RECEIVELI
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
POSTAL RATE AND FEE CHANGES, 1997
SEP 2
Docket
i
4 59 PM '9'1
No.
R97-1
THE DIRECT MARKETING ASSOCIATION,
INC.'S
SEClOND SET OF
INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOC!UMENTS DIRECTED
TO USPS WITNESS CRUU (DMAfUSPS-T28-lo-,181
Pursuant
Rules
of
submits
for
Practice,
the
attached
production
10-18).
of
If
the
to
Sections
the
Direct
second
documents
designated
we request
interrogatory,
25 and 26 of
Marketing
set
to
of
Inc.
interrogatories
is
a response
Commission's
Association,
USPS witness
witness
the
and requests
Crum
to
unable
hereby
(DMA/USPS-T28respond
by some other
to
this
qualified
witness.
Respectfully
submitted,
/
Dana T.
David L. MeyerMichael
D. Bergman
COVINGTON & BURLING
1201 Pennsylvania
Avenue,
20004
Washington,
D.C.
(202) 662-5296
Counsel
for the
Association,
September
2,
-
1997
Direct
Inc.
N.W.
Marketing
2
Witness
Crum
(USPS-T-26)
DMA/USPS-T28-10.
Please provide
the number of direct
mail
tallies
for Standard
(A) nonletter,
nonflat
pieces
individually
for each subclass
and each year from 1990-1996.
DMA/USPS-T28-11.
direct
mail
tally
Codes Questions
For each Standard
(A) nonletter,
from 1990-1996,
please
provide
18 A-G and 19.
nonflat
piece
the responses
to
DMA/USPS-T28-12.
Ignoring
mail characteristics
related
to depth
of sort,
depth of entry,
and weight,
are there
characteristics
of
nonletter,
nonflat
pieces
that would result
in lower
than average
mail processing
costs?
Please
respond
in as much detail
as
possible.
a.
All
else being
(equal,
should
the cost ofi processing
a
machinable
nonletter,
nonflat
piece be l.ower than the
cost of processing
a nonmachinable
nonletter,
nonflat
piece?
Please
(explain
your response
ful.ly.
b.
All
else being
equal,
should
the cost ofi processing
a
(in volume)
machinable
nonletter,
nonflat
piece
be lower
than the cost of processing
a large
(in
volume)
machinable
nonletter,
nonflat
piece?
Please
explain
your response
fully.
small
C.
All
else being
equal,
should
the cost of processing
nonflat
piece
be lower
sturdy
machinable
nonletter,
a similar
piece
that
is
than the cost of processing
sturdy?
Please
explain
your response
fully.
a
not
DMA/USPS-T28-13.
Please
confirm
that
the analysis
presented
in
your direct
testimony
does not rule
out the possibility
that
an
nonflat
piece
in a specific
rate category
individual
nonletter,
could
have the same unit
attributable
cost as all
flats
in that
rate
category.
Please
confirm
that
the analysis
presented
in
DMA/USPS-T28-14.
your testimony
does not rule
out the possibility
that
a specific
nonflat
pieces
in a specific
rate
category
type of nonletter,
could
have the same unit
attributable
cost as all
flats
in that
rate
category.
Please
refer
to page 11, line
10, of your
DMA/USPS-T28-15.
"[sleveral
studies
supply
direct
testimony
where you state
that
please
summarize
and produce
(as
additional
data as necessary."
a library
reference)
the studies
to which YOU referred.
DMA/USPS-T28-16.
as ~~-pC&50
in
Please
confirm
that,
~~97-2
and the studies
other
than
referenced
the study
filed
in your direct
3
tesl:imony
in R97-1 regarding
weight,
depth
entry,
the Postal
Service
has not performed
cost-causing
characteristics
of nonletter,
not confirmed,
please
summarize
and produce
reference)
such studies.
of sort
and depth of
any studies
of the
nonflat
pieces.
If
(as a library
DMA,/USPS-T20-17.
Please
refer
to page 11, lines
1.6-17, of your
direct
testimony
in which you state
that
you "combine[d]
Regular
and Enhanced
Carrier
Route as well as Regular
Rate and Nonprofit
costs
and volumes"
for your analysis.
Please
clarify
what types
of mail are included
in your "Regular
Rate" category
if different
than Standard
(A) Regular
mail.
DMA/USPS-T28-18.
Please
refer
to your response
to DMA/USPS-T28Please
provide
the pe'rcentage
of mailing
statements
that
were
4.
"corrected
upon verification"
and the reasons
that
such
statements
were corrected.
-
---
-.
4
CERTIFICATE
foregoing
proceeding
Postal
3 of
I hereby
certify
document
upon
in
Rate
the
accordance
Commission’s
Commission's
proceeding.
September
2,
1997
that
all
I have
this
participants
with
Rules
Special
OF SERVICE
Rule
date
of
12
served
record
(section
in
3001.12)
of
Practice
and Procedure
Rules
of
in
Practice
this
the
this
of
the
and Rule