistent
achievement of service standards, which
is referred to as ‘‘service performance.’’
See id. at 296; Order No. 4257 at 262–
263. The existing regulatory system has
a mechanism to hold the Postal Service
accountable for its service performance:
The annual compliance review
proceeding.29 If commenters have
28 See id. at 251–252. By way of example, there
are three separate service standards for First-Class
Mail: (1) 1-Day (referred to as ‘‘overnight’’); (2)
2-Day; and (3) 3–5-Day; business rules determine
whether an individual mailpiece will be delivered
overnight, in 2 days, or in 3–5 days. See id. at 250–
251.
29 Order No. 5763 at 296; Order No. 4257 at 264;
Docket No. RM2009–11, Order Establishing Final
Rules Concerning Periodic Reporting of Service
Performance Measurements and Customer
Satisfaction, May 25, 2010, at 32 (Order No. 465).
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Federal Register / Vol. 86, No. 23 / Friday, February 5, 2021 / Proposed Rules
suggestions on how to improve upon
that mechanism, they may propose
changes in their response to this Order.
An effective price cap system
maintains reliable, efficient, and
economical service.30 ‘‘The Postal
Service cannot be permitted to degrade
service in order to comply with the
revenue constraints associated with the
price cap.’’ Order No. 4257 at 255 (citing
Docket No. N2010–1, Advisory Opinion
at 8). ‘‘A reduction in service must be
warranted by declining demand for the
service, rather than to ease the
obligation of adhering to the price cap.’’
Docket No. N2010–1, Advisory Opinion
at 10. Introducing a direct financial
incentive connected to operational
efficiency gains and cost reductions may
undermine the existing incentives to
maintain high-quality service
standards.31 Accordingly, to give due
consideration to a potential need to
counterbalance such unintended
consequences, the Commission raises
the following discussion points:
1. How to identify potential regulatory
changes that may be needed to
counterbalance any perverse incentive
to degrade service standards and/or
service performance that may be created
by introducing an operational-efficiency
based requirement?
2. How to identify the relative
advantages of designing a system that
creates a direct financial link to changes
in service standards?
3. What data and methods could be
used to design a system that creates a
direct financial link to changes in
service standards?
jbell on DSKJLSW7X2PROD with PROPOSALS
IV. Administrative Actions
The Commission establishes Docket
No. RM2021–2 for consideration of the
matters discussed in the body of this
advance notice of proposed rulemaking.
The Commission will accept
comments and reply comments
concerning the topics identified in this
advance notice of proposed rulemaking.
Comments are due April 15, 2021. Reply
comments are due May 17, 2021.
Pursuant to 39 U.S.C. 505, Richard A.
Oliver is designated as an officer of the
Commission (Public Representative) to
represent the interests of the general
public in this proceeding.
The Postal Service shall file the
documentation and linked workpapers
for its TFP methodology to aid in the
30 Order No. 4257 at 255 (citing Docket No.
N2010–1 Advisory Opinion at 7–10).
31 See Order No. 5763 at 171 (citing Order No.
5337 at 142, 144; Order No. 4257 at 255); see also
2006 Joskow, supra at 8 (observing that regulatory
mechanisms focusing on cost reductions
exclusively may lead to the operator reducing its
service).
VerDate Sep<11>2014
16:29 Feb 04, 2021
Jkt 253001
evaluation of TFP by February 16, 2021.
Materials filed in this docket will be
available for review on the
Commission’s website (https://
www.prc.gov).
The Regulatory Flexibility Act
requires federal agencies, in
promulgating rules, to consider the
impact of those rules on small entities.
See 5 U.S.C. 601, et seq. If the proposed
or final rules will not, if promulgated,
have a significant economic impact on
a substantial number of small entities,
the head of the agency may certify that
the initial and final regulatory flexibility
analysis requirements of 5 U.S.C. 603
and 604 do not apply. See 5 U.S.C.
605(b). In the context of this
rulemaking, the Commission’s primary
responsibility is in the regulatory
oversight of the United States Postal
Service. The rules that are the subject of
this rulemaking have a regulatory
impact on the Postal Service, but do not
impose any regulatory obligation upon
any other entity. Based on these
findings, the Chairman of the
Commission certifies that the rules that
are the subject of this rulemaking will
not have a significant economic impact
on a substantial number of small
entities. Therefore, pursuant to 5 U.S.C.
605(b), this rulemaking is exempt from
the initial and final regulatory flexibility
analysis requirements of 5 U.S.C. 603
and 604.
V. Ordering Paragraphs
It is ordered:
1. Docket No. RM2021–2 is
established for the purpose of
considering amendments to Chapter III
of title 39 of the Code of Federal
Regulations as discussed in this advance
notice of proposed rulemaking.
2. The Postal Service shall file the
documentation and linked workpapers
for its total factor productivity
methodology, in a manner that displays
the formulae used and links to related
spreadsheets by February 16, 2021.
3. If the Postal Service proposes to use
a metric other than total factor
productivity for a performance incentive
mechanism, then it shall file a detailed
public explanation of the methodology
along with its comments.
4. Pursuant to 39 U.S.C. 505, Richard
A. Oliver shall serve as an officer of the
Commission (Public Representative) to
represent the interests of the general
public in this proceeding.
5. Interested persons may submit
comments no later than April 15, 2021.
6. Interested persons may submit
reply comments no later than May 17,
2021.
PO 00000
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Fmt 4702
Sfmt 4702
7. The Secretary shall arrange for
publication of this order in the Federal
Register.
By the Commission.
Erica A. Barker,
Secretary.
Editorial Note: This document was
received at the Office of the Federal Register
on January 19, 2021.
[FR Doc. 2021–01500 Filed 2–4–21; 8:45 am]
BILLING CODE 7710–FW–P
DEPARTMENT OF HOMELAND
SECURITY
Federal Emergency Management
Agency
44 CFR Part 206
[Docket ID FEMA–2020–0038]
RIN 1660–AA99
Cost of Assistance Estimates in the
Disaster Declaration Process for the
Public Assistance Program; Public
Meeting
Federal Emergency
Management Agency, Department of
Homeland Security.
ACTION: Announcement of meeting;
extension of comment period.
AGENCY:
The Federal Emergency
Management Agency (FEMA) is
extending the public comment period
for its proposed rule published
December 14, 2020, and will hold a
public meeting remotely via web
conference to solicit feedback on the
proposed rule. The rule proposed to
substantively revise the ‘‘estimated cost
of the assistance’’ disaster declaration
factor that FEMA uses to review a
Governor’s request for a major disaster
under the Public Assistance Program.
DATES: Written comments on the
proposed rule published at 85 FR 80719
(December 14, 2020) may be submitted
until 11:59 p.m. ET on Friday, March
12, 2021.
The meeting will take place on
Wednesday, February 24, 2021, from 1
to 3 p.m. Eastern Time (ET).
To register in order to make remarks
during the meeting, contact the
individual listed in the FOR FURTHER
INFORMATION CONTACT section below by
12 p.m. ET on Tuesday, February 23,
2021.
SUMMARY:
The meeting will be held
via web conference. Members of the
public may view the public portion of
the meeting online at https://
fema.zoomgov.com/s/1617851830.
ADDRESSES:
E:\FR\FM\05FEP1.SGM
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Agencies
[Federal Register Volume 86, Number 23 (Friday, February 5, 2021)]
[Proposed Rules]
[Pages 8330-8334]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2021-01500]
=======================================================================
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POSTAL REGULATORY COMMISSION
39 CFR Part 3030
[Docket No. RM2021-2; Order No. 5816]
Market Dominant Products
AGENCY: Postal Regulatory Commission.
ACTION: Advance notice of proposed rulemaking.
-----------------------------------------------------------------------
SUMMARY: The Commission is initiating a review seeking input from the
public about what additional regulations promulgated by the Commission
may be necessary to achieve the objectives of the Postal Accountability
and Enhancement Act (PAEA) particularly related to maximizing
incentives to increase efficiency and reduce costs, maintaining high-
quality service standards, and assuring financial stability (including
retained earnings). This advance notice informs the public of the
docket's initiation, invites public comment, and takes other
administrative steps.
DATES:
Comments are due: April 15, 2021.
Reply comments are due: May 17, 2021.
ADDRESSES: Submit comments electronically via the Commission's Filing
Online system at https://www.prc.gov. Those who cannot submit comments
electronically should contact the person identified in the FOR FURTHER
INFORMATION CONTACT section by telephone for advice on filing
alternatives.
FOR FURTHER INFORMATION CONTACT: David A. Trissell, General Counsel, at
202-789-6820.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Introduction
II. Background
III. Substantive Areas for Further Refinement
IV. Administrative Actions
V. Ordering Paragraphs
I. Introduction
Pursuant to 39 U.S.C. 3622(d)(3), the Commission issues this
advance notice of proposed rulemaking to seek input from the public
about what additional regulations promulgated by the Commission may be
necessary to achieve the objectives of the Postal Accountability and
Enhancement Act (PAEA) \1\ over the longer-term, particularly related
to maximizing incentives to increase efficiency and reduce costs,
maintaining high-quality service standards, and assuring financial
stability (including retained earnings).
---------------------------------------------------------------------------
\1\ Public Law 109-435, 201, 120 Stat. 3198, 3204 (2006).
---------------------------------------------------------------------------
II. Background
In Docket No. RM2017-3, the Commission found that the existing
Market Dominant ratemaking system did not achieve the PAEA's objectives
during the 10 years following the PAEA's enactment.\2\ The Commission's
findings were premised in part on the existing ratemaking system's
inability to assure financial stability (including retained earnings),
maximize incentives to reduce costs and increase efficiency, and
maintain high-quality service standards. See Order No. 4257 at 3-5,
274-275. During the PAEA era, the existing ratemaking system was
inadequate, which resulted in an accumulated deficit,\3\ maximum use of
the Postal Service's borrowing authority and a sharp decline in capital
investments,\4\ operational efficiency increases and cost reductions
that were insufficient to achieve overall financial stability and/or
retained earnings,\5\ and reduction of the high-quality service
standards that were set in 2007.\6\
---------------------------------------------------------------------------
\2\ See Docket No. RM2017-3, Order Adopting Final Rules for the
System of Regulating Rates and Classes for Market Dominant Products,
November 30, 2020, at 2 (Order No. 5763); see also Docket No.
RM2017-3, Revised Notice of Proposed Rulemaking, December 5, 2019,
at 7 (Order No. 5337); Docket No. RM2017-3, Notice of Proposed
Rulemaking for the System for Regulating Rates and Classes for
Market Dominant Products, December 1, 2017, at 26 (Order No. 4258);
Docket No. RM2017-3, Order on the Findings and Determination of the
39 U.S.C. 3622 Review, December 1, 2017, at 3-5, 274-275 (Order No.
4257).
\3\ See Order No. 4257 at 171-172 (describing how the
consecutive net losses resulted in an accumulated deficit).
\4\ The Postal Service lacks shareholders and instead must
finance capital investments through revenue or through borrowing.
Order No. 4258 at 48-49. Therefore, as consecutive years of net
losses resulted in an accumulated deficit, the Postal Service relied
heavily on its borrowing authority, deferred capital investments,
and increased its cash reserves. See id. at 46-52.
\5\ Order No. 4257 at 222, 274-275 (summarizing that while some
cost reductions and efficiency gains were achieved post-PAEA, they
were insufficient to achieve financial stability in the medium term
and long term).
\6\ Id. at 273. The two major service standard changes in the
first 10 years after the passage of the PAEA were reviewed by the
Commission, prior to implementation, in Docket Nos. N2012-1 and
N2014-1. The ``Network Rationalization'' initiative implemented by
the Postal Service included changes to the service standards for
First-Class Mail, Periodicals, USPS Marketing Mail, and Package
Services. The ``Load Leveling'' initiative included changes to the
service standards for USPS Marketing Mail. Id. at 264-273.
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In response, the Commission modified the ratemaking system's design
to encourage and enable the Postal Service to address its complex
challenges by making prudent pricing and operational decisions. See
Order No. 5763 at 285. Among other changes made, the modified rules
provide additional rate authority to address two underlying drivers of
the Postal Service's net losses that are largely outside of its direct
and near-term control: (1) The increase in per-unit cost resulting from
the decline in mail density for each fiscal year under subpart D of 39
CFR part 3030 of this chapter; and (2) the statutorily mandated
amortization payments for particular retirement costs under subpart E
of 39 CFR part 3030 of this chapter. See id. These principled
adjustments to the price cap made by the Commission in Docket No.
RM2017-
[[Page 8331]]
3 are necessary to achieve the objectives of the PAEA, in conjunction
with each other, and are focused on vital near-term improvements.
However, the objectives of the PAEA related to maximizing
incentives to increase efficiency and reducing costs as well as
assuring financial stability (including retained earnings) set forth
ambitious goals that are difficult to achieve instantaneously or
simultaneously. See 39 U.S.C. 3622(b)(1) and (5). These goals must also
be achieved in conjunction with other priorities over time, such as
maintaining high-quality service standards. See id. section 3622(b)(3).
Consistent with the Commission's findings in Docket No. RM2017-3,
Docket No. RM2021-2 is initiated to explore whether additional
regulatory changes may be necessary to promote longer-term financial
stability, increased efficiency and cost reductions, while maintaining
high-quality service standards, and if so, how to best design these
potential changes. See Order No. 5763 at 166. The Commission invites
any interested party to submit comments on the following topics and
asks the following questions to initiate a meaningful dialogue with
stakeholders.
III. Substantive Areas for Further Refinement
A. Incentive Regulation
Performance-based regulation is a broad concept referring to a
regulatory system that applies incentives to promote targeted behavior
by the regulated entity.\7\ More specifically, a performance incentive
mechanism (PIM), also referred to as a targeted performance incentive
(TPI), is used by regulators to set a target for acceptable performance
by the regulated entity in a specific area and attach financial
consequences to ensure compliance. See Zarakas, supra. This rulemaking
is initiated to explore whether and how to introduce any potential
modifications to the design of the ratemaking system that would further
enhance (i.e., maximize over the longer-term) the Postal Service's
incentives to increase efficiency and reduce costs. Achieving such
efficiencies could benefit the Postal Service by improving its longer-
term financial viability and could benefit the ratepayers by leading to
improved service performance. At the same time, the Commission remains
mindful that further enhancing the Postal Service's incentives to
increase efficiency and reduce costs may weaken the incentive to
maintain high-quality service standards. The Commission also
acknowledges that ratepayers may have different preferences with
respect to the speed and/or the consistency of delivery service for
Market Dominant products. Accordingly, to explore possible enhancements
to the Market Dominant ratemaking system overall, through the
introduction of direct financial consequences (such as an upward or
downward adjustment to rate authority) using a PIM or a different
method, the Commission raises the following discussion points:
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\7\ See William Zarakas, A New Face for PBR: Aligning Incentives
in the Electric Utility Ecosystem, PUB. UTILS. FORT., December 2017
(Zarakas), available at: https://www.fortnightly.com/fortnightly/2017/12/new-face-pbr?authkey=e0a4230ee85eb602f123c1e633c0e5b5260f9bd3f297c094c055e7868e5a4589.
---------------------------------------------------------------------------
1. Whether additional regulatory changes are needed to further
enhance the Postal Service's incentives to increase efficiency and
reduce costs while maintaining high-quality service standards. Why or
why not?
2. How to identify and evaluate potential types of regulatory
changes that would introduce direct financial consequences that would
further enhance the Postal Service's incentives to increase efficiency
and reduce costs while maintaining high-quality service standards? Are
there any financial consequences that can be drawn from other postal
systems or other regulated industries that should be considered?
3. How to identify and evaluate potential types of regulatory
changes other than the connection of direct financial consequences that
would further enhance the Postal Service's incentives to increase
efficiency and reduce costs while maintaining high-quality service
standards? Are there any non-financial incentives that can be drawn
from other postal systems or other regulated industries that should be
considered?
B. Mechanism for a Financial Incentive
The Commission is interested in exploring whether a regulatory
mechanism connecting direct financial consequences with increasing
efficiency and reducing costs and maintaining high-quality service
standards would benefit the Market Dominant ratemaking system, and how
to connect the Postal Service's behavior with the financial incentive
introduced. The Commission acknowledges that every proposal has
tradeoffs and that it is impossible to refine the connection to a level
of absolute precision.\8\ This rulemaking does not aim for this level
of precision. Generally, the Commission seeks to identify an amount of
a financial incentive that is both meaningful to the Postal Service
(i.e., would actually motivate it to engage in the desired behavior)
and would neither be excessive to the ratepayers nor threaten the
financial integrity of the Postal Service.
---------------------------------------------------------------------------
\8\ See Nat'l Ass'n of Broadcasters v. F.C.C., 740 F.2d 1190,
1210 (D.C. Cir. 1984) (``But administrative action generally occurs
against a shifting background in which facts, predictions, and
policies are in flux and in which an agency would be paralyzed if
all the necessary answers had to be in before any action at all
could be taken.'').
---------------------------------------------------------------------------
Preliminarily, the Commission is interested in exploring whether
and how to introduce a financial incentive by modifying the Postal
Service's authority to adjust its rates. Adjustments to rate authority
could be upwards (increase rate authority), downwards (reduce rate
authority), or both. See Zarakas, supra. An upward PIM would reward
superior performance, whereas a downward PIM would penalize
unsatisfactory performance. The PIM may be designed to operate
simplistically: For instance, a specific upward or downward incentive
is either provided or not provided, based on the observed performance.
On the other hand, a more nuanced PIM could be designed to provide a
particular tier of financial incentive based on the observed
performance: For instance, progressively increasing rewards or
penalties.\9\ If any commenters have a basis for connecting particular
requirement(s) with particular amount(s), they may include such
proposals in their response to this Order.
---------------------------------------------------------------------------
\9\ See Synapse Energy Economics, Inc., Melissa Whited, Tim
Woolf, & Alice Napoleon, Utility Performance Incentive Mechanisms: A
Handbook for Regulators, Prepared for the Western Interstate Energy
Board, March 9, 2015 (2015 PIM Handbook), at 43-44 (demonstrating
quadratic versus step functions).
---------------------------------------------------------------------------
One potential method to develop a PIM for both upward and downward
adjustments would be to set a ``dead-band'' around historical
performance.\10\ This type of PIM would trigger a penalty when actual
performance falls below the lower target (unsatisfactory performance)
and trigger a reward when actual performance exceeds the upper target
(superior performance).\11\ The lower and upper targets could be
derived by measuring the standard deviation(s) from historical
[[Page 8332]]
performance.\12\ Actual performance within the dead-band (a neutral
zone) would not result in a direct financial consequence.\13\
---------------------------------------------------------------------------
\10\ See 2015 PIM Handbook at 38; Paul L. Joskow, Incentive
Regulation in Theory & Practice: Electricity Distribution &
Transmission Networks, January 21, 2006 (2006 Joskow), at 8,
available at: https://economics.mit.edu/files/1181.
\11\ See 2015 PIM Handbook at 38; see also 2006 Joskow, supra at
8.
\12\ See 2015 PIM Handbook at 38; see also 2006 Joskow, supra at
8.
\13\ See 2015 PIM Handbook at 38.
---------------------------------------------------------------------------
Therefore, to develop a mechanism that would balance simplicity
with optimal refinement, the Commission raises the following discussion
points:
1. How to identify the percentage of rate authority that would
provide a meaningful incentive(s) to the Postal Service, while also not
leading to excessive rate increases for mailers nor threatening the
financial integrity of the Postal Service?
2. How to identify data and methods available to develop a
connection between the amount of the financial incentive(s) at stake
with the observed performance (i.e., the change(s) in or level(s) of
efficiency, costs, and/or service standards)?
3. How to identify the relative advantages of applying incentives
as upward adjustments (increasing the amount of rate authority(ies)),
downward adjustments (reducing the amount of rate authority(ies)), a
combination mechanism (both), or another method?
4. How best to administer the chosen method?
C. Operational Efficiency-Based Requirement
The Commission intends to explore whether and how to translate the
broad policy goals of the PAEA--incentivizing the Postal Service to
increase efficiency and reduce costs--into a specific PIM.
For purposes of evaluating the Postal Service's operational
efficiency, total factor productivity (TFP) is a highly comprehensive
metric.\14\ The Commission intends to further explore whether TFP or an
alternative metric is capable of producing sufficiently reliable,
accurate, and transparent results that would be appropriate for use as
a potential benchmark on which to condition rate authority. While the
Commission's preliminary expectation is that there is not a practical
way to refine TFP to focus on only Market Dominant products (see Order
No. 5337 at 134), the Commission would welcome any comments proposing a
basis for doing so. There have been some changes in the TFP methodology
over the years, and TFP results have been revised after-the-fact on
occasion.\15\ Accordingly, the Commission intends to review how these
changes impact reliability and accuracy over time. While there is not
necessarily a reason to believe that the Postal Service would attempt
to influence TFP results by making unreasonable business decisions (see
Order No. 5337 at 135), the Commission also intends to further explore
how TFP could be refined methodologically to produce results that are
adequately safeguarded against manipulation. A critical step to enable
this study of TFP is to require the Postal Service to file the
documentation and linked workpapers containing all formulae for its TFP
methodology.\16\ Therefore, this Order imposes a deadline for the
Postal Service to file this information of February 16, 2021.
---------------------------------------------------------------------------
\14\ See Docket No. RM2017-3, Northwest Postal Consulting (NWPC)
for the Postal Regulatory Commission, Report 1, Adequacy of the
Postal Service's TFP Model, Final Report, March 27, 2017, at 2 (NWPC
Report 1) (opining that the Postal Service's TFP Model contains
significant levels of detail regarding different aspects of Labor,
Capital, Materials, Mail Volume, and Possible Deliveries).
\15\ Compare, e.g., United States Postal Service, USPS Annual
Tables, FY 2017 TFP (Total Factor Productivity), February 28, 2018,
Excel file ``table annual 2017 public (2017 cra).xlsx,'' tab ``Tfp-
52'' (updating FY 2016 TFP result to 1.262) with United States
Postal Service, USPS Annual Tables, FY 2016 TFP (Total Factor
Productivity), March 1, 2017, Excel file ``table annual 2016 public
(2016 cra).xlsx,'' tab ``Tfp-52'' (reporting FY 2016 TFP result as
1.260). While the Postal Service did not provide an explanation for
the updated FY 2016 TFP result, Commission analysis identified
updated source data for FY 2016. Additional technical changes to the
TFP are detailed in the NWPC Report 2 filed by the Commission in
conjunction with Order No. 5337. See generally Docket No. RM2017-3,
Northwest Postal Consulting (NWPC) for the Postal Regulatory
Commission, Report 2, Comparison of Postal Service Productivity
Measurement: Before and After PAEA Enactment, March 27, 2017, at 8-
11 (NWPC Report 2).
\16\ By way of background, the TFP workpapers filed by the
Postal Service contain hardcoded inputs and outputs rather than
displaying the formulae used and links to related spreadsheets.
Compare, e.g., United States Postal Service, USPS Annual Tables, FY
2019 TFP (Total Factor Productivity), February 27, 2020 with 39 CFR
3050.2(c).
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The Commission intends to explore whether TFP can be refined to
better focus on efficiency gains within the Postal Service's control or
whether an alternative metric should be developed. The Postal Service
has used the Deliveries per Total Workhours (DPTWH) as an alternative
efficiency metric in its annual reports to Congress and to develop its
Integrated Financial Plan.\17\ The Commission has expressed concerns
with the underlying methodology, finding that DPTWH is less
comprehensive than TFP for purposes of measuring productivity because
DPTWH isolates workhours (labor) and because DPTWH does not recognize a
major workload component: The collection, processing, transporting, and
sequencing for delivery of mail.\18\ However, it may be possible to
develop an alternate methodology that is easier to calculate,
understand, and apply than TFP but still comprehensive enough to
reflect overall efficiency gains. If the Postal Service proposes that
the Commission use a metric other than TFP for a PIM, then it shall
file a detailed public explanation of the methodology along with its
comments.
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\17\ See Docket No. ACR2019, Library Reference USPS-FY19-17,
December 27, 2019, United States Postal Service FY 2019 Annual
Report to Congress, at 34 (FY 2019 Annual Report). DPTWH is
calculated by multiplying the total possible deliveries by the
number of delivery days and dividing that product by total work
hours. FY 2019 Annual Report at 34. ``Starting in FY 2021, the DPTWH
metric will no longer be tracked as a corporate indicator.'' Docket
No. ACR2020, Library Reference USPS-FY20-17, December 29, 2020,
United States Postal Service FY 2020 Annual Report to Congress, at
52 (FY 2020 Annual Report).
\18\ See Docket No. ACR2010, Annual Compliance Determination,
March 29, 2011, at 39; see also Docket No. ACR2013, Review of Postal
Service FY 2013 Performance Report and FY 2014 Performance Plan,
July 7, 2014, at 25.
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Some of the sources of inefficiency (and the potentially resulting
lost opportunities to reduce costs and improve service performance) are
known in theory but difficult to correct in practice. The following
examples are not intended to exhaustively detail these types of issues
and instead are intended to promote thoughtful engagement and
exploration of the potential challenges and opportunities to enhance
the design of the Market Dominant ratemaking system.\19\
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\19\ Extremely detailed discussions of issues related to
specific processing (referred to as pinch-points) may be found in a
number of other proceedings. See, e.g., Docket No. ACR2015, Annual
Compliance Determination, March 28, 2016, at 165-180; Docket No.
ACR2016, Annual Compliance Determination, March 28, 2017, at 165-
170; Docket No. ACR2017, Annual Compliance Determination, March 29,
2018, at 175-181; Docket No. ACR2018, Annual Compliance
Determination, April 12, 2019, at 215-222; Docket No. ACR2019,
Annual Compliance Determination, March 25, 2020, at 161-174 (FY 2019
ACD).
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For instance, while the Postal Service acknowledges that it must
better align labor with volume, it has stated that this has been
difficult to put into practice.\20\ During a given day, there are
periods of higher workload (peaks) and lower workload (valleys or off-
peaks). More staff are needed to handle peaks, whereas, during the
valleys, fewer staff are needed. These peaks and valleys do not
naturally align with the traditional Postal Service labor structure,
which operates in three tours, or 8-hour cycles, per day.\21\
Therefore, Postal Service
[[Page 8333]]
management must plan carefully to minimize inefficient outcomes, such
as insufficient staff during peaks or over-staffing during valleys.\22\
Additionally, inefficient staffing may lead to mail failing to clear
operational checkpoints as expected, which may lead to other negative
effects such as the use of overtime hours or additional contract
transportation to ``catch-up'' and/or late delivery.\23\
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\20\ See, e.g., Docket No. ACR2019, Library Reference USPS-FY19-
29, December 27, 2019, PDF file ``FY19-29 Service Performance
Report.pdf,'' at 7, 30.
\21\ Tour 1 is from 11:00 p.m. to 07:00 a.m.; Tour 2 is from
07:00 a.m. to 3:00 p.m.; Tour 3 is from 3:00 p.m. to 11:00 p.m.
United States Postal Service, Office of the Inspector General,
Report No. 20-144-R20, Transportation Network Optimization and
Service Performance, June 5, 2020, at 15, available at: https://www.uspsoig.gov/sites/default/files/document-library-files/2020/20-144-R20.pdf (OIG Rep. No. 20-144-R20).
\22\ See Docket No. N2010-1, Advisory Opinion on Elimination of
Saturday Delivery, March 24, 2011, at 115-126 (Docket No. N2010-1
Advisory Opinion); see also OIG Rep. No. 20-144-R20 at 15-16
(finding insufficient management staff working during Tours 1 and
3); United States Postal Service, Office of the Inspector General,
Report No. 19XG013NO000-R20, U.S. Postal Service's Processing
Network Optimization and Service Impacts, October 15, 2018, at 17-
18, available at: https://www.uspsoig.gov/sites/default/files/document-library-files/2020/19XG013NO000-R20.pdf (OIG Rep. No.
19XG013NO000-R20) (finding employee availability issues contributed
to lower productivity, higher costs, and slower service
performance).
\23\ For example, if inefficient staffing leads to failure to
complete origin processing by the applicable target time of day, the
affected mail may miss its scheduled transportation. While the
Postal Service may try to mitigate the downstream effects by
catching-up during transit or destination processing, the Postal
Service acknowledges that these types of delays often require
extraordinary action to deliver the affected mail within the
applicable service standard. FY 2019 ACD at 109 (The Postal Service
asserts that if a mailpiece misses its scheduled transportation,
then generally that mailpiece will not be delivered within the
expected timeframe absent ``extraordinary measures at substantial
cost, such as extra transportation along with clerk and carrier
overtime at the delivery point.'') (quoting Docket No. ACR2018,
Responses of the United States Postal Service to Questions 1-9 of
Chairman's Information Request No. 13, February 21, 2019, question
2).
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As another example, while the Postal Service acknowledges that it
must better encourage preparation of the mail by mailers and/or mail
service providers so as to facilitate more efficient handling by the
Postal Service, existing practices do not maximize this
opportunity.\24\ For instance, certain ways of preparing mail for
presentation to the Postal Service are more likely to result in bundle
breakage.\25\ Increased bundle breakage tends to reduce the ability to
process the affected mail using machines and increase the likelihood
that the affected mail will undergo manual processing instead. Manual
processing is less efficient (slower and more costly) than machine
processing.\26\ Increased manual processing may lead to mail failing to
clear operational checkpoints as expected, which may lead to other
negative effects such as the use of overtime hours to ``catch-up'' and/
or late delivery.\27\
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\24\ See, e.g., United States Postal Service, Office of the
Inspector General, Report No. 20-088-R20, Cost Reduction Initiatives
for Mail Products, Report Number, August 3, 2020, at 1, available
at: https://www.uspsoig.gov/sites/default/files/document-library-files/2020/20-088-R20.pdf (OIG Rep. No. 20-008-R20) (finding that
the Postal Service personnel did not regularly record mail
preparation quality issues, report such issues to Postal Service
management for updates to the guidance provided to mailers, or
otherwise communicate with mailers concerning correction).
\25\ See, e.g., OIG Rep. No. 20-088-R20 at 5-9 (detailing that
mailpieces that are relatively thinner, shrink-wrapped, bundled
using rubber bands or strings, or presented in sacks tend to break
more often than mailpieces that are relatively thicker, not shrink-
wrapped, bundled using polypropylene (plastic) straps, or presented
on pallets).
\26\ See, e.g., OIG Rep. No. 20-088-R20 at 6 (estimating that
for FYs 2018-2019, broken bundles could have increased bundle
processing costs by $96.9 million).
\27\ For example, if bundle breakage triggers manual processing
of the affected mail, the affected mail may miss its applicable time
target to clear the next processing operation. See, e.g., Docket No.
ACR2019, Library Reference USPS-FY19-29, December 27, 2019, PDF file
``FY19-29 Service Performance Report.pdf,'' at 19. The Postal
Service may try to use overtime hours to speed up manual processing
in an effort to deliver the affected mail within the applicable
service standard. See, e.g., OIG Rep. No. 20-088-R20 at 8.
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Generally, the Commission aims to select targets that are outcome-
oriented, consistent with the policy goals of the PAEA, objectively
measureable and verifiable, readily interpretable, and achievable.
Because the Commission is particularly focused on promoting the Postal
Service's longer-term financial viability, the Commission is interested
in selecting a metric(s) and target(s) for the PIM that would be
consistent with ancillary benefits such as increasing the opportunities
for reducing costs and improving service performance. Moreover, the
Commission intends to consider potential safeguards to incorporate into
the PIM, to ensure that results are adequately safeguarded against
manipulation and that selection of a shorter-term target would not
perversely incentivize behavior that would be detrimental in the
longer-term.
Therefore the Commission raises the following discussion points:
1. How to identify possible refinements to TFP to increase its
reliability, accuracy, and representativeness as a measure of
efficiency gains within the Postal Service's control?
2. How to identify alternative potential metric(s) other than TFP
that could be developed or refined as an accurate, reliable, and
representative measure of efficiency gains within the Postal Service's
control? Should the Commission consider industry-wide, economy-wide, or
similar comparative benchmarks for efficiency? Are there any metrics
that the Commission can learn from in adjacent industries, other
sectors, or other posts?
3. How to identify potential target(s) for efficiency gains?
4. How to identify potential metric(s) and target(s) related to
efficiency gains to promote the longer-term financial viability of the
Postal Service, such as by increasing the opportunities for cost
reduction and/or improved service performance?
5. How to identify potential safeguards designed to minimize
manipulation by the operator and prevent the operator from engaging in
behavior that would be detrimental over the longer-term?
D. Service Standards-Based Requirement
Additionally, the Commission intends to explore whether and how to
translate the policy goal of the PAEA to maintain high-quality service
standards into a specific PIM. This goal is intended to encourage the
maintenance of high-quality service standards established pursuant to
39 U.S.C. 3691, and to hold the Postal Service accountable for
consistently achieving those standards. See Order No. 4257 at 261.
The first aspect underlying this goal is referred to as ``service
standards,'' which are the stated days-to-delivery for different types
of mail. See id. at 250. Service standards are comprised of a delivery
day range and business rules.\28\ With respect to service standards,
the Commission is interested in whether introducing direct financial
consequences linked to maintenance of the existing service standards
would enhance the system, and if so, how to calibrate that mechanism.
See Order No. 5763 at 170.
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\28\ See id. at 251-252. By way of example, there are three
separate service standards for First-Class Mail: (1) 1-Day (referred
to as ``overnight''); (2) 2-Day; and (3) 3-5-Day; business rules
determine whether an individual mailpiece will be delivered
overnight, in 2 days, or in 3-5 days. See id. at 250-251.
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The second aspect underlying this goal implicitly requires
consistent achievement of service standards, which is referred to as
``service performance.'' See id. at 296; Order No. 4257 at 262-263. The
existing regulatory system has a mechanism to hold the Postal Service
accountable for its service performance: The annual compliance review
proceeding.\29\ If commenters have
[[Page 8334]]
suggestions on how to improve upon that mechanism, they may propose
changes in their response to this Order.
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\29\ Order No. 5763 at 296; Order No. 4257 at 264; Docket No.
RM2009-11, Order Establishing Final Rules Concerning Periodic
Reporting of Service Performance Measurements and Customer
Satisfaction, May 25, 2010, at 32 (Order No. 465).
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An effective price cap system maintains reliable, efficient, and
economical service.\30\ ``The Postal Service cannot be permitted to
degrade service in order to comply with the revenue constraints
associated with the price cap.'' Order No. 4257 at 255 (citing Docket
No. N2010-1, Advisory Opinion at 8). ``A reduction in service must be
warranted by declining demand for the service, rather than to ease the
obligation of adhering to the price cap.'' Docket No. N2010-1, Advisory
Opinion at 10. Introducing a direct financial incentive connected to
operational efficiency gains and cost reductions may undermine the
existing incentives to maintain high-quality service standards.\31\
Accordingly, to give due consideration to a potential need to
counterbalance such unintended consequences, the Commission raises the
following discussion points:
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\30\ Order No. 4257 at 255 (citing Docket No. N2010-1 Advisory
Opinion at 7-10).
\31\ See Order No. 5763 at 171 (citing Order No. 5337 at 142,
144; Order No. 4257 at 255); see also 2006 Joskow, supra at 8
(observing that regulatory mechanisms focusing on cost reductions
exclusively may lead to the operator reducing its service).
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1. How to identify potential regulatory changes that may be needed
to counterbalance any perverse incentive to degrade service standards
and/or service performance that may be created by introducing an
operational-efficiency based requirement?
2. How to identify the relative advantages of designing a system
that creates a direct financial link to changes in service standards?
3. What data and methods could be used to design a system that
creates a direct financial link to changes in service standards?
IV. Administrative Actions
The Commission establishes Docket No. RM2021-2 for consideration of
the matters discussed in the body of this advance notice of proposed
rulemaking.
The Commission will accept comments and reply comments concerning
the topics identified in this advance notice of proposed rulemaking.
Comments are due April 15, 2021. Reply comments are due May 17, 2021.
Pursuant to 39 U.S.C. 505, Richard A. Oliver is designated as an
officer of the Commission (Public Representative) to represent the
interests of the general public in this proceeding.
The Postal Service shall file the documentation and linked
workpapers for its TFP methodology to aid in the evaluation of TFP by
February 16, 2021. Materials filed in this docket will be available for
review on the Commission's website (https://www.prc.gov).
The Regulatory Flexibility Act requires federal agencies, in
promulgating rules, to consider the impact of those rules on small
entities. See 5 U.S.C. 601, et seq. If the proposed or final rules will
not, if promulgated, have a significant economic impact on a
substantial number of small entities, the head of the agency may
certify that the initial and final regulatory flexibility analysis
requirements of 5 U.S.C. 603 and 604 do not apply. See 5 U.S.C. 605(b).
In the context of this rulemaking, the Commission's primary
responsibility is in the regulatory oversight of the United States
Postal Service. The rules that are the subject of this rulemaking have
a regulatory impact on the Postal Service, but do not impose any
regulatory obligation upon any other entity. Based on these findings,
the Chairman of the Commission certifies that the rules that are the
subject of this rulemaking will not have a significant economic impact
on a substantial number of small entities. Therefore, pursuant to 5
U.S.C. 605(b), this rulemaking is exempt from the initial and final
regulatory flexibility analysis requirements of 5 U.S.C. 603 and 604.
V. Ordering Paragraphs
It is ordered:
1. Docket No. RM2021-2 is established for the purpose of
considering amendments to Chapter III of title 39 of the Code of
Federal Regulations as discussed in this advance notice of proposed
rulemaking.
2. The Postal Service shall file the documentation and linked
workpapers for its total factor productivity methodology, in a manner
that displays the formulae used and links to related spreadsheets by
February 16, 2021.
3. If the Postal Service proposes to use a metric other than total
factor productivity for a performance incentive mechanism, then it
shall file a detailed public explanation of the methodology along with
its comments.
4. Pursuant to 39 U.S.C. 505, Richard A. Oliver shall serve as an
officer of the Commission (Public Representative) to represent the
interests of the general public in this proceeding.
5. Interested persons may submit comments no later than April 15,
2021.
6. Interested persons may submit reply comments no later than May
17, 2021.
7. The Secretary shall arrange for publication of this order in the
Federal Register.
By the Commission.
Erica A. Barker,
Secretary.
Editorial Note: This document was received at the Office of the
Federal Register on January 19, 2021.
[FR Doc. 2021-01500 Filed 2-4-21; 8:45 am]
BILLING CODE 7710-FW-P