POSTAL REGUI.ATORY COMMISSION

Washington, DC 20268-000i

Robert G. Taub

Acting Chairman

September 11,2015

Ms. Lori Rectanus

Director, Physical lnfrastructure lssues

Govern ment Accou ntability Office

441 G Street, NW

Washington, DC 20548

RE: VIA EMAIL AND U.S. MA|L

Dear Ms. Rectanus:

Thank you for the opportunity to offer comments on the Government

Accountability Office's (GAO) Draft Report titled U.S. Posfa t Seruice Actions Needed to

Make Delivery Pertormance lnformation More Complete, lJseful, and Transparent

(GAO-15-756) (Draft Report). The Commission appreciates the opportunity for

constructive dialogue that the GAO has provided in sharing and discussing the Draft

Report.

The GAO made two recommendations in this Draft Report to the Commission:

(1) hold a public proceeding to address how the Postal Service can improve the

"completeness" of its delivery performance information; and (2) provide more readily

available data and additional analysis of the Postal Service's delivery performance

information.l The Commission adopts both recommendations as follows: (1) the

Commission is committed to holding a public proceeding to consider the issues raised

1 GeneralAccountability Office, U.S. Postal Service Actions Needed to Make Delivery Performance lnformation More Complete, Useful, and Transparent, GAo-1s-7s6, Sãpiemoer 2015, at26 (Draft Report).

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September 11,2015

Page 2 ot 17

by the GAO in the Draft Report; and (2) the Commission already has updated its

website to provide instantaneous access to service performance reports and dockets.

However, as described below, the Commission finds portions of the Draft Report

unsupported by evidence. Specifically, the Commission disagrees with the GAO's

characterization of the Commission's oversight of the Postal Service, the critería the

GAO uses to evaluate delivery performance information, the analytical basis the GAO

employs, the GAO's limited review of the record, and the conclusions the GAO reaches

to formulate its recommendations.

l. The Commission Objects to the GAO's Characterization of the Commission's

oversight Responsibilities Based on GAo-created criteria

As an initial matter, the Commission objects to the GAO's implication that ít is not

fully successful in meeting its oversight responsibilities. To make such an assessment,

an initial inquiry must identify the Commission's statutory responsibílities with respect to

measurement of service performance data submitted by the Postal Service. Only then is

it possible to assess whether the Commission has met that responsibility. The

Commission's responsibility to determine the Postal Service's service performance is

specifically outlined in the Commission's governing authority.

The Postal Accountability and Enhancement Act (PAEA) charges the

Commíssion with establishing the methodologies by which guality of service is

analyzed, including regulations prescribing the form and content of reports to the

Commission and consulting with the Postal Service concerning the establishment of

service standards.2 The PAEA also mandates that the Commission annually review

service performance.3

The Commission has consistently reported in Annual Comptiance Determinations

whether any service standards, on a nationwide basis, in effect during the year under

'39 u.s.c. g 36s2(e).

t 39 u.s.c. S 3653.

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September 11,2015

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review were not met. Because of the Commission's report¡ng, review, and oversight

since enactment of the PAEA, all policymakers, including Congress, the President, and

postal stakeholders, know whether or not the Postal Service has been meeting its

delivery standards on a nationwide basis for all market dominant products.

The Draft Report does not suggest that the Commission has been anything but

fully successful in meeting its mission and statutorily required duties as ouflined in the

PAEA. lnstead, the GAO produces an assessment based on GAO-created criteria,

rather than the statutory requirements of the PAEA. The GAO then posits that because

the Commission has not ventured into areas beyond its clear statutory mandate,

regardless of the reasons, it is not providing the oversight mandated by Congress when

it passed the PAEA.a

Congress's enactment of the PAEA in December 2006 created a new system of

modern postal rate regulation, including a complementary provision for service

performance measurement.s ln thís new statute, Congress delegated authority to the

Commission to prescribe, by regulation, how the Postal Service would report on the

newly created service performance standards.o

The Commission did not formulate its regulations in a vacuum. The PAEA directs

the Commission to balance providing the public with "timely, adequate information" with

"avoiding unnecessary or unwarranted administrative effort and expense."T This

mandate was embraced by the Commission when it proposed the annual service

o For example, the GAO suggests the Commission provide trend analysis of service performance

results at the sub-national level and provide service performance data specific to rural areas. Draft Report

at20,22. The PAEA, however, provides for an annual determination of compliance with service

performance standards. The Commission, in establishing regulations concerníng the postal Service's

reporting, determined that it would measure the Postal Service's attainment of sèrvice standards at a

national level. See 39 U.S.C. SS 3652, 3653, 3691; 39 C.F.R. S 3055.2(g). Commission rutes require

Postal Service reporting at the district, area, and national levels. See 3g C.F.R. part 3055, suOpart a.

Sub-national data is used to validate national-level data.

s See Pub. L. No. 109-435, SS 2O4,301 (2006).

6 See Pub. L. No. 109435, S 204 (codified at 39 U.S.C. S 3652).

i 39 u.s.c. S 36s2(eXl XA), (B)

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September 11,2015

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performance reporting regulat¡ons. The Commission explained that "these proposed

rules are being published at a time when the Postal Service is experiencing

unprecedented fiscal challenges" and, as such, were "designed to maximize

transparency using data sources that either exist now, or are in active development."s

Moreover, the two Commission dockets concerning service performance

measurement reporting proceeded under notice-and-comment rulemaking procedures

and provided the Postal Service, mailers, and the general public with the opportunity for

meaningful participation.e ln the 5 years since those regulations were issued,lo no

stakeholder has petitioned the Commission to revisit those regulations or othenruise

improve service performance reporting.t' ln addition, the statute directs the Commission

to review the entire system of rate regulation, including maintaining the service

standards established under 39 U.S.C. S 3691, 10 years after its enactment (r.e.,

commencing in December 2016).12 The PAEA also requires the Commission to submit

a report to the President and Congress by December 2016 on how the entire law is

working and any recommendations for improvement.l3

The Commission recognizes that continual improvement should be the goal of all

government agencies. lndeed, rather than restrict this discussion to a single chapter in

the Commission's Annual Compliance Determínation, the Commission for the past 2

I Docket No. RM2009-1 1, Order No. 

-292, 

Notice of Proposed Rulemaking on periodic Reporting

of Service Performance Measurements and Customer Satisfaction, September ZlZOOS, atZ.

s See Docket No. P12008-1, Service Performance Measurement Systems for Market Dominant

Products; Docket No. RM2009-11, Periodic Reporting of Service Performance Measurements and

Customer Satisfaction.

10 Docket No. RM2009-11, Order No. 465, Order Establishing Final Rules Concerning periodic

Reporting of Service Performance Measurements and Customer Satrsfaction, May 25,2010;lee atso 75

FR 38725 (July 6, 2010).

11 See 39 C.F.R. S 3050.11. Since the enactment of these rules, various stakeholders have

petitioned the Commission to improve other types of periodic reporting and the Commission has acted on

those concerns. See, e.9., Docket No. RM2014-5.

" 39 u.s.c. S 3622(dX3).

tt See Pub. L. 109435, 120 Stat. 319S (2006), S 701.

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years has chosen to evaluate the Postal Service's plans and progress with the

Government Performance and Results Act in an ín-depth report, which has provided a

more thorough assessment of Postal Service performance, including meeting its service

performance goals over time. The Commission's work in the area of service

performance has led to significant improvements.

To reiterate, the Commission has provided strong oversight in order to achieve

the transparency and accountability required by Congress. The Commission objects to

the GAO's statements that by not entering into issues that are unilaterally created by the

GAO, the Commission is not providing the oversight mandated by Congress when it

enacted the PAEA. The Commission acknowledges there are legitimate concerns

regarding the Postal Service's service performance, especially in rural service areas.

The Commission is working with Congress on those issues and is committed to

responding appropriately to the GAO's recommendations. However, in this Draft Report

the GAO simultaneously finds fault with the Commission's regulatory efforts but does

not acknowledge the Commission's statutorily defined regulatory role with respect to

service performance repoñing under the PAEA.

ll. The Commission Has Provided Strong Oversight of Service Performance

Measurement, Consistent with the PAEA; the Commíssion Disagrees with the

GAO Over the Significance of Data "Completeness"

The GAO concludes in its Draft Report that the Postal Service's measurement of

service performance is "incomplete because only about 55 percent of market-dominant

mail volume is currently included in measurement."l4 According to the GAo,

Commission reports "have not assessed why these measurements were incomplete nor

specified what actions USPS needs to take to achieve complete performance data."15

As a result of this conclusion, the GAO recommends the Commission conduct a

1a Draft Report at 9.

'u /d. at 16-17.

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September 11, 2015

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proceeding focused on data quality and completeness.16 As indicated above, the

Commission is committed to initiating a proceeding to consider the issues raised in the

Draft Report. However, as further addressed in the following sections, the Commission

strongly disagrees with the basis used to arrive at this recommendation, particularly the

GAO's focus on data "completeness," and lack of recognition for the Commission's

efforts in improving data quality.

A. The Commission has prompted consistent, continual improvement in the

quality of service performance data

The GAO concludes the Commission should initiate a proceeding to improve the

quality of Postal Service data.17 Under section 3652 of title 39, such a proceeding is

warranted by statute when it appears "the quality of service data has become

significantly inaccurate or can be significantly improved."18 The Commission sees clear

evidence, as explained below, that the quality (r.e., accuracy, reliability, and

representativeness) of the Postal Service's service performance data is and has been

improving.le Specificalty, the Commission has observed a decrease in the amount of

"uncategorized" mail and an increase in the number of postal districts with enough

measured volume to provide meaningful results.

B. The GAO's focus on data "completerìess" is not statistically meaningful

The Commission respectfully notes that the GAO's definition of "completeness" is

not a meaningful statistical measure. The Commission has not concluded that the

"percentage of mail measured" should be the primary determinant of accurate, reliable,

or representative service performance data. lnstead, the Commission reviews Postal

tu td. at 19.

'7 rd. at 17-18.

tt 39 u.s.c. S 3ôs2(eX2XB).

1e ln addition, stakeholders have not presented the Commission with any evidence that there is

any systematic problem with the quality of data.

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September 11,2015

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Service data using accepted statistical principles that determine whether service

performance data are sufficient and service performance results are meaningful.

Sampling fractions, confidence intervals, and margins of error at the district level

are the primary factors used by the Commission to determine whether data are accurate

and reliable. To illustrate, the Postal Service derives sample sizes at a given reporting

level (n¿) for presoft First-Class Mail, Standard Mail, Periodicals, and Package Services

using the following formula, where p is the expected on-time rate in the worst-case

scenario for a specified mail product; d is the desired margin of error; and z is the score

corresponding to a selected confidence level:

n 

- 

zzP(l-P) ,!o 

- d,z

After estimating sample size per recording level ne, the total sample size n is

calculated by multiplying ne by the number of service standard types and postal districts.

Next, the sampling fraction f, which is the fraction of mail pieces selected for actual

measurement, is determined. The sampling fraction f is derived by dividing the

estimated sample size per recording level (ne) by population size, where N is the

population size at the mail class level:

ln order to estimate the overall maíl population in each mail category, the postal

Service uses data on historical mail volumes by class, mail shape level, and 3-digit Zlp

Code. Density and overall mail volumes in postal districts vary; therefore to obtain

samples of the same size in different districts, sampling fractions in the districts with low

mail volumes should be higher than in districts with higher mail volumes. Consequenfly,

only focusing on the "percentage of mail in measurement" as a determinant of service

pedormance data "completeness" is not meaningfulfrom a statistical perspective.

c 116

,N

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September 11,2015

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C. The Commission has assessed and issued directives related to data

quality

The Commission would like to correct the GAO's statement that Commission

"reports have not assessed why these measurements were incomplete nor specified

what actions USPS needs to take to achieve complete performance data.',2o

1. The Commissíon has assessed mail exclusions

The Commission has assessed the primary reasons measured mail may be

inaccurate, unreliable, or not representative of nationwide performance. These reasons

include data not in full-service lMb, uncategorized mail, invalid data, and low district

level volumes. Under the Commission's oversight, the Postal Service has been

improving in each of these areas.

Parlicipation in full-seruice lMb. The Postal Service shifted from a pilot test for

lMb measurement to an actual measurement system in the second half of fiscal year

2010.ln the Annual Compliance Determination for fiscal year 2010, the Commission

noted:

The data yield on both Bulk Firsf-class Mait and standard

Mail is minimal and must be increased to be usefulfor

measurement purposes. Participation rates and compliance

must be increased and progress reports made on a monthly

basrs to the Commission. The Commission witt monitor

pafticipation rates. should growth not continue during this

fiscalyear, the commission may review its previous decrsion

to allow the Postal seruice to proceed with devetopment of

an internal lMb based hybrid measurement system.2l

ln fiscal year 2011, the Commission noted that the pieces in measurement had

almost doubled over the year but that some concerns about the reliability of data for

20 Draft Report at 16-17.

21 Docket No. 4CR2010, Annual Compliance Determination Report, March 29,2011, at67

(FY 2010 ACD).

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September 11,2015

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specif¡c products remained. The Commission warned that "[i]t [was] imperative for the

Postal Service to find a reliable way to measure service performance" and the

Commission would continue to monitor progress.22 ln each of the subsequent 3 fiscal

years, the number of pieces in measurement for most products continued to increase.

Additionally, the Commission consults with Postal Service leadership on a monthly

basis to discuss progress in lMb participation and other issues related to service

performance.

Uncategorized mail. Mail pieces are uncategorized if the specific product cannot

be identified. These pieces are captured in either Mixed Product Letters or Mixed

Product Flats categories. ln fiscal year 2011, the Postal Service reported that 61

percent of measured Standard Mail letter volume and 91 percent of measured Standard

Mail flat volume fell into the Mixed Product categories. The Commission determined that

the large quantity of mail pieces categorized as a Mixed Product hindered proper

service performance measurement and insisted the Postal Service "work with mailers to

obtain the data necessary to accomplish product level reporting in FY 2012."23 As a

result, the Postal Service reported in fiscal year 2012 that it had been working with the

mailing industry to revise the documentation requirements for mailers.2a The new

system required mailers to document all mail pieces, thereby ensuring proper

categorization of each mail piece.25 ln the Annual Compliance Determination for fiscal

year 2012, the Commission stated that "[i]t is encouraging that measured mix product

volumes... have declined significantly.... The effort to properly categorize Standard Mail

products should improve the accuracy of service performance measurements."26

22 Docket No. ACR2011, Annual Compliance Determination Report, March 28, 2¡12,at 64-65

(FY 2011 ACD).

23 FY 2011 ACD at 73.

2a Docket No. ACR2012, Annual Compliance Determination Report, March 28,2013, at54

(FY 2012 ACD).

'u Fy 2}12ACD at s5.

'u td. ats7.

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September 11,2015

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ln fiscal yeat 2014, the Postal Service reported that 1.4 percent of measured

letter volume and 0.1 percent of measured flat volume fell into the Mixed product

categories.2T The Commission's attention to this issue spurred the Postal Service's new

requirements and increased the accuracy of product level measurement by increasing

the volume of identifiable mail pieces and decreasing the volume of Mixed product

categories.2s

Data validation. For the annual compliance determinations for fiscal years 2011

and 2012, the Commission expressed concern about the lack of progress towards data

reliability for some products. Consequently, in fiscal year 2013, the Commission asked

the Postal Service to provide an updated description of the parameters used to

determine the reliability of lMb data.2s ln general, data undergo a series of validation

reviews which test for start-the-clock accuracy, address quality, mail preparation, receipt

date accuracy, and assurance that the piece originated from and destinated to a Zlp

Code.30

lMb data passing these validation tests are then assessed to determine whether

there are sufficient data to meet the Postal Service's minimum requirements. The postal

Service explained that these requirements include:

o Excluding pieces where the total volume of origin plus destination pieces

for a Postal Area is less than or equal to 10,000 for presort FirslCiass

Mail at the service standard group level, Periodicals mail at the Entry Type

and service standard group level, Standard Mail at the Entry Type and

service standard group level, and Bound Printed Matter Flats at the Entry

Type level.

. Excluding pieces where the total volume of measured pieces is less than

or equal to 50 pieces for an origin district-destination district combination

27 Docket No. 4CR2014, Annual Compliance Determination Report, March 27,2015, at93

(FY 20't4 ACD).

'u FY 2014 ACD at 95.

2e Docket No. ACR2O13, Responses of the United States Postal Service to euestions 1-11 of

Chairman's lnformation Request No. 2, January 23,2014, question g.

'o rd.

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September 11,2015

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for the following: First-Class Mail at the service standard level by shape,

Periodicals mail at the basic Entry Type (DDU, DSCF, DADC, DNDC) and

service standard level, Standard Mail at the basic Entry Type (DDU,

DSCF, DADC, DNDc), shape, and service standard level, and Bound

Printed Matter Flats at the basic Entry Type (DDU, DSCF, DADC, DND6)

level.

. Excluding pieces for individual Standard Mail products where the total

volume of originating plus destinating pieces are less than 1000 pieces for

a district and basic entry type (DDU, DSCF, DADC, DNDC) and excluding

pieces where the total volume of originating plus destinating pieces are

less than 100 at the district and service standard groqp reporting level.

These are evaluated for each Standard Mail product.3l

The Commission has observed continuous, steady declines in the amount of

measured mail pieces excluded during this process. Due to this improvement, data

reliability has also markedly improved.

District-levelvolume. Another critical step in assessing whether data are reliable

and representative is to evaluate the number of districts that report reliable data.32 The

Commission continuously monitors the number of districts that reported service

performance results and has noted that for certain mail products or categories the

number was low. For example, the Commission found that none of the 67 districts

reported results for Bound Printed Matter Flats measured End-to-End service quality in

several quarters of fiscal years 2012 and 2013.33

As a result, the Commission directed the Postal Service to "develop strategies to

enhance Full-Service mailer participation and increase service performance results."3a

ln fiscal year 2014, the Postal Service reported results in all 67 districts for all market

tt rd.

32 ld.

33 Docket No. ACR 2013, Annual Compliance Determination Report, March 27,2014,at 114 (Fy

2013 ACD)

to Fy 2o1g ACD at 1 15.

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dominant products, standards, and categories including End{o-End Bound printed

Matter Flats.

2. The Commission has issued directives with respect to data quality

The Commission has regularly directed the Postal Service to improve data

reliability and accuracy by: (1) increasing full-service lMb participation; (2) increasing

measured volumes for mail product categories in districts where the volume measured

was insufficient; and (3) increasing the number of districts providing results.3s As a

result of Commission directives, factors related to the overall quality of Postal Service

service performance data have markedly improved.36

D. The GAO disregards the USPS OIG's important role

The GAO Draft Report also does not fully consider the important role of the

Postal Service's lnspector General (USPS OIG) with respect to data quality. When

Congress enacted the PAEA, it mandated that the USPS OIG-not the Commissionperform the critical task of "regularly audit[ing] the data collection systems and

procedures utilized in collecting information and preparing such reporl [on measures of

the quality of servicel" and required those audits to be submitted to the Commission.3T

When the USPS OIG audited the service performance measurement data for mail

measured with full-service lMb in 2012 (the most recent audit conducted), it found the

tu See Docket No. ACR2008, AnnualCompliance Determination Report, March 30,200g,at44

(FY 2008 ACD); Docket No. 4CR2009, Annual Compliance Determination Report, March 29,2010, at E4

(FY 2009 ACD); FY 201 1 AcD at 64-65, 73, 75; Fy 2012 ACD at 49-s1 , s3-57, 61 ; Fy 201 3 ACD at

102-103, 105-108, 110-111 , 113-115. ln certain instances, the Postal Service has withhetd service

performance data when it did not have the requisite number of mail pieces to provide statistically reliable

service performance resu lts.

tu See Docket No. ACR2O07, Annual Compliance Determination Report, March 27,2008, at SS;

FY 2008 ACD at 44; FY 2009 ACD at 54-55; FY 2010 ACD at 64-67; FY 2011 ACD at 64-65, 69, 73;

FY 2012 ACD at 51, 57.

tt 39 u.s.c. S 36s2(aX2).

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data to be "generally reliable."38 This is another example that data "completeness" is not

an issue.

lll. The Commission's Reports are Useful

ln its Draft Report, the GAO also comments on the usefulness and transparency

of Commission reports on service performance. The GAO does not allege the

Commission ís deficient in performing its statutorily required duties; rather, the GAO

claims that Commission reports regarding other areas of service performance could be

more usefulto stakeholders.3s While the Commission recognizes additional analysis

may be useful, it is inaccurate to label Commission reports as "not sufficiently useful"

when the reports are tailored to current law. ln addition, the Commission has gone

beyond the requirements of current law by mandating quarterly reporting by the postal

Service, providing district-level trend analysis, and is working with congressional

requesters to explore the ability of the Postal Service to isolate rural service

performance.

A. Trend data

The GAO comments that "... PRC reports provided little analysis to facilitate an

understanding of results and trends below the national level."ao The Draft Report

acknowledges the Commission provides annual service performance trend data

analysis at the national level, but concludes this analysis is not "sufficiently useful for

determíning variations in delivery performance across the nation."41

tt Office of lnspector General, United States Postal Service, CRR-AR-12-005, Service

Performance Measurement Data - commercial Mail Audit Report, June 2s,2012, at3.

3s Draft Report at 1g-20.

oo td. at19.

o' ld. at 19-20.

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The Commission uses area- and district-level data that have been validated for

reliability, accuracy, and representativeness to: (1) analyze geographic effects of

storms; (2) identify districts that routinely report lower than average service performance

scores; and (3) compare regional versus nationwide results.a2 For example, the

Commission reported in fiscal year 2013 "[t]he Northeast area, especially for the

3-5-day service standard category [for Standard Mail flats], has been a consistent

underperformer and is a partial reason for below-target national scores."43 The following

year, which is the most recent Annual Compliance Determination, the Commission

conducted several district-level analyses, which: (1) evaluated the impact of severe

winter storms; (2) investigated low performing districts in the Northeast area;

(3) compared Parcels service performance in Chicago with nationwide results; and

(a) highlighted End-to-End Periodicals service performance in the Great Lakes area.aa

Analysis of data that have not been validated or may not be sufficiently robust,

such as quarterly district-level data, could result in misleading or erroneous reports.

B. Data do not currently exist to report separately on rural areas

The GAO states in its Draft Report that the Commission does not separately

reporl service performance data for rural areas.as This is correct. Although the

Commission has addressed service pedormance in rural and urban areas in other

dockets, it does not separately analyze rural service performance in its Annual

Compliance Determinations. Data to perform such an analysis have not been developed

because the PAEA and the regulations promulgated thereunder provide for a

determination of compliance with service performance standards on a nationwide

o' See FY 2014 ACD at 96-103, 110-112; FY 2O13ACD at 106, 135-142.

ot FY 2013 ACD at 106.

oo See FY 2O14ACD at 96-99, 101-103, 110.

as Draft Report at 22.

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basis.a6 However, the Commission evaluates a special study that, by regulation, it

requires the Postal Service to conduct every 2 years, which measures the final delivery

service performance to remote locations of Alaska, Caribbean, and Honolulu districts.aT

Recently, Senators Heidi Heitkamp and Jon Tester asked the Commission to

produce a semi-annual report on rural service performance for market dominant mail.a8

ln working with Senate staffers and the Postal Service to meet this request, the

Commission has discovered several fundament difficulties with respect to separately

reporting service performance results in rural areas. This is not unexpected, given that

the service performance measurement systems in place were designed by regulation to

produce results at the national level.as

First, there is no consensus definition of "rural." Several government agencies

define rural and non-rural, but significant differences exist among the definitions.

Second, the Postal Service must determine whether its data correspond with a

particular definition of rural. Third, it is unknown whether enough measurable mail

pieces exist between particular "rural" areas and other specified areas to provide

statistically meaningful results. Fourth and finally, the Postal Service must consider

potentially signíficant costs associated with extracting, compiting, or reporting these data

at a more disaggregated and granular level than what presently exists. The

Commission, the Postal Service, and the Senate requesters are working collaboratively

to better understand the challenges in resolving these issues with the goal of providing

the requested information.

ou 39 u.s.c. SS 3622, 3653, 3691; 39 c.F.R. S 30ss.2(g).

a7 See 39 C.F.R. $ 3055.7; see a/so FY 2011 ACD at77-79; FY 2O13ACD at 135-l'42.

ot Letter from the Honorable Heidi Heitkamp, U.S. Senator, and the Honorable Jon Tester, U.S.

senator, to Robert raub, Acting chairman, Postal Regulatory commission , May 26,201s.

as See Docket No. P12008-1, Service Performance Measurement Systems for Market Dominant

Produçts; Docket No. RM2009-1 1, Periodic Reporting of Service Performance Measurements and

Customer Satisfaction.

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C. The Commission has updated its website in response to the GAO's

recommendation

The GAO is also critical of the Commission's website, noting that information is in

multiple locations.so ln response, the Commission agrees that information it receives

and produces regarding performance measures for the Postal Service can be better

organized, and has updated its website in response to the GAO's recommendation. A

menu item on the homepage of the Commission's website titled "Reports/Data Service

Reports" has been adjusted to allow instantaneous access to service performance

related reports and dockets.

Under this tab, visitors to the Commission's website can locate all Annual

Compliance Determination reports since inception in 2007, Commission analysis of

Postal Service fiscal year program peformance and performance plans, rulemaking and

public inquiry dockets related to service performance, and periodic reports on service

pedormance filed with the Commission by the Postal Service. While these website

changes will make navigation easier, all of these reports have been consistently issued

widely to the public and postal stakeholders, including a request in the recent Annual

Compliance Determinations seeking feedback from users on how reporting could be

improved or made more useful.

Lastly, the Commission notes that the GAO's recommendations should be

directed towards the Commission rather than to the agency's Acting Chairman.

Although the Acting Chairman serves as the principal executive officer of the

Commission, neither he nor any other Commissioner has the power to exercise

unilaterally the Commission's statutory authority.5l This authority resides with the

Commission's five Commissioners.s2

50 Draft Report at 22.

u' See 39 U.S.C. $ 502; 39 U.S.C. g s0a(a); 39 C.F.R. S 3002.10(b).

ut 39 u.s.c. g so2(a).

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Ms. Lori Rectanus

September 11,2015

Page 17 of 17

ln closing, the Commission appreciates the opporlunity to offer comments on this

Draft Report and the recommendations contained within. The Commission is committed

to continual improvement and consequently has already acted upon, and is committed

to implementing, the GAO's recommendations. The Commission also appreciates the

constructive dialogue that the GAO has provided in discussing the Draft Report. The

Commission strongly urges the GAO to substantially revise its Draft Report to correct

the issues and inaccuracies identified in these comments.

With best wishes, I am

Robert G. Taub

Acting Chairman

Postal Regulatory Commission

901 New York Avenue . Suite 2OO. (202) 789-6820 . www.prc.gov