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Federal Register / Vol. 86, No. 152 / Wednesday, August 11, 2021 / Rules and Regulations they were opposed to the proposed service standard changes, which they alleged would permanently slow down the delivery of much of the mail;
that the Postal Services focus should be on improving the delays that plagued service during the past year; that the Postal Service is critical to keeping all citizens connected; and that the commenters depend on reliable and affordable postal services. These last views, expressed repeatedly in over 100,000 submissions, confirm that the American public overwhelmingly depends upon reliable and affordable postal services.
To be clear, this does not mean that many comments do not also express an interest in more expeditious service. Yet the comments undeniably recognize that reliability is significant. Further, what they express clearly was the essential nature of postal services to the public, and that they want to see these essential services both maintained and improved for years to come. The comments highlight the many aspects of what quality postal services include:
reliability and affordability, as well as fast delivery. These sometimes competing qualities must be balanced when designing service standards. 39
U.S.C. 3691b1C.
The Postal Service has taken the comments into account, and has determined that they do not furnish a reasonable basis to deviate from the initial set of proposed changes to the service standards in question. In particular, the comments do not present any compelling explanation for why adding a day or two to a minority of First-Class Mail and end-to-end Periodicals volume would make postal services insufficiently speedy, let alone negate the benefits of enhanced reliability, cost effectiveness, and financial sustainability that will inure to all. The Postal Service therefore considers that these new standards properly balance the various statutory policies regarding the design of service standards, and should be implemented.

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III. Response to Comments A. Representative Concerns To the extent that anecdotes of performance failures relate to First-Class Mail and end-to-end Periodicals, the Postal Service has concluded that the changes will help to ameliorate, rather than worsen, service performance and customer satisfaction. By enacting these service standards, the Postal Service will be able to increase service reliability and thus ensure that its service standards provide customers with more meaningful service
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expectations compared to the current standards.
As an initial matter, the Postal Service notes that over 60 percent of First-Class Mail volume will remain unaffected by the changes, and that 70 percent of First-Class Mail volume will continue to have a service standard of 3 days or less.
The Postal Service further notes that it has been unable to achieve its service performance targets for many years, and that these service failures illustrate the weakness of the current transportation model. Indeed, the commenters who cite these failures make a strong case for the changes. Bills do not, in general, arrive late due to the insufficient speed of surface transportation, but rather because a mailer relied on a service standard that failed to materialize: had the mailer known that delivery would take longer, the mailer could have mailed sooner. Many of the commenters frustrations, in other words, appear to have arisen from the lack of reliability currently ingrained in the transportation network. Service standards that are reliably achieved can be planned around; service failures of fluctuating duration often cannot.
Numerous commenters related anecdotes of service performance failures, complaining of slow delivery times and occasional lost items, which resulted in missed payments on bills, delayed receipt of prescription medications, and other inconveniences.
These commenters frequently misconstrue service changes as an attempt to enshrine and regularize the service failures of the past year. As noted above, to the extent that these anecdotes relate to First-Class Mail and end-to-end Periodicals, the Postal Service submits that the changes will help to ameliorate, rather than worsen, service performance and customer satisfaction. Many of the items about which customers express concern, such as bills, tend to ship from locations of relatively close geographical proximity, and as such, they will figure among the group of unaffected mailings. Further, the Postal Service aims, with the new service standards, to deploy a transportation network capable of delivering on time and with consistency, one on which customers can count. Vulnerable customers who rely on the Postal Service for predictable delivery would particularly stand to benefit from the enhanced service reliability that will result from these changes.
Some comments express skepticism of surface transportation. For example, one commenter asserts that the justification/rationale . . . that airplanes are less reliable than trucks
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driving across country is beyond absurd, and speculated that delivering First-Class Mail cross country by using only trucks realistically would need a standard maximum of 12 days, and that even then the actual could exceed 15
days. One individual commenter, who intervened in the PRC docket and then re-submitted a copy of his brief from that case, comments that air and surface transportation are comparably reliable, and that, moreover, non-transportation root causes of delay make a 95 percent service performance target impossible.
However, experience indicates both that the air transportation network is less reliable than surface transportation, and that by beneficially exploiting the capabilities of the surface transportation network, the Postal Service can achieve a greater degree of reliability. With regard to root causes of delay, the changes afford additional time to rectify certain handling errors and transit failures. Furthermore, these changes form but one part of a broader strategy, set forth in the Postal Services comprehensive Delivering for America strategic plan, to achieve 95 percent success in the metric of service performance; the Postal Service has not portrayed these changes as sufficient to achieve that end, but rather as a necessary component, among others, to ultimately achieving a 95 percent service level.
The same commenter references certain service standard changes implemented in the years 2000 and 2001, pursuant to which the Postal Service defined a service standard to match a range of truck driving time.
The commenter then asserts that these former changes did not yield an increase in improved reliability, and suggests that the current changes will likewise fail to realize their stated goal.
Nonetheless, the commenter offers little evidence to legitimize any such comparison between two different service standard changes occurring in two vastly different contexts. The current changes are different from and more extensive than the changes implemented two decades ago.
At least one commenter alleges that if one can plan for 95 percent on-time delivery within a five-day timeframe, one can make a plan for 95 percent ontime delivery within a three-day timeframe. Actual experience, though, overwhelmingly indicates that the Postal Service cannot, in a cost-effective manner, achieve 95 percent on-time delivery within a 3-day timeframe. The Postal Service has not met its First-Class Mail service targets in years, and these service failures have been particularly
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