BEFORE THE
POSTAL RATE COMMlSSlON
WASHINGTON, D.C. 20268-Q;;j2
R’ICEIVCL’
ii 57 17/I198
..~
,~B..:
/I,~,~;
POSTAL RATE AND FEE CHANGES, 1997
,,‘,,>
.,
~.‘:~
Docket No. R97-4
i
UNITED STATES POSTAL SERVICE
INTERROGATORIES
AND REQUESTS FOR PRODUCTION OF DOCUMENTS
THE NEWSPAPER ASSOCIATION OF AMERICA WITNESS DONLAN
(USPSINAA-T2-5-6)
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
of America witness Donlan:
to the Newspaper
USPSINAA-T2-5-6.
Respectfully
submitted,
UNITED STATES POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
475 L’Enfant Plaza West, SW.
Washington, D.C. 20260-I 137
(202) 268-2997; Fax -5402
January 22, 1998
USPSINAA-T2-5.
Please refer to your testimony at page 1, lines 22-24.
You state that
you, “conclude that the proposed increases in the presort discounts are not justified and
[you] recommend
that the Commission
maintain current discounts for these categories
of mail.”
a.
Please refer to Attachment
1 embodies
your recommended
discounts for ECR.
b.
1 to this interrogatory.
discounts,
Please confirm that Attachment
i.e., the maintenance
of the current
If not confirmed, please explain.
Please confirm the accuracy of Attachment
1. If not confirmed,
please explain
your response.
C.
Please attach a copy of Attachment
1 to your response or, if you do not confirm
subpart (b), please attach a corrected copy of Attachment
d.
Please refer to Attachment 2 to this interrogatory.
2 shows the effective
Commission
proposed
I.
Please confirm that Attachment
rates using your recommendation
maintain the current discounts for ECR.
that the
If not confirmed,
please
explain.
e.
Please attach a copy of Attachment
2 to your response or, if you do not confirm
subpart (d), please attach a corrected copy of Attachment
USPS/NM-TZ6.
2.
Please refer to page 12 lines 20-21 of your testimony.
You state, “the
analytical approach used by the Postal Service accounts for DPS-related mail processing
costs but ignores offsetting delivery cost savings.”
a.
Please confirm that your statement
confirmed,
please explain.
applies only to letter shaped mail.
If not
b.
Please confirm that your statement
“automation
equipment.
C.
compatible,”
applies only to letter shaped mail that is
Le., capable
If not confirmed,
of being
on automation
please explain.
Please confirm that in order for the Postal Service to receive any savings
delivery for ECR Basic letters that are processed
must be successfully
barcoded.
d.
processed
barcoded,
on automation,
if they are not already
in
such pieces
correctly
customer
If you do not confirm, please explain.
Please confirm that in order for the Postal Service to receive any savings
delivery for ECR Basic letters that are processed
must be successfully
sequenced
on delivery
on automation,
barcode sorters.
in
such pieces
If you do not
confirm, please explain.
e.
Please
confirm
automation
that ECR Basic letters that are successfully
sequenced
on
to delivery sequence consist of only a subset of ECR Basic letters.
If not confirmed,
please explain.
Attachment
1 to USPSINAATZ-5
Moeller WPl, page 18. Presort discounts held at currant value
ENHANCED CARRIER ROUTE SUBCLASS
DEVELOPMENT OF PRESORT AND AUTOMATION
Item
1
2
3
4
5
6
7
8
9
10
11
Nonletters:
Basic
High Density
Saturation
Subtotal
Letters:
Basic
Automated
High Density
Saturation
Letter Discount
Subtotal
Total
MP + Del
Unit Cost
(Cents)
Differential
(Cents)
(1)
(2)
10.3844
7.5692
5.9082
-
2.8152
1.6610
6.8745
6.2687
4.7640
3.8560
3.5099
0.6058
2.1105
0.9080
-
Discount
(4)
-
(5) Cumulative discount for that category.
(6) Page 4
(7) Cal(5) * Col (6)
(5)
-
0.8
1.0
0.8
1.8
-
0.0
0.7
0.8
0.9
0.0
0.7
0.8
1.7
0.0
--
(1) Page IO
(2) Difference between relevant cost figures in Cal(1)
.:,
Cumulative
Discount
(Cents)
DISCOUNTS
Pieces
(Millions)
Value
(Millions)
(‘3)
(7)
10706.608
1150.761
8172.668
20030.037
9.206
147.108
156.314
6781.043
2123.223
394.077
3095.861
3489.938
12394.204
32424.241
0.000
14.863
3.153
52.630
0.000
70.645
226.959
Attachment 2 to USPS/NW+TZ-5
Moeller WI,
page 31. Effective rates if ECR presort discounts held constant.
Standard Mail (A) - Enhanced
Proposed
Carrier Route
Rates (6)
Minimum
per piece rates
Density tier
Shape
Basic
Letter
Automation
Nonletter
0.150
0.146
0.155
0.162
0.155
0.162
8.0%
6.2%
4.6%
High-Density
Letter
Nonletter
0.142
0.147
0.164
0.154
8.6%
4.8%
Saturation
Letter
Nonletter
0.133
0.137
0.145
0.144
9.0%
6.1%
Pound-rated
current
pieces
current
High Density
destination
Wee-rated
proposed
per piece
per pound
0.018
0.663
0.053
0.530
per piece
per pound
0.010
0.663
0.045
0.530
per piece
per pound
0.000
0.663
0.035
0.530
DBMC
DSCF
DDU
current
per piece
0.013
0.018
0.023
proposed
per piece
0.015
0.018
0.023
DBMC
DSCF
DDU
current
per pound
0.064
0.085
0.111
provosed
per bound
0.072
0.088
0.110
Entry Discounts
pieces
I
Pound-rated
proposed
pieces
%chg
CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoing document
participants
upon all
of record in this proceeding in accordance with section 12 of the Rules of
Practice.
475 L’Enfant Plaza West, SW.
Washington, D.C. 20260-I 137
January 22, 1998