BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20266-0691
RECEiVEC
,,()q*i ,{h,i COHHI5SIGH
cIF+ oi ;I,[ SCCRETAR“
POSTAL
RATE AND FEE CHANGES,
1997
)
)
Docket No. R97-1
FIRST SET OF INTERROGATORIES
OF MAJOR MAILERS ASSOCIATION
TO UNITED STATES POSTAL SERVICE WITNESS
SHARON DANIEL (USPS-T-29)
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,
Rules of
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 with General
Instructions
interrogatory,
G and H. If the designated witness is unable to respond to any
the Postal Service is asked to redirect the question to alnother Postal
Service witness who can answer It
Respectfully submitted,
MAJOR MAILERS ASSOCIATION
i-7
1220 Nineteenth St. N.W.
Suite 400
Washington, DC 20036
Phone: (202) 466-8260
August 13, 1997
MMA INTERROGATORIES
TO USPS WITNESS
(Sharon Daniel: Set One)
MMAIUSPS-T29-1.
Please refer to USPS-29C, pages 1 and 2. Comparing First-Class Automated
unit costs for mail processing and delivery versus Standard Mail Regular
Automation
costs (rounded):
(A)
Why is the Standard Mail Basic letter unit cost (8.‘7 cents) lower
than for a First-Class Basic letter (9.0 cents)?
(B)
Why is the Standard Mail 3-Digit letter unit cost (8.15 cents) about
the same as for a First-Class 3-Digit letter (8.2 cents)?
(C)
Why is the Standard Mail 5-Digit letter unit cost (t3.8 cents) higher
than for a First-Class 5-Digit letter (6.6 cents)?
(D)
Confirm the following unit costs and rates (in cents, rounded) shown
below are proposed by the Postal Service in this proceeding.
Unit
Mail Cateaoly
Unit Rate (I oz)
Unit Rate (2 oz)
First Class:
Basic
Automated 3-digit
Automated 5-digit
9.0
8.2
6.6
26.1
25.4
23.8
49.1
48.4
46.8
Standard A Regular:
Basic Automation
Automated 3-digit
Automated 5-digit
8.7
8.15
6.8
18.9.
17.8’
16.0’
18.9’
17.8’
16.0”
*Assumes no destination entry discount
(D)
Confirm that the rates for Standard Mail Regular Automation
are the
same for all pieces that weigh up to 3 oz. If you cannot, please explain.
1
(E)
Please confirm that the average First-Class presorted letter weighs
.6 ounces whereas the average Standard Mail non-carri’er route presorted
letter weighs 2.3 ounces.
(F)
(See USPS-T-5, pages 15 ansd 18.)
What is the average weight of (1) a First-Class Automation
and (2:1a Standard Mail Regular Automation
letter
letter? If this information
not available, which weighs on average more, a First-Class Automation
letter or a Standard Mail Regular Automation
letter? Support your
answer.
End of Set One Interrogatories,
but please note attached
General Instructions
For Answering)
is
CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoIng document,, by First-Class Mail,
upon the participants requesting such service in this proceeding
August 13, 1997
ATTACIMENT 1
Page 1 of 3
GENERAL INSTRUCTIONS FOR ANSWERING INTERROGATORIES
A.
If
Request
for
the witness
Production
respond,
the
question
or request
answer
the
Service
and his
that
position
with
promptly
it
should
is asked
by facsimile
If
the
who can
the
Postal
can respond
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
Interrogatory
its
of Documents
witness
beiieves
to whom a particular
to an
MBA counsel
message to Telecopy
of
Number
202-293-4377.
B.
In interpreting
Request
for
Production
hypertechnical
what
is
not worded
available,
other,
could
the
but
witness
Documents
previously
will
information
that
the
the
information
party
or know about
the
available
requests
supplied
Interrogatory
be
Interrogatory
or
Similarly,
that
an
is not
the
availability
of
the
requesting
party
In such cases,
Interrogatory
that
or
ab:Le to ascertain
information.
that
the
the
know about
if
If
for
often
or correctly.
asked to interpret
have asked
C.
even if
of the unavailable
providing
is
do not
may seek information
different
lieu
is
generously,
precisely
precisely
the witness
somewhat
use in
would
sought
or Request
please
A witness
is being
Interrogatory
of an Interrogatory
of Documents,
or grudging.
information
Request
the wording
the
of Request
requesting
had phrased
the
party
inquiry
more
information.
or Request
information
that
in this
proceeding,
for
the Postal
please
Production
Service
state
Of
has
and identify
ATTACHMENT 1
Page 2 of 3
the
document
in which
any Library
References
information
relevant
D.
to the
Production
E.
the
to the
witness'
"documents"
provide
response
includes,
reports,
clippings,
tabulations,
created,
studies,
recorded,
written
or Request.
all
"workpapers"
prepared
manually,
that
are
or Request
all
by or for
replication
for
limited
of the
arithmetic
means
any
or use such documents.
prices,
explanatory
newspaper
with
material,
or electronically,
with
letters,
by whatever
together
back-up
the witness
Production,
to:
pamphlets,
to understand
of costs,
together
is not
and workpapers
mechanically
created
or Request
testimonies,
includes
calculations
testimony,
workpapers
or transmitted,
necessary
The term
analyses
co'ntain
to an Interrogatory
but
drafts
stored
material
the
also
of Documents.
memoranda,
permit
that
Interrogatory
should
Identify
was provided.
As used in an Interrogatory
term
forth
information
and Workpapers
The witness
relevant
for
that
whether
and should
rates
or statistical
in preparing
information
steps
set
his
sufficient
to
depicted
in such
cite
the complete
workpapers.
F.
In referring
title,
author,
should
cite
testimony
location
to a document,
publisher
page and line,
filed
and,
in this
if
not
number of the
G.
When a witness
request
should
if
Unless
please
proceeding,
document's
the
the document
state
identity,
the
location
is
document's
and
custodian.
is asked to provide
be interpreted
References
of publication.
possible.
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
the
Ruling
which
10,
provide
that
doing
party
the
In the
information
is expected
of the
Postal
Service
make analyses,
principles
event
the Postal
Service
Service's
in Presiding
requests
objections
In the
to Compel.)
provide
the
information
so would
expected
event
Commission's
because
Rules
showing
of Practice
to perform
research
or to
to (comply with
the
No. R94-l/18
(pp.
Ruling
No. R94~-1 concerning
and the
Federal
to Postal
court
under
and Procedure.
decisions
believes
requested
Rule
Motion
does not
party
the
Postal
Service's
party
requested
burden,
required
Rule 25(c)
the
requested
the
believes
requested
under
to compel
1994 Response
the
does
requires
(See also
'that
party
in
request
in Docket
and motions
be an unreasonable
to make the
the
Officer's
thereto.
in MMA's June 16,
required
both
party
the
is requested
Orders
and June
to Compel,
requested
in
and Procedure.
answering
information,
cited
Response
burden,
is
Presiding
the requested
showing
to compile
Presiding
authorities
the
of Practice
that
Commission
MMA's discovery
cited
Rules
sta,ted
and other
that
because
to make the
In the
"The available
be an unreasonable
Commission‘s
H.
that:
Motion
In
Postal
the
Leave to File
event
burden.
Commission's
(See also
Service's
knows
follow
p. 5; legal
for
to Postal
so would
6),
to the
25 of the
to obtain."
1994 Request
No. R94-1.)
not
(p.
No. R94-l/38,
16, 1994 Response
Docket
should
witness
reasonable
"available"
witness
is possible
the
without
of Section
No. R94-l/18
Ruling
May
is
the meaning
of Practice,
and that
to locate
information
within
Rules
doing
Service
or has the ability
determining
5-6)
Postal
25(c)
party
Of the
that
is