[Federal Register Volume 73, Number 233 (Wednesday, December 3, 2008)]
[Notices]
[Pages 73664-73679]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E8-28643]
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POSTAL REGULATORY COMMISSION
[Docket No. PI2008-1; Order No. 140]
Postal Service Plan for Service Performance Measurement
AGENCY: Postal Regulatory Commission.
ACTION: Notice.
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SUMMARY: This document approves most elements of a proposed Postal
Service plan for service performance measurement. Both the Postal
Service's plan and the Commission's approval respond to requirements in
a 2006 federal law that revised and updated the regulatory approach to
postal operations.
DATES: Postal Service response: June 1, 2009.
FOR FURTHER INFORMATION CONTACT: Stephen L. Sharfman, General Counsel,
202-789-6820 and [email protected].
SUPPLEMENTARY INFORMATION:
Regulatory History
72 FR 72395 (December 20, 2007)
73 FR 36136 (June 25, 2008)
73 FR 39996 (July 11, 2008)
I. Executive Summary
The Commission today approves a Postal Service request to employ
internal service measurements developed from its Intelligent Mail
Barcode (IMb) data to track service performance of bulk letters and
flats. This data would be combined with externally collected
information to provide the first system measuring the speed and
consistency of delivery for most types of mail.
A major feature of the Postal Accountability and Enhancement Act of
2006 is the requirement that the Postal Service begin to measure and
publicly report on its service performance for all market dominant
products. That law directs that external measurement systems be used
for this task unless alternate systems are approved by the Postal
Regulatory Commission.
This order reviews a Postal Service request to employ both external
and internal service measurement systems, and the public's comments on
that proposal. The Commission authorizes most aspects of the plan.
The Postal Service states that reliable external measurement of all
products would be very expensive and hard to implement. In particular,
to be reliable, test pieces must be indistinguishable from ``real
mail'' while being sufficiently physically diverse and geographically
dispersed to reflect service performance for different types of mail in
all parts of the country. The Postal Service claims this would be very
difficult to achieve in any affordable fashion.
The comments agree that it is important to utilize reliable
existing data sources where possible, and to avoid requiring costly new
external measurement systems.
[[Page 73665]]
The Postal Service proposes to expand its existing external system
for measuring single-piece First-Class Mail, and use its existing
Delivery Confirmation data to measure parcel service. For the majority
of its volume, letter and flat-shaped mail sent in bulk by businesses,
it proposes to measure performance with a hybrid system that would use
data from its new IMb program, scheduled for implementation in May
2009, in combination with already available externally derived service
information.
A measurement system that tracks representative, live mail from
deposit to delivery would provide the most meaningful measure of
service performance. The Postal Service believes that its planned
``full service'' IMb program will meet that standard. It will allow the
Postal Service to begin measurement when it receives mail, and track
containers and individual pieces as they proceed through its processing
and transportation networks. These data would be combined with
externally measured data quantifying time from ready-for-delivery, to
actual delivery, providing end-to-end service measurement.
Assuming IMb scanning and reporting technology can be successfully
implemented, and full service IMb is utilized by a representative
cross-section of mailers, this service measurement program should
produce high quality, minimal cost results. Therefore, the Commission
approves its use, and urges the Postal Service to proceed quickly to
deploy this system.
The Postal Service is to provide quarterly public progress reports
while full service IMb is being tested and implemented. The Commission
will carefully monitor IMb implementation and usage to assure that
accurate and representative performance data are obtained. If
necessary, modifications to the service performance measurement plan
will be developed. A separate public proceeding will be initiated
shortly to establish specific requirements for the periodic reporting
of service achievement by type of mail.
In one area, the Commission has identified problems that require
immediate adjustment. The Postal Service proposes to combine the
measurements for its diverse special services into an index. The
Commission finds that the proposed measures fail to reflect actual
performance for several of the more important services, including
Delivery Confirmation and Return Receipt. More realistic measures of
actual performance need to be developed in these areas.
II. Background
The Postal Accountability and Enhancement Act (PAEA), Public Law
109-435, 120 Stat. 3218 (2006), requires the Postal Service, in
consultation with the Postal Regulatory Commission, to establish by
regulation a set of modern service standards for market dominant
products. 39 U.S.C. 3691. Initial consultations between the Commission
and the Postal Service concluded on November 16, 2007, with the
Commission providing the Postal Service with comments addressing the
Postal Service's service standards proposals.\1\ The Postal Service
completed this task by publishing as a final rule Modern Service
Standards for Market-Dominant Products, December 19, 2007 (Service
Standards).\2\
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\1\ Comments of the Postal Regulatory Commission on Modern
Service Standards for Market Dominant Products, November 16, 2007.
The consultations are described as ``initial'' because of the
ongoing nature of consultations that are necessary to transition
from a set of standards to an operational measurement system
encompassing performance goals (see uncodified section 302(b)(1) of
the PAEA) and reporting mechanisms (see 39 U.S.C. 3652).
\2\ 72 FR 72216 (December 19, 2007) (codified at 39 CFR parts
121 and 122).
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Having established service standards, the Postal Service is
developing systems to measure actual service performance. On November
29, 2007, the Postal Service provided the Commission with a draft of
its Service Performance Measurement plan (Initial Plan), and through a
continuation of the consultation process, sought the views of the
Commission. The Commission posted the Initial Plan on its Web site as
an attachment to Order No. 48, which also established Docket No.
PI2008-1 for this matter and provided interested persons an opportunity
to comment on the Postal Service's service performance measurement
proposals.\3\ The Commission received 18 sets of comments and 9 sets of
reply comments from the mailing community.\4\
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\3\ PRC Order No. 48, Notice of Request for Comments on Service
Performance Measurement Systems for Market Dominant Products,
December 4, 2008 (Order No. 48).
\4\ The members of the mailing community that have filed
comments, reply comments, and additional comments are identified
after the signature of this order. As a matter of convenience,
citations to these comments will identify the party's comments as
comments, reply comments, or additional comments. For example,
Pitney Bowes' comments are cited as Pitney Bowes Comments at xx;
reply comments are cited as Pitney Bowes Reply Comments at xx; and
additional comments are cited as Pitney Bowes Additional Comments at
xx.
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Since November, the Postal Service has been consulting with its
customers, working with its external measurement vendors, and working
through the implementation of the Intelligent Mail Barcode system. This
has led to the continuous refinement of the Service Performance
Measurement plan. In June 2008, the Postal Service provided the
Commission with a second draft of its Service Performance Measurement
plan (Revised Plan). The Commission posted the June 2008 draft Service
Performance Measurement document on its Web site as an attachment to
Order No. 83, and again provided interested persons an opportunity to
comment.\5\ The Commission received 10 sets of additional comments
addressing the Revised Plan.
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\5\ PRC Order No. 83, Second Notice of Request for Comments on
Service Performance Measurement Systems for Market Dominant
Products, June 18, 2008 (Order No. 83).
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III. Statutory Requirements
The Postal Service's Revised Plan provides proposals both for
performance measurement systems and for reporting data generated by the
performance measurement systems. Performance measurement systems and
reporting of data are linked, but evaluation of each requires
consideration of different statutory requirements and issues unique to
each area. They appropriately may be considered separately. The focus
of this Order is on the first topic, the approaches proposed for the
various measurement systems.
Because the Postal Service's Revised Plan also includes proposals
for data reporting and comments were solicited in this area, this order
also describes the Postal Service's proposals for data reporting and
reviews the comments that were submitted, with limited Commission
discussion. A comprehensive review of the data items required by the
Commission for annual determination of compliance, including more
detailed reporting on a quarterly basis, will await a rulemaking as
previously suggested in Docket No. RM2008-4.\6\
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\6\ See Docket No. RM2008-4, Notice of Proposed Rulemaking
Prescribing Form and Content of Periodic Reports, August 22, 2008,
at 11-12 for a discussion of the future rulemaking.
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A. Internal Versus External Measurement Systems
An objective in designing service performance standards is for the
Postal Service to provide ``a system of objective external performance
measurements for each market-dominant product as a basis for
measurement of Postal Service performance.'' 39 U.S.C. 3691(b)(1)(D).
However, ``with the approval of the Postal Regulatory Commission an
internal measurement system may be implemented instead of an external
measurement system'' for individual
[[Page 73666]]
products. 39 U.S.C. 3691(b)(2). The Revised Plan presents the various
measurement systems the Postal Service proposes to use to measure the
standards presented in the Service Standards document. In the Revised
Plan, the Postal Service proposes various internal, external, and
hybrid (containing both internal and external elements) measurement
systems to measure the performance of its mail products.\7\
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\7\ For the purposes of the statutory requirements, the
Commission will consider all hybrid systems to be internal systems
because of the level of control that the Postal Service exerts over
the internal elements of the proposed hybrid systems.
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The Postal Service submitted the Revised Plan for the Commission's
``review, feedback, and concurrence.'' \8\ In consultations with the
Commission, the Postal Service indicated that it seeks approval of the
direction that it is taking with its measurement systems, specifically
whether the Commission finds any issues that may be ``show-stoppers''
to proceeding with the various external and hybrid measurement systems.
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\8\ Letter from Thomas G. Day, Senior Vice President, United
States Postal Service, to Dan G. Blair, Chairman, Postal Regulatory
Commission, June 3, 2008.
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This order provides the Postal Service with the requested feedback.
Specific approvals will be subject to review as the quality of the data
produced is evaluated.
B. Data Reporting
The Postal Service's Revised Plan also describes how it proposes to
report to the Commission the data generated by its measurement systems.
The Postal Service states:
In accordance with Sec. 3652 of the Postal Accountability and
Enhancement Act, the Postal Service is required to report measures
of the quality of service on an annual basis. The Postal Service's
proposal for service measurement goes far beyond annual reporting
and will instead provide quarterly reporting for all market-dominant
products, almost entirely at a district level.
Revised Plan at 12 39 U.S.C. 3652 requires that the Postal Service
include in an annual report to the Commission an analysis of the
quality of service ``for each market-dominant product provided in such
year'' by providing ``(B) measures of the quality of service afforded
by the Postal Service in connection with such product, including--(i)
the level of service (described in terms of speed of delivery and
reliability) provided; and (ii) the degree of customer satisfaction
with the service provided.''
As noted above, the Commission intends on initiating a rulemaking
to develop rules for both annual and periodic reports of service
performance measurements through its authority to (1) prescribe by
regulation the content and form (including the methodologies used) of
the annual report to the Commission (39 U.S.C. 3652(a)(1) and (e)(1)),
and (2) prescribe data reporting requirements as part of designing a
modern system for regulating rates and classes for market dominant
products (39 U.S.C. 3622(a)). The Postal Service proposals presented in
its Revised Plan, along with all comments received, will be
incorporated by reference and considered in that rulemaking docket.
IV. Review of the Postal Service Performance Measurement Systems
Proposals
Many service performance measurement issues are common to multiple
mail products. These issues include the structure and reliability of a
hybrid measurement system, exclusions from measurement, and IMb
adoption rates, among others. The Commission addresses these issues
first, discussing its concerns with the Postal Service's proposals,
including where applicable, concerns presented by mailers.
The Commission then reviews service performance measurement issues
as applicable to the individual classes of mail. The review addresses
specific Commission concerns and provides recommendations on the
approaches that the Postal Service is proposing for service performance
measurement systems and data reporting. It also considers mailer
comments specific to individual mail products.
A. Multiproduct Issues
1. The Hybrid Measurement System
The Postal Service proposes service performance measurement systems
that incorporate both internal and external measurement elements to
measure the performance of First-Class Mail presort letters and cards,
Standard Mail non-saturation letters and flats, and Package Services
presort flats. The systems for each type of mail share similar
attributes. Collectively, these measurement systems are referred to as
the ``hybrid measurement system.''
The hybrid measurement system hinges on successful implementation
and mailer adoption of the internal IMb system.\9\ Only mail using the
full service option of IMb will be included in the measurement.\10\ The
measurement system uses a sampling, not a census, of full service IMb-
compliant mail.
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\9\ The Intelligent Mail Barcode is a new data rich, four-state
barcode that the Postal Service is in the process of introducing.
The IMb system includes the process and documentation requirements
for inducting mail into the postal system, and the data system to
monitor and report on mail containing IMbs.
\10\ Full service and basic options are available for IMb. Basic
IMb requires mailers to use an IMb that includes a Barcode ID,
Service Type ID, Mailer ID, Serial Number (does not have to be
unique and can include all zeroes), and a Delivery Point ZIP Code.
In addition to the requirements for basic service IMb, full service
IMb mailpieces must include serial numbers that are unique for 45
days, unique Tray/Container barcodes, and electronic documentation.
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A prerequisite for mail to be measured is the submission of
electronic mailing documentation by the mailer. Generally, the mailer's
submission of electronic mailing documentation and the documented
arrival time at a postal facility starts the clock of the
measurement.\11\
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\11\ The actual start-the-clock takes into consideration the
critical entry time (CET) for that type of mail.
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The hybrid measurement system measures end-to-end service
performance in two steps. In the first step, a mail processing factor
is developed. The mail processing factor is the time from the start-
the-clock event described above to the last recorded mail processing
scan using IMb system data. In the second step, a delivery factor is
developed. The delivery factor represents the time from the last
recorded mail processing scan to actual delivery of a mailpiece. In
calculating the delivery factor, an external contractor uses the last
recorded mail processing scan reported by the IMb system, and the
actual delivery date recorded by external reporters with scanners
capable of reading IMbs. The mail processing factor is combined with
the delivery factor to provide an end-to-end measurement of service
performance.\12\
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\12\ The external reporters generate an actual stop-the-clock
event, which also can be used to develop an actual end-to-end
measurement. At this time, it is unclear how this end-to-end
measurement will be incorporated into the reported service
performance measurement.
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A variety of mailers support the hybrid measurement system
approach. AMEE Comments at 2; DFS Reply Comments at 1; MMA Comments at
2; NPPC Comments at 4; Pitney Bowes Comments at 3; and PostCom/DMA
Comments at 7.
AMEE and MMA comment that the existing External First-Class (EXFC)
infrastructure used by the hybrid system and external reporters will
add credibility to the system. AMEE Comments at 2; and MMA Comments at
2. However, Pitney Bowes and Valpak suggest eventually eliminating the
external reporters to reduce costs once IMb becomes widespread enough
to ensure statistical validity of the system. Pitney Bowes Comments at
3; and
[[Page 73667]]
Valpak Comments at 8-9; see also IWCO Additional Comments at 1.
PostCom/DMA and DFS also suggest eliminating the external reporters as
a cost savings measure, but suggest using an independent study as an
internal delivery proxy instead. PostCom Comments at 7; and DFS Reply
Comments at 3.
Commission analysis. The Commission supports the approach the
Postal Service is taking to implement the hybrid system for service
performance measurement, with the following caveats.
The mail sampled by the hybrid system must be representative of the
overall mail subject to performance measurement for the system to
produce meaningful results. Representativeness is further discussed in
section VI.A.2 which addresses mail excluded from measurement. A
representative sample also may depend on mailers' adoption of the IMb
system, which is further discussed in section VI.A.3.
The Commission notes the common analytical and statistical practice
of combining the results of more than one separate and independent
analytical sample. The Postal Service proposes to achieve an end-to-end
measurement of service performance by combining the mail processing
factor (step one estimation) with the delivery factor (step two
estimation). It appears that the volume of data used in the step one
estimations will be much larger than the volume used in the step two
analysis. Although independence appears to hold between the two
separate analyses for the two separate factors, the Commission suggests
that it will be important to monitor if that independence is true for
all components within each analyses for all classes of mail so as to
avoid possible unintended bias effects.
The Commission also recommends monitoring and testing for
potentially negative influences on measurement resulting from the type/
frequency of mismatched data pairs that may enter the analyses such as
a reliable start-the-clock with no final external reporter scan, or no
reliable start-the-clock with a reliable final external reporter scan.
The methodology for incorporating (or scrubbing) mismatch data pairs
into the measurement may bias the measurement result. Thus, the
methodology must be fully understood and disclosed to assure that any
bias is reasonably limited.\13\
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\13\ For example, a mailpiece with a valid start-the-clock but
without a valid stop-the-clock (due to the mailpiece never being
delivered) that is scrubbed from the dataset will not be represented
in the overall measurement of service performance, i.e., the
measurement system will indicate a higher level of service
performance than what is actually occurring. This is a complex issue
because the decisions concerning atypical data typically affect
measurement bias.
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As suggested by AMEE and MMA, the Commission finds that the
existing EXFC infrastructure and the external panel of reporters
equipped with devices to scan all IMb First-Class, Periodical, and
Standard letters/cards and flats delivered to their in-home addresses
will add credibility to the hybrid system. The option of reducing or
eliminating the use of external reporters to reduce costs may be
considered at a later date.
2. Exclusions From Measurement
Mail that is excluded from measurement may impact the ability of
the sampled mail to represent the total of the mail subject to
measurement. For the IMb-based measurement systems, only mail
participating in full service IMb is measured. This excludes mail
participating in only the basic IMb service. Similar questions exist
for DelTrak and Red Tag, and the Delivery Confirmation-based systems,
where a significant portion of the mail does not utilize these systems.
Finally, mailers express concern with the exclusion from measurement of
mail that does not meet preparation requirements.
Valpak expresses concern that the exclusion from measurement of
(Standard) bulk mail not using full service IMb raises the possibility
of bias, and the possibility that the measurement is not representative
of the wider universe. It suggests that the Postal Service provide an
annual explanation of the universe from which performance data is
derived and an explanation of what universe this data can be considered
to represent. Where the represented universe is larger than the
performance data universe, the Postal Service also should explain why
the data universe is representative of the larger universe. Valpak
Comments at 4-5; and Valpak Reply Comments at 7-8; see also Research
International Additional Comments at 2.
GCA provides an example of where representativeness issues may
exist with single-piece mail. It requests clarification on the
treatment of mis- or badly-addressed single-piece mail in the
measurement system. GCA Comments at 1.
MOAA comments that it is reasonable to exclude mail that does not
meet mail preparation requirements, but further suggests procedures are
necessary to inform mailers of any mail that is excluded from
measurement.\14\ MOAA Comments at 1-2. APWU contends that excluding
mail that does not meet mail preparation requirements may cause
measurements that are not reflective of the mail being sent. APWU
Comments at 2. PostCom/DMA adds that data excluded from service
performance measurement should be provided to mailers to resolve
service issues and improve mail quality. PostCom/DMA Comments at 16.
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\14\ For bulk mail, the Postal Service proposes only to measure
end-to-end performance of mail that is verified as satisfying mail
preparation requirements associated with applicable price categories
and that complies with the requirements of full service IMb. Revised
Plan, Appendix, para. 4.
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Commission analysis. The Commission recognizes that the full
service IMb mail used in the end-to-end service measurement
calculations may not be representative of the larger populations it
seeks to represent in making service measurement claims. The full
service IMb mail and the remainder of the mail of a given class may
differ in terms of mail characteristics, geographical location, and
most importantly, service performance. If these two sets of mail groups
do indeed differ significantly in important characteristics, then the
``estimated'' measures for the full service IMb mail may be very
different than the service performance for the rest of the mail.
To assess this potential bias problem, the Commission recommends
limited performance measurement tests be conducted for mailpieces
excluded from the primary measurement system and used for comparison
purposes. For example, the Postal Service could apply unique
identifying barcode information to a random sample of mailpieces that
do not use full service IMb to obtain an estimate of service
performance. This estimate could then be compared to the estimate
obtained from the full service IMb pieces to monitor how representative
full service IMb pieces are as adoption rates increase. A plan for
implementing a system for ascertaining the representativeness of annual
compliance report (ACR) service performance measurements based on IMb
should be provided with the 2009 ACR.
The Commission finds that the Postal Service is taking a reasoned
approach to addressing the MOAA, et al. concerns of determining whether
to include or exclude mail from measurement because of a variety of
mail validation deficiencies. See Revised Plan, Appendix, para. 4. In
some instances, the mailer will be provided an opportunity to correct
the deficiencies and the mail then will be included in the performance
measurement. In all
[[Page 73668]]
instances of this nature, communication between the Postal Service and
the mailer is beneficial to reducing the occurrence of validation
issues so that the mail system operates smoothly.
3. IMb Adoption
The IMb system, used to capture internal service performance data,
is the centerpiece of several of the measurement systems proposed by
the Postal Service. In particular, successful operation of the IMb
system is necessary for implementation of the hybrid measurement
system. Thus, the rate at which mailers are likely to start using the
IMb, specifically the full service option of IMb that is required by
the measurement systems, along with whether the IMb mail presented by
the adopting mailers is representative of intended total population
subject to measurement, must be considered.
AMEE has an expectation of rapid adoption of IMb, but comments that
undefined Postal Service requirements, the mailer's own data
requirements, the Postal Service IT infrastructure, and the issue of
rate incentives could add uncertainty to its expectations. AMEE
Comments at 4. NPPC comments that the effectiveness of the hybrid
system will depend on IMb adoption rates; however, NPPC contends that
it is unclear how fast IMb will mature, when the Postal Service will
specify business requirements, and how mailers will convert to IMb.
NPPC Comments at 4. Pitney Bowes asserts that the hybrid measurement
system is critically dependent upon mailer participation in IMb, and
suggests promoting adoption with meaningful price incentives and
advance notice regarding the size of these incentives. In accord,
PostCom/DMA Additional Comments at 5-6.
PostCom/DMA and Pitney Bowes suggest implementation of a data
collection process to monitor IMb adoption. Pitney Bowes explains the
adoption monitoring system can be used to assess the validity of the
hybrid system. Additionally, PostCom/DMA assert that the Postal Service
must work aggressively with mailers to overcome implementation barriers
to IMb, and that a monitoring system can be used to explore alternate
requirements or measurement systems if IMb adoption rates are
significantly less than anticipated. Pitney Bowes Comments at 4; and
PostCom/DMA Comments at 18-19.
Research International questions whether a system based on the
natural adoption of IMbs for bulk mail will produce a measurement that
is representative. It contends that adoption may be skewed by
geography, size of mailer, types of mailing, or other factors.
Alternatively, Research International suggests a system using seeded
mailings, including transponders, to give a more complete end-to-end
measurement. Research International Comments at 1. To the extent that
the Postal Service may need to supplement IMb data, McGraw-Hill
comments that the Postal Service should evaluate the costs and benefits
of the Research International approach. McGraw-Hill Reply Comments at
5.
Commission analysis. The Commission recognizes that mailer adoption
of full service IMb that provides a representative cross-section of the
mail population being measured is critical to the success of the hybrid
system. It is uncertain, at this time, when sufficient adoption of IMb
will occur. In the Initial Plan, the Postal Service projected presort
First-Class and letter-shaped Standard Mail adoption at 25-50 percent
in FY 2009 with a projected increase to 50-75 percent in FY 2010. The
Revised Plan does not give projection percentages for full service IMb
adoption.
The Postal Service has made several statements to the mailing
community concerning the operational date of the IMb system and
possibly developing differential rates specific to IMb mail.
Uncertainty in the mailing community of IMb requirements,
implementation dates, and applicable rates may lead to delay in the
adoption of the system. Additional issues that may impede adoption are
mailer concerns over final Postal Service requirements, mailer data
requirements, and Postal Service IT infrastructure.
The Commission also finds that tracking the representativeness of
the actual full service IMb sample is important. For presort mail, the
sample of full service IMb presort mailers must be representative of
the entire population of presort mailers. The Commission expects the
Postal Service to develop a protocol for testing to assess whether this
sample is in fact representative.
To the extent that uncertainty exists, the Commission agrees with
the mailers' suggestions that it will be necessary to monitor IMb
adoption rates so that possible solutions may be formulated to ensure
reasonably representative and unbiased service performance estimates.
The appropriate place to consider periodic reporting of IMb adoption
rates and analysis of representativeness is the upcoming rulemaking on
service performance data reporting requirements.
4. Start-the-Clock and Critical Entry Times
Most mailers concerned with a credible service performance
measurement system comment on some aspect of start-the-clock. MOAA
Comments at 2; MPA Comments at 2-3; NPPC Comments at 2-3; PostCom/DMA
Comments at 14; Time Warner Comments at 2-3; NPPC Additional Comments
at 2-5; Valpak Comments at 5-8; and McGraw-Hill Reply Comments at 4-5.
Generally, start-the-clock is the date and time that a mailpiece enters
the mailstream for the purpose of service performance measurement.\15\
It is the starting point from which performance measurements are made.
The issues are broad and encompass anything from documenting mail
arrival times to mail acceptance. They include highly technical issues
such as concerns with the need for better definitions of the electronic
mailing information necessary to start-the-clock. AMEE Comments at 1-2;
and MMA Comments at 2.
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\15\ Where applicable, start-the-clock takes into consideration
critical entry times (CET) and customer/supplier agreements (C/SA).
For certain Special Services, start-the-clock is the date and time
when the mail service is initiated.
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In many cases, there is a CET associated with start-the-clock. The
Postal Service defines the CET as ``the latest time that a reasonable
amount of a class of mail can be received at designated induction
points in the postal network for it to be processed and dispatched in
time to meet service standards.'' Revised Plan at 3. For mail accepted
before the posted CET for that day, the day of entry is designated as
the ``start-the-clock.'' For mail accepted after the posted CET for
that day, the mailpiece has a start-the-clock date of the following
applicable acceptance day. The Postal Service has established national
CETs for destination-entered Standard Mail, and has established
locally-defined facility CETs for all other classes of mail. A C/SA may
identify an alternate acceptance window.
Several mailers ask the Postal Service to better define how CETs
will be established and modified, and to develop a method for
communicating CETs and changes to CETs to the mailing industry. AMEE
Comments at 1-2; BAC Comments at 2; MMA Comments at 2; and Public
Representative Reply Comments at 5. In addition, NPPC suggests
specifying CETs in the service standards and providing a Web-based
system for mailers to access CET information. NPPC Comments at 3-4. MPA
supports
[[Page 73669]]
a centralized system for mailers to access CETs for all facilities, and
also proposes the establishment of a centralized process for national
mailers to negotiate C/SAs that cover all of their entry points. MPA
Additional Comments at 4. Time Warner and DFS generally support locally
established CETs that reflect local conditions. Time Warner Comments at
3; and DFS Reply Comments at 3-4.
The Postal Service indicates that it ``will be centrally
documenting local product-specific CETs on a facility-by-facility basis
for the purpose of responding to mailer information access concerns.''
Postal Service Reply Comments at 9.
Commission analysis. The Postal Service is to be commended for
addressing many mailer concerns in the time between submitting its
Initial Plan and its Revised Plan. Successfully generating accurate
start-the-clock times is essential to the development of a credible
performance measurement system. The Commission perceives start-the-
clock as a detailed and difficult issue, and urges the Postal Service
to continue working with the mailing community in developing a working,
user-friendly, information system. The Commission supports the Postal
Service's proposal to document CETs and encourages it to develop
systems to make this information publicly available in the very near
future.
Bulk mailers that rely on CETs make several good suggestions for
increasing the visibility and the transparency of CETs that the
Commission fully supports. Additionally, the Postal Service is reminded
that CETs also are important to low-volume and single-piece mailers
when entering mail at a window or into a blue collection box. Easy
access to CET information is essential to informing mailers of what
service is to be expected.
The Commission also is aware of the potential impact that gradual
small changes to CETs could have on service performance. Readily
transparent access to CET information will allow for monitoring of this
particular situation.
5. Miscellaneous Issues
Implementation benchmarks. APWU suggests the establishment of
benchmarks to track the development and implementation of the
performance measurement system and to ensure that the system accurately
reflects actual performance. APWU Comments at 2, see also PostCom/DMA
Comments at 21; and Valpak Reply Comments at 3.
External audits. Noting the removal of the section describing
external service performance measurement validation from the Postal
Service's Revised Plan, PostCom/DMA stresses the need for independent
external auditing and evaluation of the service performance measurement
systems, processes, and data quality/accuracy. PostCom/DMA Additional
Comments at 7.
Data security. BAC, NPPC, PostCom/DMA, and Time Warner are
concerned with the security of the data generated by the performance
measurement system and contend that this issue has not been adequately
addressed by the Postal Service. BAC Comments at 1; PostCom/DMA
Comments at 20; PostCom/DMA Additional Comments at 6; Time Warner
Comments at 1-2; and NPPC Additional Comments at 5-6.
Commission analysis. The Commission recognizes the importance of
each of these issues. Establishing benchmarks to track the various
stages of system development are essential management tools that the
Postal Service properly has been employing. The Commission concludes
that public acceptance of IMb, and the use of IMb in service
performance measurement reporting, will be significantly enhanced by
greater transparency in this area. Therefore, the Postal Service is to
provide reports at the beginning of each fiscal quarter on progress
toward its benchmarks for implementing full service IMb for each mail
shape. In the rulemaking on reporting that will shortly follow this
order, the Commission will suggest for public comment specific periodic
updates on the progress toward full implementation and the development
of representative samples for measuring performance.
External audits will protect the credibility of various internal
and hybrid measurement systems. Although the Postal Service no longer
describes such audits in its proposal, the Commission expects to
require appropriate verification that reported service performance is
representative. This may well involve audits of service achievement in
various processing streams. At this juncture, however, it seems
premature to focus resources on exploring methods for auditing systems
that are not yet operational.
Security also is an essential aspect of developing any information
collection and reporting system. Mailers reasonably want assurances
that data on their business activities will be properly safeguarded.
The Postal Service may not have included extensive details on security
in its request as this topic is somewhat tangential to whether IMb can
provide robust performance data. As this system is implemented, the
Postal Service will be expected to remain vigilant to preserve its long
established record of attention to data security issues.
B. Class-Specific Issues
The Postal Service proposes new measurement systems based on the
IMb (the hybrid measurement systems), Delivery Confirmation scans
(predominately the parcel-shaped mail measurement systems), DelTrak and
Red Tag (the Periodicals mail measurement systems), and the
International Mail Measurement System to measure the various types of
mail. The Postal Service also will continue use of the External First-
Class (EXFC) system for measuring most single-piece First-Class Mail.
The DelTrak and Red Tag systems are proposed as interim measurement
solutions until IMb-based systems become viable. IMb-based systems also
may replace the Delivery Confirmation-based systems in the future.
The Commission finds that these measurement systems are likely to
be representative of a significant portion of the mail sent as First-
Class Mail, Standard Mail, Periodicals, and Package Services, and have
the potential of producing meaningful data. Notwithstanding the
concerns previously noted, and noted in the additional comments below,
the Commission approves of the Postal Service's general approach in
these areas.
The Commission, however, cannot approve the approaches that the
Postal Service is proposing for the majority of the Special Services.
More robust measurement systems capable of generating data that is
representative of the services being offered must be developed.
The remainder of this section discusses the Postal Service's
individual proposals for implementing performance measurement systems
by mail class. Issues identified by the mailing community are
discussed, and specific recommendations by the Commission are
presented.
1. First-Class Mail
First-Class Mail includes Single-Piece Letters/Postcards; Presorted
Letters/Postcards; Flats; Parcels; Outbound Single-Piece First-Class
Mail International; and Inbound Single-Piece First-Class Mail
International. Of all domestic First-Class Mail, 38.0 percent are
single-piece letters and cards, 3.3 percent are single-piece flats, 0.4
percent are single-piece parcels, 57.1 percent are presort letters and
cards, 1.0 percent are presort flats, and 0.2 percent are presort
parcels. Revised Plan at 13.
Single-piece letters, cards, and flats. The Postal Service proposes
to continue
[[Page 73670]]
measuring single-piece letters, cards, and flats using the EXFC
measurement system. EXFC is an end-to-end time to delivery measurement
system administered by an external contractor. Mail droppers employed
by the external contractor report the date and time test mailpieces are
deposited into the mail system to the external contractor. The time and
date that the mail is dropped starts the clock of the measurement. Mail
reporters employed by the external contractor record the date they
receive test mailpieces and report this information to the external
contractor. The date the mail reporter receives the mailpiece stops the
clock of the measurement. The difference, in calendar days, between the
start-the-clock event and the stop-the-clock event is reported as the
service performance measurement.\16\
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\16\ Non-delivery days are factored into the service performance
calculation.
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The Public Representative suggests expanding EXFC to include a
statistically valid measurement system for single-piece First-Class
Mail letters and flats delivered to post office boxes. Public
Representative Comments at 33.
The Commission asks the Postal Service to consider whether it is
possible to incorporate pieces delivered to post office boxes and
pieces requiring forwarding and return into its current EXFC design.
The Postal Service should consider both the benefits of measuring
pieces with these delivery characteristics and the added costs
involved, and inform the Commission of its analysis by the conclusion
of fiscal year 2009.
GCA stresses the importance of non-standard aspect ratio mailpieces
which currently are not being represented by EXFC. GCA Comments at 1-2.
The Commission finds that EXFC does not include any non-machinable
mail (such as square envelopes) in its seeded mailings, nor will
nonmachinable mail be captured by the IMb-based systems. Consequently,
this mail will not be represented in the performance measurement
system. This issue eventually may require a special study to measure
non-machinable mail performance.
BAC and NPPC suggest disaggregating the service performance
measurement of remittance mail and treating remittance mail as a
distinct category of First-Class Mail. BAC Comments at 2; and NPPC
Comments at 7.
Presort letters and cards. The Postal Service proposes to use the
hybrid measurement system to measure presort letters and cards.
Presort flats. The Postal Service does not propose a measurement
system for presort flats. It proposes use of the EXFC measurement for
single-piece flats (machine addressed only) as a proxy for the presort
flats measurement. It states that presort flats make up only 0.4
percent of the total mailstream. The Postal Service notes the
possibility of employing the IMb measurement system in the future if
the volume of mailpieces with IMbs is sufficient to provide actual
measurements.
Several mailers oppose the proposal to use the EXFC measurement for
single-piece flats (machine addressed only) as a proxy for the presort
flats measurement. They acknowledge the low volume of presort flats,
but contend that to qualify for automation rates they will be required
to adopt IMb and other processes that are identical between letters and
flats. AMEE Comments at 2; MMA Comments at 2; Pitney Bowes Comments at
3-4; Pitney Bowes Additional Comments at 3; and PostCom/DMA Comments at
4-5. These mailers suggest using the hybrid system to obtain
performance measurements. BAC adds that there should be enough presort
flats with IMbs in the system to measure performance without the need
to use a proxy. BAC Comments at 4. PostCom/DMA ponders why a
statistically valid system cannot be developed for presort flats when
the Postal Service proposes a distinct measurement system for retail
parcels that comprise less mail volume. PostCom/DMA Comments at 4. The
Public Representative views the proposal ``a request to avoid measuring
directly that price category of the First-Class Flats.'' Public
Representative Comments at 34-35.
The Commission acknowledges the mailer comments opposing use of the
EXFC single-piece flat measurement as a proxy for presort flats.
However, because the single-piece flat mail measured by EXFC is all
machinable and does not include address correction, these pieces are
likely to be representative of ``clean'' mail. Presort flats are also
likely to be clean. Therefore, the Commission accepts the Postal
Service's proposal to use the EXFC's First-Class single-piece flats
measurement as a proxy for presort flats with the understanding that
IMb will be used instead when it becomes possible to do so.
Retail and presort parcels. The Postal Service proposes an internal
measurement system for retail and presort parcels. Only parcels that
have purchased Delivery Confirmation will be measured. For retail
parcels, the Delivery Confirmation scan at the time of purchase at the
retail counter starts the clock of the measurement. For presort
parcels, the documented arrival time at the Postal Service acceptance
facility along with the mailer provided electronic mailing
documentation starts the clock of the measurement. The clock is stopped
when the Postal Service scans the Delivery Confirmation label at
delivery or attempted delivery. The difference, in calendar days,
between the start-the-clock event and the stop-the-clock event is
reported as the service performance measurement.
The Commission notes that use of Delivery Confirmation scan data
when evaluating service performance for First-Class retail and presort
parcels has limitations that relate to the limited use of Delivery
Confirmation service by First-Class presort parcel mailers.
Additionally, First-Class single-piece parcels using Delivery
Confirmation is estimated to be only 3.9 percent. The Postal Service
will have to analyze this system and demonstrate that it produces a
representative measurement. The Postal Service should include such an
analysis with its annual compliance report for fiscal year 2009.
Inbound and outbound single-piece international letters. Inbound
and outbound single-piece international letter-shaped mail will be
measured using the external International Mail Measurement System
(IMMS). IMMS is an end-to-end system provided by an external contractor
based on sample mailpieces entered into the system by droppers and
received by reporters. Only domestic transit time will be measured. The
system also relies on an internal ID tag and/or PLANET Code scan
(PLANET Code will be phased out and replaced with IMb) to signal when
the mailpiece either enters or leaves the control of the Postal
Service.
Single-piece international flats. Single-piece international flats
will not be measured, and single-piece domestic flats external EXFC
data will be used as a proxy for its service measurement.
The Commission finds that single-piece domestic flats external EXFC
data can be used as an acceptable proxy for single-piece international
flats service measurement.
Single-piece international parcels. Single-piece international
parcels will not be measured, and single-piece domestic parcels
internal Delivery Confirmation data will be used as a proxy for its
service measurement.
The Commission finds that single-piece domestic parcels internal
Delivery Confirmation data can be used as an acceptable proxy for
single-piece international parcels service measurement.
[[Page 73671]]
Miscellaneous comments. The Public Representative contends that
``the forwarding (and return or wasting) of undeliverable-as-addressed
First-Class Mail remains a large and costly problem for the Postal
Service.'' Public Representative Comments at 10. This category of
First-Class Mail is not measured. Thus, the Public Representative,
joined by Pitney Bowes, suggest establishment of service standards for
undeliverable-as-addressed, forwarded, and returned mail. Public
Representative Comments at 8-12; and Pitney Bowes Reply Comments at 4.
The Postal Service should explore the cost of periodically conducting
studies of service performance for forwarded and returned First-Class
Mail and inform the Commission of their feasibility by the conclusion
of fiscal year 2009.
2. Standard Mail
Standard Mail includes High Density and Saturation Letters; High
Density and Saturation Flats/Parcels; Carrier Route; Letters; Flats;
and Not Flat-Machinables (NFMs)/Parcels. Of all Standard Mail, 61.1
percent are presort letters and cards, 38.3 percent are presort flats,
and 0.6 percent are presort parcels. Revised Plan at 26.
Saturation letters and flats. The Postal Service proposes to use a
variation of the hybrid measurement system to measure saturation
letters and flats. Unique barcodes are not required on saturation mail,
which presents additional challenges to stopping-the-clock for both
mail processing and delivery measurement. The Postal Service states it
will develop alternative methods for external recipients to identify
saturation mail and to stop the clock of the measurement.
The Commission recognizes that using the hybrid system for
saturation letters and flats is problematic. Service performance cannot
be accurately measured without a valid stop-the-clock event. The
Commission understands that the Postal Service is working to develop
stop-the-clock measurements and encourages it to do so expeditiously.
Non-saturation letters and non-saturation flats. The Postal Service
proposes to use the hybrid measurement system to measure both non-
saturation letters and non-saturation flats.
Miscellaneous comments concerning flats. MOAA suggests that the
Postal Service develop tracing at the destination delivery unit (DDU)
for flats entered as carrier route mail. MOAA Comments at 3.
Parcels. The Postal Service proposes an internal measurement system
for parcels. Only parcels that have purchased Delivery Confirmation
will be measured. The mailer's documented arrival time at the Postal
Service acceptance facility is used to start the clock of the
measurement. The Postal Service's scan of the Delivery Confirmation
label at delivery, or attempted delivery, stops the clock of the
measurement. The number of calendar days from when the clock is started
to when it is stopped is reported as the measure of service
performance.
3. Periodicals
Periodicals include Within County Periodicals and Outside County
Periodicals. Of all Periodicals, 1.5 percent are letters, and 98.5
percent are flats. Revised Plan at 33.
As an interim solution, the Postal Service proposes using the
external Red Tag and DelTrak service measurement providers to measure
the service performance of Periodicals. The long-term solution is to
switch to an internal IMb-based system once there is a sufficient
volume of Periodicals mail using IMbs.
The Red Tag and DelTrak systems rely on mailer reported induction
times to generate a start-the-clock event.\17\ A delivery date reported
online by external reporters generates a stop-the-clock event. The
measurement of service performance is the number of calendar days from
the start-the-clock event to the stop-the-clock event.
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\17\ It is unclear whether the mailer-reported induction time is
reported to the Postal Service or directly to the external service
measurement providers. If the information flow of the mailer-
reported induction time is not directly from the mailer to the
external measurement providers, the measurement system incorporates
features of both internal and external measurement systems.
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MPA supports the use of DelTrak and Red Tag as an interim solution
until IMb is implemented for Periodicals. MPA Comments at 2. Research
International expresses concern over the representativeness of DelTrak
and Red Tag. It notes that mailers must pay to participate in Red Tag,
Red Tag mail is identifiable to the Postal Service, and the receiving
reporters are volunteers. Research International Additional Comments at
4-5.
McGraw-Hill asserts that ``[a]ccurate service performance
measurement is important for smaller mailers no less than for larger
mailers.'' It questions the eventual adoption rate of IMb by small
mailers and whether measurements from IMb Periodicals will be
representative of the class as a whole. It suggests studying the
temporary use of seed mail. McGraw-Hill Reply Comments at 4-5. The
Postal Service is currently working to assure that Red Tag and DelTrak
will provide it with a representative sample of Periodical
publications. It should include an analysis of representativeness of
the Periodicals measurements with its 2009 ACR.
NNA suggests that there are many hurdles to overcome before IMbs
begin to appear on newspapers and comments on the many unique problems
of representing smaller publications in the measurement system. NNA
Comments at 3-6. NNA concludes that it is content with leaving Within
County unmeasured for the time being. Id. at 11.
The Commission recognizes the opinion of Within County mailers that
it is acceptable for the time being for their mail to escape
measurement. Nonetheless, service problems for nationally distributed
pieces paying Within County rates have been reported, and the statute
does not provide an exemption from measurement for this significant
segment of Periodicals mail. Thus, the Postal Service must strive to
develop an appropriate measurement system for Within County mail and
inform the Commission of its proposal by the conclusion of fiscal year
2010.
The Commission notes that an additional benefit of the Red Tag- and
DelTrak-based systems will be to serve as a check on the IMb-based
system that the Postal Service proposes for the future. Both systems
should be run in parallel at the start to make appropriate comparisons.
4. Package Services
Package Services includes Single-Piece Parcel Post; Inbound Surface
Parcel Post (at UPU rates); Bound Printed Matter Flats; Bound Printed
Matter Parcels; and Media Mail/Library Mail. Package Services contains
both parcel-shaped and flat-shaped mail. Of the parcel-shaped mail,
14.5 percent is considered retail and 85.5 percent is considered
presort.
Retail parcels. The Postal Service proposes an internal measurement
system for retail parcels based on Delivery Confirmation scans. Thus,
only parcels with purchased Delivery Confirmation will be measured. The
Delivery Confirmation scan at the time of purchase starts the clock of
the service performance measurement. The Postal Service scan of the
Delivery Confirmation label at delivery, or attempted delivery, stops
the clock of the service performance measurement. The difference, in
calendar days, between the start-the-clock event and the stop-the-clock
event is reported as the service performance measurement.
[[Page 73672]]
Presort parcels. The Postal Service proposes an internal
measurement system for presort parcels based on Delivery Confirmation
scans. Thus, only parcels with purchased Delivery Confirmation will be
measured. The documented arrival time at the Postal Service acceptance
facility starts the clock of the service performance measurement. The
Postal Service scan of the Delivery Confirmation label at delivery, or
attempted delivery, stops the clock of the service performance
measurement. The difference, in calendar days, between the start-the-
clock event and the stop-the-clock event is reported as the service
performance measurement.
Publishers Clearing House comments that industry and the Postal
Service need to work together to overcome adoption barriers to placing
Delivery Confirmation barcodes on small parcels (of all classes).
Publishers Clearing House Comments at 1-2.
PostCom/DMA, joined by PSA, and Publishers Clearing House oppose
using Delivery Confirmation data from retail Package Services as a
proxy to measure presort Package Services. PostCom/DMA Comments at 5-6;
PSA Comments at 6-7; and Publishers Clearing House Comments at 2. They
infer that the Postal Service proposes to use Delivery Confirmation
data from retail Package Services as a proxy to measure presort Package
Services from its Initial Plan.\18\ PostCom/DMA asserts that the Postal
Service's intentions for measuring parcel-shaped presort Package
Services are unclear. It contends that retail Package Services and
presort Package Services have different entry and operational
characteristics, and that there is adequate Delivery Confirmation data
to separately measure retail and presort Package Services. PostCom/DMA
Comments at 5-6.
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\18\ ``The existing Delivery Confirmation performance reports
for mail originating at postal retail units can be used in the
short-term to measure the service performance of all Package
Services until service measurement can be extended to Presort
parcels.'' Initial Plan at 11.
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The Commission notes that the references implying use of a proxy do
not appear in the Revised Plan. The Revised Plan appears to indicate
that retail and presort will be measured separately with Delivery
Confirmation-based systems.\19\ The Postal Service appears to propose
separate measurement systems based on Delivery Confirmation scans for
retail and presort parcel-shaped Package Services mail. The Commission
approves of the separate measurement approach.
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\19\ See Revised Plan at 37-38, para. 7.2 (retail) and para. 7.3
(presort).
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Presort flats. The Postal Service proposes to use the hybrid
measurement system to measure presort flats.
The Commission looks forward to the development of this aspect of
the performance measurement system. Until the hybrid measurement system
for flats becomes a reality, the Postal Service should include a
discussion of its progress toward implementing this system with every
annual compliance report.
5. Special Services
Special Services are services offered by the Postal Service related
to the delivery of mailpieces, including acceptance, collection,
sorting, transportation, or other functions. Services within the
Ancillary Services and the International Ancillary Services products
can be purchased only in conjunction with the purchase of mail service.
Other Special Services products can be purchased on a stand-alone
basis. Special Services includes Ancillary Services; \20\ International
Ancillary Services; \21\ Address List Services; Caller Service; Change-
of-Address Credit Card Authentication; Confirm; International Reply
Coupon Service; International Business Reply Mail Service; Money
Orders; and Post Office Box Service.
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\20\ Ancillary Services include Address Correction Service;
Applications and Mailing Permits; Business Reply Mail; Bulk Parcel
Return Service; Certified Mail; Certificate of Mailing; Collect on
Delivery; Delivery Confirmation; Insurance; Merchandise Return
Service; Parcel Airlift (PAL); Registered Mail; Return Receipt;
Return Receipt for Merchandise; Restricted Delivery; Shipper-Paid
Forwarding; Signature Confirmation; Special Handling; Stamped
Envelopes; Stamped Cards; Premium Stamped Stationery; and Premium
Stamped Cards.
\21\ International Ancillary Services include International
Certificate of Mailing; International Registered Mail; International
Return Receipt; International Restricted Delivery; International
Insurance; and Customs Clearance and Delivery Fee.
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Delivery Confirmation, Signature Confirmation, Certified Mail,
Registered Mail, electronic Return Receipt, and Collect on Delivery.
The Postal Service proposes service measurements for Delivery
Confirmation, Signature Confirmation, Certified Mail, Registered Mail,
electronic Return Receipt, and Collect on Delivery that use internally
generated data from delivery event barcode scans to measure the time
between when delivery information is collected to when the information
is made available to the customer. The service performance score is the
percentage of information available within 24 hours.
The Public Representative notes that the Postal Service is
measuring only the time between when delivery information was collected
and when that information was made available to the mailer. However,
mailpieces that do not receive a delivery scan event to stop-the-clock
will not be measured, i.e., a failed performance will not be counted.
The Public Representative suggests that the Postal Service also report
the ratio of the number of pieces scanned at delivery to the number of
such pieces scanned at acceptance. Public Representative Comments at
48-52.
Confirm and automated Address Correction. The Postal Service
proposes service measurements for Confirm and automated Address
Correction that use passive scans of individual IMb mailpieces on
automated mail processing equipment. For Confirm, the start-the-clock
event is the time stamp of the mailpiece scan, and the stop-the-clock
is the date and time when data is made available to the subscribers.
For automated Address Correction, the start-the-clock event is the date
and time that data is transmitted to the Address Correction system, and
the stop-the-clock is the date and time when data are forwarded to the
participants. The service performance score is the percentage of on-
time information availability.
The Public Representative finds deficiencies similar to what is
discussed above with Confirm and Address Correction measurements. Id.
at 52. PostCom/DMA makes similar comments in the areas of Confirm and
Delivery Confirmation Service. PostCom/DMA Comments at 8-9.
Post Office Box Service. The Postal Service proposes a measurement
for Post Office Box Service that uses internally generated scanning
technology to measure the percentage of post office box sections that
meet their up-time service standards.
The Public Representative notes that this system does not prevent
the Postal Service from changing post office box up-times, and further
contends that the system lacks controls to prevent premature scanning
of the barcode to meet the up-time service standard. The Public
Representative proposes expanding EXFC coverage and using EXFC
reporters to measure post office box up-times. Public Representative
Comments at 52-54; see also Popkin Reply Comments at 1-2.
Insurance Claims Processing, Postal Money Order Inquiry Processing,
and Address List Services. For Insurance Claims Processing, Postal
Money Order Inquiry Processing, and Address List
[[Page 73673]]
Services the Postal Service proposes to internally measure the
percentage of time that the services meet their maximum processing
duration standards. The system for Insurance Claims Processing
generates a start-the-clock event when all information is received by
the Customer Inquiry Claims Response System, and generates a stop-the-
clock event upon the transmission to the customer of the adjudicator's
decision to pay, deny, or close the claim. The system for Postal Money
Order Inquiry Processing generates a start-the-clock event upon the
purchase of the service, and generates a stop-the-clock event upon the
transmission of a response to the customer. The system for Address List
Services generates a start-the-clock event upon the receipt of the
address list or address cards from the mailer at the delivery unit of
the postal district Address Management System office, and generates a
stop-the-clock event upon the transmission to the customer of corrected
address information.
Caller Service. The Postal Service contends that measuring Caller
Service is not practical because there is no one up-time as many
customers arrange for multiple pickups each day. It proposes to address
this issue through individual agreements.
Mailers concerned with remittance mail request establishing a
service standard for Caller Service. MMA Comments at 3; NPPC Comments
at 7; PostCom/DMA Comments at 9; Publishers Clearing House Comments at
2; and NPPC Additional Comments at 9-11. BAC further contends that
using the single post office box up-time measurement does not represent
the needs of remittance mailers. BAC Comments at 3.
Change-of-Address. The Postal Service does not propose a specific
measurement system for Change-of-Address service.
Noting the challenges of keeping up with the current addresses of
customers, BAC urges the Postal Service to establish standards for
Change of Address Service. BAC Comments at 3. The Public Representative
echoes this suggestion describing change of address requests and
forwarded mail as the Achilles' heel of First-Class Mail service
performance. Public Representative Comments at 8-12.
Commission analysis of Special Services. Special Services include
approximately 35 postal services with diverse attributes and a wide
range of revenue production levels.\22\ This diversity contributes to
the challenges of designing meaningful performance measurement systems
for each service. Some services such as Certificate of Mailing or
Stamped Cards essentially are transactions that may not merit much
performance measurement attention.\23\ Other services such as Insurance
and Delivery Confirmation are more complex and may warrant development
of measurement systems specifically tailored to the services being
provided.
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\22\ As noted above, most of the approximately 35 individual
services are components of either Ancillary Services or
International Ancillary Services.
\23\ Similarly, some services such as Caller Service may not be
susceptible to any meaningful measurement because of the nature of
the service itself.
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The different levels of revenue production for the various services
also may provide some indication of the effort warranted for developing
measurement systems. However, just because a service does not produce a
large revenue stream does not mean that the service is not important to
the customer that undertakes the additional effort to purchase the
service.
Three services--Certified Mail, Post Office Boxes, and Return
Receipts--account for nearly 70 percent of overall Special Services
revenue. It may be desirable to place special emphasis on these to
assure that they maintain a high level of service performance based on
revenue production alone.
For several of the services that include a barcode scan, the Postal
Service proposes to measure the time from the barcode scan event to the
time this information is made available to the customer. The percentage
of time that this duration falls within the applicable service standard
is reported as the measure of service performance. Although this
measurement may provide some information on one component of the
service, that measurement is not representative of the service that a
customer has purchased or expects.
As an example, the Postal Service states in the Domestic Mail
Manual that ``Delivery Confirmation service provides the mailer with
information about the date and time an article was delivered and, if
delivery was attempted but not successful, the date and time of the
delivery attempt.'' Thus, a typical mailer purchasing Delivery
Confirmation reasonably could expect to be provided with information
concerning the date and time of delivery or attempted delivery. If
Delivery Confirmation performs as advertised (or slower than
advertised), the proposed measurement system will capture whether or
not delivery information was provided to the customer in a reasonable
period of time. However, if Delivery Confirmation fails to report any
information at all to the customer, the measurement system will not
report this as a failure. Failures such as not scanning a mailpiece at
delivery or attempted delivery, or a failure of the scanning equipment
itself, are failures that will not be reported through the proposed
performance measurement system. In this case, the measurement is not
representative of the service being offered. At a minimum, the Postal
Service must incorporate into its proposed measurement systems for
Delivery Confirmation and other similar electronic systems a factor for
the volume of services purchased versus the volume of services
successfully completed.\24\
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\24\ Arguments have been made that this cannot be accomplished
because the Postal Service does not know exactly when to expect a
final scan or will not have an actual stop-the-clock. However,
reasonable assumptions can be made that overcome these arguments.
The Postal Service will now be developing and reporting measures of
time-to-delivery for all products.
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The measurement system for Return Receipt service presents
additional concerns. The Postal Service proposes to use the same
measurement system as described for Delivery Confirmation. However, the
vast majority of Return Receipt service is provided through delivery of
the green return receipt card. It is not apparent how a delivery scan-
based measurement system can be representative of the delivery of green
return receipt cards. As mentioned above, Return Receipt is one of the
highest revenue producing Special Services. It warrants a more robust,
independent performance measurement system.
The problems discussed above are symptomatic of many of the
measurement systems proposed for Special Services. The Commission finds
that the proposed measurement system does not take into account the
diverse attributes of these individual services, and does not provide
informative insight into their level of performance. The Commission
recommends that the Postal Service determine the attributes of each
service including the customer's reasonable expectations of what is
being purchased, and then design measurement systems considering these
parameters. A cost benefit analysis factoring in the sophistication of
the proposed measurement systems, the particular reliance a customer or
group of customers may have on a service, and the revenue generated by
a particular service also may be appropriate. Before providing the
Postal Service with an
[[Page 73674]]
endorsement of its approach to these internal measurement systems, the
Commission awaits further development of the systems to provide a
representative measure of the service being provided. The Postal
Service either should proceed with external measurement of service
performance for Certified, Return Receipt, and Delivery Confirmation or
develop an alternative internal measurement system by June 2009.
Post Office Box Service provides an exception to the above
comments. The proposed measurement system for post office boxes, which
measures the up-time, or the time that a day's mail becomes available
to customers, should provide a reasonable measure of performance. The
Commission recommends that the measurement system provide for internal
audits to verify that up-times are properly recorded by Postal Service
personnel, and that up-times are conspicuously available to mailers to
both inform customers of when mail is available and to deter any
tendency to shift up-times to later in the day in order to meet service
standards.
The Commission also approves the proposals for internally measuring
the percentage of time that Insurance claims processing, Postal Money
Order inquiry processing, and Address List Services meet their maximum
processing duration standards. For these systems, it appears
appropriate to measure the noted processing times instead of attempting
to develop a performance measurement of the product itself. These
systems can be enhanced in the future if necessary.
V. Review of the Postal Service Data Reporting Proposals
This section of the order provides a discussion of the Postal
Service's proposals for reporting data generated by its performance
measurement systems. The discussion includes consideration of the
comments submitted by the mailing community with limited
recommendations from the Commission. As mentioned previously, the
Commission intends to comprehensively consider annual and periodic data
reporting issues related to service performance measurement in a
separate rulemaking. The discussion that follows is a first step in
framing the issues that will be considered in that rulemaking.
It is important to note that this section does not discuss the
additional data reporting requirements that need to be developed to
assure that the measurement system provides representative and
statistically valid data. This also is an appropriate topic for future
rulemaking.
A. Postal Service Reporting Proposals
The Postal Service proposes providing two types of reports to the
Commission. The first is an annual report for the purpose of reviewing
compliance with service performance standards. Other reports will be
provided on a quarterly basis and provide more detail than the annual
report.
1. Annual Report Proposals
First-Class Mail. The Postal Service proposes reporting three
national aggregate annual percentage on-time service performance scores
for single-piece First-Class Mail: Overnight, 2-day, and 3-day/4-day/5-
day mail.\25\ It proposes reporting three national aggregate annual
percentage on-time service performance scores for presort First-Class
Mail: Overnight, 2-day, and 3-day mail. It proposes reporting a single
national aggregate annual percentage on-time service performance score
for single-piece International First-Class Mail.
---------------------------------------------------------------------------
\25\ The business rules defining 1- through 5-day domestic
First-Class Mail service standards appear at 72 FR 72225 (December
19, 2007). The Postal Service proposes to aggregate the reporting of
4-day and 5-day service standard mail (predominately mail with an
origin and/or a destination outside of the 48 contiguous states)
with the reporting of 3-day service standard mail (predominantly
origin-destination mail within the 48 contiguous states). An
estimated 99.7 percent of First-Class Mail pieces will have a
service standard of either 1, 2, or 3 days, and 0.3 percent will
have a service standard of either 4 or 5 days. Id. For brevity, 3-
day/4-day/5-day mail will be referred to as 3-day mail hereafter.
---------------------------------------------------------------------------
Standard Mail. The Postal Service proposes reporting a single
national aggregate annual percentage on-time service performance score
for Standard Mail. The score aggregates all of the 2- through 22-day
service performance standard groups for letter-, flat-, and parcel-
shaped mail.
Periodicals. The Postal Service proposes reporting a single
national aggregate annual percentage on-time service performance score
for Periodicals. The score aggregates each of the 1- through 8-day
service performance standard groups for letter- and flat-shaped mail.
Package Services. The Postal Service proposes reporting a single
national aggregate annual percentage on-time service performance score
for Package Services. The score aggregates each of the 2- through 20-
day service performance standard groups for Package Services mail.
Special Services. The Postal Service proposes reporting a single
national ``index'' representative of all Special Services. The index
weights and aggregates the various Special Services.
2. Quarterly Report Proposals
First-Class Mail. The Postal Service proposes providing data which
reports First-Class Mail on-time service performance and service
variances. Separate reports will be provided for domestic single-piece,
domestic presort, and international single-piece mail.
The on-time service performance reports provide the same
information as provided annually, but at a disaggregated level. The
domestic reports will be disaggregated by postal district and by
overnight, 2-day, and 3-day mail. The international reports will be
disaggregated by postal administrative area level and by inbound and
outbound mail.
The variance reports provide data on the percentages of mail
delivered within 1 day, 2 days, or 3 days of the applicable service
performance standard at the same level of disaggregation as the on-time
service performance reports.
Standard Mail. The Postal Service proposes providing data which
reports Standard Mail on-time service performance and service
variances.
The on-time service performance report provides the same
information as provided annually, but at a disaggregated level. The
report will be disaggregated by postal district and by destination
entry versus end-to-end mail.\26\
---------------------------------------------------------------------------
\26\ Destination entry includes destination bulk mail center,
destination area distribution center, destination sectional center
facility, and destination delivery unit.
---------------------------------------------------------------------------
The variance report provides data on the percentages of mail
delivered within 1 day, 2 days, or 3 days of the aggregated service
performance standard. This report also will display data by postal
district and by destination entry versus end-to-end mail.
Periodicals. The Postal Service proposes providing data which
reports Periodicals on-time service performance and service variances.
The on-time service performance report provides the same
information as provided in the Annual Compliance Report filing, but at
a disaggregated level. The report will be disaggregated by postal
administrative area level.
The variance report provides data on the percentages of mail
delivered within 1 day, 2 days, or 3 days of the aggregated service
performance standard. This report also will display data by postal
administrative area level.
Package Services. The Postal Service proposes providing data which
reports
[[Page 73675]]
Package Services on-time service performance and service variances.
The on-time service performance report provides the same
information as provided in the Annual Compliance Report filing, but at
a disaggregated level. The report will be disaggregated by postal
district.
The variance report provides data on the percentages of mail
delivered within 1 day, 2 days, or 3 days of the aggregated service
performance standard. This report also will display data by postal
district.
Special Services. The Postal Service proposes providing a
performance score which aggregates Delivery Confirmation, Signature
Confirmation, Certified Mail, Registered Mail, electronic Return
Receipt, and Collection on Delivery reported by postal district. A
quarterly score is reported for post office boxes disaggregated by
postal district. The performance scores for Confirm, automated Address
Correction, Insurance Claims Processing, Address List Services, and
Money Order Inquiry Processing each will be reported separately at the
national level.
B. Concerns of the Mailing Community
1. Granularity of Reporting
Reporting by product. Pitney Bowes, joined by DFS, requests that
the performance measurement plan reflect service performance data
reported by product as required by 39 U.S.C. 3691(b)(1)(D). They
contend that reporting by groups of products may make it difficult, or
impossible, for a mailer of a particular product to assess performance.
DFS Reply Comments at 3; Pitney Bowes Comments at 6-7; and Pitney Bowes
Additional Comments at 7.
General support is expressed by others for performance reporting by
product. PostCom/DMA contends that ``[m]easurement at the class level
obscures actual performance at product levels because of volume
differences by shape.'' PostCom/DMA Additional Comments at 2-3. McGraw-
Hill supports disaggregate reporting by product. McGraw-Hill Reply
Comments at 3. Valpak contends that saturation letters and carrier
route flats are separate products and should be measured separately.
Valpak Comments at 3-4; and Valpak Additional Comments at 5-7.
The Commission finds that compliance with the requirements of 39
U.S.C. 3691(b)(1)(D) is an appropriate issue to be considered in the
previously mentioned rulemaking on service performance data reporting
requirements.
Reporting by shape. Several mailers request shape-based reporting.
BAC Comments at 3; NPPC Comments at 6; PostCom/DMA Comments at 12-13;
Time Warner Comments at 3; Publishers Clearing House Comments at 1;
Valpak Comments at 10; DFS Reply Comments at 2; and NPPC Additional
Comments at 7.
MOAA extends this request to include separately reporting Standard
Mail letters and flats, tracing flats entered as carrier route on the
basis of entry as bundles or pallets, reporting by level of entry, and
by rate tiers. MOAA Comments at 2-3.
PSA argues that Standard Mail parcels and First-Class Mail parcels
are distinct products, and that the associated performance measurements
should be reported separately from other mail shapes. PSA Comments at
3-5; and PSA Additional Comments at 3-4. PostCom/DMA also opposes
aggregating the measurement of parcels with other shaped mail for each
of the respective classes. PostCom/DMA Comments at 5-6.
The Postal Service contends that the PAEA does not require the
establishment of standards based on price category or mailpiece shape
to satisfy the Commission's regulatory responsibilities. Postal Service
Reply Comments at 5-6.
Shape-based reporting in general might be informative to evaluate
the Postal Service's mail processing systems, since most mail
processing systems are designed around shape and not class or product.
Thus, the Commission finds that reporting by shape is an appropriate
issue to be considered in the previously mentioned rulemaking on
service performance data reporting requirements.
Reporting by service standard day. To allow for adequate evaluation
of service performance to the non-contiguous United States, PostCom/DMA
suggests separate reporting of 3-day and 4/5-day First-Class Mail which
is largely comprised of the 3-digit pairs that include the non-
contiguous United States. PostCom/DMA Additional Comments at 4-5.
The Commission finds that the level of aggregation of service
standard days is an appropriate issue to be considered in the
previously mentioned rulemaking on service performance data reporting
requirements. This issue is applicable to all classes of mail that have
specific days to delivery standards.
Data rich reporting. Most mailers submitting comments are
interested in obtaining service performance measurement data at a
higher level of detail than proposed by the Postal Service. Generally,
they request reporting most statistics by 30-digit ZIP Code pairs. AMEE
Comments at 2; NPPC Comments at 5; BAC Comments at 3-4; PostCom/DMA
Comments at 10-11; PostCom/DMA Additional Comments at 2-3; NPPC
Additional Comments at 6-8; Publishers Clearing House Comments at 2;
DFS Reply Comments at 2-3; IWCO Additional Comments at 2; and Public
Representative Comments at 46, 48.
In addition, some mailers request timely, or real time, Web-based
access to this data. McGraw-Hill Reply Comments at 2-3; Pitney Bowes
Comments at 5-6; and Time Warner Comments at 4. Other mailers propose
monthly interim reports as opposed to the proposed quarterly interim
reports. MMA Comments at 3; and PSA Comments at 5-6.
McGraw-Hill, MOAA, and Publishers Clearing House argue that mailers
should be able to obtain reports on their own mail down to 3-digit
pairs, together with the aggregate periodic reports. McGraw-Hill Reply
Comments at 4, n.4; MOAA Comments at 2; and Publishers Clearing House
Comments at 2.
The Postal Service responds that although the PAEA does not require
the generation of customer-specific reports, it intends on working with
the mailing industry in this area. It suggests that the degree of
customer access to disaggregate service performance data (in excess of
that required for the regulatory process), may have the character of an
ancillary service. Postal Service Reply Comments at 6.
The Commission observes that business needs of some mailers may
vastly exceed the needs of the regulator to perform its functions.
Although the Commission may well specify reporting in a greater level
of detail over time, it is not anticipated that the level of reporting
will reach the provision of near real time data envisioned by some
mailers. The Postal Service should be allowed time to explore the
business needs of its customers and propose information products to
meet those needs outside the context of the regulatory requirements.
Reporting volume information. AMEE and MMA suggest including
reporting volumes to determine relative weightings of the data. AMEE
Comments at 2; and MMA Comments at 2.
The Commission will require the reporting of volume data with the
quarterly reports. The need to be able to aggregate the quarterly data
up to annual levels was discussed during the consultation between the
Commission and the Postal Service. This includes provision of
respective volumes to
[[Page 73676]]
establish the necessary weighting of data. The Postal Service has
verbally agreed to providing volume information and a means to
aggregate the data from the quarterly reports up to the annual level.
Separate reporting of inbound and outbound International Mail.
Separate reporting of service performance for inbound and outbound
International Mail was discussed during the consultation between the
Commission and the Postal Service. Currently, the IMMS report is not
disaggregated in this fashion although the data to do so appears to be
available. The Postal Service indicated that it is possible to provide
separate reporting. This will be further examined in the previously
mentioned rulemaking on service performance data reporting
requirements.
2. Tail-of-the-Mail
A theme expressed in many comments is the need to expand tail-of-
the-mail reporting to obtain a more accurate picture of service
performance. The variance reports proposed by the Postal Service
generally provide data on the percentages of mail delivered within 1
day, 2 days, or 3 days of the applicable service performance standard.
NPPC stresses the importance to the remittance industry of a system
that distinguishes the distribution of late delivery by days of
lateness. NPPC Additional Comments at 9. Commenters generally express
opposition to truncating the variance reports at 3 days. Several
mailers propose expanding the variance reports to include the
additional days until delivery reaches a 99 percent level. BAC Comments
at 4; MPA Additional Comments at 4-5; McGraw-Hill Reply Comments at 3-
4; NPPC Comments at 5-6; NPPC Additional Comments at 8; PostCom/DMA
Comments at 14; PostCom/DMA Additional Comments at 4; and Public
Representative Comments at 45, 47-48.
Other approaches to expanding tail-of-the-mail reporting include
adding a column to the variance reports to show mail that is not
delivered within 3 days of the applicable standard (PSA Comments at 3),
and calculating and presenting the average number of days by which all
mailpieces are delivered in excess of the standard (Valpak Comments at
11-14; and Valpak Additional Comments at 3-4). Valpak also suggests
reporting tail-of-the-mail in the annual report in addition to what is
presented in the variance reports. Valpak Additional Comments at 4-5.
The other side of tail-of-the-mail is early delivery of mail.
Standard mailers in particular are sensitive to the consistency of
delivery for planning advertising to reach homes on specific dates.
These mailers propose expanding the variance reports to include
reporting on early deliveries of mail. AMEE Comments at 2; BAC Comments
at 4; MMA Comments at 2; IWCO Additional Comments at 2; MOAA Comments
at 3; NPPC Additional Comments at 9; and Valpak Additional Comments at
2-3.
The Commission recognizes the benefits to mailers of more detailed
reporting of delivery variance and consistency. The proposed
measurement systems should be able to capture this type of data and
provide the Postal Service with significant actionable data to
troubleshoot its systems. However, the Commission is not convinced that
data on early delivery is required for the Commission's purposes.
Mailers will still be able to work with the Postal Service when
specific problems are identified. This area is subject to re-evaluation
once the measurement systems begin generating actual data and specific
problems are identified.
3. Miscellaneous Issues
Consideration of customer satisfaction. The Public Representative
contends that the plan does not adequately measure or report customer
satisfaction, nor does it provide a mechanism to assess whether
customers, especially those with physical impairments, believe their
needs are being met. Public Representative Comments at 12-19.
The Postal Service asserts that it intends to redesign its Customer
Satisfaction Measurement survey to meet the requirements of the PAEA
and to generate customer satisfaction data on a product-by-product
basis. Postal Service Reply Comments at 10-11. It notes that the
survey's respondents are randomly solicited without regard to physical
impairment, and can be expected to include the view of customers with
such impairments. Id. at 12.
The Commission notes that the Postal Service is required to provide
an analysis of customer satisfaction in its annual report to the
Commission. See 39 CFR 3652(a)(2)(B)(ii). The Postal Service's Revised
Plan addresses measurement systems and data reporting. Discussion of
customer satisfaction appears beyond the scope of the Postal Service's
proposals and was appropriately omitted until the Customer Satisfaction
Measurement Survey has been redesigned.
Quality of service performance index. The Public Representative
proposes a Quality of Service Performance Index ``to review objectively
the results of the service performance measurements of the Postal
Service.'' The index can represent all postal products or groups of
products. The index would reduce the variety of performance statistics
to a single, or a few, numbers, and permit objective comparisons of
service over time. Public Representative Comments at 19-32.
McGraw-Hill supports the idea of an index to track performance over
time. McGraw-Hill Reply Comments at 1-3. NPPC calls this idea
intriguing and worthy of consideration. NPPC Reply Comments at 5.
PostCom/DMA does not oppose development of an index for each product or
each group of products, but opposes one overall index because such an
index would mask performance issues by specific products. PostCom/DMA
Reply Comments at 4-6. The Postal Service argues that the index is
beyond the statutorily defined scope of the Commission's regulatory
oversight. Postal Service Reply Comments at 11.
The Commission finds the proposal to provide indexes for the entire
service performance measurement system or for product groups therein
noteworthy, but premature. The immediate goal is to develop and
implement a performance measurement system and begin reporting data.
Specific indexes may be considered in the future to evaluate the data
once the measurement systems become operational.
Class-specific miscellaneous issues. MPA supports the revision to
the Postal Service's original proposal to report Periodicals service
measurement by performance area instead of only reporting a national
aggregate. MPA Additional Comments at 2. However, it continues to
suggest reporting Periodicals by postal district once IMb is in place.
MPA Comments at 3; and MPA Additional Comments at 2.
BAC and NPPC suggest disaggregating the service performance
measurement of remittance mail and treating remittance mail as a
distinct category of First-Class Mail. BAC Comments at 2; and NPPC
Comments at 7.
The Commission distinguishes separate reporting of remittance mail
from treating remittance mail as a distinct category of First-Class
Mail. The Postal Service has indicated to the Commission in
consultations that it is considering ways to separately measure the
performance of remittance mail, which indicates a future potential for
separate reporting of remittance mail. However, treating remittance
mail as a distinct category of First-Class Mail raises classification
issues that are beyond the scope of this discussion.
[[Page 73677]]
VI. Opportunity for Further Review
The PAEA provides the Postal Service and the Commission with the
flexibility to develop a useful and beneficial performance measurement
system over time. The Commission approves of the approach that the
Postal Service is taking to establish most of its measurement systems
recognizing that these systems are in the early stage of development.
The Commission is greatly appreciative of the Postal Service's
efforts thus far in making the measurement of service standards a
reality. The task is complex and will require continuing effort.
Inevitably, problems will arise as the systems are implemented that
will require changes to these systems. Informal procedures are
available for the Postal Service to keep the Commission apprised of
developments and to seek consultation where necessary as the
measurement systems progress. Regular meetings between the Postal
Service and the Commission to provide updates on progress and problems
are beneficial, including workgroup meetings at the staff level.
Continuing attention is necessary to keep the implementation of the
measurement systems on track. The Commission supports the ideas
expressed in the comments for the Postal Service to share its internal
milestones with the public, and to regularly report on progress. See
APWU Comments at 21; PostCom/DMA Comments at 21; and Valpak Reply
Comment at 3. The Postal Service will provide such reports to the
Commission at the beginning of each fiscal quarter.
Many formal avenues also are available by statute for reviewing and
improving the performance measurement system. These methods may be
employed as the needs of the Commission, the Postal Service, and the
mailing community change over time, or when specific issues arise that
require closer examination. The Commission will shortly initiate a
rulemaking to prescribe the content and form of public reports (and any
nonpublic annex and supporting materials) for performance data in the
Postal Service's annual report to the Commission. 39 U.S.C. 3652(e)(1).
It also may prescribe the methodologies used in preparing the annual
report. 39 U.S.C. 3652(a)(1).
Progress towards a smoothly functioning, broadly representative,
measurement system based on full service IMb must be monitored, and the
Postal Service should include with its ACR, discussions of the extent
to which various measures are representative. In this order, the
Commission identifies several potential problem areas the Postal
Service should focus on. Should it appear that progress toward reliable
measurement has ceased, or that ``the quality of service data has
become significantly inaccurate or can be significantly improved[,]''
proceedings may be initiated to remedy identified problems. 39 U.S.C.
3652(e)(2).
The effort to improve service through establishing standards and
measuring performance will be continuing. The modern service standards
are subject to review through the complaint process. 39 U.S.C. 3691(d).
Additionally, the Commission may, if necessary, initiate reporting
requirements through its obligation to establish a modern system for
regulating rates and classes for market dominant products. 39 U.S.C.
3622(a).
VII. Ordering Paragraphs
It is Ordered:
1. The Commission approves of the approaches that the Postal
Service is taking in developing internal measurement systems for
various classes of mail as specified in the body of this order.
2. The Commission finds the proposed measurement systems for
several Special Services are inadequate as specified in the body of
this order. Remedial action is to be proposed by June 1, 2009.
3. The Postal Service is to provide progress reports and analyses
of reliability for its measurement systems as specified in the body of
this order.
4. The Motion of the Public Representative for Late Acceptance of
Comments on United States Postal Service June 2008 Service Performance
Measurement Plan for Market-Dominant Products, filed July 10, 2008, is
granted.
5. The Secretary shall arrange for publication of this order in the
Federal Register.
VIII. Concurring Opinion of Commissioner Goldway
I agree with my colleagues that the initial approach to service
performance measurement proposed by the Postal Service offers the
potential of a reliable, low cost system. The Postal Service seeks to
use scans of Intelligent Mail Barcodes (IMb) to gauge service
performance by measuring the processing and transportation of bulk
letters and flats.
The Commission identifies a number of areas where the ability of
this system to accurately depict actual service performance will depend
on whether a representative mix of mail uses ``full service'' IMb. For
this reason, the Commission also directs the Postal Service to provide
quarterly progress reports on IMb implementation and to include with
its Annual Compliance Reports analyses of the representativeness of
certain service performance measurement results.
I write separately to clarify that, while the language of the order
offers options and suggestions on how to proceed to the Service, these
analyses and reports must be undertaken promptly and be complete in
their scope.
The Commission and the Postal Service have been consulting on these
issues for almost two years. The Commission views accurate and
comprehensive service performance measurement as a requirement of the
Postal Accountability and Enhancement Act. Unjustified, further delay
in obtaining reliable, representative service performance measurements
will not be acceptable.
Attachment A--Comments to Service Performance Measurement Systems for
Market Dominant Products
------------------------------------------------------------------------
Participant Title Filing date
------------------------------------------------------------------------
American Postal Workers Union, Initial Comments of January 18, 2008.
AFL-CIO (APWU). American Postal
Workers Union, AFL-
CIO, on Service
Performance
Measurement Systems
for Market Dominant
Products.
Association for Mail Comments of the January 18, 2008.
Electronic Enhancement (AMEE). Association for Mail
Electronic
Enhancement.
Association for Postal Initial Comments of January 18, 2008.
Commerce and Direct Marketing the Association for
Association (PostCom/DMA). Postal Commerce
Joined by the Direct
Marketing
Association.
[[Page 73678]]
Reply Comments of the February 1, 2008.
Association for
Postal Commerce
Joined by the Direct
Marketing
Association
(Corrected Version).
Comments of the July 9, 2008.
Association for
Postal Commerce
Joined by the Direct
Marketing
Association: Order
No. 83.
Bank of America Corporation Comments of the Bank January 18, 2008.
(BAC). of America
Corporation.
Cond[egrave] Nast Publications Comments of July 8, 2008.
Cond[egrave] Nast
Publications.
Discover Financial Services Reply Comments of DFS February 1, 2008.
LLC (DFS). Services LLC in
Response to Notice
for Request for
Comments.
Greeting Card Association Comments of the January 18, 2008.
(GCA). Greeting Card
Association.
IWCO Direct................... Comments of IWCO July 9, 2008.
Direct.
Magazine Publishers of Comments of Magazine January 18, 2008.
America, Inc. (MPA). Publishers of
America, Inc.
Comments of Magazine July 9, 2008.
Publishers of
America, Inc.
Mail Order Association of Comments of the Mail January 17, 2008.
America (MOAA). Order Association of
America on the
Postal Service's
``Service
Performance
Measurement'' for
Market Dominant
Products.
Major Mailers Association Comments of Major January 18, 2008.
(MMA). Mailers Association.
McGraw-Hill Companies, Inc. Reply Comments of The February 1, 2008.
(McGraw-Hill). McGraw-Hill
Companies, Inc.
National Newspaper Association Comments of National January 18, 2008.
(NNA). Newspaper
Association on
Service Performance
Measurement Systems
for Market Dominant
Products.
National Postal Policy Council Comments of National January 18, 2008.
(NPPC). Postal Policy
Council.
Reply Comments of February 1, 2008.
National Postal
Policy Council.
Comments of National July 9, 2008.
Postal Policy
Council.
Parcel Shippers Association Comments of the January 18, 2008.
(PSA). Parcel Shippers
Association on
Service Performance
Measurement Systems
for Market Dominant
Products.
Further Comments of July 9, 2008.
the Parcel Shippers
Association on
Service Performance
Measurement Systems
for Market Dominant
Products.
Pitney Bowes Inc. (Pitney Initial Comments of January 18, 2008.
Bowes). Pitney Bowes Inc. in
Response to Notice
of Request for
Comments on Service
Performance
Measurement Systems
for Market Dominant
Products.
Reply Comments of February 1, 2008.
Pitney Bowes Inc. in
Response to Notice
of Request for
Comments on Service
Measurement Systems
for Market Dominant
Products.
Comments of Pitney July 9, 2008.
Bowes Inc. in
Response to the
Second Notice of
Request for Comments
on Service
Performance
Measurement Systems
for Market Dominant
Products.
David B. Popkin (Popkin)...... Initial Comments of January 18, 2008.
David B. Popkin.
Reply Comments of February 1, 2008.
David B. Popkin.
Public Representative......... Public Representative January 18, 2008.
Initial Comments in
Response to Notice
of Request for
Comments on Service
Performance
Measurement Systems
for Market-Dominant
Products.
Public Representative February 1, 2008.
Reply Comments in
Response to Notice
of Request for
Comments on Service
Performance
Measurement Systems
for Market-Dominant
Products.
Public Representative July 10, 2008.
Comments on United
States Postal
Service June 2008
Service Performance
Measurement Plan to
Market-Dominant
Products.
Publishers Clearing House..... Comments on Docket January 18, 2008.
No. PI2008-1 Service
Performance
Measurement Systems
for Market Dominant
Products.
Research International........ Comments of Research January 14, 2008.
International.
Research July 8, 2008.
International Second
Notice of Request
for Comments on
Service Performance
Measurement Systems
for Market Dominant
Products.
[[Page 73679]]
Time Warner Inc. (Time Warner) Comments of Time January 18, 2008.
Warner Inc. in
Response to
Commission Order No.
48.
United States Postal Service Reply Comments of the February 1, 2008.
(Postal Service). United States Postal
Service.
Valpak Direct Marketing Valpak Direct January 18, 2008.
Systems, Inc. and Valpak Marketing Systems,
Dealers' Association, Inc. Inc. and Valpak
(Valpak). Dealers'
Association, Inc.
Comments on Service
Performance
Measurement Systems
for Market Dominant
Products.
Valpak Direct February 1, 2008.
Marketing Systems,
Inc. and Valpak
Dealers'
Association, Inc.
Reply Comments on
Service Performance
Measurement Systems
for Market Dominant
Products.
Valpak Direct July 9, 2008.
Marketing Systems,
Inc. and Valpak
Dealers'
Association, Inc.
Comments on Service
Performance
Measurement Systems
for Market Dominant
Products in Response
to Order No. 83.
------------------------------------------------------------------------
By the Commission.
Steven W. Williams,
Secretary.
[FR Doc. E8-28643 Filed 12-2-08; 8:45 am]
BILLING CODE 7710-FW-P