DOCKET SECTION
RECEIVED
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
POSTAL W\TE AND FEE CHANGES,
1997
Docket No. R97-1
RESPONSES OF UNITED STATES POSTAL SERVICE WITNESS SCHENK
TO INTERROGATORIES
OF DIRECT MARKETING ASSOCIATION
AND MOTION FOR LATE ACCEPTANCE
(DMAIUSPS-T27-1
- 3)
The United States Postal Service hereby files the responses of Leslie Schenk to
the following interrogatories
1997: DMAfUSPS-T27-1
The interrogatories
of Direct Marketing Association, filed September
15, 1997,
through 3.
are stated verbatim and are followed by the responses.
These responses were due to have been filed on September 29, 1997. Witness
Schenk’s workload and travel schedule on matters unrelated to this proceeding
prevented a timely filing of these responses,
The Postal Service regrets this delay and
has sent facsimile copies to DMA counsel to mitigate any prejudice
Respectfully submitted,
UNITED STATES POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux,
Michael T. Tidwell
475 L’Enfant Plaza West, SW.
Washington, D.C. 20260-I 137
(202)26&2996/FAX:
,-5402
October 6, 1997
have
Jr.
RESPONSE
DMAIUSPS-T27-1.
direct testimony.
a.
b.
c.
d.
OF THE UNITED STATES POSTAL
TO THE INTERROGATORIES
SERVICE WITNESS
OF DMA
Please refer to page 2, line 18 through
Please confirm that all
i) What percentage
of
processed
on automated
ii) What is the average
secondary
sort?
i) What percentage
of
manually sorted?
ii) What is the average
sort?
i) What percentage
of
sorted mechanically?
ii) What is the average
secondary
sort?
SCHENK
page 3. line 3 of your
BRMAS-qualified
BRM is prebarcoded.
Base Year non-BRMAS
prebarcoded
First-Class
operations?
cost for a First-Class
Mail automated
incoming
Base Year non-BRMAS
cost for a First-Class
Base Year non-BRMAS
cost for a First-Class
prebarcoded
Mail manual
First-Class
incoming
prebarcoded
Mail is
secondary
First-Class
Mail mechanical
Mail is
Mail is
incoming
RESPONSE:
a.
Confirmed
b., c., and d. The mail flow
for First-Class
Automation
percentages
Presort
and incoming
secondary
are given in USPS-T-25,
sorl. percentages
Appendix
1.
RESPONSE
OF THE UNITED STATES POSTAL
TO THE INTERROGATORIES
DMA/USPS-T27-2.
a.
b.
c.
Please refer to Exhibit
SERVICE WITNESS
OF DMA
SCHENK
USPS27C.
Please confirm ,that the marginal processing
and Postage Due Unit cost par piece
for BRMAS-qualified
BRM that is counted and rated in the BRMAS operation
is
1.04 cents.
Please confirm ,that BRMAS-qualified
BRM that is counted and rated in the
BRMAS operation
avoids the 2.31 cent cost for an incoming secondary
sort for
automation
compatible
First-Class
Mail pieces.
Please confirm that the marginal cost for BRMAS-qualified
BRM th:st is counted
and rated in the BRMAS operation
is less than the cost for similar prebarcoded
First-Class
Mail that is not BRMAS-qualified.
RESPONSE:
a.
The marginal
BRM that
cost per piece for sorting,
is counted
operations
and rated in the BRMAS
Confirmed.
c.
I cannot
confirm
counted
and rated in the BRMAS
prebarcoded
testimony,
that the marginal
First-Class
the BRMAS
on BRMAS
because
they
operation
of BRMAS-qualified
at five surveyed
methodologies
operation
costs
BRMAS
in five BRMAS
high volumes
is not developed
employed,
make a comparison
As I stated
are based on the results
operations
which
of BRMAS-qualified
mail.
for prebarcoded
First-Class
in the same way.
necessitated
BRM that
is
is less than the cost for similar
I have estimated
that the cost model
BRMAS-qualified
cost for all BRMAS-qualified
Mail that is not BRMAS-qualified.
productivity
processed
understanding
processing,
and rating
is 1.04 cents,
b.
survey
counting
The two
by the lack of information
of the results
difficult.
in my
of a
wmare selected
It is my
Maill that
is not
different
on BRMAS
RESPONSE
OF THE UNITED STATES POSTAL
TO THE INTERROGATORIES
DMAIUSPS-T27-3.
direct testimony.
a.
b.
c.
SERVICE WITNESS
OF DMA
Please refer to page 12, line 14 through
SCHENK
page 13, line 1 of your
Please confirm that, according
to the BRM Practices Survey, 14.24 percent of all
BRMAS-qualified
BRM is counted and rated in the BRMAS operatia#n.
If not
confirmed,
please explain fully.
Is the 14.24 percent of BRMAS-qualified
BRM that is counted and rated in the
BRMAS operation
different
(with respect to any cost-causing
characteristics)
than the 85.76 percent of BRMAS-qualified
BRM that is not counted in the
BRMAS operation?
Are characteristics
of the bulk mailers whose BRMAS-qualified
BRM is counted
and rated in the BRMAS operation different than the characteristics
of mailers
whose BRMAS-qualified
BRM is not counted and rated in the BRM.AS operation?
RESPONSE:
a.
Confirmed.
b.
The BRMAS-qualified
a particular
counted
facility
is counted
can be different
and ra,ted in a BRMAS
the BRMAS
operation
Operationally,
program
qualified
lower
Vo’lurne
BRM counted
BRMAS-qualified
not necessarily
operation
BRNI that
in that the volume
countled
tend to be for the high volume
accounts
volume
to include
accounts,
per account
could
high volume
accounts
to most efficiently
operation
and rated manually
at
is not
and rated
in
in the BRMAS
use the sortation
also be a difference
and rated in a BRMAS
BRM counted
between
at one faciility
at another
facility,
the BRMASand the
but it is
so.
Other
than a volume
know
of no other
how their
would
and rated in the BRMAS
than the BRMAS-qualified
operation
i,t is more efficient
before
equipment.
c.
BRM that
related
difference
characteristics
BRMAS-qualified
as discussed
of the bulk mailers
BRM is counted
in my response
to part b., I
themselves
determine
and rated.
that
DECLARATION
I, Leslie M. Schenk, hereby declare, under penalty of perjury, that the foregoing
Docket No. R97-1 in1:errogator-y responses are true to the best of my knowledge,
information, and belief.
Date
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the foregoing document upon all
participants of record in this proceeding in accordance with section 12 of the Rules of
Practice.
Michael T. Tidwell
475 L’Enfant Plaza West, SW.
Washington, D.C. 20260-I 145
October 6, 1997