&W
BEFORE THE
POSTAL FATE COMMISSION
WASHINGTON, D.C. 20268-0001
POSTAL RATE AND FEE CHANGES, 1997
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Docket
:
No.
R97-1
TEE DIRECT MARKETING ASSOCIATION,
INC.'S
FOLLOW-UP
INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS
DIRECTED TO TEE UNITED STATES POSTAL SERVICE (DMA/USPS-2-10)
Pursuant
Practice,
the
to Sections
the
Direct
attached
production
any
qualified
Marketing
follow-up
o'f
documents
(DMA/USPS-2-10).
to
25 and 26 of
If
interrogatory,
the
the
Association,
Inc.
interrogatories
to
the
designated
we
request
States
witness
a
hereby
and
United
Rules
Commission’s
is
response
submits
requests
Postal
unable
by
for
Service
to respond
some
other
witness.
Respectfully
submitted,
Dana T. Ackerly
ff,
Esq.
David L. Meyer
Michael
D. Bergman
COVINGTON & BURLINO
1201 Pennsylvania
.Avenue,
Washington,
D.C.
20004
(202) 662-5296
Counsel
for the
Association,
September
of
22,
1997
Direct
Inc.
N.W.
Marketing
- 2 DMA/USPS-T-2.
Please refer
to the Postal
Service's
response
to
DMA/USPS-T14-34b
where it states
that
"in comparison
with MODS,
the
numbers
used
by different
BMCs to
refer
to
various
operations
are much less
uniform
across
facilities."
Please
provide
the operation
codes or numbers used by BMCs to describe
the various
mail processing
operations.
DMA/USPS-T-3.
Please refer
to the Postal
Service's
response
DMA/USPS-T14-34b
where
it
lists
various
categories
operations,
but
notes
that
the manual
letter
(no.
045)
manual
flat
operations
categories
(no. 075) "are no longer
effect.
Most facilities
do not report
hours
or workload
those
operations."
a.
Please
explain
why BMC facilities
for these
operations.
b.
Please
explain
the
data
on workhours
processingoperations
and manual activities).
DMA/USPS-4.
Please
refer
DMA/USPS-T14-34(b)
where
to
it
full
or
do not
extent
to which
workload
for
flat
(includingautomated,
the Postal
Service's
discusses
workhours
at
clocked
report
to
for
and
in
in
data
BMCs report
or letter
mechanized
response
BMCs.
a.
What percentage
of workers
are
operation
for an entire
tour?
b.
What percentage
operation
for
C.
When an employee moves between operations
during
their
tc#ur, what percentage
of such moves are calculated
by
(i)
clock
rings
or (ii)
use of Form 2345 by their
supervisor?
d.
Please
explain
fully
why some moves are calculated
clock
rings
and others
by the Form 2345.
by
e.
What safeguards
are in place to ensure
that
moves
by employees
are accurately
either
the clock
rings
or Form 2345?
on
of workers
actually
an entire
tour?
into
to
work
the
in
a base
one base
reliability
reflected
Please
refer
to the Postal
Service's
response
to
DMA/USPS-5.
DMA/USPS-T14-34(b)
where it states,
\\For manual operations,
the
workload
measures
are derived
from
the
type
and number
of
which
is collected
as the containers
are
containers
sorted,
Conversions
factors
are
used to estimate
the
being
dumped.
of pieces
associated
with
the
number
of
containers
number
Some of these conversion
factors
are fairly
standard
processed.
- 3
nationwide,
equipment
while
others
exhibit
and handling
practices."
more
variation
based
a.
Please list
the manual operations
factors
are used (including,
but
IPPS, and 115s).
for which
not limited
b.
Please
describe
operation.
factors
C.
When were
d.
Do these
are full?
these
refer
Please
list
conversion
limited
to,
conversion
conversion
conversion
DIVA/USPS-~.
Please
DMA/USPS-T14-34(b).
a.
the
factors
factors
to
the
Please
describe
the
mechanized
operation.
C.
When were
d.
Do these
are full?
these
factors
factors
factors
assume
last
that
in
each
revised?
the
containers
response
operations
(including,
conversion
conversion
conversion
last
Service's
all
mechanized
factors
are
used
NMOs and 115s).
b.
conversion
to, NMOs,
used
assume that
Postal
on local
for
used
to
but
which
not
in
each
revised?
the
containers
DMA/USPS-7.
Please
refer
to the Postal
Service's
response
to
DMA/USPS-T14-34(b).
Please
describe
in greater
detail
how TEP
are
including
the
(Total
Equivalent
Pieces)
calculated,
determination
of the weight
to be given
to pieces
processed
on
different
operations.
DMA/USPS-0.
Please
refer
to
DMA/USPS-T14-34(b)
concerning
a.
Please
routine."
b.
Please
be run
finalized
describe
what
it
Service's
response
under PIRS.
means
explain
when the "Headquarters
(ii)
on a (i)
preliminary,
basis.
Please
refer
to
DMA/USPS-9.
DM?&JSPS-T14-34(b)
concerning
a.
the Postal
reporting
by
to
"Headquarters
routine"
revised
or
would
(iii)
the Postal
Service's
response
data reliability
under
PIRS.
to
are
taken
workhours
by
are
the
explain
Please
Supervisors
to ensure
accurately
recorded.
that
"steps"
that
operation
- 4 b.
Have there
been instances
for the supervisor
from
to the beginning
inventory
please
explain
fully.
the
where the ending
inventory
prior
shift
is not equal
for the next shift?
If so,
c.
Please explain
the manner in which
errors
or questionable
observations"
corrected
by local
staff
and the
errors
or observations.
d.
Please
explain
the manner in which
"potential
errors
and discrepancies"
are
detected
and corrected
by
Headquarters
personnel
and the
frequency
of
such
errors
or discrepancies.
DMA/USPS-10.
Postal
Service's
Please
identify
the individual
responses
to DMA/USPS-T14-34
"obvious
reporting
are detected
and
frequency
of such
who provided
the
and DMA/USPS-2-9.
- 5 CERTIFICATE
I
foregoing
proceeding
Postal
Rule
hereby
certify
document
upon
in
Rate
3 of
accordance
Commission's
the
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
of
in
proceeding.
-4%%yDkFSeptember
22,
1997
this
Procedure
Practice
ergman
the
the
and
this