BEFORE THE
REWED
POSTAL RATE COMMISSION
WASHINGTON
POSTAL RATE AND FEE CHANGES,
INSTITUTIONAL
Qp \Q
DC 20268-0001
DocKE.~~~~~~~~~~~~‘~~~,
1997
INTERROGATORIES
2 11 PO’
OF DAVID 6. POPKIN TO THE UNITED
STATES POSTAL SERVICE AND MOTION TO FILE ALL FOLLOWUP
INTERR’OGATORIES
/MOTIONS
TO COMPEL IN A SINGLE PLEADING
David H. Popkin hereby requests the United States Postal Service to answer, fully and
completely,
the following
Commission’s
encouraging
pursuant
Rules of Practice and Procedure.
cooperation
liberally interpreting
information.
interrogatories
from the interveners,
to Rules
Particularly
25 and
26 of the
since the Postal Service is
I request that similar cooperation
the requests made by my interrogatories
in
and provide the desired
To reduce the volume of paper, I have combined related requests into a
single numbered
interrogatory,
however, I am requesting
made to each separate question asked.
responses to a Library Reference,
since II am lociated at a distance
that a specific response
To the extent that a reference
I would appreciate
be
is made in the
receiving a copy of the reference
from Washington,
DC.
All responses
should be
complete without reference to any previous Postal Rate Commission dockets.
In the event that the Postal Service does not respond
so tha,t they are received
required
ta all of my interrogatories
on the same date or does not file responses
time or files an objection
to any of my interrogatories,
I request
of the filing time rules which will allow me file all of my follow-lup
that
may
be
interrogatories
calculated
required
or file
a response
at the same time in a single
for all of the USPS separate
to
mailing
responses
Septernber 6, 1,997
1
any
USPS
within
a waiver
interrogatorises
objection
made on the latest
and pleadings.
the
to
my
date as
DAVID B. POPKIN, POST OFFICE BOX 528, ENGLEWOOD,
DBPIUSPS-53
Request
In the response
to Question
1 in Presiding
No. 2, it was stated that, “Our conclusion
Ciassroom,
suffer Irom some insiabiiiiy
IOCS sampling procedures.”
NJ 07631-0528
Officer’s
is that Library
lnformatioln
rate costs, like
due to the smaii volume and rhe nature of the
[a] Describe the IOCS method of obtailning cost data. [b]
Quantify and explain the words “some instability” as they were utilized in that response.
[c]
Explain and quantify
procedure.”
[d]
what is the meant by the “nature
What other classes or subclasses
of rates have similar or greater
levels of instability and quantify and explain the amount.
instability
existed in the data for Special Handling,
stamped envelopes,
Certified
Mail, Registered
of the IOCS sampling
[e] Specifically
what level of
Return Receipt for Merchandisis,
Mail, and Return Receipt service.
For each of the different classes and subclasses of rates [including those mentioned
[fl
in
subpad e] for which the IOCS is utilized to provide cost data, furnlish a listing of the
class atr subclass, the IOCS results for that class or subclass, the conversion
of the
IOCS clata to actual costs, the reliability of the data, and the range of actual costs and
cost coverage percents that would result based on the reliability of the IOCS data. The
reliability
candidate
accurate
should be expressed
in a manner similar to a political poll when it states
A is leading candidate
B by a 50 to 40 percent margin and the data is
to plus or minus 4 percentage
points.
[g]
Explain the method utilized to
calculate the reliability.
DBPIUSPSS4
Refer to interrogatory
DBPIUSPS-27.
[a] With respect to the new
Return Receipt service showing the new address of delivery
has Headquarters
or any
Area prepared a training course or other training material to explain the new service?
[b] If so, provide copies of the training material.
response to subpart f of DBPIUSPS-27.
[c] If not,. add that reason into your
DBPIUSPS65
Refer to interrogatory
DBPIUSPS-35
and in your responses
!:o
subparts b and c specify the locations of the facilities that presently do not have 100%
capability to “trap” Certified Mail.
DBPIUSPS-66
envelopes.
Refer to interrogatory
DBPIUSPS-54
which
[a] If you arrive at a price for any of the following
response to the following subparts of DBP/USPS-54,
is provided
relates
to stampe!d
types of envelopes
,in
explain how that price was arrived
at utilizing
the data which
in the specific
Fee Schedule
envelopes:
subparts d, e, k, and w. [b] Confirm, or explain if you are unable to do so,
that the Postal Service issued a “G” rate stamped envelope
which was prepared
advance of the last case and was sold with a postage value of 32 cents.
be an “H” rate, or other designation,
for stamped
stamped envelope prepared
in
[c] Will there
iI1 advance for use
with the rate approved in the current case? [d] How many colors will be utilized to print
the envelopes referred to in subpart c?
DBPIUSPS-67
With respect to undeliverable-as-addressed
First-Class
Mail, [a]
are there any service standards for the time taken to markup and rei:urn the mail to the
sender’? [b] If so, what are they?
DBPILEPS-68
Confirm, or explain if you are unable to do so, that the following
types or categories of stamps have been issued by the United States; Postal Service, ‘or
any of its predecessors
government
stamps,
[a] postage stamps,
[g] Postage Due stamps,
stamps with service endorsements
class mail categories,
[n]
[c] Special Delivery
[e] Registration
stamp,
[h] Parcel Post stamps,
[j] Parcel Post - Postage Due stamps,
stamps with service endorsements
stamps issued by oth,er
[b] Air Mail stamps,
[d] Air Mail - Special Delivery stamps,
Mail stamp,
stamps,
agencies],
[this does not include non-postage
[i] Special Handling
[k] Newspaper / Periodical stamps,
for the various
First-Class
for the various Standard
Mali1 categories,
[m]
by a means other
only, [o] Official Mail or Penalty Mail stamps.
3
[I]
Mail or the former third-
stamps which have been precancelled
than with a service endorsement
[fl Certified
[p] List
any other types or categories
each of the categories
of stamps that have been issued.
listed in subparts a through p, advise the use that may be made
of these stamps by an individual mailer.
possible,
limit your response
postage and fees,
category
to one or more of the following
shown on the stamp,
4.
domestic mail, so indicate.
fee for a special service
If there is any restriction
If
1. for all
3. for only the fee for the
for use by the USPS only,
15. for use by an
If a permit is required
to use in international
and/or
[r] If there is a stamp which may only be used to pay the
and that service
such as was done with Special
is eliminated
Delivery
exchanlged for ordin,ary postage stamps?
or reduc:ed by the Postal
in a recent
happens to indi’viduals who are holding those stamps?
any postage or fee?
responses:
agency only, or 6. no use may be made.
for their use, so indicate.
Service,
Only consider stamps issued since 1860.
2. for all postage but not for any fees,
authorized government
[q] With respect to
PRC Docket,
what
[s] May they be redeemed
or
[t] May they be utilized for the payment of
[VI If your response to subparts s and t is no, then explain why
you feel that this would not be a taking of property
by the Postal Service without
compensation.
CERTIFICATE
I hereby
participants
certify
that
OF SERVICE
I have this date served
of record in this proceeding
in accordance
practice.
David H. Popkin
September 8, 1997
4
_.__----
the foregoing
document
upon
all
with section 12 of the rules Iof