XKET
SECTION
RE:GEIVED
BEFORE THE
POSTAL RATE COMMISSION
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WASHINGTON, DC 20268-OOOlDEC 9
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Docket No. R97-1
Postal RateAnd Fee Changes,1997
FURTHER INTERROGATORIES OF
ALLIANCE OF NONPROFIT MAILERS
TO UNITED STATES POSTAL SERVICE
(ANMIZTSPS-18through 26)
December 9,1997
Pursuantto Rules 25 and 26 of the Rules of Practiceand Procedureand Order
1200,the Alliance of Nonprofit Mailers hereby submitsthe following interrogatoriesand
requestsfor production of documentsto the United StatesPostal Service.
ANM/USPS-18 Pleaseconfii
that the Postal Servicefirst pu’blishedregulations
in the FederalRegisterto implement Section705(a) of Public Law 103-123,codified at
39 U.S.C. 5 3626(j)(l)(D), on May 5, 1995. If you do not con&m fully, pleaseprovide a
FederalRegistercitation to any prior regulations.
ANMAJSPS-19. Pleaseconfii
that the first Postal Servicehandbookexplaining
Section 705(a) of Public Law 103-123and the regulationspromulgatedon May 5, 1995,
was Publication 417, publishedon or about October 1, 1995-i.e., the ,Fist month of
FY96. If you do not contii
fully, pleaseproducea copy of any prior handbook.
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ANMIUSPS-20:
(a)
Pleasestatehow many mailings, pieces,and pounds of mail preparedfor
entry at StandardA (formerly third-class) nonprofit rates were in fact
enteredat commercialrates during eachof the following periods because
the Postal Servicedetermined,before or during entry of the mail, that it did
not qualify for StandardA (or third-class) nonprofit rates:
(i)
the period from May 5, 1995,through the end of Fiscal Year 1995,
(ii)
Fiscal Year 1996,and
(iii)
the period from the beginningof Fiscal Year 1997through March 8,
1997.
If any of the data requestedare unavailablefor the entire period, please
provide all data currently availableand indicate the period(s) to which such
data apply.
(b)
For eachmailing identified in responseto part (a), pleasestatewhether the
Postal Servicerequired the mailer to correct the permit imprint, meter
stamp,or postageaffixed to the mail to reflect the fact that the mail was
ultimately enteredat somerate other than StandardA Nonprofit Rates.
ANM/USPS-21.
Pleasestatehow many mailings, pieces,and pounds of mail
originally enteredat StandardA (formerly third-class) nonprofit rates later generatedback
postagepaymentsto the Postal Serviceduring eachof the following periods after the
Postal Servicefound that the mail was ineligible for commercialrates:
(a)
Tom May 5, 1995,through the end of Fiscal Year 1995,
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(b)
during Fiscal Year 1996,and
(c)
from the beginningof Fiscal Year 1997through March Z:,1997.
If any of the datarequestedare unavailablefor the entire period, pleasleprovide all data
currently available and indicate the period(s) to which such data apply.
ANMKJSPS-22. Pleaseproduceall Postal Servicerules, regulations,operations
manuals,handbooksand similar documentsin effect during any part o:fthe period from
May 5, 1995through March 8, 1997,which dealt with the any of the following topics:
(a)
The accountingtreatment(in RPW data and elsewhere)of mail bearing
StandardA (or third-class)nonprofit indicia, but enteredat commercial
rates;
(b)
The accountingtreatment(in RPW data and elsewhere)of mail bearing
StandardA (or third-class)nonprofit indicia, but later giving rise to a
payment of back postageon the ground that the mail was,ineligible for
nonprofit rates.
ANMAJSPS-23. With respectto all IOCS tallies used in tbis rate case,what
instructions were given to IOCS tally takersconcerningthe classification of a mail piece
that bore StandardA nonprofit indicia but was in fact enteredat anotherrate? If tbe
instructions were other than to record the piece as StandardA nonprofit mail, please
produce documentssetting forth the instructions in full.
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ANlWUSPS-24.
Describethe policies and practicesof the USPSconcerning
enforcementof the mail preparationrequirementsadoptedaspart of nonprofit mail
reclassificationduring the secondhalf of calendar1996and fust quarter of calendar
1997.In your response,pleasefocus on the extent to which the USPSpermitted nonprofit
mailers to enter alreadypreparedmail that did not meet all of the reqmrementsfor the
rate categoryat which it was entered. Provide the best data or your best estimatesof the
actual volume of mail that was enteredin a rate categoryfor which it may not have met
every requirementduring (a) last quarter of FY 96 and (b) the first two quartersof FY97.
ANMKJSPS-25. This questionconcernsmailings enteredat standardA (formerly
third-class) nonprofit rates betweenMay 5, 1995through March 8, 1997,but later
assessedadditional postageunder anotherrate classor subclass.
(a)
For how many of the mailings did the Postal Servicerevise the Form 3602s
or the datareported on the Form 3602s?
(b)
What revisions were made?
(c)
Pleaseproduce all Postal Servicerules, regulations,operationsmanuals,
handbooksand similar documentsgoverningrevision of Form 3602, or data reported on
Form 3602, in thesecircumstances.
(d)
Pleaseproduce all data, studies,analysesor similar documentsconcerning
the actual rate of compliancewith the proceduresspecifiedin responseto part (b).
ANMKJSPS-26. This questionconcernsmailings which the mailer attemptedto
enter at standardA (formerly third-class) nonprofit ratesbetweenMay 5, 1995through
March 8, 1997,but which the Postal Servicerefusedto acceptfor entry without payment
of additional postageunder anotherrate classor subclass.
(a)
For how many of the mailings did the Postal Servicerevise the Form 3602s
or the datareported on the Form 3602s?
4
@)
What revisions were made?
(c)
Pleaseproduce all Postal Servicerules, regulations,operationsmanuals,
handbooksand similar documentsgoverningrevision of Form 3602, or data reported on
Form 3602, in thesecircumstances.
(d)
Pleaseproduce all data, studies,analysesor similar documentsconcerning
the actual rate of compliancewith the proceduresspecified in responseto part @).
Respectfully submitted,
Joel T. Thomas
1800K Street,N.W. Suite 810
Washington,DC. 20006
(202) 659-2333
David M. Levy
4
SIJILEY & AUSTIN
1722Eye Street,N. W.
Washington,DC 20006
(202) 736-8214
Counselfor Alliance of Nonprofit Mailers
December9, 1997
CERTIFICATE
OF SERVICE
I hereby certify that I havethis day servedthe foregoing documenton all
participants of record in this proceedingin accordancewith section 12 of the Rules of
Practice.
December9, 1997
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