BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
RECEIVEC
but 13 II 51 AH'97
PEST&L
n*if CLii!t!l'S!Oti
OFF~,;E
Oi IHEL~ZHE~ARY
POSTAL
RATE AND FEE CHANGES,
1997
)
Docket No. R97-1
FIRST SET OF INTERROGATORIES
OF MAJOR MAILERS ASSOCIATION
TO UNITED STATES POSTAL SERVICE WITNESIS
JOSEPH D. MOELLER (USPS-T-36)
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 this 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,
MAJOR MAILERS ASSOCIA.TION
1220 Nineteenth St. N.W
Suite 400
Washington, DC 20036
Phone: (202) 466-8260
August 13, 1997
MMA INTERROGATORIES
TO USPS WITNESS
(Joseph D. Moeller: Set One)
11
MMAIUSPS-T36-1.
In your Testimony (USPS-T-36,
Standard (A) Regular Automation
page 21), you list the proposed rates for
letters
(A) Confirm that the Service’s proposed Standard Automation
result in the following postage prices for letters:
Standard(A) Regular
Automation
5-Digit: Weight
(No Entry Discount)
Rate
(Cents)
(B) If you cannot confirm this, please state the
correct postage prices for each of the listed letters.
rates would
MMAIUSPS-T36-2.
In your Testimony (USPS-T-36,
Standard (A) Regular Automation
page 21), you list the proposecl rates for
letters
(A) Confirm that the Service’s proposed Standard Autornation
result in the following postage prices for letters:
Standard(A)Regu
Automation
3-Digit: Weight
(No Entry Discount)
Rate
(Cents)
0.1 oz. to 1 .o oz.
17.8
1 .I oz. to 2.0 oz.
17.8
2.1 oz. to 3.0 oz.
17.8
(B) If you cannot confirm this, please state the
correct postage prices for each of the listed letters.
rates would
MMAIUSPS-T36-3.
In your Testimony (USPS-T-36,
Standard (A) Regular Automation
page 21), you list the proposed rates for
subclass
(A) Confirm that the Service’s proposed Standard Autornation
result in the following postage prices for letters:
Standard(A)Regu
Automation
Basic: Weight
(No Entry Discount)
Rate
(Cents)
(B) If you cannot confirm this, please state the
correct postage prices for each of the listed letters
rates would
MMAIUSPST36-I.
In your Testimony (USPS-T-36,
page 21), you list the proposed rates for
Standard (A) Regular Presort letters
(A) Confirm that the Service’s proposed Standard Presort rates would
result in the following postage prices for letters:
Standard(A)Regu
3/5 Digit Presort: Weight
(No Entry Discount)
Rate
(Cents)
(B) If you cannot confirm this, please state the
correct postage prices for each of the listed letters,
MMAIUSPS-T36-5.
In your Testimony (USPS-T-36,
page 21), you list the proposed rates for
Standard (A) Regular Presort letters.
(A) Confirm that the Service’s proposed Standard Presort rates vould
result in the following postage prices for letters:
Rate
Standard(A)Regu
Basic Presort: Weight
(No Entry Discount)
(Cents)
(B) If you cannot confirm this, please state the
correct postage prices for each of the listed letters.
MMAIUSPS-T36-6.
In your Testimony (USPS-T-36,
page 21) you list the proposed rates for
Standard (A) non-letters.
Please confirm that:
(A)
For basic automation flats, the rates are the same for all pieces
weighing up to 3.3 ounces.
(B)
For 3/5 digit automation flats, the rates are the salme for all pieces
weighilng up to 3.3 ounces.
(C)
If not please explain.
If not, please explain.
For basic presorted non-letters, the rates are the :same for all pieces
weighing up to 3.3 ounces.
If not, please explain.
5
(D)
For 3/5 digit presorted non-letters, the rates are the same for all
pieces ,weighing up to 3.3 ounces.
If not, please explain.
MMAIUSPS-T36-7.
(A)
Please confirm that Standard Mail (A) letters are generally processed
on
the same barcode sorters as First-Class letters.
(B)
If you cannot confirm, please explain the frequency of occurences
when
Standard Mail (A) letters and First-Class letters are processed separately and
the circumstances
(C)
that dictate such separate processrng.
Are barcode sorters capable of processing Standard (A) letters and First-
Class letters together without impairing throughput
(D)
and productivity?
Can barcode sorters detect the difference between First-Class letters and
Standard (A) letters and, if so, how?
MMAIUSPS-T36-8
In a document entitled “Revisions To Weight and Preparation
Standards for
Barcoded Letter Mail, published in 59 Federal Register 65967-:71 (Dec. 22. 1994)
and 60 Federal Register 5860-61 (January 31, 1995) the Posl:al Service
announced:
“For a period of up to 1 year, beginning January 16, 1995, the
Postal Service will conduct a test of live barcoded bulk third-class regular rate
letter mail weighing between 3.0 and 3.3071 ounces, and barcoded bulk thirdclass nonprofit rate, First-Class and second-class
letter mail weighing between
3.0 and 3.376 ounces” (60 Fed. Reg. at 5860) in order “to determine whether a
permanent
increase in the maximum weight for barcoded letter mail is
appropriate....”
(59 Fed. Reg. at 65969).
6
(A)
In those tests, did the Postal Service test letters that weighed:
(1)
3.0 ounces but not more than 3.3 ounces (rounded)?
(2)
(B)
2.9 ounces but not more than 3.0 ounces?
Did the tests show that the automation machinery experienced
reduced throughputs for letters that weighed:
(1)
(2)
(C)
2.9 ounces but not more than 3.0 ounces?
3.0 ounces but not more than 3.3 ounces (rounded)?
If the answer to Paragraph (B)(l) or (2) is other than no, please
explairl and state the weight of letters that reduced throughputs.
state the degree of such reduction in throughputs
Please
for each type of letter by
weight,,
MMAIUSPS-T36-9.
In USPS-T-36,
incorporates
page 16, you state that the Standard mail rate design
a breakpoint weight--the
the per-piece rate--of 3.3 ounces.
(A)
maximum weight for piec:es that pay only
(See also Id. page 7. note 7.)
Please explain whether the selection of this breakpoint takes into
account the results of the “live” test announced
in 59 Federal Register
65967-71 and 60 Federal Register 5860-61 and, if so, how.
(B)
Please explain whether the “live” test announced
in 59 Federal
Register 65967-71 and 60 Federal Register 5860-61--which
process “First-Class and second-class
letter mail weighing between 3.0
and 3.376 ounces” (60 Fed. Reg. at 5860)--supports
breakpoint rate of 3.3 ounces and, if so, how.
7
was to
yolur use of a
MMAIUSPS-T36-10.
Please refer to Interrogatory
MMA/USPS-T36-8
and 9 concerning the Postal
Service’s “live” test announced in 59 Federal Register 65967-71
Federal Register 5860-61,
and 60
Those Federal Register Notices also published a final
rule entitled “Revisions To Weight and Preparation Standards for Barcoded
Letter Mail.
(4
How did the test results affect the rule published in 59 Federal
Register 65967-71 and 60 Federal Register 5860-61 ?
ItI)
Was the rule continued in effect and, if so, does the rule
remain in effect?
(2)
Was the rule modified and, if so, how was it modified?
Does
the modified rule remain in effect?
‘(3)
Was another rule adopted in place of the rule and, if so, what
did the modified rule provide and does it remain in effect?
If
another rule was adopted, please provide a copy.,
(B)
.Vith respect to automation-compatible
barcoded letter-size mail,
does the Postal Service currently allow Standard and First-Class Mail
weighing 3.0 ounces to be accepted at Automation
rates and, if so, what
is the maximum allowable rate?
(C)
With respect to automation-compatible
barcoded letter-size mail,
does the Postal Service currently allow Standard and First-Class Mail
weighing 2.0 ounces or more to be accepted at Automation
so, what is the maximum allowable rate?
8
rates and, if
(D)
In the live tests announced in 59 Federal Registelr 65967-71 and 60
Federal Register 5860-61, were the First-Class
and the third-class
letters
processed on the same machines and, if so, were the First-Class and
third-class
letters processed together?
MMAIUSPS-T36-11.
Please refer to Interrogatories
(4
MMNUSPS-T36-8
In the live tests announced
through 10.
in 59 Federal Register 65967-71 and
60 Federal Register 5860-61, on what types of Postal Service processing
machines were the third-class and First-Class letters processed?
(B)
What was the basis on which it was determined that the tests
should be conducted on these types of machines?
End of Set One Interrogatories,
but please note attached
General Instructions
For Answering)
*
CERTIFICATE
OF SERVICE
I hereby certit) that I have this day served the foregoIng document. by Ftrst-Class Mail.
upon the participants requesting such service in this proceeding
August 13. 1997
ATTACHIIENT 1
I?age 1 of 3
GENERAL INETRUCTIONS POR ANSWERING
A.
If
Request
for
the
witness
Production
respond,
the
question
or request
answer
the
Service
Interrogatory
its
and his
that
position
with
promptly
it
is
should
by facsimile
the
who can
If
the
Postal
can respond
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
question
believes
to whom a particular
of Documents
witness
INTERROGATORIES
to an
MMA counsel
message to Telecopy
of
Number
202-293-4377.
B.
In
Request
for
interpreting
Production
hypertechnical
what
is being
is not
Interrogatory
other,
could
worded
but
use in
sought
different
lieu
will
providing
C.
Documents
previously
for
the
if
or know about
If
the
requests
supplied
the
know about
that
of the unavailable
generously,
precisely
even if
information
is asked to interpret
have asked
is often
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.
the witness
would
do not
may seek information
the witness
somewhat
please
A witness
precisely
or Request
available,
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
ATTACRMENT 1
I?age 2 of 3
the
document
in which
any Library
References
information
relevant
D.
to the
Production
E.
the
to the
that
provide
response
includes,
rep'orts,
clippings,
tabulations,
studies,
recormded,
written
material
or Request.
all
prepared
manually,
all
that
are
or Request
for
limited
by whatever
with
means
any
or use such documents.
materia.1,
whether
and should
rates
in preparing
steps
set
or statistical
information
of the arithmetic
newspaper
together
prices,
explanatory
letters,
pamphlets,
back-up
the witness
Production,
to:
or electronically,
of costs,
with
replication
not
to understand
by or for
together
is
and workpapers
mechanically
created
or Request
testimonies,
includes
calculations
testimony,
workpapers
or transmitted,
necessary
Mworkpapers"
analyses
contain
to an Interrogatory
but
drafts
stored
The term
the
Identify
of Documents.
"documents"
created,
also
Interrogatory
should
witness'
memoranda,
permit
was provided.
As u,sed in an Interrogatory
term
forth
information
and Workpapers
The witness
relevant
for
that
his
sufficient
depicted
to
in such
workpapers.
In referring
F.
title,
author,
should
cite
testimony
location
request
and date
page and line,
and,
G.
the
publisher
filed
telephone
to a document,
in this
if
if
possible.
When a witness
should
complete
th'e document
state
identity,
is
the document's
location
and
custodian.
is asked to provide
be interpreted
the
References
Unless
please
the
number of the document's
cite
of publication.
proceeding,
not published,
please
as asking
data
for
or a document,
information
that
ATTACENENT
I?age 3 of 3
is available
about
to the
or has the
determining
Officer's
that
it
Officer's
:is possible
Ruling
MMA's May 10,
16,
Docket
that
the
doing
party
so would
Postal
Service
make analyses,
principles
5-6)
the
Service
Postal
in Presiding
requests
in MMA's June 16,
In the
to Compel.)
provide
the
information
so would
expected
event
Commission's
because
Rules
showing
of Practice
believes
Rule 25(c)
the
to perform
research
or to
to comply
Ruling
with
No.. R94-l/18
the
(pp.
No. R94-1 concerning
to compel
and the
Federal
to Postal
requested
court
and Procedure.
decisions
Motion
does not
partyy believes
the
under
Postal
Service's
party
requested
burden,
required
does
requires
in Docket
the
party
under
requested
1994 Response
be an unreasonable
to make the
is
the
party
in
request
(See also
that
both
the requested
required
the
and motions
thereto.
requested
in
and June
to Compel,
requested
Officer's
Orders
cited
and Procedure.
answering
information,
is
Presiding
Response
burden,
showing
to compile
objections
Service's
the
of Practice
that
Commission
MMA's discovery
doing
event
stated
and other
cited
Rules
Presiding
authorities
the
because
to make the
In the
"The available
be an unreasonable
Commission's
H.
that:
Motion
that
In
Commission's
the
Leave to File
In the event
burden.
to the Postal
(See also
Service's
information
reasonable
p. 5; legal
for
to Postal
is expected
of the
6),
knows
follow
to obtain."
1994 Request
No. R94-1.)
not provide
(p.
witness
25 of the
should
No. R94-l/38,
1994 Response
without
of Section
No. R94-l/18
the
"available"
the witness
Ruling
which
is
the meaning
of Practice,
and that
to locate
information
within
Rules
Service
ability
what
Service,
Postal
1
requested
Rule
25(c)
party
of the
that
is