PRC Issues Advisory Opinion on USPS Proposal to Change Service Standards for First-Class Package Service Nationwide: Plan lacks demonstrable evidence
The Commission finds: *The Postal Service’s stated goals for the proposal appear reasonable. *The Postal Service assumed factors necessary for successful implementation of the proposal that have not been demonstrated. *It is unclear when the Postal Service plans to realize the full impact of its proposed changes to the service standards. The proposed changes may have a positive impact on the Postal Service’s ability to meet its service performance targets. *The Postal Service’s cost-saving estimates of the proposed changes may be inflated and the proposed changes would not substantially affect the Postal Service’s overall financial condition. *Flaws in the Postal Service’s transportation model could diminish its reliability. The Postal Service’s surface network impact projections and estimated cost changes are potentially inaccurate and unachievable. *The Postal Service has not demonstrated that it is operationally capable of running the complex surface network modeled to support the service standard changes it plans to implement. *Implementing processing and transportation changes prior to peak season may be challenging due to the continuation of the COVID-19 emergency and stress on the logistics industry. In general, the Commission finds that the proposed changes appear to be consistent with applicable statutory requirements. Nevertheless, the Postal Service has not demonstrated that its implementation of the proposed changes will satisfy the requirements.