Consider the following scenario: You have recorded your plan for a single-family residential development and begin to install infrastructure.  After streets, utilities and curbs are constructed, individual lots are sold off and residents begin to move into your development.  After a week or two, you receive several complaints that the Post Office is not delivering mail to the mailboxes you installed along the frontages of each home.  When you reach out to the Post Office, you are told that curbside mail delivery is not available for your development and instead you must install centralized mail in the form of cluster box units (“CBUs”).  What do you do?

The foregoing scenario (or something similar) is occurring more and more regularly throughout the country as the United States Postal Service (“USPS”) continues to prioritize its transition from traditional curbside mail delivery to CBUs in residential developments.

Under the USPS’s Postal Operations Manual (“POM”), curbside delivery is generally not available for new delivery points, except for “very rare exceptions, as determined by the Postal Service in its sole discretion”.  Consequently, single-family homes constructed in a new phase of an older development might not qualify for curbside mail delivery, even if the older homes are serviced by an existing curbside delivery route.  Under the POM, “[w]hen new development replaces more than one block, delivery methods must comply with mode of delivery options for establishment and extension of delivery service.”  In this case, the preferred (and almost mandatory) mode of delivery for new residential delivery points is centralized mail in the form of CBUs.

In view of the foregoing, it is important that developers have a strategy for providing USPS-approved mail delivery to new residential development. Otherwise, they may erroneously believe that the USPS will provide curbside delivery and find themselves in the position of requiring CBUs after plans have been engineered (or worse- after streets, utilities and curbs are installed).  This can be costly, as centralized mail consumes more space and impervious coverage than traditional delivery.

To prevent the above scenario, the USPS includes guidelines for developers in its National Delivery Planning Standards (“NDPS”).  The NDPS encourage developers to contact their local USPS Growth Manager during the design and planning phase (i.e., before plans and site plats are finalized with the appropriate planning/zoning authorities).  Growth Managers work with developers to ensure suitable type and placement of CBUs in each development and, more importantly, that modes of delivery are approved in advance of selling lots.

If a developer finds itself in a situation where CBUs are impractical or cause excessive hardship, the developer has the right to appeal a postmaster’s determination requiring centralized delivery.  The USPS’s central office will consider the unique facts and circumstances of the development and potential effects on postal operational efficiencies in rendering a decision.  If a hardship is deemed to exist, the USPS may authorize curbside delivery on a multiple-mailbox-per-post basis.  However, there is no guarantee that the USPS will grant an appeal, and developers should plan to meet with their local Growth Manager as early as possible to ensure that any proposed mode of mail delivery is acceptable (including type and location of CBUs).

If you have any questions regarding the foregoing, or need assistance with a USPS appeal, do not hesitate to contact a member of the McNees Land Use Group.