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The DMA'S Comments on USPS Transformation Plan
January 30, 2002
Ms. Julie S Moore
Executive Program Director
Office of Transformation, Strategic Planning
United States Postal Service
475 L’Enfant Plaza, SW
Washington, DC 20260-1520
re: Concepts for Postal Transformation
Dear Ms. Moore:
The Direct Marketing Association (DMA) appreciates the opportunity afforded its staff to meet last summer with the Office of Transformation team and to provide comments on the Outline for Discussion. We recognize the daunting nature of the task and that the September 30, 2001, document is a discussion draft. However, we are deeply concerned that this draft does not establish a base from which the Service can readily meet the very specific charge from Congress that the Service develop a comprehensive transformation plan.
In his testimony before the Committee on Government Reform of the House of Representatives last April, Comptroller General David Walker recommended that the Service develop a comprehensive transformation plan "that would identify the actions needed to address [its] financial, operational, and human capital challenges and establish a timeframe and specify key milestones for achieving positive results." [GAO-01-598T at p.2] In a June 14, 2001 letter the leaders of the Senate Committee on Governmental Affairs endorsed the Walker recommendation and directed that Service prepare and transmitted a plan to Congress.
The preface to the discussion draft states that "[t]he report is designed to generate discussion among all postal stakeholders to address the fundamental question…what should America’s postal system be like (or transform to) in the next decade?" While we recognize the importance of considering the views of stakeholders, we are concerned that the Service, whether or not to avoid controversy, chose not to provide its own specific views on transforming itself. Consequently, although the draft provides a fairly comprehensive discussion of the current state of its affairs, the draft does not convey the sense of urgency that pervades the postal community that transformation must begin
immediately to preserve this nationwide delivery system. That urgency is also implicit in the Service having been assigned the distinction of being placed on the General Accounting Office’s "high-risk" list of government agencies.
In place of specific plans with timetables and measurable objectives that might have been set forth for discussion and comment in the draft, the September 30 document offers what purports to be three parallel transformational phases. They are as follows: Phase One--Incremental Administrative and Operational Improvement (actions possible under current law); Phase Two--Moderate Legislative Reform; and, Phase Three--Structural Transformation. The DMA agrees that these three phases establish a workable framework to craft a transformation of the Postal Service. They should progress in parallel.
The discussion draft also has duplicative tasks in more than one phase. For example, streamlining networks through "consolidation initiatives" is part of Phase One while the Phase Two task is determining the "size, number, location … of all plants." This may be due to the fact that the Service has not established any plan of action for transformation. The DMA believes it is imperative that the Service begin the transformation immediately.
The DMA’s specific recommendations begin with the Mailing Industry Task Force. The Postal Service has already had lengthy and significant discussion with its customers. The Task Force Report contains significant recommendations which the Service should already have begun to implement. The DMA’s question is, "Why not?"
Phase One. Under current law, the Postal Service has authority to change mail classifications, adjust delivery and service standards, and establish the level of retail access. Phase One should not be constricted to assume the same standards as today. It is time to think outside the box. The Service should:
Phase Two. The DMA is very disappointed that the draft does not contain specific proposals for "interim" legislative reform. There is very little time left to attempt enactment of reform legislation in this Congress. The March 30th date for USPS delivery of its transformation plan is probably too late. A group of mailers and postal employee groups have worked together to craft compromise reform legislation. Rep. John McHugh and Rep. Danny Davis have embraced that attempt and have prepared draft legislation. Sadly, USPS has been silent on that bill. This is the only piece of legislation on postal reform that has a chance of enactment this Congress. USPS should be working with the legislators, its customers and employees to amend the draft so that we can all support it. Why is that not being done at this very moment?!!! Any interim legislation must:
Phase Three. The Transformation Plan should establish a framework to discuss and debate the future of the Postal Service. That debate must cover:
The DMA cannot stress how imperative it is for the Postal Service to move quickly in all three phases. Phase One should already be in full bloom. We stand ready to work with the Postal Service on transformation. We need it. For the Postal Service to miss this chance at transformation would be tragic. Our economy cannot withstand a $900 billion
per year disruption. Nine million Americans need their jobs. Stealing a phrase used by President Bush, "Let's roll." The time for action is now.
Senior Vice President, Government Affairs
The Direct Marketing Association