DOCKET SECTION
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
POSTAL RATE AND FEE CHANGES,
1997’)
RECEIVELJ
h
23
1 56 PM ‘97
Docket No. R97-1
FIRST SET OF FOLLOW-UP INTERROGATORIES
OF MAJOR MAILERS ASSOCIATION
TO UNITED STATES POSTAL SERVICE
REGARDING OCTOBER 21,1997 RESPONSE
Major Mailers Association
following
follow-up
Rules of Practice
requested
and Procedure.
pursuant
information,
that if a new analysis
that information
the Presiding
POR No. R94-l/38
(page 6), the Presiding
under Commission
(page 5).
L
the Service
is
Officer disagreed
in order to provide requested
Officer ruled, “is that which is possible
submitted,
MAJOR MAILERS
23. 1997
these interrogatories,
is required
is not “available”
Respectfully
October
to Rules 25 and 26 of the Commission’s
In answering
to note that, in POR No. R94-l/18
wrth a contention
available,”
interrogatories
asks the United States Postal Service to answer the
ASSOCIATION
Richard Littell
1220 Nineteenth St. N.W.
Suite 400
Washington, DC 20036
Phone: (202) 466-8260
Rule 25(a).
to obtain.”
“The
See also
MMA INTERROGATORIES
TO POST.AL SERVICE
MMAIUSPS-FU-2
Please refer to the Postal Service’s
October
21 Response
to Order No. 1197,
Table 11-2. where the Service lists the total mail processing
the following
presort,
categories
(b) Automation
Automation
letter and cards: (a) Nonautomation
basic presort, (c) Automation
!I-digit presort, and (e) Automation
Please confirm
(as requested
in this Response
Service]
of First-Class
unit cost results for
(d)
carrier route presort
by the Interrogatory)
“shows how the costs of First-Class
had used the Commission-approved
3-digit presort,
that the information
provided
letters would change
if [the
methodology.”
MMAIUSPS-FU-3
Please refer to Interrogatory
and 8, where the Commission
various
rate categories
worksharing
amount
discounts
MMA/USPS-FU-2
said that witness
for First-Class
letters and cards because
of costs avoided by the various worksharing
on the cost avoidance
calculations
discounts
is information
attribution
methods
evaluate
Is it possible
“unit costs [for the
letters and cards] provide the basis of
proposed
(A)
Hatfield’s
of First-Class
of the Postal Service’s
properly
and to Order No. 1197. pages 6-7
changes
that is obviously
and its proposed
the Postal Service’s
to determine
categories”
in mail processing
that underlie
its proposed
proposed
methods
rate category
both its proposed
Indeed, it would be difficult to
discounts
the
and “The effect
attribution
relevant to evaluating
discounts.
they indicate
without
from the Table II-2 unit costs alone:
it.”
(1)
“[Tjhe basis of worksharing
discounts
for letter and cards” (See Order
No. 1197, page 6)?
(2)
“[The
amount of the costs avoided
categories”
(3)
(See Order No. 1197, pages 6-7)?
“[Tjhe cost avoidance
category
discounts”
calculations
the amount
underlie
that [should]
of this Interrogatory
in detail and provide a calculation
rate category
discounts
is other than “no,”
of the basis of the discounts,
of costs avoided, and the cost avoidance
First-Class
underlre...rate
(See Order No. 1197, page 8)?
If the answer to any of the subparts
please explain
by the various worksharing
calculations
that should
under the Commission’s
methodology.
MMAIUSPS-FU-4
Please refer to Interrogatory
MMAAJSPS-FU-2
19, where the Postal Service witness
resulting
discounts
under consideration
are measured
stated that “cost avoidances
by subtracting
from the benchmark
critical as the measured
disapproved
that Instead:
automation
metered
the cost of the rate category
in determining
is just as
the discount.”
pages 19-21. where the Postal Service
the use of “all presorted
“The specrfic benchmark
page
and the
cost” and that “the benchmark
cost of the rate category
Please also refer to Exhibit USPST32,
witness
and to Exhibit USPS-T32,
letters as a benchmark,”
I used in setting the discounts
letters is the sum of mail processing
and delivery
saying
for bulk
costs for bulk
mail” (Italics added).
If the Commissron
decrdes to establish
discounts
by using the methodology
2
-
I,
-
implicit in the Table II-2 of the October 21 Response
and the unit costs shown in
that Table, does the Postal Service still believe that:
(4
Cost avoidances
by subtracting
and the resulting
the (labor plus delivery)
under consideration
(W
The benchmark
category
CC)
discounts
should be measured
cost of the rate category
from the benchmark
cost?
is just as critical as the measured
in determinrng
cost of the rate
the discount?
The unit costs of all presorted
letters should not be used as a
benchmark?
CD)
The specrfic benchmark
discounts
that should be used in setting the
for bulk automation
letters is the sum of mail processing
and delivery unit costs for bulk metered
mail?
MMAIUSPS-FU-5
Please refer to Interrogatory
(4
MMAfUSPS-FU-4.
Does the Postal Service’s
show a unit processing
(6)
October 21 Response
cost for the bulk metered
for First-Class
letters. computed
Commission’s
methodology
accordance
for First-Class
with the Commission’s
provide a copy of that document
3
with the
any other document
that shows the unrt processing
metered mail benchmark
mail benchmark
?
Has the Postal Service submitted
proceeding
in accordance
to Order No. 1197
in this
cost for the bulk
letters, computed
methodology?
in
If so. please
or (if it is voluminous)
a citation to
the place in the record where that benchmark
is available
MMAIUSPS-FU-6
Please refer to Interrogatories
Servrce’s
October
16 Response
MMAAJSPS-T25-1,
costs in witness
to Order No. 1197.
Hatfield’s
testimony...differ
in Exhibit USPS-T32
processing
unit cost for the bulk metered
(page 26) in conjunction
costs” to derive the First-Class
under the Commission’s
If the Commission
methodology,
Service’s
decided to compute
October 21 Response,
methodology
derive the First-Class
cost savings
benchmark]
used
Hatfield’s
“unit
shown on that
that would be
discounts
according
to its own
costs shown in Table II-2 of the
would it be proper and consistent
benchmark
with witness
with
to adopt the Postal
used in Exhibit USPS-T32
Hatfield’s
“unit processing
costs” to
letter-discount?
If the answer to Subparagraph
detail why it is appropriate
derived
benchmark,
with witness
for the Commrssion
unit cost bulk metered
(page 26) in conjunctron
CC)
processing
costing methodology”?
using the unit processing
the Commission’s
Service’s
to Interrogatory
from those that would be produced
page, also “differ from [the bulk metered
(Q
In response
costing methodology.”
Does the Postal Service’s
produced
and FU-5 and to the Postal
the Postal Service said that “The unit benchmark
under the Commission’s
(A)
MMAAJSPS-FU-4
(6) is other than “no,” please explain
to derive discounts
under one methodology
by subtracting
from a benchmark
4
In
unrt costs
that is derived
under a
different
methodology?
MMAIUSPS-FU-7
Please refer to Interrogatories
provide the unit processing
comparable
October
mail benchmark
that is
costs shown in Table II-2 to the Service’s
to Order 1197 and that will provide the Commission
basis to employ the Table II-2 costs in making a determinatron,
the Commissron’s
(1)
and FU-4 through 6. Please
cost for a bulk metered
to the unit processing
21 Response
consistent
MMAAJSPS-FU-2
methodology,
with a
under
about:
“[Tjhe basis of worksharing
discounts
for letter and cards” (See Order
No. 1197, page 6)?
(2)
“[Tjhe amount of the costs avoided
categories”
(3)
by the various worksharing
(See Order No. 1197, pages 6-7)?
“[Tjhe cost avoidance
calculations
[for]...rate
category
discounts”
Please supply the workpapers
that support the Service’s
October
21 Response
to Order No. 1197, especially
Table II-2 of that Response.
document,
by First-
(See Order No. 1197, page 8)?
MMAIUSPS-FU-8
CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoing
Class Mail, upon the participants
October 23, 1997
in this proceeding.