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We recommend that the Postal Service review the confusing array of special services that provide the customer with information about delivery for an additional fee. These services include certified mail, return receipt, delivery confirmation, signature confirmation, and certificates of mailing. Each service comes with a separate menu of attributes, but many of these services share some of the same attributes. Each also comes with a separate set of usage restrictions, e.g., delivery confirmation and signature confirmation cannot be used for First-Class letters, while basic return receipt can only be purchased with another service, such as certified.
Return receipt and certified, which are based on costly manual operations, have high fees and a history of poor service quality. See Carlson Brief at 10-16; Popkin Brief at 2-4; PRC Op. R97-1, para. 5951. The Commission has been concerned with this quality of service issue since R90-1. See PRC Op. R90-1, paras. 6576-77, fn. 110. Apparently, the Inspection Service also has been concerned. A Postal Service Inspection Service audit report reveals nationwide problems with certified and return-receipt mail, e.g., failure to maintain proper control over the return receipts, especially with regard to mail sent to the IRS and the state tax agencies, and mail delays. USPS-LR-I-200 at 18-20.
Because return receipt and certified are often used in high volume situations (e.g., mailers sending in tax returns, where volume tends to peak around filing deadlines) improvements to these manual-based systems may be difficult. Indeed, the Service admits "obtaining signatures of each return receipt before delivery is not always practical when many return receipts are delivered at one time." Postal Service Reply Brief at VII-16. It argues that employing more personnel to solve the problem would increase fees. Ibid. It concludes that allowing large organizations to sign for receipt of all certified mail at the time of delivery, and then complete the return receipt cards later "may at least be temporarily necessary in order to avoid even more problematic delivery delays." Id. at VII-17.
We have constrained fees for return receipt and certified because of the quality of service issue. The Service on brief asserts that if the fees for these services are set too low it "may actually discourage such service improvements, however, since attention might be diverted to products with higher contributions." Postal Service Reply Brief at VII-14. See also Id. at VII-18: "[P]ostal management may have a reduced financial incentive to focus resources on a particular product for which fees do not provide a significant contribution above costs." We cannot accept this argument in a rate setting context given the clear directives of the statute; customers receiving poor service should not also pay premium rates.
We suggest that extending the more electronically-based delivery and signature confirmation services to First-Class letter mail would have a mitigating effect on or, perhaps, even obviate the need to address many problems associated with the manual accountable services. Electronic confirmation services do not require the extensive interaction between postal employees and the sender and recipient of First-Class Mail, as do the currently available manual services. They are, therefore, less costly to the Postal Service. For example, the Service's cost for each of its roughly 275 million Certified Mail transactions is on the order of $1.60 per piece, compared to approximately $0.40 for a Delivery Confirmation transaction.
An opportunity to extend one highly regarded existing service as a substitute for another poorly perceived service should not be ignored. This is especially so when the potential exists to drive more than $300 million in costs out of the system and to offer customers a high-tech, lower price option.
 Postal Rate Commission http://www.prc.gov Voice: (202) 789-6800 Fax: (202) 789-6886 prc-admin@prc.gov |
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