Letter to Ruth Y. Goldway, Chairman of the Postal Regulatory Commission

Letter

Dear Chairman Goldway:

As the Postal Regulatory Commission (PRC) solicits public comments for its advisory opinion on the U.S. Postal Service's (USPS) plan to consider closing nearly 3,700 post offices nationwide, we would appreciate your consideration of our concerns on behalf of the residents and businesses in West Virginia that would be impacted by the potential closure of 150 post offices in our State.

The potential closures would affect roughly one in five postal facilities in West Virginia and follow an aggressive schedule of Area Mail Processing studies to consolidate distribution and processing operations in the State. These additional potential closures threaten to further disrupt postal services in our State, inconveniencing and burdening businesses and residents alike.

The law recognizes that postal facilities in profitable markets would subsidize postal services in less profitable markets. The Congress required the Postal Service to "provide a maximum degree of effective and regular postal services to rural areas, communities and small towns where post offices are not self-sustaining," declaring that "no small post office shall be closed solely for operating at a deficit."

And, yet, the financial condition of the Postal Service is the primary catalyst for these closure studies, targeting smaller, rural post offices where foot traffic and revenues are, not surprisingly, less than their more profitable counterparts. The Postal Service's filing with your Commission lists 2,825 post offices that earn less than $27,500 per year, which tend to be located in rural areas.

Forcing rural communities in our State to make do with less is contrary to the spirit of the law. The practical reality is that rural areas depend on the Postal Service because they often lack access to alternative means like the Internet for conducting postal businesses.

In many cases, closing the local post office in rural areas creates an undue burden on seniors and lower-income working families. These customers rely on the post office as the only convenient and realistic option for purchasing money orders, and safely retrieving and sending mail -- whether a monthly benefit check, vital prescription medication, or a parcel pickup or mailing for a routine business transaction. Mail theft also is a problem in rural areas, requiring residents to have mail boxes at the local post office. It's inconvenient, to say the least, to have to drive to the next town, 20 miles into the hills, just to pick up your daily mail.

In addition, these postal facilities act as community centers and gathering spots and can be the heart of communities. We find it deeply ironic that when public meetings are held about closing postal facilities in some West Virginia communities, there is such a big turnout that the only place available to host such meetings is the local post office.

Village Post Offices may work in some rural communities, as the Postal Service has proposed, but not in all. The Postal Service must be mindful in conducting its discontinuance studies that Village Post Offices and other contract postal units cannot provide a full range of services like a traditional post office. Such contract postal units will inevitably lead to degradation in postal services for communities.

We must ensure the opportunity for public comment and participation during this closure process. Residents in the communities we represent too often feel the public meetings and comment periods organized by the Postal Service are perfunctory, and that decisions have already been made before community input is considered. Public input is especially important in considering whether alternative access channels, such as a Village Post Offices, are really feasible and practical for some communities. The Postal Service should be urged to not rely too heavily in assuming one alternative access channel will work for everyone.

We must also ensure comprehensive cost-benefit analysis in considering a postal closure, incorporating not just the foot traffic and financial balance sheets for each post office, but also the impact of a closure on the community, on postal workers, and on mail delivery services. Residents should know the potential cost savings within a state when postal facilities are closed, and when that savings is expected to be realized. They should be able to comment on whether the potential savings warrants the disruption and inconvenience to the community. Certainly, rural post offices should not be closed in order to finance post offices in more profitable areas.

We urge you to ensure that the Postal Service thoroughly considers how to protect vulnerable populations from the negative impacts of a post office closure and that its policies and procedures comport with the law.