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Federal Register / Vol. 86, No. 23 / Friday, February 5, 2021 / Proposed Rules
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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. 20144R20.
22 See Docket No. N20101, Advisory Opinion on Elimination of Saturday Delivery, March 24, 2011, at 115126 Docket No. N20101 Advisory Opinion; see also OIG Rep. No. 20144R20 at 15
16 finding insufficient management staff working during Tours 1 and 3; United States Postal Service, Office of the Inspector General, Report No.
19XG013NO000R20, U.S. Postal Services Processing Network Optimization and Service Impacts, October 15, 2018, at 1718, available at:
https www.uspsoig.gov/sites/default/files/
document-library-files/2020/19XG013NO000R20.pdf OIG Rep. No. 19XG013NO000R20
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 Chairmans Information Request No. 13, February 21, 2019, question 2.
24 See, e.g., United States Postal Service, Office of the Inspector General, Report No. 20088R20, 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
008R20 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. 20088R20 at 59
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 Services longer-term financial viability, the Commission is interested in selecting a metrics and targets 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 Services control?
2. How to identify alternative potential metrics other than TFP that could be developed or refined as an accurate, reliable, and representative measure of efficiency gains within the Postal Services 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. 20088R20 at 6
estimating that for FYs 20182019, 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 USPSFY1929, December 27, 2019, PDF file FY1929 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. 20088R20 at 8.

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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 targets for efficiency gains?
4. How to identify potential metrics and targets 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 251252. 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 35-Day; business rules determine whether an individual mailpiece will be delivered overnight, in 2 days, or in 35 days. See id. at 250
251.
29 Order No. 5763 at 296; Order No. 4257 at 264;
Docket No. RM200911, 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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