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Post Office Discontinuance Meeting

The meeting with the Postal Service representatives was held on November 2, 2011 in the Max Community Center from 6:00pm until just after 7:00pm. Although we can't say if the meeting was a success or not, as the meeting was only part of a study conducted by the Postal Service to determine if they should close the Max Post Office.

About 30 people showed up for the meeting, in addition to the two Postal Service representatives, and Jason Frederick of the Benkelman Post. The meeting seemed to be a good one, with Postal Service representative Kevin Allard (postmaster from Gothenburg, Nebraska) giving an overview of the Postal Service and what the closure of the Max Post Office would mean to Max residents. After this presentation, Mr. Allard opened up the meeting for questions and answers from those present.

Among the topics discussed were the justification for closing the Max Post Office. The question was asked how can the Postal Service justify closing the post office when federal law prohibits the closing of any post office simply for economic reasons. Ms. Barton (the other Postal Service representative) stated that the Max Post Office was being studied for closure due to “insufficient customer demand” and “insufficient workload” rather than economic reasons. Mr. Allard stated that the law prohibiting the closure of any post office only for economic reasons had been changed and no longer contained that prohibition. Further research by this writer has shown that Senate Bill S.3831 which would change the law as Mr. Allard has stated, has not yet passed and is still being considered. Therefore, it is still a violation of federal law to close a post office solely for economic reasons.

A question was also brought up concerning the printed Postal Service proposal sent out by the Postal Service, which states that the justification for closing the Max Post Office was “severe building deficiencies” which were defined by the Postal Service as a lease which expires in July 2016. The question asked was, how can a five-year lease contract be considered a “severe building deficiency.” Neither Mr. Allard nor Ms. Barton would answer that question. When pressed, both Postal Service representatives said that they did not have an answer, but would “look into it.”

The question was asked, how would Max residents receive their mail if the Max Post Office was closed. Mr. Allard stated that residents would make that decision, but that the preferred method would be personally purchased mail boxes set near the road in front of each residence. When asked about the possibility of locked cluster boxes (as mentioned in the proposal), Mr. Allard stated that the Postal Service would rather not use cluster box units (CBU) due to the potential buildup of mud, snow and debris and the lack of anyone to clear it away from the CBU. It was also pointed out by Mr. Allard that there would be a potential for injury should anyone slip and/or fall as a result of that buildup.

Several other attendees asked about package pick-up and delivery, and also any possible reduction of services which could or would occur as a result of the post office closure. Mr. Allard explained that the route carrier would be able to handle any of these services from his or her truck while they are delivering mail. Other attendees voiced their opinions and suggestions regarding the Postal Services financial woes, and the Postal Service representatives made note of each of these, and offered some discussion for them. Mr. Allard emphasized the need for each resident to write everything down and send it to their congressmen, representatives, and also the Postal Regulatory Commission. Mr. Allard explained that it was very important for residents to document everything and to present as detailed as possible letters, proposals, etc., and that each piece would be placed into a “docket” (or file) and would be used to make the final decision as to whether or not to close the Max Post Office.

After the meeting concluded, both Mr. Allard and Ms. Barton remained at the community center to answer any other concerns individually with residents.

Max Post Office "Optional Comment Form"

Currently there are comment forms available at the Max Post Office for residents of Max to pick up and fill out, and return to the Max Post Office. These forms will be used by the United States Postal Service Office of Discontinuance to determine whether or not to close our post office.I would encourage every resident of Max to visit the Max post office, and pick up one of these forms, fill it out and turn it back in to the Max post office. We have until December 8, 2011 to get these forms picked up, filled out, and turned back in. If you do not have enough room on comment form to express your concerns, you can attach additional pages. Don't be afraid to do so. If you are not sure what to write on your comment form, I have already filled mine out and turned it back in. I am including my comment form here to give you some ideas of what you may want to write on yours. If you would like to simply print this out and use it as your own, please feel free to do so.

Optional Comment Form

Following are comments I wish to make concerning the proposed discontinuance of the MAX Post Office.

1. Effect on Your Postal Services. Describe any favorable or unfavorable effects you believe the proposal would have on the regularity or effectiveness of your postal services.

Closing the Max Post Office will reduce the postal services that are currently available to me. As a disabled person on a limited income, I rely heavily on the closeness of the Max Post Office both to receive my mail, and to send mail out. I also rely solely on the Max Post Office to provide availability of stamps and other mail services. Closing the Max Post Office will require me to drive 16 miles (round trip) on a daily basis, six days each week. That’s 4,992 miles a year I will have to drive just to pick up my mail. In addition to the wear and tear on my vehicle driving an addition 96 miles each and every week, closing the Max Post Office will now cost me an additional $18,294.64 per year just in fuel costs, and that is assuming the price per gallon of fuel does not go up.

In addition: I understand that if the Max Post Office is closed, mail delivery service in Max could be replaced by either a cluster box unit, or personal mail boxes for all residents clustered together in a specific location in Max (at an additional cost to me). If either of these options are utilized, then any mail delivered to them will not be inside (as they are now) and thus will expose me to potentially hazardous weather conditions, i.e. I will need to leave my vehicle to retrieve my mail (thus exposing me to inclement weather), and will expose me to potentially hazardous conditions (such as slipping on ice or mud and possibly causing injury). With the delivered mail being exposed to the weather as it would be in conditions such as these, the mail could be damaged or destroyed. Also, if the personally purchased mail box option is utilized, any mail delivered to it would be unsecured and available to any thief who happened to come along, whether in town or off of the highway.

So, in other words, closing the Max Post Office will cause me personally an undue and unnecessary physical and financial hardship.

2. Effect on Your Community. Please describe any favorable or unfavorable effects that you believe the proposal would have on your community.

In addition to the comments I have made in section #1 above, which would hold true for most if not all of the residents of Max and the surrounding area; as a small rural community, the Max Post Office serves not just as a place to pick up or deliver mail, or purchase postal supplies, but also as a community gathering place and a place to hear news that directly affects the Max community – news that is generally not available anyplace else. News bulletins containing local news and items of interest are posted at the Max Post Office for all residents to read, and residents meeting one another at the Post Office also provide important community related news. Closing the Max Post Office would take this all away from the community.

3. Other Comments. Please provide any other views or information that you believe the Postal Service should consider in deciding whether to adopt the proposal.

According to the “Proposal to Close the Max Post Office,” the USPS has several “reasons” to close the Max Post Office. The reasons given in this document (written and provided by the USPS) are as follows: “The office is being studied for possible closing or consolidation due to the following reasons; Due to declining office workload, which may indicate that maintaining this facility is not warranted. Over the past several years, this office has experienced a steady decline in revenue and/or volume. The Post Office facility had severe building deficiencies that included: Leased Facility Lease Expires 7/1/2016 Termination Clause – 30 days. The Max Post Office provides retail service from 800 to 1215 Monday through Friday and 800 to 945 on Saturday. Over the past several years there has been a decline in the amount of walk in revenue generated. This revenue trend is as follows: FY 07 $5,407, FY 08 $4,365, FY 09 $6,201 and FY 10 $3,637.”

There are then only two reasons given by the USPS to close the Max Post Office. The first is a decline in revenue. Not only do the Max Post Office revenue figures given by the USPS not show a declining revenue trend (note that revenue went up in FY 2009 to a point higher than the previous two years, so a declining revenue “trend” is not substantiated by these figures); but more importantly, federal law forbids the closing of a post office solely for operating at a deficit. The USPS is required to show reasons other than economic reasons for closing a post office. This brings us to the second reason given in the proposal to close the Max Post Office, as written by the USPS itself.

The second reason given by the USPS for closing the Max Post Office is, “The Post Office facility had severe building deficiencies that included: Leased Facility Lease Expires 7/1/2016 Termination Clause – 30 days.” A building deficiency would indicate a structural problem. A “severe” building deficiency would indicate a severe structural problem. There are no structural problems with the building currently housing the Max Post Office. A guaranteed lease of the building for the next five years, with a 30-day termination clause, cannot be considered a “severe building deficiencies” as stated by the USPS, nor would any logical person consider them as such.

The proposal written and provided by the USPS states there are several “advantages” and “disadvantages” to closing the Max Post Office. I would like to address these here.

“Some advantages of the proposal are:”

1. “The rural and contract carriers may provide retail services, alleviating the need to go to the post office.” (this is also reiterated in the “disadvantages” section of the proposal). Since the rural and contract carriers will not, and cannot be in Max at the same specific time each day, Max residents (many of whom are elderly or disabled) will be forced to wait, sometimes for an hour or more, and sometimes in inclement weather, in order to take advantage of USPS retail services. Maintaining the Max Post Office would alleviate this problem. Having the rural and contract carriers provide retail services is a distinct disadvantage and hardship on the residents of Max.

2. “Customers opting for carrier service will have 24-hour access to their mail.” As we already have 24-hour access to our mail with the Max Post Office, this is not an advantage.

3. “Savings for the postal service contribute in the long run to stable postage rates and savings for customers.” Any savings the USPS would incur by closing the Max Post Office would be inconsequential, and akin to removing one teaspoon of water from the Pacific Ocean in an attempt to lower the water level. In fact, if the USPS closes 16,000 of the most “under-performing” post offices in the country (or in other words, half of the post offices in the country), the USPS would save less than two percent of the USPS yearly budget of $67 billion. Again, this is not an advantage.

4. “CBU’s can offer the security of individually locked mail compartments.” As with #2 above, we already have individual locked mail compartments inside the Max Post Office. Closing the post office and installing CBU’s would lower the security of our delivered mail by placing it outside in the elements, and removing the added security of the Postmaster. In addition, Max residents would be exposed to inclement weather and potentially hazardous conditions with the use of CBU’s – conditions not currently faced. Number 4 is also not an advantage.

5. “Customers opting for carrier service will not have to pay post office box fees.” As we currently do not pay post office box fees, this too is not an advantage.

6. “Saves time and energy for customers who drive to the post office to pick up mail.” Closing the Max Post Office, and requiring Max residents to drive to Benkelman (16 miles roundtrip) to pick up mail will not save time and energy for customers. In fact it will increase the time and energy residents currently spend to pick up mail. Also, driving the additional 16 miles to pick up mail will require more driving time, and more exhaust pollutants into the atmosphere. For a government such as ours, who is so strongly advocating for environment friendly solutions, this is not only a disadvantage for Max residents, but a step backwards for the Presidents initiatives. 

“Some disadvantages of the proposal are:”

1. “The loss of a retail outlet and a postmaster position in the community.” This disadvantage is a very real disadvantage, and will not be alleviated by the use of rural and contract carriers as explained above (in “advantages” point #1).

2. “Meeting the rural or contract delivery carrier at the box to transact business.” As noted above, since the rural and contract carriers will not, and cannot be in Max at the same specific time each day, Max residents (many of whom are elderly or disabled) will be forced to wait, sometimes for an hour or more, and sometimes in inclement weather, in order to take advantage of USPS retail services. Therefore, this too is a very real disadvantage that will create a hardship on many if not all of the residents of Max – a disadvantage that can only be alleviated by maintaining the Max Post Office.

3. “A change in the mailing address.” Although the community name will continue to be used, assigned a new carrier route address to each resident of Max will not only be time consuming for the USPS, but will also incur the related costs of several USPS employees time and efforts to accomplish this. It will also force Max residents to incur the costs of both mail and telephonic change of address notifications. Another disadvantage that can only be alleviated by maintaining the Max Post Office.

The only conclusion that can logically be made when thoroughly examining both the “advantages” and “disadvantages” to the closing of the Max Post Office (as presented in the USPS proposal), is that there are no advantages to closing the Max Post Office. Not one. Only disadvantages for both the USPS and the residents of Max.

The “Proposal to Close the Max Post Office” (as written and provided by the USPS) also speaks about the “Effect on Employees” and “Economic Savings.” The proposal states that the current Postmaster “may be moved to another facility if possible” and the PMR “may be separated from the Postal Service.” The proposal also states: “The Postal Service estimates a ten year savings of $297,437 with a breakdown as follows:”

Building Maintenance………………………………………….$0

Utilities…………………………………………………………..$0

Transportation………………………………………………….$12,097

EAS Craft & Labor……………………………………………..$365,971

Contracts………………………………………………………..$0

Rent……………………………………………………………..$0

Relocation One-Time Cost…………………………………...$0

Total Ten Year Savings……………………………………….$297,437

(breakdown is taken verbatim from the USPS proposal)

Evidently, the USPS is not supplying the correct figures for this breakdown. Figures are either intentionally missing and not available for examination, or simply miscalculated. That aside, however, the only savings would be the yearly lease of the building, and the termination of both employees. Transportation costs would not be saved, as the rural or contract carrier would still make the same trip to Max as he always has. He would simply be delivering the mail to a CBU or cluster of customer purchased mail boxes rather than picking up mail at the post office as he currently does. The only transportation that would change would be the large truck that delivers bags of mail in the morning and picks up bags of mail in the evening. Closing the Max Post Office would mean that large truck would not travel the 4 blocks in the morning and the 4 blocks in the evening. An inconsequential savings of transportation costs that amount to only a few cents per day.

The amount saved by the USPS on the yearly lease would in turn cause the lease holder to lose that income. Terminating either or both of the post office employees may amount to a miniscule savings for the USPS. In either case, however, these actions would serve to add to already rising unemployment rates in Nebraska and at the national level. In a time where unemployment is over 9% and not expected to go any lower at any time over the next five years; and in a time where the current administration is attempting to focus on job retention and job creation, it seems counter-productive for the USPS to even consider adding to the already high unemployment rate.

The proposal also goes on to say that the Max Post Office provides delivery and retail services to 29 PO Box or general delivery customers and no delivery route customers. This statement is pure fantasy. Not only does the Max Post Office provide delivery and retail services to the 29 box holders, but the Max Post Office also provides retail services to non-box holders in the community of Max, as well as providing retail services to those who live on route outside of Max, and these include some who live closer to Max than to Benkelman, but still have an assigned Benkelman address.

The proposal states in its conclusion the following: “Taking all available information into consideration, the Postal Service has determined that the advantages outweigh the disadvantages and this proposal is warranted.” Clearly, the only “advantages” are to the USPS, and those being only a miniscule financial savings, which, as I pointed out above, is not a legally allowable reason to close any post office. When one takes into consideration the inconvenience’s and the hardships and the potential dangers the residents of Max will be faced with if the Max Post Office closes, the it is clear that the disadvantages in closing the Max Post Office far outweigh and possible advantage.

_________________________________________________________________________________

Name of Postal Customer                                                                              Signature of Postal Customer

________________________________________________________________________________

Mailing Address

________________________ ________________________________________________________

City, State, and ZIP Code                                                                                                                Date

SAMPLE APPEAL LETTER TO POSTAL REGULATORY COMMISSION

SAMPLE APPEAL LETTER TO POSTAL REGULATORY COMMISSION

(This sample letter is to be used only during the 30 day appeal period when the Final Determination is posted)

Ruth Y. Goldway

Chairman

Postal Regulatory Commission

901 New York Avenue, NW, Suite 200

Washington, DC 20268-0001

Dear Chairman Goldway:

The Postal Service has posted the Final Determination to (insert close or if service is to be provided by another post office use consolidate).

The attached list containing signatures of customers served by (insert name and state of post office) do not feel that the alternate service offered by the Postal Service is acceptable as it does not provide a maximum degree of regular and effective service that customers are entitled to in accordance with federal law.

(If the post office is to be closed or has been closed by emergency suspension and they offer rural delivery as the alternative service, use the following).

We do not believe closing our post office and providing delivery and retail service by a carrier meets the requirements of the above mentioned rule.  It is very inconvenient for customers to purchase money orders/stamps and sending/receiving accountable mail such as registered and certified mail.  We are also concerned about vandalism, theft of our mail, and identity theft.

(If the Postal Service offers service through a community post office or village post office (contract facility), use the following).

The decision to change our post office to a contract facility is unacceptable.  We are concerned that a contract employee may not be adequately trained, provide efficient prompt service that we have received for years and are very concerned about mail security.  Only limited postal services will be offered at this “new” office.   We understand that money order service will not be available at a contract facility.  Also, the Postal Service can terminate the contract and close the contract facility at any time and we customers would lose our appeal rights to the Postal Regulatory Commission.

(If the Postal Service is consolidating with a neighboring post office, use the following).

The decision has been made to combine our post office with the (insert name and state of post office) and we strongly oppose this action.  The postmaster plays an important role in our community, especially for the elderly and infirm.  Many of our residents do not drive or even have checking accounts and they will be hit hard by this decision because our postmaster assists them in meeting their obligations.  Our postmaster helps them pay bills, writes money orders and provides much non-postal caretaking. 

(Use this paragraph in all the situations previously listed).

Our post office represents the federal government to our residents and it is hard for us to understand the reasoning.  We understand that the Postal Service has financial issues but isn’t it against the law to close a post office just to save money?  How can the federal government spend billions of dollars in an attempt to create jobs and then a branch of the federal government eliminates vital jobs in small towns?   Rural America is just as important as urban America.  A post office in urban America may be a luxury or a convenience but in rural America a post office is a necessity and we are proud to see our flag flying over our post office every day.

Sincerely,

(Community leader signs with name and address and attaches a copy of a petition signed by residents who want to keep their post office).

Max Post Office Closure Meeting

The meeting with the U.S. Postal Service representatives is tomorrow, November 2nd, from 6:00pm until 8:00 pm. It is important for all Max residents to be at this meeting as this will be our only opportunity to meet face to face with the Postal Service to express our concerns about the closing of our post office, and to ask some pointed questions as to why our post office is scheduled for closure. Even if you do not wish to speak out in defense of our post office, your presence at this meeting will show the postal representatives that the residents of Max care about our post office. If you would like to be there, but are not sure what kind of questions to ask, here are some sample questions and statements that you may like to bring up.

The questions are not listed in any particular order and may be revised as deemed necessary.  Select the questions applicable to your situation:

1. I rely on the postmaster to help me pay my bills using money orders because I do not have a checking account.  Will the rural carrier or highway contract carrier have time to help me?  I’m concerned because the carrier doesn’t come at the same time every day, so how can I receive money order service?  If I have to leave cash in the mailbox to buy stamps, someone might steal it.  I am also fearful about the possibility of becoming a victim of identity theft.

2. Our post office is a meeting place for our community and also provides bulletin board space for us to post notices of community activities, provides a safe school bus stop, and serves many other functions. When the post office closes, the town dies.  Clearly, the post office is a vital communication center and can provide guidance and information for America’s rural population during a national emergency.

3. The federal government is spending an enormous amount of taxpayer money trying to create jobs. Why is the Postal Service trying to cut back and/or eliminate such an important business/service?

4. I understand that facility specifications for a contract post office are not as stringent as a real post office building operated by real postal employees. The security of the mail, safety, and health issues should be the same, whether postal services are provide at a real post office or a contract facility. Why are there separate facility specifications for a post office operated by postal employees and a contract post office operated by private contractors?

5. We are concerned about losing our community identity if our post office is closed.

6. Our carrier has been relocated to another post office, meaning I have to travel some distance to pick up my mail when I receive a notification from the Postal Service. I no longer drive nor do I have anyone to drive me. Further, I will not receive important mail if I have to wait until the next delivery day for redelivery. Further, the carrier does not arrive at about the same time each and I may be subject to inclement weather while I wait by my mailbox for service provided at our post office.

7. Why are you proposing to move (or have moved) our post office boxes to a private business?  Are you going to close our post office?  Will the contract workers handling our mail be trained adequately? Will he or she give the mail the same urgency and security as in a real post office?  Will the contract person provide the same urgency in sorting the mail to my post office box? [Note: It is my understanding that the postal service is considering either installing locked cluster PO boxes, or, having the residents purchase their own mail boxes and having them installed in a centralized location]

8. Will the training given to the contract person be the same training a real postal                            employee receives for doing the same job?  What controls will you put in place to ensure compliance with postal rules and regulations?  How will you know if an adequately trained person will be providing service at the contract unit?  Additionally, how can I be certain I am being charged the right fees for packages and other type mail? I never have such concerns or doubts when I go to a real post office.[Note: see the notation with question #7]

9. Why will this Village Post Office not be able to sell me a money order or allow me to mail a package to my son overseas in the military unless it happens to fit into a certain size box?  [Note: see the notation with question #7]