National Association of Letter Carriers, AFL-CIO, Comment to PRC on Exigent Calculation


In its June 12 Order, the Commission invited interested parties to comment “on the Postal Service’s methodological approach for accounting for volume losses due to the Great Recession in a cumulative manner.” June 12 Order at 7. In its June 8, 2015 motion (“USPS Motion”), USPS explained how the removal of the “count once” rule from the Commission’s analysis of mail volume losses caused by the Great Recession increased the estimated loss from approximately 25.2 billon to approximately 35 billion pieces.

The NALC’s comments draws on analysis provided to NALC by Dr. Michael Crew, CRRI Distinguished Professor of Regulatory Economics at the Rutgers University Business School. Dr. Crew is an expert in postal and regulatory economics and has provided testimony, advice and analysis to the Commission in a number of cases, and has also consulted on issues of regulatory economics for numerous private and public entities.

In short, the NALC urges the Commission to reconsider its “new normal” framework, to allow USPS to recoup more in exigent surcharges than the Commission’s current framework allows.

The filing is available at