DOCKET .%CTlON
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
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Docket No. R97--1
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UNITED STATES POSTAL SERVICE
INTERROGATORIES
AND REQUESTS FOR PRODUCTION OF DOCUMENTS
THE NATIONAL NEWSPAPER ASSOCIATION
(USPSINNA-1-34)
Pursuant to rules 25 and 26 of the Rules of Practice and Procedure
TO
and rule 2 of
the Special Rules of Practice, the United States Postal Service directs the following
interrogatories
Association:
and requests for production of documents to the National Newspaper
USPSINNA-1-34.
Respectfully submitted,
UNITED STATES POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
Susan M. Duchek
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-I 137
(202) 268-2990; Fax -5402
January 22, 1998
USPS/NNA-I.
For each year fiscal year (or calendar year if fiscal year is unavailable)
from 1986 to present, please provide a list of publications
of your trade association and mailed at second-class
USPSINNA-2.
published by each member
regular or periodical regular rates.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please for each publication listed in response to interrogatory
from
number
1 the following information:
(4
The number of issues mailed.
03
The average number of editions (versions) per issue.
(cl
An indication of the kind or type of each version.
USPSINNA-3.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present,
please provide the total volumes mailed at second-class
periodical regular rates for each publication listed in response to interrogatory
from
regular or
number
1.
USPS/NNA-4.
For each fiscal year (or calendar year if fiscal year is, unavailable)
1986 to present, please provide the volumes mailed at second-class
regular required
number 1.
presort rates for each publication
from
regular or periodical
listed in response
to interrogatory
USPSINNA-5.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volumes mailed at second-class
regular
3-digit
interrogatory
city/5digit
presort
rates for each publication
from
regular or periodical
listecl in response
to
number 1.
USPSINNA-6.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volumes mailed at second-class
from
regular or periodical
regular carrier route presort rates for each publication listed in response to interrogatory
number 1.
USPSINNA-7.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volumes mailed at second-class
regular destination
regular or periodical
delivery office discount rates for each publication listed in response
to interrogatory
number 1.
USPSINNA-8.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volumes mailed at second-class
regular
destination
interrogatory
USPSINNA-9.
from
SCF discount
rates for each publication
from
regular or periodical
listed in response
to
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volumes mailed at second-class
2
from
regular or periodical
regular high density discount rates for each publication listed in response to interrogatory
number 1.
USPS/NNA-10.
For each fiscal year (or calendar year if fiscal year is unavatlable) from
1986 to present, please provide the volumes mailed at second-class
regular or periodical
regular saturation discount rates for each publication listed in response to interrogatory
number 1.
USPS/NNA-11.
For each fiscal year (or calendar year if fiscal year is unavailable) from
1986 to present, please provide the required presort volumes mailed at second-class
regular or periodical regular prebarcoded
listed in response to interrogatory
USPS/NNA-12.
letter size discount rates fclr each publication
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable) from
1986 to present, please provide the volumes mailed at second-class
regular prebarcoded
interrogatory
flat size discount rates for each publication
regular or periodical
listed in response to
number I.
USPSINNA-13.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the 3-digit city/5-digit volumes mailed at second-class
regular
or periodical
publication
regular prebarcoded
3-digit letter size discount
listed in response to interrogatory
3
number 1.
rates for each
USPSINNA-14.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the 3-digit city&digit
regular or periodical
publication
regular prebarcoded
USPSINNA-15.
rates for each
number I.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the 3-digit city/5digit
regular or periodical
regular prebarcoded
listed in response to interrogatory
USPSINNA-16.
volumes mailed at second-class
5-digit letter size discount
listed in response to interrogatory
from
from
volumes mailed at second-class
flat size discount rates for each publication
number 1.
For each fiscal year (or calendar year if fiscal year is; unavailable)
from
1986 to present, please provide the volume, total weight and advertising weight mailed
at second-class
regular or periodical
listed in response to interrogatory
USPSINNA-17.
regular rates for zones l&2 fclr each publication
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the volume, total weight and advertising weight mailed
at second-class
regular or periodical regular rates for zone 3 for each publication
in response to interrogatory
USPSINNA-18.
listed
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the volume, total weight and advertising weight mailed
4
at second-class
regular or periodical regular rates for zone 4 for each publication listed
in response to interrogatory
USPS/NNA-19.
number I.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the volume, total weight and advertising weight mailed
at second-class
regular or periodical regular rates for zone 5 for each1 publication listed
in response to interrogatory
USPWNNA-20.
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the volume, total weight and advertising weight mailed
at second-class
regular or periodical regular rates for zone 6 for each publication listed
in response to interrogatory
USPSINNA-21.
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable) from
1986 to present, please provide the volume, total weight and advertising weight mailed
at second-class
regular or periodical regular rates for zone 7 for each publication listed
in response to interrogatory
USPSINNA-22.
number I.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volume, total weight and advertking
at second-class
from
weight mailed
regular or periodical regular rates for zone 8 for each publication listed
in response to interrogatory
number 1.
USPSINNA-23.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present,
please provide the average
mailed at second-class
of nonadvertising
content
regular or periodical regular rates for each publication
response to interrogatory
USPSINNA-24.
percentage
from
listed in
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the volumes mailed on pallets at second-class
regular
or periodical regular rates for each publication listed in response to interrogatory
number
1 by the following pallet presort levels:
(4
5-digit pallets
(b)
3-digit pallets
(4
SCF pallets
(4
ADCKDC
63
BMC pallets
(f)
Mixed-BMC
USPSINNA-25.
pallets.
For each fiscal year (or calendar year if fiscal year i:s unavailable)
1986 to present,
periodical
pallets
for those
volumes
mailed on pallets at second-class
from
regular
regular rates for each publication listed in response to interrogatory
or
number
1, please provide the average number of pieces per pallet by the following pallet presort
levels:
(a)
5-digit pallets
6
(b)
3-digit pallets
(cl
SCF pallets
(4
ADClSDC
(4
BMC pallets
(9
Mixed-BMC
USPSINNA-26.
pallets
pallets
For each fiscal year (or calendar year if fiscal year is unavailable) from
1986 to present,
for those volumes
mailed on pallets at second-class
regular
periodical regular rates for each publication listed in response to interrogatory
or
number
1, please provide the average pallet weight by the following pallet presort levels:
(a)
5-digit pallets
(b)
3-digit pallets
(cl
SCF pallets
Cd)
ADClSDC
(e)
BMC pallets
(9
Mixed-BMC
USPSINNA-27.
pallets
pallets.
For each fiscal year (or calendar year if fiscal year is unavailable) from
1986 to present, please provide the volumes mailed in sacks at second-class
regular or
periodical regular rates for each publication listed in response to interrogatory
1 by the following sack presort levels:
(4
Carrier route(s) sacks
7
number
(b)
Firm sacks
(c)
5-digit sacks
(4
3-digit unique city sacks
(4
3-digit sacks
(9
SCF sacks
(9)
ADWSDC
(h)
Mixed sacks.
USPWNNA-28.
sacks
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, for those volumes mailed in sacks at second-class
regular rates for each publication
listed in response to interrogatory
from
regular or periodical
number 1, please
provide the average number of pieces per sack by the following sack presort levels:
(4
Carrier route(s) sacks
@I
Firm sacks
(cl
5digit
(d)
3-digit unique city sacks
W
3-digit sacks
(9
SCF sacks
(9)
ADCLSDC sacks
(f-4
Mixed sacks.
sacks
8
USPSINNA-29.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volumes mailed in trays at second-class
periodical
regular rates for each publication listed in response to interrogatory
from
regular or
number
1 by the following tray presort levels:
(a)
Carrier route(s) trays
W
Firm trays
(cl
5-digit trays
(4
3-digit unique city trays
(4
3-digit trays
(fl
SCF trays
(9)
ADCYSDC trays
(h)
Mixed trays.
USPSINNA-30.
For each fiscal year (or calendar year if fiscal year is unavailable) from
1986 to present, for those volumes mailed in trays at second-class
regular rates for each publication
listed in response to interrogatory
rlegular or periodical
number 1, please
provide the average number of pieces per tray by the following tray presort levels:
(4
Carrier route(s) trays
(b)
Firm trays
(c)
5digit
(4
3-digit unique city trays
(e)
3-digit trays
trays
9
(9
SCF trays
(9)
ADClSDC
‘(W
trays
Mixed trays.
USPSINNA-31.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the volumes mailed in bundles at second-class
regular
or periodical regular rates for each publication listed in response to interrogatory
number
1.
USPSINNA-32.
1986 to present,
For each fiscal year (or calendar year if fiscal year is unavailable)
for those volumes
mailed
periodical regular rates for each publication
in bundles
at second-class
from
regular
listed in response to interrogatory
or
number
1, please provide the average number of pieces per bundle.
USPSINNA-33.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the volumes mailed at second-class
iregular or periodical
regular rates that were plant loaded in USPS provided transportation
for each publication
listed in response to interrogatory
USPSINNA-34.
number 1.
Please also provide all data furnished in response to interrogatories
through 33 above in electronic format.
10
1
CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoing
participants
of record in this proceeding in accordance
with section 12 of the Rules of
Practice.
Susan M. Duchek
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-I 137
January 22, 1998
document upon all