USPS v. PRC, 963 F.3d 137

Inbound Letter Post (foreign-origin mail to the U.S.) was priced largely under Universal Postal Union (UPU) rules and undercompensated the USPS by hundreds of millions annually.
The Postal Regulatory Commission (PRC) reviewed USPS’s 2018 annual compliance report and ordered disclosure of aggregated revenue, volume, cost, and contribution data for Inbound Letter Post to inform public debate and potential reforms.
USPS sought to keep the data confidential, arguing disclosure would cause commercial harm (help competitors and foreign negotiators) and that the statutory “public interest” limitation should be read narrowly.
Two Commissioners partially dissented, favoring disclosure of revenue and volume only, citing negotiation and competitive risks; after the PRC vote, the UPU agreed to let the U.S. set some rates for certain items.
USPS petitioned for review in the D.C. Circuit; the court reviewed statutory interpretation under Chevron and the PRC’s order under the Administrative Procedure Act and denied the petition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Scope of “public interest in maintaining the financial transparency of a government establishment competing in commercial markets”	Phrase should be limited to preventing abuse tied to statutory monopoly or government status	Broader public interest in transparency about large financial losses and competitive distortions	Court upheld PRC’s broader reading; Chevron deference applies; PRC’s interpretation reasonable
Whether PRC properly balanced commercial harm vs public interest	Disclosure would enable competitors and foreign nations to exploit data; harms are concrete and substantial	Data are aggregated by large UPU groups, lack disaggregation, and thus harms are speculative	Court held PRC’s balancing reasonable and not arbitrary or capricious
Whether PRC failed to consider dissenting Commissioners’ arguments	PRC ignored or insufficiently addressed dissenters raising negotiation and competition concerns	PRC acknowledged and rejected those arguments on the record	Court found PRC adequately considered and responded to dissenting views
Whether PRC provided a workable standard for future confidentiality rulings	PRC gave no clear, administrable standard (analogized to USPS I)	Statute supplies the test; PRC explained case‑specific reasoning and need not announce all hypotheticals	Court held standard and explanation sufficient; USPS I inapposite

USPS v. Postal Regulatory Comm’n, 886 F.3d 1253 (D.C. Cir. 2018) (discussing Chevron deference and transparency obligations)
USPS v. Postal Regulatory Comm’n, 785 F.3d 740 (D.C. Cir. 2015) (agency must articulate a comprehensible standard)
United Parcel Serv., Inc. v. Postal Regulatory Comm’n, 890 F.3d 1053 (D.C. Cir. 2018) (APA standard for review of PRC orders)
Mudge Rose Guthrie Alexander & Ferdon v. U.S. Int’l Trade Comm’n, 846 F.2d 1527 (D.C. Cir. 1988) (aggregated industry data may not reveal firm‑specific data)
Int’l Fabricare Inst. v. EPA, 972 F.2d 384 (D.C. Cir. 1992) (agency must address significant public comments)
USAir, Inc. v. Dep’t of Transp., 969 F.2d 1256 (D.C. Cir. 1992) (limited review of agency multi‑factor balancing)
Am. Gas Ass’n v. FERC, 593 F.3d 14 (D.C. Cir. 2010) (agency must acknowledge and consider dissents)
SEC v. Chenery Corp., 332 U.S. 194 (1947) (agency need not announce in advance how it will rule on hypotheticals)
NTCH, Inc. v. FCC, 950 F.3d 871 (D.C. Cir. 2020) (courts judge agency reasonableness based on the record before the agency at decision time)