Statutory Review of the System for ) Docket Nos.: Regulating Rates and Classes for ) RM2024-4 Market Dominant Products ) RM2022-5 (Consolidating Docket Nos. ) RM2022-6 RM2024-4, RM2022-5, RM2022-6, ) RM2021-2 and RM2021-2) )

Reply of the Coalition for a 21st Century Postal Service

The Coalition for a 21st Century Postal Service (“C21”)1 hereby submits these comments in response to the Commission’s invitation in the above-captioned proceeding. C21 commends the Commission for initiating this review and reconsideration of the Market Dominant (“MD”) rate- and class-setting system substantially before the five-year interval it had previously planned. The regrettable and somewhat alarming results to date of the Postal Service’s Delivering for America Plan (“DFA” or “Plan”) and the contribution of pricing to those results more than justify that decision.

C21’s mailing, shipping and supply chain members represent a broad cross-section of the business mailing ecosystem which generated $1.9 trillion in sales and employed nearly 8 million workers in 2022.2 This community is dependent upon an efficient, reliable, ubiquitous and affordable universal postal system that combines and fully serves both mail and packages.
It is hardly exaggerating to say that the future of the postal system is at stake in this proceeding. The additional MD rate authority granted to the Postal Service in RM 2017-3 and its relentless application in full in support of the Plan has not generated the long-term financial stability sought by this Commission. To the contrary: notwithstanding $120 billion from Congress in grants and balance sheet adjustments3, the Postal Service managed to lose $6.5 billion in FY 2023, a breathtaking nearly 9% of its business, and failed to apply the new authority judiciously at any time since first conferred. They also fell far short of their original target of breaking even in FY 2023. And all this while service has declined very seriously, leaving customers paying far more for less. 

To view a chart laying out postal volumes over the years, as well as the rest of the document, please download it below: