“Defining a USO Is The Way To Go”

The following is a perspective from postal commentator Gene Del Polito, Executive Director- Association for Postal Commerce, was recently published in the PostCom Bulletin

Not long ago, I wrote an article on the status of postal reform in the last Congress. I’ll spare you the pain of having the read the whole thing, but here is the part I believe is most relevant.

Coming up with possible alternative business models isn’t child’s play. On the other hand, it isn’t rocket science either. In fact, I just recently had the task of discussing a range of alternative models at a postal conference (PostalVision 2020), and, to be sure, the range of alternatives  presented was far from exhaustive or definitive. The goal, however, was just to illustrate what  could be done if a serious effort were put forth.
There was one reality, though, that became abundantly clear during this search for alternatives, i.e., you can’t devise alternative business models if you have left undefined the very mission you  expect the enterprise to fulfill. We know one thing for sure. America still needs a viable universal  mail delivery system, and preferably one that is self-supporting. But saying that we need a viable  universal mail delivery system implies that there surely must be some underlying expectation of  the enterprise.

Believe it or not, we as a nation have never clearly and succinctly defined what we believe is or  should be the universal service obligation (USO) we expect for our post. Look as hard as you  might, it’s impossible to find anywhere in current postal law a definition of that universal service  need that would need to be fulfilled by whomever serves as the nation’s designated postal  service provider. In a sense, this is as fault-filled as a coach telling his team that their obligation  is to win games. Win games? How many? All of them? Some of them? Fairly by observing the  rules? Or by any means possible? This is about as dumb as expecting the Navy Seals to go out  and do their thing without first being told the mission they needed to accomplish in sufficient  detail to ensure the highest probability of success.

So, before we go on our merry way trying to enact some new postal law. Before we go willy-nilly  assuming we know what that USO should be, it’s important to understand that whatever USO  we define must be based on a clear-headed definition of what we believe constitutes the  nation’s present and future needs. Given today’s economic realities, we need to give up  yesteryear’s vision of basing our postal system on some nice, but no longer affordable, social  wants. Today, we can count ourselves luck if we simply can find the resources necessary for
addressing the nation’s needs.

To date, we have done very little (if anything at all) to define in any meaningful way what we expect  from our postal system in the years ahead. What are the needs we expect the Postal Service to address?  In what manner? And how shall we measure and know just how well these needs are being served? Think of it this way, you wouldn’t create a new position on your staff without first writing a description  of the job you expect to be done. How then can we shape the Postal Service of the future (or the future  of any alternative postal provider) without first specifying the job we expect the to be accomplished?By 2016, Section 3622 (3) of the Postal Accountability and Enhancement Act of 2006 requires the  following:

Ten years after the date of enactment of the Postal Accountability and Enhancement Act and as appropriate thereafter, the Commission shall review the system for regulating rates and classes  for market-dominant products established under this section to determine if the system is  achieving the objectives in subsection (b), taking into account the factors in subsection (c). If the  Commission determines, after notice and opportunity for public comment, that the system is  not achieving the objectives in subsection (b), taking into account the factors in subsection (c),  the Commission may, by regulation, make such modification or adopt such alternative system  for regulating rates and classes for market-dominant products as necessary to achieve the  objectives.

It would be reasonable to require in any new law that a report be made to Congress by a responsible  party on its efforts to set forth a more formal determination of the Postal Service’s universal service  obligation. It then could be up to Congress, either by acting affirmatively or simply by allowing the  recommendations be implemented without opposition, this formal definition of the nation’s postal USO,  which would serve as the benchmark against which the Postal Service could be measured.

Who should take on the responsibility of specifying what this universal service obligation should be?  Should it be Congress? Should it be the Postal Service? The Postal Service’s Office of the Inspector  General? The Postal Regulatory Commission?

Can you imagine what it would be like to ask 535 members of Congress to agree on the how and the  substance of defining the nation’s universal postal service obligation? It would be like trying to herd 535  feral cats. The job would never get down. Besides, Congress, these days, has its hands filled with  weightier matters than this. Asking Congress to define the USO out of the blue is unwise, unnecessary,  and unfair.

What about the Postal Service? Couldn’t it do the job? Perhaps it could. But the Postal Service has done  a less than sterling job so far in coming forth with anything even remotely resembling a strategic vision  for the nation’s postal system, let alone take a crack at defining the USO. Besides, the Postal Service  seems to be looking to Congress to take up the task. Sure, and when it does, it quickly would be  followed by a great deal of postal weeping and gnashing of teeth over the outcome. Never leave to  someone else a job you should do yourself.

What about the Office of the Postal Inspector General? Is this a task that it could reasonably undertake?  Given the creativity and openness that has marked much of the thought work the OIG has undertaken  thus far, one could easily envision the OIG serving as the reasonable agent for accomplishing this task.

And what about the Postal Regulatory Commission? After all, it already has produced one report  ostensibly dealing with the USO. While the PRC could possibly undertake this task, its initial effort fell far  short of providing the kind of real-world analysis of the future needs of those who rely on the postal  system as a vehicle for business communication and commerce. Plainly put, someone has to do it, and inserting the necessary authorizing language into a postal reform  bill is a task that is somewhat less complicated than rocket science. For instance, here’s something that  could work the trick.


(1) IN GENERAL.-Not later than 9 months [or any other such period of time that may be needed]  after the date of enactment of this Act, the [fill in your agency of choice] shall submit a report to  the President and Congress on the definition of the universal service obligation to provide  adequate and efficient postal services to patrons across the nation.

(2) CONTENTS.-The report under this subsection shall include-

(A) a comprehensive analysis of the nation’s current universal postal service needs, including a  review of rural and urban areas;

(B) a comprehensive description of the methods used by the [fill in your agency of choice] to  derive the nation’s postal needs across all sectors of the nation and the economy; and

(C) the scope and standards of universal service likely to be required in the future in order to  meet the needs and expectations of the United States public, including all types of mail users,  based on discussion of such assumptions, alternative sets of assumptions, and analyses.

(3) CONSULTATION.-In preparing the report required by this section, the [fill in your agency of  choice]-

(A) shall solicit input from any interested party, including the Postal Service, the Postal RegulatoryCommission, other Federal agencies, users of the mails, enterprises in the private sector engaged in the delivery of the mail, and the general public; and

(B) shall address in the report any input considered under this section.

Any sponsor of postal legislative reform would find that there are substantive policy benefits to having  this work done. First, it would get Congress off the treadmill of whether mail service should be six days,  five days, or whenever. A well-defined and flexibly drawn statement of the postal system’s universal  service obligation based on a clear-headed assessment of what the nation truly needs from a postal  system, instead of everything every special interest may want, could ensure the nation gets what it  needs and at a rate it can afford to pay. The same would be true about the endless congressional  debates over facility consolidations and closures. A carefully crafted USO statement could set out in  broad strokes the basic policy objectives that would need to be met and could address the means by  which an overseer could determine whether and how well these needs were being addressed.
But who am I kidding? This is Washington. The tidal flow in the Potomac is to prevent good things from  getting done, not to facilitate it. This is a town flush with campaign and lobbying cash, and they aren’t  writing many profiles in courage for Congress or the President these days.

But why be cynical? (Another Washington trait.) Why not think of what could be possible and dedicate  ourselves to working toward those ends?


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