Why is the USPS Non-Compliant with the Paperwork Reduction Act?

Roedd y cais yn llwyddiannus.

Dear Postal Services Commission,

This Request is made persuent the Freedom of Information Act:

Upon reviewing the laws of this land concerning United States Postal Service forms, several questions have presented themselves. When an individual desires to open a private mailbox with a company outside of the United States Postal Service (third party agent), they are requested to provide information on form PS 1583 prior to obtaining a mailbox. This form request private information and compels one to furnish accurate information per 18 U.S.C. 1001. Based on a study of these laws, the following has been determined:

• The United States Code Title 39 § 201states that the United States Postal Service is established, as an independent establishment of the executive branch of the Government of the United States. (Public Law 91-375 § 201) (emphasis added)

• The Paperwork Reduction Act, Title 44, chapter 35 § 3502 defines the term “agency” means any executive department, military department, Government corporation, Government controlled corporation, or other establishment in the executive branch of the Government (including the Executive Office of the President), or any independent regulatory agency. (emphasis added)

• Title 44, chapter 35 § 3512 states:
(a) Notwithstanding any other provision of law, no person shall be subject to any penalty for failing to comply with a collection of information that is subject to this subchapter if—
(1) the collection of information does not display a valid control number assigned by the Director in accordance with this subchapter; or
(2) the agency fails to inform the person who is to respond to the collection of information that such person is not required to respond to the collection of information unless it displays a valid control number.
(b) The protection provided by this section may be raised in the form of a complete defense, bar, or otherwise at any time during the agency administrative process or judicial action applicable thereto.

In short, the United States Postal Service is defined as an independent establishment of the executive branch and therefore is required to follow United States Code Title 44. This requires that forms produced by the United States Postal Service must have properly established and applied OMB numbers printed on said forms, such as PS Form 1583.

To be specific, if a person is in need of establishing a private mailbox through an agent other than the United States Postal Service, how can one be legally compelled to provide personal information on PS Form 1583 when said form is not in compliance with US Code Title 44, chapter 35 § 3512?
If a person refuses to provide the requested information and declares Postal Service Form 1583 as being non compliant to the law as mentioned, would this specifically prevent a third party agency from establishing a contractual business relationship to provide a mailbox for mail deliveries?
If a third party agent provided a mailbox service with a person that has made such determination concerning PS Form 1583 and its lack of an OMB number, could said third party agent be held for any wrong doing of establishing a private mail service?
Also, why are there no OMB numbers printed on PS Form 1583 and other forms utilized by the United States Postal Service?

Please provide copies of any notes, legal briefs, executive orders and/or judicial documents which will specifically show why the USPS does not have to be in compliance to the Paperwork Reduction Act as questioned above. Thank you for your time and consideration to this matter.

HAL CARDIFF

Jonathan Pillinger, Postal Services Commission

Dear Mr Cardiff

Thank you for your recent freedom of information request about the United States Postal Service(USPS) and the Paperwork Reduction Act. As Postcomm is the regulator of postal services in the United Kingdom and not the United States we do not have the information you have requested.

The best organisation for you to contact for help with your enquiry would be the Postal Regulatory Commission who you can either telephone on (+001) 202 789-6800 or email from this link: http://www.prc.gov/prc-pages/about/conta....

If you would like any information about postal regulation in the United Kingdom then please contact me and I'd be more than happy to help.

I hope you feel that we have done our best to answer your question, but if you are unhappy with the answer or the way we have dealt with your question, you can request an internal review by our Director of Resources, Colin Sharples. The contact address is Postal Services Commission, Hercules House, Hercules Road, London, SE1 7DB; or if you wish you can email: [Postcomm request email] .

Or if you feel it would be more appropriate you can contact the Information Commissioner who can review your case. Generally, the Information Commissioner's Office cannot make a decision unless you have already been through the complaints procedure we provide. The best way to contact the Information Commissioner’s Office is either by telephoning them on 0303 123 1113 (9am-5pm Monday to Friday) or by emailing them at [email address]

Kind Regards

Jonathan

dangos adrannau a ddyfynnir

Dear Jonathan Pillinger,

I thought that I had stumbled upon a site to ask my Freedom of Information question concerning the United States Postal Service. I had not realized that I stumbled upon a site designated for the United Kingdom. So I offer you my apology and my thanks for the response given. So I will redirect my question and then wait and see if I should be so lucky as to have such a quick and informative response from the USPS like the one you have given.
Yours sincerely,

HAL CARDIFF