of market dominant measurement systems, and asserts that those systems are not at issue in this docket (§ 3691(b)(1)(D)). Id. Service standard factors. The PAEA requires service standards to take the following factors into account: (1) the actual level of service that Postal Service customers receive under previous and current service standards; (2) the degree of customer satisfaction with Postal Service performance in the acceptance, processing and delivery of mail; (3) the needs of Postal Service customers, including those with physical impairments; (4) mail volume and revenues projected for future years; (5) the projected growth in the number of addresses the Postal Service will be required to serve in future years; (6) the current and projected future cost of serving Postal Service customers; (7) the effect of changes in technology, demographics, and population distribution on the efficient and reliable operation of the postal delivery system; and (8) the policies of title 39 generally and such other factors as the Postal Service determines appropriate. 39 U.S.C. § 3691(c). The Postal Service states that it has Commission approved measurement systems in place for measuring both level of service and customer satisfaction. Tr. 7/2437-38. It has also considered the information gathered from market research when developing the proposed rules, citing to USPS-T-11, USPS-T-12, and USPS-T-13 at 4 (§ 3691(c)(1-3)). The Postal Service asserts it has considered future declining mail volumes which contribute to revenue declines that currently outpace cost reductions (§ 3691(c)(4,6)). at 2438. It also comments on the growth in the number of delivery Id. points that impact overall costs (§ 3691(c)(5)). Id. at 2439 The Postal Service states that the current processing network was established in response to many decades of mail growth, but because volumes have since declined, the Postal Service now has
of market dominant measurement systems, and asserts that those systems are not at issue in this docket (§ 3691(b)(1)(D)). Id. Service standard factors. The PAEA requires service standards to take the following factors into account: (1) the actual level of service that Postal Service customers receive under previous and current service standards; (2) the degree of customer satisfaction with Postal Service performance in the acceptance, processing and delivery of mail; (3) the needs of Postal Service customers, including those with physical impairments; (4) mail volume and revenues projected for future years; (5) the projected growth in the number of addresses the Postal Service will be required to serve in future years; (6) the current and projected future cost of serving Postal Service customers; (7) the effect of changes in technology, demographics, and population distribution on the efficient and reliable operation of the postal delivery system; and (8) the policies of title 39 generally and such other factors as the Postal Service determines appropriate. 39 U.S.C. § 3691(c). The Postal Service states that it has Commission approved measurement systems in place for measuring both level of service and customer satisfaction. Tr. 7/2437-38. It has also considered the information gathered from market research when developing the proposed rules, citing to USPS-T-11, USPS-T-12, and USPS-T-13 at 4 (§ 3691(c)(1-3)). The Postal Service asserts it has considered future declining mail volumes which contribute to revenue declines that currently outpace cost reductions (§ 3691(c)(4,6)). Id. at 2438. It also comments on the growth in the number of delivery points that impact overall costs (§ 3691(c)(5)). Id. at 2439 The Postal Service states that the current processing network was established in response to many decades of mail growth, but because volumes have since declined, the Postal Service now has
Advisory_Opinion_%2009282012.docx