So we sent the PRC a link to our article and asked if it had reviewed the plan and asked, “Does the PRC believe it should review the plan, or is the USPS within its rights to transform the network without PRC input?”
A spokesperson provided us with PRC Chairman Michael Kubayanda’s response. It’s detailed, and we are providing it verbatim below, including the background bullet points he provided:
“Current law requires the Postal Service to request an advisory opinion from the Postal Regulatory Commission only for operational changes that affect service on a nationwide or substantially nationwide basis. Commission regulations require the Postal Service to file the request 90 days prior to implementation. Federal courts and the Commission have previously found that broad strategic plans alone do not trigger this legal requirement, although Commission leadership monitors such plans.
Specific elements of a strategy may trigger this legal requirement when the Postal Service moves to implement them on a nationwide basis. Earlier this year, the Commission identified the need for the Postal Service to request an advisory opinion on its proposed changes to Critical Entry Times for certain periodicals. Last week, on September 2, the Postal Service formally made the request for an advisory opinion on these changes. The Commission previously issued three extensive advisory opinions on proposed service changes from July 2021 through June 2022.”