<‘3CMET SECTION BEFORE THE POSTAL RATE COMMISSION WASHINGTON, D.C. 20268-0001 POSTAL RATE AND FEE CHANGES, 1997 INTERROGATORIES .p~cg:‘c[) JBH22 4 ‘10i/i ‘$0 Docket No R97-1 i UNITED STATES POSTAL SERVICE AND REQUESTS FOR PRODUCTION THE AMERICAN BUSINESS PRESS (USPSIABP-1-34) OF DOCUMENTS TO Pursuant to rules 2.5 and 26 of the Rules of Practice and Proceclure and rule 2 of the Special Rules of Practice, the United States Postal Service directs the following interrogatories Press: and requests for production of documents to the American Business USPSIABP-1-34 Respectfully submitted, UNITED STATES POSTAL SERVICE By its attorneys: Daniel J. Foucheaux, Jr. Chief Counsel, Ratemaking &gLb??AA Susan M. Duchek 475 L’Enfant Plaza West, SW. Washington, D.C. 20260-I 137 (202) 268-2990; Fax -5402 January 22, 1998 USPWABP-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 USPWABP-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: (a) The number of issues mailed. (b) The average number of editions (versions) per issue. (4 An indication of the kind or type of each version. USPS/ABP-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 from regular or listed in response to intlerrogatory number 1. USPS/ABP-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 USPWABP-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 USPSIABP-6. city/5-digit presort 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 from regular or periodical regular carrier route presort rates for each publication listed in response to interrogatory number 1. USPS/ABP-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 to interrogatory USPSJABP-8. delivery office discount rates for each publication USPSJABP-9. listed in response For each fiscal year (or calendar year if fiscal year is unavailable) destination interrogatory regular or periodical number 1. 1986 to present, please provide the volumes mailed at second-class regular 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. USPSJABP-10. 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 saturation discount rates for each publication listed in response to interrogatory number 1. USPS/ABP-1 1. 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/ABP-12. letter size discount rates for each publication 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 regular prebarcoded interrogatory flat size discount rates for each publication from mgular or periodical listed in response to number 1. USPSJABP-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 USPS/ABP-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 volumes mailed at second-class 5-digit letter size discoulnt rates for each listed in response to interrogatory USPSJABP-15. from number 1. 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 regular prebarcoded listed in response to interrogatory USPSJABP-16. 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 regular rates for zones l&2 for each publication listed in response to interrogatory USPWABP-17. number 1. 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 USPS/ABP-18. weight mailed regular or periodical regular rates for zone 3 for each publication in response to interrogatory from 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 in response to interrogatory USPSIABP-19. 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 at second-class regular or periodical regular rates for zone 5 for each publication in response to interrogatory USPYABP-20. listed 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 6 for each publication in response to interrogatory USPWABP-21. 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 at second-class regular or periodical regular rates for zone 7 for each publication in response to interrogatory USPWABP-22. number 1. 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 listed from weight mailed regular or periodical regular rates for zone 8 for each publication listed in response to interrogatory number 1. USPSJABP-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 USPSIABP-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: (3) 5-digit pallets (b) 3-digit pallets Cc) SCF pallets (4 ADC/SDC (4 BMC pallets VI Mixed-BMC USPQABP-25. pallets. For each fiscal year (or calendar year if fiscal year is unavailable) 1986 to present, periodical pallets for those volumes mailed on pallets at second-class regular rates for each publication listed in response to interrogatory from regular or number 1, please provide the average number of pieces per pallet by the follc’wing pallet presort levels: (a) 5-digit pallets (b) 3-digit pallets ((3 SCF pallets (4 ADCEDC (e) BMC pallets (9 Mixed-BMC USPS/ABP-26. pallets pallets For each fiscal year (or calendar year if fiscal year is unavailable) 1986 to present, for those volumes mailed on pallets at second-class periodical regular rates for each publication listed in response to interrogatory from regular or number 1, please provide the average pallet weight by the following pallet presort levels: (4 5-digit pallets (b) 3-digit pallets (4 SCF pallets (4 ADWSDC W BMC pallets (9 Mixed-BMC USPWABP-27. pallets pallets. For each fiscal year (or calendar year if fiscal year is unavailable) 1986 to present, please provide the volumes mailed in sacks at second-class periodical regular rates for each publication 1 by the following sack presort levels: (a) Carrier route(s) sacks listed in response to interrogatory from regular or number (b) Firm sacks (4 5digit 03 3-digit unique city sacks (4 3-digit sacks (9 SCF sacks (9) ADWSDC 04 Mixed sacks. USPSJABP-28. sacks 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 re’gular or periodical number 1, please provide the average number of pieces per sack by the following sack presort levels: (a) Carrier route(s) sacks (b) Firm sacks Cc) 5digit (d) 3-digit unique city sacks (e) 3-digit sacks (9 SCF sacks (9) ADClSDC (h) Mixed sacks. sacks sacks USPSIABP-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: (4 Carrier route(s) trays (b) Firm trays (cl 5digit trays (d) 3-digit unique city trays (4 3-digit trays (9 SCF trays (9) ADCEDC (h) Mixed trays. USPWABP-30. trays For each fiscal year (or calendar year if fiscal year is unavailable) 1986 to present, for those volumes mailed in trays at second-class regular rates for each publication listed in response to interrogatory regular or periodical number 1, please provide the average number of pieces per tray by the following tray presort levels: (a) Carrier route(s) trays (b) Firm trays (c) 5-digit trays Cd) 3-digit unique city trays (6 ‘3-digit trays from (9 SCF trays (9) ADWSDC (W Mixed trays. USPS/ABP-31. trays 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. USPSJABP-32. 1986 to present, periodical For each fiscal year (or calendar year if fiscal year is unavailable) for those volumes mailed in bundles at seconcl-class regular rates for each publication listed in response to interrogatory from regular or number 1, please provide the average number of pieces per bundle. USPS/ABP-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 regular or periodical regular rates that were plant loaded in USPS provided transportation for each publication listed in response to interrogatory USPWABP-34. number I. Please also provide all data furnished through 33 above in electronic format. IO in response to interrogatories 1 CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing document participants of record in this proceeding in accordance with section 12 of the Rules of Practice. &zL/ S&d% Susan M. Duchek 475 L’Enfant Plaza West, S.W. Washington, D.C. 20260-I 137 January 22, 1998 upon all
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