RESPONSES OF THE UNITED STATES POSTAL …

[Pages:12]Postal Regulatory Commission Submitted 11/29/2021 4:18:21 PM Filing ID: 120283 Accepted 11/29/2021

BEFORE THE POSTAL REGULATORY COMMISSION

WASHINGTON, D.C. 20268?0001

ANNUAL COMPLIANCE REVIEW, 2020

Docket No. ACR2020

RESPONSES OF THE UNITED STATES POSTAL SERVICE TO QUESTIONS 1-6 OF CHAIRMAN'S INFORMATION REQUEST NO. 33

The United States Postal Service hereby provides its responses to the abovelisted questions of Chairman's Information Request No. 33, issued on November 19, 2021. Each question is stated verbatim and followed by the response.

475 L'Enfant Plaza, S.W. Washington, D.C. 20260-1137 (202) 277-6333 eric.p.koetting@ November 29, 2021

Respectfully submitted,

UNITED STATES POSTAL SERVICE

By its attorneys:

Anthony F. Alverno Chief Counsel Global Business and Service Development Corporate and Postal Business Law Section

Eric P. Koetting Jeffrey A. Rackow

RESPONSES OF THE UNITED STATES POSTAL SERVICE TO CHAIRMAN'S INFORMATION REQUEST NO. 33

1. The Commission directed the Postal Service "...to evaluate the efficacy of its FY 2021 nationwide efforts to improve transit and Last Mile and to provide specific detailed plans to improve service performance results for First-Class Mail."1 Specifically, the Postal Service was directed to include a Last Mile evaluation that explained "how the progress made in FY 2021 (or lack thereof) toward ensuring that facilities have proper education and are held accountable affected on-time service performance results for First-Class Mail in FY 2021" and that explained "how the Postal Service will improve results for First-Class Mail by describing: each planned action, the problem that the planned action is expected to remediate, the estimated timeframe for implementation and completion of each planned action, and the metrics used to measure progress toward completion." FY 2020 ACD at 181. The Postal Service explains how it intends to improve performance by reducing Last Mile failures but does not identify the estimated timeframe for implementation and completion for each planned action or the metrics used to measure progress towards completion. See June 28 Response, question 2.a.2. a. Please provide a detailed description of the "...timeframe for implementation and completion for each planned action" identified as an attempt to reduce Last Mile failures. b. For each planned action, please identify the metric(s) used to quantitatively evaluate the success or failure of that action. If quantitative support is unavailable for an identified action, please state and explain why it is unavailable.

RESPONSE:

a. The Postal Service provided and is continuing to provide ongoing Service

Performance Measurement (SPM) training through Informed Visibility (IV)

quarterly. In addition, enhanced visibility of failures was improved, and best

practices on how to address failures are continuously shared. Daily/weekly

service performance and virtual reviews to ensure precise attention is levied

on opportunity sites are conducted. In September 2021, Delivery operations

1 Annual Compliance Determination, March 29, 2021, at 180 (FY 2020 ACD).

RESPONSES OF THE UNITED STATES POSTAL SERVICE TO CHAIRMAN'S INFORMATION REQUEST NO. 33

also created the visibility to triangulate other indicators to reduce Last Mile failures. Daily communications and meetings commenced in October 2021 with the responsible delivery unit management officials and their leadership. Additionally, ongoing dialog among processing operations, transportation and delivery in order reduce the number of Last Mile failures was implemented in October 2021.

b. Real time data visualization tools are available at all management levels through IV dashboards to evaluate and measure performance. Daily communications, virtual and service reviews and meetings cannot be quantified with a specific metric. However, these actions give cause to the assessment of tasks and procedures that should be performed daily to reduce service impacts caused by Last Mile failures.

RESPONSES OF THE UNITED STATES POSTAL SERVICE TO CHAIRMAN'S INFORMATION REQUEST NO. 33

2. In the FY 2020 ACD, the Commission directed the Postal Service "...to provide information for each of the geographic Postal Service Divisions" on numerous matters, including each Division's "area of geographic oversight" and "...the Division's progress made toward addressing the top root causes of failure to deliver First-Class Mail on-time and explaining how the Division's progress (or lack thereof) toward addressing each root cause affected on-time results for First-Class Mail in FY 2021." See FY 2020 ACD at 181-82. In response, the Postal Service provided plans and current practices that remediate problems, but did not generally address these matters in detail or identify the Division's area of geographic oversight. See June 28 Response, question 3.b. a. Please provide a detailed description of each Division's progress toward addressing the top root causes of failure to deliver First-Class Mail on-time and explain how the Division's progress (or lack thereof) toward addressing each root cause affected on-time results for First-Class Mail in FY 2021. b. Please confirm that, going forward, the Postal Service will provide to the Commission service performance results using the new Division/District structure as well as continue reporting using the legacy Area/District structure (as required by 39 C.F.R. part 3055).2 c. Please provide the GIS ShapeFile for the new Division/District structure so that the Commission may make meaningful geographic comparisons between the new Division/District structure and the legacy Area/District structure.

RESPONSE: a. Please see Attachment A (electronically attached to this response) for a

detailed description of each Division's progress toward addressing the top

root causes of failure to deliver First-Class Mail on-time in FY 2021 and an

explanation of how the Division's progress (or lack thereof) toward

2 The Commission has instructed the Postal Service that it is expected to file a petition with sufficient supporting justification if the Postal Service seeks relief from the requirements of 39 C.F.R. part 3055 for future service performance measurement data reports. See Order Granting Extension of Time and Providing Additional Instruction Regarding Future Report, March 8, 2021, at 2 (Order No. 5844).

RESPONSES OF THE UNITED STATES POSTAL SERVICE TO CHAIRMAN'S INFORMATION REQUEST NO. 33

addressing each root cause affected on-time results for First-Class Mail in FY 2021.

b. Confirmed insofar as annual reporting is concerned. For the Division reports that the Postal Service will file with its 2021 ACR, the Postal Service will provide service performance results using the Postal Service's new Division structure as well as continue reporting using the Postal Service's legacy Area structure. Going forward, the Postal Service will evaluate whether to provide service performance results using the Postal Service's new Area/District structure or legacy Area/District structure in any future Division reports.

c. Please see the subfolder labeled "GIS Shape Files," which is electronically attached to this response, for the GIS ShapeFiles for the Postal Service's new Division/District structure.

RESPONSES OF THE UNITED STATES POSTAL SERVICE TO CHAIRMAN'S INFORMATION REQUEST NO. 33

3. In the FY 2020 ACD, the Commission directed the Postal Service to provide "[t]he top five root cause point impacts for First-Class Mail, disaggregated by shape/product and service standard, presented for the nation and each Area," and particularly requested results "...for Flats at the product level and disaggregated by the single-piece and presorted categories." FY 2020 ACD at 183. In its response, the Postal Service did not present results for Flats at the product level and instead the results were only disaggregated by the single-piece and presorted categories.3 a. Please provide the top five root cause point impacts for Flats, at the product level, presented for the nation and each Area. b. If the analysis requested in question a. is not feasible, please provide a detailed description of the metrics/data that prevent the calculation of service performance results for Flats at the product level.

RESPONSE:

a. Please see the Excel file "Q3 ? Flats Rt Cs Pt Impcts ? ChIR 33" that is electronically attached this Response.

b. N/A

3 See, e.g., ZIP file ACD.June.28.Resp.Attachments, folder "Item 4," Excel file "Questions 4c1 4c4 7b," June 28, 2021.

RESPONSES OF THE UNITED STATES POSTAL SERVICE TO CHAIRMAN'S INFORMATION REQUEST NO. 33

4. The Commission directed the Postal Service "...to evaluate the feasibility and status of its efforts to develop point impact data for Inbound Letter Post and Outbound Single-Piece International." FY 2020 ACD at 184. In its response, the Postal Service indicated that it is feasible for it to develop point impact data for International Mail but that "...it is difficult to assess exactly when and the extent to which the Postal Service will be able to develop point impact data that quantifies the number of percentage points by which on-time results are affected by each specific root cause indicator." July 2 Response, question 6. a. Please provide an update on when and the extent to which the Postal Service will be able to develop point impact data that quantifies the number of percentage points by which on-time results are affected by each specific root cause indicator and a detailed description of the data limitations that prevent the quantification of point impact data for Inbound Letter Post and Outbound Single-Piece International mail.

RESPONSE:

The Postal Service implemented Root Cause reporting for Single Piece First-Class-

International (SPFC-I) mail beginning FY 2021, Q3. As a result, root cause point impact

data now exists for the second half of FY 2021, which the Postal Service plans to

include in its FY 2021 Annual Compliance Report. It should be noted that the root

cause point impact data for SPFC-I will reflect only the domestic processing legs of

inbound and outbound international mail.

The Postal Service is in the process of reviewing and analyzing FY 2021 information

concerning international mail, as well as considering how best to respond to the

Commission's previous similar request on page 184 of the Commission's FY 2020

Annual Compliance Determination. Thus, the Postal Service plans to include a more

detailed response in its FY 2021 Annual Compliance Report, which the Postal Service

plans to file with the Commission within about a month.

RESPONSES OF THE UNITED STATES POSTAL SERVICE TO CHAIRMAN'S INFORMATION REQUEST NO. 33

5. The Postal Service states that it intends to "authoriz[e] the Surface Planner Group to deny an extra-trip request where the requested extra trip would not be service standard responsive or would transport only a very small volume." June 4, Response at 4. Please confirm that the Postal Service has since authorized the Surface Planner Group to make such denials. If confirmed, please identify the date such authorization was given and if the Postal Service has modified the criteria described in its filing for denying extra-trip requests. If not confirmed, please identify the expected date of authorization.

RESPONSE: Following court orders clarifying that certain preliminary injunctions did not

prohibit such authorization, on August 30, 2021, the Department of Logistics, Surface

Planning was authorized to deny extra trip requests in situations in which:

1) the extra trip would not be service responsive and would not meet the critical

entry time for operations at the receiving facility; or

2) denying the extra trip would delay only a small volume of mail (less than 15

percent of the truck's total capacity), insignificant to the overall service

performance of the organization.

The Surface Planning Department, however, did not implement or exercise this

authority until November 1, 2021, due to the onboarding of a new "Freight Auction"

system that provides a more automated method of conducting freight auction and

tender (the solicitation for the tendering and awarding of loads for the transport of mails)

and the associated electronic payment of the services provided.

As of the close of business November 22, 2021 (17:00pm CST), a total of five

extra trip requests were denied out of a total of 3518 loads entered for auction--two

extra trip requests were denied "on the grounds that the trip would not be service

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