DOCKET SECTION
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
POSTAL RATE AND FEE CHANGES,
1997
Docket No. R97-1
RESPONSES OF THE UNITED STATES POSTAL SERVICE
TO INTERROGATORIES
OF NASHUA, DISTRICT, MYSTIC & SEATTLE
(NDMSIUSPS-T27-2b&c,
3,4b&c)
The United States Postal Service hereby files its responses to the following
interrogatories
of Nashua, District, Mystic & Seattle, dated August 29, 1997, 1997:
NDMS/USPS-T27-2b&c,
The interrogatories
3,4b&c and 5a-d
are stated verbatim and are followed by the responses
A motion for late acceptance of these responses has been filed in connection
with the filing of witness Schenk’s responses to NDMS/USPS-T27-1,
2a, 4a and 5.
Respectfully submitted,
UNITED STATES POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
h.A ,I&2&&
Michael T. Tidwell
475 L’Enfant Plaza West, SW.
Washington, D.C. 20260-l 137
(202)268-2998/FAX:
-5402
September 30, 1997
RESPONSE OF THE UNITED STATES POSTAL SERVICE TO NDMS
INTERROGATORY
REDIRECTED FROM WITNESS SCHENK
NDMSIUSPS-T27-2.
b.
c.
In Base Year 1996, how many facilities
used automated
BRMAS equipment
to
process ERM paying the BRMAS rate?
In Test Year After Rates, how many facilities
were expected
to process BRM on
automated
BRMAS equipment?
RESPONSE:
b. and c.
Although
believed
that the overwhelming
software
when
This would
witness
which
what
no comprehensive
appear
Schenk
could
the program
empirical
majority
be expected
it may currently
be
of facilities
was implemented
to be confirmed
in USPST27.
survey
to improve
expected
it is
to use BRMAS
did not do so in the base year.
by the BRMAS
The Postal
has been conducted,
Service
the coverage
coverage
factor
has not developed
factor
developed
any plans
in the test year above
by
RESPONSE OF THE UNITED STATES POSTAL SERVICE TO NDMS
INTERROGATORY
REDIRECTED FROM WlTNEsS
SCHENK
NDMSIUSPS-T27-3.
For a P&DC that has the capability
to run BRMAS on its automated
equipment,
what is the estimated
minimum daily volume of automatable
BRM below which it is
more practical to send all BRM to the postage due unit rather than use BRMAS?
To
the extent that the minimum
daily volume may vary by location,
please explain all
important
factors that would enter into the decision to prefer use of the postage
due unit rather than BRMAS.
RESPONSE:
It is not possible
to provide
an estimate
facilities
of a minimum
practical
to send all ERM to the postage
determination
of whether
or in a manual
sortation
makeup
operation
and the number
equipment,
during
the time
institutional
of automatable
be applicable
is going to depend
when
on many
factors,
of different
of Information
The
operation
including
to ensure
Systems
the
BRM
has), the availability
BRM has to be processed
factors.
it is more
BRM in a BRMAS
each recipient
the availability
and site-specific
which
than use BRMAS.
at a site (e.g., the number
frame
for all Postal
BRM below
due unit rather
of separations
to the mail recipient,
well as other
would
to sort and rate automatable
of the BRM recipients
recipients
delivery
daily volume
that
support,
of
timely
as
RESPONSE OF THE UNITED STATES POSTAL SERVICE TO NDMS
INTERROGATORY
REDIRECTED
FROM WITNESS
SCHENK
NDMSIUSPS-T27-4.
b.
c.
What are the major reasons why the BRMAS coverage
factor has never reached
the levels anticipated
by the Postal Service in Docket No. R90-1 ?
What sense does it make to have a “BRMAS
Program”
when the coverage
factor is less than 6 percent, and declining?
RESPONSE:
b.
In Docket No. R94-1, the Postal Service offered, but was not permitted, to enter into
evidence its analysis of major reasons why the BRhUS coverage factor fell short of
expectations. Many of the reasons why BRMAS did not perform up to expectations by
1994 still apply today. A copy of the pertinent portlon of the aforementioned analysis is
attached.
C.
The current state of the BRMAS program presents a challenge for management. It is
hoped &at the outcome of the Postal Service’s QBRM proposal will help set the course
for the future.
II. Current
Operational
A. Integration
The BRMAS
of BRMAS
software
Sorter (DBCS)
Status
of BRMAS
- Chances
system
Docket
No. R90-1
With Bar Code Sorters.
has been placed on the MPBCS
operating
Since
computers.
and Delivery
This enables
Bar Code
Processing
to use any
bar code sorter to count and rate BRMAS mail oieces.
6
Integrating
the BRMAS
software
into the bar code sorter operating
7
also result in combining
BRMAS
sortation.
a
operations,
9
Consequently,
such as Incoming
10
eliminated.
11
and BRMAS.
Primary
counting
or Incoming
the unique MODS operations
The result has been shared volume
allocated
recording
distribution.
solely to BRMAS
for automated
The lack of the ability to easily monitor the volume
Mail (BRM) processed
13
processing
.I4
the program.
'I 5
While the availability
16
encourage
17
opposite
outcome
18
BRMAS
mailpieces
19
already
using the BRMAS programs
plants, may have contributed
of BRMAS
the use of the BRMAS
assigned
has resulted,
on a separate,
and provide feedback
software
it now appears
Most sites that utilize BRMAS
unique sort program.
a variety of BRMAS
customers
Reply
to
expansion
on all bar code sorters was expected
program,
was
distribution
of Business
to the slower than expected
software
may
and ratincj with other automated
Secondary
number
systems
of
to
that the
continue
This is because
to process
they have
to the same 5-Digit BRMAS
ZIP
1
Code, and addltional
software
3
support
workhours
are required
to maintain
the BRMAS
when it is placed on more than one bar code sorter.
B. Da,tabase/Software
Maintenance
4
Inaccurate
5
and kept current.
6
assIgnIng
new BRMAS bar codes to reflect the use of postcards
as well as letters,
7
removing
customers
bar code sorter
a
sort programs
9
affect the counting
10
In-Plant
RRM billing occurs when BRMAS customer
to customer
account
that drop out of the program,
to reflect seasonal
Support
processrng
Modifications
changes
information
is not maintained
characteristics.
and modifying
in volume
are examples
such as
of data that may
and rating process.
personnel
procedures,
of the BRMAS
are required
to develop
as well as continually
update the office and processing
7.2
versions
13
operational
14
opportunities,
15
maintenance.?
‘I 6
‘I 7
10
2’ As indicated above, updating BFLMAS software is cot simply loading a new software version.
Rather, it requires obtaining BRh4 customer information on a regular basis from sources
separate fTom the In-Plant Suppon function, such as Finance and Marketing.
environment,
software.
new sort plans, mail flows and
including
With the recent changes
re-prioritization
there are fewer resources
of potential
available
for database
6
~__
in organization
cost
and the
reduction
and software
~&uLbw-+ +- *‘f-y.
to VJDrnL/ubPJ-Tz-bq
P’bc‘L
--
----
C. Manual
Many BRMAS
Counting
customers
are in fact agents for clients selling a product.
3
Indirect communication
(through
,4
the client may at times cause the client to believe their new BRMAS
5
a new ZIP Code for all of their correspondence.
6
mailpreces
7
used to count and rate mailpieces.
8
manually
9
appropriate
to be sorted and counted
recount
these “problem”
postage
Initially, as is frequently
11
had several
software
non-BRMAS
mailpieces
if BRMAS
software
Consequently,
is
many sites have chosen to
BRMAS separations
the situation
to assure that the
when any new software
“bugs” which sometlmes
affected
‘I4
count.
15
counts are still performed
by BRMAS sites to assure
16
bills.
customers
17
a stamp or meter imprint
18
reimbursed
19
through
20
the Postal Service
and chose to manually
While these software
BRMAS
verii
which the customer
sometimes
applied to those pieces.
presents
performs
postage
counts
short time. manual
re-
of the customers’
that BRMAS
pieces to which
so that they can be
While there is a procedure
paid mailpieces
these manual
of mailpiece
of the mailpiece
the accuracy
request
BRMAS
in automated
the accuracy
have been affixed be counted
for the postage
the accuracy
bugs were fixed in a relatively
frequently
is developed,
lost confidence
provided
-
bar code is also
causes
‘I 3
In addition,
and
This situation
wtth BRMAS
As a result, some sites and customers
by BRMAS,
the Postal Service
is charged.
10
counts.
the BRMAS agent) between
This
for reimbursement,
counts as a customer
service.
D. Incompatibility
of Equipment
2
The Postal Service contracted
3
(DBCSs).
4
(MMC) were each awarded
5
machme
6
accuracy.
7
MMC In modifying
8
These basic operating
9
plan formafs
for two different
IElectrocom AutomatIon
for 614 DBCSs.“’
did not live up to performance
software
problems
the MMC DBCS software.
11
Service bar code sorters,
12
DBCS software
While BRMAS
Delivery
combined
the MMC
in order to assist
with constant
changes
BRMAS
is now resident
interface
Corporation
Point Sequencing
the Postal Service’s
software
Bar Code Sorters
in the area of sortation
from other projects
it does not currently
and therefore
However,
especially
to accommodate
made it difficult to integrate
10
standards,
were diverted
their sofhvare
types of Delivery
Ltd. (ECA) and Martin Marietta
contracts
Postal resources
with BRMAS
effectively
(DPS).
in sort
software
with
on all Postal
with the MMC
cannot be used to count and rate BRMAS
mailpieces.
13
E. Insufficient
14
FY 1993 billing determinants
15
per customer
16
produce
17
18
z’ This 1,228 DBCS procurement was designated Phase I. ECA was awarded the entire Phase
II DBCS contract based on their superior performance in Phze I.
19
20
21
2’ 665,010,200 divided by 64,244 BRMAS accounts (assuming half of the BRM advance
deposit accounts are for BRh4AS) divided by 312 days per year (6 days a week) = 33.18 pieces
per account/day. See W/p I of wimess Foster, section D, page L-2.
22
23
24
6’ Many BRMAS customers’ volumes change significantly based upon seasonal renewals for
publication :subscriptions or special promotions. Therefore, average daily volumes are not
(continued...)
Volumes
indicate that the average
per day is relatively
a further
reduction
low.’
Seasonal
number
fluctuations
of BRMAS
pieces
in BRM volumes
in volume for some days.6-’ Sites may not choose
to
1
repeatedly
change therr distribution,
BRMAS customer
3
counting
4
As plants developed
5
sorter stackers
6
generation
7
actually
a
and billing system
9
In some cases,
.I0
volume
of BRMAS
fluctuates.
counting
and rating procedures
Instead these sites would use manual
mailpieces.
BRMAS
received
processz,
sort programs
minimal
combined
volumes.
they discovered
Consequently,
be counted,
that many bar code
the BRMAS
with the time used to process
took longer and used more resources
outs” cannot
as individual
BRMAS
than did the manual
report
mail pieces,
sorting,
counting,
used prior to BRMAS implementation.
BRMAS volumes
be justifiedc’.
are so low that separate
In addition,
manually
rated and billed, so that both manual
bar code sorter “hold
sorted BRMAS?’ pieces must still
and automated
bills must be
l2
combined.
713
II4
115
il 6
6’ (...continued)
representative of the seasonal low volume periods. These low volume periods may not warrant
a bar code sorter separation. This situation would result in manual counting and rating part
of the year and BRMAS counting and rating another part of the year.
‘I 7
11a
19
1’ BRMAS produces a one page “bill” for each customer. This process takes considerable time
(30 seconds to one minute). Therefore, a sort program with fifty customers receiving 20 pieces
per customer may take over one-half an hour for report generation.
;!o
;!l
22
p Volume analysis is performed by local In-Plant Support operations to determine the most
efficient manner in which to develop sort plans. This analysis is performed due to the limited
number of stackers on bar code sorters and efforts to reduce unnecessary rehandlings.
z’ Even though BRMAS pieces are barcoded, rejected, jammed, and damaged mailpieces must
be sorted, counted and rated manually.
23
;!4
F. Administrative
Issues
L
As is the case with any nationwrde
3
based overslght
4
the programs
5
program
6
programs,
7
management.
Ei
However,
9
by recent organizational
approach
combined
Initially, considerable
matured
these resources
national
program
the management
10
changing
operational
11
centered
around
2
postal project,
and delivering
decreased,
management
changes
the potential
the mail.
to support
However,
Typically
transferred
as the
in srmilar
to local
may have been affected
of priorities
along with the
used to allocate limited resources
“pay back” and efficiencies
to be gained
in processing
One result was less focus on BRMAS at the national
as with other programs,
14
level.
15
their operations
16
modify certain
1’7
operating
18
how to use E3RMAS. The results appears
19
BRMAS.
this approach
management
of ERMAS was moved
gave field managers
than those managers
conditions.
is eventually
The process
Moreover,
aspects
as expected.
process for BRMAS
13
In theory,
implementation
were expended.
and the evolution
environment.
used a Headquarters-
with field (Regional)
resources
transttion
BRMAS
far removed
of the BRMAS program
from the mail) greater
more discretion
to have been reduced
10
---
to the plant
(who have better knowledge
to accommodate
It also gave field managers
level.
-__
specific
of
flexibility
to
local
in whether
implementation
and
of
G. Relation
At the inception
to Other
Automation
of the BRMAS
program
3
place after incomrng
secondary
4
dedicated
5
separations
6
firm/BRM
7
sector/segment
8
first to a part of the Box section,
9
is “street”
bar code s0rter.c’
BRMAS
rnail.
BRM processing
primary,
upon local conditions,
incoming
took
secondary,
BRMAS
on a
BRM
‘Box, or special
BRM sorted to a large Box section may require
using a “two pass” sort program
and then to a particular
and would need to be Delivery
BRMAS
generally
for other mail had been completed
Now, depending
sequencing
delivered,
BRMAS
operations
may occur on Incoming
sort programs.
Programs
BRM may be separated
in order to be sorted
Box.. Some BRMAS
Point Sequenced
with the rest of
10
the carrier’s
1I
if the secondary
12
pulled out on the second
13
The implementation
1,4
the volume
15
that this proc:essing
16
mail to the carrier route level, two “passes”
17
sequence
18
processing
19
BRMAS
20
ill
212
!? Most automated incoming secondary operations were completed between 6:30 a.m. and 7:04
a.m. MOST BRMAS processing immediately follotied this secondary processing and was
completed in order to meet BOX or caller service clearance times (8:00 am. to 9:00 am.).
zone is receiving
window
Point Sequencing
automated
is performed.
for the carrier.
“two pass” processing,
BRMAS
secondary
level;
BRM may be
pass.
of Delivery
that requires
at the incoming
BRM
incoming
processing
as well as the time of day
Instead of one bar code sorter “pass” to distrjbute
This additional
and encroached
(DPS) has had a major impact on
are needed
pass expanded
to sort mailpieces
the incoming
into the same operational
window
in delivery
secondary
in which
was being processed,
Later marl arrival trmes at the delivery
elimrnation
unit were made possible
of carrier casing time resulting
3
reduction
of earner casing time will enable
4
carrier in-office
5
Accordingly,
6
favor of Delivery
workhours
from the sequencing
delivery
and assert greater
many sites have chosen
Point Sequencrng
by the reduction
of this mail.
oftices -to significantly
control over labor-related
to eliminate
and its potential
automated
ERMAS
for cost reductions.
or
The
reduce
costs.
processing
in
RESPONSE OF THE UNITED STATES POSTAL SERVICE TO NDMS
INTERROGATORY
REDIRECTED
FROM WITNESS
SCHENK
NDMS/USPS-T27-5.
Your testimony
at p. 13 states that “a new BRMAS program is expected
to be I”
place during the test year.”
a. What is the new BRMAS program?
Please provide a brief explanation
and
submit a copy of the program as a library reference.
b. When is implementation
of the new BRMAS program expected
to begin. and
when is full implementation
expected
to be accomplished?
c. How does the new BRMAS program differ from the old BRMAS program?
d. What is 1:he expected
effect of the new BRMAS program on the BRMAS
coverage
factor?
RESPONSE:
(a-d)
There is no new BRMAS program. No timetable is available for the development of a
new program.
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the foregoing document upon all
participants of record in this proceeding in accordance with section 12 of the Rules of
Practice.
/
Michael T. Tidwell
475 L’Enfant Plaza West, S.W.
Washington, 1D.C. 20260-I 145
September 30, 1997