BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
POSTAL RATE AND FEE CHANGES,
1997
FIECEIVELI
SEP 16
12 09 PM ‘9’1
Docket No. R97-1
)
THIRD SET OF INTERROGATORIES
OF MAJOR MAILERS ASSOCIATION
TO UNITED STATES POSTAL SERVICE WITNESS
PHILIP A. HATFIELD (USPS-T-25)
Major Mailers Association
following
interrogatories
Practice
and Procedure.
follow the General
Interrogatories
accordance
pursuant to Rules 25 and 26 of the Commission’s
In answering
lixtructions
to this witness.
with General
these interrogatories,
the witness
that are set forth in the Attachment
Requests
Instructions
respond to any interrogatory,
another
asks the United States Postal Service to answer the
for data or documents
G and H. If the designated
are to be interpreted
witnlsss is unable to
the Postal Service is asked to redirect the question
Respectfully
submitted,
MAILERS
ASSOCIATION
Suite 400
Washington, DC 20036
Phone: (202) 466-8260
.---~
16, ‘I 997
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is requested
__
.-
to
to iihe First Set of
Postal Service witness who can answer it.
September
Rules of
to
in
MMA INTERROGATORIES
TO USPS WITNESS
(Philip A. Hatfield: Set Three)
MMAIUSPS-T25-12.
In response
to MMNUSPS-T25-2
lower throughputs
on automated
you state that “heavier
equipment
pieces may lead to
and cause more jams and damage.”
A) What is the basis for this conclusion?
B) What do you mean by “heavier”
measurement?
pieces in terms of an actual weight
Please support your answer.
MMAIUSPS-T25-13.
In response
l:o MMANSPS-T253(E)
costs were 100% variable
processing
in your cost models.
costs would increase.
cost differences
you note that if you had assumed
that labor
it is likely that the unit mail
You do not, however,
agree that the computed
would increase.
A) Isn’t it absolutely
true that if you were to assume
that labor costs were
100% variable in you models. the unit costs would incre,ase?
B) Do you agree given the nature of the mathematical
comprise
your cost models,
between
the unit costs would also increase?
c:omputations
that
it is more than likely that the differences
Please explain any no
answer.
C) Please explain how an intervenor
reproduce
in this proceeding
your cost models under the assumption
can
that labor costs are
100% variable.’
MMAIUSPS-T25-14.,
In response
MPBCS
to MMANSPS-T25-4
OSS operation.
you provide the reasons for rejects from the
Please confirm that none of the problems
provided
can
be directly tied to the weight of a letter.
MMAIUSPS-T25-15
Please refer to your response
to MMANSPS-T25-5
A) Please confirm that it is the unrt cost differences
cost models (between
benchmarks
discussed
the various presort/automation
categories
by witness Fronk (see his response
T32-2(ID)), that are the bases for the proposed
presort/automation
that you derive in your
discounts
and the
to ABANSPS-
First-Clasis
in this proceeding.
If you cannot confirm,
please explain
B) Please confirm that the specific changes
requirements
that were implemented
taken specrfically
into account
in mail preparation
after re-classification
in your cost models.
and entry
are in no way
If you cannot confirm,
please explain
C) Please confirm that the specific changes
1
in mail preplaration
and entry
Recogizing the Presiding Officer has not yet ruled on MMA’s September 8
Marion LOCompel, MM.4 is agreeable TOhaving the Postal Service defer its Response or
Ohjecrion IO Subpan (0 orthis Interrogatory until the Presiding Officer rule:;.
2
requirements
account
that were implemented
by the Postal Service,
determrnation
after rates.
after re-classification
are taken into
as far as you know, in thle
of the volume variable costs for the test year before and
If you cannot confirm, please explain.
D) In part D) to your answer you indicate that you believe that your
methodology
preparation
does take into account
costs.
Compared
differences
to the mail preparation
required to process single piece stamped
methodology
provide?
in mail
costs
mail, doesn’t your
omit any cost savings that presorted
letters
Please explain any no answer?
MMAIUSPS-TX-16.
Please refer to your response to MMNUSPS-TZH(C).
There you note that
your models do take into account the stricter address
been implemented
for First-Class
Automation
that have
mail since re-classification.
A) Isn’t it true that as a result of re-classification,
Class Automation
requirements
the addresses
mail are required to be more accurate
for First-
and current?
Please explarn any no answer.
6) Isn’t it true that more accurate
fewer pieces being forwarded
and current addresses, will result in
and returned?
Please explain any no
answer.
C) Please confirm that any cost savings due to reduced
forwarding
and return of First-Class
stncter address requrrements
Automation
letters, r#esulting from the
that were Implemented
since re-
classificatron,
are not taken into account
in your cost mo’dels.
cannot confirm, please explain and provrde data showing
value given to those savings in you testimony
If you
the numerical
and exhibits.
MMAIUSPS-T25-17,.
Please refer to your response
to MMNUSPS-T25-8(D).
A) Do you agree that there are cost savings associated
requirement
that reply envelopes
Automation
outgoing
compatible?
included with First-Class
letters be pre-barcoded
and automation-
Please explain any no answer.
6) Since your testimony
does not estimate these cost savings,
confirm that any cost savings due to the requirement
envelopes
from the new
included with First-Class
and automatron-compatible.
are not taken into account
Automation
that all reply
letters tte pre-barcoded
that was implemented
in your cost models.
since re-classification,
If you cannot confirm,
please explain and provide data showing the numerical
sLrch savings in your testimony
please
value grven to
and exhibits.
C) Is it your posrtion that these cost savings be creditecl to First-Class
single piece maulers rather than First-Class
automation
explarn.
(End of thus set of Interrogatories)
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mailers?
Please
CERTIFICATE
OF SERVICE
I hereby certify that 1 have this day served the foregoing documenr, by First-Class Maii,
upon the participants requesting such serwce m this proceedmg.
September 16, I997