The U.S. Postal Service holds a unique, if not special, place in American government. It’s an agency with rules set by Congress, with a large non-tax revenue stream, much like the National Parks Service, the Tennessee Valley Authority and the Bureau of Land Management. But unlike those agencies, the USPS must be self-funded, making it look and behave more like a private business than its peers.

The USPS is run by a board, not a secretary, which under normal circumstances would allow it to be governed by a group of postal experts rather than a single political appointee. But USPS governance is anything but normal; in recent years nominations were slow, confirmations slower, and the Postal Board of Governors slowly withered until it sat empty in 2018. While prospects improved with the appointment and confirmation of two new governors, the hopes of a quorum before the end of 2019 or even 2020 get bleaker by the day.

At a typical agency, the absence of a secretary might simply shuffle work to an acting secretary and the existing group of undersecretaries. But USPS procedures are different, as the postmaster general and deputy postmaster general were tasked with some board responsibilities when appointments lapsed.

Under such “emergency” leadership, the board still does not have a quorum and cannot engage the full scope of its authority.

This might not be a problem if the agency simply needed to keep doing what it was doing. But the USPS has a self-funding mandate powered by a declining industry. Changes to postal business practices, including some price adjustments, must be initiated by the Postal Board, not the USPS or the Postal Regulatory commission.

Not having a board means the USPS cannot execute the changes it needs to make to maintain its self-funded status as people send less mail and more packages.

The changing market calls for frequent reconsideration of product prices and the scope of different postal product lines. As a recent report on the USPS to the president notes, now is an appropriate time to discuss what package products should be considered for universal service, and what packages should be priced at cost.

Yet the biggest problem for a barely-there Postal Board is the pending American withdrawal from the UN’s Universal Postal Union. With only seven months until the U.S. begins to leave the world mail coordination agency, the USPS must be prepared to set its own rates for inbound letters and small packages. The postmaster general claims the agency is ready, but such an unprecedented transition would be easier if the agency had a complete leadership team in place.

If the USPS is supposed to behave like a private business, shareholders should work to fill the openings. Given that Congress and the president have struggled to keep the board filled, they might find it appropriate to change appointment procedures, either by once again making the postmaster general more like an agency head, or by otherwise lowering the bar for Senate confirmation of postal governors. While there would be risk to changing appointment rules, that risk is outweighed by the risks of long-term leadership vacuums that the USPS is already facing.

Until the Postal Board is reconstituted, the agency will struggle to follow through on recommendations like those in the task force report to the president. Congress may legislate, and the Postal Regulatory Commission may undertake prescribed rulemaking work. But without enough members to vote, the Postal Service will stumble forward into a very different post and parcel business than the one in which it once flourished. Updating rules to make filling the Postal Board easier would be a radical step. But a radical step might be better than no step at all, which is the status quo for a Postal Board that hasn’t had a quorum in years.