VOTE FORWARD et al v. DEJOY et al

Filing 16

MOTION for Preliminary Injunction by AMY BOLAN, AARON CARREL, COLORADO ORGANIZATION FOR LATINA OPPORTUNITY AND REPRODUCTIVE RIGHTS, INDERBIR SINGH DATTA, DANTE FLORES-DEMARCHI, PAUL HUNTER, SEBASTIAN IMMONEN, KATHRYN MONTGOMERY, SEAN MORRISON, PADRES & JOVENES UNIDOS, LINDA ROBERSON, MARTHA THOMPSON, VOCES UNIDAS DE LAS MONTANAS, VOTE FORWARD, GARY YOUNG (Attachments: #1 Memorandum in Support, #2 Exhibit Index, #3 Exhibit USPS OIG Report (Aug. 2020), #4 Exhibit USPS, Postal Operations Manual (Excerpts), #5 Exhibit USPS OIG Report (May 2020), #6 Exhibit USPS, Mandatory Stand-Up Talk: All Employees, #7 Exhibit Leaked USPS Powerpoint, #8 Exhibit DeJoy Testimony - House Oversight Hearing (Aug. 24, 2020), #9 Exhibit DeJoy Testimony - Senate Hearing (Aug. 21, 2020), #10 Exhibit Statement of DeJoy - House Oversight Comm. (Aug. 24, 2020), #11 Declaration Professor Justin Grimmer, #12 Exhibit USPS, Congressional Briefing (Aug. 31, 2020), #13 Exhibit Chart of States Where Voters' Mail-In Ballots Are Impacted By Defendants' Delays, #14 Exhibit USPS Letter to Pa. (July 29, 2020), #15 Declaration Eitran D. Hersh, #16 Exhibit House Oversight Hearing on USPS Operations - Transcript (Aug. 24, 2020), #17 Exhibit Senate HSGAC Hearing on USPS Operations - Transcript (Aug. 21, 2020), #18 Declaration Aaron Carrel, #19 Declaration Martha Thompson, #20 Declaration Kathryn Montgomery, #21 Declaration Sebastian Immonen, #22 Declaration Amy Bolan, #23 Declaration Inderbir Singh Datta, #24 Declaration Scott J. Forman of Vote Forward, #25 Declaration Alex Sanchez of Voces Unidas De Las Montanas, #26 Text of Proposed Order)(Duraiswamy, Shankar)

EXHIBIT 10

CONGRESSIONAL BRIEFING:
Transportation & Service
Performance Updates
August 31, 2020

Transportation Performance
Data Through 8/29/20

2

Transportation Analysis Overview
Service Impacts: USPS transportation and logistics professionals manage an average flow of over 390 million mail pieces
daily throughout the Postal Service network, which includes 285 processing facilities and about 35,000 retail locations.
Postal Service facilities are linked by a complex transportation network that depends on the nation’s highway, air, rail, and
maritime infrastructures. The success of each system affects the success of others. If surface transportation departs late or
unscheduled trips are added, the connection between processing facilities, post offices, airlines, and others become
misaligned, impacting downstream operations and hindering efforts to meet service performance.
Financial Impacts: In FY 2019, the Postal Service spent over $550 million extra in transportation to mitigate delays that
occurred in the network:
• $266 million in extra trips;
• $130 million in overtime;
• $14 million in late trips; and
• $140 million in air freight mitigation
Effectively aligning operational plans and a timely, consistent transportation network will improve service and reduce cost.
For more information, please reference the Office of Inspector General Audit Report Number 20-144-R20

3

Transportation Summary
Trips on Time vs. Late and Extra Trips (Weekly)
35000

300000

30000

250000

Number of Trips on Time

200000
20000
150000
15000
100000
10000

50000

0

Number of Late and Extra Trips

25000

5000

7-Jun

14-Jun

21-Jun

28-Jun

5-Jul

Number of Trips On Time

12-Jul

19-Jul

Number of Late Trips

26-Jul

2-Aug

9-Aug

16-Aug

23-Aug

0

Number of Extra Trips

Trips on time references left axis. Late and extra trips references right axis

Source: SV - Surface Visibility

4

Late Trips Analysis

Source: SV - Surface Visibility

5

Extra Trips Analysis

Source: SV - Surface Visibility

6

Service Performance
Data Through 8/26/20

7

50%

75%

70%

65%

First-Class Mail
USPS Marketing Mail

All scores for current week-to-date (week of 8/22) are through 8/26. USPS Marketing Mail score for current week-to-date does not include Saturation Mail as that data is available after the end of the week i.e. on 9/1
8/22/2020

8/15/2020

8/8/2020

8/1/2020

7/25/2020

7/18/2020

7/11/2020

7/4/2020

7/1/2020

6/27/2020

6/20/2020

6/13/2020

6/6/2020

5/30/2020

5/23/2020

5/16/2020

5/9/2020

5/2/2020

4/25/2020

4/18/2020

4/11/2020

4/4/2020

4/1/2020

3/28/2020

3/21/2020

3/14/2020

3/7/2020

2/29/2020

2/22/2020

2/15/2020

2/8/2020

2/1/2020

1/25/2020

1/18/2020

1/11/2020

1/4/2020

1/1/2020

12/28/2019

12/21/2019

12/14/2019

12/7/2019

11/30/2019

11/23/2019

11/16/2019

11/9/2019

11/2/2019

10/26/2019

10/19/2019

10/12/2019

10/5/2019

10/1/2019

9/28/2019

COVID-19

California Wildfires

Pitney Bowes Cyber Attack

Tropical Storm Imedla
Houston Roof Collapse

9/14/2019
9/21/2019

55%

Hurricane Dorian

60%

9/7/2019

Rochester Mercury Spill

80%

8/31/2019

85%

8/24/2019

8/17/2019

On-Time Score

Official Scores
52 Week Trend

100%

95%

90%

Periodicals
8

Presort First-Class Mail
Score Breakdown – Processing vs Last Mile
• Baseline Period: 3/14 - 7/3
• Current week-to-date: 8/22 - 8/26

OVERALL

OVERALL

100%

5.30%

0.28%

LOWER
THAN
BASELINE

HIGHER
THAN
8/1 – 8/7

LAST MILE

5.58%
2.21%

PROCESSING
LOWER
THAN
BASELINE

LOWER
THAN
BASELINE

0.00%

On-Time Score

-1.00%
90%
-1.50%
85%
-2.00%
80%

Last Mile Impact

-0.50%

95%

-2.50%
-3.00%

75%

Overall Score

Processing Score

1 Extra Day

Last Mile Impact

Last Mile Impact represents the score decrease caused by time spent in the last mile (from last processing scan to delivery); Processing score represents service performance from USPS possession to last processing scan
measured against the service expectation; Overall score represents service performance from USPS possession to delivery (i.e. includes the last mile) measured against the service expectation; 1 Extra Day represents the
overall score if the mailpiece had 1 extra day to meet service expectations; Scores are NOT weighted and may NOT match the official scores in slide 1 which are weighted.

9

Single Piece First-Class Mail
Score Breakdown – Processing vs First & Last Mile
• Baseline Period: 3/14 - 7/3
• Current week-to-date: 8/22 - 8/26

OVERALL

HIGHER
THAN
8/1 – 8/7

100%

PROCESSING

4.26%
4.37%

OVERALL

LAST MILE

FIRST MILE

3.28%

0.42%

0.56%

LOWER
THAN
BASELINE

LOWER
THAN
BASELINE

LOWER
THAN
BASELINE

LOWER
THAN
BASELINE

0.00%
-0.50%
-1.00%
-1.50%

90%

-2.00%
85%

-2.50%

Last Mile Impact

On-Time Score

95%

-3.00%

80%

-3.50%
75%

-4.00%

Overall Score

Processing Score

1 Extra Day

First Mile Impact

Last Mile Impact

First Mile Impact represents the score decrease caused by time spent in collection; Last Mile Impact represents the score decrease caused by time spent in the last mile (from last processing scan to delivery); Processing
score represents service performance from USPS possession to last processing scan measured against the service expectation; Overall score represents service performance from USPS possession to delivery measured 10
against the service expectation; 1 Extra Day represents the overall score if the mailpiece had 1 extra day to meet service expectations; Scores are NOT weighted and may NOT match the scores on slide 1 which are weighted.

USPS Marketing Mail
Score Breakdown – Processing vs Last Mile
• Baseline Period: 3/14 - 7/3
• Current week-to-date: 8/22 - 8/26

OVERALL

OVERALL

100%

0.10%

0.40%

LOWER
THAN
BASELINE

HIGHER
THAN
8/1 – 8/7

LAST MILE

0.49%
8.26%

PROCESSING
LOWER
THAN
BASELINE

LOWER
THAN
BASELINE

0.00%

On-Time Score

-1.00%
90%
-1.50%
85%
-2.00%
80%

Last Mile Impact

-0.50%

95%

-2.50%
-3.00%

75%

Overall Score

Processing Score

1 Extra Day

Last Mile Impact

Last Mile Impact represents the score decrease caused by time spent in the last mile (from last processing scan to delivery); Processing score represents service performance from USPS possession to last processing scan
at the destination plant measured against the service expectation; Overall score represents service performance from USPS possession to delivery (i.e. it includes the last mile) measured against the service expectation;
1 Extra Day represents the overall score if the mailpiece had 1 extra day to meet service expectations; Scores are NOT weighted and may NOT match the official scores in slide 1 which are weighted.

11

Periodicals
Score Breakdown – Processing vs Last Mile
• Baseline Period: 3/14 - 7/3
• Current week-to-date: 8/22 - 8/26

OVERALL

OVERALL

100%

0.60%

2.29%

LOWER
THAN
BASELINE

HIGHER
THAN
8/1 – 8/7

LAST MILE

2.88%
7.83%

PROCESSING
LOWER
THAN
BASELINE

LOWER
THAN
BASELINE

-1.00%

95%

-2.00%

90%

-3.00%
-4.00%

85%

-5.00%
80%

-6.00%

Last Mile Impact

On-Time Score

0.00%

-7.00%

75%

-8.00%

70%

-9.00%

65%

-10.00%

Overall Score

Processing Score

1 Extra Day

Last Mile Impact

Last Mile Impact represents the score decrease caused by time spent in the last mile (from last processing scan to delivery); Processing score represents service performance from USPS possession to last processing scan
at the destination plant measured against the service expectation; Overall score represents service performance from USPS possession to delivery (i.e. it includes the last mile) measured against the service expectation;
1 Extra Day represents the overall score if the mailpiece had 1 extra day to meet service expectations; Scores are NOT weighted and may NOT match the official scores in slide 1 which are weighted.

12