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USPS Office of Inspector General Semiannual Report
to Congress 2005 Highlights
April 1, 2005 – September
USPS OIG Semiannual Report to Congress
Changes to the
Mail Processing Network
posted December 2,, 2005
Evolutionary Network Development (END) is the Postal Service’s network
redesign strategy. The END initiative is to migrate to a flexible
network that increases operational efficiency, reduces costs, and
improves consistency of service. This future network will have Regional
Distribution Centers, Local Processing Centers, and Destinating
Processing Centers. Significant changes are also taking place in the
mail processing operations at the network level. Some examples of
processing changes are:
equipment that is being developed will sequence flats (large envelopes,
magazines, and publications) in delivery order. This will eliminate
manual sorting and thereby achieve savings. The Postal Service plans to
field test this equipment in April 2006 with deployment scheduled to
begin early in 2008.
equipment has been developed to further automate the parcel process and
eliminate manual keying of addresses. These machines are currently being
deployed in large plants to replace small parcel sorting machines.
some outdated and labor-intensive mail bag sorting machines will
increase efficiency in plants. Mail in trays is more efficient and
easier to process.
Service is also making network infrastructure changes to improve
efficiency and service, as well as reduce costs. Examples include:
50 annexes that are temporary plants used for mail processing when
space is limited.
38 Remote Encoding Centers that assign barcodes to mail pieces from
BMCs that process and distribute bulk Standard Mail and parcels to
Regional Distribution Centers to address redundancies in the network.
Priority Mail Processing Centers that process only Priority Mail, to
Logistics and Distribution Centers that process multiple types of
Service and the OIG will continue working together to identify
opportunities to improve operations and reduce costs. Some of the
near-term challenges for the Postal Service in making END a reality
include continuing to:
to a new infrastructure that focuses on processing mail based on
the processing network by implementing Area Mail Processing proposals.
the transportation network, including the Surface Transfer Centers
(formerly called the Hub and Spoke Program) and AMCs.
deploy various types of new mail processing equipment.
analysis of trailer requirements and lease versus buy decisions to
optimize vehicle management prior to the possible extension of the
National Trailer Lease in 2006.
section, we identify and assess the status of the major management
challenges confronting the Postal Service: cost control, revenue, human
capital, preserve integrity and security, and strategic direction.
Service has made a significant infrastructure investment to meet its
universal service obligation. Delivery now extends to more than 144
million delivery points involving more than 290,000 city and rural
letter carriers, and approximately 7,100 box delivery highway route
contractors. Based on these facts and our work in the areas of delivery,
mail processing operations, transportation, and contracting, we believe
cost control continues to be a significant issue for the Postal Service,
and will likely remain so for some time. The greatest opportunities to
reduce costs continue to be in the areas of optimizing the network to
control delivery costs, increasing efficiencies of technology
investments, and maximizing the cost-effectiveness of contracts.
As part of our
ongoing initiative to add value to the Postal Service, we implemented
the Value Proposition. Its aim is developing audit work that maximizes
benefits to the Postal Service and assists top management in reaching
their goals. Highlighted below are three Value Propositions for mail
processing facilities, highway transportation routes, and city letter
Mail Processing Plants
The Postal Service spends more than $20
billion annually on the mail processing infrastructure. It continues to
create a flexible logistics network that reduces Postal Service and
customers’ costs, increases operational effectiveness, and improves
In 2002, we
developed a methodology to evaluate the efficiency of the Postal
Service’s mail processing operations. During this reporting period, we
identified opportunities to improve operations by reducing more than
300,000 workhours in four mail processing facilities.
that the Postal Service:
efficiency and consolidate the network by reducing 202,000 work hours at
the Canton P&DF. This work hour reduction could produce a cost avoidance
of approximately $64 million in labor savings over 10 years.
efficiency of operations at the Los Angeles International Service
Center by reducing 85,000 work hours, producing a cost avoidance of
$26 million over 10 years.
efficiency of the Airmail Records Units at the Los Angeles and San
Francisco International Service Centers by reducing 13,207 work
hours, producing a monetary impact of about $4.4 million over 10 years.
BMC Highway Transportation Routes
Service spends more than $2.6 billion annually for contracted highway
transportation to move mail across nationwide highway networks. A major
component of the Postal Service’s highway transportation network is the
BMC network. It services the nation’s 21 BMCs and other processing
facilities. The BMC network transports magazines, advertising, and
merchandise shipped by major mailers, such as publishers, catalog
companies, and on-line retailers.
We signed a
pilot Value Proposition agreement with the Vice President of Network
Operations Management (NOM) in April 2005. Under this agreement, we
committed to completing four audits on BMC highway transportation
routes. We examined about 600 surface transportation contracts covering
more than 5,400 surface trips, issued four value proposition reports,
recommended elimination of more than 140 scheduled surface trips, and
identified potential savings exceeding $14 million.
Service agreed with close to 99 percent of all trip reduction,
elimination, or consolidation proposals. Our Value Proposition efforts
helped Postal Service management to optimize its surface network that
resulted in savings. We will continue our work under this agreement in
Dating back to
September 2004, we issued 10 audit reports under our national audit
project covering BMC Highway Transportation Routes. Working with Postal
Service headquarters, area, and plant transportation officials, we
identified 351 bulk mail transportation trip eliminations,
consolidations or modifications — potentially resulting in savings of
more than $36 million over the life of the contracts. The Postal Service
eliminated or modified most of these 351 trips without negatively
affecting service or operational flexibility.
transportation network is dynamic and fluid, and transportation
requirements continually change. This was especially evident immediately
after Hurricanes Katrina and Rita in August and September 2005,
respectively, when all Postal Service areas were reassessing the
transportation needs of the affected areas, redirecting transportation
to locations such as Houston, and quickly implementing changes in
surface transportation service. We will continue to work with the Postal
Service to assess its changing transportation needs.
delivery costs is critical for the Postal Service because mail delivery
requires a significant infrastructure investment, especially as delivery
points increase each year with population growth.
operations are the Postal Service’s largest cost center, making up 42
percent of the total labor hours in the FY 2006 Field Operating Budget.
These are hours that the city and rural letter carriers expend casing
mail in the office and delivering mail on routes. Salaries and benefits
for city carriers are budgeted at more than $16 billion, which
represents 34 percent of the Postal Service’s salaries and benefits in
the FY 2006 Field Operating Budget.
In FY 2004,
the Postal Service began implementing early morning standard operating
procedures (AMSOP), designed to assist the managers and postmasters in
making better business decisions for city delivery operations (for
example, estimating work hours accurately). The Vice President of
Delivery & Retail established a goal of 100 percent implementation of
AMSOP in FY 2005 at all facilities using the Delivery Operations
Information System (DOIS) that was deployed in 2002.
At the end of
FY 2005, 100 percent of the DOIS facilities (6,198) have implemented
AMSOP. DOIS provides delivery supervisors and managers with data (such
as workload status reports and carrier performance information) to
improve daily delivery operational performance.
also allows the supervisors and managers to determine the number of work
hours required to deliver the mail on daily carrier routes. Managed
Service Points (MSP), a part of DOIS, is a computerized tool designed to
monitor consistency of delivery time and enhance street management.
FY 2005, AMSOP was enhanced with standard delivery management practices
called the Lean Enterprise. This new initiative will establish standard
practices for managing all delivery and retail functions at the unit
level and oversight responsibilities at each tier of management above
the unit level. A key component of this standardization is identifying
the “vital few” delivery units— those units with the largest opportunity
for improvement that require specific management actions. In those units
the AMSOP, rural delivery standard operating procedures, and customer
service reviews will serve as tools to aid senior management in
identifying problems and developing suitable remedies.
One of our
initial Value Proposition Agreements is with the Vice President of
Delivery & Retail to assess management of City Letter Carrier
Operations. During this reporting period, we expanded our ongoing
assessment of city letter carrier operations to the Pacific and Great
the management of city letter carrier operations in the Santa Ana, San
Diego, and Chicago Districts in 18 delivery facilities (six per
showed that management can improve operations by adequately reviewing
the daily mail volumes and data in DOIS when determining daily work
hours for each carrier’s route to maintain efficiency and cost, using
the MSP information, and documenting carriers’ unauthorized overtime
determined that delivery unit supervisors and managers in these three
districts did not adequately match work hours with workload (mail
volume). We identified almost 216,000 unjustified work hours in these
three districts valued at about $5.5 million total in unrecoverable
costs for five-month periods in 2004 and 2005. We are continuing to
review city letter carrier operations in the Great Lakes
Area, and plan
to conduct additional audits in delivery operations to assist the Postal
Service in reducing the cost of delivery.
Service supports its delivery network with a vehicle fleet of about
212,000 vehicles. The fleet travels 1.19 billion miles each year to an
increasing number of delivery points. It also has a vehicle management
infrastructure designed to ensure operational readiness, safety, and
reliability. Approximately 188,000 of its vehicles are used for mail
delivery and collections.
In addition to
these vehicles, the Postal Service augments its delivery fleet with
leased vehicles obtained through local commercial sources or the General
Services Administration (GSA). In 2004, the Postal Service spent $564
million on delivery vehicles ($184 million for vehicle purchasing, $48
million for leasing, and $332 million for parts and maintenance). We
assessed the utilization of GSA-leased vehicles used in support of
delivery operations, and determined that management needs to more
effectively use Postal Service-owned delivery vehicles.
City and rural
carriers’ compensation systems are collectively bargained between the
Postal Service and their associated unions. The Postal Service contracts
with private individuals or firms for box delivery highway contract
issues pertaining to the city and rural carrier models. City carriers’
workweek is 40 hours per week, eight hours per day. Overtime is paid in
the event city carriers work beyond eight hours in a day and 40 hours in
a week, at 150 percent of the carrier’s regular rate and at 200 percent
beyond 10 hours on their scheduled work day or beyond 8 hours on their
non-scheduled work day.
compensation is the basis for compensating rural carriers. This
compensation is based on a route review that includes mail counts, route
miles, evaluated time as determined by the office, and the route
standard time. Evaluated compensation is generally based on rural
carriers assigned to evaluated routes totaling 35 hours or more.
routes, there is an incentive to complete the routes more efficiently;
hourly routes do not have incentives to be efficient. Because city
letter carriers are compensated hourly, there is little incentive for
them to deliver the mail quickly; in fact, this compensation method
could encourage slower delivery because of overtime compensation.
Service has two methods at its disposal to achieve this lower cost —
convert some existing city routes to rural routes or establish new
growth as Conversion from city to rural routes presents the Postal
Service with a challenging union and labor relations issue.
all changes to routes must be in accordance with applicable provisions
of the city and rural letter carrier national labor agreements.
Currently, the Postal Service has about 200 grievances relating to the
conversion of deliveries from city service to rural delivery service.
has generally been favorable to the unions. However, the obstacles that
exist in converting city to rural routes do not exist for new growth
Service estimates an increase of 1.89 million delivery points in FY
2005. Establishing rural routes in new growth areas, to the maximum
extent possible, would provide the best opportunity for reducing
USPS OIG Semiannual Report
to Congress 2005 Highlights
October 1, 2004 – March 31, 2005
posted June 24, 2005
USPS Inspector General's Semi-Annual Report
Customer Service Operations
the Postal Service maintains approximately 30,000 vending machines
(27,000 self-service postal centers and 3,000 other types of vending
equipment) that generate more than $1.9 billion in revenue. The OIG
assessed the vending program and recommended that area and district
officials improve the program’s effectiveness and efficiency by
relocating equipment that does not meet minimum revenue requirements,
and possibly reduce maintenance and repair costs by discontinuing the
use of obsolete equipment.
The OIG is
also assessing the APC deployment strategy. The Postal Service deployed
2,500 APCs in FY 2004, in an effort to move simple transactions to Post
Office lobbies and create a new low-cost alternative to the postal
counter. The Postal Service invested more than $95 million in the
deployment. As of March 2005, these APCs have generated more than $169
million in revenue for the Postal Service. The Postal Service has plans
for a second phase of the APC program project during FY 2005.
Service requires a significant infrastructure investment to meet its
universal service obligation to deliver millions of pieces of mail
daily. Delivery extends to more than 142 million delivery points,
involving approximately 290,000 city and rural letter carriers and more
than 6,000 box delivery highway route contractors to deliver the mail.
The Postal Service estimates an increase of 1.8 million delivery points
in FY 2005, mostly in rural areas. The Postal Service has, thus far,
managed this continued delivery point growth and improved its delivery
operations with these initiatives.
Letter Carrier Operations
delivery costs is necessary as the Postal Service continues to
experience increases in delivery points (addresses) each year. There is
an expectation that delivery point growth will continue to increase
annually as the population grows. Higher revenue-contribution mail
volume, such as First-Class Mail, has continued to decline as the public
increases its use of alternative means of messaging, although overall
revenue has increased slightly due to volume increases in other mail
operations accounted for 45 percent of the Postal Service’s total labor
hours in the FY 2005 field operating budget. These are hours city and
rural letter carriers spend casing mail in the office and delivering
mail on routes.
In FY 2005,
salaries and benefits for city carriers are budgeted at more than $16
billion, with a budget performance goal of reducing city delivery
workhours by 4.5 million. The Postal Service is making efforts to
improve delivery efficiency with standardization of city delivery
operations, in order to manage delivery workhours. In FY 2004, the
Postal Service began implementing AM Standard Operating Procedures (AM
SOP). These new morning management procedures assist managers and
postmasters in making better business decisions for city delivery
operations (e.g., more accurately estimating daily workhours needed).
Carrier Compensation Models
Service and its associated unions use collective bargaining and
compensation models on reach agreement to city and rural letter
carriers’ compensation. Compensation for box delivery highway contract
route (HCR), or contract carriers, is established via the contract the
Postal Service enters into with private individuals or firms. The OIG
will examine issues pertaining to these three letter carrier models to
determine whether lower cost alternatives exist.
continuing cost for the Postal Service is compensation for injured
workers. Due to the size of their bargaining unit workforce, the Postal
Service is the largest participant in the Department of Labor’s (DOL)
Office of Workers’ Compensation Programs (OWCP) in 2004, representing
about 30 percent of the total federal workforce that participated.
The Postal Service was also the largest payor to OWCP, with
approximately $830 million in payments for the same year.
examined a contract between the Postal Service and a preferred provider
organization supplying injury compensation medical bill review services.
The review determined and verified the cost savings claimed and realized
by the Postal Service. The Postal Service realized $2.2 million in cost
savings due to the contractor’s billing reviews from March 2001 through
July 2004. Although the cost savings was not the annual $30 million the
Postal Service anticipated, they are working with DOL and the contractor
to improve the program.
Consolidating, and Realigning Facilities.
The Postal Service reported that, as part of the END
initiative, it closed more than 50 facilities and annexes; closed 38
remote encoding centers; and consolidated some distribution operations.
of Facility Costs
Service operates more than 34,000 geographically dispersed facilities.
Specifically, it owns more than 8,800 facilities; leases more than
25,400 facilities (at a rental cost of approximately $946 million per
year); and occupies space in approximately 425 General Services
Administration/federal facilities. The Postal Service has identified
opportunities to reduce costs or maximize the return on property,
including standardization of building design, post-occupancy evaluations
of recently built facilities, and proactive leasing programs. It has
also developed a new prioritization system to
successfully carry out its longstanding mission of providing affordable,
universal service, the Postal Service relies on its 807,000 career and
non-career employees. Employees satisfaction with their work environment
is imperative to maximizing performance in an increasingly competitive
environment. Consequently, the Postal Service strives to maintain a
workforce that is effective, diverse, highly motivated, and recognized
for individual and group accomplishments.
Worksites. The Postal Service has taken a number of steps to improve
the work environment for its employees. The Workplace Environment
Improvement Advisory Committee, which includes representatives of
employee unions, management associations, labor relations, and human
resources, has identified “troubled worksites” based on established
criteria. These worksites may be susceptible to threatening or other
undesirable behavior as a result of individual or systemic problems. The
number of troubled Postal Service worksites was reduced from 39 in 2002
to eight in 2004 as a result of proactive intervention and resolution of
conducted six audits during this reporting period due to complaints of
hostile work environments at Postal Service worksites. The OIG found
that hostile work environments did not exist at these sites; however,
some employees experienced events that they perceived as hostile. The
OIG also found that Postal Service management quickly responded to
employee complaints and took the steps necessary to improve the
environment, including providing training and stand-up talks for
employees and removing supervisors who acted inappropriately.
Chain Management Business Practices
Service manages contracts with commitment values totaling more than $25
billion annually. The Postal Service issued over 39,000 contract actions
with commitment values exceeding $6.8 billion during FY 2004 and has,
over the years, implemented the supply chain management philosophy to
maximize the effectiveness and efficiency of these expenditures.
Service’s challenge in this area is controlling and reducing costs while
maintaining efficient acquisition practices with effective controls to
prevent fraud, waste, and mismanagement. The Postal
expanded the use of supply chain management business practices to meet
the Transformation Plan goal of continuing to implement and
institutionalize supply chain management. For example, it established
several strategic partnerships and expanded the use of web-based
ordering to help achieve its planned cost reductions. However, it must
continue to enforce measures that reduce the risk of loss and ensure
that it receives the best possible value from its purchases.
the OIG identified opportunities to improve the program management of
APC acquisition. Specifically, the Postal Service agreed with
recommendations to develop and document future APC requirements; prepare
schedules and cost estimates for planned upgrades not already on
contract; complete site security reviews; and ensure contractor
employees obtain appropriate security clearances. Additionally, the
Postal Service agreed to coordinate the site selection process for
future APCs with all affected stakeholders and to submit quarterly
Decision Analysis Report (DAR) compliance reports that fully communicate
missing APC functionality and operational concept changes.
The OIG plans
to expand program management reviews to include software acquisitions
and will also determine whether the Postal Service is properly planning
for, and using, contract types that can help reduce overall operating
due to congressional interest, the OIG is reviewing the efficiency of
the Postal Service’s use of a national office supply contract.
USPS OIG Semiannual Report
to Congress 2004 also discusses OWCP programs (changing from DOL
controlled to USPS) , commercialization of benefits programs, unaddressed
"neighborhood mail", flexibility in crossing crafts, Right-sizing Post Offices:
Providing Fair and Efficient Retail Services, more services through its
extensive retail network for other government agencies (such as the case with
passports), and more...
Rural Routes VS. City
APRIL 1, 2004 – SEPTEMBER
Postal Service’s largest labor cost center is delivery operations, which
encompasses 43 percent of total labor hours. These hours are time
expended by city and rural letter carriers sorting and delivering mail.
The Postal Service developed the management tool, Delivery Operations
Information System (DOIS), to aid delivery managers in matching workload
to workhours. Recent OIG reviews noted opportunities for supervisors and
managers in several delivery units to increase use of DOIS to improve
management of city letter carrier delivery operations. In FY 2005, the
OIG will expand these reviews to other postal delivery units, as well as
assess the rural and highway contract letter carrier models to determine
whether they are more efficient and cost-effective than the city letter
"...delivery costs for the Postal Service are significant and grow with
increases in the number of addresses. Unlike processing, street delivery
is intrinsically labor intensive. The Postal Service uses more than
220,000 city carriers and 60,000 rural carriers to deliver the mail to
more than 140 million delivery points.
Both city and rural carriers are Postal Service employees. However, city
carriers are paid
hourly wages with overtime, if worked, while rural carriers are paid an
annual salary based
on an evaluation of the average workload per route. The Postal Service
also contracts with
private individuals and businesses through competitive bidding for the
and delivery of mail to another two million delivery points.
Salaries and benefits for letter carriers, which constitute about 43
percent of total
salaries and benefits for the Postal Service, are projected for FY 2005
to be $21 billion
— $16 billion for city carriers and $5 billion for rural carriers. A
1999 study by Postal Rate Commission (PRC) staff concluded that the
costs of the different types of delivery
vary significantly. The study showed that the average annual cost per
route for city carriers
was about $104,000; for rural carriers, about $74,000; and for highway
A July 2004 report from the Government Accountability Office (GAO) noted
Postal Service estimated the annual cost in FY 2003 for each city door
was more than twice as expensive as rural delivery ($143) and over three
expensive as highway contract deliveries ($90). The GAO report said a
key factor in
determining the total cost of a route is the carriers’ compensation
system, which differs
for each type of carrier. Compensation for city and rural carriers is
between the Postal Service and the National Association of Letter
Carriers (NALC) and the
National Rural Letter Carriers Association (NRLCA), respectively.
contract carriers is established by the terms of their contracts.
The OIG plans to consult with the Postal Service and its unions to
explore the merits
and concerns regarding the various methods of compensating carriers for
a day’s work.
Because city letter carriers are compensated hourly, there is little
incentive for them to
deliver the mail quickly; in fact, this compensation method could
encourage slower delivery
because of overtime compensation. Rural and contract carriers have more
deliver mail quickly because, in general, their compensation does not
vary even if it takes
longer than normal to deliver a given day’s mail volume.
The Postal Service may consider exploring legislation permitting a form
of pay called
“administratively uncontrolled overtime,” a substitute form of
payment used by other
agencies for irregular, unscheduled overtime work, which is paid on an
annual rather than
hourly basis. This form of compensation could allow the Postal Service
predict and control overtime costs.
—(Administratively Uncontrolled Overtime) is an increment of up to
25 percent of basic pay paid on an annual basis for substantial amounts
of overtime work that cannot be controlled administratively and that
required on an irregular basis. (5 CFR 550.151) source: OPM
Semi-Annual Report to Congress (pdf) |
FIVE-DAY VERSUS SEVEN-DAY DELIVERY
The Postal Service
currently delivers mail six days-a-week as part of its universal
service obligation. Changing this six-day commitment to ﬁve or seven
days could be
explored for opportunities to enhance the Postal Service’s current financial
The Postal Service has already examined the five-day option and deemed it
from a financial perspective, or from impact on stakeholders. (On April
3, 2001 the Postal
Service Board of Governors directed management to study cost savings
with reducing delivery service to five days. On July 10, 2001, the
that the Postal Service will continue with its existing six-day delivery
service after hearing
preliminary findings on the study of the five-day option.) The estimated
net savings was
found to be negative due to loss of revenue and less than expected cost
More importantly, the adverse impact on customer service and customer
was deemed to be prohibitive. These findings suggest that increasing the
frequency to seven days may result in equally interesting but favorable
findings. It is
conceivable that a seven-day delivery service may result in additional
revenues that would
offset additional costs while increasing customer service and
satisfaction, and offering
the Postal Service a competitive advantage.
The OIG may consider exploring the operational feasibility and financial
of changing the frequency of delivery to seven days. The Postal Service
has a significant infrastructure in place that is generally not utilized
one day a week. Market research
and cost studies need to be undertaken to properly examine the
financial impact of such a proposal. Market research would be helpful to
needs and stakeholders’ reaction, and to estimate volume and revenue
There could also be political pressure against this change from
competitors such as
newspaper associations and other delivery services. If these studies,
favorable findings, the Postal Service may opt for a gradual approach (as
to a big bang approach) in implementing this change in a test market
before full and
USPS OIG Semi-Annual Report to
PROPERTY LINE MAILBOX
The Postal Service is
continually challenged to keep up with increasing mail delivery points
(drop-off points for mail, such as houses, businesses, housing
developments, etc.). It delivers to more than 140 million delivery
points, or stops, daily; and, as of the third quarter of 2004, there
were more than 1 million additional delivery points added over the
According to the U.S. Census Bureau, the nation’s population was more
than 282 million in 2000, and by 2010 it will be approximately 309
million. As urban and suburban areas continue to grow, maximizing mail
carrier efficiency to new and existing delivery points will be key to
controlling the costs of providing universal service.
City delivery workhours comprise the largest workhour segment in the
Postal Service. City letter carriers can make deliveries in vehicles, on
foot, or a combination of vehicle and on foot. The cost per delivery
increases as the delivery is made closer to the customer’s door.
Delivery to a customer’s door is the least efficient mode of delivery
because the carrier has to dismount from the vehicle, walk onto the
customer’s property and, in many cases,
climb stairs to perform the door delivery.
According to a recent Government Accountability Office review, door
delivery once was the norm in urban settings; however, the Postal
Service changed its policy in 1978 to limit additional door deliveries
to further enhance delivery efficiencies. To comply with this policy, the
Postal Service started working with developers of new single-family
neighborhoods to provide alternatives to door delivery. As a result,
property line delivery is one of the fastest growing modes of delivery.
According to Postal Service delivery officials, the only instance where
new delivery points would receive door delivery would be if the new
delivery point is established on a block that currently receives door
At the end of FY 2003, approximately 32 percent of deliveries (excluding
those to postal retail facilities) were still made to the door. This has
a significant impact on the workhours and thus the costs of delivery for
the Postal Service.
Instituting a national policy on mailbox placement, whereby existing
door deliveries would be converted to property line deliveries, might
possibly provide for savings in excess of a billion dollars annually to
the Postal Service. Other key factors such as customer concerns and
Congressional interests would need to be considered. This national
policy could also allow for certain exceptions, through a local approval
process, to provide continued door service for senior citizens and other
customers who for reasons of disability or other appropriate reasons
need door delivery on a continual or periodic basis.
Semi-Annual Report to Congress (pdf) |