Financial Analysis of 

United States Postal Service 

Financial Results and 10-K Statement

Fiscal Year 2020 

Revised—November 4, 2021
1 

Table of Contents 

Chapter I. Overview .............................................................................................................................. 3 

Purpose of This Report ......................................................................................................................... 3 

Chapter II. Postal Service Financial Status ................................................................................... 8 

Introduction .............................................................................................................................................. 8 

Analysis of Income Statements .......................................................................................................... 9 

Market Dominant Revenue Compared to Prior Year ............................................... 11 

Competitive Product Revenue Compared to Prior Year......................................... 13 

Expense Analysis as Compared to Prior Year ............................................................. 14 

Personnel Expenses .............................................................................................................. 15 

Non-Personnel Expenses .................................................................................................... 22 

Comparison of Postal Service Actual Results to Operating Plan ......................... 23 

Financial Ratio Analysis ...................................................................................................... 27 

OPERATING RATIO ................................................................................................. 27 

RETURN ON ASSETS .............................................................................................. 28 

Analysis of Balance Sheets ............................................................................................................... 30 

Assets...... ................................................................................................................................... 33 

Liabilities .................................................................................................................................. 34 

Balance Sheet Trend Analysis ........................................................................................... 35 

DEBT RATIO .............................................................................................................. 35 

CURRENT RATIO ..................................................................................................... 37 

CASH RATIO .............................................................................................................. 38 

Analysis of Statements of Cash Flows............................................................................ 39 

CASH FLOW RATIO ANALYSIS ........................................................................... 40 

Chapter III. Volume, Revenue, and Cost Trends ....................................................................... 43 

Overview ................................................................................................................................................. 43 

Overall Volume, Revenue, and Cost Trends ............................................................................... 43 

Attributable and Institutional Cost Calculation ......................................................... 43 

Methodological Changes ..................................................................................................... 44 

Market Dominant Products and Services ..................................................................... 44 

Market Dominant Volume Trends .................................................................................. 46 

Market Dominant Revenue and Cost Trends .............................................................. 47 
2 

Competitive Products and Services ................................................................................ 48 

Market Dominant Volume, Revenue, and Cost Trends by Class ........................................ 51 

First-Class Mail ....................................................................................................................... 51 

FIRST-CLASS MAIL LETTERS COMPARED WITH FY 2019.................. 51 

TRENDS IN FIRST-CLASS MAIL LETTERS .................................................. 53 

TRENDS IN FIRST-CLASS MAIL FLATS ....................................................... 56 

OTHER FIRST-CLASS MAIL COMPARED WITH FY 2019 ...................... 59 

USPS Marketing Mail ............................................................................................................ 60 

USPS MARKETING MAIL LETTERS COMPARED WITH FY 2019 ....... 60 

TRENDS IN USPS MARKETING MAIL LETTERS ....................................... 61 

USPS MARKETING MAIL FLATS COMPARED WITH FY 2019 ............ 63 

TRENDS IN USPS MARKETING MAIL FLATS ............................................ 64 

Periodicals ................................................................................................................................ 67 

PERIODICALS COMPARED WITH FY 2019 ................................................ 67 

TRENDS IN PERIODICALS ................................................................................ 68 

Package Services .................................................................................................................... 71 

Market Dominant Special Services ................................................................................. 73 

Competitive Volume, Revenue, and Cost by Product ............................................................. 75 

Trends in Competitive Products ...................................................................................... 77 

Chapter IV. Cost and Profit Analysis ............................................................................................. 80 

Introduction ........................................................................................................................................... 80 

Contribution Margin Income Statement ..................................................................................... 80 

Analysis of Cost Segments .................................................................................................. 87 

Analysis of Employee Labor Cost .................................................................................... 88 

COVID-19 IMPACT ON LABOR COST ............................................................ 93 

Appendix A FY 2020 Volume, Revenue, Incremental Cost, and Cost Coverage by Class, 

Current Classification (Products) .................................................................................................. 99 

Appendix B Total Factor Productivity ...................................................................................... 100 
3 

Chapter I. Overview 

Purpose of This Report 

This report provides an in-depth analysis of the Postal Service’s financial performance 

primarily using information reported in its FY 2020 Form 10-K measured against FY 2019 

and its FY 2020 Integrated Financial Plan (Financial Plan).1 Additionally, data filed with the 

FY 2020 Annual Compliance Report (ACR), such as the Cost and Revenue Analysis report 

(CRA), the Cost Segments and Components (CSC) report, and the Revenue, Pieces, and 

Weight (RPW) report, are utilized in developing this report. 

Four chapters comprise this year’s report. Chapter 1 provides a summary of the 

Commission’s findings. The first section presents highlights from the remaining chapters. 

The second section presents a high-level view of the Postal Service’s Income Statement and 

Balance Sheet. 

Chapter 2 analyzes the Postal Service’s overall financial status, with a focus on key figures 

in the Income Statement, Balance Sheet, and Cash Flow Statement. The Commission 

evaluates relationships between the essential components of the Postal Service’s financial 

statements to understand the Postal Service’s profitability, stability, and long-term 

viability. 

Chapter 3 describes the calculation of attributable and institutional cost and examines the 

overall trends for Market Dominant and Competitive products and services. It includes 

comparisons of volume, revenue, and cost between FY 2019 and FY 2020, as well as trend 

analyses that highlight changes in volume, revenue, and cost that have occurred over time. 

Chapter 4 disaggregates broad categories of costs into segments categorized by function 

and includes a discussion of labor costs and workhours. The Commission also develops a 

contribution margin income statement that facilitates analysis of the relationships between 

revenue, attributable costs, institutional costs, and overall net income or loss. 

The Postal Service Remains Financially Unstable—

Key Findings

During FY 2020, the COVID-19 pandemic had a significant impact on Postal Service volume, 

revenue, and expenses. The COVID-19 pandemic exacerbated market dominant volume 

declines as many businesses that relied on mail were forced to close or reduce their 

 

1

 The Integrated Financial Plan is a Postal Service report that includes the operating plan, capital investment plan, and financing plan for the 

fiscal year. This document is required to be filed as a periodic report pursuant to the 39 C.F.R. § 3050. The plan for FY 2020 originally filed on 

February 13, 2020 and revised on March 9, 2020 did not include the effects of the pandemic. See 

https://www.prc.gov/dockets/document/112610. 
4 

operations, although package volumes increased due to a spike in e-commerce. The volume 

changes impacted overall revenues and costs, while changes in workforce hours in 

response to the pandemic-impacted labor costs. 

In FY 2020, the Postal Service recorded a net loss from operations of $3.6 billion,2 a $0.4 

billion decline in profitability. The increase in the FY 2020 net operating loss is the result of 

higher operating expenses which were $2.4 billion higher than in FY 2019.3 

When Non-operating Expenses (NOEs) are included,4 the net operating loss of $3.6 billion 

becomes a total net loss of $9.2 billion. This is a decline of $0.4 billion compared to FY 

2019. Figure I-1 shows net income (loss) and net operating income (loss) results for the 

period FY 2011 – FY 2020. 

Figure I-1 

Postal Service’s Financial Condition Has Declined in the Last Four Years 

Source: United States Postal Service, 2011 Report on Form 10-K [Erratum], November 16, 2011; United States Postal Service, 2012 Report on 

Form 10-K, November 15, 2012; United States Postal Service, 2013 Report on Form 10-K, January 31, 2014; United States Postal Service, 2014 

Report on Form 10-K, December 5, 2014; United States Postal Service, 2015 Report on Form 10-K, November 13, 2015; United States Postal 

Service, 2016 Report on Form 10-K, November 15, 2016; United States Postal Service, 2017 Report on Form 10-K, November 14, 2017; United 

States Postal Service, 2018 Report on Form 10-K, November 14, 2018 (Postal Service FY 2018 Form 10-K); United States Postal Service, 2019 

Report on Form 10-K, November 14, 2019 (Postal Service FY 2019 Form 10-K); Postal Service FY 2020 Form 10-K (collectively, Postal Service 

Form 10-K, FY 2011–FY 2020). 

 

2

 United States Postal Service, 2020 Report on Form 10-K, November 13, 2020 (Postal Service FY 2020 Form 10-K). Net income or loss from 

operations is also referred to as net operating income (loss). The Commission’s calculation of net operating income (loss) differs from the 

controllable net income (loss) reported in Postal Service Form 10-K by a negative $226 million and $151 million for FY 2019 and FY 2020, 

respectively. The Postal Service excludes the difference in the normal cost of Retiree Health Benefits from its controllable income (loss) because 

it is the result of actuarial changes. Postal Service FY 2020 Form 10-K at 23. 

3 Operating expenses include compensation and benefits, transportation, as well as supplies and services, depreciation and amortization, rent, 

utilities, vehicle maintenance, delivery vehicle fuel, information technology and communications, rural carrier equipment maintenance and 

miscellaneous other.

4 NOEs include all non-cash workers’ compensation costs, accruals to retirement accounts, and one-time adjustments.
5 

As seen in Figure I-1, the Postal Service has not had a profitable year in the last decade. 

Even when excluding NOEs, the Postal Service had posted a net operating income for only 

three of the last 10 years, FY 2014 through FY 2016, when the exigent price increase was in 

effect.

5

These continuing losses have negatively affected the Postal Service's financial position, 

creating a substantial gap between the Postal Service’s assets and liabilities. Although total 

assets increased by $10.3 billion during FY 2020, total liabilities also increased by $19.5 

billion. At the end of FY 2020, the Postal Service recorded total assets of $35.9 billion and 

total liabilities of $116.6 billion. In FY 2020, the Postal Service continued to accrue unpaid 

retiree expenses, which, at the end of FY 2020 totaled $51.9 billion. In FY 2020, the Postal 

Service had current assets of $16.3 billion and current liabilities of $79.2 billion, as seen in 

Figure I-2. 

Figure I-2 

The Gap Between the Postal Service’s Current Assets and Current Liabilities Has Increased 

Considerably Over the Last Decade 

Source: Postal Service Form 10-K, FY 2011–FY 2020

If current assets are insufficient to meet short-term liabilities, the Postal Service could have 

problems paying its creditors, at least in the short term. As seen in Figure I-2 above, the gap 

 

5 From January 2014 to April 2016, an exigent price surcharge allowed the Postal Service to recover $4.6 billion in net revenue above its price 

cap due to volume declines attributable to the Great Recession. 
6 

between current assets and current liabilities has increased substantially since FY 2011. A 

restructuring of short-term debt to long-term debt in FY 2019 led to a $3.1 billion decrease 

in current liabilities, the only such decrease since FY 2011. 

The Postal Service’s liquidity continued to improve and was $25.4 billion at the end of FY 

2020. This was an increase of $12.6 billion, or almost 100 percent, from FY 2019. Much of 

this increase is a result of the CARES Act,6 which allowed the Postal Service access to an 

additional $10 billion from the U.S. Treasury to fund operating expenses. This financing is 

subject to terms and conditions as agreed upon by the Postal Service and the U.S. Treasury. 

Financial sustainability of the Postal Service remains weak due to large personnel-related 

liabilities and the slow replacement of fully depreciated capital assets. Its overall financial 

condition is adversely impacted by insufficient current assets to cover current liabilities. 

At the end of FY 2020: 

 The Postal Service’s total net loss was $9.2 billion. 

o The net deficit was $80.7 billion, consisting of an accumulated deficit of $83.8 

billion offset by capital contributions of $3.1 billion. This is primarily the 

result of multiple years of net losses that started in FY 2007. 

 The Postal Service’s cash and cash equivalents total, excluding restricted cash, was 

$14.4 billion, an increase of $5.6 billion. 

o The Postal Service had the highest cash balance since FY 2006 with a 37 

percent lower net capital asset base. 

o The cash ratio was 0.19, an increase of 0.05 compared to the prior year. The 

FY 2020 cash ratio was also higher than the 10-year average of 0.13. 

 The Postal Service’s operating revenue was $73.1 billion, which was $2.0 billion 

higher than the previous year, and $1.5 billion more than the pre-pandemic 

Integrated Financial Plan. 

o Pandemic induced e-commerce led to $6.4 billion or 26.5 percent more 

Competitive product revenue, the largest increase in over a decade. 

o Market Dominant revenue decreased by $4.0 billion in FY 2020, driven by 

pandemic-related business closings. Consumer price index (CPI)-based price 

increases were not enough to offset volume lost. Marketing Mail volume 

declined particularly sharply – the 11.5 billion piece volume loss was far 

 

6

 Public Law 116-136, the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act). March 27, 2020.
7 

larger than in previous years, accounting for 62.7 percent of the 18.3 billion 

piece loss over the last 10 years. 

 Net operating expenses stood at $76.6 billion, which were $2.4 billion greater in FY 

2020 than the prior year, and $1.0 billion more than the pre-pandemic Integrated 

Financial Plan. 

o Increased expenses for compensation (2.6%), transportation (7.7%), and 

supplies and services expenses (9.5%), were driven by pandemic-related 

increases in more labor-intensive package shipping, disruptions in air and 

highway transportation, and enhanced safety measures. 

 Personnel-related expenses made up 77.0 percent of total expenses. While 

compensation costs grew in FY 2020, the increase in the growth rate of 

compensation costs slowed to 0.03 percent from 0.47 percent in 2019. This measure 

reflects cost management despite the added workload driven by the pandemic due 

to the use of additional overtime workhours and changes in the postal workforce 

mix. 

o Overtime hours increased by 12.6 million (9.3 percent) compared to FY 

2019. 

o Total postal employees increased by a net of 10,948 or 1.7 percent. Over the 

past decade (FY 2011–FY 2020), the Postal Service has reduced its full-time 

and part-time workforce by approximately 61,000 employees and added 

approximately 59,000 non-career employees. 
8 

Chapter II. Postal Service Financial Status 

Introduction 

The Commission evaluates relationships of the essential components of the Postal Service’s 

financial statements to analyze the Postal Service’s profitability, stability, and long-term 

viability. 

The Commission’s analysis, primarily based upon the Postal Service’s Form 10-K financial 

statements, provides a basis for comparing FY 2019 and FY 2020. The Commission also 

incorporates select key financial data from various relevant periods to support this 

analysis. 

The Postal Service’s Form 10-K report consists of: 

 Income Statements, which measure the Postal Service’s financial performance 

(profit and loss) over the fiscal year 

 Balance Sheets, which summarize the Postal Service’s assets and liabilities held at 

the end of the fiscal year 

 Statements of Changes in Net Deficiency, which combine the accumulated net deficit 

from operations and initial capital contributions 

 Statements of Cash Flows, which measure the Postal Service’s inflows and outflows 

of cash during the fiscal year 

This chapter is divided into the following sections: 

Analysis of Income Statements. This section reviews overall income and expenses and 

compares actual revenue and expenses with those forecasted for the current year and 

reported during the prior fiscal year. It also includes an analysis of key financial ratios that 

help the Commission further assess the Postal Service’s profitability. 

Analysis of Balance Sheets. This section begins with a summary of the Postal Service’s assets 

and liabilities at the end of the fiscal year. The section also discusses changes in net 

deficiency, which occur because Postal Service liabilities exceed its assets. The remainder 

of the section provides a financial ratio analysis to assess both the short-term and longterm stability of the Postal Service. 

Analysis of Statements of Cash Flows. This section analyzes the Postal Service’s inflows and 

outflows of cash and debt during the year. 
9 

Analysis of Income Statements 

To facilitate a detailed financial analysis of the Postal Service’s Income Statements, the 

Commission separately identifies elements of reported operating revenue and operating 

expenses. Net operating revenue includes mail and services revenue as well as government 

appropriations revenue.7 Net operating expense is calculated as the total expenses minus 

accruals for certain unfunded retirement liabilities and the non-cash adjustments to the 

workers’ compensation liability.8 The unfunded retirement liabilities consist of three 

components: (1) amortization of unfunded liabilities for retiree health benefits in the 

Retiree Health Benefits Fund (RHBF), (2) for pensions in the Civil Service Retirement 

System (CSRS), and (3) the Federal Employees Retirement System (FERS) in the Civil 

Service Retirement and Disability Fund (CSRDF).9 

The PAEA10 established the RHBF to fund the long-term retiree health benefits for postal 

employees, retirees, and their survivors. From FY 2007 through FY 2016, the PAEA 

required the Postal Service to make specified annual payments into the RHBF. The Postal 

Service defaulted on its annual payments from years FY 2012 through FY 2017, leaving a 

$33.9 billion unfunded balance in the RHBF.11 Beginning in FY 2017, these annual 

installment payments were replaced with annual amortization payments calculated by the 

Office of Personnel Management (OPM) for any remaining unfunded balance to liquidate 

the fund and ensure that RHB liabilities are fully funded by 2056. In addition, beginning in 

FY 2017, the Postal Service’s share of healthcare premiums for retired employees has been 

paid from the RHBF. The Postal Service is also required to make annual contributions to the 

RHBF for the normal costs12 of retiree health benefits. In FY 2020, the Postal Service did 

not make either the normal cost or the unfunded amortization payments, totaling $4.7 

billion. At the end of FY 2020, the Postal Service had a total unpaid balance of $51.9 billion 

in retiree health benefit liabilities.13

The PAEA suspended the Postal Service’s contributions for CSRS until after FY 2016. In 

June 2017, OPM revalued the CSRS liability at $26.9 billion and assessed annual installment 

payments in order to liquidate the unfunded liability by FY 2043. In FY 2020, the Postal 

Service did not pay its annual installment of $1.8 billion. As of September 30, 2020, the 

Postal Service had a total of $6.6 billion in unpaid CSRS liabilities for years FY 2017 through 

FY 2020. 

 

7

 In FY 2020, $73 billion (98.7 percent) of total Postal Service revenue came from the sale of postage and mail services. It received a small 

governmental appropriation for providing free mail for the blind and overseas voting and a few other programs. 

8

 These adjustments and expenses are properly recognized as accrual entries on the Postal Service’s Income Statements and are disaggregated 

by the Commission to provide an in-depth analysis of the financial results for FY 2020. The Postal Service considers these expenses noncontrollable. 

9

 Career Postal Service employees participate in one of two federal pension programs; CSRS is a traditional defined-benefit program that is now 

closed to new entrants. The newer FERS generally covers employees hired since 1984. FERS has a smaller annuity than CSRS and is designed to 

work with Social Security and the Thrift Savings Plan, a 401(k) style program. 

10 Postal Accountability and Enhancement Act (PAEA), Pub. L. 109-435, 120 Stat. 3198 (2006).

11 For years FY 2007 through FY 2011, the Postal Service contributed $20.9 billion into the RHBF. Postal Service FY 2020 Form 10-K at 8. 

12 Normal costs represent the present value of the estimated retiree health benefits attributable to active employees’ current year of service. 

Id. at 9. 

13Id. at 10. 
10 

The Postal Service is also required to make annual amortization payments for unfunded 

FERS liabilities. FERS is a defined benefit plan that, up until FY 2013, had assets that exceeded 

its liabilities. Since FY 2013, liabilities have grown faster than assets, requiring the Postal 

Service to make annual amortization payments. These 

payments are calculated annually by the OPM to liquidate 

the unfunded liability over a 30-year period on a rolling 

basis. In FY 2020, the Postal Service did not make the FERS 

amortization payment of $1.3 billion. Since FY 2013, the 

Postal Service has accumulated total unpaid FERS 

liabilities of $4.8 billion.14

Disaggregating the expenses in the Income Statement 

highlights the Postal Service’s income with and without these statutorily required 

payments and the non-cash adjustments to the workers’ compensation liability. Table II-1 

illustrates the Commission’s disaggregated version of the Income Statements.

Table II-1 

Analysis of Postal Service Income Statements, FY 2019 and FY 2020 ($ in Millions) 

Decrease in revenue and expense is denoted by (). Increase in net loss is denoted by ().

Numbers may not add across due to rounding.

Source: Docket No. ACR2020, Library Reference USPS-FY20-5, December 29, 2020; Docket No. ACR2019, Library Reference USPS-FY19-5, 

December 27, 2019; FY 2012 Plan data from USPS Preliminary Financial Information (Unaudited), September 2020, November 13, 2020 

(November 13, 2020, Preliminary Financial Information), file "2020.11.13 September 2020 Monthly Financial Report to the PRC.pdf." 

Net operating loss occurs when the costs of running a business are not covered by revenue. 

Sustained net operating losses can indicate deterioration of the business. The Postal 

 

14 Form 10-K at 10. 

FY 2020 $ Change 

Plan from Plan

Net Operating Revenue $ 73,133 71,154 $ 1,979 $ 71,651 $ 1,482 $ 

Operating Expense as Reported by the Postal Service 82,187 79,879 2,308 79,167 3,020 Less: Amortization of RHB Unfunded Liability (810) (789) (21) (900) 90 

 Amortization of CSRS Unfunded Liability (1,817) (1,617) (200) (1,617) (200) 

 Amortization of FERS Unfunded Liability (1,343) (1,060) (283) (1,060) (283) 

 Non-Cash Change to Workers' Compensation Liability (1,605) (2,155) 550 0 (1,605) Net Operating Expense $ 76,612 74,258 $ 2,354 $ 75,590 $ 1,022 $ 

Interest Income 92 152 (60) 157 (65) Interest Expense 214 240 (26) 255 (41) Net Income (Loss) from Operations $ (3,601) (3,192) $ (409) $ (4,037) $ 436 $ 

Amortization of RHBF Unfunded Liability 810 789 21 900 (90) Amortization of CSRS Unfunded Liability 1,817 1,617 200 1,617 200 Amortization of FERS Unfunded Liability 1,343 1,060 283 1,060 283 Non-Cash Change to Workers' Compensation Liability 1,605 2,155 (550) 0 1,605 Net Loss (8,813) $ (9,176) $ (363) $ (7,614) $ (1,562) $ 

FY 2019 $ Change FY 2020

The Postal Service’s FY 

2020 net operating loss 

is $409 million more 

than the FY 2019 loss. 
11 

Service’s FY 2020 net operating loss is $409 million more than the FY 2019 loss, 

representing a decline in profitability.15 

The COVID-19 pandemic had a significant impact on Postal Service operations during FY 

2020.16 Stay-at-home orders, business closings, and travel restrictions affected Postal 

Service volume, revenue, and expenses. Beginning in March 2020, stay-at-home orders 

were issued for the majority of the country to slow the spread of COVID-19. These 

restrictions closed many businesses throughout the country and limited travel. 

Operating revenue increased by approximately $2 

billion compared to FY 2019. This increase in 

revenue was driven by significant package volume 

increases that resulted from a rise in fulfillment of 

online-ordered goods to households during the 

pandemic. Partially offsetting the increase in 

Competitive revenue was a significant decline in 

Market Dominant volume and revenue driven by 

pandemic-related business closings.17

Net operating expenseswere $2.4 billion greater in FY 2020 than the prior year, primarily 

driven by increases in compensation, transportation, and supplies and services. The 

increase was largely caused by the pandemic-related increases in more labor-intensive 

package shipping, enhanced safety measures, and disruptions in air and highway 

transportation.18

When adding the adjustments back in, the net operating loss of $3.6 billion becomes a total 

net loss of $9.2 billion. This loss is $363 million higher than the total net loss in FY 2019. As 

shown in Table II-1, the slight improvement in the non-operating expenses results from 

higher retirement expenses fully offset by a favorable adjustment to the non-cash portion 

of workers’ compensation expense.19

Market Dominant Revenue Compared to Prior Year 

The discussion in this section summarizes the overall revenue by class for Market 

Dominant products. Chapter 3 disaggregates revenue by class and product. Table II-2 

compares FY 2020 and FY 2019 revenue by class. 

 

15 The Commission’s calculation of net operating income (loss) differs from the controllable net income (loss) reported in Postal Service Form 

10-K by negative $151 million and negative $226 million for FY 2019 and FY 2020, respectively. The Postal Service excludes the difference in the 

normal cost of RHBs from its controllable income (loss) because it is the result of actuarial changes. Postal Service FY 2020 Form 10-K at 23. 

16 See also United States Postal Service, Office of Inspector General, Report No. 20-257-R21, Impact of Pandemic on Postal Service Finances, 

March 29, 2021, available at https://www.uspsoig.gov/sites/default/files/document-library-files/2021/20-257-R21.pdf.

17 Form 10-K at 21. 

18 Id. at 31, 44, and 45. 

19 Workers’ compensation is administered by the U.S. Department of Labor and its calculation reflects the impacts of changes in discount rates 

as well as actuarial revaluation of new cases and revaluation of existing ones. The decrease in the FY 2020 non-cash portion of workers’ 

compensation expense was driven by a less significant decrease in discount rates in FY 2020 compared to FY 2019. Postal Service FY 2020 Form 

10-K at 43. 

Expenses increased in FY 

2020. This was due to 

increases in compensation, 

transportation and supplies 

and services. 
12 

Table II-2 

Revenue by Market Dominant Class,20 FY 2019 and FY 2020 ($ in Millions) 

Decrease in revenue is denoted by (). 

Numbers may not add across due to rounding.

Source: Library Reference PRC-LR-ACR2020/1, March 29, 2020; Docket No. ACR2020, Library Reference PRC-LR-ACR2019/1, March 25, 2020; 

Library Reference USPS-FY20-42, December 29, 2020. 

Market Dominant Mail and Services revenue21 declined 8.7 percent from the prior year. 

Revenue declined in all Market Dominant classes, except Package Services. 

Changes in revenue per piece resulting from rate increases, volume changes, and migration 

between classes, products, and rate categories (known as mail mix fluctuations) affect total 

revenue. Figure II-1 isolates the change in Market 

Dominant revenue due to mail volume changes, mail 

mix, and average revenue per piece for each year since 

FY 2015. For overall Market Dominant products, 

increases in revenue per piece were not enough to 

offset volume decline and mail mix fluctuations. The 

volume impact was particularly dramatic in FY 2020.

 

As shown in Table II-2, the largest contributing factor 

to the overall decline in Market Dominant revenue 

was revenue losses in both First-Class Mail and 

Marketing Mail primarily caused by volume losses. 

First-Class Mail volume declined by 2.7 billion pieces, 

and Marketing Mail volume declined by 11.5 billion 

pieces compared with FY 2019. According to the 

Postal Service, pandemic-related volume losses began a rapid overall volume decline in 

March 2020, followed by a modest recovery in the third and fourth quarters.22

 

20 Other Market Dominant revenue includes appropriations, miscellaneous item revenue, and revenue foregone. 

21 This excludes Other Market Dominant Mail revenue. 

22 Postal Service Form FY 2020 Form 10-K at 68.

FY 2019 FY 2020 $ Change % Change

First-Class Mail $ 24,203 25,462 $ (1,259) $ (4.9%)

Marketing Mail 13,959 16,407 (2,448) (14.9%)

Periodicals 1,024 1,194 (170) (14.3%)

Package Services 832 821 11 1.4%

Ancillary and Special Services 1,713 1,810 (97) (5.4%)

Subtotal Market Dominant Mail and Services Revenue $ 41,731 45,695 $ (3,964) $ (8.7%)

Other 779 1,299 (520) (40.1%)

Total Market Dominant Mail and Services Revenue 46,994 $ 42,509 $ (4,484) $ (9.5%)

Total Market Dominant 

Mail and Services revenue 

declined 8.7 percent from 

the prior year. Revenue 

declined in all Market 

Dominant classes, except 

Package Services. 
13 

Figure II-1 

Change in Market Dominant Revenue Due to Changes in Mail Volume, Mail Mix, and Average 

Revenue per Piece, FY 2015-FY 2020 ($ in Millions)

Source: PRC derived from Docket No. ACR2015, Library Reference USPS-FY15-42, December 28, 2015; Docket No. ACR2016, Library Reference 

USPS-FY16-42, December 27, 2016; Docket No. ACR2017, Library Reference USPS-FY17-42, December 29, 2017; Docket No. ACR2018, Library 

Reference USPS-FY18-42, December 28, 2014; Library Reference USPS-FY19-42, December 27, 2019; Docket No. ACR2020, Library Reference 

USPS-FY20-43, December 29, 2020 (collectively, Postal Service RPW Report, FY 2015–FY 2020). 

Competitive Product Revenue Compared to Prior Year 

Total revenue from Competitive products increased $6.4 

billion or 26.5 percent compared to FY 2019, resulting 

from volume increases in all products except for Priority 

Mail Express. Shipping and packages volume began to 

increase during the pandemic as online shopping 

increased. Table II-3 compares revenue for Competitive 

products between FY 2020 and FY 2019. 

Total revenue from 

Competitive products 

increased 26.5 percent in 

FY 2020. 
14 

Table II-3 

Competitive Product Revenue, FY 2019 and FY 2020 ($ in Millions) 

Decrease in revenue denoted by (). 

Numbers may not add across due to rounding. 

Source: Library Reference PRC-LR-ACR2020/1; Library Reference PRC-LR-ACR2019/1; Library Reference USPS-FY19-42. 

Expense Analysis as Compared to Prior Year 

As noted earlier, for purposes of understanding the Postal Service’s financial position, the 

Commission differentiates between operating and total expenses. As shown in Table II-4, 

in FY 2020, total expenses increased by $2.3 billion (2.9 percent) while operating expenses 

increased by $2.4 billion (3.2 percent). The increase in operating expenses was due to 

increases in personnel ($1.5 billion) and transportation ($0.6 billion) expenses. A decline in 

the non-cash change to workers’ compensation liability ($0.6 billion) offset increases in 

retirement amortization expenses ($0.5). 

 

FY 2019 FY 2020 $ Change % Change

Priority Mail 9,464 $ 11,529 $ 2,065 $ 21.8%

Total Ground 9,195 7,271 1,924 26.5%

First-Class Package Service 6,228 4,466 1,762 39.4%

Priority Mail Express 697 716 (19) (2.7%)

International 1,959 1,380 579 42.0%

Ancillary and Special Services 1,004 911 93 10.3%

Subtotal Competitive Products Mail and Services Revenue $ 30,611 24,207 $ 6,404 $ 26.5%

Other Revenue 142 142 (0) (0.2%)

Total Competitive Products Mail and Services Revenue $ 30,752 24,349 $ 6,403 $ 26.3%
15 

Table II-4 

Total Expenses, FY 2019 and FY 2020 ($ in Millions) 

Decrease in expenses is denoted by (). NM denotes not meaningful.

Numbers may not add across due to rounding.

Source: USPS Preliminary Financial Information (Unaudited), September 2020, November 13, 2020 (November 13, 2020, Preliminary Financial 

Information), file "2020.11.13 September 2020 Monthly Financial Report to the PRC.pdf." 

Personnel Expenses 

The majority of Postal Service expenses are personnel-related. In FY 2020, personnel 

expenses excluding the non-cash adjustment to workers’ compensation and amortization 

costs of unfunded retirement liabilities made up 75.3 percent of operating expenses; when 

these expenses are included, Postal Service labor 

costs are 77.0 percent of total expenses. 

Table II-5 shows that total personnel expenses 

for FY 2020 increased by $1.5 billion from FY 

2019, resulting from increases in personnel 

operating expenses. The decline in the non-cash 

adjustment to workers’ compensation liability23

fully offsets the increase in non-operating 

retirement expenses. Compensation, retirement, 

and health benefit expenses all increased during 

FY 2020.

 

23 Workers’ compensation expense consists of cash payments, miscellaneous expenses, and the net increase (decrease) in the workers’ 

compensation liability. 

FY 2019 FY 2020 $ Change % Change FY 2019 FY 2020

Compensation & Benefits Expenses:

 Salaries and Benefits 50,934 $ 52,411 $ 1,477 $ 2.9% 63.8% 63.8%

 Workers' Compensation - Cash Outlays 1,349 1,298 (51) (3.8%) 1.7% 1.6%

 Normal Costs of Retiree Health Benefits 3,774 3,850 76 2.0% 4.7% 4.7%

 Other Personnel Related 105 123 18 17.1% 0.1% 0.1%

Subtotal Personnel Expenses Excluding Systemwide Personnel Expenses 56,162 $ 57,682 $ 1,520 $ 2.7% 70.3% 70.2%

Transportation 8,184 8,814 630 7.7% 10.2% 10.7%

Other Expenses 9,911 10,116 205 2.1% 12.4% 12.3%

Total Operating Expenses 74,258 $ 76,612 $ 2,354 $ 3.2% 93.0% 93.2%

Systemwide Personnel Expenses:

Non-Cash Change to Workers' Compensation Liability 2,155 1,605 (550) NMF 2.7% 2.0%

Amortization of RHB Unfunded Liability 789 810 21 2.7% 1.0% 1.0%

Amortization of FERS Unfunded Liability 1,060 1,343 283 26.7% 1.3% 1.6%

Amortization of CSRS Unfunded Liability 1,617 1,817 200 12.4% 2.0% 2.2%

Total Expenses 79,879 $ 82,187 $ 2,308 $ 2.9% 100.0% 100.0%

% of Total Expenses

The Postal Service’s labor costs 

are a large proportion of total 

costs. Compensation and 

benefits expenses made up 

77.0 percent of total costs in 

FY 2020.
16 

Table II-5 

Breakdown of Total Personnel Expenses, FY 2019 and FY 2020 ($ in Millions) 

Decrease in expenses is denoted by (). NMF denotes not meaningful figures. 

Numbers may not add across due to rounding. 

Source: PRC derived from Postal Service National Trial Balance September 2020; Postal Service National Trial Balance September 2019. 

Total compensation comprises salaries for 

employees (full-time career, part-time career, 

and non-career), overtime and leave pay, and 

performance or arbitration awards. There are 

several cost drivers for compensation, 

including contractual pay increases, inflation 

used to calculate semi-annual Cost of Living 

Allowances (COLAs), the number of overtime 

workhours, and the composition of the 

workforce. Total compensation in FY 2020 

increased by approximately $1 billion 

compared to FY 2019 primarily due to additional city carrier overtime hours needed for the 

higher shipping and packages volumes, contractual wage increases, and new paid leave 

categories that resulted from the passage of the Families First Coronavirus Response Act 

(FFCRA).24 Overtime hours increased by 12.6 million (9.3 percent) compared to FY 2019, 

resulting in a $0.6 billion increase in overtime compensation expense.

 

24 Postal Service Form 10-K at 31. 

FY 2019 FY 2020 $ Change % Change

Total Compensation 38,756 $ 39,754 $ 998 $ 2.6%

Retirement 6,846 7,254 409 6.0%

Health Benefits-Current Employees 5,121 5,188 67 1.3%

Workers' Compensation - Cash Outlays 1,349 1,298 (51) (3.8%)

Normal Costs of Retiree Health Benefits 3,774 3,850 76 2.0%

Other Compensation 317 338 21 6.6%

Total Personnel Operating Expenses 56,163 $ 57,682 $ 1,520 $ 2.7%

Non-Cash Change to Workers' Compensation Liability 2,155 1,605 (550) NMF

Amortization of RHB Unfunded Liability 789 810 21 2.7%

Amortization of FERS Unfunded Liability 1,060 1,343 283 26.7%

Amortization of CSRS Unfunded Liability 1,617 1,817 200 12.4%

Total Personnel Expenses 61,784 $ 63,257 $ 1,474 $ 2.4%

The total compensation in FY 2020 

increased by approximately $1 

billion compared to FY 2019 

primarily due to additional city 

carrier overtime hours. 
17 

Figure II-2 

Change in Overtime Workhours, FY 2019 and FY 202025 (in Millions) 

Source: PRC derived from National Payroll Hours Summary Report, Pay Period 20, 2020, September 2020, October 7, 2020; National Payroll 

Hours Summary Report, Pay Period 20, 2019, October 15, 2019. 

The Postal Service’s workforce comprises career (full-time and part-time) and non-career 

employees, including postal support employees, city carrier assistants, mail handler 

assistants, and other non-career employees. Table II-6 shows the number of employees by 

type for FY 2018-FY 2020. 

Table II-6 

Postal Service Employee Complement, FY 2018–FY 2020 

 

Decrease in amounts is denoted by (). 

Numbers may not add across due to rounding. 

Source: United States Postal Service, On-Roll and Paid Employee Statistics Report, September 2020, October 7, 2020; United States Postal 

Service, On-Roll and Paid Employee Statistics Report, September 2019, October 15, 2019 (Postal Service September 2019 ORPES Report); 

United States Postal Service On-Roll and Paid Employee Statistics Report, September 2018, October 11, 2018 (Postal Service September 2018 

ORPES Report). 

 

25 Other includes Postmasters, Professional and Administrative, Vehicle Operators, and Headquarters. 

FY 2019 FY 2020 Change FY 2020 

over FY 2019 FY 2018 Change FY 2019 over FY 2018

Career Employees 496,934 495,941 (993) 497,157 (223) Postal Support Employees (PSE) 26,251 25,778 (473) 26,386 (135) City Carrier Assistants (CCA) 42,121 38,079 (4,042) 42,115 6 Mailhandler Assistants (MHA) 6,369 12,927 6,558 6,274 95 Other Non-Career 61,433 71,308 9,875 62,515 (1,082) Total On-Roll Employees 633,108 644,033 10,925 634,447 (1,339) 
18 

In FY 2020, the Postal Service’s total workforce increased by more than 10 thousand 

employees resulting from an increase in the non-career workforce of approximately 12 

thousand positions, offset by a decrease of almost 1 thousand career positions. According 

to the Postal Service, the increase in the non-career workforce reflected the need to 

address the pandemic-related surge in shipping and packages volume.26 The decline in 

career workforce positions resulted from normal attrition to align the workforce with 

declining mail volume.27

In May 2019, the Postal Service reached a 3-year agreement with the National Rural Letter 

Carriers Association (NRLCA), which includes modest general wage increases over the life 

of the contract and a reduction in the Postal Service share of health insurance premiums.28 

 

The new American Postal Workers Union, AFL-CIO (APWU) contract includes modest 

general wage increases, a reduction in Postal Service share of health insurance premiums, 

and wage improvements for postal support employees. The contract will expire on 

September 20, 2021.29

In January 2020, the Postal Service reached an agreement with the National Postal Mail 

Handlers Union, AFL-CIO (NPMHU), on a new three-year agreement which union 

membership ratified on April 7, 2020. The new contract includes modest wage increases, a 

reduction in health insurance premiums, increased flexibility to use mail handler 

assistants, and the elimination of non-career casual employees. The contract will expire on 

September 20, 2022.30 In November 2020, the Postal Service reached a tentative 

agreement, subject to ratification, with the National Association of Letter Carriers, AFL-CIO 

(NALC) that provides wage increases and a reduction in health insurance premiums.31

Total workhours increased by approximately 1.1 million during FY 202032 Figure II-3 

illustrates the change in total workhours since FY 2006. 

 

 

26 Postal Service Form 10-K at 32.

27 Id. 

28 Id. at 78. 

29 Id. 

30 Id. 

31 Postal Service Quarter I, 2021 Form 10-Q, February 9, 2021, at 13. 

32 Postal Service FY 2020 Form 10-K at 32. 
19 

Figure II-3 

Change in Total Workhours, FY 2006–FY 2020 

Source: Postal Service Form 10-K, FY 2006–FY 2020. 

An analysis of workhours by function shows that in FY 2020, workhours increased in Rural 

Delivery (2.8 percent), and Vehicle Maintenance (0.8 percent)., categories.33 Workhours 

declined in Mail Processing (0.8 percent), Customer Service (0.8 percent), City Delivery 

(0.04 percent), Plant & Equipment (1.6 percent) as shown in Table II-7 and Other (1.2 

percent). 

 

33 The “Other” category represents Operations Support, Finance, Human Resources, Administration, Training, and Rehabilitation workhours. 
20 

Table II-7 

Workhours by Function (Thousands of Workhours), FY 2018–FY 2020

Decrease in amounts is denoted by (). 

Numbers may not add across due to rounding. 

Source: Library Reference USPS-FY20-7, December 29, 2020; Docket No. ACR2019, Library Reference USPS-FY19-7, December 27, 2019; Library 

Reference USPS-FY18-7, December 28, 2018. 

The Postal Service defines productive hourly wage rates as the labor costs per work hour 

by cost segment/craft.34 This metric reflects the effect of wage levels, the composition of 

workers, overtime, pay premiums, and leave usage on hourly labor costs. Table II-8 shows 

the productive hourly wage rates.35 The productive hourly wage rate for building 

equipment (3 percent) and headquarters (3.6 percent) decreased compared to the prior 

year. The productive hourly wage rate for supervisors (2.6 percent), clerks (5.1 percent), 

mailhandlers (0.8 percent), vehicle drivers (4.6 percent), city delivery carriers (1.9 

percent), rural carriers (0.2 percent), building services (6.6 percent), operating equipment 

(7.4 percent), and motor vehicle service (4.2 percent) all increased compared to the prior 

year. 

 

34 USPS-FY20-17 Preface at 1. 

35 The productive hourly wage rate is a measure of total compensation and benefits costs per hour worked. Compensation includes overtime, 

annual, sick, or holiday pay and any other hourly pay premiums. 

% Change % Change

FY 2020 over FY 2019 FY 2019 over FY 2018

Mail Processing 194,905 193,286 (0.8%) 198,029 (1.6%)

Customer Service 168,992 167,676 (0.8%) 169,372 (0.2%)

Delivery Service:

 City Delivery 425,894 425,728 (0.04%) 426,353 (0.1%)

 Rural Delivery 211,505 217,396 2.8% 204,874 3.2%

Maintenance:

 Plant & Equipment 62,525 61,540 (1.6%) 63,302 (1.2%)

 Vehicle 30,822 31,058 0.8% 29,990 2.8%

 Other 78,566 77,642 (1.2%) 77,697 1.1%

Total Workhours 1,174,326 1,173,208 0.1% 1,169,617 0.3%

FY 2019 FY 2018 FY 2020
21 

Table II-8 

Productive Hourly Wage Rates ($ per Workhour), FY 2018–FY 2020 

Decrease in amounts is denoted by (). 

Numbers may not add across due to rounding. 

NMF = Not Meaningful Figure 

Source: Library Reference USPS-FY20-7, December 29, 2020; Library Reference USPS-FY19-7, December 28, 2019; Library Reference USPSFY18-7, December 28, 2018. 

Workers’ compensation expenses declined by $0.6 billion in FY 2020. Workers’ 

compensation expenses consist of a cash payment and a non-cash change in long-term 

workers’ compensation liability. The cash payment is paid to the United States Department 

of Labor for the current year’s cost of medical and compensation benefits and an 

administrative fee. The non-cash change in long-term workers’ compensation expense 

includes actuarial revaluations of existing cases and new cases, initial costs of new cases for 

the year, and any changes in the discount rate used to estimate the amount of current funds 

needed to settle all claims in the current year. These factors cause the non-cash portion of 

workers’ compensation to fluctuate year to year. In FY 2020, the non-cash component of 

long-term workers’ compensation expense declined slightly by $51 million compared to 

the prior year. The portion of long-term workers’ compensation expense attributable to the 

impact of discount rate changes resulted in a $0.6 billion increase.36 Table II-9 

disaggregates components factoring into the workers’ compensation expense for the past 

two years. 

 

36 Postal Service FY 2020 Form 10-K at 43. 

% Change % Change

FY 2020 over FY 2019 FY 2019 over FY 2018

Supervisors & Technicians 52.78 $ 54.17 $ 2.6% 52.52 $ 0.5%

Clerks 40.61 42.69 5.1% 40.87 (0.6%)

Mailhandlers 41.45 41.80 0.8% 41.27 0.5%

City Delivery Carriers 42.34 43.17 1.9% 41.31 2.5%

Vehicle Drivers 45.41 47.52 4.6% 45.67 (0.6%)

Rural Carriers 38.17 38.25 0.2% 36.72 3.9%

Building Services 42.96 45.80 6.6% 43.37 (0.9%)

Operating Equipment 54.36 58.41 7.4% 55.32 (1.7%)

Building Equipment 55.32 53.65 (3.0%) 51.36 7.7%

Motor Vehicle Service 50.66 52.78 4.2% 49.86 1.6%

Headquarters 71.36 68.81 (3.6%) 68.07 4.8%

FY 2019 FY 2018 FY 2020
22 

Table II-9 

Components of Workers’ Compensation Expense, FY 2019 and FY 2020 ($ in Millions) 

Decrease in expenses is denoted by (). 

Numbers may not add across due to rounding. 

NMF = Not Meaningful Figure 

Source: Postal Service FY 2020 Form 10-K at 42-43. 

Non-Personnel Expenses 

Transportation is by far the biggest non-personnel Postal Service expense. It accounts for 

10.7 percent of total expenses. Table II-10 shows transportation expenses by category. 

Table II-10 

Transportation Expenses by Category, FY 2019 and FY 2020 ($ in Millions) 

Decrease in expenses is denoted by (). Numbers may not add across due to 

rounding. 

Source: Postal Service FY 2020 Form 10-K at 43-44. 

Total transportation expenses increased by 7.7 

percent from FY 2019. Air transportation expenses 

increased by 12.7 percent compared to last year 

resulting from the pandemic-related package volume 

increases and travel restrictions, slightly offset by 

lower average jet fuel prices.37 Highway 

transportation expenses increased by 5.2 percent 

resulting from an increase in miles driven due to 

pandemic-related shifts in modes of transportation.38

A decline in international transportation (including 

 

37 Postal Service FY 2020 Form 10-K at 44. 

38 Id. 

FY 2019 FY 2020 $ Change % Change

Medical and Compensation Claims Payments 1,266 $ 1,216 $ (50) $ (3.9%)

Administrative Fee 83 82 (1) (1.2%)

Cash Outlays 1,349 $ 1,298 $ (51) $ (3.8%)

(Decrease) Increase in Long Term Workers' Compensation Obligation 2,155 1,605 (550) (25.5%)

Workers' Compensation Expense 3,504 $ 2,903 $ (601) $ (17.2%)

FY 2019 FY 2020 $ Change % Change

Highway Transportation 4,517 $ 4,753 $ 236 $ 5.2%

Air Transportation 3,070 3,461 391 12.7%

International Transportation 556 555 (1) (0.2%)

Other Transportation 41 45 4 9.8%

Total Transportation $ 8,814 8,184 $ 630 $ 7.7%

Purchased transportation 

costs represent the largest 

non-personnel Postal Service 

expense, at about 10.7 

percent of total expenses. 

Total transportation 

expenses increased by 7.7 

percent in FY 2020. 
23 

only expenses related to outbound mail) of 0.2 percent slightly offsets these expenses. This 

decline resulted from volume declines in Priority Mail International and other international 

service volumes.39

Table II-11 shows all other non-personnel-related expenses increased by $0.2 billion in FY 

2020. Increases in supplies and services, depreciation, rent and utilities, and information 

technology partially offset declines in vehicle maintenance, delivery vehicle fuel, rural 

carrier equipment maintenance, and other expenses. The $0.3 billion increase in supplies 

and services was largely the result of additional COVID-19 related expenses.40

Miscellaneous other expenses consist mainly of travel, training, repairs, and contingency 

accounts. 

Table II-11 

Other Non-Personnel Expenses, FY 2019 and FY 2020 ($ in Millions) 

Decrease in expenses is denoted by (). 

Numbers may not add across due to rounding. 

Source: Postal Service FY 2020 Form 10-K at 44.

Comparison of Postal Service Actual Results to Operating Plan

Each year the Postal Service develops an integrated financial plan that includes forecasts of 

volume, revenue, and expenses for the following year.41 This section compares the Postal 

Service’s forecasts with actual results. The Postal Service’s FY 2020 Operating Plan, as 

outlined in its 2020 Integrated Financial Plan (IFP), projected a net loss of $7.6 billion in FY 

2020.42 The actual total net loss of $9.2 billion was $1.6 billion more than the Postal Service 

estimated. Total revenue was $1.4 billion more than planned. Total operating expenses 

were $1.0 billion more than planned with net retirement accruals slightly over budget by 

$0.4 billion. However, if the $1.6 billion change in non-cash worker’s compensation is 

excluded from the comparison, the Postal Service’s projected net loss was in line with its 

 

39 Id. 

40 Id. 

41 See also United States Postal Service, Office of Inspector General, Report No. 21-037-R21, Pandemic Volume and Revenue Projected 

Scenarios, February 10, 2021, available at https://www.uspsoig.gov/sites/default/files/document-library-files/2021/21-037-R21.pdf.

42 United States Postal Service, Integrated Financial Plan, Fiscal Year 2020, February 13, 2020, at 1 (Postal Service FY 2020 IFP); see also Postal 

Service September 2020 IFP Report. 

FY 2019 FY 2020 $ Change % Change

Supplies and Services 2,819 $ 3,088 $ 269 $ 9.5%

Depreciation and Amortization 1,697 1,706 9 0.5%

Rent and Utilities 1,714 1,757 43 2.5%

Vehicle Maintenance Services 627 618 (9) (1.4%)

Delivery Vehicle Fuel 491 432 (59) (12.0%)

Information Technology and Communications 916 946 30 3.3%

Rural Carrier Equipment Maintenance 588 586 (2) (0.3%)

Miscellaneous Other 1,059 983 (76) (7.2%)

Total Other Non-Personnel Expenses 9,911 $ 10,116 $ 205 $ 2.1%
24 

actual net loss. Table II-12 compares actual FY 2020 results with the estimated results in 

the Operating Plan. 

Table II-12 

Actual and Operating Plan Income Statements, FY 2020 ($ in Billions) 

Decrease in revenue and expense is denoted by (). Increase in net loss is denoted by (). 

Numbers may not add across due to rounding. 

Source: USPS Preliminary Financial Information (unaudited), September 2020, November 13, 2020, file "2020.11.13 September 2020 Monthly 

Financial Report to the PRC.pdf". 

As seen in Table II-13, total revenue from Market Dominant mail was $3.9 billion less than 

expected, while Competitive mail was $5.2 billion greater than anticipated. First-Class and 

Marketing Mail revenues were less than projected, resulting from continuing migration to 

electronic communication exacerbated by pandemic-related volume declines.43 Periodicals 

and Other Mail revenues were also less than the plan.44 

 

43 Form 10-K at 26. 

44 Other mail includes Market Dominant Package Services, Special Services, and Other Ancillary Services. 

FY 2020 Actual FY 2020 

Operating Plan $ Change

Total Revenue 73.2 $ 71.8 $ 1.4 $ 

Total Operating Expense 76.8 75.8 1.0 Net Operating Income/(Loss) (3.6) $ (4.0) $ 0.4 $ 

Non-Cash Change to Workers' Compensation 1.6 0.0 1.6 RHBF Unfunded Liability Amortization 0.8 0.9 (0.1) FERS Unfunded Liability Amortization 1.3 1.1 0.3 CSRS Unfunded Liability Amortization 1.8 1.6 0.2

Total Net Income/(Loss) (9.2) $ (7.6) $ (1.6) $ 
25 

Table II-13 

Actual and Operating Plan Revenue by Categories Shown in IFP,45 FY 2020 ($ in Billions)46

Decrease in revenue is denoted by (). 

Numbers may not add across due to rounding. 

Source: USPS Preliminary Financial Information (unaudited), September 2020, November 13, 2020, file "2020.11.13 September 2020 Monthly 

Financial Report to the PRC.pdf"; Postal Service Fiscal Year 2020 Integrated Financial Plan, February 13, 2020. 

Total volume was less than expected, primarily due to lower than expected volume in USPS 

Marketing Mail and First-Class Mail. Table II-14 compares volumes for FY 2020 with the 

volume projected in the Operating Plan. 

Table II-14 

Actual and Operating Plan Volume by Categories Shown in IFP,47 FY 2020 (in Billions) 

 Decrease is denoted by (). Numbers may not add due to rounding. 

 Source: Postal Service September 2020 PFI Report at 2; Postal Service FY 2020 IFP at 3 

 

45 The Postal Service FY 2020 IFP isolates volume from International and Parcels from the other categories. See Postal Service FY 2020 IFP at 3. 

46 Total mail revenue excludes investment income. 

47 The Postal Service FY 2020 IFP isolates revenue and volume from International and Parcels from the other categories. See Postal Service FY 

2020 IFP at 3. 

FY 2020 Actual FY 2020 

Operating Plan $ Change

First-Class Mail 23.8 $ 24.4 $ (0.6) $ 

Periodicals 1.0 1.2 (0.2) Marketing Mail 14.0 16.0 (2.0)

Other 3.2 4.2 (1.0)

Competitive and Other Parcels 28.8 23.6 5.2 International 2.4 2.4 (0.0) Total Mail Revenue 73.1 $ 71.8 $ 1.3 $ 

FY 2020 

Actual

FY 2020 

Operating Plan Change

First-Class Mail 52.6 54.0 (1.4) Periodicals 4.0 4.4 (0.4)

Marketing Mail 64.2 72.7 (8.5)

Other 0.9 0.3 0.6 Competitive and Other Parcels 6.7 6.0 0.7

International 0.7 0.7 0.0

Total Mail Volume 129.2 138.1 (8.9) 
26 

Total expenses were $3.0 billion more than anticipated, the combined result of higher than 

expected operating and non-operating expenses. Total operating expenses were $1.0 

billion more than expected; compensation and benefits ($0.6 billion), transportation ($0.3 

billion), and supplies and services ($0.2 billion) were all higher than planned. Excluding the 

non-cash workers’ compensation adjustment,48 non-operating expenses were $0.4 billion 

higher than anticipated resulting from lower discount rates used in OPM’s actuarial 

calculation of the unfunded FERS and CSRS annual installment payments.49

Total non-personnel expenses were $0.4 billion more than projected, resulting from higher 

than anticipated transportation and supplies and services expenses. 

Table II-15 

Actual and Operating Plan Expenses, FY 2020 ($ in Billions) 

Decrease in amounts is denoted by (). 

Numbers may not add across due to rounding. 

Source: Postal Service September 2020 PFI Report at 3; Postal Service FY 2020 IFP at 1. 

 

 

48 The Postal Service excludes the non-cash adjustment to workers’ compensation from plan because it is dependent on actuarial assumptions, 

interest rates, and other factors outside of Postal Service management’s control. See IFP at 1. 

49 FY 2020 Form 10-K at 35.

FY 2020 Actual FY 2020 

Operating Plan $ Change

Compensation & Benefits 57.7 $ 57.1 $ 0.6 $ 

Transportation 8.8 8.5 0.3 Supplies & Services 3.1 2.9 0.2

Depreciation and Amortiation 1.7 1.7 0.0

Rent/Utilities/Other 5.3 5.5 (0.2) Total Operating Expenses 76.6 $ 75.6 $ 1.0 $ 

Workers' Compensation Adj. 1.6 0.0 1.6 RHB Unfunded Amortization 0.8 0.9 (0.1) FERS Unfunded Amortization 1.3 1.1 0.3 CSRS Unfunded Amortization 1.8 1.6 0.2

Total Expenses $ 82.2 $ 79.2 $ 3.0
27 

Financial Ratio Analysis 

Financial ratios assist in interpreting accounting information. The Commission calculated 

key financial ratios to facilitate its analysis of the Postal Service’s financial performance 

between FY 2006 and FY 2020. These ratios provide a concise and systematic way to 

organize financial data into meaningful information. The historic accounting information 

used in ratio analysis is not adjusted for inflation in order to maintain consistency with 

Generally Accepted Accounting Principles (GAAP) and comparability over time and also 

because some postal expenses, such as labor, retirement, and workers’ compensation, are 

impacted by cost indexes other than inflation. 

OPERATING RATIO 

The operating ratio measures how well an organization can control operating expenses 

while generating revenue. The Commission measures this by comparing the Postal 

Service’s total operating expenses to its total 

operating revenue. An operating ratio greater 

than 1.0 indicates a net operating loss, and a 

ratio less than 1.0 indicates a net operating 

profit.50 In the period reflected in Figure II-4, 

the Postal Service had a net operating profit in 

FY 2006 through FY 2008 and FY 2014 

through FY 2016. An increasing operating 

ratio indicates a deterioration in the Postal Service’s ability to reduce its operating 

expenses while generating revenue. As seen in Figure II-4, although the Postal Service’s 

operating ratio has fluctuated annually, it has trended upward since FY 2016; average 

growth in operating expense has increased at a higher rate than the growth in revenue over 

this period. Notably, for FY 2020, operating revenue and operating expenses are the 

highest in more than a decade. 

 

50 The Commission calculates the operating ratio by dividing total operating expenses by total operating revenue. 

Notably for FY 2020, operating 

revenue and operating expenses are 

higher than they have been in more 

than a decade. 
28 

Figure II-4 

Operating Ratio Trend Since FY 2006 

 Source: PRC derived from Postal Service Form 10-K, FY 2006–FY 2020.

RETURN ON ASSETS 

The return on assets ratio is a measure of how efficiently an organization uses its assets to 

generate profits. It compares total assets to net income (loss) for each year. A negative 

return on assets indicates net losses and/or low investment in capital investments. Figure 

II-5 shows the Postal Service’s return on assets since FY 2006. 
29 

Figure II-5 

Return on Assets Trend Since FY 2006 

 Source: PRC derived from Postal Service Form 10-K, FY 2006–FY 2020. 

The Postal Service’s total assets are cash and cash equivalents, receivables and property, 

plant, and equipment. At the end of FY 2020, the Postal Service had a negative return on 

assets ratio of 0.26, an improvement compared to the 

prior year’s ratio of 0.34. This resulted from a larger 

increase in total assets driven by an increase in cash 

from the issuance of notes payable and the addition to 

noncurrent assets of operating lease rights. In FY 2020, 

the Postal Service had the highest cash balance since FY 

2006 with a 37 percent lower net asset base.51 

At the end of FY 2019, the Postal Service had a negative 

return on assets ratio of 0.34, a decline of 0.20 compared to the end of FY 2018. This was 

the result of the large increase in the Postal Service’s net loss. 

FY 2006 was the last year that showed a positive ratio. This was during the Postal 

Reorganization Act regime when revenue was required to cover costs (break-even). From 

FY 2007 through FY 2010, the percentage change in year-to-year net losses was greater 

than the percentage change in year-to-year total assets, resulting in increasingly negative 

ratios. During this period, the Postal Service began using available debt to invest in capital 

 

51 Net asset base includes property, plant, and equipment which has declined from $23.1 billion in FY 2006 to $14.6 billion in FY 2020. 

In FY 2020, the Postal 

Service had the highest 

cash balance since FY 2006. 
30 

and fund its operations. From FY 2006 through FY 2011, the Postal Service used $13 billion 

of its $15 billion allowable debt.52 The sharp decline in FY 2012 was largely the result of 

two RHB prefunding payments totaling $11.1 billion. The improvement in FY 2014 through 

FY 2016 was primarily the result of revenue generated from the exigent surcharge53 and 

improving cash balances resulting from defaults on annual RHB prefunding payments. The 

improvement in FY 2017 resulted from lower retirement-related health benefit expenses 

compared to the statutory prefunding of the RHB and a decrease in non-cash workers’ 

compensation expense from higher discount rates. 

Analysis of Balance Sheets

This section analyzes the Postal Service’s financial situation and use of resources based on 

data from Balance Sheets prepared according to GAAP. The analysis compares two points 

in time, September 30, 2020 (FY 2020) and September 30, 2019 (FY 2019). Table II-16 

compares certain categories in the Postal Service’s asset and liability structure for FY 2020 

with FY 2019. 

Table II-16 

Structure of Assets and Liabilities, FY 2019 and FY 2020 ($ in Millions) 

Decrease in amounts is denoted by (). 

Numbers may not add across due to rounding. 

Source: Postal Service FY 2020 Form 10-K at 59. 

 

52 Postal Service Form 10-K, Balance Sheet, FY 2007–FY 2010. 

53 See Docket No. R2013-11, Order Granting Exigent Price Increase, December 24, 2013 (Order No. 1926). 

Assets FY 2019 FY 2020 $ Change FY 2019 FY 2020

Cash and Cash Equivalents (includes Restricted Cash) 9,161 $ 14,712 $ 5,551 $ 35.7% 41.0%

Receivables 1,461 1,359 (102) 5.7% 3.8%

Supplies and Prepayments 178 224 46 0.7% 0.6%

 Total Current Assets 10,800 16,295 5,495 42.1% 45.4%

 Noncurrent Assets 14,833 19,609 4,776 57.9% 54.6%

Total Assets 25,633 $ 35,904 $ $ 100.0% 100.0% 10,271

Liabilities FY 2019 FY 2020 $ Change FY 2019 FY 2020

Retiree Benefits $ 51,865 47,205 $ 4,660 $ 48.6% 44.5%

Short-Term Debt 0 3,000 3,000 0.0% 2.6%

Deferred Revenue-Prepaid Postage 2,225 2,489 264 2.3% 2.1%

Other Current Liabilities 16,852 21,821 4,969 17.3% 18.7%

 Total Current Liabilities 66,282 79,175 12,893 68.2% 67.9%

Workers' Compensation Costs, Noncurrent 17,170 18,754 1,584 17.7% 16.1%

Long-Term Debt 11,000 11,000 0 11.3% 9.4%

Other Noncurrent Liabilities 2,713 7,683 4,970 2.8% 6.6%

 Total Noncurrent Liabilities 30,883 37,437 6,554 31.8% 32.1%

Total Liabilities 97,165 $ 116,612 $ 19,447 $ 100.0% 100.0%

% of Total Assets

% of Total Liabilities
31 

At the end of FY 2020, total assets increased by $10.3 billion compared to the prior period, 

driven by increases in cash and the addition of operating lease rights, recorded as a 

noncurrent asset. Current assets are the sum of cash and cash equivalents, receivables and 

supplies, and prepayments, easily converted to cash for financing operations. Noncurrent 

assets, mainly buildings and equipment (capital assets), are more difficult to convert to 

cash in the short term. 

At the end of FY 2020, the Postal Service had increased its cash balance by $5.5 billion 

compared to FY 2019, primarily resulting from $3 billion issuances of notes payable during 

FY 2020 and a deferral of approximately $1.2 billion in payments for the Postal Service’s 

share of Social Security benefits.54 Noncurrent assets increased by $4.8 billion resulting 

from the Postal Service’s adoption of Accounting Standards Codification (ASC) 842 on 

October 1, 2019, which requires most leases to be recorded on the balance sheet as both a 

lease liability for the obligation to make lease payments and a right-of-use asset for the 

right to use the underlying asset for the lease term.55

Liabilities at the end of FY 2020 totaled $116.6 billion, 68 percent of which were current 

liabilities. Current liabilities are obligations that will come due within one year, while 

noncurrent liabilities are long-term financial obligations. Current liabilities consist largely of 

missed payments for statutory RHB prefunding and 

amortization of unfunded RHB liabilities, and 

defaulted payments for amortization of unfunded 

CSRS and FERS liabilities. The Postal Service 

continued to accrue unpaid retirement expenses, 

which totaled $51.9 billion at the end of FY 2020. 

This includes accruals for FY 2012 through FY 2016, 

when the Postal Service could not pay down the 

liability along with the amortization payments on the 

RHB unfunded liability. This obligation is 65.5 percent of current liabilities. Additionally, at 

the end of FY 2020, the Postal Service had an additional $3 billion in short-term debt 

compared to FY 2019. Long-term liabilities consist mainly of workers’ compensation liability 

($18.8 billion) and the total net debt owed to the Federal Financing Bank ($11 billion). 

On the Balance Sheets, net deficiency represents the difference between total assets and 

total liabilities. This indicates whether assets were financed by borrowing (liability) or by 

capital contributions and accumulated earnings from prior years. Net deficiency occurs 

when liabilities are greater than assets. 

At the end of FY 2020, the Postal Service recorded an $80.7 billion net deficit consisting of 

an accumulated deficit of $83.8 billion offset by capital contributions of $3.1 billion. This is 

primarily the result of multiple years of net losses, starting in FY 2007. 

 

54 Under the CARES Act, payment for the employer share of Social Security benefits through December 31, 2020 are deferred until December 

31, 2021 and December 31, 2022. Postal Service Form 10-K at 50. 

55 Id. at 65.

At the end of FY 2020, the 

Postal Service recorded an 

$80.7 billion net deficit. 
32 

Figure II-6 shows the mix of the Postal Service’s asset and liability structure as of 

September 30, 2020. The shortage of current assets (45.4 percent of total assets) to cover 

current liabilities (68 percent of total liabilities) adversely affects the Postal Service’s 

financial condition. The Postal Service does not have a sufficient amount of current assets 

to pay for current liabilities, including the congressionally mandated retirement health 

benefit payments that the Postal Service accumulated in years FY 2012 through FY 2017. 

Non-current assets comprise 54.6 percent of total assets, while non-current liabilities only 

comprise 32.1 percent of total liabilities. 

Figure II-6 

Comparison of Postal Service’s FY 2020 Current and Noncurrent Assets and Liabilities 

Source: PRC derived from Postal Service FY 2020 Form 10-K at 59. 

Working capital is the difference between current assets and current liabilities. Negative 

working capital indicates an excess of current liabilities over current assets. In FY 2020, the 

Postal Service’s working capital was negative $62.9 billion. 

During FY 2020, total assets increased by $10.3 billion, primarily due to a $5.5 billion 

increase in the cash balance. The increase in cash resulted from the issuance of notes 

payable due to the Federal Financing Bank, deferral of employer contributions of social 

security, nonpayment of retiree benefits amortization and normal cost, and increased 

revenue from additional shipping and package volume. Total liabilities increased by a net 

of $9.2 billion mainly due to personnel-related liabilities, such as the accrual of the unpaid 

retirement expenses for FY 2020 and the issuance of notes payable. 
33 

Assets

Postal Service capital investments have not kept pace 

with depreciation and amortization since 2008. Aging 

capital assets and the continued restrictions on capital 

investment resulted in a depreciation expense in excess of 

investments from FY 2008 to FY 2019, and fixed assets 

have declined by $9.2 billion over that period. The Postal 

Service reduced its capital expenditures from an annual 

average of approximately $1.5 billion in FY 2009 through 

FY 2011 to an annual average of approximately $850 

million in FY 2012 through FY 2015, a reduction of 

approximately 43 percent. From FY 2015 through FY 

2019, capital expenditures to upgrade its facilities, 

equipment, and vehicle fleet increased to an annual 

average of approximately $1.4 billion. 

Figure II-7 

Percent Change in Capital Assets, FY 2010–FY 2020 

 

Source: PRC derived from Postal Service Form 10-K, FY 2006–FY 2020. 

FY 2020 was the first year that the Postal Service recorded positive growth in capital assets 

since FY 2007. The Postal Service recorded a 1.5 percent growth in capital, compared to the 

negative growth of 1.8 percent in FY 2019. The Postal Service purchased $1.8 billion in 

property and equipment, offset by $1.7 billion in depreciation. 

While the Postal Service 

continues to limit its capital 

expenditures, FY 2020 was 

the first year since FY 2007 

that the Postal Service 

recorded growth in capital 

assets. 
34 

The Postal Service continues to limit its capital expenditures to necessary safety, customer 

support, and high-return investments.56 During FY 2020, the Postal Service purchased 

9,500 new vehicles at an approximate cost of $0.4 billion.57 According to the Postal Service, 

its delivery fleet includes approximately 140,000 vehicles that are at least 20 years old and 

require significant maintenance.58

Liabilities 

In FY 2020, total liabilities increased by $19.4 billion, largely due to higher balances in 

retirement-related liabilities, a $3.0 billion balance of the current portion of debt, and 

noncurrent operating lease liabilities. 

The long-term portion of workers’ compensation increased by $1.6 billion in FY 2020. This 

is highly sensitive to discount and inflation rates in actuarial adjustment and to new and 

existing claims. Figure II-8 shows the current breakdown of the Postal Service’s liabilities 

as of September 30, 2020. 

Figure II-8 

Postal Service Liabilities Structure, September 30, 2020 

Source: PRC derived from Postal Service FY 2020 Form 10-K at 59. 

In addition to the liabilities recorded on the Postal Service’s Balance Sheets, there are other 

liabilities not recognized in the Postal Service’s financial statements. These liabilities are 

controlled and administered by OPM and relate to the assets and liabilities attributed to the 

 

56 Postal Service FY 2020 Form 10-K at 41. 

57 Id. at 47. 

58 Id.
35 

CSRDF and the RHBF.59 The CSRDF provides pension benefits to retired and disabled 

Federal employees, including Postal Service employees covered by CSRS and FERS.60

In addition, the PAEA requires the Postal Service to report certain disclosures provided by 

OPM regarding the funded status of the CSRDF, specifically for postal employees and the 

Postal Service RHBF, reported on the Postal Service Form 10-K statements. 

Balance Sheet Trend Analysis 

To facilitate its analysis, the Commission applies key financial ratios to the Postal Service’s 

Balance Sheet to further assess the current and historical financial stability of the Postal 

Service. Table II-17 summarizes the key balance sheet ratios used in this analysis. 

Table II-17 

Postal Service Balance Sheet Ratios FY 2019 and FY 2020 

 Source: PRC derived from Postal Service FY 2020 Form 10-K. 

DEBT RATIO 

Debt ratio is the percentage of total liabilities an entity has on its balance sheet to its total 

assets. The higher the ratio, the greater the risk that the entity’s debt level may impede its 

ability to respond to challenges and opportunities effectively. Figure II-9 reflects the Postal 

Service’s debt ratio trend since FY 2006.

 

59 See 5 U.S.C. § 8909a. 

60 See 5 U.S.C. § 8348. 

FY 2019 FY 2020 Change

Debt Ratio 3.79 3.25 (0.54) Current Ratio 0.16 0.21 0.04 Cash Ratio 0.14 0.19 0.05
36 

Figure II-9 

Debt Ratio, FY 2006–FY 2020

Source: PRC derived from Postal Service Form 10-K, FY 2006–FY 2020. 

The ratio is generally a conservative measurement because the liabilities are carried at 

estimated amounts of expected cash outflows. At the same time, some assets may be 

understated because no adjustments have been made to restate for fair value. For example, 

land or a fully depreciated building or equipment may have a higher fair market value than 

its book value. As it pertains to the Postal Service, the debt ratio provides information 

about the increasing amount of the Postal Service’s liabilities relative to its small asset base. 

At the end of FY 2020, the debt ratio decreased to 3.25 from the 3.79 debt ratio for FY 2019. 

The decrease is the result of the higher growth of total assets and comparatively slower 

growth in total liabilities. The Postal Service’s FY 2020 debt ratio was higher than the 

average 10-year debt ratio of 2.87. This ratio is indicative of the Postal Service’s insufficient 

resources to invest in capital and pay down its liabilities. 

 
37 

CURRENT RATIO 

The current ratio indicates the degree to which current assets meet current liabilities. The 

higher the current ratio, the more likely an entity can pay its current liabilities because it 

has a larger proportion of current assets relative to its current liabilities. Figure II-10 

highlights the fluctuations in the current ratio since FY 2006. 

Figure II-10 

Current Ratio, FY 2006–FY 2020 

Source: PRC derived from Postal Service Form 10-K, FY 2006–FY 2020. 

At the end of FY 2020, the Postal Service had a current ratio of 0.21, an increase of 0.05 

from the end of FY 2019. This is higher than the Postal Service’s ten-year average of 0.15. 

The increase in the ratio resulted from a smaller increase in current liabilities compared to 

current assets. Current liabilities increased by $12.9 billion (19.5 percent) due to higher 

retirement liabilities and a $3 billion increase in short-term debt. Current assets increased 

by $5.5 billion (50.9 percent) compared to the end of FY 2019 as a result of an increase in 

cash. It is worth noting that approximately $1.2 billion included in the FY 2020 cash 

balance is a deferred payment due within the next two years. 

The reduction of statutory prefunding payments in FY 2009 resulted in a higher current 

ratio. A combination of increasing current liabilities and increasing cash has helped the 

current ratio remain relatively flat. 
38 

CASH RATIO 

The cash ratio compares total liquid assets to its current liabilities. The ratio measures an 

entity’s ability to pay current liabilities with available cash or cash equivalents. Figure II-11 

illustrates the cash ratio from FY 2006 through FY 2020. 

Figure II-11 

Cash Ratio, FY 2006–FY 2020 

 Source: PRC derived from Postal Service Form 10-K, FY 2006–FY 2020. 

The Postal Service had a cash ratio of 0.19 at the end of FY 2020. This is an increase 

compared to the prior year’s cash ratio of 0.14. The FY 2020 cash ratio is also higher than 

the 10-year average of 0.12. This increase is the result of a $5.6 billion increase in cash 

compared to FY 2019. In FY 2008 and FY 2009, the Postal Service’s cash balances increased 

by $533 million and $2.7 billion, respectively, which increased the cash ratio. During FY 

2011 through FY 2019, the Postal Service’s cash balance gradually increased along with its 

current liabilities. 
39 

Analysis of Statements of Cash Flows 

At the end of FY 2020, the Postal Service’s total cash and cash equivalents, excluding $0.3 

billion in restricted cash, was $14.4 billion. Cash and cash equivalents excluding restricted 

cash were $5.6 billion higher than at the end of FY 2019. At the end of FY 2020, the Postal 

Service had $1 billion in available borrowing authority remaining from the PAEA-mandated 

debt ceiling of $15 billion. Table II-18 compares the Postal Service’s cash flows from FY 

2012 to FY 2020. 

Table II-18 

Postal Service Statements of Cash Flows, FY 2012–FY 2020 ($ in Millions)

Numbers may not add across due to rounding. 

Source: PRC derived from Postal Service Form 10-K, FY 2012–FY 2020. 

Table II-19 illustrates the current liquidity position of the Postal Service. The Postal 

Service’s liquidity is limited to cash and cash equivalents (excluding restricted cash) and 

available borrowing authority. During FY 2020, the Postal Service was issued $3 billion in 

short-term debt from its revolving credit facility payable in April 2021. An additional $11 

billion, consisting of fixed-rate and floating-rate notes with various maturities, is recorded 

as long-term debt.61 

As a result of the CARES Act, the Postal Service is allowed access to an additional $10 billion 

from the U.S. Treasury to fund operating expenses. This additional financing is subject to 

terms and conditions as agreed upon by the Postal Service and the U.S. Treasury.62

 

61 Postal Service FY 2020 Form 10-K at 48. 

62 In January 2021, the Postal Service and the U.S. Treasury agreed to the terms and conditions, as amended by the Consolidated Appropriations 

Act, 2021 that allow the Postal Service to request up to $10 billion in funding from the U.S. Treasury for COVID-19 related expenses that will not 

need to be repaid. Postal Service Quarter 1, 2021 Form 10-Q, February 9, 2021, at 9. 

FY FY FY FY FY FY FY FY FY

2012 2013 2014 2015 2016 2017 2018 2019 2020

Net Income/(Loss) (15,906) $ (4,977) $ (5,508) $ (5,060) $ (5,591) $ (2,742) $ (3,913) $ (8,813) $ (9,176) $ 

Non-Cash Items and Other Cash Flows 15,475 5,911 8,822 8,327 7,939 6,565 6,680 11,278 13,545 Cash Flows From Investing Activities: 0 0 0 0 0 0 0 0 0

 Decrease (Increase) in Restricted Cash (28) (79) 66 (20) 13 (38) 16 (91) 12 Purchase of Property and Equipment (705) (667) (781) (1,428) (1,222) (1,344) (1,409) (1,419) (1,810) 

 Proceeds From Sale of Property and Equipment 148 158 129 206 120 58 32 27 32 Net Cash Used in Investing Activities (588) (585) (586) (1,089) (1,242) (1,324) (1,361) (1,483) (1,766) Cash Flows From Financing Activities: 0 0 0 0 0 0 0 0 0

 Increase (Decrease) in Debt 1,200 0 0 0 0 0 (1,800) 1,800 3,000 

 Payments for Capital Leases (51) (59) (58) (51) (62) (63) (58) (48) (40) Net Change in Revolving Credit Line 800 0 0 0 0 0 0 0 (4,000)

 U.S. Government Appropriations - Expensed (129) (48) (90) 0 0 0 0 0 0

Net Cash (Used) Provided by Financing Activities 1,820 (107) (148) (51) (62) (63) (1,858) (2,248) 2,960 Net Increase/(Decrease) in Cash 804 803 2,580 1,443 1,728 2,436 (452) (1,266) 5,563 Cash Balance Beginning of Year 1,283 1,283 2,326 6,634 4,906 8,077 10,513 10,061 8,795 Cash Balance End of Year 2,087 $ 2,086 $ 4,906 $ $ 8,077 6,634 $ 10,513 $ 10,061 $ 8,795 $ 14,358 $ 

Debt Outstanding 15,000 $ 15,000 $ 15,000 $ $ 15,000 15,000 $ 15,000 $ 13,200 $ 11,000 $ 14,000 $ 
40 

Table II-19 

Total Postal Service Liquidity (in $ Millions) 

End of FY 2019 Compared to FY 2020 

 Source: Postal Service FY 2020 Form 10-K at 59 and 69. 

CASH FLOW RATIO ANALYSIS 

Cash flow ratios are applied in the Commission’s analysis to illustrate the Postal Service's 

financial solvency. The asset efficiency ratio, current liability ratio, and long-term debt ratio 

are all helpful indicators of the Postal Service’s current and historical ability to pay down 

debt and remain financially solvent. 

Table II-20 

Cash Flow Ratios, FY 2019 and FY 2020 

Source: PRC derived from Postal Service FY 2020 Form 10-K 

Figure II-12 shows all three ratios and their trends since FY 2006. 

FY 2019 FY 2020

Cash and Cash Equivalents 8,795 $ 14,358 $ 

Current Portion of Debt 0 3,000 Long-Term Debt 11,000 11,000 Total Debt 11,000 $ 14,000 $ 

Statutory Debt Limit 15,000 15,000 Available Debt 4,000 1,000 CARES Act Borrowing Authority 0 10,000

Total Liquidity (Cash + Available Debt) 12,795 $ 25,358 $ 

FY 2019 FY 2020 Change

Asset Efficiency Ratio 0.10 0.12 0.03 Cash Flow to Debt Ratio 0.04 0.06 0.02

Long Term Debt Ratio 0.08 0.12 0.04
41 

Figure II-12 

Cash Flow Ratio Trend Analysis FY 2006–FY 2020 

Source: PRC derived from Postal Service Form 10-K, FY 2006–FY 2020. 

The asset efficiency ratio compares operating cash flows to total assets. It measures how 

efficiently an entity uses its assets to generate cash. At the end of FY 2020, the Postal 

Service had an asset efficiency ratio of 0.12, which is slightly higher than the prior year. The 

FY 2020 asset efficiency ratio was 0.05 higher than the historical 10-year average of 0.07. 

Cash flow from operations and total assets increased in FY 2020. From FY 2006 to FY 2011, 

the ratio was quite volatile. The ratio gradually ticked up from FY 2012 through FY 2014 as 

a result of the Postal Service defaulting on RHB liabilities and increases in revenue from 

the exigent surcharge. From FY 2017 through FY 2019, both cash from operations and total 

assets declined slightly, resulting in a relatively flat trend. This ratio illustrates the Postal 

Service’s inability to generate sufficient operating cash, using its total assets. 

The Postal Service had an operating cash flow ratio of 0.06 at the end of FY 2020, which is 

an increase of 0.02 from the prior year and higher than the historical 10-year average. The 

operating cash flow ratio measures an entity's ability to generate cash that can be used to 

cover current debt. In FY 2020, both cash flow from operations and current liabilities 

increased compared to FY 2019. In FY 2007 and FY 2008, the ratio was below zero 

resulting from negative operating cash flows caused by payments to the RHBF. FY 2012 

was the first year the Postal Service defaulted on its RHB payment, which increased cash 

from operations and increased current liabilities. Since FY 2012, the Postal Service has 

been unable to pay down its unfunded retirement liabilities, and the cumulative missed 

payments increase the current liability on the balance sheet. The increase in operating cash 
42 

from these defaulted payments was not enough to offset revenue loss from declining 

volume, resulting in a relatively flat increase in operating cash and gradually increasing 

current liabilities. 

The long-term debt ratio compares the Postal Service’s cash from operations to its longterm debt. It illustrates the Postal Service’s ability to pay down long-term debt using cash it 

generates from operations. Long-term debt includes non-current workers’ compensation 

expense and non-current portions of debt owed to the Federal Financing Bank. At the end 

of FY 2020, the Postal Service had a long-term debt ratio of 0.12, an increase of 0.04 from 

the end of FY 2019. Although cash increased, the Postal Service remains unable to generate 

sufficient cash to pay down its total debt. 
43 

Chapter III. Volume, Revenue, and Cost 

Trends 

Overview 

This chapter presents an in-depth analysis of volume, revenue, and cost trends in three 

sections. 

The first section describes the calculation of attributable cost and institutional cost and 

notes methodological changes implemented in FY 2020, with significant cost impacts. It 

also examines the overall trends for Market Dominant and Competitive products and 

services. 

The second and third sections analyze Market Dominant (organized by class) and 

Competitive products, respectively. These sections contain analyses that compare volume, 

revenue, and cost between FY 2019 and FY 202063; trend analyses that highlight changes in 

volume, revenue, and cost that have occurred over the last 10 years; and analyses by cost 

segment. 

Overall Volume, Revenue, and Cost Trends 

Attributable and Institutional Cost Calculation 

39 U.S.C. § 3622(c)(2) defines attributable cost as the “direct and indirect postal costs 

attributable to each class or type of mail service through reliably identified causal 

relationships plus that portion of all other costs of the Postal Service reasonably assignable 

to such class or type[.]” In Order No. 3506, the Commission determined that attributable 

product costs include volume-variable costs,64 which, in the aggregate, increase as volume 

increases and decrease as volume decreases; product-specific fixed costs, which are costs 

caused by a specific product but do not vary with volume; and inframarginal costs 

developed as part of the estimation of each product’s incremental costs.65 Attributable 

costs for classes and Competitive products collectively also include group-specific costs, 

which are costs caused by a group of products in combination rather than by an individual 

product, and inframarginal costs developed as part of the estimation of incremental costs 

for classes and Competitive products collectively. Attributable costs are equal to 

 

63 FY 2019 volume, revenue, and cost data that are not depicted in tables in this section can be found in the corresponding section of the FY 

2019 Financial Report. 

64 Total volume-variable cost is calculated by multiplying total cost by the volume variability ratio for each cost segment. 

65 Docket No. RM2016-2, Order Concerning United Parcel Service, Inc.’s Proposed Changes to Postal Service Costing Methodologies (UPS 

Proposals One, Two, and Three), September 9, 2016 (Order No. 3506). 
44 

incremental costs, which reflect the total marginal costs of the volume in a class, or a 

product, or Competitive products collectively.66

The Commission intends to provide insight into the cost of the activities performed in 

handling mailpieces and analyze changes in cost for certain cost segments. Attributable 

cost is distributed to products using distribution keys that reflect the underlying cost 

driver.67 These costs are piggybacked to include the indirect costs of each activity. 

Institutional cost cannot be attributed to a specific product or service, a class, or 

Competitive products collectively and is equal to total accrued cost minus total attributable 

cost. While sometimes referred to as “fixed cost,” it is more accurately characterized as 

“common cost” because it includes costs that are variable but not causally related to an 

individual product, class, or Competitive products collectively. Institutional cost includes 

costs for carrier network travel time, amortization of RHB unfunded liability, amortization 

of CSRS unfunded liability apportioned to prior years, and various administrative costs. 

Methodological Changes 

In FY 2020, two methodological changes significantly shifted costs between products. The 

Commission approved a change to the cost attribution procedures for Special Purpose 

Routes (SPRs). That methodological change shifted costs for city carrier activities from 

letter and flat-shaped mail to packages, and consequently, from Market Dominant products 

to Competitive products.68 

The Commission also approved a change to the In-Office Cost System (IOCS) methodology 

for sampling city carriers. This change increased attributable costs overall, but primarily 

for domestic Competitive Mail and Services. However, for some products, including FirstClass Mail Single-Piece Letters and Cards, USPS Marketing Mail Flats, and USPS Marketing 

Mail Parcels, the methodological change resulted in a significant decrease in attributable 

costs.69 

Market Dominant Products and Services 

Table III-1 illustrates the changes in total volume, revenue, attributable cost, and 

contribution to institutional cost for Market Dominant products and services between FY 

2019 and FY 2020. 

 

66 Incremental costs are sub-additive, meaning that the sum of the attributable costs of all products in a class is not equal to the attributable 

cost of the class as a whole. The Postal Service generally exhibits declining marginal costs. As a result, the incremental cost of a class includes 

additional inframarginal costs that are not included in the incremental cost of the individual products within the class. For this reason, product 

attributable costs do not add to total attributable cost in Tables III-20, III-23, and III-25. 

67 The Postal Service assigns these costs to each product according to methodologies approved by the Commission. Changes to those 

methodologies are reviewed by the Commission in informal rulemaking proceedings, and members of the general public are given the 

opportunity to comment in such proceedings. 

68 See Docket No. RM2019-6, Proposal One, Order No. 5405, January 14, 2020. 

69 See Docket No. RM2020-10, Proposal Three, Order No. 5405, September 25, 2020. 
45 

Table III-1 

Market Dominant Volume, Revenue, and Cost, FY 2019 and FY 2020 

 

Negative values are denoted by (). 

Source: Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LR-ACR2020/1. 

Market Dominant volume and revenue have been declining for several years, as customers 

moved from traditional paper communication and correspondence to electronic 

alternatives.70 In FY 2020, the COVID-19 pandemic further exacerbated the decline, forcing 

many businesses to close or reduce their operations. Total Market Dominant revenue 

decreased by 8.7 percent in FY 2020 due to the decrease in Market Dominant volume. On a 

unit basis, revenue increased from $0.33 per piece in FY 2019 to $0.34 in FY 2020. 

Total attributable cost for Market Dominant products decreased by 6.8 percent from FY 

2019. However, the average unit attributable cost increased from $0.21 per piece in FY 

2019 to $0.22 in FY 2020. 

Total Market Dominant contribution to institutional cost decreased by $2.0 billion, or 11.9 

percent in FY 2020, as Market Dominant volume decreased by 14.8 billion pieces, or 10.8 

percent. 

Market Dominant products accounted for 94.5 percent of total mail volume, a drop of 1.5 

percentage points from FY 2019. Revenue from these products as a percentage of total 

revenue from mail and services decreased from 64.2 percent to 57.1 percent. Market 

Dominant attributable cost as a percentage of total attributable cost decreased from 64.3 

percent in FY 2019 to 58.0 percent in FY 2020. 

Several Market Dominant products failed to generate sufficient revenue to cover 

attributable cost, resulting in negative contributions for these products. The total negative 

contribution to institutional cost from these products amounted to $1.8 billion in FY 2020; 

in FY 2019, the negative contribution from these 

products was $1.7 billion. Eight domestic mail 

products and services failed to cover their 

attributable cost: USPS Marketing Mail Flats ($780.0 

million), USPS Marketing Carrier Route ($53.6 

million), USPS Marketing Mail Parcels ($15.3 

million), Periodicals Outside County ($725.3 million), 

Periodicals In-County ($48.8 million), Package 

 

70 Postal Service FY 2020 Form 10-K at 23.

 FY 2019 FY 2020 % Change

Volume (Millions) 136,897 122,054 (10.8%)

Revenue ($ Millions) 45,695 41,731 (8.7%)

Attributable Cost ($ Millions) 28,891 26,922 (6.8%)

Contribution to Institutional Cost ($ Millions) 16,804 14,809 (11.9%)

The Postal Service lost $1.8 

billion from underwater 

products in FY 2020. 
46 

Services Bound Printed Matter Parcels ($18.6 million) Package Services Media 

Mail/Library Mail ($91.2 million), and Money Orders ($3.7 million). In addition, Inbound 

Letter Post had a negative contribution in FY 2020. 

Market Dominant Volume Trends 

Figure III-1 shows the total volume for Market Dominant products over the last 10 years. 

Over the last decade, volume for Market Dominant products declined by 47.1 billion pieces. 

Figure III-1 

Market Dominant Volume, FY 2011–FY 2020

Source: Docket No. ACR2011, Library Reference USPS-FY11-1, December 29, 2011; Docket No. ACR2012, Library Reference USPSFY12-1, December 28, 2012; Docket No. ACR2013, Library Reference USPS-FY13-1, December 27, 2013; Docket No. ACR2014, 

Library Reference USPS-FY14-1, December 29, 2014; Docket No. ACR2015, Library Reference USPS-FY15-1, December 29, 2015; 

Docket No. ACR2016, Library Reference USPS-FY16-1, December 29, 2016; Docket No. ACR2017, Library Reference USPS-FY17-1, 

December 29, 2017; Docket No. ACR2018, Library Reference USPS-FY18-1, December 28, 2018; Library Reference USPS-FY19-1, 

December 27, 2019; Library Reference USPS-FY20-1, December 29, 2020, (collectively, Postal Service CRA Report, FY 2011–FY 

2020).
47 

In FY 2020, First-Class Mail and USPS Marketing Mail 

accounted for 96.0 percent of total Market Dominant 

volume. First-Class Mail volume has declined every year 

over the last decade, resulting in a loss of 25.9 billion 

pieces, representing a 33.0 percent loss in volume. USPS 

Marketing Mail volume has also declined considerably 

over the last decade. The loss in USPS Marketing Mail 

volume in FY 2020 was far larger than in previous years, 

accounting for 62.7 percent of the 18.3 billion pieces lost 

over the last 10 years. 

Market Dominant Revenue and Cost Trends 

Total Market Dominant revenue and attributable cost have also declined over the past 

decade. Figure III-2 compares annual revenue and attributable cost from FY 2011 to FY 

2020. Over that period, total revenue declined by 21.9 percent while total attributable cost 

declined by 17.0 percent. 

Figure III-2

Market Dominant Revenue and Attributable Cost, FY 2011–FY 2020 

Source: FY 2011–FY 2013 ACD; Docket No. ACR2014, Library Reference PRC-LR-ACR2014/1; Docket No. ACR2015, Library Reference PRC-LRACR2015/1; Docket No. ACR2016, Library Reference PRC-LR-ACR2016/1; Docket No. ACR2017, Library Reference PRC-LR-ACR2017/1; Docket 

No. ACR2018, Library Reference PRC-LR-ACR2018/1; Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LRACR2020/1. 

 

First-Class Mail volume 

has declined every year 

over the last decade, 

resulting in a loss of 

25.9 billion pieces. 
48 

Competitive Products and Services 

The COVID-19 pandemic caused a surge in e-commerce, resulting in higher Competitive 

product volume in FY 2020.71 Revenue for Competitive products also increased 

significantly. Table III-2 compares the total volume, revenue, and cost of these products 

and services between FY 2019 and FY 2020. 

Table III-2 

Competitive Volume, Revenue, and Cost, FY 2019 and FY 2020 

 

Source: Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LR-ACR2020/1. 

Volume for Competitive products grew 25.7 percent in FY 2020 compared with 0.2 percent 

in FY 2019. In FY 2020, both revenue and unit revenue increased. Revenue increased by 26.5 

percent, or $6.4 billion, while unit revenue 

increased by 0.6 percent. Attributable cost 

increased by 21.7 percent in FY 2020; however, 

on a unit basis, attributable cost decreased by 

3.2 percent, primarily due to a change in mail 

mix. Contribution to institutional cost also 

increased, both in the aggregate and on a unit 

basis. In FY 2020, contribution to institutional 

cost increased by 35.6 percent and 7.9 percent 

on a unit basis. 

As shown in Figure III-3, the Competitive 

products’ share of total Postal Service revenue and attributable cost has increased more 

than 20 percentage points since FY 2011. Competitive products’ share of contribution to 

institutional cost has also steadily increased from just 7.8 percent in FY 2011 to 42.0 

percent in FY 2020. 

 

 

71 Postal Service FY 2020 Form 10-K at 21.

FY 2019 FY 2020 % Change

Volume (Millions) 5,672 7,130 25.7%

Revenue ($ Millions) 24,207 30,611 26.5%

Attributable Cost ($ Millions) 15,960 19,426 21.7%

Contribution to Institutional Cost ($ Millions) 8,247 11,185 35.6%

Competitive products’ share of 

contribution to institutional 

cost has steadily increased 

from just 7.8 percent in FY 2011 

to 42.0 percent in FY 2020. 
49 

Figure III-3 

Competitive Percent Share of Total Postal Service Revenue, Cost, 

and Contribution to Institutional Cost, FY 2011–FY 2020

Source: Docket No. ACR2010, Library Reference USPS-FY10-1, December 29, 2010; Docket No. ACR2011, Library Reference USPS-FY11-1, 

December 29, 2011; Docket No. ACR2012, Library Reference USPS-FY12-1, December 28, 2012; Docket No. ACR2013, Library Reference USPSFY13-1, December 27, 2013; Docket No. ACR2014, Library Reference USPS-FY14-1, December 29, 2014; Docket No. ACR2015, Library 

Reference USPS-FY15-1, December 29, 2015; Docket No. ACR2016, Library Reference USPS-FY16-1, December 29, 2016; Docket No. ACR2017, 

Library Reference USPS-FY17-1, December 29, 2017; Docket No. ACR2018, Library Reference USPS-FY18-1, December 28, 2018; Docket No. 

ACR2019, Library Reference USPS-FY19-1, December 27, 2019; Library Reference USPS-FY20-1, December 29, 2029 (collectively, Postal Service 

CRA Report, FY 2011–FY 2020). 

Figure III-4 illustrates the changes in average unit revenue and cost from FY 2011 to FY 

2020. Competitive products are required to cover their required contribution to 

institutional cost collectively.72 Figure III-4 shows the minimum required contribution as 

an average cents per piece. Since FY 2011, average unit revenue for Competitive products 

and services exceeded the combined average unit attributable cost and required 

contribution per piece. 

 

 

72 See Docket No. RM2017-1, Order Adopting Final Rules Relating to the Institutional Cost Contribution Requirement for Competitive Products, 

January 3, 2019 (Order No. 4963). On April 14, 2020, the United States Court of Appeals for the District of Columbia remanded Order No. 4963 

to the Commission for further explanation. United Parcel Serv. v. Postal Regulatory Comm’n, No. 19-1026 (D.C. Cir. Apr. 14, 2020). Order No. 

4963 prescribed the formula for determining the appropriate share. Docket No. RM2017-1, Order Adopting Final Rules Relating to the 

Institutional Cost Contribution Requirement for Competitive Products, January 3, 2019 (Order No. 4963). The Commission is reviewing the 

court’s decision to determine its next actions with respect to this issue. 
50 

Figure III-4 

Competitive Average Unit Revenue and Cost, FY 2011–FY 2020 

Source: Postal Service CRA Report, FY 2011–FY 2020.

Through FY 2020, total contribution to institutional cost from Competitive products 

continued to exceed the required contribution to institutional cost.73 As shown in Figure 

III-5, the contribution from Competitive products has increased significantly in recent 

years. However, the increase in FY 2020 is particularly large compared with other years. 

Previous large increases in the share of institutional cost contributed by Competitive 

products resulted primarily from Market Dominant products transferred to the 

Competitive product list. 

 

 

73 See Docket No. RM2017-1, Order Adopting Final Rules Relating to the Institutional Cost Contribution Requirement for Competitive Products, 

January 3, 2019 (Order No. 4963). 
51 

Figure III-5 

Competitive Contribution to Institutional Cost, FY 2011–FY 2020 

Source: FY 2011–FY 2013 ACD; Docket No. ACR2014, Library Reference PRC-LR-ACR2014/1; Docket No. ACR2015, Library Reference PRC-LRACR2015/1; Docket No. ACR2016, Library Reference PRC-LR-ACR2016/1; Docket No. ACR2017, Library Reference PRC-LR-ACR2017/1; Docket 

No. ACR2018, Library Reference PRC-LR-ACR2018/1; Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LRACR2020/1. 

Market Dominant Volume, Revenue, and Cost 

Trends by Class 

First-Class Mail 

There are five products assigned to First-Class Mail: Single-Piece Letters/Postcards; 

Presorted Letters/Postcards; Flats; Outbound Single-Piece First-Class Mail International; 

and Inbound Letter Post. For comparison purposes in this report, the products are grouped 

into letters, flats, and “all other.”74

FIRST-CLASS MAIL LETTERS COMPARED WITH FY 2019 

Table III-3 summarizes the FY 2020 change in total volume and revenue for First-Class Mail 

letters. First-Class Mail letters volume declined considerably in FY 2020, after more 

moderate declines in previous years. For single-piece letters, the decline rate was 7.9 

 

74 “All other” includes single-piece and presorted postcards, Outbound Single-Piece First-Class Mail International, Inbound Letter Post, and 

Inbound International negotiated service agreements (NSAs). 
52 

percent compared to less than 6 percent in the preceding 3 years. Presorted letters volume 

decreased 3.0 percent in FY 2020, compared to 1.6 percent in FY 2019. 

Total revenue for First-Class Mail letters decreased by 2.6 percent in FY 2020 due to 

volume loss. Unit revenue increased slightly from 43 cents per piece in FY 2019 to 44 cents 

in FY 2020. The volume of single-piece letters declined more than presorted letters , 

resulting in a larger decrease in total revenue for single-piece letters than presorted letters, 

3.9 percent and 1.7 percent, respectively. 

Table III-3 

First-Class Mail Letters Volume and Revenue, FY 2019 and FY 2020 

Negative values denoted by (). 

Source: Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LR-ACR2020/1. 

Table III-4 summarizes the FY 2020 change in total attributable cost for First-Class Mail 

letters. Total attributable cost for First-Class Mail letters decreased by $344 million in FY 

2020 due to a sizable decrease in the attributable cost of single-piece letters. The decrease 

in the attributable cost of single-piece letters is primarily due to the decrease in volume. 

However, attributable cost for single-piece letters also decreased slightly on a unit basis, in 

large part, due to methodological changes implemented in FY 2020 that changed the 

attribution of city carrier costs. The following section further discusses these changes in 

detail. 

Table III-4 

First-Class Mail Letters Attributable Cost and Average Unit Attributable Cost 

FY 2019 and FY 2020 

Source: Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LR-ACR2020/1. 

FY 2019 FY 2020 FY 2019 FY 2020

Single-Piece 15,954 14,696 (1,258) (7.9%) 8,347 8,020 (327) (3.9%)

Presorted 35,207 34,167 (1,040) (3.0%) 13,725 13,488 (236) (1.7%)

Total Letters 51,161 48,863 (2,299) (4.5%) 22,071 21,508 (563) (2.6%)

(Millions) ($ in Millions)

Mail Volume Mail Revenue

Increase or 

Decrease

Percent 

Change

Percent 

Change

Increase or 

Decrease

FY 2019 FY 2020 FY 2019 FY 2020

Single-Piece 5,273 4,826 (447) (8.5%) 32.8 33.0 (0.2) (0.6%)

Presorted 4,678 4,781 103 2.2% 14.0 13.3 0.7 5.3%

Total Letters 9,951 9,607 (344) (3.5%) 19.7 19.4 0.2 1.1%

Increase or 

Decrease

Increase or 

Decrease

($ in Millions) (Cents per Piece) Percent 

Change

Percent 

Change

Attributable Cost Unit Attributable Cost
53 

TRENDS IN FIRST-CLASS MAIL LETTERS 

Although customer “migration toward electronic communication and transaction 

alternatives” has been eroding First-Class Mail letters volume for some time, the Covid-19 

pandemic accelerated the loss in volume in FY 2020.75 Figure III-6 illustrates the rate of 

decline for First-Class Mail letters volume. In FY 2020, the decline rate for Single-Piece 

letters increased after decreasing in FY 2019 and FY 2018. Over the last decade, the volume 

of First-Class Mail presorted letters has decreased every year. The decline rate for FirstClass Mail presorted letters volume increased to 3.0 percent in FY 2020, representing the 

greatest decline since FY 2013. 

Figure III-6 

First-Class Mail Letters Percent Change in Volume, FY 2011–FY 2020 

Source: Docket No. ACR2011, Library Reference USPS-FY11-42, December 29, 2011; Docket No. ACR2012, Library Reference USPS-FY12-42, 

December 28, 2012; Docket No. ACR2013, Library Reference USPS-FY13-42, December 27, 2013; Postal Service RPW Report, FY 2014–FY 2020 

(collectively, Postal Service RPW Report, FY 2011–FY 2020).

Figure III-7 shows the change in the average unit attributable cost for First-Class Mail 

letters. The average unit attributable cost of First-Class Mail single-piece letters decreased 

for the first time in 5 years, primarily due to the methodological changes that decreased the 

amount of city carrier costs attributed to letter-shaped mail. 

The average unit attributable cost for First-Class Mail presorted letters increased for the 

fourth year in a row. Although the rate of increase in FY 2020 was tempered by the costing 

 

75 Postal Service FY 2020 Form 10-K at 25. 
54 

methodology changes that decreased the city carrier costs attributed to First-Class Mail 

presorted letters, the increase in average unit attributable cost in FY 2020 was the second 

largest over the past decade. 

Figure III-7 

First-Class Mail Letters Percent Change in Average Unit Attributable Cost 

FY 2011–FY 2020 

Source: FY 2011–FY 2013 ACD; Docket No. ACR2014, Library Reference PRC-LR-ACR2014/1; Docket No. ACR2015, Library Reference PRC-LRACR2015/1; Docket No. ACR2016, Library Reference PRC-LR-ACR2016/1; Docket No. ACR2017, Library Reference PRC-LR-ACR2017/1; Docket 

No. ACR2018, Library Reference PRC-LR-ACR2018/1; Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LRACR2020/1. 

Table III-5 compares the average unit attributable cost for presorted letters by cost 

segment for FY 2019 and FY 2020. The unit attributable costs presented include all of the 

indirect cost that is piggybacked to the direct cost.76 The average unit attributable cost for 

the city carrier street and rural carrier cost segments increased substantially in FY 2020, by 

20.6 percent and 18.2 percent, respectively. The mail processing unit cost for presorted 

letters also increased in FY 2020. That increase (4.2 percent), however, is not only smaller 

than the increases for delivery activities but is also more modest than the increase in mail 

processing unit cost in FY 2019. Carrier in-office cost, largely comprised of time spent 

sorting mail for delivery, represents a mail processing activity. The average unit 

attributable cost for carrier in-office cost segment decreased 3.1 percent in FY 2020. As 

previously discussed, city carrier costs were impacted by a methodological change 

implemented in FY 2020. Transportation unit costs decreased by 9.0 percent in FY 2020. 

 

 

76 In addition to the direct costs, there are other “indirect” costs associated with the direct cost component or cost segment. Some examples of 

these indirect costs are Cost Segment 3 Administrative Clerks, Cost Segment 12 Vehicle Service Costs, Cost Segment 15 Rents and Fuel and 

Utilities, and Cost Segment 18 Service-wide Labor Costs (such as, workers’ compensation, etc.). These “indirect” costs are referred to as 

“piggybacked” costs. The unit attributable cost by cost segment presented in this report are “piggybacked” costs, unless stated otherwise. 
55 

Table III-5 

First-Class Mail Presorted Letters Average Unit Attributable Cost by Segment 

FY 2019 and FY 2020 

Source: Docket No. ACR2019, Library Reference USPS-FY19-43, December 27, 2019; Docket No. ACR2020, Library 

Reference USPS-FY20-43, December 29, 2020. 

1

 In the FY 2019 Financial Analysis Report, unit cost for this segment did not include inframarginal cost. 

FIRST-CLASS MAIL FLATS COMPARED WITH FY 2019 

Table III-6 shows the total volume and revenue for First-Class Mail Flats. First-Class Mail 

single-piece flats volume declined 8.3 percent in FY 2020 compared to a 10.4 percent 

decline in FY 2019. First-Class Mail presorted flats volume declined 5.3 percent in FY 2020, 

after a mere 0.1 percent decrease in FY 2019. 

Total revenue for First-Class Mail Flats also declined compared with FY 2019. The decrease 

in FY 2020 is more moderate than the decrease in FY 2019, 6.3 percent versus 13.7 

percent. 

Table III-6 

First-Class Mail Flats Volume and Revenue, FY 2019 and FY 2020 

Negative values denoted by ().

Numbers may not add due to rounding. 

Source: Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LR-ACR2020/1.

Table III-7 summarizes the FY 2020 change in attributable cost. Attributable costs for FirstClass Mail Flats increased both in the aggregate and on a unit basis. The increase in both is 

primarily due to increased costs for single-piece flats, although presorted flats also 

FY 2019 FY 2020

Mail Processing 5.99 5.75 4.2%

City Carrier In-Office 1.60 1.65 (3.1%)

City Carrrier Street 3.06 2.54 20.6%

Rural Carriers 1.08 0.91 18.2%

Transportation1

 1.60 1.76 (9.0%)

All Other 0.66 0.67 (1.0%)

(Cents per Piece) Percent 

Change

Attributable Cost

FY 2019 FY 2020 FY 2019 FY 2020

Single-Piece 741 679 (61) (8.3%) 1,144 1,064 (79) (6.9%)

Presorted 555 525 (29) (5.3%) 509 484 (25) (4.9%)

Total Flats 1,295 1,205 (91) (7.0%) 1,652 1,548 (104) (6.3%)

Mail Volume Mail Revenue

Increase or 

Decrease

Percent 

Change

Increase or 

Decrease

Percent 

Change

(Millions) ($ in Millions)
56 

increased on a unit basis. The average unit attributable cost for single-piece flats and 

presorted flats increased by 12.9 percent and 3.9 percent, respectively. 

Table III-7 

First-Class Mail Flats Attributable Cost and Average Unit Attributable Cost, 

FY 2019 and FY 2020 

Negative values denoted by (). 

Source: Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LR-ACR2020/1.

TRENDS IN FIRST-CLASS MAIL FLATS

First-Class Mail Flats volume has been declining for a number of years. Figure III-8 

compares the percent change in First-Class Mail Flats volume from FY 2011 to FY 2020. 

Over the past decade, First-Class Mail Flats volume decreased by 51.5 percent. Single-piece 

flats volume continued its downward trend in FY 2020 and, although both presorted flats 

and single-piece flats lost volume over the past decade, most of the First-Class Mail Flats 

volume loss occurred in First-Class Mail single-piece flats. Over that period, single-piece 

flats volume decreased 62.5 percent, compared to a 21.6 percent volume decrease for 

presorted flats. Even so, as Figure III-8 shows, the 5.3 percent volume loss for presorted 

flats in FY 2020 was the largest annual loss over the 10-year period.

 

FY 2019 FY 2020 FY 2019 FY 2020

Single-Piece 1,015 1,052 37 3.6% 137.1 154.8 17.7 12.9%

Presorted 498 490 (8) (1.6%) 89.8 93.3 3.5 3.9%

Total Flats 1,513 1,545 31 2.1% 117.0 128.2 11.2 9.6%

($ in Millions) (Cents per Piece)

Attributable Cost Unit Attributable Cost

Increase or 

Decrease

Percent 

Change

Increase or 

Decrease

Percent 

Change
57 

Figure III-8 

Percent Change in First-Class Mail Flats Volume, FY 2011–FY 2020 

Source: PRC derived from Postal Service (RPW Report), FY 2011–FY 2020.

Figure III-9 compares the average unit attributable cost for First-Class Mail single-piece 

and presorted flats since FY 2011. The average unit attributable cost for First-Class Mail 

single-piece flats and presorted flats has steadily increased since FY 2016. In FY 2016, the 

Postal Service corrected an IOCS coding error that shifted costs from First-Class Mail 

presorted flats to First-Class Mail single-piece flats. This resulted in an atypically large 

change in average unit attributable costs for both categories that year. 

 
58 

Figure III-9 

First-Class Mail Flats Average Unit Attributable Cost, FY 2011–FY 2020 

Source: FY 2011–FY 2013 ACD; Docket No. ACR2014, Library Reference PRC-LR-ACR2014/1; Docket No. ACR2015, Library Reference PRC-LRACR2015/1; Docket No. ACR2016, Library Reference PRC-LR-ACR2016/1; Docket No. ACR2017, Library Reference PRC-LR-ACR2017/1; Docket 

No. ACR2018, Library Reference PRC-LR-ACR2018/1; Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LRACR2020/1.

Table III-8 compares the average unit attributable cost by cost segment of First-Class Mail 

single-piece and presorted flats for FY 2019 and FY 2020. With the exception of the city 

carrier street segment for single-piece flats, costs increased in every segment depicted. The 

average unit attributable cost for First-Class Mail single-piece flats exceeded the average 

unit attributable cost for First-Class Mail presorted flats for all cost segments except rural 

carrier. Additionally, except for city carrier street and rural carrier segments, the difference 

between the unit attributable cost for First-Class Mail single-piece flats and First-Class Mail 

presorted flats increased from FY 2019. 

 
59 

Table III-8 

First-Class Mail Flats Average Unit Attributable Cost by Segment 

FY 2019 and FY 2020 

Negative values denoted by (). 

Source: PRC derived from Postal Service CSC Report, FY 2019 and FY 2020. 

OTHER FIRST-CLASS MAIL COMPARED WITH FY 2019 

Table III-9 shows the volume and revenue for “all other” First-Class Mail. Outbound SinglePiece First-Class Mail International, Inbound Letter Post, and Inbound International NSAs 

each decreased considerably in FY 2020. Only Cards volume increased, likely due to volume 

shifting to this product from First-Class Mail Letters. 

Similar to volume, revenue decreased for Outbound Single-Piece First-Class Mail 

International, Inbound Letter Post, and Inbound International NSAs compared with FY 

2019, while Cards revenue increased slightly. Revenue for both inbound categories 

decreased considerably in FY 2020, outpacing decreases in recent years. 

Table III-9 

All Other First-Class Mail Volume and Revenue, FY 2019 and FY 2020 

Negative values denoted by (). 

Source: Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LR-ACR2020/1.

Table III-10 presents the changes in total attributable cost and average unit attributable 

cost for “all other” First-Class Mail between FY 2019 and FY 2020. In FY 2020, attributable 

cost decreased in the aggregate and on a unit basis for both of the inbound international 

products. On a unit basis, attributable cost increased for Outbound Single-Piece First-Class 

Mail International and First-Class Mail cards, 15.9 percent and 3.2 percent, respectively. 

Single-Piece Presort Diff. Single-Piece Presort Diff.

Mail Processing 76.0 51.4 24.6 87.1 51.6 35.5 City Carrier In-Office 14.3 13.2 1.1 16.7 15.1 1.6 City Carrrier Street 8.7 4.7 4.0 8.3 4.8 3.5

Rural Carriers 3.5 3.5 0.0 4.1 4.4 (0.3) Transportation 23.8 13.6 10.2 25.5 14.5 11.0 All Other 10.8 1.3 9.5 13.1 2.9 10.2

Total 137.1 87.7 49.4 154.8 93.3 61.5

Cents per Piece Cents per Piece

FY 2019 FY 2020

FY 2019 FY 2020 FY 2019 FY 2020

Total Cards 2,487 2,566 79 3.2% 711 728 17 2.4%

Outbound Single-Piece First-Class Mail International 126 97 (29) (23.2%) 184 145 (40) (21.7%)

Inbound Letter Post 560 219 (342) (60.9%) 598 223 (376) (62.8%)

Inbound International NSAs 3 1 (2) (67.5%) 245 52 (193) (78.9%)

Total Other First-Class Mail 3,176 2,883 (293) (9.2%) 1,738 1,147 (592) (34.0%)

Mail Volume Mail Revenue

(Millions) ($ in Millions) Increase or 

Decrease

Percent 

Change

Increase or 

Decrease

Percent 

Change
60 

Table III-10 

Other First-Class Mail Attributable Cost and Average Unit Attributable Cost 

FY 2019 and FY 2020 

Negative values denoted by (). 

Source: Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LR-ACR2020/1.

USPS Marketing Mail 

Seven products comprise USPS Marketing Mail: Letters, Flats, Parcels, Carrier Route, High 

Density and Saturation Letters, High Density and Saturation Flats/Parcels, and Every Door 

Direct Mail—Retail (EDDM-R). For comparison purposes, the products have been grouped 

into letters and flats. 

USPS MARKETING MAIL LETTERS COMPARED WITH FY 2019 

Table III-11 summarizes the FY 2020 change in volume and revenue of letter-shaped USPS 

Marketing Mail. Both volume and revenue decreased for letter-shaped USPS Marketing 

Mail. Although volume and revenue were favorably impacted by the increase in political 

and election mail associated with the 2020 general elections,77 the effect of the COVID-19 

pandemic on volume and revenue was overwhelmingly negative. Despite price increases in 

FY 2020,78 the loss of volume for both Letters and High Density and Saturation Letters 

resulted in lower revenue in FY 2020 than in FY 2019. 

 

77 Postal Service FY 2020 Form 10-K at 26.

78 See Docket No. R2020-1, Order No. 5321, Order on Price Adjustments for USPS Marketing Mail, Periodicals, Package Services, and Special 

Services Products and Related Mail Classification Changes, November 22, 2019, and Order No. 5373, Order Approving Price Adjustments and 

Related Mail Classification Changes for First-Class Mail, December 20, 2019. 

FY 2019 FY 2020 FY 2019 FY 2020

Total Cards 360 384 23 6.5% 14.5 14.9 0.5 3.2%

Outbound Single-Piece First-Class Mail International 127 113 (14) (11.0%) 100.4 116.4 16.0 15.9%

Inbound Letter Post 762 267 (495) (65.0%) 136.0 122.0 (14.0) (10.3%)

Inbound International NSAs 38 11 (27) (71.8%) 1,453.9 1,261.1 (192.8) (13.3%)

Total Other First-Class Mail 1,628 774 (854) (52.5%) 51.3 26.9 (24.4) (47.6%)

Attributable Cost Unit Attributable Cost

($ in Millions) (Cents per Piece) Increase or 

Decrease

Percent 

Change

Increase or 

Decrease

Percent 

Change
61 

Table III-11 

USPS Marketing Mail Letters Volume and Revenue, FY 2019 and FY 2020

Negative values denoted by (). 

Source: Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LR-ACR2020/1. 

Table III-12 summarizes the FY 2020 change in attributable cost for USPS Marketing Mail 

letters.79 Overall, attributable cost decreased 6.4 percent for USPS Marketing Mail letters in 

FY 2020. The Covid-19 pandemic affected attributable cost in two ways, it increased costs 

on the unit basis and decreased volume. Since High Density and Saturation Letters is a 

relatively low-volume product compared with USPS Marketing Mail Letters, the average is 

closer to the increase in the attributable cost of USPS Marketing Mail Letters (reduction of 

6.4 percent). On a unit basis, attributable cost for both Letters, and High Density and 

Saturation Letters increased in FY 2020, 11.2 percent and 10.9 percent, respectively. 

Table III-12 

USPS Marketing Mail Letters Attributable Cost and Average Unit Attributable Cost, 

FY 2019 and FY 2020 

Source: Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LR-ACR2020/1. 

TRENDS IN USPS MARKETING MAIL LETTERS

As shown in Figure III-10, after years of substantial 

volume changes, USPS Marketing Mail letters volume 

changes became more moderate until FY 2020. The 

change in volume for both categories of letters in FY 

2020 is the largest over the past decade. For High 

Density and Saturation Letters, although volume 

increased every year from FY 2012 to FY 2018, the 

volume losses in FY 2019 and FY 2020 wiped out 43.0 

percent of the increase in volume over those years. 

Annual changes in USPS Marketing Mail Letters 

volume have been relatively small in recent years, 

 

79 Marketing Mail letters refers to letter-shaped Marketing Mail which is the sum of the Letters and High Density and Saturation products. 

FY 2019 FY 2020 FY 2019 FY 2020

Letters 45,966 38,408 (7,559) (16.4%) 9,735 8,156 (1,578) (16.2%)

High Density and Saturation Letters 7,254 6,533 (721) (9.9%) 1,199 1,103 (96) (8.0%)

 Total Letters 53,220 44,940 (8,279) (15.6%) 10,934 9,260 (1,674) (15.3%)

Mail Volume Mail Revenue

(Millions) ($ in Millions) Increase or 

Decrease

Percent 

Change

Increase or 

Decrease

Percent 

Change

In FY 2020, USPS Marketing 

Mail Letters volume fell 15.6 

percent. This steep decrease 

in volume resulted in the 

lowest USPS Marketing Mail 

Letters volume in a decade. 
62 

with FY 2020 being an extraordinary exception. The decrease in volume in FY 2020 

resulted in the lowest USPS Marketing Mail Letters volume in a decade. 

Figure III-10 

Percent Change in USPS Marketing Mail Letters Volume, FY 2011–FY 2020 

Source: FY 2011–FY 2013 ACD; Docket No. ACR2014, Library Reference PRC-LR-ACR2014/1; Docket No. ACR2015, Library Reference PRC-LRACR2015/1; Docket No. ACR2016, Library Reference PRC-LR-ACR2016/1; Docket No. ACR2017, Library Reference PRC-LR-ACR2017/1; Docket 

No. ACR2018, Library Reference PRC-LR-ACR2018/1; Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LRACR2020/1. 

Figure III-11 shows the average unit attributable cost for USPS Marketing Mail letters since 

FY 2011. Average unit attributable cost for High Density and Saturation Letters and USPS 

Marketing Mail Letters has been on an upward trend in recent years. The average unit 

attributable cost for USPS Marketing Mail Letters has increased for the last 4 years, while 

High Density and Saturation Letters average unit attributable cost has increased since FY 

2014. Even so, the FY 2020 increase in average unit attributable cost for both products was 

particularly large compared with previous years.
63 

Figure III-11 

USPS Marketing Mail Letters Average Unit Attributable Cost, FY 2011–FY 2020 

Source: FY 2011–FY 2013 ACD; Docket No. ACR2014, Library Reference PRC-LR-ACR2014/1; Docket No. ACR2015, Library Reference PRC-LRACR2015/1; Docket No. ACR2016, Library Reference PRC-LR-ACR2016/1; Docket No. ACR2017, Library Reference PRC-LR-ACR2017/1; Docket 

No. ACR2018, Library Reference PRC-LR-ACR2018/1; Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LRACR2020/1. 

USPS MARKETING MAIL FLATS COMPARED WITH FY 2019 

Table III-13 summarizes the FY 2020 changes in volume and revenue for flat-shaped USPS 

Marketing Mail.80 Volume for all flat-shaped USPS Marketing Mail declined substantially in 

FY 2020. Carrier Route flats experienced the largest decrease (20.6 percent) in FY 2020. 

The volume declines for USPS Marketing Mail Flats and EDDM-R were nearly as large, 16.2 

percent and 18.4 percent, respectively. Volume for High Density and Saturation 

Flats/Parcels decreased 10.2 percent. 

Revenue for flat-shaped USPS Marketing Mail declined 14.3 percent in FY 2020. Large 

decreases in volume resulted in large revenue decreases for all flat-shaped USPS Marketing 

Mail in FY 2020. Carrier Route experienced the largest drop in revenue (19.8 percent). 

 

 

80 Some products include parcels; however, those products contain predominantly flat-shaped mailpieces. 
64 

Table III-13 

USPS Marketing Mail Flat Volume and Revenue, FY 2019 and FY 2020 

Negative values denoted by (). 

Source: Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LR-ACR2020/1. 

Table III-14 summarizes the FY 2020 change in USPS Marketing Mail flats attributable cost. 

Total attributable cost for flat-shaped USPS Marketing Mail decreased 9.6 percent in FY 

2020 due to the loss of flat-shaped USPS Marketing Mail volume. On a unit basis, 

attributable cost increased for all flat-shaped USPS Marketing Mail products in FY 2020. 

Table III-14 

USPS Marketing Mail Flats Attributable Cost and Average Unit Attributable Cost 

FY 2019 and FY 2020 

Negative values denoted by (). 

Source: Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LR-ACR2020/1. 

TRENDS IN USPS MARKETING MAIL FLATS 

Flat-shaped USPS Marketing Mail has lost nearly a third of its volume over the last decade. 

As shown in Figure III-12, volume decreased considerably for all flat-shaped USPS 

Marketing Mail categories in FY 2020. For High Density and Saturation Flats/Parcels, the 

large decline in FY 2020 comes after relatively small decreases from FY 2012 to FY 2019. 

The volume decreases for Flats and Carrier Route were also unusually large in FY 2020, 

although volume for both has been on a downward trend for years.81 

 

81 Large volume changes in FY 2016 and FY 2017 were due in large part to changes to the pricing structure of the Flats and Carrier Route 

products. See Docket No. ACR2017, Financial Analysis of United States Postal Service Financial Results and 10-K Statement, April 5, 2018, at 53-

54. 

FY 2019 FY 2020 FY 2019 FY 2020

High Density and Saturation Flats/Parcels 11,607 10,427 (1,180) (10.2%) 2,071 1,867 (205) (9.9%)

Carrier Route 6,359 5,048 (1,311) (20.6%) 1,672 1,341 (331) (19.8%)

Flats 3,818 3,199 (619) (16.2%) 1,562 1,344 (219) (14.0%)

Every Door Direct Mail ̶ Retail 649 530 (120) (18.4%) 120 99 (21) (17.4%)

Total 22,433 19,203 (3,230) (14.4%) 5,425 4,650 (775) (14.3%)

(Millions) ($ in Millions)

Mail Volume Mail Revenue

Increase or 

Decrease

Percent 

Change

Increase or 

Decrease

Percent 

Change

FY 2019 FY 2020 FY 2019 FY 2020

High Density and Saturation Flats/Parcels 1,437 1,499 (62) (4.1%) 13.8 12.9 0.9 6.7%

Carrier Route 1,394 1,673 (279) (16.7%) 27.6 26.3 1.3 5.0%

Flats 2,124 2,307 (183) (7.9%) 66.4 60.4 6.0 9.9%

Every Door Direct Mail ̶ Retail 38 46 (8) (16.8%) 7.2 7.1 0.1 2.0%

Total 4,993 5,525 (531) (9.6%) 26.0 24.6 1.4 5.6%

Attributable Cost Unit Attributable Cost

($ in Millions) (Cents per Piece) Increase or 

Decrease

Percent 

Change

Increase or 

Decrease

Percent 

Change
65 

Figure III-12 

USPS Marketing Mail Flats Percent Change in Volume, FY 2011–FY 2020 

Source: FY 2011–FY 2013 ACD; Docket No. ACR2014, Library Reference PRC-LR-ACR2014/1; Docket No. ACR2015, Library Reference PRC-LRACR2015/1; Docket No. ACR2016, Library Reference PRC-LR-ACR2016/1; Docket No. ACR2017, Library Reference PRC-LR-ACR2017/1; Docket 

No. ACR2018, Library Reference PRC-LR-ACR2018/1; Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LRACR2020/1. 

The average unit attributable cost of each flat-shaped USPS Marketing Mail product has 

increased significantly over the last decade. Figure III-13 illustrates the annual changes in 

average unit attributable cost. Over the last decade, the average unit attributable cost 

increased nearly every year for flat-shaped USPS Marketing Mail products. The FY 2020 

increases were similar to previous increases for flat-shaped USPS Marketing Mail products. 

 
66 

Figure III-13 

USPS Marketing Mail Flats Percent Change in Average Unit Attributable Cost 

FY 2011–FY 2020 

Source: FY 2011–FY 2013 ACD; Docket No. ACR2014, Library Reference PRC-LR-ACR2014/1; Docket No. ACR2015, Library Reference PRC-LRACR2015/1; Docket No. ACR2016, Library Reference PRC-LR-ACR2016/1; Docket No. ACR2017, Library Reference PRC-LR-ACR2017/1; Docket 

No. ACR2018, Library Reference PRC-LR-ACR2018/1; Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LRACR2020/1. 

Table III-15 compares the change in the average unit attributable cost between FY 2019 

and FY 2020 by cost segment. With the exception of USPS Marketing Mail Flats, mail 

processing unit cost decreased, while city carrier in-office unit cost increased for all USPS 

Marketing Mail flats products. For USPS Marketing Mail Flats mail processing unit cost 

increased, while city carrier in-office unit cost decreased. Rural carrier unit costs increased 

for all USPS Marketing Mail flat shaped products. City carrier street unit costs increased for 

USPS Marketing Mail Flats only. However, as previously discussed, city carrier in-office 

unit costs were affected by a costing methodology change. 

 
67 

Table III-15 

Change in USPS Marketing Mail Flats Average Unit Attributable Cost by Cost Segment, 

FY 2019 and FY 2020 

Source: PRC derived from Docket No. ACR2019, Library Reference USPS-FY19-24, December 27, 2019; Library Reference USPS-FY20-24, 

December 29, 2020. 

Periodicals 

Two products comprise the Periodicals class: In-County and Outside County. In-County is 

typically used by newspapers with smaller weekly circulations for distribution within the 

county of publication. Outside County consists of publications with a wide variety of 

circulation sizes, distribution patterns, and frequencies. 

PERIODICALS COMPARED WITH FY 2019 

Table III-16 summarizes the FY 2020 changes in volume and revenue for Periodicals. In FY 

2020, Periodicals volume declined by 629 million pieces, or 13.6 percent, with most of the 

decrease occurring in Outside County publications. In FY 2020, Outside County volume 

decreased 13.6 percent, nearly double the rate of decrease in FY 2019. Total revenue for 

Periodicals declined 14.3 percent in FY 2020. The decline in total revenue is due, in part, to 

High Density and 

Saturation Carrier Route Flats EDDM-R

Mail Processing

FY 2019 1.7906 8.4318 32.7557 0.2137 FY 2020 1.6708 7.8054 38.0007 0.1747

% Change (6.7%) (7.4%) 16.0% (18.2%)

City Carrier In-Office

FY 2019 1.4086 6.5614 12.5872 1.3441 FY 2020 1.8684 7.7470 11.4994 1.8286

% Change 32.6% 18.1% (8.6%) 36.0%

City Carrier Street

FY 2019 5.4544 5.5262 4.8294 4.5456 FY 2020 4.8093 5.3949 5.0062 4.1820

% Change (11.8%) (2.4%) 3.7% (8.0%)

Rural Carriers

FY 2019 3.6605 4.1299 3.9017 0.5598 FY 2020 4.5930 4.9502 4.7320 0.6713

% Change 25.5% 19.9% 21.3% 19.9%
68 

the loss of volume and to a decrease in unit revenue for both Outside County and In-County 

Periodicals resulting from a lower average weight compared with FY 2019.82 

Table III-16 

Periodicals Volume and Revenue, FY 2019 and FY 2020 

Negative values denoted by ().

Source: Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LR-ACR2020/1.

Table III-17 compares total attributable cost and average unit attributable cost for 

Periodicals for FY 2019 and FY 2020. Total Periodicals attributable cost decreased by $67 

million, or 3.6 percent. The decrease in Outside County exceeded the increase in In-County 

attributable cost. However, on a unit basis, both In-County and Outside County costs 

increased in FY 2020. 

Table III-17 

Periodicals Attributable Cost and Average Unit Attributable Cost, FY 2019 and FY 2020 

Negative values denoted by (). 

Source: Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LR-ACR2020/1. 

TRENDS IN PERIODICALS

As shown in Figure III-14, Periodicals volume has continued to decline, in large part due to 

the availability of electronic alternatives. For In-County Periodicals, the decline in FY 2020 

is similar to declines seen in recent years. Volume loss for Outside County Periodicals far 

exceeds volume losses in previous years, even though losses in volume have accelerated in 

recent years. Over the last decade, volume for Outside County Periodicals decreased by 

46.2 percent or 3.0 billion pieces. 

 

82 See Docket No. ACR2020, Responses of the United States Postal Service to Questions 1-26 of Chairman’s Information Request No. 3, January 

22, 2021, Question 4. 

FY 2019 FY 2020 FY 2019 FY 2020

In-County 499 469 (30) (6.0%) 56 51 (5) (9.3%)

Outside County 4,135 3,537 (599) (14.5%) 1,138 973 (165) (14.5%)

Total 4,635 4,006 (629) (13.6%) 1,194 1,024 (170) (14.3%)

Increase or 

Decrease

Percent 

Change

Increase or 

Decrease

Percent 

Change

Mail Volume Mail Revenue

(Millions) ($ in Millions)

FY 2019 FY 2020 FY 2019 FY 2020

In-County 96 100 3 3.6% 19.3 21.3 2.0 10.2%

Outside County 1,769 1,698 (70) (4.0%) 42.8 48.0 5.2 12.3%

Total 1,866 1,798 (67) (3.6%) 40.3 44.9 4.6 11.5%

Percent 

Change

Attributable Cost Unit Attributable Cost

($ in Millions) (Cents per Piece) Increase or 

Decrease

Percent 

Change

Increase or 

Decrease
69 

Figure III-14 

Periodicals Percent Change in Volume, FY 2011–FY 2020 

Source: FY 2011–FY 2013 ACD; Docket No. ACR2014, Library Reference PRC-LR-ACR2014/1; Docket No. ACR2015, Library Reference PRC-LRACR2015/1; Docket No. ACR2016, Library Reference PRC-LR-ACR2016/1; Docket No. ACR2017, Library Reference PRC-LR-ACR2017/1; Docket 

No. ACR2018, Library Reference PRC-LR-ACR2018/1; Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LRACR2020/1. 

Figure III-15 shows the percent change in the average unit attributable cost for In-County 

and Outside County Periodicals. Average unit attributable cost for In-County and Outside 

County has been increasing for several years. However, the increases in the last year were 

particularly large. 
70 

Figure III-15 

Periodicals Percent Change in Average Unit Attributable Cost, FY 2011–FY 2020 

Source: FY 2011–FY 2013 ACD; Docket No. ACR2014, Library Reference PRC-LR-ACR2014/1; Docket No. ACR2015, Library Reference PRC-LRACR2015/1; Docket No. ACR2016, Library Reference PRC-LR-ACR2016/1; Docket No. ACR2017, Library Reference PRC-LR-ACR2017/1; Docket 

No. ACR2018, Library Reference PRC-LR-ACR2018/1; Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LRACR2020/1. 

Table III-18 disaggregates the average unit attributable cost of Outside County Periodicals 

for FY 2019 and FY 2020. As shown in Table III-18, the average city carrier in-office unit 

cost increased while average mail processing unit cost decreased in FY 2020. Unit cost for 

rural carriers increased in FY 2020, while the unit city carrier street cost decreased. As 

previously discussed, methodological changes involving city carrier costs reduced costs 

attributed to Outside County Periodicals. Unit transportation cost also decreased, likely due 

to lower average weight for Outside County Periodicals in FY 2020 than in FY 2019. 

Table III-18 

Outside County Periodicals Average Unit Attributable Cost by Segment, FY 2019 and FY 2020 

Source: PRC derived from Postal Service CSC Report, FY 2019–FY 2020.

FY 2019 FY 2020

Mail Processing 19.41 17.12 (11.8%)

City Carrier In-Office 6.19 7.75 25.2%

City Carrrier Street 4.29 3.59 (16.3%)

Rural Carriers 4.09 4.26 4.1%

Transportation 4.26 3.63 (14.8%)

All Other 1.22 1.53 25.1%

(Cents per Piece) Percent 

Change

Unit Attributable Cost
71 

Package Services 

The Package Services class consists of four products: Alaska Bypass Service; Bound Printed 

Matter (BPM) Flats; BPM Parcels; and Media Mail/Library Mail. Table III-19 summarizes 

the FY 2020 changes in volume and revenue for Package Services. Overall, Package Services 

volume decreased 8.2 percent in FY 2020. However, Media Mail/Library Mail volumes were 

significantly higher compared with FY 2019. 

Two Package Services products had higher revenue in FY 2020 than in FY 2019, resulting 

in slightly higher revenue for the Package Services class overall. On a unit basis, revenue 

increased slightly for all Package Services products in FY 2020. 

Table III-19 

Package Services Volume and Revenue, FY 2019 and FY 2020 

Negative values denoted by (). 

Source: Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LR-ACR2020/1. 

As shown in Table III-20, attributable cost increased in the aggregate for all Package 

Services products compared with FY 2019, except for BPM Flats. In FY 2020, Alaska Bypass 

Service cost, which consists entirely of Cost Segment 14 transportation, increased both in 

the aggregate and on a unit basis, 7.1 percent and 7.9 percent, respectively. The 

attributable cost of BPM Parcels increased 3.8 percent due to a large increase in unit cost 

(13.9 percent) compared with FY 2019. Although BPM Flats attributable cost decreased in 

FY 2020, attributable cost increased 16.3 percent on a unit basis. Only Media Mail/Library 

Mail experienced a unit cost decrease in FY 2020. A 5.0 percent decrease in the average 

weight per piece for Media/Library Mail and, to a lesser extent, efficiency improvements 

contributed to the decrease in average unit attributable cost for Media Mail/Library Mail. 

FY 2019 FY 2020 FY 2019 FY 2020

Alaska Bypass 1 1 (0) (0.7%) 32 32 0 1.5%

Bound Printed Matter Flats 254 211 (43) (17.0%) 191 161 (30) (15.5%)

Bound Printed Matter Parcels 286 261 (25) (8.9%) 315 289 (25) (8.1%)

Media Mail/Library Mail 80 98 18 22.1% 284 349 65 23.0%

Total 622 571 (51) (8.2%) 821 832 11 1.3%

Mail Volume Mail Revenue

(Millions) ($ in Millions) Increase or 

Decrease

Percent 

Change

Increase or 

Decrease

Percent 

Change
72 

Table III-20

Package Services Attributable Cost and Average Unit Attributable Cost, FY 2019 and FY 2020

Negative values denoted by (). 

Source: Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LR-ACR2020/1. 

Table III-21 shows the FY 2020 percent change in unit attributable cost for selected cost 

segments. As shown in Table III-21, city carrier in-office activities increased substantially 

for all three products, primarily due to the change in In-Office Cost System (IOCS) 

methodology for sampling city carriers. For BPM Flats and Media Mail/Library Mail unit 

mail processing cost decreased in FY 2020, while it increased moderately for BPM Parcels. 

For BPM Flats, while unit attributable cost increased overall in FY 2020, in addition to the 

mail processing unit cost, unit costs decreased for motor vehicles service and motor vehicle 

service drivers. For this product, transportation unit cost increased 35.9 percent. In FY 

2020, highway transportation costs per mile increased due to a national shortage of truck 

drivers and higher average fuel costs.83

For BPM Parcels, unit attributable cost increased for most cost segments in FY 2020. In 

addition to city carrier in-office, transportation and vehicle service driver unit costs 

increased most substantially compared with FY 2019. 

Although city carrier in-office unit cost increased by 113.6 percent in FY 2020, unit cost 

decreases in the remaining segments resulted in a decrease in Media Mail/Library Mail's 

unit attributable cost in FY 2020. 

 

83 Postal Service FY 2020 Form 10-K at 22.

FY 2019 FY 2020 FY 2019 FY 2020

Alaska Bypass 22 20 1 7.1% 1,598.5 1,725.0 126.5 7.9%

Bound Printed Matter Flats 128 133 (5) (3.4%) 52.2 60.7 8.5 16.3%

Bound Printed Matter Parcels 308 297 11 3.8% 103.8 118.1 14.4 13.9%

Media/Library Mail 441 397 44 11.0% 495.5 450.5 (45.1) (9.1%)

Total 899 848 52 6.1% 136.4 157.6 21.2 15.5%

Increase or 

Decrease

Percent 

Change

Increase or 

Decrease

Percent 

Change

Attributable Cost Unit Attributable Cost

($ in Millions) (Cents per Piece)
73 

Table III-21 

Package Services Percent Change in Average Unit Attributable Cost by Segment, FY 2020

Source: PRC derived from Postal Service CSC Report, FY 2019 and FY 2020. 

Market Dominant Special Services

The Special Services class consists of 11 products: eight domestic products and three 

international products. Three Special Services products: Ancillary Services,84 Address 

Management Services, and International Ancillary Services, include a number of distinct 

services. 

Special Services include Certified Mail, Insurance, Money Orders, Post Office Box Service, 

and other services that enhance Market Dominant products. As shown in Table III-22, total 

revenue for Special Services declined $98 million in FY 2020. Revenue decreased for all 

services in FY 2020 except Insurance and Post Office Box Service. 

 

84 One category included in Ancillary Services is “Other Ancillary Services,” which consists of USPS Tracking, Return Receipts, Restricted Delivery, 

Signature Confirmation, Bulk Parcel Return Service, and Special Handling. 

BPM Flats BPM Parcels Media Mail/ 

Library Mail

Mail Processing (5.0%) 8.7% (11.6%)

City Carrier In-Office 82.5% 164.4% 113.6%

City Carrier Street 12.6% 22.5% (3.8%)

Vehicle Service Driv. (24.1%) 37.0% (20.0%)

Rural Carriers 24.4% 10.2% (11.1%)

Motor Vehicle Service (2.2%) 6.5% (22.1%)

Transportation 35.9% 42.7% (7.5%)

All Other 9.1% (2.8%) (24.1%)

Total Attributable Cost 16.3% 13.9% (9.1%)
74 

Table III-22 

Market Dominant Ancillary Services and Special Services Revenue, FY 2019 and FY 2020 

Negative values denoted by (). 

Source: Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LR-ACR2020/1. 

Table III-23 shows that attributable cost for Special Services decreased $131 million in FY 

2020. Although the attributable cost appears to have decreased most substantially for Post 

Office Box service in FY 2020, the decrease was primarily due to a change in costing 

methodology that shifted facility-related costs between mail and services.85

Table III-23 

Market Dominant Ancillary Services and Special Services Attributable Cost 

FY 2019 and FY 2020 

Negative values denoted by (). 

Source: Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LR-ACR2020/1. 

 

85 See Docket No. RM2020-1, Order on Analytical Principles Used in Periodic Reporting, August 17, 2020 (Order No. 5637). 

FY 2019 FY 2020

Certified Mail 654 598 (56) (8.5%)

COD 4 3 (1) (17.7%)

Insurance 78 93 15 19.4%

Registered Mail 24 21 (3) (12.5%)

Stamped Envelopes & Cards 13 13 (0) (0.4%)

Other Ancillary Services 390 374 (15) (3.9%)

Money Orders 163 153 (10) (5.9%)

Post Office Box 294 298 4 1.3%

Other Services 191 159 (32) (16.6%)

Total Services 1,810 1,713 (98) (5.4%)

Revenue

($ in Millions) Increase or 

Decrease

Percent 

Change

FY 2019 FY 2020

Increase or 

Decrease

Percent 

Change

Certified Mail 478 485 7 1.4%

COD 3 3 0 0.0%

Insurance 41 32 (9) (22.3%)

Registered Mail 17 14 (2) (13.6%)

Stamped Envelopes & Cards 11 10 (1) (5.5%)

Other Ancillary Services 247 268 21 8.5%

Money Orders 155 157 2 1.6%

Post Office Box 256 130 (125) (49.0%)

Other Services 95 71 (24) (25.4%)

Total Services 1,323 1,192 (131) (9.9%)

Attributable Cost ($ in Millions)
75 

Competitive Volume, Revenue, and Cost by 

Product 

Competitive products consist of both domestic and international products. Domestic 

Competitive products include Priority Mail Express; Priority Mail; Parcel Select; Parcel 

Return Service; First-Class Package Service; Retail Ground; Address Enhancement Services; 

Greeting Cards, Gift Cards, and Stationery; Competitive Ancillary Services; Premium 

Forwarding Service; Post Office Box Service; and Shipping and Mailing Supplies. There 

were also 560 Domestic Competitive NSA products in effect during FY 2020. International 

Competitive products include Outbound International Expedited Services; Outbound 

Priority Mail International; Inbound Air Parcel Post (at UPU rates); Outbound Single-Piece 

First-Class Package International Service; International Surface Air Lift; International 

Priority Airmail; International Direct Sacks—M-Bags; International Money Transfer 

Service—Outbound; International Money Transfer Service—Inbound; and International 

Ancillary Services. In FY 2020, there were also 771 International Outbound NSAs and 18 

International Inbound NSAs. 

The products are grouped into several broad categories to facilitate comparisons. Table III24 summarizes the FY 2020 changes in volume and revenue for Competitive products and 

services. Although total volume for Competitive products has been on an upward trend for 

years, in FY 2020, volume increased dramatically due to the surge in e-commerce related to 

the COVID-19 pandemic.86 Total volume for Competitive products increased 25.7 percent, 

with only Priority Mail Express losing volume compared with FY 2019. Among domestic 

Competitive products, First-Class Package Service volume increased most substantially in 

FY 2020, increasing 32.2 percent versus 9.7 percent in FY 2019. International volume more 

than doubled in FY 2020. 

Total Competitive product revenue increased 26.5 percent, or $6.4 billion, in FY 2020. 

Revenue for every domestic Competitive product except Priority Mail Express increased, 

mirroring the changes in volume. On a unit basis, for domestic Competitive products 

overall, revenue increased by approximately 2.9 percent. 

 

86 Postal Service FY 2020 Form 10-K at 26.
76 

Table III-24 

Competitive Products Volume and Revenue, FY 2019 and FY 2020 

Negative values denoted by (). 

Source: Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LR-ACR2020/1.

Table III-25 summarizes the FY 2020 changes in attributable cost. Total attributable cost 

for Competitive products increased 21.7 percent, or approximately $3.5 billion, in FY 2020. 

While the increase in attributable cost is primarily due to the increase in volume, costing 

methodology changes implemented in FY 2020 also increased costs attributed to 

Competitive products. On a unit basis, attributable costs decreased or increased modestly 

for all Competitive products in FY 2020. 

Table III-25 

Competitive Products Attributable Cost and Unit Attributable Cost, FY 2019 and FY 2020

 

Negative values denoted by (). 

Source: Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LR-ACR2020/1. 

1

 In the FY 2019 Financial Analysis Report, attributable cost for this category did not include group-specific cost. 

FY 2019 FY 2020 FY 2019 FY 2020

Priority Mail Express 26 24 (2) (7.9%) 716 697 (19) (2.7%)

First-Class Package Service 1,398 1,848 450 32.2% 4,466 6,228 1,761 39.4%

Priority Mail 1,085 1,262 176 16.2% 9,464 11,529 2,065 21.8%

Ground Parcels 2,997 3,584 587 19.6% 7,271 9,195 1,924 26.5%

International 166 413 247 149.0% 1,380 1,959 579 42.0%

Domestic Services 911 1,004 93 10.3%

Total Competitive 5,672 7,130 1,458 25.7% 24,207 30,611 6,403 26.5%

Mail Volume Mail Revenue

(Millions) ($ in Millions) Increase or 

Decrease

Percent 

Change

Increase or 

Decrease

Percent 

Change

FY 2019 FY 2020 FY 2019 FY 2020

Priority Mail Express 301 280 (20) (6.7%) 1,149 1,163 14 1.2%

First-Class Package Service 3,014 3,907 893 29.6% 216 211 (4) (1.9%)

Priority Mail 7,045 8,284 1,239 17.6% 649 657 8 1.2%

Ground Parcels1

 4,693 3,846 847 22.0% 128 131 3 2.2%

International 981 1,451 470 47.9% 592 352 (240) (40.6%)

Domestic Services 483 345 (138) (28.6%)

Total Competitive 15,960 19,426 3,466 21.7% 281 272 (9) (3.2%)

Attributable Cost Unit Attributable Cost

($ in Millions) (Cents per Piece) Increase or 

Decrease

Percent 

Change

Increase or 

Decrease

Percent 

Change
77 

Trends in Competitive Products 

With the exception of FY 2019, Competitive 

product volume has exceeded 10 percent 

growth each year since FY 2012.87 Figure III-16 

highlights the growth in Competitive categories 

since FY 2011. It illustrates the large increase 

in FY 2020, compared with previous years. 

Figure III-16 

Competitive Products Volume by Category, FY 2011–FY 2020 

Source: FY 2011–FY 2013 ACD; Docket No. ACR2014, Library Reference PRC-LR-ACR2014/1; Docket No. ACR2015, Library Reference PRC-LRACR2015/1; Docket No. ACR2016, Library Reference PRC-LR-ACR2016/1; Docket No. ACR2017, Library Reference PRC-LR-ACR2017/1; Docket 

No. ACR2018, Library Reference PRC-LR-ACR2018/1; Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LR-ACR2020/1. 

Competitive products attributable cost has grown rapidly over the last decade and now 

comprises 42.0 percent of the total attributable cost. The increase in total attributable cost 

over time includes the effects of mail classification changes that resulted in transfers of 

products from the Market Dominant to the Competitive product list. These include the 

transfer of Commercial First-Class Mail Parcels to a new Lightweight Commercial Parcels 

 

87 The transfer of First-Class Mail commercial parcels and lightweight Standard Mail parcels from the market dominant product list to the 

Competitive product list was completed by FY 2012. 

Competitive products attributable 

cost has grown rapidly over the 

last decade and now comprises 

42.0 percent of the total 

attributable cost. 
78 

category, USPS Marketing Mail lightweight parcels to the Competitive ground parcels 

category, single-piece Parcel Post from Market Dominant products to the Competitive 

Standard Post product, and First-Class Mail single-piece retail Parcels to the First-Class 

Package Service product.88 

Figure III-17 shows the average unit attributable cost by category from FY 2011 to FY 

2020. With the exception of ground parcels, the average unit attributable cost for 

Competitive products has generally trended upward in recent years. 

Figure III-17 

Competitive Products Average Unit Attributable Cost by Category, FY 2011–FY 2020 

Source: FY 2011–FY 2013 ACD; Docket No. ACR2014, Library Reference PRC-LR-ACR2014/1; Docket No. ACR2015, Library Reference PRC-LRACR2015/1; Docket No. ACR2016, Library Reference PRC-LR-ACR2016/1; Docket No. ACR2017, Library Reference PRC-LR-ACR2017/1; Docket 

No. ACR2018, Library Reference PRC-LR-ACR2018/1; Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LRACR2020/1. 

Figure III-18 shows the percent change in average unit attributable cost by category from 

FY 2011 to FY 2020. Increases and decreases in unit attributable cost have generally 

become smaller in magnitude in recent years. 

 

88 See Docket No. MC2011-22, Order Adding Lightweight Commercial Parcels to the Competitive Product List, April 6, 2011 (Order No. 710); 

Docket No. MC2010-36, Order Conditionally Granting Request to Transfer Commercial Standard Mail Parcels to the Competitive Product List, 

March 2, 2011 (Order No. 689); Docket No. MC2012-13 Competitive Product List Order Conditionally Granting Request to Transfer Parcel Post 

to the Competitive Product List, July 19, 2012 (Order No. 1411); and Docket No. MC2015-7, Order Conditionally Approving Transfer, July 20, 

2017 (Order No. 4009). 
79 

Figure III-18 

Competitive Products Percent Change in Average Unit Attributable Cost by Category 

FY 2011–FY 2020 

Source: FY 2011–FY 2013 ACD; Docket No. ACR2014, Library Reference PRC-LR-ACR2014/1; Docket No. ACR2015, Library Reference PRC-LRACR2015/1; Docket No. ACR2016, Library Reference PRC-LR-ACR2016/1; Docket No. ACR2017, Library Reference PRC-LR-ACR2017/1; Docket 

No. ACR2018, Library Reference PRC-LR-ACR2018/1; Docket No. ACR2019, Library Reference PRC-LR-ACR2019/1; Library Reference PRC-LRACR2020/1. 
80 

Chapter IV. Cost and Profit Analysis 

Introduction 

Chapter 4 divides the broad categories of costs analyzed in Chapter 2 into segments 

categorized by function and explores how operations impact these costs and how they 

impact total net income/loss. As stated in Chapter 2 (see Table II-5), the single largest cost 

for the Postal Service is employee salaries and benefits. This chapter contains a discussion 

of labor costs and workhours. 

The basis of the analyses in this chapter are from reports filed by the Postal Service: the 

Cost and Revenue Analysis (CRA) Report, the Cost Segment and Components (CSC) Report, 

and payroll data. 

Contribution Margin Income Statement 

The contribution margin income statement distinguishes between the institutional and 

attributable costs of each cost segment. By bifurcating the costs from Chapter 2 into 

institutional and attributable cost categories, it aims to provide an alternative analysis of 

the current financial condition of the Postal Service. 

Table IV-1 presents a high-level view of the contribution margin income statement, 

highlighting total attributable and institutional costs. From FY 2019 to FY 2020, total 

revenue increased 2.7 percent, total attributable cost increased 3.3 percent, and total 

institutional cost increased 2.2 percent. 

Table IV-1 

Condensed Contribution Margin Income Statement89

Source: Postal Service CRA Report, FY 2019 and FY 2020.

The contribution margin income statement analyzes the relationships between revenue, 

attributable costs, institutional costs, and overall net income or loss. 

 

89 The Postal Service includes inframarginal and group-specific costs in institutional costs. Table IV-4 reallocates inframarginal and group-specific 

costs as attributable costs. 

$ Change % Change

Total Revenue 71,305 $ 73,224 $ 1,918 $ 2.7%

Total Attributable Costs 44,920 46,414 1,495 3.3%

Contribution Margin 26,386 26,809 424 1.6%

Total Institutional Costs 35,199 35,986 786 2.2%

Net Loss (8,814) $ (9,176) $ (363) $ 4.1%

Total All Mail and Services Volume (in Millions) 142,570 129,184 (13,386) (9.4%)

FY 2020 over FY 2019 FY 2019 FY 2020
81 

Contribution margin on the contribution margin income statement differs from the 

controllable loss on the Postal Service Form 10-K.90 The Postal Service defines controllable 

loss, a non-GAAP measure, as the excess of revenue over costs for normal business 

operations and calculates it by adding to total net loss those costs that it determines do not 

arise from normal business operations and over which it has no control. These costs 

include amortization of unfunded retirement obligations and actuarial revaluation of and 

discount rate changes on workers' compensation obligations, and retirement obligations. 

Contribution margin, also a non-GAAP measure, is the excess of revenue over attributable 

costs. Attributable costs are the “direct and indirect postal costs attributable to each class 

or type of mail service through reliably identified causal relationships plus that portion of 

all other costs of the Postal Service reasonably assignable to such class or type[.]”91 In 

Order No. 3506, the Commission revised the methodology for determining attributable cost 

to include inframarginal costs developed to estimate incremental costs. Previously, 

attributable cost only included the sum of volume-variable costs, which, in the aggregate, 

increase as volume increases and decrease as volume decreases, and product-specific fixed 

costs, which are costs caused by a specific product or class but do not vary with volume. 

The Postal Service records costs, initially, as accrued costs. Accrued costs are separated 

into cost segments generally corresponding to major divisions in the Postal Service’s chart 

of accounts. The use of various systems designed to break down the cost of various postal 

activities determines separation. Identifying cost drivers that reflect the essential activity 

of each cost component determines the volume variable portion of attributable costs. Most 

cost segments contain multiple cost components. Attributable costs are distributed to 

products using distribution keys that reflect the underlying cost driver.92

After attributable costs are determined, the residual costs classify as institutional costs. 

Institutional cost cannot be attributed to a specific product or service and is equal to total 

cost minus total attributable cost. While sometimes referred to as “fixed cost,” it is more 

accurately characterized as “common cost” because it includes costs that are variable but 

not causally related to an individual product or class. Institutional cost includes costs for 

carrier network travel time, amortization of RHB unfunded liability, amortization of CSRS 

unfunded liability apportioned to prior years, and various administrative costs. 

In FY 2019 and FY 2020, the Postal Service generated a positive contribution after 

subtracting all attributable costs from revenue. However, total institutional cost exceeded 

the contribution amount leading to a net loss in both years. Between FY 2019 and FY 2020, 

the net loss increased 4.1 percent. Total volume declined 9.4 percent during that same 

period. All else being constant, total attributable costs should generally track volume 

declines; however, changes to the mail mix and cost of inputs impact expected results. 

 

90 Postal Service FY 2020 Form 10-K at 23. 

91 39 U.S.C. § 3622(c)(2). 

92 The Postal Service assigns these costs to each product according to methodologies approved by the Commission. Changes to those 

methodologies are reviewed by the Commission in informal rulemaking proceedings, and members of the general public are given the 

opportunity to comment in such proceedings. 
82 

The Postal Service’s institutional costs include substantial costs for retirement-related 

obligations and workers’ compensation. These costs can be highly volatile and are affected 

by actuarial assumptions, health care inflation rates, and discount rates. These costs 

experience more year-to-year fluctuation at a faster rate than the costs for common 

overhead, such as non-labor items for rent, supplies, and transportation, which are largely 

driven by inflation. 

To better understand the increase in institutional cost in FY 2020, the Commission analyzes 

individual cost segment changes. Table IV-2 presents the underlying changes in 

institutional cost by year, beginning in FY 2016. In the last 3 years, the largest changes have 

been in workers’ compensation. In most years, the combined annual changes in annuitant 

health benefits, amortization on unfunded retirement funds, and other operational costs 

are not as significant as the year-to-year changes in workers’ compensation cost. In 

addition, in FY 2020, the impact of COVID-19 on institutional costs is seen in city carrier 

costs and supplies and services. City carrier street delivery cost increased overall, with 

costs for letter route street time decreasing and costs for Special Purpose Routes 

increasing.93 This outcome is consistent with the change in volume and the product mix. 

Table IV-2 

Change in “Other Costs” by Segment, FY 2016–FY 2020 ($ in Millions)

Source: Postal Service CSC Report, FY 2016–FY 2020.

To further understand the cost changes that contribute to the Postal Service’s net loss, 

Table IV-3 breaks out both volume variable and product-specific costs and other costs by 

cost segment. The term “other costs” is derived from the Cost Segment and Component 

Report and refers to the residual cost remaining after the subtraction of volume variable 

and product-specific costs from total accrued cost for a cost segment or component. Prior 

to Order No. 3506, the sum of “other costs” was equal to institutional costs, but “other 

costs” include inframarginal costs and group-specific costs that are now attributable. It is 

still the case that most “other costs” are institutional (and most institutional costs are 

 

93 See Library Reference USPS-FY20-32, Tab 6.0.3, December 29, 2020; Library Reference USPS-FY19-32, December 27, 2019.

FY 2016 FY 2017 FY 2018 FY 2019 FY 2020

Annuitant Health Benefits 389 $ (4,914) $ 14 $ 9 $ 71 $ 

CSRS Supplemental Liability 0 1,550 (270) 204 225 City Carriers 261 (95) 167 157 227 Rural Carriers 141 165 187 218 179 FERS Supplemental Liability 149 669 42 102 283 Transportation 103 580 99 112 92 Supplies and Services 117 74 3 (35) 188 Clerks and Mailhandlers 100 35 54 (25) 39 Other 451 405 (435) 349 422 Subtotal 1,711 $ (1,531) $ (140) $ 1,091 $ 1,725 $ 

Workers' Compensation 966 (3,420) 1,002 3,495 (657) Total Change 2,677 $ (4,951) $ 862 $ 4,585 $ 1,069 $ 
83 

“other costs”), so analysis of them provides insights into the composition and behavior of 

institutional costs.

 
84 

Table IV-3 

Contribution Margin Income Statement, FY 2019 and FY 2020 ($ in Millions) 

Source: Postal Service CSC Report, FY 2019 and FY 2020. 

$ Change % Change

Total Revenue 71,305 $ 73,224 $ 1,918 $ 2.7%

Volume Variable and Product Specific Costs:

Postmasters 293 $ 302 $ 9 $ 3.1%

Supervisors and Technicians 1,910 1,954 44 2.3%

Clerks and Mailhandlers 12,350 12,520 170 1.4%

City Delivery Carriers – Office Activity 3,142 3,424 282 9.0%

City Delivery Carriers – Street Activity 4,904 4,949 45 0.9%

Vehicle Service Drivers 493 516 23 4.6%

Rural Carriers 3,055 3,176 121 4.0%

Custodial and Maintenance Services 2,348 2,165 (183) (7.8%)

Motor Vehicle Service 657 614 (43) (6.5%)

Miscellaneous Local Operations 287 308 21 7.4%

Purchased Transportation 6,467 7,004 537 8.3%

Building Occupancy 1,449 1,489 40 2.7%

Supplies and Services 1,462 1,524 62 4.2%

Research and Development 0 0 0 n/a

Servicewide Personnel Benefits and HQ/Area Operations 3,071 3,193 122 4.0%

General Management Systems 0 0 0 n/a

Other Accrued Expenses (Servicewide) 1,484 1,446 (38) (2.5%)

Total Volume Variable and Product Specific Costs 43,373 $ 44,585 $ 1,212 $ 2.8%

Contribution Margin 27,933 $ 28,639 $ 706 $ 2.5%

Other Costs:

Postmasters 1,373 $ 1,418 $ 45 $ 3.3%

Supervisors and Technicians 1,595 1,611 16 1.0%

Clerks and Mailhandlers 2,704 2,743 39 1.4%

City Delivery Carriers – Office Activity 624 497 (127) (20.3%)

City Delivery Carriers – Street Activity 8,080 8,434 353 4.4%

Vehicle Service Drivers 323 338 15 4.6%

Rural Carriers 5,460 5,639 179 3.3%

Custodial and Maintenance Services 842 1,080 237 28.2%

Motor Vehicle Service 1,048 1,023 (25) (2.3%)

Miscellaneous Local Operations 334 311 (23) (6.8%)

Purchased Transportation 1,717 1,809 92 5.4%

Building Occupancy 596 613 17 2.9%

Supplies and Services 1,616 1,805 188 11.6%

Research and Development 27 18 (8) n/a

Servicewide Personnel Benefits and HQ/Area Operations 9,750 9,829 80 0.8%

General Management Systems 18 15 (3) n/a

Other Accrued Expenses (Servicewide) 641 633 (7) (1.2%)

Total Other Costs 36,746 $ 37,815 $ 1,069 $ 2.9%

Total Costs 80,119 $ 82,400 $ 2,281 $ 2.8%

Net Loss (8,814) $ (9,176) $ (363) $ 4.1%

Total All Mail and Services Volume (in Millions) 142,570 129,184 (13,386) (9.4%)

FY 2020 over FY 2019 FY 2019 FY 2020
85 

As seen in Table IV-3, volume variable and product-specific costs decreased for Custodial 

and Maintenance Services, and other costs increased for this segment. The decrease in total 

volume variable and product-specific cost was primarily due to a 12.8 percent decrease 

from the prior year in Component 075 (Operating Equipment Maintenance). In FY 2020, 

Component 075 consisted of slightly less than half of total accrued costs (47 percent) for 

Custodial and Maintenance Services. Operating equipment maintenance costs are for 

personnel responsible for maintaining mail processing equipment, Point of Service, 

Intelligent Mail Devices (IMDs) and Mobile Delivery Devices (MDDs), and other window 

service and computer equipment.94 The decrease in total volume variable and productspecific cost for this segment is because the equipment variabilities for three out of the five 

largest maintenance labor cost pools decreased: FSS (Component 976), DBCS (Component 

978), and FSM (Component 981) decreased from the prior year. 

As seen in Table IV-3, certain cost segments show large absolute increases from FY 2019 

amounts. The three largest absolute increases from the prior year, which occur in the cost 

segments for city delivery carriers - street activity, purchased transportation, and rural 

carriers, are discussed below. 

City Delivery Carriers – Street Activity consists of the costs of carriers delivering and 

collecting mail from customers. Three components comprise this cost segment: Network 

Travel (Component 54), Delivery Activities (Component 47), and Delivery Support 

(Component 280). The largest portion of the increase in FY 2020 in this cost segment 

occurred in total accrued cost for Delivery Activities, increasing 6.4 percent. Overtime and 

penalty overtime and Other Leave increased in FY 2020. The accrued cost for 

Sunday/Holiday Delivery, a subcomponent of Delivery Activities, increased 34.1 percent 

from the prior year. However, costs in this subcomponent are fully volume variable95 and 

significantly lower in aggregate than Delivery Activities costs. This results in the greater 

percentage increase in institutional costs in this cost segment compared to attributable 

cost. Delivery Activities have a volume variability of 38.6 percent.96 

 

Purchased Transportation consists of the costs of contracted air, trucking, rail, and water 

transportation. Six components comprise this cost segment: Domestic Air (Component 

142), Domestic Alaska Air (Component 681), Highway (Component 143), Railroad 

(Component 144), Domestic Water (Component 145), and International (Component 146). 

The largest portion of the increase from FY 2019 occurred in Domestic Air and Highway. 

Total accrued costs in these components increased by 13.3 percent and 5.3 percent, much 

larger than the increase in FY 2019 from the prior year, 5.9 percent and 4.5 percent, 

respectively. The Postal Service explains that increased online shopping, restricted drivers' 

availability due to sickness or quarantine, and significantly fewer commercial air flights 

shifted volume to surface transportation. 97 

 

94 United States Postal Service, Rule 39 C.F.R. Section 3050.60(f) Report for FY 2019 (Summary Descriptions), July 1, 2020, folder 

“SummaryDescriptionsFY2019,” file “CS11-19.docx,” at 11-3 and 11-4 (Postal Service FY 2019 Summary Descriptions). 

95 Id. at 7-5. 

96 Id. at 7-2. 

97 See Responses of the United States Postal Service to Questions 1-21 of Commission Information Request No. 1, January 15, 2021, Question 3a 

(Responses to CIR No. 1).
86 

Table IV-4 shows the percentage change from the prior-year quarter in accrued Domestic 

Air and Domestic Highway costs. The third and fourth quarters, which historically have 

been lower than the first two quarters, as shown in the percentages for FY 2019 over FY 

2018, increased significantly in FY 2020 over FY 2019, resulting from the effects of the 

pandemic. 

Table IV-4 

Percent Change from Same Period Last Year (SPLY) in Purchased Transportation Accrued Cost 

FY 2019 and FY 2020 

 Source: PRC derived from Docket No. ACR2020, Library Reference USPS-FY20-32, Tab "Input-Costs".

The Postal Service states that the pandemic negatively affected its surface and air 

contracted transportation and highway contract route drivers “recorded hundreds of 

contract failures daily, with some districts experiencing failures for extended periods.”98 

According to the Postal Service, the increase in transportation costs resulted from a surge 

in shipping and packages volumes and the need for alternative modes of transportation 

such as charter flights and highway contract routes when the pandemic negatively affected 

available commercial flights.99 The increase in highway transportation costs was driven by 

an increase in the number of miles driven and a one-time accounting adjustment associated 

with embedded leases.100

Rural carriers deliver to and collect mail from non-urban zones determined through labor 

negotiations.101 Three cost components comprise the rural carrier cost segment: Evaluated 

Routes (Component 69), Other Routes (Component 70), and Equipment Maintenance 

Allowance (Component 73). The largest portion of cost in this segment comprises labor 

costs for full-time or Evaluated Routes, which grew by 5.1 percent from FY 2019, the same 

rate as in the prior year. However, in a change from the pattern of the past ten years, costs 

for Other Routes decreased 9.5 percent from the prior year, resulting in an overall 

reduction in the rate of growth in costs for the cost segment rural carriers in the past two 

years. Other Routes are not classified as full-time and are “typically created to relieve 

overburdened routes or to accommodate route expansion that cannot be handled by 

adding segments to existing routes.”102 Compared to FY 2019, higher costs in this segment 

partly result from a 1.5 percent increase in headcount for full-time rural delivery carriers, 

 

98 Postal Service FY 2020 Form 10-K at 2. 

99 Id. at 11 and 12. 

100 Id. at 21 and 22. 

101 United States Postal Service, Rule 39 C.F.R. Section 3050.60(f) Report for FY 2019 (Summary Descriptions), July 1, 2020, folder 

“SummaryDescriptionsFY2019,” file “CS10-19.docx,” at 10-1 (Postal Service FY 2019 Summary Descriptions). 

102 Postal Service, Rule 39 C.F.R. Section 3050.60(f) Report for FY 2019 (Summary Descriptions), folder “SummaryDescriptionsFY2019,” file 

“CS10-19.docx,” at 10-3 

1st Quarter 2nd Quarter 3rd Quarter 4th Quarter 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter

Domestic Air 12.4% 1.0% 14.0% (2.8%) (4.5%) 3.9% 20.3% 34.3%

Domestic Highway 10.0% 8.1% 0.0% (0.7%) 7.3% (1.7%) 7.3% 7.8%

Purchased Transportation Total Cost 9.7% 4.0% 4.6% (2.5%) 2.4% 0.4% 10.8% 18.9%

FY 2019 over FY 2018

Percent Change from SPLY

FY 2020 over FY 2019

Percent Change from SPLY
87 

from 73,165 to 74,255 carriers,103 and the growth of rural routes (0.6 percent) and 

residential and business rural delivery points (2.0 percent).104 

Analysis of Cost Segments 

The majority of the Postal Service’s costs concentrate in five cost segments (CS): Clerks and 

Mailhandlers (CS3), City Delivery Carriers – Street Activity (CS7), Rural Carriers (CS10), 

Purchased Transportation (CS14), and Servicewide Personnel Benefits and HQ/Area 

Operations (CS18). See Table IV-2. 

Figure IV-1 

Share of Total Costs by Major Cost Segment, FY 2016–FY 2020 

* Other comprises of cost segments for Postmasters, Supervisors and Technicians, City Delivery Carriers-Office Activity, Vehicle Service 

Drivers, Custodial and Maintenance Services, Motor Vehicle Services, Miscellaneous Local Operations, Building Occupancy, Supplies and 

Services, Research and Development, General Management Services and Other Accrued Expenses (Servicewide). 

Source: Postal Service CRA Report, FY 2016–FY 2020. 

From FY 2016 to FY 2020, the rate of growth in total costs in these five cost segments (6.5 

percent) was slightly lower than the rate of growth in the Postal Service’s total costs (6.8 

percent). 

 

103 Library Reference USPS-FY20-17, December 23, 2020, file “FY2020.Annual.Report.USPS.FY20.17.pdf,” at 28 (Postal Service FY 2020 Annual 

Report to Congress). 

104 Id. at 26. 
88 

Table IV-5 shows the share of costs that are “other costs” for each cost segment. For three 

out of the five cost segments identified in Figure IV-1, more than 60 percent of total costs 

are ”other costs.” 

Table IV-5 

“Other Costs” Share of Total Costs, FY 2016–FY 2020 

Source: Postal Service CRA Report, FY 2016–FY 2020.

Analysis of Employee Labor Cost 

Employee labor costs, including compensation 

and benefits, are 77.0 percent of total Postal 

Service costs. There are three categories of 

Postal Service employees: full-time career 

employees, part-time career employees, and 

non-career employees. Full-time or part-time 

career employees typically receive full federal 

benefits, whereas non-career employees serve 

in temporary positions and do not receive full 

federal benefits. Over the past decade (FY 2011–

FY 2020), the Postal Service has reduced its fulltime and part-time workforce by approximately 

61,000 employees and added approximately 

59,000 non-career employees. See Figure IV-2.

FY 2016 FY 2017 FY 2018 FY 2019 FY 2020

CS1 Postmasters 82.4% 82.4% 82.4% 82.4% 82.4%

CS2 Supervisors and Technicians 45.9% 45.7% 45.9% 45.5% 45.2%

CS3 Clerks and Mailhandlers 17.9% 18.0% 18.2% 18.0% 18.0%

CS6 City Delivery Carriers – Office Activity 16.5% 16.2% 16.5% 16.6% 12.7%

CS7 City Delivery Carriers – Street Activity 63.7% 63.1% 62.3% 62.2% 63.0%

CS8 Vehicle Service Drivers 39.6% 39.6% 39.6% 39.6% 39.6%

CS10 Rural Carriers 65.7% 65.6% 64.9% 64.1% 64.0%

CS11 Custodial and Maintenance Services 28.9% 31.9% 31.9% 26.4% 33.3%

CS12 Motor Vehicle Service 62.3% 61.8% 61.0% 61.5% 62.5%

CS13 Miscellaneous Local Operations 55.5% 54.2% 59.2% 53.8% 50.3%

CS14 Purchased Transportation 13.3% 20.8% 20.4% 21.0% 20.5%

CS15 Building Occupancy 30.0% 29.3% 29.0% 29.1% 29.2%

CS16 Supplies and Services 52.1% 51.3% 50.8% 52.5% 54.2%

CS17 Research and Development 99.1% 99.9% 100.0% 100.0% 100.0%

CS18 Servicewide Personnel Benefits and HQ/Area Operations 79.7% 63.3% 64.1% 76.0% 75.5%

CS19 General Management Systems 99.9% 100.0% 99.9% 99.9% 99.5%

CS20 Other Accrued Expenses (Servicewide) 25.2% 27.9% 28.3% 30.2% 30.4%

"Other Costs" Share of Total Accrued Costs

Over the past decade (FY 

2011–FY 2020), the Postal 

Service has reduced its full 

and part-time career 

workforce by approximately 

61,000 employees and added 

approximately 59,000 noncareer employees. 
89 

Figure IV-2 

Breakdown of Workforce, FY 2011–FY 2020 

Source: Postal Service September 2020 ORPES Report; Postal Service September 2019 ORPES Report; Postal Service September 2018 ORPES 

Report; Postal Service September 2017 ORPES Report; United States Postal Service, On-Roll and Paid Employee Statistics Report, September 

2016, October 6, 2016; United States Postal Service, On-Roll and Paid Employee Statistics Report, September 2015, September 24, 2015; 

United States Postal Service, On-Roll and Paid Employee Statistics Report, September 2014, September 26, 2014; United States Postal Service, 

On-Roll and Paid Employee Statistics Report, September 2013, September 27, 2013; United States Postal Service, On-Roll and Paid Employee 

Statistics Report, September and October 2012, November 28, 2012; United States Postal Service, On-Roll and Paid Employee Statistics 

Report, July, August, and September 2011, October 27, 2011.

From FY 2011 to FY 2014, the Postal Service reduced workhours each year. That trend 

changed in FY 2015, and workhours have, generally, been increasing each year since then. 

In FY 2015 and FY 2016, workhours increased 1.9 percent and 2.6 percent, respectively. 

Since the peak in FY 2016, workhours have been increasing at a slower pace, at 0.5 percent 

or lower each year. Workhours increased 0.1 percent compared to the prior year in FY 

2020, the lowest annual rate in the past five years. Figure IV-3 depicts annual workhours 

during the past 10 years.
90 

Figure IV-3 

Total Workhours, FY 2011–FY 2020 

Source: Postal Service FY 2020 TFP, tab "Lab-13b.” 

As illustrated in Figure IV-4, the Postal Service reduced its workforce and workhours from 

FY 2011 to FY 2014. Decreases in workhours and workforce during this period reflect 

declines in mail volume, delivery optimization initiatives, streamlining area and district 

offices, incentives for employees to retire or resign, and the slowing growth rate of new 

delivery points due to lower housing starts. Savings from the reduction in career 

employees during FY 2011 and FY 2012 were partially offset by higher retirement costs 

due to increases in the FERS contribution rate from 11.2 percent in FY 2010 to 11.7 percent 

in FY 2011 and higher health benefit premiums. Increases in overtime hours of 8.4 percent 

in FY 2011 and 3.4 percent in FY 2012 also offset the savings. The number of total 

employees remained essentially unchanged from FY 2013 to FY 2014 with a slight decrease 

(0.3 percent) in workhours. 

The cost of compensation and benefits spiked in FY 2015. Total workhours during FY 2015 

increased by 1.9 percent, in part due to an increase in workhours for city delivery and 

customer service operations. The increase in workforce, a slight increase (0.6 percent) in 

career employees, and contractually obligated salary escalations during FY 2015 resulted 

in higher compensation and benefits costs. Retirement expenses during FY 2015 increased 
91 

12.5 percent, primarily due to increases in the FERS employer contribution rate from 11.9 

percent to 13.2 percent. Compensation and benefits have continued to grow since FY 2017. 

Although there was a reduction in workforce in FY 2018 and FY 2019, workhours and 

compensation and benefits costs continued to increase. 

Figure IV-4 

Percent Change from Prior Year in Compensation and Benefits, 

Workforce and Workhours, FY 2011 – FY 2020 

Source: Postal Service FY 2020 Form 10-K at 34 and 31; Postal Service FY 2019 Form 10-K at 25; Postal Service FY 2016 Form 10-K at 20; 

Postal Service FY 2013 Form 10-K at 28; Postal Service FY 2020 TFP, tab "Lab-13b;” Postal Service September 2020 ORPES Report; Postal 

Service September 2019 ORPES Report; Postal Service September 2018 ORPES Report; Postal Service September 2017 ORPES Report; 

United States Postal Service, On-Roll and Paid Employee Statistics Report, September 2016, October 6, 2016; United States Postal Service, 

On-Roll and Paid Employee Statistics Report, September 2015, September 24, 2015; United States Postal Service, On-Roll and Paid 

Employee Statistics Report, September 2014, September 26, 2014; United States Postal Service, On-Roll and Paid Employee Statistics 

Report, September 2013, September 27, 2013; United States Postal Service, On-Roll and Paid Employee Statistics Report, September and 

October 2012, November 28, 2012; United States Postal Service, On-Roll and Paid Employee Statistics Report, July, August, and September 

2011, October 27, 2011.

The composition of the postal workforce is a significant factor in compensation and 

benefits costs. Between FY 2011 and FY 2013, the Postal Service reduced its career 

employees by 11.8 percent and increased its non-career employees by 42.7 percent. This 

lowered the hourly wage in FY 2013 and FY 2014, and because the Postal Service does not 

cover health benefit premiums for non-career employees, the cost of benefits as well. 

Consequently, the Postal Service was able to decrease total compensation and benefits 

costs at a pace that exceeded the decrease in total workforce and workhours. 
92 

In FY 2016 and FY 2017, the number of total employees and total workhours increased. 

Compensation and benefits costs also increased during the same period due to 

contractually obligated salary escalations. The increase in compensation and benefits costs 

from additional workhours and contractually obligated salary escalations was partially 

offset by attrition of higher-paid employees, who were replaced by newly converted career 

employees and non-career employees earning lower wages. In FY 2016 and FY 2017, FERS 

normal costs increased by 5.5 percent and 1.1 

percent, respectively, consistent with the 

increase in the FERS employer contribution rate. 

Average health benefit premiums also increased 

by 3.8 percent in FY 2016 and 4.4 percent in FY 

2017. 

In FY 2018 and FY 2019, the total number of 

employees decreased by 1.5 percent and 0.2 

percent, respectively, reflecting normal attrition 

as the Postal Service aligns its workforce with 

declining mail volume. During the same period, 

total workhours increased slightly, influenced 

primarily by the growth in the number of delivery points and higher volume during the 

holiday seasons. Compensation and benefits cost increased by 1.8 percent and 2.1 percent, 

respectively, due to contractual wage adjustments and the increase in total workhours. In 

FY 2018 and FY 2019, average health benefit premiums increased by 4.0 percent and 1.2 

percent, respectively. 

In FY 2020, compensation and benefits cost increased 2.5 percent. Compared to the prior 

year, compensation increased 2.6 percent, retirement expenses increased 6.0 percent, and 

health benefits increased 1.3 percent. More than a quarter of the increase in compensation 

was from the new category of sick leave applicable under the Families First Coronavirus 

Response Act (FFCRA).105 Other drivers of the compensation increase were contractual 

wage increases, higher overtime hours, and increased sick leave. Consistent with increases 

in compensation, Postal Service contributions for Social Security increased 3.7 percent, TSP 

increased 3.9 percent, FERS normal cost increased 8.1 percent, and the average FEHB 

premiums increased 4.0 percent. 

In FY 2020, the postal workforce increased by 1.7 percent, reversing the trend of the prior 

two years. In FY 2020, total workhours slightly increased by 0.1 percent, with an increase 

in overtime workhours of approximately 13 million offsetting a decrease of straight time 

hours of approximately 12 million. 

The total postal workforce increased compared to the prior two years due to conversions 

of non-career employees to full-time career employees and the hiring of additional casual 

 

105 Enacted in March 2020, the Families First Coronavirus Relief Act (FFCRA) required employers to provide 10 days of sick leave and up to 10 

weeks of family leave for COVID related absences, and provided a payroll tax credit to reimburse employers. 

More than a quarter of the 

increase in compensation was 

from the new category of sick 

leave applicable under the 

Families First Coronavirus 

Response Act (FFCRA). 
93 

employees to handle higher shipping volume in the second half of the year. The 

Memorandums of Understanding (MOUs) with the postal unions allowed the Postal Service 

to exceed the negotiated cap for non-career employees.106 Despite the added workload 

driven by the pandemic, the pace of growth in compensation costs slowed due to a 

combination of the use of additional overtime workhours to offset the reduction of straight 

time workhours (and the associated benefits cost), the addition of non-career employees, 

and a net reduction in career employees. 

COVID-19 IMPACT ON LABOR COST 

This section examines changes in compensation in FY 2020 across the three cost segments 

where labor costs are highest by comparing compensation costs (salary before benefits) in 

FY 2020 to the prior year. 

Four Cost Segments account for almost 80 percent of total compensation costs: CS 6&7 City 

Delivery Carriers (in-office and street), CS 3 Clerks and Mailhandlers, and CS 10 Rural 

Carriers. 

Figure IV-5 

Cost Segment Share of Total Compensation Cost, FY 2020 

Source: PRC derived from Docket No. ACR2020, Library Reference USPS-FY20-7, Worksheet “Wkyrcalc.xls,” Tab "Calculations," December 29, 

2020.

 

106 Docket No. ACR2020, Commission Information Request No.1, January 15, 2021, Responses to Question 2.a (CIR No. 1). 
94 

Total compensation cost increased by 2.6 percent in FY 2020, a 0.1 percent increase from 

the previous fiscal year’s cost growth rate.107 Figure IV-6 presents the relative contribution 

to compensation growth for FY 2019 and FY 2020. This shows how each cost segment’s 

share of the total growth rate changed significantly from the prior year. Notably, CS 6&7 

City Delivery Carriers contributed much more to the increase in FY 2020, and CS 10 Rural 

Carriers' share of the total increase was much smaller. 

Figure IV-6 

Cost Segment Shares of Growth Rate of Total Compensation Cost, FY 2019 and FY 2020 

Source: PRC derived from Docket No. ACR2020, Library Reference USPS-FY20-7, Worksheet “Wkyrcalc.xls,” Tab "Calculations," December 

29, 2020.

These differences, driven by changes in the mix of the workforce and type of workhours, 

caused individual cost segment growth rates to change between FY 2019 and FY 2020. The 

result was a change in each segment’s share of total compensation costs. 

As shown in Figure IV-7, in FY 2020, total compensation cost for CS 6 & 7 City Delivery 

Carrier increased by 4 percent ($453 million), doubling the 2 percent ($251 million) 

increase in the prior year. Compensation cost for overtime increased by 15 percent ($368 

million), compared to 5 percent ($117 million) in FY 2019. Straight time compensation108

for full-time employees increased by 2 percent, consistent with the prior year. Straight time 

compensation for part-time employees decreased in both years, 9 percent ($134 million) in 

FY 2020 and 2 percent ($35 million) in FY 2019. 

 

107 Postal Service FY 2020 Form 10-K at 31.

108 Straight time compensation includes salary for hours of work or authorized paid leave in a service week excluding overtime, EAS additional 

pay, and other premium pay. See https://about.usps.com/manuals/elm/html/elmc4_014.htm. 
95 

Figure IV-7 

Composition of Cost Segment 6 & 7 Change from Prior Year, FY 2019 and FY 2020 

Source: PRC derived from Docket No. ACR2020, Library Reference USPS-FY20-7, Worksheet “Wkyrcalc.xls,” Tab "Calculations," December 29, 

2020.

In FY 2020, the total compensation cost for CS 10 Rural Carriers increased by 2 percent 

($115 million), a reduction from the 6 percent ($251 million) increase in the prior year. 

Compensation cost for overtime increased by 16 percent ($54 million) compared to a 6 

percent ($20 million) increase in FY 2019. Straight time compensation for full-time 

employees decreased by 1 percent ($40 million) compared to an 8 percent ($302 million) 

increase in FY 2019. Straight time compensation for part-time employees increased in both 

years: 7 percent ($101 million) in FY 2020 and 2 percent ($24 million) in FY 2019. 

 
96 

Figure IV-8 

Composition of Cost Segment 10 Change from Prior Year, FY 2019 and FY 2020 

Source: PRC derived from Docket No. ACR2020, Library Reference USPS-FY20-7, Worksheet “Wkyrcalc.xls,” Tab "Calculations," December 29, 

2020.

In FY 2020, total compensation cost for CS 3 Clerks and Mailhandlers increased by 1 

percent ($132 million), consistent with the 1 percent increase in the prior year. 

Compensation cost for overtime increased by 10 percent ($183 million) compared to 2 

percent ($40 million) in FY 2019. Straight time compensation for full-time employees 

increased by 0.3 percent ($25 million), lower than the 1 percent ($66 million) increase in 

FY 2019. Straight-time compensation for part-time employees decreased by 3 percent ($76 

million) compared to the 7 percent ($135 million) increase in FY 2019. 

 
97 

Figure IV-9 

Composition of Cost Segment 3 Change from Prior Year, FY 2019 and FY 2020 

Source: PRC derived from Docket No. ACR2020, Library Reference USPS-FY20-7, Worksheet “Wkyrcalc.xls,” Tab "Calculations," December 29, 

2020.

As shown in Figures IV-7, IV-8, and IV-9, compensation costs for overtime109 increased in 

all three cost segments. Generally, compensation cost for overtime is lower than 

compensation cost for straight time because benefit costs do not increase as overtime 

workhours increase.110 

In addition to the increased use of overtime in FY 2020, there were notable changes to the 

mix of postal career and non-career employees. At the end of FY 2020, total postal 

employees increased by a net of 10,948 or 1.7 percent; career headcount decreased by 970 

employees or 0.2 percent, and non-career headcount increased by 11,918 employees or 8.8 

percent.111 While some career categories saw modest net increases, the largest net 

increases occurred in the non-career category. Casual employees'112 headcount increased 

by a net of 9,412 (1,109 percent), and the Mailhandler Assistants’ headcount increased by a 

 

109 Postal overtime is compensation paid at 150 percent of the employee’s basic hourly rate. Penalty overtime is compensation paid at two 

times the employee’s basic hourly straight time rate for hours described in applicable labor agreements. Employee and Labor Relations Manual 

ELM 49, at 162, September 2020. 

110 Generally benefits such as retirement are based on straight time basic wage which is defined “as higher level pay but does not include 

Territorial Cost of Living Allowances, overtime pay, night differential, military pay, allowances, premium pay, or lump-sum terminal leave 

benefits.” Employee and Labor Relations Manual ELM 49, at 513, September 2020. 

111 Docket No. ACR2020, Library Reference USPS-FY20-17, File “FY2020.Annual.Report.USPS.FY20.17”, at 28. 

112 Casual employees are non-career employees with limited-term appointments used as a supplemental workforce to perform duties assigned 

to bargaining unit positions. Employee and Labor Relations Manual ELM 49, at 419, September 2020. 
98 

net 6,558 employees (103 percent). The largest 

net decreases occurred in the career category 

“Clerks,” decreasing by a net of 2,402 employees 

(2 percent).113 

Career employees are eligible for benefits such 

as retirement that increase the average cost of 

their labor. For example, costs of benefits for 

Mailhandler Assistant (MHA) and Mailhandler 

Casual employees average 10 percent114 and 8 

percent115 of their average accrued salary, 

respectively. The cost of benefits for Mailhandler 

full-time employees average over 30 percent116

of their average accrued salary. 

In FY 2020, the increase in compensation and 

benefits was only slightly higher than the 

increase in the prior year despite the increased 

use of sick leave during the pandemic.117 This was due to the change in the postal 

workforce mix, with lower career headcount and higher non-career headcount. 

 

113 Docket No. ACR2020, Library Reference USPS-FY20-17, File “FY2020.Annual.Report.USPS.FY20.17”, at 28.

114 United States Postal Service National Payroll Hours Summary Report, Pay Period 20, 2020, Excel file “NationalPayrollSummary-PP20-

2020.xlsx,” cell J1745 divided by cell J1734 (Postal Service National Payroll Hours Summary Report). 

115 Id. cell J1837 divided by cell J1826. 

116 Id. cell J1607 divided by cell J1596. 

117 Postal Service FY 2020 Form 10-K at 21. 

In FY 2020, the increase in 

compensation and benefits 

was only slightly higher than 

the increase in the prior year 

despite the increased use of 

sick leave during the pandemic. 

This was due to the change in 

the postal workforce mix, with 

lower career headcount and 

higher non-career headcount. 
99 

Appendix A 

 FY 2020 Volume, Revenue, Incremental Cost, and Cost Coverage by Class, Current 

Classification (Products)

Source: Library Reference PRC-ACR2020-LR1 

Contribution to Contribution to Attributable Institutional Institutional Volume Revenue (Incremental) Cost Cost Rev./Pc. Cost/Pc. Cost/Pc. Cost

(000) ($ 000) ($ 000) ($ 000) (Cents) (Cents) (Cents) Coverage COMPETITIVE MAIL Priority Mail Express 24,106 696,690 280,324 416,367 2,890.071 1,162.863 1,727.208 248.5%

Priority Mail 1,261,551 11,528,769 8,283,888 3,244,881 913.857 656.643 257.214 139.2%

Retail Ground 12,534 302,372 218,634 83,738 2,412.480 1,744.377 668.102 138.3%

Parcel Select and Parcel Return Service (PRS) 3,571,475 8,892,630 4,469,670 4,422,960 248.990 125.149 123.841 199.0%

Total Ground 3,584,009 9,195,002 4,692,607 4,502,395 256.556 130.932 125.625 195.9%

First-Class Package Service 1,848,140 6,227,508 3,907,274 2,320,233 336.961 211.417 125.544 159.4%

Competitive Domestic Services 1,003,933 345,046 658,888 291.0%

Competitive Domestic Group Specific & Inframarginal Cost 432,754

Total Domestic Competitive Mail 6,717,806 28,651,902 17,941,894 10,710,008 426.507 267.080 159.427 159.7%

Competitive International Mail & Services 412,539 1,958,907 1,450,596 508,311 474.842 351.626 123.215 135.0%

Competitive International Non-Product Inframarginal Cost 326

Total Competitive Non-Product Inframarginal Costs 33,140

Total Competitive Mail and Services 7,130,345 30,610,808 19,425,955 11,184,853 429.303 272.441 156.863 157.6% MARKET DOMINANT MAIL First-Class Mail Single-Piece Letters and Cards 15,182,051 8,199,076 5,022,096 3,176,980 54.005 33.079 20.926 163.3%

Presort Letters and Cards 36,246,494 14,036,776 4,996,052 9,040,725 38.726 13.784 24.942 281.0%

Flats 1,204,654 1,548,120 1,544,559 3,561 128.512 128.216 0.296 100.2%

First-Class Non-Product Inframarginal Costs 260,479

Total Domestic First-Class Mail 52,633,199 23,783,972 11,823,186 11,960,786 45.188 22.463 22.725 201.2% MARKETING MAIL High Density & Saturation Letters 6,532,835 1,103,246 584,878 518,367 16.888 8.953 7.935 188.6%

High Density & Saturation Flats & Parcels 10,426,613 1,866,636 1,436,980 429,656 17.903 13.782 4.121 129.9%

Carrier Route 5,047,509 1,340,501 1,394,131 (53,630) 26.558 27.620 (1.063) 96.2%

Letters 38,407,623 8,156,373 4,759,464 3,396,910 21.236 12.392 8.844 171.4%

Flats 3,199,130 1,343,724 2,123,754 (780,030) 42.003 66.385 (24.383) 63.3%

Parcels 36,715 49,722 65,009 (15,288) 135.427 177.066 (41.639) 76.5%

Every Door Direct Mail - Retail 529,699 98,957 38,394 60,563 18.682 7.248 11.433 257.7% Marketing Mail Non-Product Inframarginal Costs 380,570

Total Marketing Mail 64,180,125 13,959,158 10,783,181 3,175,978 21.750 16.801 4.949 129.5%

Periodicals Within County 469,363 50,951 99,764 (48,813) 10.855 21.255 (10.400) 51.1%

Outside County 3,536,716 972,886 1,698,156 (725,269) 27.508 48.015 (20.507) 57.3%

Periodicals Non-Product Inframarginal Costs 517

Total Periodicals 4,006,079 1,023,838 1,798,437 (774,599) 25.557 44.893 (19.336) 56.9%

Package Services Alaska Bypass 1,264 32,200 21,811 10,389 2,546.728 1,725.044 821.684 147.6%

Bound Printed Matter Flats 211,204 161,408 128,283 33,125 76.423 60.739 15.684 125.8%

Bound Printed Matter Parcels 260,591 289,284 307,862 (18,578) 111.010 118.140 (7.129) 94.0% Media and Library Mail 97,801 349,397 440,575 (91,178) 357.252 450.479 (93.228) 79.3%

Package Services Non-Product Inframarginal Costs 869

Total Package Services 570,861 832,289 899,400 (67,111) 145.795 157.551 (11.756) 92.5%

U.S. Postal Service Mail 321,763

Free Mail 25,186 34,754 (34,754) 137.988

Total Market Dominant Mail 121,737,213 39,599,257 25,338,956 14,260,301 32.528 20.814 11.714 156.3% Market Dominant Services Ancillary Services Certified Mail 598,064 485,172 112,892 123.3%

COD 3,462 2,974 488 116.4%

Insurance 92,743 32,207 60,536 288.0%

Registered Mail 20,584 14,482 6,103 142.1%

Stamped Envelopes 12,182 10,010 2,173 121.7%

Stamped Cards 518 175 342 295.2%

Other Ancillary Services 374,476 268,230 106,246 139.6% Money Orders 153,274 156,947 (3,673) 97.7%

Post Office Box Service 298,145 130,450 167,696 228.6%

Caller Service 86,501 28,154 58,346 307.2%

Other Special Services 50,354 19,080 31,273 263.9% Market Dominant Services Non-Product Inframarginal Costs 20,087

Total Market Dominant Domestic Services 1,690,304 1,167,968 522,336 Outbound Single-Piece Mail Intl 96,831 144,590 112,723 31,867

Inbound Single-Piece Mail Intl 219,767 274,194 277,811 (3,617)

International Services 22,438 23,669 (1,230) Market Dominant Intl Non-Product Inframarginal Costs 972 Market Dominant International Mail & Services 316,598 441,222 415,175 26,048 Other Income 732,096 732,096 Other International Mail Attributable 66,330 (66,330) Total Mail and Services 129,184,156 73,073,687 46,414,384 26,659,303 56.566 35.929 20.637 157.4%

Institutional Costs 35,985,658 Appropriations: Revenue Forgone 58,772

Investment Income 91,359

Total Revenues 73,223,819

Total Costs 82,400,043 Net Income (Loss) (9,176,225)
100 

Appendix B 

Total Factor Productivity 

TFP is a measure of Postal Service productivity for any given year. TFP measures the 

change in the relationship between outputs (workload processed) and inputs (resource 

usage) over a period of time. Workload consists of weighted mail volume, miscellaneous 

output, and the expanding delivery network. Resources consist of labor, materials 

(including purchased transportation), and capital assets. TFP is calculated as the difference 

in workload growth and the growth of resources used. 

The Postal Service is a labor-intensive organization. Approximately 70 percent of its 

resource usage is made up of labor. Prior to FY 2000, the Postal Service’s growth in 

workhours outpaced its workload, resulting in either reductions or small gains in TFP. 

From FY 2000 to FY 2007, the Postal Service reduced its labor force while its workload 

remained basically flat, resulting in improvements in productivity. The large drop in mail 

volume in FY 2008 and FY 2009 resulted in a decline in workload and a corresponding 

decline in productivity. 

The last decade saw early TFP growth that leveled off in recent years. The productivity 

growth is partly caused by the reduction in workhours and the continued restrictions on 

capital investment, resulting in lower resource usage and a corresponding improvement in 

productivity. From FY 2011 to FY 2015, TFP improved each year as workhours decreased. 

Since FY 2016, average annual wages increased, resulting in yearly increases in the postal 

inflation factor (a measure of the change in the cost of resources used) after a period of 

decline. 

In FY 2020 and FY 2019, TFP decreased by 1.0 percent and 0.3 percent, respectively. Total 

workload increased by 0.3 percent in FY 2020, less than the 1.3 percent increase in 

resources for the same period. The growth rate of resources used, specifically materials 

(domestic air transportation, highway transportation, and supplies), contributed to the 

decrease in TFP in FY 2020. 

Figure IV-5 shows the trend in TFP from FY 1972 through FY 2020. 

 
101 

Figure B-1 

Postal Service Total Factor Productivity, FY 1972–FY 2020 

Source: Postal Service FY 2020 TFP, tab “Tfp-52.”