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 3

AUDIT REPORT

Late and Extra Trips at the
Philadelphia, PA,
Processing and Distribution
Center
May 13, 2020

Report Number 20-164-R20

May 13, 2020
MEMORANDUM FOR:

JUDITH W. HERRICK
MANAGER, PHILADELPHIA METROPOLITAN DISTRICT

FROM:

Matthew B. Hartshorn
Director, Plant Evaluation Team

SUBJECT:

Audit Report – Late and Extra Trips at the Philadelphia, PA,
Processing and Distribution Center
(Report Number 20-164-R20)

This report presents the results of our audit of Late and Extra Trips at the Philadelphia,
PA, Processing and Distribution Center.
We appreciate the cooperation and courtesies provided by your staff. If you have any
questions or need additional information, please contact Jeff Giordano, Operational
Manager, or me at 703-248-2100.
Attachment
cc: Chief Operating Officer and Executive Vice President
Acting Vice President, Processing and Maintenance Operations
Vice President, Logistics
Acting Vice President, Eastern Area Operations
Corporate Audit and Response Management

Late and Extra Trips at the Philadelphia, PA,
Processing and Distribution Center

20-164-R20

Background
This report presents the results of our self-initiated audit of late and extra trips at the
Philadelphia Processing and Distribution Center (P&DC) in Philadelphia, PA (Report
Number 20-164-R20). We conducted this audit to provide U.S. Postal Service
management with timely information on operational risks at the Philadelphia P&DC.
Late trips occur when various conditions cause a delay in the arrival or departure of
transportation beyond the scheduled times. In April 2019, Postal Service Headquarters
management informed plant management to eliminate all late trips and specified that all
trips should depart and arrive to their destinations on time. From July 1 to December 31,
2019, the Postal Service reported 591,140 late trips from P&DCs to delivery units.
When mail processing operations do not process mail timely or mail volume is above
normal or expected levels, managers may have to call extra trips to transport this mail.
From July 1 to December 31, 2019, the Postal Service reported 176,940 extra trips from
P&DCs to delivery units. Late and extra trips to delivery units can cause disruptions and
increase the number of carriers returning after 6 p.m. When carriers return after 6:00
p.m., customer service can suffer, and mail collected by the carriers may be late to the
P&DC. In addition, late returning carriers can result in increased overtime and penalty
overtime costs.
The Philadelphia P&DC is in the Philadelphia District within the Eastern Area. The
P&DC processes letters, flats, and parcels. From July 1 to December 31, 2019, it
reported 13,206 late trips (third highest among P&DCs) and 1,297 extra trips (40 th
highest among P&DCs) from the plant to delivery units.
Our fieldwork was completed before the President of the United States issued the
national emergency declaration concerning the novel coronavirus disease outbreak
(COVID-19) on March 13, 2020. The results of this audit do not reflect operational
changes and/or service impacts that may have occurred at this facility as a result of the
pandemic.

Objective, Scope, and Methodology
Our objective was to assess the causes of late and extra trips at the Philadelphia
P&DC.
To accomplish our objective, we analyzed Philadelphia P&DC late and extra trip data
from July 1 to December 31, 2019. During our February 24-26, 2020, site visit, we
interviewed P&DC management and observed dock operations. We also reviewed the

1

Late and Extra Trips at the Philadelphia, PA,
Processing and Distribution Center

20-164-R20

P&DC’s Operating Plan to identify mail clearance times 1 and compared them to
clearance times in the Web End-of-Run 2 and Run Plan Generator (RPG) report. 3
We relied on computer-generated data from the Enterprise Data Warehouse (EDW), 4
Application System Reporting, 5 and Surface Visibility Web 2.0 (SVweb). 6 Although we
did not test the validity of controls over these systems, we assessed the accuracy of the
data by reviewing existing information, comparing data from other sources, observing
operations, and interviewing Postal Service officials knowledgeable about the data.
Therefore, we determined the data were sufficiently reliable for the purposes of this
report.
We conducted this audit from February through May 2020, in accordance with generally
accepted government auditing standards. Those standards require that we plan and
perform the audit to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objective. We believe that the
evidence obtained provides a reasonable basis for our findings and conclusions based
on our audit objective. We discussed our observations and conclusions with
management on April 28, 2020, and included their comments where appropriate.

Finding #1 Management Oversight of Mail Processing Operations
We found that inadequate management oversight of mail processing operations caused
late trips from the Philadelphia P&DC to delivery units. During our observations on
February 26, the Philadelphia P&DC reported 22 late Postal Vehicle Service (PVS) 7
Express Mail trips to delivery units during Tour 2 8 (see Figure 1).

1

The latest time committed mail can clear an operation for proper dispatch or delivery.
A web-based application used in collecting operational data from automated and mechanized mail processing
equipment.
3
An Excel-based application mail processing facilities use to plan machine utilization based on volume, clearance
times, throughputs, and other criteria.
4
A repository intended for all data and the central source for information on retail, financial, and operational
performance. Mission-critical information comes to EDW from transactions that occur across the mail delivery system,
points-of-sale, and other sources.
5
A module designed to mirror the actual reporting database.
6
A website dedicated to the Surface Visibility program. SVweb provides real time transportation updates and
reporting on the movement of trailers in the surface network. The data captured to identify early, on time, late or
cancelled trips is also used to evaluate and improve transportation schedules.
7
Trips that are internally operated by the Postal Service.
8
7:00 a.m. to 2:59 p.m.
2

2

Late and Extra Trips at the Philadelphia, PA,
Processing and Distribution Center

20-164-R20

Figure 1. Late Express Mail Trips on February 26, 2020
Number of Late Trips

14
12
10
8
6
4
2
0
1-5

6-10

11-15

16-20

21+

Minutes Late
Source: SVweb

The trips were late because the Express Mail operation was not completed on time.
This occurred because, although a significant amount of the Express Mail had been
processed, mail processing personnel did not timely move it to the loading docks.
Additionally, there was insufficient staff to process the remaining Express Mail timely.
We also noted that there were no supervisors in either the Express Mail processing
area or at the loading docks to ensure the timely movement of Express Mail.
We reviewed RPG reports for the period January 28 to February 26, 2020, and found
217 of 1,131 (19 percent) instances where Delivery Barcode Sorter (DBCS) 9 machine
operations ran past the established clearance time of 5:15 a.m. for letter mail
established by the Philadelphia P&DC’s Operating Plan. During our February 24-26,
2020, observations, there were 15 of 156 (10 percent) instances where DBCS machine
operations ran late.
Recommendation #1: We recommend the District
Manager, Philadelphia District, instruct Philadelphia
Processing and Distribution Center management to ensure
that operations have appropriate supervision to ensure
Express Mail is processed timely.
Recommendation #2: We recommend the District
Manager, Philadelphia District, instruct Philadelphia
Processing and Distribution Center management to ensure
adherence to mail clearance times in the Run Plan
Generator Report.

9

Machines that sort letters and use a computerized camera to read the addresses on the mail and sort it for delivery
by the letter carrier.
3

Late and Extra Trips at the Philadelphia, PA,
Processing and Distribution Center

20-164-R20

Finding #2: Overstated Number of Late Trips
The number of late trips from the Philadelphia P&DC to delivery units was overstated.
During our observations, we identified three daily PVS trips from the P&DC to the
Paschall, PA, Post Office that were classified as late in SVweb. However, the trips were
actually bypassing the Paschall Post Office and going to the South Fork, PA, Post
Office. According to Postal Service policy, 10 P&DC personnel are required to regularly
review transportation schedules to ensure their accuracy. This occurred because the
Philadelphia P&DC Transportation Operations & Networks Manager had not reviewed
and updated the transportation schedule. As a result, the number of late trips was
overstated by over 900 annually. Trips on Time is an important metric the transportation
network uses to measure performance. Using inaccurate data to support management
conclusions puts the Postal Service at risk of making operational decisions that are
incorrect and can negatively affect the transportation network.
During our audit, Philadelphia P&DC management took corrective action by reviewing
and updating trip schedules at the facility. Therefore, we are not making a
recommendation regarding this issue.

Management’s Comments
Management agreed with the report's findings and recommendations.
Regarding recommendation 1, management stated that to ensure Express Mail is
processed timely, the Tour 2 supervisor’s duties will be modified to ensure they are
present in the Express Mail operation during peak processing times. The lead manager
for Tour 2 operations will provide the senior plant manager a weekly staffing model to
ensure the daily compliment supports the Express Mail operation. In addition, In-Plant
Support personnel will provide daily reports to the senior plant manager that identifies
the arrival time of Express Mail to the Philadelphia P&DC, the completion time for the
express mail operation, and the time the product is dispatched to the plants and delivery
units. The target implementation date is June 1, 2020.
Regarding recommendation 2, management stated that the lead manager of Distribution
Operations will discuss the RPG report daily with the In-Plant Support Manager to make
necessary adjustments when warranted. In addition, the lead manager of Distribution
Operations will retrain the managers responsible for mail processing operations on the
RPG methodology and compliance. The target implementation date is June 1, 2020.
See Appendix A for management’s comments in their entirety.

Evaluation of Management’s Comments
The U.S. Postal Service Office of Inspector General (OIG) considers management’s
comments responsive to the recommendations and planned actions should resolve the
issues identified in the report.

10

Standard Work Instruction: Network Specialist, dated December 2016.
4

Late and Extra Trips at the Philadelphia, PA,
Processing and Distribution Center

20-164-R20

All recommendations require OIG concurrence before closure. Consequently, the OIG
requests written confirmation when corrective actions are completed. All
recommendations should not be closed in the Postal Service’s followup tracking system
until the OIG provides written confirmation that the recommendations can be closed.

5

Late and Extra Trips at the Philadelphia, PA,
Processing and Distribution Center

20-164-R20

Appendix A: Management’s Comments

6

Late and Extra Trips at the Philadelphia, PA,
Processing and Distribution Center

20-164-R20

7