RlICElVEll
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON,
D.C.
4 59 Pti ‘97
SEP 2
20268-OOO1POSTdl~hTE
CCHHISPiON
OFFICE OFTHE SECRETARY
POSTAL RATE AND FEE CHANGES, 1997
Docket
No.
R97-1
1
THE DIRECT MARKETING ASSOCIATION,
INC.'S
SECOND SET OF
INTERROGATORIES AN-D REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED
TO USPS WITNESS MOELLER (DMA/USPS-T36-2-S)
Pursuant
Rules
of
submits
for
Practice,
the
attached
production
T36-2-S).
If
to
Sections
the
Direct
second
of
documents
the
designated
we request
interrogatory,
25 and 26 of
Marketing
set
to
of
a response
Commission's
Association,,
Inc.
interrogatories
USPS witness
witness
the
is
and requests
Moeller
unable
hereby
to
(DMA/USPSrespond
by some other
to
qualified
witness.
Respectfully
submitted,
David L. MeyerMichael
D. Bergman
COVINGTON & BURLING
1201 Pennsylvania
Avenue,
20004
Washington,
D.C.
(202) 662-5296
Counsel
for the
Association,
September
2,
1997
Direc:t
Inc.
N.W.
Marketing
this
2
Witness
Moeller
DIV./USPS-T36-2.
confirm
that
in
(USPS-~-36)
Please
refer
GFY 1996:
to
LR-H-108,
page
6,
Table
1,
and
a.
There were 938.9 million
(A) commercial
pieces.
b.
There were
pieces.
C.
A ten cent residual
shape surcharge
for the Standard
(A) commercial
subclasses
would have raised
approximately
$93.9 million
in revenues
if the
surcharge
did not affect
nonletter,
nonflat
volume.
d.
If the increase
in revenue
from the residual
shape
surcharge
were used to reduce
the Standard
(A)
commercial
flat
rates,
the average
rate per piece
for
Standard
(A) commercial
flats
in GFY 1996 could have
been lowered
by .35 cents while
keeping
revenue
constant.
DMA/USPS-T36-3.
piece
that
has
that
this
piece
surcharge.
26.5
billion
nonletter,
flat
Standard
nonflat
Standard
(A)
commercial
Please
assume that
there
is a nonletter,
nonflat
cost-causing
characteristics
similar
to a flat
and
is subject
to the ten cent residual
shape
a.
Do you think
contemplated
fully.
that
this
would be fair
in 39 U.S.C.
5 3622(b)?
b.
Do you think
that
applying
the ten cent surcharge
to
this
piece
of mail would properly
take into
account
the
Please
explain
cost of service
of this
piece
of mail?
fully.
Please
explain
fully
why the
DMA/USPS-T36-4.
chose not to propose
a four cent discount
for
Standard
(A) machinable
parcels
as it did for
Standard
(B) machinable
parcels.
and equitable
as
Please
explain
Postal
Service
prebarcoded
prebarcoded
Please
refer
to pages 3 through
6 of your direct
DMA/USPS-T36-5.
testimony
in which you propose
the elimination
of the Standard
Please
explain
why costs
for this
(A) single-piece
subclass.
subclass
are such that
increasing
rates
to cover
its
costs
would
result
in rates
that
would exceed First
class
mail rates
and
Please
explain
rate
relationships."
would result
in "illogical
whether
this
anomaly
reflects
a fundamental
problem
with
the
Postal
Service's
cost attribution
systems
(e.g.,
IClCS)?
3
DMA/USPS-T36-6.
Please
refer
to page 10 of your
testimony.
Was the need to "temper
the increase
category"
considered
with
the decision
to impose
residual
shape surcharge?
Please
explain
fully.
DMA/USPS-T36-7.
Please
define
flats
and parcels
in
letters,
dimensions
and weight.
direct
on any one
a ten cent
rate
machinable
and nonmachinable
terms of minimum and maximum
Please
refer
to page 16, lines
7-8,
and page 27,
DMA/USPS-T36-8.
Please
explain
fully
how the
lines
1-2, your direct
testimony.
proposed
breakpoint
weight
was calculated
for both Standard
(A)
Commercial
Regular
and Enhanced
Carrier
Route subclasses.
4
CERTIFICATE
foregoing
proceeding
Postal
3 of
I hereby
certify
document
upon
in
Rate
the
accordance
Commission's
Commission's
proceeding.
September
2,
1997
that
all.
I have
this
participants
with
Rules
Speci.al
OF SERVICE
Rule
date
of
12
served
record
(section
in
the
this
3001.12)
of
Practice
and Procfedure
Rules
of
in
Practice
this
of
the
and Rule