United States Postal Service

National Labor Relations Board - Board DecisionsFeb 5, 1974

208 N.L.R.B. 948 (N.L.R.B. 1974)

948 DECISIONS OF NATIONAL LABOR RELATIONS BOARD United States Postal Service and Metropolitan Area Bargaining Council of Postal Workers, and Greater New York Area Council, National Association of Letter Carriers, Petitioner and National Alliance of Postal and Federal Employees, Local 202, Balti- more, Maryland, Petitioner and National Alliance of Postal and Federal Employees, Local 701, Chicago, Illinois, Petitioner and National Alliance of Postal and Federal Employees, Locals 703 and 912 East St. Louis, Illinois; St. Louis, Missouri, Petitioner. Cases 2-RC-15673(P), 2-RC-15675(P), 2-RC-15812(P), formerly 5-RC-7773(P), 2-RC-15813(P), formerly 13-RC-l2539(P), 2-RC-15815(P), formerly 14-RC-6806(P), and 2-RC-15816, formerly 14-RC-6825 February 5, 1974 DECISION AND ORDER On various dates, as set forth below, the Petitioners filed petitions seeking to represent certain employees of the U.S. Postal Service at various locations.' On various dates in September 1971, the Employer filed motions with supporting briefs requesting that the petitions herein be dismissed on the ground that said petitions are barred by section 10 of the "Postal Reorganization Act" (herein called PRA)2 and by the 1971-73 Postal Service national agreement dated July 20, 1971. Thereafter, the Petitioners and Intervenors; filed briefs stating their respective positions. On February 4, 1972, the Board, Member Kennedy dissenting, issued an Order Directing On July 1, 1971, the Metropolitan Area Bargaining Council of Postal Workers (herein called MABC) filed a petition in Case 2-RC-I5673( P) for a unit of "All employees of the United States Postal Service in the New York Metropolitan Postal Region in the groups generally known as Postal Clerks, including those assigned to the Postal Data Center and to the Regional Office ; Maintenance Employees : Special Delivery Messengers, Motor Vehicle Employees , and Mail Handlers, including Mail Equipment Handlers , Excluding: Letter Canners, Management Officials and supervi- sors, employees engaged in confidential personnel work; professional employees , and security guards" (herein called Petition 1) On July 2, 1971, the Greater New York Area Council, NALC (herein called GNYA('), filed a petition in Case 2-RC-15675(P) for a unit of "All employees of the United States Postal Service in the New York Metropoli- tan Postal Region in the group known as Letter Carriers, Excluding, Postal Clerks, including those assigned to the Postal Data Center and to the Regional Office, Maintenance Employees, Special Delivery Messengers: Motor Vehicle Employees, Mail Handlers , including Mail Equipment Handlers; Management officials and supervisors , employees engaged in confidential personnel work, professional employees , and security guards" (herein called Petition 11). On August 16, 1971, the National Alliance of Postal and Federal Employees of Baltimore , Maryland, Local 202 (herein called National Alliance Local 202). filed a petition in Case 5-RC-7773(P) which was subsequently consolidated herein and renumbered 2-RC-15812(P) for a unit of "All Motor Vehicle Service employees including vehicle operators and maintenance employees working out of Oliver Street , Parkville Station and Helethrope Station [Baltimore , Maryland ], Excluding, all management officials, supervisors , employees engaged in confidential clerical work and security guards" (herein called Petition 111) On August 17, 1971, the National Alliance of Postal and Federal Hearing whereby the instant petitions were consoli- dated for hearing. Pursuant to the Board's Order, hearings were held in New York, New York, before Hearing Officer Arthur A. Herman on April 10, 11, 18, 19, and 20, May 1, 2, 3, 4, 9, 10, 16, 17, 30, and 31, June 1, 7, and 15, October 30, and November 20, 1972. On December 19, the Regional Director for Region 2 transferred the case to the Board. Thereafter, the Petitioners, Intervenors, and the Employer filed briefs in support of their respective positions, and several parties filed reply briefs. On September 10, 1973, the Board heard oral argument on the issues raised herein. The National Labor Relations Board, having duly considered the Hearing Officer's rulings made at the hearing, finds they are free of prejudicial error and they are hereby affirmed. Upon consideration of the matter, including the record and the briefs and the oral argument, the Board hereby finds: 1. BUSINESS OF THE EMPLOYER Congressional enactment of the PRA in 1970 created the United States Postal Service (herein called the Postal Service or Employer) to supersede the United States Post Office Department. By virtue of section 1209 of the PRA, the National Labor Relations Act (herein called the Act) became applicable to employee-management relations in the Postal Service on July 1, 1971. Since all of the petitions herein were filed on or after this date, we find the Postal Service to be an employer whose operations are subject to the provisions of the Act. Employees of Chicago, Local 701 (herein called National Alliance Local 701). filed a petition in Case 13-RC-12539(P) which was subsequently conso' dated herein and renumbered 2-RC-15813(P) for a unit of "All employees of O'Hare-Midway Facility [Chicago, Illinois], Excluding: supervisors, security guards and professional employees " (herein called Petition IV). On July 22, 1971, the National Alliance of Postal and Federal Employees, Local 703 (herein called National Alliance Local 703), filed a petition in Case 14-RC-6806(P) which was subsequently consolidated herein and renumbered 2-RC-15815( P) for a unit of "All employees in the United States Postal Service, East St Louis, Illinois, employed in the Main Post Office and Branch Stations , Excluding, office clerical and professional employees, guards and supervisors as defined in the Act" (herein called Petition V). On August 23, 1971 , the National Alliance of Postal and Federal Employees, Local 912 (herein called National Alliance Local 912). filed a petition in Case 14-RC-6825(P) which was subsequently consolidated herein and renumbered 2-RC-15816(P) for a unit of "All mail handlers employed in the St. Louis, Missouri Main Post Office and Related Branch Stations , Excluding ; Office clerical and professional employees , guards and supervisors as defined in the National Labor Relations Act, and all other employees" (herein called Petition VI). 2 P L. 91-375. 84 Stat. 719, 39 U S.C Â§ 101, et seq. a National Association of Letter Carriers, AFL-CIO (NALC). American Postal Workers Union, AFL-CIO (APWU), National Association of Post Office Mail Handlers , Division of Laborers' International Union of North America, AFL-CIO (Mail Handlers); and Local 917, International Brotherhood of Teamsters, Chauffeurs , Warehousemen and Helpers of America , intervened in these proceedings On November 20, 1972, Teamsters Local 917 withdrew its intervention in the proceedings. 208 NLRB No. 144 UNITED STATES POSTAL SERVICE 949 H. LABOR ORGANIZATIONS INVOLVED The parties stipulated and we find that the National Alliance, its locals, and the Intervenors are labor organizations within the meaning of the Act.4 III. QUESTION CONCFRNING REPRESENTATION No question affecting commerce presently exists concerning the representation of employees of the Employer within the meaning of Section 9(c)(1) of the Act, since we find that none of the instant Petitioners seeks to represent employees in an appropriate um t.5 Our factual findings upon which we base our decision and our reasons therefor are set forth below. A. Postal Service Operations Organizationally the Postal Service is controlled by a board of governors who, along with the National Operating Committee composed of the Postmaster General, the five Regional Postmasters General, the Senior Assistant Postmasters General, and the General Counsel, establishes the operating policies for the Postal Service. Administratively the Postal Service is divided into five regions: Eastern, South- ern, Central, Western, and New York,6 each of which regions is subdivided into metropolitan centers, metropolitan areas, and districts.7 However, process- ing of mail is through 552 sectional centers (50 to 120 post offices are assigned to each sectional center) which operate across the foregoing administrative subdivisions. There are six postal data centers established by headquarters throughout the country, which act as the disbursing, accounting, and computing centers for the post offices and which obtain their informa- tion from 80 personnel centers. These centers maintain all personnel records. Payroll and person- nel records are also centralized at the six postal data centers. Data centers report directly to the national headquarters through the Senior Assistant Postmas- ter General for Support, and operate independently of regional control. 4 Although Intervenors NALC and APWU declined to stipulate that Petitioners GNYAC and MABC were labor organizations within the meaning of the Act, and such issue was litigated at the heating , we find it unnecessary to decide this question at the present time in view of our disposition of these petitions 5 Accordingly, we need not decide the various other motions now pending before the Board 6 On July 16, 1973, the Postal Service informed the Board by letter that it was restructuring its administrative organization by substantially expanding the New York Region . On October I, 1973, the designation "New York Region" was eliminated and a new "Northeastern Region" (including New York, Connecticut , Rhode Island . Massachusetts , Vermont, New Hamp- shire, and Maine) was created After the Postal Service served a copy of the letter on all parties , which contained inter alia a motion to reopen the record , each Petitioner separately filed a response essentially urging the Board not to consider this administrative change. In view of our present The Postal Service headquarters in Washington, D.C., is involved in the total budget for all regions." It allocates the amount of money to be expended in each region; it is involved in research and engineer- ing, the procurement process, the administration of labor relations and employee relations, and the payroll system. Since passage of the PRA, labor relations and employee relations policy matters are determined and administered by the Senior Assistant Postmaster General for Employee Relations and Labor Rela- tions at the national headquarters. All benefits, such as holidays, sick leave, vacations, health insurance, life insurance, pensions, and wage scales are uniform throughout the postal system. However, continuing the pre-PRA practice, seniority rights are by classifi- cations within a post office, and there is little, if any, interchange or transfer of personnel between post offices. For purposes of daily decision making, a comprehensive set of guidelines and regulations is maintained by headquarters for assisting regional and local postmasters. The five Regional Postmasters General report directly to the Deputy Postmaster General in Washington and are responsible for the day-to-day operations of their respective regions. Administra- tively each region is structured in a parallel fashion to the headquarters. Although regional administra- tion is centralized through the Regional Postmaster General, the administration of labor relations is handled through a separate chain of command responsible directly to national headquarters. Sometime in 1962, in accordance with Executive Order 10988 which issued January 7, 1962, the Post Office Department determined that appropriate bargaining units should be national in scope and coincide with seven traditional so-called "craft" lines. At that time, the seven such groups were (1) letter carriers, (2) mailhandlers, (3) clerks, (4) special delivery messengers, (5) rural letter carriers, (6) motor vehicle employees, and (7) maintenance employees .9 On July 1, 1971, after passage of the PRA but prior to execution of the interim collective- disposition , we deny the motion to reopen the record , as we need not consider the effect of the Employer's reorganization r Metropolitan centers are the 10 largest urban concentrations of post offices, and metropolitan areas are the 21 next largest . The remaining post offices are grouped into 86 distracts . A "post office" is a single mail- processing and delivery center under the head of a single manager. There are four classes of post offices: first class. numbering about 5,000 post offices, employ about 85 percent of all postal employees , and are the largest post offices, second-class post offices, numbering about 12 ,000, employ approximately 7 employees each; third-class post offices, numbering about 7,000, each employ about 3 persons ; and fourth-class, usually rural, post offices, numbering about 5.500 , are generally one-man operations. E Budget requests emanate from the regions , are consolidated by headquarters , and are submitted to the board of governors . Headquarters then allocates the money to the regions for disbursement internally. Elections were conducted in 1962 and 1963 and the seven national (Continued) 950 DECISIONS OF NATIONAL LABOR RELATIONS BOARD bargaining agreement , the clerks , special delivery messengers, motor vehicle employees , maintenance employees, and the National Postal Union merged to form the APWU, but each union except NPU signed the agreement as a separate entity. Rural letter carriers remain as a separate craft , but have not intervened herein. Thus there are four unions presently representing employees in the seven "craft" groups. Following execution of the 1971 interim national agreement, 10 local "memos of understanding" were reached between local postmasters and local union officials as part of local implementation which appears to be a dimension of collective bargaining designed to implement the national agreement on the local level. In those situations where an impasse was reached, the respective postmaster and local union official notified their regional counterparts, who then entered into the negotiations . In this regard the region provided the guidelines to local management for negotiating. Both prior to August 1971 and since, Washington has set national policies to be implemented in the regions . In terms of labor relations administration, the Assistant Regional Postmaster General of the region reports almost daily to Washington on labor problems. He has authority to resolve local or regional labor problems without resorting to head- quarters if he follows national precedent. Although the Postmaster General for the region is his superior, he has the ultimate authority to administer the Employer's labor relations and employee relations programs in that he reports directly to Washington and can only be overruled by the Senior Assistant Postmaster General. During the term of the interim agreement , the New York Assistant Regional Postmaster General for Labor Relations participated in about 150 contractu- al -grievances at the regional level , and of these about 100 have reached the Washington level, of which about a half dozen have actually reached arbitration. While there are relatively few transfers between post offices, some voluntary transfers of employees unions (the Intervenors herein ) were granted national "exclusive recogni- tion" rights by the Post Office Department as representatives of postal employees in the seven groupings. Between 1962 and 1970, four successive national agreements were jointly negotiated between the Post Office Department and the national unions , each of which was embodied in a single national agreement . However, the National Alliance and the National Postal Union did win some local elections and received consultation rights on the national level and "formal recognition" in approximately 200 local units . Under the Executive Order 's proportional representation system, the National Alliance and NPU actively participated in local discussions and processed grievances and EEO matters even though a different union held national exclusive recognition rights . On the local level, several locals of the National Alliance negotiated local agreements with local postmasters, while others merely adopted the national agreement. Prior to enactment of the PRA, the National Alliance had dues -checkoff rights and processed grievances and adverse actions at all levels. National Alliance operates a do occur within the region. Local postmasters have the authority to effectuate such transfers, while the Regional Postmaster General can do the same' thing on an involuntary basis if the need arises. The supervisory structure at the local post office level is dependent upon the size of the facility. For example, at Grand Central Station or the 34th Street Station, New York; each 100 letter carriers are supervised by a section foreman. The supervisory chain continues upward: the general foreman, assistant tour superintendent, tour superintendent, assistant operations manager, operations manager, superintendent of delivery and collection, and finally, the postmaster. At a small Long Island station, a letter carrier reports to his foreman who in turn reports to the local postmaster. Other crafts are similarly supervised. From the present record, it appears that work operations are performed in the same manner at all facilities of comparable size, although the sorting schematics or equipment may vary slightly. In terms of daily operation, local post offices handle four types of mail: first-class mail is primarily letter-type mail, and it accounts for about 58 percent of all mail in the system; second-class mail is mainly periodicals and accounts for 12 percent of all mail; third-class mail consists of circulars, advertisements, catalogues, etc., and approximately 26 percent of all mail is third class; fourth-class mail is commonly referred. to as parcel post, and this amounts to about 1 percent of all mail. Airmail accounts for about 2 percent of all mail. Mail is collected by letter carriers from mailboxes along their route and brought to a post office. It is dumped on a table where it undergoes a culling process, an initial separation of the mail, by either a mailhandler or postal clerk, depending on the size of the post office. The mail is then faced and stacked and fed through a canceling machine. The canceled mail is then sorted based on a schematic or zip code reading and is then put in sacks which are labeled and tracked to a sectional center.11 The mail proceeds from the receiving sectional health insurance program and maintains credit unions at postal installa- tions. Since the 1971 agreement , the National Alliance has not been permitted to represent its members in negotiations, to process grievances, or to participate in labor-management conferences. However , the National Alliance has represented its members on EEO matters. *0 In accordance with the provisions of sec . 10 of the PRA, which provided for "transitional collective bargaining" in the preexisting units as a "stopgap" measure during the transition period under PRA, negotiations began in early 1971 between the Employer and the unions, culminating in a joint national agreement on July 20, 1971, effective to July 20, 1973. 11 The 552 sectional centers act as the main mail-processing installations and transportation hubs and serve all post offices within their geographic constraint. The Management Information Systems Section in Washington monitors a national service index, through computers , to control the flow of mail throughout the country . Transportation schedules are prepared and UNITED STATES POSTAL SERVICE center to the sectional center in the area to which that mail is addressed and then the reverse process begins so as to get the mail to the addressee. When the mail gets to the delivery post office, postal clerks bring it from the truck and, utilizing their schematic knowledge , segregate the mail for each letter carrier's route, and the latter delivers the mail to the addressees. Operations are conducted on a 24-hour basis.12 There are approximately 666,000 postal employees who are classified in 7 occupational classifications which the parties designate as crafts. Within these seven craft groupings, employees are graded at levels of performance and competence. New hires are assigned to a particular craft and have seniority within the craft. There is little craft interchange. Furthermore, there is virtually no interchange of employees between geographical areas as employees do not have rights to bid on jobs outside their installation. The primary job of postal clerks is the distribution of incoming and outgoing mail. In addition, postal clerks sell stamps, dispense money orders, designate registered mail, receive parcel post packages, and post to a ledger accounts of customers who have permits. A letter carrier is responsible for the delivery of mail to the addresses, and for the collection of mail from mailboxes along his route. In performing his task of delivery of mail, he is responsible for the sorting of his mail in the post office. Basically a letter carrier at Grand Central Station performs the same work as a letter carrier in Minneapolis or Akron, except that the volume of mail at the larger station may require a somewhat different procedure. In this regard, in the less concentrated areas carriers use jeeps to cover their larger geographical areas rather than making deliveries on foot. In addition to his other duties, a letter carrier collects on c.o.d. accounts and is responsible for obtaining signatures on registered mail. Mail handlers are employed in those post offices in which it is determined that there is at least 8 hours of work for a mailhandler. There are fewer than 200 post offices that employ mailhandlers. Mailhandlers are responsible for unloading massive quantities of mail from trucks and bringing the mail to postal clerks for distribution. They also assist in culling and facing mail, and operate electronic processing can- cellation machines . Mailhandlers set up sacks for receipt of mail and tie out sacks, and outgoing sacks maintained at headquarters . The established specified standards of delivery of mail are uniform throughout the country, as are postal rates . In addition, and to improve the flow of mail, the Postal Service has developed several programs; namely, the area mail processing centers , a managed mail processing program , a bulk mail program with 20 national processing 951 are brought to the trucks by mailhandlers . Jitneys, forklifts, and. mechanical mules are operated by mailhandlers inside the post offices. Special delivery messengers do what their name implies . The service is repeated several times a day and the purpose is to provide an expedited delivery system for postal customers. Rural carriers 'Iervice those areas of the country that are not dense enough to qualify for what is termed city delivery. Such carriers furnish their own vehicles for the transportation of the mail , for which they are reimbursed . The rural letter carrier also performs the retail functions which are performed by postal clerks in city post offices ; i.e., sells stamps, issues money orders, etc. Motor vehicle employees perform two functions: they drive tractor-trailers between postal installations to move mail ,- and they maintain , repair, and service motor vehicles. Maintenance employees are responsible for build- ing maintenance and custodial work. In addition, they maintain, repair, and service the full range of devices used in post offices; i.e., canceling machines and letter-sorting, parcel post-sorting, and sack- sorting machines. B. Positions of the Parties 1. Petitioners' arguments All of the Petitioners argue that the congressional intent in the PRA was to decentralize the Post Office Department; that "national" was deleted from the Senate version of the Board's mandate on unit determinations; and that Congress did not intend the section 10(a) interim agreement to be a bar to unit determinations. All Petitioners further argue that, under the current method of representation, only one national contract is negotiated and that the Employ- er and the Intervenors have thus ignored the craft lines. Petitioners GNYAC and MABC, who seek to represent certain employees in the New York area, argue that the employees in the petitioned-for units share common socio-economic interests and prob- lems within a definable. geographic location. They contend that neither centralization in Washington nor the interchangeability of employees per se renders the petitioned-for units inappropriate. They argue that the units are coextensive with craft lines and with the Employer's administrative organization. They also point to the similarity of working condi- centers, and a preferential mail program. 12 Additional post office functions include the retail sale of stamps, the setting of meters, the registry of important documents , and the issuance of postal money orders. 952 DECISIONS OF NATIONAL LABOR RELATIONS BOARD tions throughout New York, local supervision, and the impossibility of headquarters' controlling daily labor relations matters. To support their argument, GNYAC and MABC maintain that (1) the 1970 postal strike originated in New York ; (2) the high crime rate makes working conditions . there unique; (3) the ethnic and safety problems which exist in New York are unique ; (4) the cost of living in New York is far in excess of national averages; (5) the volume of New York mail far exceeds that of other urban cities ; and (6) specific labor problems are resolved at the local and regional level. The National Alliance argues that all major postal functions are performed at the local and regional levels ; that a decentralization program was begun in 1969; that local representation existed under the executive orders; that local bargaining has not produced catastrophic results; that a potential national strike is more dangerous than a local strike; that urban center employees have interests different from rural employees ; and that Congress did not intend to disenfranchise the National Alliance. 2. Employer's and Intervenors' arguments The Postal Service and the Intervenors essentially contend that the only appropriate units are the seven national craft units (now represented by the three Intervenors and the Rural Letter Carriers) and that all petitions herein must be dismissed. In support of its contention, the Employer argues that the postal operations are functionally integrated, centralized, administered by national headquarters, and that the Employer has historically bargained on a national level, and that to fragmentize existing units would cause great inefficiency and create chaos in the postal service. Employer and the Intervenors further argue that the collective-bargaining history requires national units in that local participation was not a conflicting practice, and that the legislative intent as set forth in the entire PRA was to establish a national postal system. In this latter regard, they argue that the congressional delegation of unit determination to the Board was merely to avoid congressional fiat of appropriate units and not to suggest the appropriate- ness of less than national craft units. The Intervenors argue that, even if considered as a matter of initial organization, the Petitioners' evidence does not overcome the presumption of appropri- ateness of systemwide units since ( 1) regional officials are not autonomous ; (2) regional employees are not geographically proximate; (3) functional integration of employees in any region is indistin- guishable from the national functional integration; (4) only ministerial duties are delegated to the region ; (5) benefits and wages follow national guidelines; (6) New York is not distinguishable from other urban areas ; and (7) PRA sec . 1203 omits the 9(b) "fullest freedom" language . of the National Labor Relations Act. They dispute the validity of Petitioners' statistics and also contend that the socio- economic data proferred by the Petitioners are irrelevant to the unit determination . They note that no petition seeks all employees in any region even if, such would be appropriate and that the Intervenors do not seek to represent all employees in each craft. NALC further contends that Petitioners are seek- ing inappropriate craft severance under Mallinc- krodt 13 since (1) this is not an initial organizational campaign ; (2) the units proposed for severance are not coextensive with the existing "multiplant" unit; (3) the proposed severance cuts across craft lines; (4) letter carriers are not a true craft group; (5) nothing indicates that the present pattern of national unit bargaining is not conducive to stability ; (6) separate identity has not been maintained by either GNYAC or MABC; (7) the Employer is highly integrated; and (8) neither MABC or GNYAC has prior experience on basic items of negotiations. The Postal Service and the Intervenors also contend that the 1971 agreement pursuant to section 10 of the PRA constitutes a bar to the National Alliance petitions filed after execution of the nation- al agreement. Further, they argue that any successful nonincum- bent union should be bound by the existing contract for the remainder of its term. Conclusions The congressional mandate to this Board in the comprehensive PRA legislation was to determine "in each case the unit appropriate for collective bargain- ing in the Postal Service." While an explicit standard for determining unit appropriateness was not set forth in the PRA, the legislative history instructs the Board to apply its private sector criteria . Thus the Joint Congressional Conferees stated: It is the intent of the Conference Committee that these provisions of the conference substitute leave to the National Labor Relations Board the judgment as to what will be the appropriate units for collective bargaining in the Postal Service on the basis of the same criteria applied by the Board in determining appropriate bargaining units in the private sector . The conference substitute deems it desirable to leave the determination of appropri- ate bargaining units entirely in the judgment of 13 Mallinckrodt Chemical Works, Uranium Division, 162 NLRB 387. UNITED STATES POSTAL SERVICE the NLRB rather than to predetermine such matters in any way. [Conference Report, H.R. 17070, H.R. Rep. No. 91-1363, pp. 81-82.]14 In reaching our decisions herein, we are not unmindful of the Petitioners' interests in seeking to represent postal employees on a local basis. It is quite apparent from the present record, as well as our everyday experience, that working and living condi- tions vary greatly between urban and rural areas. However, the record also shows that the Postal Service is a uniquely complex and integrated nation- al service corporation whose efficient operation is essential to the nation's commerce and domestic tranquility. The economic differentials which exist between various areas of the country, and upon which Petitioners would have us rely, have been considered in our determination of whether the petitioned-for units evidence a sufficient employee community of interest to warrant our finding them to be separate appropriate units. However, neither the congressional d,rective to this Board nor the present record give us sufficient cause to depart from our usual private sector criteria in determining the appropriateness of the petitioned-for units. Applying these criteria, we begin by examining what lines of division may be most useful to the parties in furthering their collective-bargaining rela- tionship.15 The Employer's size , collective-bargaining history, number of employees, geographic dispersion, and centralized operational organization impose certain practical limitations on the numerical prolif- eration of bargaining units. It is obvious that meaningful collective bargaining could not realisti- cally occur at each of the Employer's 32,000 individual facilities.'6 On the other hand, we are aware that certain broad horizontal or vertical divisions of employees into homogeneous units with 14 Also in this regard, Representative Udall stated. Let me observe that there has been great speculation about the future of postal unions under this new authority. I am convinced that it is in the best interest of the postal service to ultimately have one large union representing all employees subject to collective bargaining . While the Senate had provisions in its bill to allow only national craft recognition, the House allowed the National Labor Relations Board to decide the appropriate unit m the conference the House version prevailed. Some have interpreted this to mean that we believe that the NLRB should decide on local units as appropriate units for purposes of collective bargaining NothLng could be more mistaken . What conferees meant was that the NLRB should apply those guidelines normally applied in the private sector and decide the appropriate unit on that basis. They should not look to the fact that the House prevailed in this area as any indicator of preference to the national or local units, craft or otherwise. [Congressional Record, H-78681 Senator Godell (R-NY) replied: Let it be clear that it is the intent of this Congress . that nonnational and noncraft unions shall be able, after the transitional bargaining period , to compete for recognition as bargaining agents Let it be clear that it is not the intent of Congress to permit, in any contract negotiated by the new postal corporation during the transitional bargaining period, the inclusion of any provision which would have the 953 the requisite community of interests might well promote meaningful, or at least feasible, collective bargaining. Under the various Executive Orders which gov- erned employee relations matters in the Post Office Department from 1962 to 1971, the Post Office Department, in accord with the procedures described therein, granted exclusive national recognition to the seven so-called national "craft" unions (Intervenors herein) in nationwide units. Although the National Alliance and the National Postal Union received local formal recognition bargaining rights on a facilitywide basis in those areas where they received a majority of votes in local elections, the appropriate units were always described as national in scope. Negotiations between 1962 and 1970 were conducted solely on a national basis between the Employer and the Intervenors herein. It was only after a national agreement was reached that the parties entered local supplemental negotiations. In this regard, the record does not show any instances of the Employer's recognizing a craft-type unit on a local or regional basis. While the Employer specifically recognized the craft lines, i.e., the occupational classifications, and treated them as craft groups, it did so only on a national unit basis. Thus it appears to us that there has been established, with the, participation of all present Petitioners, a workable pattern of craft unit bargaining on the national basis. Although the Postal Service and the Intervenors have not previously defined the bargaining units along horizontal lines, the Board has in other related areas found appropriate units which coincide with an employer's administrative organization. Previously we outlined the nature of the Employer's administra- tive organization. The national headquarters sets effect of providing those unions which do now have national exclusive recognition rights with any advantage over those which do not, with the result of effectively freezing the latter unions out of the bargaining process indefinitely. It is the intent of Congress that bargaining during the transitional bargaining phase be conducted in such a way that upon conclusion of the transitional period non-national and non-craft unions, such as the NPU and the Alliance be able to compete for recognition on an equal footing with the national unions which have been permitted to bargain during the period [Congressional Record, S-14155.] Both the Postal Service and the Intervenors had urged Congress to mandate national bargaining units in accord with the preexisting practice and their specific agreement on the issue While 'the original House version of the bill rejected mandated national units , the Senate version contained a specifica- tion for national bargaining units The conference substitute adopted the House version . deleting the national unit mandate from sec. 1202 , and left the appropriate unit determination to this Board. 15 In this regard , we look to the fact that the Postal Service and its employees' representatives have been engaged in limited collective bargain- ing under the Executive Orders since 1962 16 The impossibility of this situation is further illustrated by the fact that, were we to find that each of the Intervenors could represent their respective "crafts" on a single facility basis, the number of potential units would exceed 100,000. 954 DECISIONS OF NATIONAL LABOR RELATIONS BOARD policies and guidelines which are administered by the five operating regions. Within the regions, each facility is organized within a hierarchical structure which is related to the volume of mail being processed . In terms of the structure , the densest concentration of post offices is a metropolitan center, followed by a metropolitan area, and then by districts. Across these hierarchical divisions are 552 sectional centers which are the key transfer points in mail processing. It is at the sectional centers that the mail from the individual -postal facilities is consoli- dated and routed to its destination. Thus the sectional centers are directly fed by individual post offices, which are the smallest units of organization in the Employer's administration. While a unit encompassing all employees within a region, metropolitan center , metropolitan area, or district might constitute an appropriate unit, none of the Petitioners herein is seeking to represent all employees in any such division. Therefore, we need not and do not reach that question. However, it is our view that any less-than-nationwide unit which does not at least encompass all employees within a district or sectional center is too fragmented for meaningful collective bargaining. Accordingly, we shall dismiss any petition which fails to at least meet this initial standard. As to the six petitions now before us, it is our considered judgment that when factors unique to the Postal Service are comingled with the other factors relating to community of interest, such as geographic proximity, employee interchange, and distinctiveness of job classifications, all of the petitioned-for units fail to evidence the community of interest which we require of appropriate units. However , our decision herein is not to be construed as an administrative fiat to adhere to the preexisting national craft units which Congress, under the PRA, continued during the transition period or as precluding a finding of unit appropriateness for a unit less than national in scope. Rather, we only hold that none of the instant Petitioners seeks to represent employees in an appropriate unit. Our concern is to encourage meaningful collective bargaining . And on the present record we find and conclude for the specific reasons set forth below that the petitioned-for units are inappropriate for achieving that goal. Petition I: Herein the MABC seeks to represent a heterogeneous mixture of employees within the New York Region of the Postal Service. The Petitioner 17 The postal data center employees are administratively placed outside the regional organization. Their function is limited to processing payroll and personnel data, and they are not involved in the processing of mail. is We note, moreover, that GNYAC's petition seeks the classification, "letter carriers," without seeking to represent rural letter carriers and special delivery messengers. Whatever functional specialization would appear to be exercised by letter carriers would appear also to be exercised by rural letter would include all postal clerks, postal data center employees, IT regional office employees,. maintenance employees, special delivery messengers, motor vehi- cle employees, mailhandlers, and mail equipment handlers. Although there are approximately 70,000 employ- ees in the petitioned-for unit, the Petitioner would exclude another 30,000 employees in the same region; e.g., letter carriers, who experience similar working and living conditions in the New York area. Furthermore, it is clear that the unit is not coexten- sive with any previously recognized unit, nor is it coextensive with the Employer's administrative organization. In determining whether the petitioned-for unit is appropriate, we note Petitioner's argument that all regional employees have the same terms and condi- tions of employment, are engaged in an integrated process, have regular and frequent contact among themselves, and share a common urban economic environment. These factors, however, are shared by the other employees in the New York Region whom Petitioner would exclude. The present record con- tains an insufficient amount of evidence to warrant our finding that the regional employees should be fragmentized along the lines proposed by the Petitioner. Since the MABC has not indicated any desire to proceed to an election in any other unit, we shall dismiss the petition. Petition II: In this petition, the GNYAC seeks to represent all city letter carriers in the New York Postal Region. Thus, the Petitioner is seeking to represent a single occupational group without seek- ing to represent all employees in the region. We reject this petition, essentially for the reasons expressed above with respect to Petition 1.18 Petition III: The National Alliance, in this petition, seeks to represent all motor vehicle employees working at several different Baltimore, Maryland, facilities. There are approximately 90 employees in the sought-for unit. At the outset, we note that the National Alliance is not seeking to represent all employees in a major administrative division of the Employer. The petitioned-for unit does not encom- pass all employees on a national, regional, metropoli- tan center, metropolitan area, or district basis; nor is it coextensive with a historically recognized national craft unit. As the National Alliance is not seeking to represent employees in the largest administrative divisions of the Employer, the issue before us is carriers and special delivery messengers. Although Petitions I and II together include all employees in the New York Region with the exception of the rural letter carriers, neither of the Petitioners has expressed an interest in the overall regional unit . According- ly, we need not and do not decide whether a unit of all regional employees would constitute an appropriate unit. UNITED STATES POSTAL SERVICE whether on the present record there is sufficient evidence to warrant a finding that a portion of a metropolitan center or area is an appropriate unit. In this regard , the National Alliance did not introduce any specific evidence regarding the job functions of these employees . It would appear from the Employer's testimony that the employees sought are engaged in maintaining the Employer's fleet of motor vehicles . The facilities at which these employ- ees work are located in, and are part of, the Baltimore Metropolitan Area. Although they work in areas separate from other postal employees, they share common working conditions and benefits with other Baltimore postal employees. As we indicated supra, to fragmentize the Employ- er's operation into units of 90 employees at one or two individual facilities would not promote a stable or meaningful collective-bargaining relationship. On this basis alone, we find that the unit is inappropri- ate. Accordingly, we shall dismiss Petition III. Petition IV: Herein the National Alliance seeks to represent all employees at the O'Hare-Midway facility in Chicago, Illinois. There are approximately 936 employees at this facility. Although the record does not disclose how these particular employees perform their assigned duties, presumably they perform the same functions as do their counterparts in other Chicago post offices ., While this airport facility may be geographically removed from down- town Chicago , it still remains an integral part of the Chicago Metropolitan Area. Despite the fact that there are 936 employees in the requested unit , we find that this single facility unit is inappropriate for collective bargaining . There are thousands of other post office employees in the Chicago Metropolitan Area. We find nothing in the present record which would lead us to separate 955 airport facilities from the remainder of the Metropol- itan Area . Accordingly , we shall dismiss Petition IV. Petition V: The National Alliance seeks to repre- sent all employees employed in the main post office and branch stations in East St . Louis , Illinois. There are approximately 476 employees in the petitioned- for unit . Although this petition is not limited to a single facility , the Petitioner does not seek to represent all employees in the metropolitan area of St. Louis . As was the case with Petitions III and IV, there is no record evidence which would warrant our fragmentizing the Employer's organization in the St. Louis Metropolitan Area. Accordingly , we shall dismiss Petition V. Petition VI: In Petition VI, the National Alliance seeks to represent all mailhandlers employed at the St. Louis, Missouri , main post office and related branch stations . As we found in regard to Petitions I and II , there is insufficient record evidence to establish that this group of employees is entitled to separate representation from other postal employees in the St . Louis Metropolitan Area. No showing has been made that these employees possess any special geographical or local interests not shared by others in the St . Louis Metropolitan Area . Considering all of these factors , and the absence of any bargaining history in support of the petitioned -for unit , we find that the Petitioner has adduced insufficient evidence to warrant our finding this unit to be a separate appropriate unit . Accordingly , we shall dismiss Petition VI. ORDER As we have found that none of the units sought is appropriate for collective-bargaining purposes, we order that the several petitions herein be , and they hereby are , dismissed.