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RAOI. CRF 241 CHAIN OF EVENTS. March 31, 2011 – The Postal Service files proposed changes to CFR 241. we were concerned specifically with three proposed rules. t hey changed 241.1 Definition of a postmaster and t hey changed 241.3 Conversion of a Post Office to another type

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  • March 31, 2011 – The Postal Service files proposed changes to CFR 241.

  • we were concerned specifically with three proposed rules.

    • they changed 241.1 Definition of a postmaster and

    • they changed 241.3 Conversion of a Post Office to another type

    • of Postal operated retail facility is not a discontinuance

    • 3. they did not seek an advisory opinion from the PRC

  • April 14 - NAPUS and League retained the Law Firm of Ford and Huff

  • May 23 - A formal complaint was filed jointly to the PRC on behalf of

  • Postmasters

  • June 13 - The Postal Service filed a 40 page brief with the PRC requesting

  • that our complaint be dismissed

  • July 5 – Filed response to Postal Service brief

  • July 14 - The Postal Service implements all proposals to the CFR 241 with

  • the exception of those applying to our 3 complaints

  • July 27 - The Postal Service requested and RAOI Advisory Opinion from the PRC




  • August 11 - PRC issued an order dismissing our complaint citing that complaints one and two are based on Postal Services rules that have been proposed but not yet implemented and therefore are premature and not ripe for adjudication. They stated that “if, in the futures, the Postal Service implements a final rule that implicates Complainants interest, they may renew complaint”. The PRC dismissed complaint 3 as being moot since the Postal Service file for an Advisory opinion on Changes on July 27 in its proposal to review the discontinuance of over 3,500 postal facilities.

  • October 26 - The Postal Service issued the remaining proposed changes to take affect December 1, 2011, changed 241.1 Definition of a Postmaster and 241.3 Conversion of a Post Office to another type of Postal operated retail facility is not a discontinuance

  • November 7 - NAPUS and League files a motion to renew the dismissed complaint

  • November 14 - Postal Service files opposition of our motion to renew the dismissed complaint

  • November 30 - PRC denies our motion for renewal renew the dismissed complaint

  • December 1 - New Rules in place


After review of the PRC Advisory Opinion and Customer Appeals the Postal Service released rule changes that creates the option to:

  • Create subordinate Post Offices under other Post Offices / PM’s

    managed by a Postal Employee other than a PM

  • Change designation of Post Office to Stations / Branches

  • Effective date 12/01/2011


Options to Proceed

Recommendations from NPAUS Legal Advisors



File a new complaint with the PRC challenging the new regulations, but also provide factual information.


Wait until the Postal Service actually implements its regulations.


  • Attorney’s Comments by Phone:

  • “At best a 40% chance of winning the

  • Postmaster vs. any postal employee can run

  • a post office.”

  • “Litigation decision meant we were all in,”

  • meaning our chances of working out a deal

  • with the Postal Service would no longer

  • exist.



  • Current lower level Postmasters that earn less than 6 hours to be replaced by a non career employee

  • New non career employee will report to “Host” Postmaster

    • Assign administrative responsibility for lower level Post Office to a “Host” Postmaster (6 - 10 subordinate offices)

  • No subordinate office will report to a Host that is more than 75 miles driving distance


The Outcome of this Proposal Would:

  • Abolish all Level 16 and Below Postmaster Positions (17,728 Positions)

  • Replace 15,206 Postmaster Positions with Non-Career Employees and the Remainder would become 6 hour EPM Positions

Total number of post offices currently below level 18 are as follows

Total Number of Post Offices currently below level 18 are as follows:

Current Workload Service Credit level does not correspond with the value of the workload


  • Stakeholder Input received from various parties that help influence the need to move to option 4 of the POStPlan:

  • PRC provided input USPS should consider “circuit” Post Offices and reducing hours of service.

  • Congress stated a reduction in hours served may provide an ability to keep Post Offices open while utilizing a lower paid employee would solve our cost/revenue imbalance.

  • Customers responded stating their desire to preserve Post Office presence even at reduced hours of operation.

  • OIG said reduced hours of operation commensurate with the demand would help solve our rural Post Office situation.


  • Congress Concerns:

  • Maintain a Post Office in all of their Districts

  • Protect Jobs in their Districts (not necessarily full-time jobs)

  • Congress is not concerned about who manages the Post Office

  • Congress comments:

  • “In these tough economic times, Western New Yorkers are making necessary sacrifices and cutting back, and they expect their public servants to do the same.”

  • If the Postal Service did not present communities alternative to closure, such as reducing hours of operation, another possibility is to offer a community the opportunity to operate the post office with volunteers, or part-time employees, and to share in the profit.

  • "Many of these postmasters make 60-to-70 thousand dollars a year each, and our post offices don't generate near the revenue necessary to keep it going. So the questions is whether or not we share facilities and move them to a 24-7 location, where they might share with a convenient store, a Wal-Mart, a Walgreens, and have the postal facility there to reduce the overhead cost."


  • Customers are not concerned about who manages the Post Office and the hours of operation.

  • Hacker Valley, W. VA

    • The new post office is in a new building operated as a Contract Postal Unit or CPU, rather than a full=fledged post office with a salaried, benefit-receiving Postmaster.

    • The newly reopened post office is also open fewer hours per week than the former post office operation – 9 a.m. to 1 p.m. Monday through Saturday.

    • The CPU approach cost the Postal Service a little less than half of what it was paying to operate the old Hacker Valley Post Office, based on documents filed in closure hearings.

  • “It beats driving back and forth between Rock Cave or Diana to get a money order.”

  • “For some communities, it’s a wonderful idea, “she said. “Here, it cuts the hours of operation

  • but it’s much better than nothing.”

  • “I would hate to see any Postmasters lose their jobs, but it seems like this approach is worth looking at in rural areas with bottom line problems.”


  • NAPUS Concerns :

  • Protecting jobs for Postmasters on the Rolls

  • Protecting the title of Postmaster in offices that earn less than 8 hours and afford them an opportunity to move up to 8 hour positions

  • NAPUS and the League are the only Stakeholders left that are concerned about who manages a Post Office, the hours of operation, and the title of Postmaster


POStPlan Structure After Consultation


Local Community Meetings Will Now Offer 4 Options Instead of 3.

  • 1. Mergewith nearby Post Office and provide service from that

  • location; discontinue the Post Office.

  • 2. Engagewith a local establishment within the community and

  • establish a Village Post Office; discontinue the Post Office.

  • 3. Deliver service using either rural carriers or highway contract

  • routes; discontinue the Post Office.

  • 4. Maintainthe Post Office with reduced retail window service hours

  • commensurate to customer need.


POStPlan Grouping Guidelines

  • Maintains service in communities while reducing costs

  • “Administrative Post Office”

    • Administrative responsibility for offices known as

    • “Remotely Managed Post Offices” or “RMPOs”

    • Offices grouped which are geographically contiguous

  • Part Time Post Offices (PTPO) are stand alone offices

  • that do not fit the APO/RMPO model – these offices will

  • report directly to the district


POStPlan Structure

  • Current Post Office level was determined by:

    • WebCoins (January 2012)

    • Facility Database (FDB) which is also in CSV/SOV

    • National Finance Database – EDW

  • Administrative PO / RMPO Configuration

    • Administrative Post Office – Level 18 and above Post Offices

      • Postmaster assumes administrative responsibility for between one, and

      • up to ten RMPO’s

    • Remotely Managed Post Office

      • Current EAS level 11-16 and level 51 – 55 Post Offices

      • Reclassified as level 2, 4, or 6 offices

      • New levels based on FY 2011 earned hours in SOV / CSV

  • Raoi

    Candidate Offices for POStPlan Implementation

    • All current Level 16 and below Post Offices

    • considered based on adjusted earned workload

    • All Level 18 and above offices remain at their current

    • level

    • All Level 18 and above offices are potential

    • Administrative Post Offices

    • Excluded from POStPlan Consideration:

      • Closed/Suspended

      • Stations/Branches/CPO/CPU/VPO


    New Post Office Levels

    Non Career:

    • Level 2 - between .01 – 1.99 hrs. adjusted earned

    • workload / day

    • Level 4 - between 2.00 – 3.99 hrs. adjusted earned

    • workload / day

  • Career:

    • Level 6 - between 4.00 – 5.74 hrs. adjusted earned

    • workload / day

    • Level 18 – 5.75 hrs. adjusted earned workload /

    • day or more

      • Some will become Administrative Post Offices

  • Raoi

    Remotely Managed Post Office Structure

    • Level 2 – non-career employee, hourly wage based

    • on 2:10 per day at five days a week

      • Window services open 2 hours/day

    • Level 4 - non-career employee, hourly wage based

    • on 4:20 per day at five days a week

      • Window services open 4 hours/day

    • Level 6 - career employee, hourly wage based on

    • 6:30 / day

      • Window services open 6 hours/day

    • Saturday hours will remain the same


    Three Exceptions to RMPO Levels

    • First Exception: Post Offices that are in excess of 25 driving miles from

    • ANY retail facility the office will automatically be ranked as a level 6 with a

    • part time career employee(494 offices fall into this category).

    • Second Exception: Post Offices that are in excess of 25 radius miles from

    • an 8 hour or more retail operating APO will automatically be ranked as a

    • level 6 with a part time career employee.

    • Third Exception: When an RMPO cannot be established within an APO

    • grouping at 10 or less reporting offices within the same District, a Part Time

    • Post Office (PTPO) will be established at level 6 with a part time career

    • employee.


    Summary of the 21,828 offices - Old Level & New Level


    POStPlan Levels and Staffing Rules

    • Workload Service Credits (WSCs) will no longer apply to

    • Level 2, 4, or 6 offices

    • Administrative Post Offices will receive the cumulative

    • WSCs for all RMPOs under their responsibility

      • This may increase the levels of some offices

      • New level and workload may change exempt status

  • Workload considerations (EAS 18 and above)

    • Supervisor Work Credits (SWCs) for all RMPOs will be

    • credited to their host Administrative Post Office

      • This may cause the host to earn 1 or more supervisors

      • Lead Clerk calculations may apply

  • Raoi

    POStPLAN New Levels / Wages

    • Level 2 and level 4 Offices

      • Non-Career PMR employees

      • Hourly pay rate of $11.76 per hour.

      • 5 - 6 day per week assignment

      • Earn 1 hour of leave for 20 hours of work

    • Level 6 offices

      • Career Evaluated Postmasters (EPMs)

      • Hourly pay rate of $12.30 per hour.

      • 5 days per week assignment

      • PMR replacements


    • 4,185 Post Offices level 16 and below are vacant

    • 13,643 Incumbent Postmasters not impacted


    Potential Attrition and POSt Structure

    • Over 13,885

    • Postmasters are

    • eligible for retirement

    • or VER eligible.

    • 11,340 are in Level 18

    • and below offices

    • Postmaster attrition is

    • an opportunity to

    • backfill positions

    • under POSt Structure.




    September 30. 2014

    Finalized RIF impacted


    POStPlan Complete

    June 30. 2014

    RIF Notice


    Implementation of POStPlan

    5/15 Moratorium

    End Date




    Aug thru Jun 2014


    l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l l

    I I I I I I I I I I I I I I I I I I I I I

    I I I I I I I I I I l l l l l l l l l l l l l I I I I I I I I I I I

    I I I I I I I I I I I I I I I I I I I I I I I

    I I I I I I I I I I I I I I I I I I I I I I

    I I I I I I I I I I I I I I I I I I I I I

    I I I I I I I I I I I I I I I I I I I I I I

    I I I I I I I I I I I I I I I I I I I I I I

    Post PM Vacancies

    Continue Posting PM job as APO, RMPO, or PTPO

    5/7- 9



    June 30, 2014




    VER Employees

    Off the Roles




    With PRC


    Cutoff Date

    VER Offer



    RIF Letter Sent


    2 Events

    PRC Filing

    VER Offer


    Implementation Plan


    POStPlan Implementation

    • POStPlan will begin implementation with the vacant offices first

    • Community meetings will be scheduled and surveys sent out to

    • the affected community

    • Go back to RAOI Offices and schedule new community

    • meetings

    • Send out the survey forms allowing community input

    • Inform the community that they are now being considered

    • under the POStPlan process and that, unless they want their

    • office closed, it will remain open with reduced hours.


    POStPlan will be completed in multiple phases

    Phase 1 – Communication Plan

    Phase 2 – Notification Letters – May 9th – 11th

    Phase 3 – Upgrade Incumbant PM’s TBD

    Phase 4 – Post Level 18 and Above PM vacancies for limited

    competition – May 22 - 28

    Phase 5 – PRC Filing on POStPlan – May 25th


    POStPlan Implementation Phases (continued)

    Phase 6 – Opt in Date for VER final date – June 22nd

    Phase 7 – Review potential PMR hiring needs and resolve –

    June 30th

    Phase 8 – Finalized National Mapping (with input) – July 31st

    Phase 9 – VER effective date – July 31st

    Phase 10 – Post Level 18 and Above PM vacancies for limited

    competition – TBD

    Phase 11 – Migration Flow process outlined by Headquarters –

    August 15th


    POStPlan Implementation Phases (continued)

    • Phase 12 – PRC 90 Advisory Ruling date – Aug 23rd

    • Phase 13 – Headquarters to notify through Areas implementation of POStPlan for vacant offices only – Aug 27th and continue implementing for vacant offices only through June 30, 2014

      • Community meetings and surveys must take place providing input on four paths

      • Data will be collected through CSDC format

      • Headquarters will control path of implementation, local messaging, and file development through the CSDC format

    • Phase 14 – RIF impact remaining encumbered positions – June 30, 2014

    • FULL UP Implementation – Sep 30, 2014


    • POStPlan Update:

      • Plan will allow:

        • For directional movement of Postmasters to higher levels

        • RIF Protection for two years with no impact

        • Incentive based VER retirement $20,000

        • Two positional postings with limited competition pre VER and post VERA

        • Over 4,561 upgraded positions upgraded to level 18

      • These steps will allow for Postmasters to view their options and migrate through a two year cycle to retirement (early or optional) or through promotion





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