BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
POSTAL RATE AND FEE CHANGES,
1997
)
1
@CEIVE~)
JEP /ii
12 o8 p,q y7
Docket No. R97-1
FIRST SET OF INSTITUTIONAL INTERROGATORlEiS
OF MAJOR MAILERS ASSOCIATION
‘TO THE UNITED STATES POSTAL SERVICE
Major Mailers Association asks the United States Postal Service to answer the
following interrogatories
pursuant to Rules 25 and 26 of the Commission’s
Practice and Procedure. In answering these interrogatories,
the Service is requested to
follow the General Instructions that are set forth in Attachment
to its witnesses.
Rules of
1 to pri’or interrogatories
Requests for data or documents are to be interpreted
in accordance
with General Instructions G and H. The Postal Service is asked to direct the question
to any Postal Service official who can answer it
Respectfully submitted,
M-MAILERS
ASSOCIATION
1226 Nineteenth St. N.W
Suite 400
Washington, DC 20036
Phone: (202) 466-8260
September
16. 1997
MMA INSTITUTIONAL
INTERROGATORIES
( Set One)
TO USPS
MMAIUSPS-INST-1
Please confirm that, as reported in the December 1995 article from the AMMA
Bulletin 52-95 (attached hereto). Deputy Postmaster General Michael Coughlin
told AMMA that the Postal Service was pleased with the results; of tests it has
been conducting with a group of AMMA-member
weighing up to 3.5 ounces.
companies involving pieces
If you cannot confirm, please explalin why and state
the Postal Service’s policy about the maximum permissible weight for
automation-rated
letters.
MMAIUSPS-INST-2
Please confirm that, as reported in the December 1995 article from the AMMA
Bulletin 52-95 (attached hereto), the Postal Service announced1 in late 1995 that
it had approved AMMA’s request to increase the maximum permissible weight
for automation-rated
letters above the then-present
3.0 ounces.
If you cannot
confirm, please explain why and state the Postal Service’s policy about the
maximum permissible weight for automation-rated
letters.
MMAIUSPS-INST-3
Has the Postal Service taken the steps necessarrly to implement a higher weight
limit for Standard Mail A automation letters on a permanent barsis? If yes, please
explain.
If no, why not?
MMAIUSPS-INST-4
Q) Please refer to your answer to MMAkJSPS-T32-24
(B). There you
indicate that the unit cost derived for First-Class Single Piece letters
includes ,the cost pool for mail preparation
and acceptance,
including
culling, facing and canceling stamped mail. Please state precisely in LR-H-106
where that cost pool is shown as being included for First-Class single piece
letters.
MMAIUSPS-INST-5
Q) Please refer to your answer to MMAfUSPS-T32-25(D)
witness Hatfield’s answer to MMAAJSPS-T253(E).
and USPS
If the Commission finds that
labor processing costs are 100% variable with volume, do you agree that the
difference between the unit costs for First-Class single piece letters and FirstClass presorted letters will increase in similar fashion as the unit costs derived by
USPS witness Hayfield in his cost models.
If not, please explain.
MMAIUSPS-6
In answer to NDMSAJSPS-T32-29
Class single piece nonstandard
surcharge.
you estimate the percentage
of BY 1996 First-
letters that have paid the nonstandard
Please estimate the number of First-Class single pke
2-ounce
letters that have paid 32 cents for the second ounce (total postage of 64 cents)
in BY 1996.
(End of this set of interrogatories)
--.
---
CERTIFICATE OF SERVICE
I hereby certify that I have this day served the foregomg documem, by First-Class Mal,
upon the participants requestmg such service in this proceeding
September
16, 1997
ATTACNNENT
1
I?age 1 of 3
GENERAL
If
A.
Request
for
INSTRUCTIONS
the witness
Production
respond,
the
question
or request
answer
the
Service
p0sitio.n
with
promptly
it
should
If
by facsimile
the
who can
the Postal
can respond
is asked to advise
to
redirect
witness
request.
witnesses
or
is unable
Service
the
none of its
or Request,
lawyers
Postal
or comply
Interrogatory
is directed
or her
to another
that
Interrogatory
its
and his
question
INTERROGATORIES
to whom a particular
of Documents
witness
believes
FOR ANSWERING
to an
MMA counsel
message to Telecopy
of
Number
202-293-437’7.
B.
1:n interpreting
Request
for
Production
hypertechnical
what
is not worded
but
available,
other,
could
somewhat
use in
lieu
providing
C.
Documents
previously
if
or know about
If
will
know about
information
the
for
the
requests
supplied
that
the
that
party
information
this
an
is not
the
availability
of
the
requesting
party
In such cases,
the
of Request
requesting
the
party
inquiry
more
information.
or Request
that
that
had phrased
the available
or
Similarly,
Interrogatory
that
to ascertain
Interrogatory
information.
information
Interrogatory
in
the
or
be
able
or correctly.
asked to interpret
have asked
is often
even if
of the unavailable
generously,
do not
may seek information
different
is
precisely
precisely
the witness
the witness
would
sought
or Request
please
A witness
is being
Interrogatory
of an Interrogatory
of Documents,
or grudging.
information
Request
the wording
the
proceeding,
for
Production
Postal
Service
please
state
of
has
and identify
ATTACENENT 1
Page
the document
any
in which
Library
References
information
relevant
relevant
to the
Production
E.
the
to the
that
provide
response
clippings,
tabulations,
studies,
recorded,
all
"workpapers"
prepared
manually,
all
that
are
or Request
replication
for
limited
explanatory
of the
arithmetic
newspaper
by whatever
together
with
means
any
or use such documents.
prices,
with
letters,
pamphlets,
back-up
the witness
Production,
to:
material,
or electronically,
of costs,
by or for
together
is not
to understand
mechanically
created
or Request
and workpapers
includes
calculations
testimony,
workpapers
or transmitted,
necessary
The term
analyses
contain
or Request.
testimonies,
drafts
stored
material
the
Identify
to an Interrogatory
but
includes,
reports,
written
3
of Documents.
"documents"
created,
also
Interrogatory
should
witness'
memoranda,
permit
was provided.
As used in an Interrogatory
term
forth
information
and Workpapers
The witness
D.
for
that
2 of
whether
and should
rates
or statistical
in preparing
information
steps
set
his
sufficient
depicted
to
in such
workpapers.
In referring
F.
title,
author,
should
cite
testimony
location
publisher
and,
telephone
G.
the request
and date
page and line,
filed
in this
if
if
When a witness
the
complete
the document
state
identity,
is
the document's
location
and
custodian.
is asked to provide
be interpreted
the
References
Unless
please
proceeding,
not published,
cite
of publication.
possible.
number of the document's
should
please
to a document,
as asking
data
for
or a document,
information
that
ATTACENENT 1
Page 3 of 3
is available
about
to the
or has the
determining
within
Officer's
which
it
16,
provide
that
doing
party
the
is expected
of the
Postal
In the
Service
make analyses,
principles
Rules
the Postal
Service
in Presiding
and other
Commission
W's
discovery
requests
objections
to Compel.)
provide
doing
the
In the
information
so would
expected
event
Commission's
the
be an unreasonable
to make the
Rules
showing
of Practice
the
party
party
the
in
does
believes
requested
under
Rule
25(c)
requires
the
to perform
research
or to
to comply
Ruling
NO. R94-l/18
to compel
and the
Federal
to Postal
the
(pp.
and Procedure.
Postal
decisions
Service's
believes
requested
Rule
Motion
does not
party
the
under
court
party
the requested
burden,
with
No. R94-1 concerning
requested
required
both
request
in Docket
1994 Response
because
requested
in
and June
to Compel,
required
(See also
that
cited
Response
is requested
and motions
thereto.
in MMA's June 16,
authorities
burden,
is
Presiding
requested
Officer's
Orders
Presiding
and Procedure.
answering
information,
5-6)
cited
showing
to compile
stated
Service's
the
of Practice
that
event
Commission's
"The available
the
In
Postal
that:
an unreasonable
to make the
Commissionfs
H.
because
burden.
the
Motion
that
knows
follow
Leave to File
event
information
be
25 of the
(See also
Service's
In the
,so would
6),
to the
p. 5; legal
for
to Postal
No. R94-1.)
not
(p.
No. R94-l/38,
1994 Response
Docket
should
witness
reasonable
"available"
to obtain."
11994 Request
the
without
of Section
No. R94-l/18
is possible
MMA~s May 10,
is
the witness
Ruling
and that
to locate
the meaning
Ruling
Officer's
.
ability
of Practice,
that
Service
wh,at information
Service,
Rules
Postal
25(c)
party
of the
that
is