Special Study on Flats Operations, 82431-82433 [2023-25914]
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Federal Register / Vol. 88, No. 225 / Friday, November 24, 2023 / Notices
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VI. Notice and Comment
VII. Ordering Paragraphs
[FR Doc. 2023–25563 Filed 11–22–23; 8:45 am]
In accordance with the Postal Service
Reform Act of 2022 (PSRA),1 the
Commission submitted a report on the
findings of its flats operations study on
April 6, 2023.2 The PSRA also required
the Postal Service to develop and
implement a plan to remedy each
inefficiency identified in the
Commission’s flats study or provide an
explanation why remedying such
inefficiency is not practicable. PSRA
section 206(b)(1). On October 6, 2023,
the Postal Service submitted its plan to
the Commission for approval.3
I. Introduction
BILLING CODE 4510–79–P
POSTAL REGULATORY COMMISSION
[Docket No. SS2022–1; Order No. 6803]
Special Study on Flats Operations
Postal Regulatory Commission.
Notice.
AGENCY:
ACTION:
The Commission is
recognizing a recently filed Postal
Service document with the Commission
concerning its plan to remedy
inefficiencies identified in the
Commission’s flats study. This notice
informs the public of the filing, invites
public comment, and takes other
administrative steps.
DATES: Comments are due: January 5,
2024.
SUMMARY:
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:
ddrumheller on DSK120RN23PROD with NOTICES1
State/
terr.
Employer name
David A. Trissell, General Counsel, at
202–789–6820.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Introduction
II. Background
III. Postal Service Flats Plan
IV. Motions
V. Commission Analysis
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21:46 Nov 22, 2023
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II. Background
The Postal Service has faced
significant challenges in processing and
delivering flats 4 in a cost-effective
manner. For years, in response to
statutory requirements and Commission
directives, the Postal Service has been
designing and implementing operational
and pricing initiatives to address these
issues, but the Postal Service has been
unable to either quantify the expected
1 Postal Service Reform Act of 2022, Public Law
117–108, 136 Stat. 1127, available at https://
www.congress.gov/117/plaws/publ108/PLAW117publ108.pdf (PSRA).
2 Flats Operations Study Report, April 6, 2023
(Flats Operations Study Report).
3 See Submission of the United States Postal
Service Flats Plan Pursuant to Section 206 of the
Postal Service Reform Act of 2022, October 6, 2023
(Notice); see also Notice, Postal Service Flats Plan
Pursuant to Section 206 of the Postal Service
Reform Act of 2022, October 6, 2023 (Flats Plan).
4 Flats, or flat-shaped mail, refers to large
envelopes, magazines, and other flexible,
rectangular mail that meet certain criteria. See
United States Postal Service, Publication 32,
Glossary of Postal Terms, July 1, 2016, at 88,
available at https://postalpro.usps.com/storages/
2016-04/pub32_glossary.pdf.
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Sfmt 4703
impact of those initiatives or isolate the
impact to specific products.5
The PSRA required the Commission,
in consultation with the Inspector
General of the United States Postal
Service (USPS OIG), to conduct a study
evaluating the Postal Service’s flats
operations. PSRA section 206(b)(2)(A).
The statute also required the
Commission to submit a report on the
findings of the study no later than 1 year
after enactment of the PSRA. Id. To
carry out the study, the Commission
collected and reviewed flats data
provided by the Postal Service. Flats
Operations Study Report at 1.
Commission staff also visited Postal
Service facilities over a period of several
months, visited mailers’ facilities,
contracted with an operations expert,
and consulted with the USPS OIG. Id.
On April 6, 2023, the Commission
submitted its report on the findings of
the study to Congress and the
Postmaster General.
In its Flats Operations Study Report,
the Commission identified multiple
causes of inefficiencies in the collection,
sorting, transportation, and delivery of
flats. Flats Operations Study Report at
23–133. In addition, the Commission
quantified the effects of the volume
trends, certain investment decisions,
excess capacity, and operational
inefficiencies of the Postal Service on
costs that are attributable to flats. Id. at
134–209. At the conclusion of the Flats
Operations Study Report, the
Commission provided eight suggestions
to the Postal Service for consideration as
the Postal Service develops its plan. Id.
at 210.
In response to the report, the Postal
Service was required to develop and
implement a plan to remedy each
5 Flats Operations Study Report at 23 (citing
Docket No. ACR2021, Annual Compliance
Determination, March 29, 2022, at 31, 60).
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Federal Register / Vol. 88, No. 225 / Friday, November 24, 2023 / Notices
inefficiency identified in the
Commission’s flats study or provide an
explanation why remedying such
inefficiency is not practicable. PSRA
section 206(b)(1). Prior to implementing
the plan, the Postal Service must give
the public an opportunity to comment
on the plan and the Commission must
approve the plan. Id. On August 16,
2023, the Postal Service published a
draft plan and sought public comments
on the plan.6 On October 6, 2023, the
Postal Service submitted its Flats Plan
to the Commission for approval.
ddrumheller on DSK120RN23PROD with NOTICES1
III. Postal Service Flats Plan
The Postal Service asserts that its plan
conforms to the relevant statutory
requirements and should be approved
by the Commission. Notice at 2. In
addition to considering public
comments, the Postal Service states that
it considered the Commission’s
suggestions, and the findings that
inform those suggestions. Id. It notes
that the Flats Plan incorporates the
majority of the Commission’s
recommendations. Id. The Postal
Service asserts that where it was unable
to accept a Commission
recommendation fully, the Flats Plan
details how such recommendations may
in the future become practicable. Id.
At the beginning of its Flats Plan, the
Postal Service describes how the
implementation of the Delivering for
America (DFA) plan will enable it to
increase revenue from flats, while also
reducing costs by addressing the
inefficiencies that currently exist in the
processing, transporting, and delivery of
flats. Flats Plan at 2. The Postal Service
claims that since enactment of the DFA
Plan in March 2021, it has made
significant progress.7 In addressing the
Commission’s suggestions from the Flats
Operations Study Report, the Postal
Service discusses specific initiatives
relating to flats, and explains that these
initiatives are part of the DFA plan.
Flats Plan at 2–3. The initiatives include
pricing to increase flats revenue,
redesigning the network, improving the
data quality, and pursuing initiatives to
reduce bundle breakage. Id. at 4–17. The
Postal Service also addresses the
6 See Notice of Availability of Draft Plan for FlatShaped Mail, 88 FR 55740 (August 16, 2023); see
also Postal Service Flats Plan Pursuant to Section
206 of the Postal Service Reform Act of 2022,
August 15, 2023, available at https://
about.usps.com/psra-flats-study/usps-flats-plan.pdf
(Draft Flats Plan). Interested parties were invited to
submit written comments during a 30-day period,
terminating on September 15, 2023. Notice at 2.
7 Id. at 1–2 (referring to United States Postal
Service, Delivering for America, Second-Year
Progress Report (April 2023), available at https://
about.usps.com/what/strategic-plans/delivering-foramerica/assets/usps-dfa-two-year-report.pdf).
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21:46 Nov 22, 2023
Jkt 262001
relationship between mail volume and
productivity, and provides analysis to
support its view that productivity
declines and therefore increased costs,
are due in part to volume declines. Id.
at 17–24. Finally, the Postal Service
addresses comments from the public
received on its Draft Flats Plan, and
‘‘clarif[ies] certain aspects of the flats
plan in response to those comments.’’
Id. at 24–27.
IV. Motions
After the Postal Service filed its Flats
Plan, the Commission received motions
for leave to provide comments on the
Flats Plan from the News Media
Alliance (NMA) and the Association for
Postal Commerce (PostCom).8
NMA and PostCom both state that
acceptance of their comments on the
Flats Plan would be in the public
interest and assist in the Commission’s
decision whether to approve or reject
the Flats Plan. NMA Motion at 1;
PostCom Motion at 1. PostCom also
provides examples of where the
Commission has accepted pleadings in
other dockets where such pleadings
were not specifically authorized but
would assist the Commission in its
deliberations. PostCom Motion at 1.
These motions are granted.
In its comments, NMA states the Flats
Plan ‘‘lacks the comprehensiveness,
metrics, and accountability’’ needed to
remedy well-established flats
inefficiencies.9 NMA recommends that
the Commission reject the plan and
direct the Postal Service to address the
deficiencies identified by NMA. NMA
Comments at 1.
PostCom also urges the Commission
to reject the Flats Plan and direct the
Postal Service to revise the plan to
respond to PSRA directives.10 PostCom
attaches its comments submitted to the
Postal Service on the Draft Flats Plan,
where PostCom asserts the draft plan
lacked, among other things, targets
toward cost coverage improvement, and
did not consider the diseconomies of
scale that result from declining flats
volume. PostCom Comments at 1.
PostCom states that despite its
comments, the Postal Service submitted
the final plan that is ‘‘essentially
unchanged’’ from its draft plan. Id.
8 Motion for Acceptance of Comments, October
16, 2023 (NMA Motion); Motion for Leave to File
Comments, October 18, 2023 (PostCom Motion).
9 Comments of the News/Media Alliance on the
Postal Service’s Flats Plan, October 16, 2023, at 1
(NMA Comments).
10 Comments of the Association for Postal
Commerce, October 18, 2023, at 1 (PostCom
Comments).
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V. Commission Analysis
Upon consideration of the Flats Plan,
the Commission finds that, as
submitted, this plan presents a highlevel proposal that lacks both important
details and analytical support needed to
evaluate the plan and determine
whether it sufficiently and effectively
addresses the inefficiencies identified
by the Commission and described in the
Flats Operations Study Report. The
Commission suggested in the Flats
Operations Study Report that the Postal
Service quantify the impact of any
initiatives on cost to ensure its efforts
are effective. Flats Operations Study
Report at 3. While the Postal Service
explains that there are processes to
validate potential net financial benefits
of initiatives and methodologies for
calculating and tracking the results, it
does not provide any quantifiable
metrics for potential benefits or cost
impact results as it describes the
initiatives throughout the Flats Plan.
See Flats Plan at 17.
Furthermore, the Postal Service does
not provide a clear timeline for
implementing the initiatives, with some
initiatives seemingly already
implemented and others in various
stages of implementation. See Flats Plan
at 7, 9–14. Additionally, while some
initiatives appear to have been
implemented as early as FY 2021, there
is no timeline for when quantifiable
impacts of these initiatives will be
available.
In its response to public comments,
the Postal Service references technology
updates to the Automated Flats Sorting
Machine. See id. at 26. This effort is
well-advised and further details of these
plans, including timelines, would
improve the Commission’s ability to
evaluate the plan. Similarly, it is
important for the Commission to
understand the plan and timeline for
other technology improvements,
including to the equipment used to
process bundles as a means to reduce
bundle breakage.
In addition, to thoroughly evaluate
the Flats Plan, it is important for the
Commission to learn more about the
improved data-collection tools
developed to enhance the reporting and
tracking of bundle irregularities and
bundle breakage. See id. at 7–9. The
discussion of these tools highlights their
capability to link images and other
evidence of mail irregularities to the
Mailer Scorecard but does not clearly
specify whether the tools also resolve
the other bundle breakage data quality
issues the Commission set out in the
Flats Operations Study Report. Id.; see
also Flats Operations Study Report at
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Federal Register / Vol. 88, No. 225 / Friday, November 24, 2023 / Notices
85–87. These data quality issues include
missing data in the bundle breakage
dataset for bundles without a fullservice Intelligent Mail barcode (IMb)
and the lack of ability to identify where
in the mail processing flow a bundle
breakage occurs. See Flats Operations
Study Report at 85–87. Addressing these
additional issues would allow the Postal
Service to identify trends and causes of
bundle breakage within the handling
and processing of bundles, which were
previously lacking in the data.
Accordingly, the Commission will seek
more information from the Postal
Service to enable evaluation of the Flats
Plan prior to issuing its approval. The
Commission also will invite comments
from other interested persons on
whether the Flats Plan is consistent
with applicable statutory requirements.
VI. Notice and Comment
Interested persons may submit
comments on the Flats Plan no later
than January 5, 2024. Pursuant to 39
U.S.C. 505, Manon A. Boudreault is
designated as an officer of the
Commission (Public Representative) to
represent the interests of the general
public in this proceeding.
VII. Ordering Paragraphs
It is ordered:
1. The News Media Alliance’s Motion
for Acceptance of Comments, filed
October 16, 2023, is granted.
2. The Association for Postal
Commerce’s Motion for Leave to File
Comments, filed October 18, 2023, is
granted.
3. Comments on the Flats Plan are due
no later than January 5, 2024.
4. Pursuant to 39 U.S.C. 505, Manon
A. Boudreault is appointed to serve as
an officer of the Commission (Public
Representative) to represent the
interests of the general public in this
proceeding.
5. The Secretary shall arrange for
publication of this notice in the Federal
Register.
ddrumheller on DSK120RN23PROD with NOTICES1
By the Commission.
Erica A. Barker,
Secretary.
[FR Doc. 2023–25914 Filed 11–22–23; 8:45 am]
BILLING CODE 7710–FW–P
VerDate Sep<11>2014
21:46 Nov 22, 2023
Jkt 262001
POSTAL REGULATORY COMMISSION
[Docket Nos. MC2024–55 and CP2024–56;
MC2024–56 and CP2024–57; MC2024–57
and CP2024–58; MC2024–58 and CP2024–
59; MC2024–59 and CP2024–60; MC2024–
60 and CP2024–61; MC2024–61 and
CP2024–62; MC2024–62 and CP2024–63;
MC2024–63 and CP2024–64; MC2024–64
and CP2024–65; MC2024–65 and CP2024–
66]
New Postal Products
Postal Regulatory Commission.
Notice.
AGENCY:
ACTION:
The Commission is noticing a
recent Postal Service filing for the
Commission’s consideration concerning
a negotiated service agreement. This
notice informs the public of the filing,
invites public comment, and takes other
administrative steps.
DATES: Comments are due: November
29, 2023.
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:
SUMMARY:
Table of Contents
I. Introduction
II. Docketed Proceeding(s)
I. Introduction
The Commission gives notice that the
Postal Service filed request(s) for the
Commission to consider matters related
to negotiated service agreement(s). The
request(s) may propose the addition or
removal of a negotiated service
agreement from the Market Dominant or
the Competitive product list, or the
modification of an existing product
currently appearing on the Market
Dominant or the Competitive product
list.
Section II identifies the docket
number(s) associated with each Postal
Service request, the title of each Postal
Service request, the request’s acceptance
date, and the authority cited by the
Postal Service for each request. For each
request, the Commission appoints an
officer of the Commission to represent
the interests of the general public in the
proceeding, pursuant to 39 U.S.C. 505
(Public Representative). Section II also
establishes comment deadline(s)
pertaining to each request.
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82433
The public portions of the Postal
Service’s request(s) can be accessed via
the Commission’s website (https://
www.prc.gov). Non-public portions of
the Postal Service’s request(s), if any,
can be accessed through compliance
with the requirements of 39 CFR
3011.301.1
The Commission invites comments on
whether the Postal Service’s request(s)
in the captioned docket(s) are consistent
with the policies of title 39. For
request(s) that the Postal Service states
concern Market Dominant product(s),
applicable statutory and regulatory
requirements include 39 U.S.C. 3622, 39
U.S.C. 3642, 39 CFR part 3030, and 39
CFR part 3040, subpart B. For request(s)
that the Postal Service states concern
Competitive product(s), applicable
statutory and regulatory requirements
include 39 U.S.C. 3632, 39 U.S.C. 3633,
39 U.S.C. 3642, 39 CFR part 3035, and
39 CFR part 3040, subpart B. Comment
deadline(s) for each request appear in
section II.
II. Docketed Proceeding(s)
1. Docket No(s).: MC2024–55 and
CP2024–56; Filing Title: USPS Request
to Add Priority Mail & USPS Ground
Advantage Contract 108 to Competitive
Product List and Notice of Filing
Materials Under Seal; Filing Acceptance
Date: November 17, 2023; Filing
Authority: 39 U.S.C. 3642, 39 CFR
3040.130 through 3040.135, and 39 CFR
3035.105; Public Representative:
Jennaca D. Upperman; Comments Due:
November 29, 2023.
2. Docket No(s).: MC2024–56 and
CP2024–57; Filing Title: USPS Request
to Add Priority Mail Express, Priority
Mail & USPS Ground Advantage
Contract 14 to Competitive Product List
and Notice of Filing Materials Under
Seal; Filing Acceptance Date: November
17, 2023; Filing Authority: 39 U.S.C.
3642, 39 CFR 3040.130 through
3040.135, and 39 CFR 3035.105; Public
Representative: Gregory S. Stanton;
Comments Due: November 29, 2023.
3. Docket No(s).: MC2024–57 and
CP2024–58; Filing Title: USPS Request
to Add Priority Mail Express, Priority
Mail & USPS Ground Advantage
Contract 15 to Competitive Product List
and Notice of Filing Materials Under
Seal; Filing Acceptance Date: November
17, 2023; Filing Authority: 39 U.S.C.
3642, 39 CFR 3040.130 through
3040.135, and 39 CFR 3035.105; Public
Representative: Gregory S. Stanton;
Comments Due: November 29, 2023.
1 See Docket No. RM2018–3, Order Adopting
Final Rules Relating to Non-Public Information,
June 27, 2018, Attachment A at 19–22 (Order No.
4679).
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Agencies
[Federal Register Volume 88, Number 225 (Friday, November 24, 2023)]
[Notices]
[Pages 82431-82433]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2023-25914]
=======================================================================
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POSTAL REGULATORY COMMISSION
[Docket No. SS2022-1; Order No. 6803]
Special Study on Flats Operations
AGENCY: Postal Regulatory Commission.
ACTION: Notice.
-----------------------------------------------------------------------
SUMMARY: The Commission is recognizing a recently filed Postal Service
document with the Commission concerning its plan to remedy
inefficiencies identified in the Commission's flats study. This notice
informs the public of the filing, invites public comment, and takes
other administrative steps.
DATES: Comments are due: January 5, 2024.
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. Postal Service Flats Plan
IV. Motions
V. Commission Analysis
VI. Notice and Comment
VII. Ordering Paragraphs
I. Introduction
In accordance with the Postal Service Reform Act of 2022 (PSRA),\1\
the Commission submitted a report on the findings of its flats
operations study on April 6, 2023.\2\ The PSRA also required the Postal
Service to develop and implement a plan to remedy each inefficiency
identified in the Commission's flats study or provide an explanation
why remedying such inefficiency is not practicable. PSRA section
206(b)(1). On October 6, 2023, the Postal Service submitted its plan to
the Commission for approval.\3\
---------------------------------------------------------------------------
\1\ Postal Service Reform Act of 2022, Public Law 117-108, 136
Stat. 1127, available at https://www.congress.gov/117/plaws/publ108/PLAW-117publ108.pdf (PSRA).
\2\ Flats Operations Study Report, April 6, 2023 (Flats
Operations Study Report).
\3\ See Submission of the United States Postal Service Flats
Plan Pursuant to Section 206 of the Postal Service Reform Act of
2022, October 6, 2023 (Notice); see also Notice, Postal Service
Flats Plan Pursuant to Section 206 of the Postal Service Reform Act
of 2022, October 6, 2023 (Flats Plan).
---------------------------------------------------------------------------
II. Background
The Postal Service has faced significant challenges in processing
and delivering flats \4\ in a cost-effective manner. For years, in
response to statutory requirements and Commission directives, the
Postal Service has been designing and implementing operational and
pricing initiatives to address these issues, but the Postal Service has
been unable to either quantify the expected impact of those initiatives
or isolate the impact to specific products.\5\
---------------------------------------------------------------------------
\4\ Flats, or flat-shaped mail, refers to large envelopes,
magazines, and other flexible, rectangular mail that meet certain
criteria. See United States Postal Service, Publication 32, Glossary
of Postal Terms, July 1, 2016, at 88, available at https://postalpro.usps.com/storages/2016-04/pub32_glossary.pdf.
\5\ Flats Operations Study Report at 23 (citing Docket No.
ACR2021, Annual Compliance Determination, March 29, 2022, at 31,
60).
---------------------------------------------------------------------------
The PSRA required the Commission, in consultation with the
Inspector General of the United States Postal Service (USPS OIG), to
conduct a study evaluating the Postal Service's flats operations. PSRA
section 206(b)(2)(A). The statute also required the Commission to
submit a report on the findings of the study no later than 1 year after
enactment of the PSRA. Id. To carry out the study, the Commission
collected and reviewed flats data provided by the Postal Service. Flats
Operations Study Report at 1. Commission staff also visited Postal
Service facilities over a period of several months, visited mailers'
facilities, contracted with an operations expert, and consulted with
the USPS OIG. Id. On April 6, 2023, the Commission submitted its report
on the findings of the study to Congress and the Postmaster General.
In its Flats Operations Study Report, the Commission identified
multiple causes of inefficiencies in the collection, sorting,
transportation, and delivery of flats. Flats Operations Study Report at
23-133. In addition, the Commission quantified the effects of the
volume trends, certain investment decisions, excess capacity, and
operational inefficiencies of the Postal Service on costs that are
attributable to flats. Id. at 134-209. At the conclusion of the Flats
Operations Study Report, the Commission provided eight suggestions to
the Postal Service for consideration as the Postal Service develops its
plan. Id. at 210.
In response to the report, the Postal Service was required to
develop and implement a plan to remedy each
[[Page 82432]]
inefficiency identified in the Commission's flats study or provide an
explanation why remedying such inefficiency is not practicable. PSRA
section 206(b)(1). Prior to implementing the plan, the Postal Service
must give the public an opportunity to comment on the plan and the
Commission must approve the plan. Id. On August 16, 2023, the Postal
Service published a draft plan and sought public comments on the
plan.\6\ On October 6, 2023, the Postal Service submitted its Flats
Plan to the Commission for approval.
---------------------------------------------------------------------------
\6\ See Notice of Availability of Draft Plan for Flat-Shaped
Mail, 88 FR 55740 (August 16, 2023); see also Postal Service Flats
Plan Pursuant to Section 206 of the Postal Service Reform Act of
2022, August 15, 2023, available at https://about.usps.com/psra-flats-study/usps-flats-plan.pdf (Draft Flats Plan). Interested
parties were invited to submit written comments during a 30-day
period, terminating on September 15, 2023. Notice at 2.
---------------------------------------------------------------------------
III. Postal Service Flats Plan
The Postal Service asserts that its plan conforms to the relevant
statutory requirements and should be approved by the Commission. Notice
at 2. In addition to considering public comments, the Postal Service
states that it considered the Commission's suggestions, and the
findings that inform those suggestions. Id. It notes that the Flats
Plan incorporates the majority of the Commission's recommendations. Id.
The Postal Service asserts that where it was unable to accept a
Commission recommendation fully, the Flats Plan details how such
recommendations may in the future become practicable. Id.
At the beginning of its Flats Plan, the Postal Service describes
how the implementation of the Delivering for America (DFA) plan will
enable it to increase revenue from flats, while also reducing costs by
addressing the inefficiencies that currently exist in the processing,
transporting, and delivery of flats. Flats Plan at 2. The Postal
Service claims that since enactment of the DFA Plan in March 2021, it
has made significant progress.\7\ In addressing the Commission's
suggestions from the Flats Operations Study Report, the Postal Service
discusses specific initiatives relating to flats, and explains that
these initiatives are part of the DFA plan. Flats Plan at 2-3. The
initiatives include pricing to increase flats revenue, redesigning the
network, improving the data quality, and pursuing initiatives to reduce
bundle breakage. Id. at 4-17. The Postal Service also addresses the
relationship between mail volume and productivity, and provides
analysis to support its view that productivity declines and therefore
increased costs, are due in part to volume declines. Id. at 17-24.
Finally, the Postal Service addresses comments from the public received
on its Draft Flats Plan, and ``clarif[ies] certain aspects of the flats
plan in response to those comments.'' Id. at 24-27.
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\7\ Id. at 1-2 (referring to United States Postal Service,
Delivering for America, Second-Year Progress Report (April 2023),
available at https://about.usps.com/what/strategic-plans/delivering-for-america/assets/usps-dfa-two-year-report.pdf).
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IV. Motions
After the Postal Service filed its Flats Plan, the Commission
received motions for leave to provide comments on the Flats Plan from
the News Media Alliance (NMA) and the Association for Postal Commerce
(PostCom).\8\
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\8\ Motion for Acceptance of Comments, October 16, 2023 (NMA
Motion); Motion for Leave to File Comments, October 18, 2023
(PostCom Motion).
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NMA and PostCom both state that acceptance of their comments on the
Flats Plan would be in the public interest and assist in the
Commission's decision whether to approve or reject the Flats Plan. NMA
Motion at 1; PostCom Motion at 1. PostCom also provides examples of
where the Commission has accepted pleadings in other dockets where such
pleadings were not specifically authorized but would assist the
Commission in its deliberations. PostCom Motion at 1. These motions are
granted.
In its comments, NMA states the Flats Plan ``lacks the
comprehensiveness, metrics, and accountability'' needed to remedy well-
established flats inefficiencies.\9\ NMA recommends that the Commission
reject the plan and direct the Postal Service to address the
deficiencies identified by NMA. NMA Comments at 1.
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\9\ Comments of the News/Media Alliance on the Postal Service's
Flats Plan, October 16, 2023, at 1 (NMA Comments).
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PostCom also urges the Commission to reject the Flats Plan and
direct the Postal Service to revise the plan to respond to PSRA
directives.\10\ PostCom attaches its comments submitted to the Postal
Service on the Draft Flats Plan, where PostCom asserts the draft plan
lacked, among other things, targets toward cost coverage improvement,
and did not consider the diseconomies of scale that result from
declining flats volume. PostCom Comments at 1. PostCom states that
despite its comments, the Postal Service submitted the final plan that
is ``essentially unchanged'' from its draft plan. Id.
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\10\ Comments of the Association for Postal Commerce, October
18, 2023, at 1 (PostCom Comments).
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V. Commission Analysis
Upon consideration of the Flats Plan, the Commission finds that, as
submitted, this plan presents a high-level proposal that lacks both
important details and analytical support needed to evaluate the plan
and determine whether it sufficiently and effectively addresses the
inefficiencies identified by the Commission and described in the Flats
Operations Study Report. The Commission suggested in the Flats
Operations Study Report that the Postal Service quantify the impact of
any initiatives on cost to ensure its efforts are effective. Flats
Operations Study Report at 3. While the Postal Service explains that
there are processes to validate potential net financial benefits of
initiatives and methodologies for calculating and tracking the results,
it does not provide any quantifiable metrics for potential benefits or
cost impact results as it describes the initiatives throughout the
Flats Plan. See Flats Plan at 17.
Furthermore, the Postal Service does not provide a clear timeline
for implementing the initiatives, with some initiatives seemingly
already implemented and others in various stages of implementation. See
Flats Plan at 7, 9-14. Additionally, while some initiatives appear to
have been implemented as early as FY 2021, there is no timeline for
when quantifiable impacts of these initiatives will be available.
In its response to public comments, the Postal Service references
technology updates to the Automated Flats Sorting Machine. See id. at
26. This effort is well-advised and further details of these plans,
including timelines, would improve the Commission's ability to evaluate
the plan. Similarly, it is important for the Commission to understand
the plan and timeline for other technology improvements, including to
the equipment used to process bundles as a means to reduce bundle
breakage.
In addition, to thoroughly evaluate the Flats Plan, it is important
for the Commission to learn more about the improved data-collection
tools developed to enhance the reporting and tracking of bundle
irregularities and bundle breakage. See id. at 7-9. The discussion of
these tools highlights their capability to link images and other
evidence of mail irregularities to the Mailer Scorecard but does not
clearly specify whether the tools also resolve the other bundle
breakage data quality issues the Commission set out in the Flats
Operations Study Report. Id.; see also Flats Operations Study Report at
[[Page 82433]]
85-87. These data quality issues include missing data in the bundle
breakage dataset for bundles without a full-service Intelligent Mail
barcode (IMb) and the lack of ability to identify where in the mail
processing flow a bundle breakage occurs. See Flats Operations Study
Report at 85-87. Addressing these additional issues would allow the
Postal Service to identify trends and causes of bundle breakage within
the handling and processing of bundles, which were previously lacking
in the data. Accordingly, the Commission will seek more information
from the Postal Service to enable evaluation of the Flats Plan prior to
issuing its approval. The Commission also will invite comments from
other interested persons on whether the Flats Plan is consistent with
applicable statutory requirements.
VI. Notice and Comment
Interested persons may submit comments on the Flats Plan no later
than January 5, 2024. Pursuant to 39 U.S.C. 505, Manon A. Boudreault is
designated as an officer of the Commission (Public Representative) to
represent the interests of the general public in this proceeding.
VII. Ordering Paragraphs
It is ordered:
1. The News Media Alliance's Motion for Acceptance of Comments,
filed October 16, 2023, is granted.
2. The Association for Postal Commerce's Motion for Leave to File
Comments, filed October 18, 2023, is granted.
3. Comments on the Flats Plan are due no later than January 5,
2024.
4. Pursuant to 39 U.S.C. 505, Manon A. Boudreault is appointed to
serve as an officer of the Commission (Public Representative) to
represent the interests of the general public in this proceeding.
5. The Secretary shall arrange for publication of this notice in
the Federal Register.
By the Commission.
Erica A. Barker,
Secretary.
[FR Doc. 2023-25914 Filed 11-22-23; 8:45 am]
BILLING CODE 7710-FW-P