BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 202680001
POSTAL
RATE AND FEE CHANGES,
1997
)
1
RECEIVE8
AN13
II 54
A/l‘97
Docket No. R97-1
FIRST SET OF INTERROGATORIES
OF MAJOR MAILERS ASSOCIATION
TO UNITED STATES POSTAL SERVICE WITNESS
PETER HUME (USPS-T-18)
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 witness is requested to
follow the General Instructions that are set forth in Attachment
1 to thus document
Requests for data or documents are to be interpreted in accordance
Instructions
interrogatory,
Rules of
with General
G and H. If the designated witness is unable to respond to any
the Postal Service is asked to redirect the question to another Postal
Service witness who can answer it.
Respectfully submitted,
*R
MAILERS ASSOCIATION
F&ard Littell
1220 Nineteenth St. N.W.
Suite 400
Washington, DC 20036
Phone: (202) 466-8260
August 13. 1997
MMA INTERROGATORIES
TO USPS WITNESS
(Peter Hume: Set One)
MMAIUSPS-TlS-1.
On page 6 of USPS-l 8A you show unit delivery costs by category for First-Class
Mail.
(A)
What is the unit delivery cost for First-Class Singk Piece letter-
shaped mail?
(B)
Why do automated letters (3.6 - 3.7 cents) cost ahout .5 cents less
to deliver than carrier route letters (4.1 cents)?
(C)
‘Why do automated letters (3.6 - 3.7 cents) cost albout .5 cents less
to deliver than presorted, non-automated
(D)
letters (4.1 cents)?
‘When estimating unit delivery costs, have you assumed that costs
were attributed using the Postal Service’s costing methodology
proposed in this proceeding,
Commission’s
(E)
as
including all of the changes from the
approved cost methodology?
When letters are sorted to carrier route on autom:ated equipment,
are First-Class and Standard Mail (A) letters ever sorted on the same
barcode sorters?
(F)
If the letters described in Paragraph (E) of the Intterrogatory are ever
sorted together, is that done:
(1)
Rarely?
(2)
Occasionally?
1
(3)
Frequently?
(4)
Regularly?
If you can, please provide an approximate
numerical estimate of the
frequency when the two types of letters are sorted together.
estimate approximation
is sufficient; precision is not required.)
End of Set One Interrogatories,
but please note attached
General Instructions
For Answering)
2
(A best
CERTIFICATE OF SERVICE
I hereby certify that I have this day served the foregoin
document, by First-Class Mail,
upon the participants requesting such serwce in this proceeding
dpkJeffrey Plummer
August 13, 1997
ATTACRMENT 1
Page 1 of 3
GENERAL
A.
If
Request
for
INSTRUCTIONS
the witness
Production
respond,
the
question
or request
answer
witness
believes
Interrogatory
its
and his
position
with
promptly
it
should
Service
witnesses
to
redirect
witness
If
the
who can
the
Postal
can respond
is asked to advise
by facsimile
or
is unable
the request.
none of its
or Request,
lawyers
Postal
or comply
Interrogatory
is directed
or her
to another
that
1NTERROC;ATORIES
to whom a particular
of Documents
the question
Service
FOR ANSWERING
to an
MMA counsel
message to Telecopy
of
Number
202-293-4377.
B.
In interpreting
Request
for
Production
hypertechnical
what
Interrogatory
but
could
the
somewhat
use in
different
lieu
generously,
providing
C.
Documents
previously
for
or know about
If
will
the
requests
supplied
the
know about
information
the
if
often
that
information
that
party
Interrogatory
that
an
is not
the
availability
of
the
requesting
party
In such cases,
the
of Request
requesting
had phrased
the available
or
Similarly,
Interrogatory
that
to ascertain
Interrogatory
information.
the
or
be
able
or correctly.
asked to interpret
have asked
precisely
even if
of the unavailable
is
is
do not
may seek information
witness
the witness
would
sought
precisely
or Request
available,
other,
worded
please
A witness
is being
is not
of an Interrogatory
of Documents,
or grudging.
information
Request
the wording
the
party
inquiry
more
information.
or Request
information
that
the
in this
proceeding,
for
Production
Postal
Service
please
state
of
has
and identify
ATTACHMENT 1
Page 2 of 3
the document
in which
any Library
References
information
relevant
D.
E.
the
to the
provide
response
"documentsB@ includes,
reports,
clippings,
tabulations,
created,
studies,
recorded,
written
"workpapers"
prepared
manually,
that
to an Interrogatory
are
or Request
all
replication
fmor Production,
limited
to:
pamphlet:s,
prices,
with
explanatory
of the
arithmetic
means
any
or use sulch documents.
back-up
the witness
newspaper
with
material,
or electronically,
of costs,
letters,
by wjhatever
together
to understand
by or for
together
is not
and workpapers
mechanically
created
or Request
testimonies,
includes
calculations
testimony,
workpapers
or transmitted,
necessary
The term
analyses
contain
or Request.
all
but
drafts
stored
material
the
also
Identify
of Documents.
memoranda,
permit
that
As used in an Interrogatory
term
forth
was provided.
Interrogatory
should
to the witness'
Production
information
and Workpapers
The witness
relevant
for
that
whether
and should
rates
or istatistical
in preparinq
information
steps
set
his
sufficient
to
depicted
in such
cite
the complete
workpapers.
In referring
F.
title,
author,
should
cite
testimony
location
to a document,
publisher
page and line,
filed
and,
in this
if
number of the
G.
When a witness
request
should
if
Unless
please
proceeding,
document's
the
thla document
state
identity,
is
tine document's
loca,tion
and
custodian.
is asked to provide
be interpreted
References
of publication.
possible.
not published,
telephone
the
and date
please
as asking
data
for
'or a document,
information
that
.-
ATTACHMENT 1
Page 3 of 3
is
available
about
to the
what
Service,
Officer's
that
it
Officer's
MMA’s
is possible
Ruling
May
No. R94-l/39,
1994 Response
Docket
provide
that
doing
party
the
is expected
H.
Postal
Service
make analyses,
principles
and other
Service's
cited
information,
the
Service
Postal
in Presiding
objections
In the
the
information
so would
expected
event
be an unreasonable
to make the
Commission's
Rules
showing
of Practice
party
party
the
in
in
does
believes
requested
under
Rule 25(c)
requires
the
to perform
research
or to
to comply
Ruling
No,. R94-1118
to compel
and. the
Federal
to Postal
court
the
(pp.
under
and Procedure.
decisions
believes
requested
Rule
Motion
does not
party
the
Postal
Service's
party
requested
burden,
with
No. R94-1 concerning
requested
required
cited
request
in Docket
the
Presiding
requested
the
1994 Response
because
is
to Ccsmpel, both
is requested
the
available
Respasnse and June
required
(See also
that
Postal
and Procedure.
and motions
thereto.
In
Presiding
requested
Officer's
Orders
burden.
authorities
burden,
answering
to compile
in MMA's June 16,
provide
the
of Practice
that
requests
to Compel.)
doing
event
Commission
MMA's discovery
"The
the
because
Rules
stated
that:
Motion
to make the showing
In the
the
(See also
that
knows
C:ommission's
follow
be an unreasonable
of the Commission's
to the
Leave to File
event
information
so would
6),
Service's
In the
reasonable
p. 5; legal
for
to Postal
No. R94-1.)
not
should
(p.
witness
25 of the
to obtain."
1994 Request
10,
without
of Section
No. X94-1/18
the
"available"
the witness
Ruling
which
is
the meaning
of Pract.ice,
and that
to locate
information
within
Rules
5-6)
Service
or has the ability
determining
16,
Postal
;:5(c)
party
of the
that
is