Right-Sizing the Mail: Advocating to Retain or Reuse Historic Post Offices

  

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In Modesto, Calif., the city’s 1933 New Deal–era Beaux Arts main post office—complete with 1937 murals by Treasury Relief Arts Project artist Ray Boynton—is currently being offered for sale at a government auction. In Northfield, Minn., the 1936 Gothic Revival main post office branch in the heart of the Downtown National Register District is slated for closure and sale. In Lakewood, N.J., the 1938 post office, with its delicate Grecian relief window surrounds, is facing a similar future, as are historic post offices in Norwich, Conn.; Reno, Nev.; York, Pa.; Fort Worth, Tex.; Eugene, Ore.; and hundreds of other communities across the nation.

These historic post offices are among the thousands of postal facilities the US Postal Service (USPS) is planning to close, vacate, and/or sell in the near future to address annual operating deficits of more than $8.5 billion. In an effort to “right-size” the postal system in the face of declining mail volumes and reduced patronage, since 2009 the USPS has been consolidating its retail locations in larger post office locations and contracting out more of its services to outside retailers, now termed “Village Post Offices.” On July 26, the USPS released a list of more than 3,700 post offices nationwide that it plans to study for closure. This list does not appear to include the hundreds of postal facilities studied and proposed for closure since 2009, and it is possible that more waves of closures will follow. Recently, the Postmaster General referred to plans to close roughly half of the existing 32,000 postal facilities in the US in the next six to seven years.

The range of properties the USPS is slating for closure is diverse, encompassing large main post offices in downtown areas; smaller sites in urban, suburban, and rural areas; and facilities of all periods of construction. As historic postal properties slated for sale and/or closure conclude their period of use as postal facilities, communities are responding in myriad ways, from engaging in legislative advocacy to preserve postal service at the site or in the downtown area to identifying preservation-friendly buyers or new public uses for the buildings. This work has not been easy, as until recently the USPS process for closing postal facilities was difficult to navigate, with limited public notice and participation and different processes for different facility designations.

As public and congressional concern over the effects of post office closures mounted during 2010, the USPS revised its public notice and involvement processes and provided more information to the public about the extent of proposed closures. This article provides details on the US Postal Service discontinuance and retail optimization process for historic postal facilities, and how preservation interests can get involved to advocate for preserving postal services or to facilitate positive outcomes for discontinued historic postal properties.

It is important to note that the USPS discontinuance process will likely evolve and change in the coming months. The USPS has requested an advisory opinion on its plans from the Postal Regulatory Commission, which is required by law before the USPS embarks on any program that could have a significant impact on postal service to the nation. This process will take several months. Those interested in this issue should consult the resources cited at the end of this article for the most up-to-date information.

Why is the USPS closing or selling so many retail postal facilities?

Since a major reorganization of the USPS in 1970, the service has been responsible for supporting itself and receives no federal appropriations for operations. The Postal Service has been operating with annual budget deficits of up to $8.5 billion since 2000 due to steeply declining mail volumes, increased delivery costs, and fundamental changes in how the world communicates. These challenges spurred the USPS to rethink its service model, and in 2010 the agency released Ensuring a Viable Postal Service for America: An Action Plan for the Future, which outlines ways to save $123 billion by 2020. Its proposals include expanding access to postal services where customers already shop, partnering with other retailers, and creating more automated services. As this shift occurs, the USPS plans to reduce existing postal facilities by closing locations, and in cases where the USPS owns the post office building, selling the property. (It is important to note that the USPS owns only about 13 percent of its facilities, meaning that most of these closures would be lease terminations versus building sales.) In limited cases, the USPS is selling properties and leasing back retail space from new owners to reduce operating costs.

How can I find out if postal facilities in my community are slated for closure or sale?

On July 26, the USPS released a list of more than 3,700 facilities it is studying for closure, but up to 1,400 additional offices currently under study for closure may not be reflected here. Typically a community will learn a local facility is under consideration for closure when the USPS initiates a feasibility study. Beginning July 14, 2011, the USPS will mail to those in the affected zip code a written notice of the preparation of a feasibility study for discontinuance of a facility and a customer questionnaire, will notify the key public official in the associated community, and will consult with the local postmaster. (For more detailed information on this process, see 39 CFR 241, Post Office Organization and Administration: Establishment, Classification, and Discontinuance.) Unfortunately, the new regulations only apply to closure studies initiated after July 14, 2011.

What is the USPS process for deciding whether to close a postal facility?

Recently amended USPS regulations on discontinuance of a postal facility (36 CFR 241.3) outline the decision-making process. According to the regulations, the discontinuation study process begins with selection for a feasibility study process based on criteria such as insufficient customer demand, insufficient workload for existing employees, availability of reasonable alternate service access, and profitability. Federal law and USPS regulations prohibit the USPS from closing postal facilities solely because a branch is operating at a deficit.

The feasibility study must consider a standard set of factors including “the effect on the community served; the effect on employees of the USPS-operated retail facility; compliance with government policy established by law that the Postal Service must provide a maximum degree of effective and regular postal services to rural areas, communities, and small towns where post offices are not self-sustaining; the economic savings to the Postal Service; and any other factors the Postal Service determines necessary.” (39 CFR 241.3(a) 3) The USPS must provide notice of the feasibility study and a questionnaire on closure impacts to the public served in the associated zip code by mail and at the postal facility.

If the USPS decides, based on the feasibility study, to propose closure of the postal facility, the agency issues a formal written proposal assessing the effect of the action on community postal needs, the overall effect on the community, effect on employees, and cost savings. The notice of the proposal is only posted in local postal facilities. The public has 60 days to comment on the proposed action before the USPS issues a determination, and the USPS is required to hold a public meeting to solicit input (a new requirement). After the USPS issues its final determination, which is posted in local postal facilities, the public may appeal the decision to the Postal Regulatory Commission within 30 days. The commission can refer the matter back to the USPS for further consideration within 120 days, but cannot modify the determination.

Is sale the only option when the USPS decides to close a postal facility?

Federal law gives the USPS sole discretion to sell or otherwise dispose of a property or property interest as it deems necessary. However, in limited cases, the USPS has negotiated with new owners of postal facilities to lease from them a portion of previously existing retail space for postal service use. Whether lease-back is feasible depends on service demands; the willingness of the new owners to enter a lease agreement; the compatibility of the new owners’ use of the building with a secure, separate postal space; and lease pricing considerations.

What protections are afforded historic post office buildings after closure and sale?

Sale of post office facilities is subject to review under Section 106 of the National Historic Preservation Act. Currently there is no programmatic agreement between the USPS and the Advisory Council on Historic Preservation that outlines standard procedures for resolving adverse effects to historic properties being sold under this effort. A draft programmatic agreement is under review with the Advisory Council.

To date, the USPS has resolved adverse effects to historic properties going out of federal ownership by placing protective covenants on the properties before sale, to be monitored by state historic preservation offices (SHPOs). These covenants typically require preservation and maintenance of the interior and exterior of the facility in accordance with the Secretary of the Interior’s Standards for Rehabilitation of Historic Properties and require SHPO review and approval of new construction at, alteration of, or remodeling of the facility.

What happens to significant artworks in post office buildings slated for sale?

Artworks in postal facilities are not sold with the postal facility. Many of these works were commissioned by the US Treasury’s Section of Fine Arts in the 1930s and 1940s and, based on their program requirements, must remain in USPS ownership and reasonably accessible to the public. When a facility with significant artwork is sold to a private buyer, the USPS tries to negotiate an art loan agreement with the buyer that includes responsibility for care of the artwork and a commitment that the artwork be reasonably accessible to the public. If this cannot be negotiated, the USPS must remove the artwork and put it in another postal facility or house the art on loan with a responsible steward.

What can preservation advocates and supporters do to advocate for keeping a post office in use or helping to facilitate good outcomes for sold postal facilities?

Participate in the USPS discontinuance process and National Historic Preservation Act Section 106 review process. Make sure the USPS, your elected officials, and your state historic preservation office know your community’s concerns about the historic importance and future of your postal facility as early as possible. The USPS typically initiates Section 106 review under NHPA after the agency has made its decision to close a facility and put it up for sale, so participation in the feasibility study process is paramount. Know the process: Use the information provided above and familiarize yourself with the USPS regulations on discontinuance of postal facilities explained in CFR 38 241.3.

Assist in identifying preservation-minded buyers, promote incentives available for historic buildings, and seek out other public uses for the postal facilities. You may not be able to prevent the closure and sale of a local postal facility, but you can help ensure that the historic post office continues to be a presence in your community.

One the biggest challenges the USPS faces in selling historic property is finding preservation-minded buyers who are savvy about adaptive use and understand how historic preservation covenants and incentives work. Do all you can to publicize the availability of a historic postal facility through your local preservation networks and educate the public on local, state, and federal incentives for rehabilitating historic properties.

Engage local, state, and federal elected officials. The news is full of stories about communities fighting the closure of their post office branch, and many of these communities have benefited from the support of their local leadership and congressional delegation. Regardless of party affiliation, access to postal service is an issue that resonates with political leaders and voters.

Learn about successful examples of adaptive reuse of post offices.

 

Learn more about the Village Post Office program.

If your community is concerned with keeping postal services in the downtown area or other neighborhood, one option is the USPS “Village Post Office” model. The USPS introduced the Village Post Office as a potential replacement option for communities affected by post office closures in 2011. According to the USPS, “Village Post Offices would be operated by local businesses, such as pharmacies, grocery stores and other appropriate retailers, and would offer popular postal products and services such as stamps and flat-rate packaging.” These facilities can also offer post office boxes. More information on this program and how to open a Village Post Office is available here.

 

Important Resources