lluc12355PH’97
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C.
20268-0001
POSTAL RATE COMHlSSiO,,
OFFlCEOi THESECRETARy
POSTAL RATE AND FEE CHANGES, 1997
Docket
No.
R97-1
THE DIRECT MARKETING ASSOCIATION,
INC.'S
FIRST SET OF
INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOClJ?.¶ENTS
DIRECTED TO USPS WITNESS CRUM
(DMA/USPS-TZS-l-9)
Pursuant
of
Practice,
submits
the
production
9)
If
Sections
the
Direct
attached
of
the
to
and 26 of
Marketing
designated
we request
to
Commission's
Inc.
and requests
USPS witness
witness
the
Association,
interrogatories
documents
interrogatory,
25
is
Crum
unable
a response
to
Rules
hereby
for
(DMA/LJSPS-T28-lrespond
by some other
to
any
qualified
witness.
Respectfully
submitted,
David L. Meyer
Michael
D. Bergman
COVINGTON & BURLING
1201 Pennsylvania
Avenue,
20004
Washington,
D.C.
(202) 662-5296
Counsel
for the
Association,
August
-.-
12,
1997
Direct
Inc.
N.W.
Marketing
- 2 WITNESS CRUN (USPS T-28)
DMA/USPS -I T28-1.
Please
refer
to
Table
1 on page
6 of
LR-H-108.
(a)
Please
provide
similar
data for FY 1993, FY 1994,
and FY 1995 showing
PERMIT estimates
of revenue,
pieces,
and weights
for letters,
flats,
and IPPs and
parcels
for Standard
A Bulk Regular
Rate mail.
(b)
Please
provide
estimates
of revenue,
pieces,
and
weights,
controlled
to GFY RPW totals
for letters,
flats,
and IPPs and Parcels
for FY 1993, FY 1994 and
FY 1995.
Cc)
Using the data provided
in this
confirm
that
the average
weight
pounds.
If you cannot
confirm,
correct
average
weight
for flats.
(d)
table,
please
Using the data provided
in this
confirm
that
the average
weight
of parcels
is
pounds.
If you cannot
confirm,
please
provide
correct
average
weight
for parcels.
Table,
please
of flats
is .2
please
provide
the
.5
the
DMA/USPS-T28-2.
Please
refer
to page 9 of your direct
testimony
concerning
cost differences
for IPPs and Parcels
in
MC97-2 (USPS-T-71
in which you stated
that
"[blecause
the
volume of Carrier
Route parcels
is much lower
than flats,
I
feared
that
the results
might vary from year to year.
To
check for such variations,
I looked
at three
years
of data."
(a)
Did you
testimony
have
in
similar
fears
this
case?
(b)
If your answer to
check for variations
of data?
If yes,
(cl
If your answer to sub-part
explain
what had transpired
your direct
testimonies
in
such fears.
while
preparing
your
sub-part
(a) is "yes!,"
did you
by analyzing
additional
years
please
provide
your findings.
(a) is "no,"
please
between
the filings
MC97-2 and R97-1 to
of
allay
Please
refer
to page 9 of your direct
DMA/USPS-T28-3.
in which you stated
that
testimony
in MC97-2 (USPS-T-7),
weight
may have an impact
on cost differences
within
Standard
Mail
(A) nonletters
and that
you analyzed
cost differences
within
the Carrier
Route category
because
you were able to
"isolate
the cost driving
effect
of shape as opposed
to
in your direct
Conversely,
within
that
category.
weight"
testimony
in R97-1
(USPS-T-28)
(page 11, lines
I6-17),
you
"combine[d]
Regular
and Enhanced
Carrier
Route as well
as
- 3 Regular
[your]
Rate and Nonprofit
analysis."
costs
and
volumes
for
of
purposes
(a)
Did you
for all
testimony
(b)
If your answer to sub-part
(a) is "no."
please
explain
why you did not control
for weight
and how
this
absence
of control
affects
your analysis
of
shape-based
cost differences
between
flats
and
parcels
in R9'7-1.
Cc)
If your
explain
similarly
control
Standard
Mail
(A)
in R97-l?
answer to sub-part
how you controlled
for the effect
subclasses
in
ia)
for
is "yes,"
the effect
of weight
your
please
of weight.
DMA/USPS-T20-4.
Please
refer
page 11, lines
5-8,
of your
direct
testimony
(USPS-T-28)
and page 2 of LR-H--l08
in which
you state
that
Standard
Mail
(A) volumes
by shape are "derived
from the Permit/Bravis
system"
which
"recorded
mailing
information
from each bulk mail transaction."
statement
(a)
Describe
in detail
how USPS expected
mailers
to
distinguish
between
"flats,"
"IPPs,"
and "parcels,"
including
without
limitation
the definitions
of
these
categories
that
USPS expected
mailers
to
in filling
out the mailing
statements
employ,
underlying
LR-H-108.
(b)
Please
describe
whether
USPS checked
the accuracy
and reliability
of shape designations
on the mailing
statement
information
underlying
LR-H--108.
Cc)
Please
describe
whether
any penalties
or other
consequences
were imposed on mailers
who incorrectly
classified
IPPs as flats
or flats
as IPPs on the
mailing
statements
underlying
LR-H-108.
(d)
Please
describe
all
steps USPS
determine
that
its
information
categorization
of Standard
(A)
flats
or non-flats
is accurate
Please
DMA/USPS-T28-5.
based on shape applicable
If you
during
FY 1996.
in detail
the nature
of
has taken
to
concerning
the
nonletter
mail
and reliable.
as
confirm
that
there
was no surcharge
to Standard
(A) IPPs or parcels
are unable
to confirm,
please
describe
any such surcharge.
- 4
DMA/USPS-T28-6.
Please
describe
nature
of the activity
underlying
3.la)
separately
for:
(a)
Carrier
Route
flats;
(b)
Carrier
Route
IPPs
Rate
Regular
flats;
(d)
Rate
Regular
IPPs
DMA/USPS-T28-7.
Please
nature
of the activities
labor
and support
costs
the
(C/S
and
and parcels
describe
in a detailed
narrative
underlying
the carrier
"in-office"
(C/S 6.1 and 6.2)
separately
for:
(a)
Carrier
Route
flats;
(b)
Carrier
Route
IPPs
(c)
Bulk
Rate
Regular
flats;
(dl
Bulk
Rate
Regular
IPPs
the
and parcels;
and
and parcels.
DMA/USPS-T28-8.
Please
describe
in
nature
of the activities
underlying
route,
access,
elemental
load,
other
costs
(C/S 7.1,
7.2,
7.3,
7.4,
7.5)
(a)
Carrier
Route
flats;
(b)
Carrier
Route
IPPs
(c)
Bulk
Rate
Regular
flats;
(d)
Bulk
Rate
Regular
IPPs
a detailed
the carrier
load and
separately
narrative
the
"street"
street
support
for:
and parcels;
DNA/USPS-T28-9.
Please
refer
to
Please
provide
similar
LR-H-108.
subclasses
of Standard
Mail
iA)
_----
a detailed
narrative
processing
costs"
"mail
and parcels;
(C) Bulk
Bulk
in
and
and parcels.
Table 3 on pages 8 and 9 of
tables
for each of the
for FY 1996.
- 5
CERTIFICATE
foregoing
I hereby
certify
document
in
accordance
Rules
of
Practice.
Commission's
that
OF SERVICE
I have
this
with
Section
date
served
12 of
,(I [‘(>&W~~
Michael
Dated:
August
12,
1997
D. tirgman
the
the