FISCAL 

YEAR 

2022

CONGRESSIONAL 

BUDGET 

JUSTIFICATION
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FY 2022 CONGRESSIONAL BUDGET JUSTIFICATION | 1

Executive Summary 3

About the Commission 5

Fiscal Year 2022 Budget Highlights 7

Fiscal Year 2022 Budget Justification 9

Commission Strategic Plan and the FY 2022 Budget Request 13

Proposed Appropriations Language 25

Office of the Inspector General Resources 27

Appendix A: Technical Budget Tables 29

Appendix B: Mission, Guiding Principles, and Vision 31

Appendix C: Strategic Goals, Work Plans, and Performance Objectives 33

TABLE OF CONTENTS
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FY 2022 CONGRESSIONAL BUDGET JUSTIFICATION | 3

Executive Summary

The Postal Regulatory Commission (Commission) is an independent agency that oversees the 

U.S. Postal Service (Postal Service) and provides 

analyses of and transparency into postal financial 

operations to Congress, stakeholders, and the 

general public. This funding request will allow 

the Commission to effectively align its mission 

resources, and invest special studies, data analytics, and transparency initiatives at a time when 

the Postal Service is facing unprecedented operational and financial challenges. The Commission’s 

staff is the driving force supporting its mission 

to ensure transparency and accountability of 

the Postal Service and foster a vital and efficient 

universal mail system for the American people. 

The Commission’s staff ensures the Postal Service 

complies with the law, in areas including postal 

rates, product offerings, service quality, the letter 

monopoly, and fair competition.

The Commission’s fiscal year (FY) 2022 request 

of $19,585,000 is necessary to support its operational expenses in a time when there is a critical 

need for postal oversight and transparency. In 

FY 2022, in addition to the Commission’s annual 

reporting and core regulatory oversight responsibilities, the Commission will continue its work to 

implement key analytics, initiatives, and conduct 

necessary research. These data transparency initiatives will focus on enhancing the accountability 

of the Postal Service in areas of non-compliance, 

such as the quality and timeliness of mail delivery and the impact of Postal Service operational 

changes. The Commission also intends to use its 

FY 2022 appropriation to fund analysis of the 

Universal Service Obligation (USO)—the Postal 

Service’s ability to meet its statutory mission of 

providing prompt, reliable universal postal services in an efficient and self-sustaining manner.

This work is critical to understanding the effects 

of certain initiatives and planned changes made 

by the Postal Service, as the Commission serves 

as a vital resource for Congress, the Administration, postal stakeholders, and the American 

public with respect to the Postal Service’s compliance with the law. The Commission will take on 

this additional work at the same time that it will 

implement the new system governing Market 

Dominant rates and continue to conduct reviews 

and analysis of postal rates, product offerings, 

service quality, post office closing appeals, and 

complaints. 

The FY 2021 appropriation will fund up to 74 

staff, which is insufficient to complete the necessary work of the Commission. The Commission’s 

FY 2022 request of $19,585,000 will fund an 

additional eight staff members to carry out its 

increasing regulatory responsibilities, support its 

investment in key special studies, data analytics, 

and transparency initiatives, and invest in necessary research to complement its work. The Commission operates on an extremely modest budget 

for an agency with its scope of responsibilities, 

with 95 percent of its expenses attributed to personnel costs and its lease. Its small complement 

of expert staff are directly responsible for achieving the Commission’s mission to ensure transparency and accountability of the Postal Service and 

foster a vital and efficient universal mail system. 

The requested funding will also support the 

Commission’s administrative work related to the 

efficient and secure operation of necessary information technology (IT) systems. These projects include deferred IT infrastructure updates, 

support of the Commission’s docket system that 

stores, organizes and makes accessible all filings 

in Commission proceedings, and development of 

a cybersecurity program. The Commission hosts 

a robust docketing system capable of handling 

large volumes of sensitive and non-public data, 

and it also serves as the system for administering 
4 | POSTAL REGULATORY COMMISSION 

Commission rulemakings and compliance determinations, including facilitating robust public 

participation. This system has reached its end 

of life and will be replaced in FY 2022, requiring 

significant investment.

Due to the impact of COVID-19 and recent initiatives announced by the Postmaster General, 

the Commission expects an increased workload 

starting in FY 2021 and needs to scale its operations to fulfill its regulatory oversight role. With 

a rapidly evolving postal sector resulting in an 

ever-increasing and complex caseload at the 

Commission, it is imperative that the Commission 

have the necessary funds to provide transparency 

and accountability of the Postal Service. The FY 

2022 Budget request of $19,585,000 will allow 

the Commission to retain and expand expert staff, 

invest in key initiatives, and ensure adequate IT 

infrastructure resources to reach its full operating 

level. 

To ensure the Commission’s independence, Congress appropriates all of the Commission’s funds 

out of the off-budget Postal Service Fund. The 

law requires that “[t]he President shall include 

these amounts, with his recommendations but 

without revision, in the budget transmitted to 

Congress....” 39 U.S.C. § 2009. Although the Commission’s funds are not derived from Treasury 

funds, participation in the appropriations process 

has constrained its ability to scale its small operations in proportion to its expanded oversight role. 

Specifically, since 2008, the Commission’s budget 

has increased 13 percent, while inflation was 25 

percent.
FY 2022 CONGRESSIONAL BUDGET JUSTIFICATION | 5

About the Commission

The Commission is an independent establishment of 

the Executive Branch of the United States Government. 

It has exercised regulatory oversight over the Postal 

Service since its creation by the Postal Reorganization 

Act of 1970, with expanded responsibilities under 

the PAEA of 2006. It has five commissioners, each 

appointed by the president, by and with the advice 

and consent of the Senate, for a term of 6 years. 

Above: Commissioner Ann Fisher, 

Commissioner Robert Taub, 

Vice Chairwoman Ashley Poling, 

Chairman Michael Kubayanda, 

Commissioner Mark Acton
6 | POSTAL REGULATORY COMMISSION 

Overview of the Commission

The Commission is an independent establishment of the executive branch, exercising regulatory oversight over the Postal Service since 

its creation by the Postal Reorganization Act of 

1970, with expanded responsibilities under the 

Postal Accountability and Enhancement Act of 

2006 (PAEA). The Commission has vast responsibility to provide critical regulatory oversight of 

the Postal Service. The Commission receives its 

funding from the off-budget Postal Service Fund, 

which is the permanently appropriated revolving fund comprised solely of the revenues that 

the Postal Service generates from selling postal 

products and services. 

The Commission is composed of five commissioners, each appointed by the President, and with 

the advice and consent of the Senate, for terms 

of 6 years. No more than three of the commissioners may be from the same political party. The 

President designates one of the commissioners to 

serve as chairman. The chairman is the principal 

executive officer of the Commission.

Commission staff have expertise in economics, 

finance, statistics, cost accounting, and law. The 

four offices are:

• Office of Accountability and Compliance (OAC)

• Office of the General Counsel (OGC)

• Office of Public Affairs and Government Relations (PAGR)

• Office of Secretary and Administration (OSA)

The Commission’s budget also maintains an independent Office of the Inspector General (OIG).

Figure I: Organizational Structure

Jack Callender

Office of the

Inspector General

Deputy Director

Matthew Robinson

Deputy Director

JP Klingenberg

Deputy General 

Counsel

Christopher Laver

Deputy General 

Counsel

Lauren D'Agostino

Office of

Accountability

& Compliance

Margaret Cigno

Office of Public Affairs 

& Government Relations

Jennifer Alvarez Warburton

Office of the

General Counsel

David Trissell

Office of Secretary

& Administration

Erica Barker

Mark Acton

Commissioner

Ann Fisher

Commissioner

Ashley Poling

Vice Chairwoman

Michael Kubayanda

Chairman

Robert Taub

Commissioner
FY 2022 CONGRESSIONAL BUDGET JUSTIFICATION | 7

Fiscal Year 2022 Budget Highlights

Special Studies, Data Analytics, and Transparency

• Implement a special studies, data analytics and transparency initiative to better use data for 

more effective oversight in furtherance of the Commission’s mission of providing accountability 

and transparency of the postal system. This initiative will provide more timely and useful 

data for the Commission, postal stakeholders, and policymakers and is consistent with recent 

congressional direction including the OPEN Government Data Act (Title II, P.L. 115-435) and 

the Confidential Information Protection and Statistical Efficiency Act (44 U.S.C. § 101, et seq.). 

The initiative also supports the Commission’s longstanding Strategic Goal 1, to deliver accurate 

and objective analyses and decisions to ensure transparency and accountability of the Postal 

Service, and Strategic Goal 2, to facilitate public access and participation and to engage with 

Congress and the public.

Accountability of Postal Operations

• Conduct a necessary review of the cost of the Postal Service’s USO and the value of its monopoly.

• Continue review of 39 U.S.C. § 601 to promulgate any necessary regulations related to the Postal 

Service’s letter monopoly.

• Ensure sufficient Commission resources (personnel and technology) are available so the 

Commission can effectively provide timely regulatory oversight for the American public, and 

postal stakeholders if the Postal Service implements nationwide changes that impact the value, 

service, and/or reliability of postal services.

Compliance with the Law

• Continue fulfillment of Commission’s core regulatory responsibilities, including:

o Conducting the Annual Compliance Determination (ACD), evaluating service, rates, and costs 

of the Postal Service

o Analyzing Postal Service Financial Results and 10-K Statements

o Reviewing proposed Market Dominant Rate Adjustments

o Reviewing proposed Competitive Rate Adjustments

o Evaluating Competitive Negotiated Service Agreements (NSAs), in FY 2020:

– 210 Domestic

– 57 International

o Analyzing the Postal Service’s Program Performance Report and Performance Plan

o Preparing an Annual Report to the President and Congress

o Reviewing proposals to change analytical principles related to Postal Service cost 

methodologies (16 proposals reviewed in FY 2020)

o Providing expert international regulatory oversight in the areas of terminal dues, bilateral and 

multi-lateral agreements, self-declared rates charged to foreign posts, and Commission views 

to the Secretary of State on international matters.

Revised System of Market Dominant Ratemaking and Classification

• Continue implementation of final regulations issued following the Commission’s “10-Year 

Review.”
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FY 2022 CONGRESSIONAL BUDGET JUSTIFICATION | 9

Fiscal Year 2022 Budget Justification

The Commission is a highly effective independent 

agency with a significant mission—to ensure 

transparency and accountability of the Postal Service and foster a vital and efficient universal mail 

system. For over 50 years, the Commission has 

provided legal and economic oversight of the one 

agency that touches the lives of all Americans and 

American businesses in every community nearly 

every day. The Postal Service will continue to face 

unprecedented challenges in FY 2022. Therefore 

to ensure the Commission is able to provide effective oversight, the Commission requests a FY 

2022 appropriation of $19,585,000, which will 

support 82 full-time equivalents (FTEs). This represents an increase of $2,585,000 over the Commission’s FY 2021 enacted budget. 

This funding increase is dedicated to increasing staff complement and funding necessary 

expenses. The increased appropriation will fund 

eight needed FTEs who will directly support the 

Commission’s mission of ensuring Postal Service accountability and transparency. This small 

increase in staff would bring the Commission to 

82 FTEs strengthening the Commission’s ability 

to deliver timely, accurate, and objective analyses that support the Commission’s regulatory 

decisions and orders that ensure compliance, 

transparency, and accountability of the Postal 

Service. The Commission’s funding request of 

$19,585,000, represents only 0.03 percent of 

the Postal Service’s total FY 2020 revenue, and a 

minute fraction of the $1.6 trillion mailing industry that employs more than 7.3 million people. 

The Commission’s requested appropriation of 

$19,585,000 and staffing level of 82 FTEs would 

allow the Commission to meet its core regulatory 

oversight responsibilities, invest in key special 

studies, data analytics, and transparency initiatives, conduct necessary research, update aging 

technology, and retain its small expert staff.

Reliable and effective postal service is vital to the 

American economy and commerce. The preparation, processing, and delivery of mail have recently encountered dramatic changes that have 

challenged Postal Service operations. Continuing 

a trend that began in the last decade, rising costs 

and deterioration in the quality of service have 

threatened the reliability and financial stability 

of an essential public service. The Postal Service’s 

ability to provide universal service that connects 

the nation has been further impacted by the effects of the COVID-19 pandemic. As the Postal 

Service, Congress, and the President look for new 

ways to improve the Postal Service’s operations, 

the Commission’s oversight is necessary to ensure the Postal Service complies with the law and 

remains accountable to the public. Investing in 

the Postal Service’s future requires funding for its 

regulator—the Commission.
Table 1: FY 2020 Actual Expenses, FY 2021 Appropriation, 

and FY 2022 Requirement ($000)

Spending Categories

FY 2020 

Actual Expenses 

(69 FTEs)

FY 2021

Appropriation

(74 FTEs)

FY 2022 

Requirement

(82 FTEs)

Personnel compensation and benefits 12,937 13,559 15,408

Rental payments to others 2,213 2,184 2,229

Services and supplies:

Information technology 334 259 265

Contracting services 315 372 379

Consulting services 325 0 597

Communications 260 181 185

Other services and supplies 231 446 522

Service and supplies subtotal 1,465 1,258 1,948

Total Obligations 16,615 17,000 19,585 

10 | POSTAL REGULATORY COMMISSION 

The Commission’s proposed budget request for 

FY 2022 of $19,585,000 represents a 2 percent increase from the FY 2021 President’s recommendation of $19,200,000. This request consists of three 

categories of spending: personnel compensation 

and benefits (payroll); rent; and services and 

supplies. The FY 2022 payroll of $15.408 million 

funds 82 FTEs. The requested amount will also 

maintain the Commission’s rent commitments for 

$2.229 million. Together, the Commission’s staff 

and rent obligations make up 90 percent of its requested budget. The remaining $1.948 million of 

the Commission’s budget request covers all other 

Commission expenses including consulting services to support special studies and research, travel, 

training, IT infrastructure, and other expenses for 

mission operations and agency administration.

Table 1, which shows FY 2020 Commission 

expenditures, illustrates the limited room for 

budget reductions outside of staff cuts that would 

ultimately degrade the Commission’s ability to 

meet its mission. The Commission is obligated to 

a long-term lease through 2022, and will continue 

to explore ways to reduce rental costs and optimize physical space throughout the Commission 

before its lease expires. 

Staff-related expenses account for 80 percent of 

the overall budget, a reflection of the Commission’s lean operations. The Commission’s technical and legal analyses are provided by its expert 

staff in OAC and OGC. In FY 2021, these offices are 

staffed by 41 analysts, economists, attorneys, and 

paralegals who review and analyze hundreds of 

Postal Service compliance matters and stakeholder requests each year and engage in significant 

and extensive regulatory actions. With a budget of 

$19,585,000 in FY 2022, the Commission will be 

able to increase the staff to better support these 

offices. 

The FY 2021 enacted budget of $17,000,000 is not 

sufficient to fund the Commission’s core regulatory oversight, let alone necessary special studies, 

modern data analytics and transparency, research, 

and updating aging technology. The Commission 

will also need to curtail planned hiring to accommodate this lower appropriation. Therefore, in 

FY 2021, the Commission will need to utilize its 

balances from previous years to fulfill its mission. 

In FY 2020, the Commission became aware that 

these balances were held within Postal Service 

accounts. In FY 2021, the Commission plans to 

exhaust at least $1 million of its prior year 
FY 2022 CONGRESSIONAL BUDGET JUSTIFICATION | 11

Table 2: FY 2008 - FY 2020 Commission Enacted Appropriation and 

Approved NSAs

FY

Enacted 

Appropriation 1

($000)

Competitive 

NSAs

Market 

Dominant 

NSAs

Total 

NSAs

Presidential 

Budget FTEs

2008 14,895 21 0 21 70

2009 14,043 66 1 67 74

2010 14,333 124 3 127 74

2011 14,304 61 2 63 74

2012 14,304 54 4 58 75

2013 14,275 81 6 87 76

2014 14,152 76 6 82 72

2015 14,700 139 3 142 77

2016 15,200 284 4 288 77

2017 16,200 315 5 320 76

2018 15,200 307 1 308 74

2019 15,200 216 1 217 74

2020 16,615 267 0 267 69

2008-2020 

change 

11.5% 1,171% n/a 1,171% n/a

1 FY 2009 was the first year that the Commission’s budget was included within appropriations legislation. Prior 

to FY 2009, the Commission submitted its budget to the Postal Service’s Board of Governors who could adjust 

the request by unanimous agreement.

balances to fund some non-salary costs; improve 

IT infrastructure, and upgrade its aging dockets 

application. However, these prior year balances 

are finite, and therefore cannot be relied on for 

any recurring expenses related to increasing staffing levels, or investing in long-term initiatives.

The Commission’s small expert staff operate with 

a very modest budget, with vast regulatory responsibilities pertaining to the Postal Service’s 

rates, financial reporting, product offerings, 

service quality, the letter monopoly, and fair 

competition. The Commission’s requested appropriation will give it the ability to build capacity to meet its core regulatory responsibilities 

with an added focus on more in-depth analysis 

of complex data and information from the Postal 

Service in order to provide greater transparency 

and accountability. The Commission must have 

sufficient resources to properly research, oversee, 

and provide transparency on the Postal Service’s 

finances, operations, and service. 

This appropriation request reflects the Commission’s need to adjust and respond to the 

increased workload due to changes in the law 

and the postal sector. Prior to 2006, the Commission, on average, reviewed major postal rate 

cases about once every three years. In 2008, the 

Commission approved 21 specialized contracts, 
12 | POSTAL REGULATORY COMMISSION 

known as NSAs, between the Postal Service and 

its customers such as businesses and nonprofit 

organizations. By FY 2020 the Commission was 

approving over 250 NSAs each year, while generally overseeing 2 annual rate cases, and managing 

the exhaustive annual compliance process, among 

other matters.

These changes also include recent service delays, potential nationwide operational changes, 

and ongoing financial challenges. In FY 2022, the 

Commission will need to adjudicate an increasing 

number of proceedings relating to the impact of 

COVID-19 and Postal Service operational changes 

affecting service performance. On March 23, 

2021, the Postal Service released a 10-year plan, 

introducing changes in the nature of postal services generally affecting nationwide service that 

the Commission may be required to review. The 

Postal Service has requested two Advisory Opinions on “Nature of Service” cases and anticipates 

additional requests as contemplated under its 

10-year plan. These cases will each require public 

notice and comment and hearings under the 

Administrative Procedures Act, and will consume 

significant resources. This additional workload 

demands intensive analysis by the Commission, involves extensive public participation, and 

requires a significant share of the Commission’s 

already strained resources. The Commission 

will need to increase its capacity to effectively 

respond to requests by the Postal Service, the 

Administration, and Congress and may require 

hiring consultants and contractors in addition to 

full time personnel. 

Additional information on the work of the Commission and its accomplishments can be found in 

the Commission’s Annual Reports, published at 

www.prc.gov. Each year the Commission’s Annual Report details key activities in its regulatory 

oversight and outlines the efficacy of the Commission’s regulatory actions as measured by statutory objectives.
FY 2022 CONGRESSIONAL BUDGET JUSTIFICATION | 13

The Commission’s budget request and justification is aligned with its Strategic Plan. The FY 2017-

2022 Strategic Plan was developed to serve as the 

framework to guide the future work of the Commission and is a fundamental beacon for the Commission’s efforts toward continuous improvement, 

efficiency, and effectiveness. The four strategic 

goals listed below guide the Commission’s work 

and serve to directly link the budget to the Strategic Plan’s Work Plans and Performance Objectives, 

provided in Appendix C.

1. Postal Service Accountability: Deliver 

accurate and objective analyses and 

decisions to ensure transparency and 

accountability of the Postal Service.

2. Public Access and Participation: Actively 

engage with Congress and stakeholders in 

support of a dynamic postal system.

3. Integration and Support: Provide an 

optimal internal infrastructure to support 

management of priorities, workload, and 

emerging requirements.

4. Workforce: Recruit, develop, and retain a 

diverse, high-performing workforce.

The Commission applies its Strategic Plan to 

prioritize and enhance the effectiveness of operations by aligning its limited resources to accomplish its vast mission and meet its statutory responsibilities. In FY 2022, the Commission will be 

creating a new strategic plan for the next 5 years. 

This effort will build upon the existing Strategic 

Plan to ensure the ongoing alignment of agency 

strategic goals and performance pay process with 

its mission.

Strategic Goal 1: Postal Service Accountability

The FY 2022 request allocates $11.030 million 

for Strategic Goal 1, Postal Service Accountability. 

Strategic Goal 1 focuses on delivering accurate 

and objective analyses and decisions to ensure 

compliance, transparency, and accountability of 

the Postal Service. Compliance and analysis is the 

core of the Commission’s work. The Commission’s 

approach to its regulatory obligations ensures 

thorough and accurate analysis and application of 

its governing statutes, regulations, and precedent. 

The Commission ensures transparent and accurate information through Postal Service reporting 

requirements and determinations of compliance 

and other regulatory orders. This includes the 

Commission’s evaluation of Postal Service data 

for lawful compliance of rates and service performance. The Commission is also required to ensure that the interests of the public are represented in every proceeding by appointing a member 

of its staff as public representative in each docket. 

This is a unique requirement specific 

to the Commission and is included in within the 

cost of Strategic Goal 1.

The Commission’s appropriated budgets in FYs 

2020 and 2021 were insufficient to meet the 

research needs required to complement the Commission’s regulatory oversight. With an increased 

budget of $19,585,000, the Commission will be 

able to hire additional staff to invest in key special 

studies, data analytics, transparency initiatives, 

and fund additional research to support its regulatory oversight and continue to ensure Postal 

Service transparency and accountability. 

As the sole regulator of the Postal Service, the 

Commission’s 74 staff (FY 2021) are tasked with 

overseeing and ensuring legal compliance of 

a global operation with $73 billion in FY 2020 

revenues and more than 630,000 employees. The 

Commission must increase its staffing levels in FY 

2022 to remain an effective regulator and invest 

in special studies, data analytics, and transparency initiatives. If the Commission lacks the 

Commission Strategic Plan and the FY 2022 Budget Request
14 | POSTAL REGULATORY COMMISSION .

resources to handle this increased workload, its 

ability to provide effective and timely oversight of 

the Postal Service—and, in turn, the protection of 

United States citizens and businesses who rely on 

the mail—will be at risk.

The FY 2022 Budget initiatives and activities that 

contribute to effective compliance and analysis 

funded by this request include:

• Data Analysis, Compliance, and Reporting

• Rulemakings

• Other Matters and Research Areas

Data Analysis, Compliance, and 

Reporting

The Commission is responsible for the thorough 

and accurate analysis of Postal Service reports on 

performance, operational, and financial issues in 

order to ensure that the Postal Service is compliant with the law and is held accountable when 

not in compliance. The Commission relies on 

its small team of expert technical and legal staff 

to support its mission and the FY 2022 funding 

request directly supports hiring additional staff 

to fulfill this responsibility and maintain payroll 

costs necessary to fund current staff. 

DATA ANALYSIS

Over the past decade, government agencies, 

including the Postal Service, have expanded their 

use of data analytics to enhance their work. In addition, the postal sector has become more digital 

and data savvy, as participants leverage data to 

play a greater role in electronic commerce; use 

application programming interfaces to link retailers, delivery providers, intermediaries, and 

customers; deploy integrated “omnichannel” or 

“multichannel” (combining multiple print and 

digital options) marketing and retail campaigns; 

and use data to improve operational efficiency 

and target bottlenecks.

The Commission has not had sufficient resources to partake robustly in these transformations despite its unique expertise and role 

in the postal sector. The Commission’s FY 2022 

Budget Request will allow the Commission to 

move past these limitations by enhancing its 

analytical expertise and obtaining tools to better 

leverage data. This initiative is consistent with 

congressionally-enacted policy goals that call 

for “improv[ing] the quality and use of Federal 

information to strengthen decisionmaking, accountability, and openness in Government and society[,]” and “provid[ing] for the dissemination of 

public information . . . in a manner that promotes 

the utility of the information to the public and 

makes effective use of information technology.” 44 

U.S.C. § 3501(4) and (7). The Commission is dealing with a number of ongoing and acute compliance issues, which could benefit from better use 

of data, including analytics and visualization. Concerns about Postal Service operations and service 

have reached their zenith in recent months, with 

poor service performance and anecdotes of mail 

taking weeks or months to reach its destination. 

Both the House Oversight and Reform Committee and the House Financial Services and General 

Government Appropriations Subcommittee held 

hearings on service matters in the first quarter of 

calendar year 2021, underscoring the urgency of 

these matters. 

The Commission plans to move past these limitations by obtaining analytical expertise and tools 

in order to better leverage data. This initiative is 

consistent with congressionally-enacted policy 

goals that call for “improv[ing] the quality and 

use of Federal information to strengthen decisionmaking, accountability, and openness in Government and society[,]” and “provid[ing] for the 

dissemination of public information . . . in a manner that promotes the utility of the information 

to the public and makes effective use of information technology.” 44 U.S.C. § 3501(4) and (7). The 

Commission is dealing with a number of ongoing 

and acute compliance issues, which could benefit from better use of data, including analytics 

and visualization. Concerns about Postal Service 

operations and service have reached their zenith 

in recent months, with poor service performance 

and anecdotes of mail taking weeks or months to 

reach its destination. Both the House Oversight 
FY 2022 CONGRESSIONAL BUDGET JUSTIFICATION | 15

and Reform Committee and the House Financial 

Services and General Government Appropriations 

Subcommittee held hearings on service matters 

in the first quarter of calendar year 2021, underscoring the urgency of these matters. 

There are also ongoing compliance issues which 

could benefit from stronger analysis. In FY 2020, 

for example, none of the flat-shaped mail products (such as catalogs and magazines) met their 

standard for service performance, while only four 

of the eight flat-shaped products covered their 

costs as required by law. For several years, the 

Commission has issued directives and regulations 

to require the Postal Service to provide better information on flat-shaped mail products and bring 

them into compliance, while the Postal Service 

has also launched a series of management initiatives to address flats costs and service issues. 

The reporting requirements are designed to elicit 

meaningful data about the state of service and 

operations, and uncover root causes of service 

and operational issues in the postal network. The 

flats non-compliance issues have been the subject 

of Commission directives dating back to 2015 and 

the issues were discussed in a 2011 report jointly 

issued by the Commission and the Postal Service.

It is difficult to pinpoint the causes of such problems and to distinguish between various drivers 

such as management initiatives, external events, 

and regulatory and legislative frameworks. Data 

is often aggregated for reporting purposes, which 

can obscure the relationships between data elements and obscure and mislead reviewers regarding causality. This is one of the main reasons that 

organizations upgrade their data analytics skills 

and resources to allow for adequate disaggregation 

of data and analytical (rather than merely intuitive) discovery of causal relationships.

The Commission addresses legal non-compliance 

primarily through its annual compliance processes, beginning with the statutorily-mandated 

ACD, due at the end of March. In preparing the 

ACD, the Commission issues a series of questions 

(Chairman’s Information Requests or Commission Information Requests) to the Postal Service, 

which then answers the questions with varying 

levels of precision and responsiveness, leading 

to more questions from the Commission, and so 

forth. The Commission may then issue directives 

to correct the non-compliance identified through 

Postal Service reports and its responses to Commission questioning.

The Commission is presently utilizing a similar 

analytical approach and back and forth question and answer process to address the present 

service problems highlighted in Congressional 

hearings earlier this year. Thus, service problems 

dating from November 2020 through February 

2021, and highlighted in Congressional hearings in February and March of 2021, might be 

addressed in the March 2022 ACD. Under this approach, the Commission may propose remedies in 

the March 2022 ACD for implementation over the 

following year and post implementation review 

into 2023. For these recent service problems and 

the flats issues identified above, data can help to 

accelerate the regulatory cycle by identifying root 

causes earlier and making the concerns visible 

for stakeholders at an earlier stage. A regulatory 

cycle that encompasses collecting, analyzing, and 

visualizing data in a timely fashion can improve 

the effectiveness of postal regulation and oversight by policymakers.

More strategic and in-depth use of data can help 

the Commission to target its regulation meaningfully and satisfy the twin planks of its mission: 

accountability and transparency.

ACCOUNTABILITY

Better use of data analytics can help the 

Commission:

• Target remedies and compliance directives. 

• Track the impact of Commission regulatory 

directives, Postal Service actions, and public 

policy, and the relationships between them.

• Pose more probative and insightful 

questions as part of the regulatory process, 

and assist with well-targeted oversight 

and enforcement mechanisms, as well as 

accurate and timely analyses.
16 | POSTAL REGULATORY COMMISSION 

• Launch and execute special studies of 

economic, financial, and statistical issues 

which would allow the Commission to 

better respond to the fast-changing 

dynamics of the postal system and 

gather insights to move through major 

rulemakings in an expeditious manner. 

TRANSPARENCY

Better use of data analytics can help the 

Commission:

• Make its work and information on the Postal 

Service more accessible for policymakers 

and stakeholders, who can in turn provide 

better informed and more targeted 

complaints and inputs to the Commission.

• Uncover problems in the postal system and 

ascertain their root causes.

In addition, analytics can help the Commission 

with internal decision-making, allowing it to 

target its limited resources toward areas where it 

can be the most productive and efficient. 

MAJOR REPORTS

The Commission’s core regulatory oversight 

includes the issuance of statutorily-mandated 

reports to review and assess the Postal Service’s 

compliance with pricing and service standards. 

The Commission’s primary regulatory document 

is the ACD. Work on the ACD requires nearly three 

months of extensive analysis with nearly all staff 

from the Commission’s OAC and OGC performing critical work on the report. The resulting ACD 

makes key findings of Postal Service compliance 

or non-compliance and issues directives requiring future Postal Service action. The ACD is an 

important tool for enhancing transparency and 

determining whether the Postal Service complies 

with statutory pricing and service requirements. 

With the FY 2022 request, the Commission intends to continue its robust and detailed technical 

and legal analysis of the Postal Service’s compliance with the law and the Commission’s regulations in its ACD.

The Commission also provides in-depth analysis 

of the Postal Service’s financial health in its Analysis of United States Postal Service Financial Results 

and 10-K Statements. This extensive financial 

report provides a detailed review of the Postal 

Service’s financial health. The FY 2022 funding 

request continues funding for the expert technical 

and legal staff who perform this vital analysis. 

Two other statutorily-mandated reports include: 

Analysis of the Postal Service’s Program Performance Report and Performance Plan, evaluating 

whether the Postal Service met its performance 

goals as required under 39 U.S.C. § 3653(d), and 

its Annual Report to the President and Congress,

analyzing the extent to which the Commission’s 

regulations are achieving the objectives under 

39 U.S.C. § 3622. These reports require detailed 

expert analysis by the Commission’s technical and 

legal staff, and the FY 2022 funding request will 

be used to support those staff.

RATE AND PRICING COMPLIANCE

The Commission provides timely, thorough, and 

independent analysis and review of the Postal 

Service’s planned changes to rates for both 

Market Dominant and Competitive products. 

These reviews are a fundamental component 

of the Commission’s mission. Market Dominant 

and Competitive rate reviews have continued 

to increase in complexity and contention over 

time, with major planned rate changes requiring frequent information requests on behalf of 

the Commission seeking additional information 

from the Postal Service, and involving numerous commenters raising issues for consideration. 

These time-sensitive reviews result in significant 

written orders published by the Commission. The 

Commission’s funding request for FY 2022 directly supports the staff who conduct these critical 

reviews. 

The Commission’s compliance reviews include 

examination of specific contracts between individual mailers and the Postal Service. The Commission staff reviews these NSAs to ensure compliance with the law. The Commission reviews 

hundreds of these requests per year, and typically 
FY 2022 CONGRESSIONAL BUDGET JUSTIFICATION | 17

issues final orders within 15 days of Postal Service requests. The work relating to the Commission’s compliance review of NSAs grows with the 

expansion of these offerings by the Postal Service 

and the Commission must have the resources to 

appropriately scale its staff to meet this demand. 

Rulemakings

The Commission has a substantial regulatory 

agenda that consists of both long and short-term 

actions. In FY 2021, the Commission issued its 

statutory review of the system for regulating 

Market Dominant rates and classifications. The 

Commission will continue to implement these 

regulations in FY 2022. In addition, the Commission is reviewing regulations related to the letter monopoly and numerous procedural rules, 

including an overhaul and reorganization of its 

rules regarding participation in Commission proceedings, Freedom of Information Act regulations, 

and procedures related to Commission views on 

international mail matters. 

REVISED SYSTEM OF MARKET DOMINANT 

RATEMAKING AND CLASSIFICATION

In FY 2021, the Commission completed an extensive rulemaking process that evaluated the 

system of ratemaking established by the PAEA 

and is implementing modifications to the system. 

This rulemaking involved qualitative and quantitative analysis of the ratemaking system and 

postal operations and also required consideration 

of hundreds of substantive comments. Work on 

this proceeding will continue into FY 2022 with 

work to implement modifications to the system of 

ratemaking for Market Dominant products. 

APPROPRIATE SHARE OF INSTITUTIONAL 

COSTS

The PAEA requires the Commission’s regulations 

“ensure that all competitive products collectively 

cover what the Commission determines to be 

an appropriate share of the institutional costs 

of the Postal Service.” 39 U.S.C. § 3633(a)(3). All 

postal costs are classified as either attributable 

or institutional. The “appropriate share” is the 

minimum amount that Competitive products as a 

whole are required to contribute to institutional 

costs annually. The PAEA directs the Commission 

to revisit the appropriate share requirement for 

Competitive products every five years to determine whether to retain it in its current form, 

modify it, or eliminate it. The Commission conducted reviews in FY 2012 and FY 2017 and the 

next review will be in FY 2022. This statutorilymandated review requires significant Commission resources and functions as an essential check 

on the Postal Service to ensure that Competitive 

products are not being subsidized by Market 

Dominant products and is the subject of great 

interest from stakeholders. The issues involving 

institutional costs of the Postal Service have increased in contention and complexity over recent 

years and have resulted in litigation. 

LETTER MONOPOLY

The Commission initiated a rulemaking related 

to the letter monopoly in FY 2020 by issuing an 

Advance Notice of Proposed Rulemaking. This 

rulemaking sought public input about what regulations the Commission may promulgate to carry 

out certain statutory responsibilities related to 

the letter monopoly. These regulations would apply to those instances where the letter monopoly 

does not apply to a mailpiece. The Commission is 

conducting a review of comments received in this 

proceeding and is in the process of determining 

the next course of action.

LITIGATION

Over the past several years, the Commission has 

faced an increase in challenges to its rulemaking 

decisions, due in part to a rapidly changing—and 

increasingly competitive—postal environment. 

Challenges to Commission decisions, by the Postal 

Service, its competitors, and affected members of 

the public, have caused additional strain on the 

Commission’s resources. See USPS v. Postal Regulatory Commission, D.C. Cir. No. 16-1412 (April 

6, 2018); USPS v. Postal Regulatory Commission, 

D.C. Cir. No. 16-1284 (April 6, 2018); UPS v. Postal 

Regulatory Commission, No. 16-1354 (May 22, 

2018); USPS v. Postal Regulatory Commission, D.C. 

Cir. No. 18-1059 (remand issued May 30, 2018); 
18 | POSTAL REGULATORY COMMISSION 

Ehrlich v. Postal Regulatory Commission, D.C. Cir. 

No. 19-1004 (December 10, 2019); USPS v. Postal 

Regulatory Commission, D.C. Cir. No. 19-1155 

(June 30, 2020); Lopez v. Postal Regulatory Commission, S.D. Fla., No. 18-22321-CIV (November 

19, 2019); USPS v. Postal Regulatory Commission, 

D.C. Cir. No. 20-1208 (pending); and UPS v. Postal 

Regulatory Commission, D.C. Cir. No. 19-1026 

(April 14, 2020). 

Other Matters and Research

In addition to the core regulatory oversight provided by the Commission related to compliance, 

the Commission is statutorily required to handle 

a wide range of other postal issues that differ in 

scope and complexity. These tasks include adjudicating complaints; providing advisory opinions 

on any planned substantially-nationwide change 

in postal services; adjudicating post office closing 

appeals; advising on international postal issues; 

and conducting public inquiry proceedings. These 

tasks are generally unpredictable, and therefore 

the Commission must always be ready to shift its 

limited resources to fulfill its responsibilities. 

The Commission’s expert staff also have critically important research projects that provide 

additional information and further engage postal 

stakeholders. These projects include: defining 

the USO; exploring issues related to the Postal 

Service’s monopoly power and competition; promoting greater transparency and accountability 

regarding international pricing; and conducting 

reviews of Postal Service costs, efficiency, and 

service performance data.

OTHER STATUTORY REQUIRED TASKS

In addition to its reporting and rate review responsibilities, the Commission is charged with 

hearing matters including complaints, post office closing appeals, and international issues. In 

certain matters, the Commission functions as an 

adjudicatory body; parties can file matters (such 

as complaints) with the Commission relating to 

the Postal Service’s compliance with Title 39. This 

work can be unpredictable and often strains the 

Commission’s resources by creating an increased 

workload without increased funding. The number of docketed cases before the Commission 

continues to increase each year and these cases 

are becoming more complex, particularly those 

related to rates, new products, service changes, 

and competition. 

When the Postal Service proposes nationwide 

changes to service—such as changes to operating 

hours, delivery service, or processing infrastructure—the Commission is required to provide 

advisory opinions, which historically have been 

highly-complex cases, to evaluate these changes. 

The filing of these cases is unpredictable, and the 

Commission must remain prepared to quickly 

reallocate its resources when a case is filed. This 

type of case highlights the Commission’s need to 

maintain sufficient staff and resources. Adequate 

staffing and resources must be available to ensure 

a complete record is developed for the Commission to issue its advisory opinion.

Additionally, as the Postal Service innovates and 

proposes new products, services, and NSAs to 

generate additional revenue, the Commission 

must review these proposals to ensure a predictable, transparent, and effective system of rate and 

product regulation that complies with the law. 

The timing and volume of these cases are also 

unpredictable, so the Commission must be at the 

ready. It is imperative that the Commission has 

the necessary resources to fulfill its statutory and 

regulatory obligations.

ADDITIONAL PROJECTS AND RESEARCH 

AREAS

With the FY 2022 funding request, the Commission intends to add expert staff, and invest in 

resources, to address numerous unfunded projects. These projects examining the USO, exploring 

issues surrounding monopoly powers and fair 

competition, providing additional international 

regulatory oversight, and conducting reviews of 

Postal Service cost, efficiency and service performance data. These are all long-term projects that 

must be balanced with the Commission’s core 

regulatory oversight. With the funding request 

of $19,585,000, the Commission will be able to 

begin these long-term initiatives. 
FY 2022 CONGRESSIONAL BUDGET JUSTIFICATION | 19

In the ever-changing postal sector, there are constant questions surrounding the Postal Service’s 

USO, monopoly power, and competition. One 

pressing question is how to define and determine 

the costs of the USO. To explore these questions, 

it is necessary for the Commission to proceed 

with a variety of important dockets and engage 

with postal stakeholders and the public. The USO 

inquiry is a vital project that the Commission has 

not had the resources to adequately explore. With 

appropriate funding, the Commission could also 

explore issues related to the Postal Service’s monopoly powers and ensure fair competition.

The Commission serves an important statutory 

role in making recommendations to the Secretary of State about U.S. Government positions at 

the Universal Postal Union (UPU), particularly 

in promoting greater transparency and accountability regarding international pricing. While the 

Commission has been effective in its oversight of 

international mail, additional funds are needed to 

develop and train staff in this highly-specialized 

area.

In addition, the Commission has experienced a 

significant increase in workload related to its 

regulatory oversight of international mail. Early 

in FY 2019, the Commission and the Postal Service were directed to implement self-declared 

rates charged to foreign posts. This will require 

new in-depth analysis by the Commission of 

proposals concerning rates for letters, flats, and 

other Market Dominant products. As a result, this 

process will likely involve a host of new issues 

and questions that will require significant staff 

and IT resources to complete. The international 

mail issues present the Commission with new 

and substantial work.

Funding is also necessary for the Commission to 

conduct further studies related to Postal Service 

costs, efficiency, and service performance. This 

additional workload will demand specialized 

analysis by the Commission, involve extensive 

public participation, and require a significant 

share of the Commission’s already strained resources. 

Finally, the Commission expects to adjudicate an 

increasing number of issues relating to the impact of COVID-19 on Postal Service operations. 

As mentioned above, the Postal Service recently 

released a 10-year plan, which includes significant operational and service changes that the 

Commission will be required to review. Moreover, the initiatives previously undertaken by the 

Postal Service are a large part of Commission’s 

current compliance review agenda. The Commission provides transparency for Congress, the 

Administration, stakeholders, and the public on 

these issues. Already, the Commission has reviewed and approved a pricing promotion for 

small business mailers to help increase mail from 

small businesses during the COVID-19 pandemic. 

In addition, the Commission recently approved 

a proposed temporary price increase for select 

competitive mail products. In preparation for 

the recently announced significant operational 

and service changes, it is necessary for the Commission to invest in improved data analytics to 

evaluate the impact of the COVID-19 pandemic on 

Postal Service operations and service. 

Strategic Goal 2 - Public Access And Participation

The FY 2022 request allocates $4.316 million for 

Strategic Goal 2, Public Access & Participation. 

Strategic Goal 2 focuses on active engagement 

with Congress and stakeholders in support of a 

dynamic postal system. The Commission’s approach to this goal requires that it clearly communicate complex analyses and decisions to address 

the needs of diverse stakeholders. All Commission offices participate in the communication of 

the Commission’s analyses and decisions. However, the Commission’s small staff within its Office 

of Public Affairs and Government Affairs (PAGR) 

(3 FTEs) is essential in meeting this goal. In FY 

2022, the Commission expects to prioritize its 

active engagement regarding the postal system as 

the Postal Service faces complex and contentious 

operational and financial problems. The Commission also anticipates many new challenges as the 
20 | POSTAL REGULATORY COMMISSION 

President, Congress, the Postal Service, and interested stakeholders continue to explore the legal 

boundaries of the PAEA and adjust to the evolving 

operational and financial threats facing the Postal 

Service. 

PAGR is a significant resource for the Commission 

in support of its outreach and engagement with 

diverse postal stakeholders. PAGR is responsible 

for public outreach and education; complaint 

processing; media relations; and is a liaison with 

Congress, the Administration, the Postal Service, and other government agencies. This office 

informs and advises commissioners and Commission staff on legislative issues and policies 

related to the Commission and the Postal Service, 

in addition to coordinating the preparation of 

both congressional testimony and responses to 

congressional inquiries concerning Commission 

policies and activities. 

The Commission’s strategy for focused engagement is multi-faceted. First, PAGR staff, with support from other Commission staff, are key to preparing information for a diverse group of postal 

stakeholders. Second, PAGR actively engages with 

the postal customers through a customer portal 

on the Commission website. Third, the Commission website serves as a tool to ensure transparent postal information is available to the public 

so that they can actively engage. Finally, for each 

docketed proceeding, the Commission assigns an 

expert staff member to serve as Public Representative and represent the views of the public. 

The Commission interacts with postal stakeholders in many ways. The Commission participates 

in hearings on postal regulatory related matters, 

including analysis and review of the Postal Service’s financial condition and the urgent need 

for reform legislation. PAGR, OGC, and OAC assist 

with briefings of Congressional committees and 

subcommittees as well as individual congressional 

offices, assist in preparing testimony for Congressional hearings, analyze proposed legislation 

affecting the agency, and respond to Congressional 

requests for agency documents. Commissioners 

and Commission staff are highly responsive to the 

needs of stakeholders. The Commission’s unique 

role can create impacts on foreign policy (through 

the required submission of Views on international 

postal topics to the Department of State) as well 

as the evaluation of postal policy by Congress. 

In addition to engagement with postal stakeholders, PAGR is the office primarily responsible for 

assisting the general public and its small threeperson team operates effectively and efficiently. 

During FY 2020, PAGR received approximately 

6,400 questions, suggestions, comments, and 

inquiries through the online “Contact PRC” portal on the Commission’s website, by phone, fax, 

email, and hardcopy mail. 

The www.prc.gov website is the Commission’s 

primary communication tool and the main outlet 

for public outreach and engagement. The website provides access to the Commission’s docket 

systems, which allows interested parties to file 

matters, documents, public and non-public data 

with the Commission. In FY 2022, the Commission intends to undertake an update of its website 

in order to expand usability for the public and 

stakeholders. With increased funding, the Commission will enhance its website to include more 

data analytics and transparency to serve as a 

resource for the postal community.

Another important feature in the Commission’s 

engagement with the public and stakeholders is 

its Public Representative program. The Commission is required to appoint a professional staff 

member to serve as an officer of the Commission 

in each docketed proceeding to represent the interests of the general public. This officer, the Public Representative, operates independently from 

the Commission and must adhere to ex parte 

rules regarding the docket with Commission staff 

assigned to the docket. This program is a unique 

resource challenge faced by the Commission. The 

Commission is the only executive branch agency 

with this requirement. This requirement means 

that one or more staff member(s) must be assigned as PR in every docket before the Commission, who, consequently, will not be available to 

assist the Commission in reviewing, analyzing, 

and making determinations for that case.
FY 2022 CONGRESSIONAL BUDGET JUSTIFICATION | 21

Strategic Goal 3: Integration And Support

The FY 2022 request allocates $3.597 million for 

Strategic Goal 3, Integration and Support. Strategic 

Goal 3 focuses on providing an optimal internal 

infrastructure—IT, administrative, and physical—

to support management of priorities, workload, 

and emerging requirements. The Commission 

is able to fulfill its mission and provide effective 

oversight of the Postal Service when it operates in 

an efficient, responsive, and transparent matter. 

The Commission achieves this operational state by 

maintaining processes and providing high-quality 

analysis, review, and reporting in accordance 

with governing statutes, authoritative guidance, 

and best practices. In accomplishing this state of 

operations, the Commission will use its resources 

efficiently to support its priorities and staff. 

IT INFRASTRUCTURE

The Commission’s IT infrastructure and equipment needs have been deferred in previous fiscal 

years due to budget constraints. The Commission’s focus for FY 2022 will be to repair and 

rebuild its support infrastructure to manage and 

advance system capability, requirements, and 

security. Funding for this goal aligns the Commission with the federal goal to build and maintain 

more modern, secure, and resilient IT in order to 

enhance mission delivery and productivity. The 

Commission will continue to prioritize resource 

allocations to the most critical infrastructure 

requirements and make prudent investments in 

relation to specific challenges. 

STATE OF THE COMMISSION’S IT 

OPERATIONS

The Commission has made great strides in improving its IT security posture over the past year, 

resolving its longstanding “At Risk” designation 

by the Department of Homeland Security and receiving its first “Managing Risk” designation. The 

impact of COVID-19 has heightened the importance of addressing the Commission’s IT security 

requirements with its reliance on remote work 

and electronic systems to perform its mission. At 

the beginning of the pandemic, the Commission 

was able to successfully transition 100 percent 

of its workforce to remote work. However, at that 

time, staff were working on personal devices, as 

the Commission did not have the funds to procure 

government furnished equipment for remote 

work. 

In order to address those concerns, the Commission dedicated significant funds in FY 2020 

to onboarding its first Cybersecurity Manager in 

order to create a cybersecurity program for the 

agency and procured secure government laptops 

to increase its security posture and efficiency of 

operations. The Commission completed its first 

Security Assessment and Authorization in March 

2021 and has entered the vulnerability remediation phase, which will continue into FY 2022 

and require additional dedication of funds. In 

addition, the Commission’s compliance with the 

Executive Order on Improving the Nation’s Cybersecurity, issued on May 12, 2021, will require 

significant investment of funds and resources 

by the Commission’s small IT team to ensure the 

Commission is protected from malicious cyber 

actors. In FY 2022, the Commission will continue to address serious existing IT cybersecurity 

concerns. The impact of COVID-19 has heightened 

the importance of addressing the Commission’s 

IT security requirements with its reliance on 

remote work and electronic systems to perform 

its mission. 

DOCKETING SYSTEM

The Commission’s docketing system is the repository for the majority of Commission documents 

and serves as the case management system for 

all matters filed before the Commission. The 

Commission’s docket system functions similar to 

that of a court’s docket, where the Postal Service 

and other parties file motions, pleadings, comments, and data for review and decision by the 

Commission. The Commission recognizes that 

data contained in its docketing system are a 

primary strategic asset, and values the openness 

and transparency that this system affords to the 

public. For a very small agency with a constrained 
22 | POSTAL REGULATORY COMMISSION 

budget, hosting a robust docketing system requires significant monetary resources and staff 

dedication.

The Commission docketing system is more than 

20 years old and the risk of an imminent, critical 

application failure is unacceptably high. The current system is outdated and uses an unsupported 

legacy application. The Commission intends to use 

its proposed FY 2022 funding to support the continued development of a new docketing system 

and has engaged contract support to manage and 

complete the development and implementation of 

the new system. The Commission, the Postal Service, stakeholders, and the public rely on the Commission’s docketing system to function efficiently 

and effectively. The Commission will protect this 

asset and ensure it is available to the public by 

replacing its aging docketing system, and enhancing its website to ensure compliance with the law. 

This includes conducting a network exfiltration, 

phishing, and penetration test as required by the 

Federal Information Security Modernization Act.

IT MODERNIZATION INITIATIVE

The Commission’s IT infrastructure modernization plan includes moving the IT services and applications to the cloud in FY 2021-2022. This will 

include implementing cloud-based office productivity software and moving continuity/disaster 

recovery systems to a secure cloud-based repository. In addition, the Commission will complete 

implementation of its selected solutions for the 

upcoming required telecommunication contract 

transition from Networx to Enterprise Infrastructure Solutions, and will finalize its implementation plan in FY 2021. An expected and necessary 

result of implementing these cloud-based solutions is the ongoing budgetary impact of annual 

licensing, service, and maintenance fees. The FY 

2022 budget request includes all necessary fees. 

The Commission’s IT modernization initiatives 

will be implemented by the Commission’s small 

IT staff. The FY 2021 IT staff consists of five FTEs 

and two contractors. The impact of the COVID-19 

has placed a strain on the Commission’s extremely limited IT resources.

Administrative Infrastructure 

Initiatives

The Commission’s OSA operates with a small 

complement of 13 FTEs, including its IT team, 

to handle all of the operational needs of the 

agency including financial management, human 

resources, IT, strategic planning, records management, privacy, administration of its docketing 

system, and reporting. The Commission’s strategy 

for meeting its infrastructure goals to support 

emerging requirements, priorities, and workload includes focusing on general administrative 

services. The Commission already sees significant 

cost savings through its use of shared services for 

a portion of its financial management and human 

resources systems. In FY 2022, the Commission 

intends to study the possibility of expanding 

shared services in other areas where inefficiencies or existing skills gaps exist, which could be 

remedied by a cost-effective shared-services 

provider.

In FY 2022, the Commission will be working 

on a new strategic plan to carry it through FY 

2023-2028. As part of this strategic planning, the 

Commission intends to engage in targeted human 

capital planning to ensure its workforce is aligned 

with the Commission’s mission. The Commission 

is focused on developing efficient and effective 

human resources processes and capabilities that 

enhance the workforce culture. This goal includes 

the Commission’s commitment to equal employment opportunity.

With respect to its facilities, the Commission 

operates from a single non-General Services 

Administration leased facility. Even though the 

Commission is increasing its staff, it does not 

contemplate any additional leases or space for FY 

2022. In FY 2022, the Commission’s lease expires 

and the Commission is currently working on various options to secure a new lease. The Commission is evaluating its physical office space usage 

and needs and expects to see a reduction in rent 

in FY 2022 as a result of this evaluation and lease 

negotiations. 
FY 2022 CONGRESSIONAL BUDGET JUSTIFICATION | 23

Strategic Goal 4: Workforce

1  Under the Inspector General Act of 1987 (Public Law 95-452; 5 U.S.C. App., as amended through Public Law 114-317), for each fiscal year, an Inspector 

General shall transmit a budget estimate and request to the head of the establishment or designated Federal entity to which the Inspector General 

reports. For FY 2022, the Inspector General has requested $642,000.

Strategic Goal 4, Workforce, is a cross-cutting 

strategic goal encompassed within the funding 

for Strategic Goals 1, 2, and 3 and is integral to 

the Commission’s mission. For FY 2022, the Commission requests $15.408 million to compensate 

its current staff, and increase staffing levels to 

82 FTEs. Strategic Goal 4 focuses on the recruitment, development, and retention of a diverse, 

high-performing workforce. Funding for this 

goal directly aligns with the goal of developing 

a workforce for the 21st Century. In alignment 

with these goals, the Commission will prioritize 

the recruitment, development, and retention of a 

diverse, high-performing workforce. 

As payroll is the Commission’s largest expenditure, and the discipline of postal regulation is a 

specialized knowledge area, the loss of staff is 

the biggest risk area for the Commission. In past 

fiscal years, the Commission has experienced 

routine, but significant, attrition of essential and 

expert staff that has threatened the ability to 

meet its mission. The Commission’s workforce 

goal for FY 2022 is to enhance its human capital 

planning and alignment, increase essential training and professional development, and improve 

recruitment strategies. This work will focus on retaining and restoring the Commission’s workforce 

by filling mission-critical positions, providing 

essential professional development and training 

to support the Commission’s work, and increasing 

staff efficiency and engagement through its merit 

pay system. 

Workforce Challenges

As the regulator of the Postal Service, the Commission employs expert technical and legal staff 

that possess a unique set of skills related to postal 

regulation. Not only does the Commission’s staff 

work to fulfill the Commission’s statutory obligations, but it must respond to the ever-changing 

needs of the Postal Service in a time where the 

Postal Service is facing many challenges and 

threats to its continued viability. The Commission 

operates as a lean organization. After accounting 

for Commissioners, their staff, and administrative 

support staff, the Commission has just 41 staff 

to perform the challenging analytical, technical, 

and legal work that is the core of the Commission’s regulatory responsibilities. In addition, 

and as mentioned previously, the Commission is 

required by law to appoint at least one professional staff member to represent the interests of 

the public in all docketed proceedings. Therefore, 

the Commission must field “two teams” for every 

case, further stretching resources. The Commission, by law, must also maintain an independent 

OIG, which is comprised of three staff at an estimated cost of $642,000 in FY 2022.1

The Commission’s low funding levels over the 

past few fiscal years have negatively affected the 

retention of staff and, if continued, will impede 

the Commission from carrying out its statutory 

and regulatory obligations. Despite past budget 

limitations, the Commission has been able to 

fulfill its mission. If the Commission is unable to 

improve retention and recruitment, the Commission’s ability to carry out its mission will be at 

risk. Since FY 2017, the Commission has lost over 

18 staff members, including 13 from its technical and legal offices (OAC and OGC). The large 

majority of staff attrition was related to austerity measures due to a limited budget over prior 

fiscal years. As described above, the work of OAC 

and OGC is essential to accomplish the goal of accountability and compliance of the Postal Service.

The Commission’s staff make up 80 percent of its 

budget expenditures. Insufficient Commission 

staffing has long been at odds with the Commission’s statutory requirements and increasing 

regulatory scope of work:
24 | POSTAL REGULATORY COMMISSION 

• Commission requested staff level of only 82 

FTEs must oversee the Postal Service, a $71 

billion enterprise. If funded at $19,585,000, 

this would represent only 0.03 percent of 

the Postal Service’s total FY 2019 revenue.

• The FY 2021 appropriation of $17,000,000 

was $2,200,000 less than the Commission’s 

FY 2021 request, and the Commission 

still needs to fill mission-essential staff 

positions. 

• As issues threatening the Postal Service 

have accelerated due to the impact of 

COVID-19, funding for the Commission 

necessary to meet this pace and demand is 

needed now more than ever.

Starting in FY 2021, the Commission will implement human capital mitigation strategies to 

account for potential loss of staff due to retirements, voluntary attrition, and other factors. The 

Commission faces workforce challenges relating to staff expertise, due to both the significant 

attrition issues and the freeze on training and 

development funds for staff. The issues facing the 

Postal Service are rapidly evolving and the Commission needs to expand its staff’s expertise and 

have the flexibility to align its workforce with 

these changes. Unfortunately, the Commission’s 

FY 2021 appropriation was not sufficient to begin 

filling these mission critical roles. Therefore, an 

appropriation of $19,585,000 in FY 2022 is even 

more urgent. With this appropriation the Commission can focus on recruiting, retaining, and 

training expert staff. Through targeted recruitment, internal and external training, the Commission will rebuild and grow its workforce to meet 

the demands necessary to support the Commission’s mission. 

The Commission will continue to employ its 

streamlined performance management system 

that applies a merit pay process to closely link 

staff pay and performance. This policy has established procedures for planning, assessing, rating, 

rewarding, and developing individual staff performance. It is the means by which the Commission measures and recognizes staff performance 

and accomplishments. This policy works handin-hand with the Commission’s compensation 

policy to ensure that pay and performance are 

also aligned with the budget, which ensures the 

sustainability over time for the merit pay process and creates a high-performance culture. For 

staff development, the Commission will create an 

agency-wide training plan by working with staff 

and management to determine training needs 

and will continue to utilize Individual Development Plans for staff. With respect to retention, 

the Commission will retain its re-instated student 

loan repayment program and telework program.
FY 2022 CONGRESSIONAL BUDGET JUSTIFICATION | 25

Postal Regulatory Commission 

Salaries and Expenses

(including transfer of funds)

For necessary expenses of the Postal Regulatory Commission in carrying out the provisions of the 

Postal Accountability and Enhancement Act (Public Law 109‐435), $19,585,000,1 to be derived by 

transfer from the Postal Service Fund and expended as authorized by section 603(a) of such Act.

1  Pursuant to 39 U.S.C. § 2009, “The President shall include [the Commission’s appropriation request], with his recommendations but without revision, 

in the budget transmitted to Congress under section 1105 of title 31.”

Proposed Appropriations Language
26 | This page has intentionally been left blank.
FY 2022 CONGRESSIONAL BUDGET JUSTIFICATION | 27

Office of the Inspector General Resources

The Commission's OIG was established in June 

2007 as required by an amendment to the Inspector General Act of 1978 included in the PAEA. 

The Commission’s Inspector General has a dual 

reporting responsibility to both commissioners 

and Congress.

The role of the OIG is to detect and deter fraud, 

waste, abuse, and mismanagement within Commission programs, as well as to promote efficient 

and effective use of Commission resources. To 

accomplish this, the OIG conducts, supervises, 

and coordinates independent audits, inspections, 

evaluations, and other reviews in accordance 

with applicable law. The OIG communicates the 

results of these assessments to commissioners, 

Commission management, Congress, other oversight entities as appropriate, and to the public. 

Generally, the OIG communicates these results in 

formal reports that contain findings and recommendations aimed at correcting any deficiencies 

identified and at promoting efficiency and effectiveness in Commission programs and operations.

The OIG maintains a hotline to allow staff and 

the public to anonymously report allegations of 

fraud, waste, abuse, and mismanagement.

The Inspector General requests $642,000 for the 

office’s personnel, travel, rent, and training costs 

as well as the Commission contribution to the 

Council of Inspectors General on Integrity and 

Efficiency. 
28 | This page has intentionally been left blank.
FY 2022 PERFORMANCE BUDGET SUBMISSION | 29

APPENDIX A — Technical Budget Tables

Table 2: Budget Program Information

Program

FY 2020

Actual

FY 2021

PRC

Appropriation

FY 2022

PRC

Request

000 FTE 000 FTE 000 FTE

Postal Service 

Accountability $9,035 37 $9,461 41 $11,030 46

Public Access & 

Participation $4,151 17 $3,923 17 $4,316 18

Integration and 

Support $,2930 12 $3,000 13 $3,597 15

*Office of the 

General $498 3 $617 3 $642 3

Total Obligations $16,615 69 $17,000 74 $19,585 82

(*) This is the full amount requested by the Inspector General to fund OIG 

personnel, travel, rent, and training. 

Table 1: Obligation by Object Classification ($000)

Object Classification

FY 2020 

Actual 

Expenses 

(69 FTEs)

FY 2021 

Approriations

(74 FTEs)

FY 2022 

Requirement

(82 FTEs)

Personnel compensation and 

benefits 12,937 13,558 15,408

Rental payments to others 2,213 2,184 2,229

Services and supplies:

Information technology 334 259 265

Contracting services 315 372 379

Consulting services 325 0 597

Communications 260 181 185

Other services and supplies 231 446 522

Services and supplies subtotal 1,465 1,258 1,948

Total Obligations 16,615 17,000 19,585 
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FY 2022 PERFORMANCE BUDGET SUBMISSION | 31

Mission Statement

Ensure transparency and accountability of the United 

States Postal Service and foster a vital and efficient 

universal mail system

Vision Statement

To be an independent regulator respected for effectively engaging postal stakeholders to promote a 

robust universal mail system through objective, accurate, and timely regulatory analyses and decisions.

We will look to achieve our vision by:

• Taking a multi-disciplinary and integrated 

approach to work

• Monitoring the environment and anticipating 

changes to enhance agility

• Utilizing rigorous evaluative methods

• Optimizing stakeholder engagement through 

an appropriate and clearly-defined public 

involvement process

• Developing staff expertise to ensure that the 

Commission is a center for excellence in postal 

regulatory matters

• Ensuring that the Commission is an employer of 

choice

• Ensuring efficient stewardship of resources

APPENDIX B — Mission, Guiding Principles, 

 and Vision

Guiding Principles

The Commission is committed to and 

operates by the principles of:

Openness

Public participation

Integrity

Fairness and impartiality

Timely and rigorous analysis

Merit

Commitment to excellence

Collegiality and multi-disciplinary

approaches

Adaptability

Proactive response to the rapidly

changing postal environment
32 | This page has intentionally been left blank.
FY 2022 CONGRESSIONAL BUDGET JUSTIFICATION | 33

Postal Service Accountability

Strategic Goal 1: Deliver Accurate 

And Objective Analyses And 

Decisions To Ensure Transparency 

And Accountability Of The Postal 

Service.

• Strategic Objective 1.1. Thoroughly and 

accurately analyze and apply statutes, 

regulations, and Commission precedent.

• Strategic Objective 1.2. Ensure 

transparent, accurate, and informative 

Postal Service reporting for evaluation 

of lawful compliance of rates and service 

performance.

• Strategic Objective 1.3. Responsibly, 

transparently, and efficiently lead the 

review of the existing statutory system 

for regulating rates and classes for Market 

Dominant products, as well as consider, and, 

if necessary, implement modifications or an 

alternative system. 

FY 2022 WORK PLAN STRATEGIES

• Analyze, develop, and implement public 

policy as it relates to postal matters.

• Execute a visible and effective advisory role 

with regard to measureable and dynamic 

Postal Service and mail delivery service 

performance.

• Consult on, revise, and augment 

performance standards and goals for 

Market Dominant products.

• Assess and refine the rules, regulations, 

and systems established for publication of 

relevant Postal Service data.

• Prepare analytical framework.

FY 2022 WORK PLAN

• Review and evaluate Postal Service 

financial data.

• Enforce compliance determinations.

• Review and evaluate Postal Service 

international data and proposals for the 

UPU.

Public Access and Participation

Strategic Goal 2: Actively Engage 

With Congress And Stakeholders 

In Support Of A Dynamic Postal 

System.

• Strategic Objective 2.1. Continue to 

strengthen proactive and responsive 

communication to foster a collaborative 

relationship with Congress.

• Strategic Objective 2.2. Foster 

constructive communications with 

the Postal Service and stakeholders to 

streamline the regulatory process. 

• Strategic Objective 2.3. Clearly 

communicate complex analyses and 

decisions to address the needs of diverse 

stakeholders. 

APPENDIX C — Strategic Goals, Workplans, and

 Performance Objectives
34 | POSTAL REGULATORY COMMISSION 

FY 2022 WORK PLAN STRATEGIES

• Effectively communicate the outcome of 

Commission work to Congress in a timely 

fashion.

• Update the strategic communication plan to 

facilitate targeted congressional outreach.

• Participate in hearings on postal regulatory 

related matters.

• Facilitate efficient and effective Commission 

regulatory process and clearly articulate 

Commission expectations and timelines.

• Strengthen open communications with 

stakeholders.

FY 2022 WORK PLAN 

• Maintain and update comprehensive 

strategy for outreach to the public and 

media. Implement consistent messaging, 

updating, and branding for public 

documents and the Commission’s website.

• Continue to enhance government 

relations through proactive outreach and 

relationship building with Congress and the 

Executive Branch, and Federal, state, and 

local governments. 

• Maintain a timely system to track, analyze, 

and respond to public and consumer 

inquiries and correspondence, including 

“informal complaints.”

• Identify legislative and public affairs 

priorities. Develop Commission Annual 

Report. 

Integration and Support

Strategic Goal 3: Provide An 

Optimal Internal Infrastructure 

To Support Management Of 

Priorities, Workload, And 

Emerging Requirements.

• Strategic Objective 3.1. Optimize support 

infrastructure to manage and advance 

system capability, requirements, and 

security.

• Strategic Objective 3.2. Prioritize and 

manage workload to increase capacity and 

agility. 

• Strategic Objective 3.3. Collaboratively 

work across functions to maintain open 

internal communication and address 

emerging requirements. 

Strategic Goal 4: Recruit, Develop, 

And Retain A Diverse, HighPerforming Workforce.

• Strategic Objective 4.1. Exercise 

Commission flexibilities to attract 

and retain a diverse, high-performing 

workforce.

• Strategic Objective 4.2. Maintain fair and 

impartial human capital management. 

• Strategic Objective 4.3. Continue to 

enhance the Commission’s commitment to 

being an employer of choice.

FY 2022 WORK PLAN STRATEGIES FOR 

STRATEGIC GOALS 3 AND 4

• Optimize IT capabilities.

• Strengthen and modernize the records 

management program.

• Streamline and standardize procurement 

policies and processes.
FY 2022 CONGRESSIONAL BUDGET JUSTIFICATION | 35

• Maintain ongoing communication of 

priorities among commissioners and senior 

staff.

• Collaborate to develop and effectively 

communicate administrative guidance and 

investment priorities.

• Attract and hire qualified and diverse 

candidates consistent with Federal laws.

• Strengthen relationships with affinity 

groups to ensure diverse outreach efforts.

• Maintain a Human Capital Plan.

• Maintain the Commission’s strong 

commitment to equal employment 

opportunity.

• Involve employees and participants as 

agents of diversity, inclusion, and mutual 

respect.

• Continue refining administrative and 

Human Resource analytics to inform 

decision-making.

FY 2022 WORK PLAN FOR STRATEGIC 

GOALS 3 AND 4

• Develop and maintain the Commission’s 

annual budget and fiscal processes based on 

Administration guidance. 

• Assess all IT security policies, practices, 

and enforcement procedures to ensure 

functionality and security of electronic 

communication systems such as website, 

dockets, Local Area Network, webcasts, 

email, Voice-Over-Internet Protocol 

telephony, etc. 

• Execute FY 2022 IT project plan.

• Ensure that Commission records are 

properly maintained in accordance with 

policies and procedures. 

• Continue to improve the records 

management program at the Commission. 

Review and modify, as necessary, records 

schedules and policies to meet records 

management directives and to simplify 

Commission workflow processes. 

Implement necessary technology to 

maintain a modern records management 

system, including management of all 

electronic records.

• Ensure the website—both internal and 

external—is current, accessible, and useful 

to stakeholders.

• Continue to maintain financial controls to 

ensure adequate fiscal responsibility.

• Ensure equipment and facilities are 

sufficient, safe, and secure.

• Enforce up-to-date IT security 

requirements.
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