AECEIVEL)
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
4 40 PM ‘97
Auc 26
POSTAL Rd??CC~~,s!,,nfi
OFFICEOF Tl!; s[C~i~c~~
POSTAL RATE AND FEE CHANGES, 1997
Docket
)
NI>. R97-1
THE DIRECT MARKETING ASSOCIATION,
INC.'S
THI:RD SET OF
INTERROGATORIES AND REQUESTS FOR PRODUCTION 0:F DOCUMENTS
DIRECTED TO USPS WITNESS MODEN (DMA/USPS-T,4-27-38)
Pursuant
Practice,
the
to Sections
the
attached
production
38).
If
25 and 26 of the
Direct
Marketing
third
set
of
documents
the
designated
we request
interrogatory,
of
to
Commission's
Association,
Inc.
interrogatories
witness
is
Moden
unable
a response
hereby
and
USPS witness
by
to
some
Rules
of
submits
requests
for
(DMA/USPS-T4-27respond
o-ther
to
any
qualified
witness.
Respectfully
submitted,
&bL
Dana T. Ackerlp
II,
Esq.
David L. MeyerMichael
D. Bergman
COVINGTON & BURLING
1201 Pennsylvania
Avenue,
20004
Washington,
D.C.
(202) 662-5296
Counsel
for the
Association,
August
26,
1997
Direct
Inc.
N.W
Marketing
- 2 Witness
Moden
(USPS-T-4)
DMA/USPS-T4-27.
in Cost Segment 3
are
affected
by
categories
include
[nonpreferential]
mail classes
are
DM?&JSPS-T4-28.
studies
or reports
a.
Please
describe
the peak load cost adjustment
and explain
which mail categories
and classes
this
adjustment.
If
the
affected
mail
"pref
[preferential]
mail"
and "nonpref
mail,"
please
describe
those
terms and which
included
in these categories.
Please
identify,
conducted
since
describe
1988 by the
anI3 produce
all
USE'S concerning:
the
general
nature
and
quantification
of
mail
processing
peak load
and premium
pay costs
and the
attribution
of such costs to mail classes,
including:
i)
whether
specific
can be causally
mail.
amounts
of premium
related
to particular
ii)
whether
causally
specific
related
iii)
whether
greater
intervals,
demand.
mail
processing
than
demand
both for total
amounts
of
to particular
pay costs
classes
of
overtime
costs
are
cl,asses
of mail.
capacit~y
is
less
or
at
particular
time
demand and pref
mail
b.
the flexibility
of mail
processing
labor
capacity,
including
the use and flexibility
of both regular
and
staff
(including
Part
Time
Flexible
supplemental
employees)
and limitations
on labor
flexibility
such
as advance
notice
requirements,
restri.ctions
on the
use of
supplemental
labor
and limit:;
on overtime
(whether
due to collective
bargaining
agreements
or
otherwise)
C.
mail
deferral
patterns,
length
and extent
of mail
reasons
for such deferral.
d.
arrival
patterns,
mail
arriving
mail
volumes
week
and
AP.
day,
e.
by
including
deferral
including
sub-class,
the
frequency,
by class
and the
fluctuations
by hour,
mail
arrival
the
relationship
between
staffing
and
requirements
processing
(including
staff
levels
and composition).
in
Tour,
peak
rates,
patterns
- 3 f.
the relative
productivities
of manual,
mechanized
and
automated
processing
and how such productivity
varies
with
fluctuating
mail volumes.
DMA/USPS-T4-29
Please
explain
whether
the Postal
Service
is
satisfied
that the current
peak load cost adjustmment methodology
is an accurate
measure of the mail processing
cost differential
between
pref
and nonpref
mail.
DMA/USPS-T4-30.
Please
respond
to
separate
answers
for
(1)
nonpref
Standard
(A) in particular:
the following
by providing
mail
in
general
and
(2)
a.
Please
describe
the
standards
including
mail to be processed.
Postal
Service's
current
service
when such standards
require
this
b.
Please
identify,
describe,
and produce
any reports
or
studies
concerning
the overall
service
performance
of
nonpref
mail including
the percentage
#of nonpref
mail
that
meets its
service
standards
and the number of
days by which various
classes
within
nonpref
mail are
delayed
beyond their
service
standards.
C.
Please
describe
the consequences
whe.n nonpref
does not meet its
service
standards.
d.
Please
confirm
that
service
standards
do not require
that
USPS process
nonpref
mail
during
premium
pay
If not confirmed,
please
explain
fully.
hmours.
e.
Please
l'owers
explain
f.
Please provide
mail by hour,
ST.
Please
explain
whether
nonpref
is routinely
deferred
including
the degree to which
it
t#o level
workloads,
is deferred
beyond
the peak period
in which
First
Class
mail
must be processed
to meet its
service
standards.
h.
and produce
all studies
and
Please describe,
identify,
reports
analyzing
the extent
to which
nonpref
mail
reflects
periods
premium
during
processed
pay
processing
voluntarily
deferred
to those periods.
i.
and produce
all studies
and
Please describe,
identify,
reports
analyzing
the extent
to which nonpref
mail is
not responsible
for mail processing
overtime
costs and
confirm
that
the
peak load
costs.
fully.
deferrabilty
If
not
mail
of nonpref
mail
confirmed,
please
a profile
of mail processing
Tour,
day, week and AP.
of nonpref
- 4 premium
costs
related
(such as delivery
unit
DNA/USPS-T4-31.
with
respect
to
to non-processing
costs).
Please respondtothe
pref
mail in general:
following
functions
interrogatories
a.
Please
describe
the
standards
including
mail to be processed.
b.
Please identify,
describe,
and produce
any reports
or
studies
concerning
the overall
service
performance
of
pref
mail including
the percentage
of pref
mail that
meets its service
standards
and the number of days by
which
various
classes
within
pref
ma.11 are delayed
beyond their
service
standards.
C.
Please
describe
the
not meet its
service
d.
PILease confirm
that
mail to be processed
e.
Please
mail
provide
by hour,
Postal
Service's
current
service
when such standards
require
this
consequences
standards.
service
at night
a profile
Tour,
day,
when pref
mail
does
standards
require
and on Sundays.
of mail processing
week and AP.
pref
of
pref
DMA/USPS-T4-32.
Please
describe,
identify
and produce
any
reports
or studies
conducted
by the USPS concerning
(i)
the
relative
percentages
of pref
and nonpref
mail being
processed
during
a lull
in a Tour when peak capacity
is not being
reached
and
(ii)
the
relative
percentages
of pref
and nonpref
mail
processed
during
the peak period
of mail processing.
Please describe
the marginal
cost differential
DM?&JSPS-T4-33.
Please
explain
between
processing
pref
mail and nonpref
mail.
between
pref
and
standard
differences
whether
the
service
mail
(including
the
facts
that
pref
mail
must
be
nonpref
processed
during
premium
pay periods
and that
nonpref
mail
is
deferrable)
cause marginal
costs for pref mail to be higher
than
If you cannot confirm,
please
explain
fully.
for nonpref
mail.
DMA/USPS-T4--34.
a.
Please
describe:
The maximum percentage
may consist
of part
daily
of
time
tour
the regular
workers
at
b.
The minimum
time workers.
for
c.
The premium
that
must be
between
6 p.m. and 6 a.m.
both
paid
full
for
work force
that
any given
time.
time
processing
and
part
mail
- 5 d.
The premium
Sunday.
that
must
be paid
for
processing
mail
on
DMA/USPS-T4-35.
Please
describe,
identify
and produce
any
studies
or
reports,
conducted
by the
USPS concerning
the
causation
of premium
pay costs
outside
of m.ail
processing
functions
(including,
but not limited
to, delivery
units).
DMA/USPS-T4-36.
Does the USPS, either
at the national,
regional
schedule
deliveries
of Standard
(A) mail
in
or local
levels,
order
to level
mail
processing
volumes?
If
"yes, 1' please
explain
the extent
of such scheduling.
Please
explain
any changes
in the
Postal
DMA/USPS-T4-37.
cost
methodology
proposed
concerning
the
mail
Service's
in R97-1
as compared
to the
processing
peak load
adjustment
Please
confirm
that
the base
Commission's
R94-1 methodology.
year peak load adjustment
conforming
to the Commission's
R94-1
reflectsed
in Attachment
1 to the
Presiding
methodology
is
Officer's
Ruling
No. R97-I/7.
DMA/USPS-T4-38.
Please provide
processed,
by sub-class,
on
mechanized
machines,
and (iii)
the relative
percsntages
of mail
(ii)
automated
machines,
(i)
manually.
- 6
CERTIFICATE
I
foregoing
proceeding
Postal
Rule
hereby
certify
document
upon
in
Rate
3 of
accordance
Commission's
the
proceeding.
August
26,
1997
Commission's
OF SERVICE
that
all
I
have
this
participants
with
Rule
Rules
of
Special
12
date
of
record
(section
Practice
Rules
in
3001.12)
and
of
served
this
of
Procedure
Practice
the
in
the
and
this