iXXKET SECTION
BEFORE
THE
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POSTAL RATE COMMISS
WASHINGTON, D.C. 20268-0001
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POSTAL RATE AND FEE CHANGES, 1997
Docket
No.
R97-I'
p,y
'97
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THE DIRECT MARKETING ASSOCIATION,
INC.'S
INTERROGATORY AND
REQUEST FOR PRODUCTION OF DOCUMENTS TO THE UNITED STATES POSTAL
SERVICE PURSUANT TO SPECIAL RULE OF PRACTICE 2.E.
(DMA/USPS-11)
Pursuant
Practice,
Practice,
attached
the
United
to
and
the
Sections
Rule
Direct
2.E.
of
the
Marketing
interrogatory
States
25 and
Service
the
Commission's
Rules
of
Special
Rules
of
Commission's
Association,
and request
Postal
26 of
for
Inc.
hereby
production
of
submits
documents
(DMA/USPS-11).
Respectfully
submitted,
Dana T. Ackedlv
II,
Bsq.
David L. MeyerMichael
D. Bergman
COVINGTON & BURLING
1201 Pennsylvania
Avenue,
20004
Washington,
D.C.
(202) 662-5296
Counsel
for the
Association,
November
25,
1997
Direct
Inc.
N.W.
Marketing
the
to
2
DMA/USPS-11.
Please
refer
to New Performance-Based
Compensation
System,
AMMA Bulletin,
No.
45-97
(Advertising
Mail
Marketing
Association,
Washington.
D.C.),
October
17, 1997, at 4 (Attachment
1) which states,
"A postal
official
said that
in large
part,
this
determination
[that
nonexempt
employees
were
no~t eligible
to
receive
bonuses
under a special
compensation
program]
was based on
the results
of a wage comparability
study
done recently
for
the
Postal
Service
in which the wages of postal
employees
were compared
to wages for employees
doing
similar
work in the private
sector.
The official
said
that
the
results
of the
study
showed
that
nonexempt
postal
employees
were paid from 30 to 60 percent
higher
wages compared
to employees
doing
similar
work
in the private
sector."
a.
Please
confirm
that
a recent
study
of Postal
Service
wages for nonexempt
postal
employees
found
that
Postal
Service
nonexempt
wages were between
30 to 60 percent
higher
than private
sector
employees
performing
similar
If not confirmed,
please
explain
fully.
work.
b.
Please
summarize
the methodology
comparability
study
and provide
C.
I
foregoing
hereby
certify
document
upon
proceeding
3 of
in
Rate
the
the wage
study.
accordance
Commission's
Commission's
I
that
all
with
Rules
Special
25,
1997
align
wages
please
OF SERVICE
have
this
participants
12
Rule
of
Rules
(section
Practice
of
date
of
served
record
in
3001.121
and Proc:edure
Practice
//Michael
November
of
the
IS the Postal
Service
taking
any actions
to better
wages for nonexempt
employees
with private
sector
for
employees
performing
similar
work?
If so,
why not?
If not,
describe
the actions.
CERTIFICATE
Postal
and results
a copy of
in this
the
this
of
and Rule
proceeding.
D". Bergman
the
Attachment
1