RECEIVED
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
posI\L
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OFF;GE
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POSTAL RATE AND FEE CHANGES, 1997
Docket
No.
R97-1
1
THE DIRECT MARKETING ASSOCIATION,
INC.'S
FIRST SET OF
INTERROGATORIES
AND REQUESTS FOR PRODUCTION OF DOCUMENTS DIRECTED
TO USPS WITNESS SCHENK (DMA/USPS-T27-l-3)
Pursuant
Rules
of
submits
Practice,
the
to
Sections
the
Direct
attached
for
production
l-3).
If
the
interrogatory,
of
first
we request
26 of
Marketing
set
documents
designated
25 and
to
witness
of
the
Commission's
Association,
interrogatories
USPS witness
is
a response
unable
Inc.
hereby
and requests
Schenk
to
(DMA/USPS-T27-
respond
by some other
to
this
qualified
witness.
Respectfully
submitted,
Dana T. AckerlpII,
Esq.
David L. Meyer
Michael
D. Bergman
COVINGTON & BURLING
1201 Pennsylvania
Avenue,
Washington,
D.C.
20004
(202)
662-5296
Counsel
for the
Association,
September
15,
1997
N.W.
Direct
Inc.
Marketing
2
DMA/USPS-T27-1.
line
3 of your
Please
refer
to
direct
testimony.
line
18 through
b.
i)
What percentage
of Base Year
First-Class
Mail is processed
operations?
non-BF0IAS prebarcoded
on automated
iii
What
a First-Class
Mail
secondary
sort?
i)
What percentage
of Base Year
First-Class
Mail is manually
ii)
What
i)
What percentage
of Base Year non-BRMAS
First-Class
Mail
is sorted
mechanically?
ii)
What is the average
mechanical
incoming
C.
d.
DMA/USPS-T27-2.
is
Please
average
automated
BRMAS-qualified
page
Please
confirm
prebarcoded.
the
all
2,
a.
is
that
page
cost for
incoming
the average
cost
_
manual lncomlng
refer
to
BRM is
non-BRMAS
sorted?
prebarcoded
for a First-Class
secondary
sort?
cost for
secondary
Exhibit
3,
Mail
prebarcoded
a First-Class
sort?
Mail
USPS-27C.
a.
Please
confirm
that
the marginal
processing
Due Unit
cost per piece
for BRM?G-qualified
counted
and rated
in the BRMAS operation
is
b.
Please
confirm
that
BRMAS-qualified
BRM that
iscounted
and rated
in the BRMAS operation
avoids
the 2.31 cent
cost for an incoming
secondary
sort
for automation
compatible
First-Class
Mail
pieces.
C.
Please
confirm
that
the marginal
cost for BRMASqualified
BRM that
is counted
and rated
in the BRM?.S
operation
is less than the cost for similar
prebarcoded
First-Class
Mail that
is not BRMAS-qualified.
DMA/USPS-T27-3.
1 of
13, line
your
Please
refer
to page
direct
testimony.
12,
line
and Postage
BRM that
is
1.04 cents.
14 through
page
a.
according
to the BRM Practices
Please
confirm
that,
14.24 percent
of all BRMAS-qualif:ied
BRM is
Survey,
If not
counted
and rated
in the BRMAS operation.
confirmed,
please
explain
fully.
b.
IS the
counted
14.24 percent
and rated
in
of BRMAS-qualified
the BFNAS operation
BRM that
different
is
3
(with
respect
to any cost-causing
85.76 percent
of BRMAS-qualified
counted
in the BRMAS operation?
t he
C.
--
characteristics)
BRM that
than
is
not
Are characteristics
of the bulk mailers
whose BRMASqualified
BRM is counted
and rated
in the BRMAS
operation
different
than the characteristics
of mailers
whose BRMA-qualified
BRM is not counted
and rated
in
the RRMAS operation?
CERTIFICATE
foregoing
proceeding
Postal
3 of
I hereby
certify
document
upon
in
Rate
the
accordance
Commission's
Commisision's
that
all
I have
this
participants
with
Rules
Special
OF SERVICE
Rule
date
of
12
served
record
(section
in
this
3001.12)
of
Practice
and Procedure
Rules
of
in
Practice
the
this
proceeding.
/s!xLL&
ikfiL&
Michael
D.%ergman
September
15,
1997
of
the
and Rule