DOCKET SECTION
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268~001
POSTAL RATE AND FEE CHANGES, 1997
Docket No. R97-1
i
RESPONSE OF UNITED STATES POSTAL SERVICE
WITNESS TAUFIQUE TO INTERROGATORIES
OF
THE NATIONAL NEWSPAPER ASSOCIATION
(NNA/USPS-T34-1,
4-8).
AND MOTION FOR EXTENSION OF TIME TO RESPOND TO NNA/USPS-T34-2-3
The United States Postal Service hereby provides responses of witness Taufique
to the following interrogatories
T34-1,
of the National Newspaper
4-8, filed on September
12, 1997.
Interrogatory
Association:
NNA/USPS-
NNAIUSPS-T34-9
was
redirected to witness Alexandrovich.
The Postal Service moves for an extension, until Wednesday,
respond to interrogatories
coordination
NNAIUSPS-T34-2
October 1, to
and 3. These responses
involve
with a manager who will not be available until Tuesday or Wednesday.
Each interrogatory
is stated verbatim and is followed by the response
Respectfully
submitted,
UNITED STATES POST,AL SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemakiing
David H. Rubin
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-I 137
(202) 268-2986; Fax -5402
September 26, 1997
RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS TAUFIQUE
TO INTERROGATORIES
OF NATIONAL NEWSPAPER ASSOCIATION (NNA)
NNA/USPS T34-1
Please refer to your testimony on Table Ill. Please confirm that the pound rate in
within-county “zoned advertising delivery unit” proposed rates is intended to
apply only to advertising weight. If you do not confirm, please explain.
RESPONSE
Not Confirmed. The within-county
pound rate label “zoned advertising delivery
unit” is incorrect. The correct label should be “DELIVERY
UNIT”. A distinction
between advertising and editorial content is not made in the Within County
subclass. An erratum will be filed
RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS TAUFIQUE
TO INTERROGATORIES
OF NATIONAL NEWSPAPER ASSOCIATION (NNA)
NNA/USPS T344
Please describe any changes that the Postal Service has publicly discussed
since June 1, 1997, regarding sortation, packaging or sacking of Periodicals mail
to Sectional Center Facilities and provide copies of any memoranda, reports or
press announcements regarding this intended change. If you do not confirm,
please explain. Please describe any effects such a change, if any, would have
upon the test year costs or rates proposed in this case.
RESPONSE
The Postal Service has published notice of a proposed rule in the Federal
Register (Vol. 62, No. 178/ Monday September
15, 1997, pages 48192-3) which
would add the SCF sack level to the presort requirements
for Periiodicals
mailings of nonletter size pieces, A copy of this proposed rule is attached. This
change would not affect the proposed rates and costs in the test year, as
explained in Witness Seckar’s response to ABPIUSPS-T34-7[b],
3, 1997.
filed September
Page L of
ATTACHMENT TO RESPONSE TO NNA/USPS-T34-4
Federal Register I Vol. 62. No. 178 I Monday.
Seprember
15. 1997 I Proposed Rule3
on Au$I 1. 1997 (62 FR 4,760 (P,
1u7and139l,and62FR41730[P~
10811.The X=RMs proposed 10 updale
lhc overall regulamry swc~ue for
airport and air carrier security.
The closing date lor cmnmen~s on
Lheseproposals is December I, 1997.
The FAA is planning these meellngs 10
give the public an addihonal
oppar.““lty to COrnme”, on lhcse
proposed rules.
Persons interested in ahtaining a copy
of cbtA,rpon Securily (Pans 107 and
1391 and/or the Axcrah Operator
Seculty IPan 108) proposed mles
should contact Elizabeth Allen at the
address or l&phone number provided
In FORFURTHER
INFORMA.TION
CONTAC’T.
An eleCVOnlc copy of these
documenrs may be downloaded using a
modem and suitable communxations
sohware fmm he FM regulation3
section of the Fedworld a1ectronic
builenn board service [reiephone: (7031
32143391 or tie Federal Register’s
elecl‘onic bulleun board seplice
(telephone: (202) 512-1661).
lntemet users may reach the FAA’3
webpage ar hrtp:/lw.
faa.gov or !Jle
Requests fmm persons who wish (0
Federal Register’s webpage at http:\/
presenr oral statements al the public
t.ww”.caccessgpo.govisu-dots fo iccess
meetings on LheAirpon Secnnly and/or
recently published rulem&ng
the aircraft Operaror Security proposals
docunenls.
rhould be received by the FAA no later
Lban October9.1997, for the
Public Meeting Pmceduw
Washington, DC meeting and no later
The following proceduns are
tsan October 15, 1997. for the Fon
estab!i&ed 10 lamlitate the public
Worth. TX meeting. Such requests
meetings on he NPRUs:
should be submltred LOElizabeth Allen
I. There will be 00 admission fee or
as hsted in the section titled FOR
other charge LOattend or LOpanicipare
FURTHER
INFORMAT~OH
COH~ACTand
in the public meetings. The meetings
should include a wntten summxy of
oral remark: to be presenwd. the date of wll be open (0 all persons who have
requested in advance lo p~sent
%e meeting the requesrer wishes to
zddress. and an estimate of time needed s~a~ernen~.or who register on the day
of the meeting (between 8.30 a.m. and
ix tie prsenNion. Requesls received
9:OOa.m.1 sublect to availability of space
aiter the dales specified above will be
in tne meeting room.
scheduled if there is Lime available
2. The public meetings will adjourn
dung the meeting: however, Lbe name3
after scheduled speakem have
of those individual3 may 110~appear on
completed their statementi.
the titten agenda. The F.A.4 will
3. The FAA will Q f~ accommodate
prepare an agenda of speaken that will
all speakers: therefore. it may be
be avaliabie at &hemeetlqgs. To
necessq to limit rhe time avadable for
Jccoxmodate as maa? speakers a3
Possible. the amount of tipe ailocaied to an individual or gmup.
4. Panicipanu should address their
each speaker may be less than the
comments to the panel. No individual
Wmm of time requested. Those
will be subject 10 cross-examination by
Pr*ans desiring lo have available
any o&r par&ipant.
*udiovisual equipment should notify
9. Sign and oral titerprelation can be
he F&r, when requesung ‘10be placed
made available at the meetings, as well
QDhe agenda.
as an assisave listening device. If
Background
requested 10 calendar days before the ’
mWing3.
6. Representatives of the F&4 ~(11
conducr tie public meetings. A panel oi
F&4 personnel involved m this issue
will be presenr.
7. The meetings will be recorded by
The notices of proposed r&making
a courr reporter. h tlpscnpl of rhe
wer3 published in the Federal Register
meeungs should be duected Lo Elizabeth
Allen. Federal Aviatmn Admmisu3lion.
Office of Ruiemakiog (ARhG1001. 800
independence Avenue. SW.
Wnshinglan. DC 20591. telephone I2021
3674199, fax (2021267-5075.
Questmns concemmg he NPRU on
Airport Secunty (Pa13 107 aad 1391
,houid be directed lo Penny Anderson.
Otficc 01 Civil Aviation Security Policy
2nd Planmng. Civil .4viation Security
Division (ACP-1001. Federal Aviation
r\dminislrauon. 800 Independence
A”?.. SW. Washington. DC 20591;
telephone jzozl x7-3.&13.
Questions concemq the N’PRM on
AircrafT Operalor SecuiQ (Put 1081
should be directed to Rhunda Halmaker.
Office of Civil hviation Securily Policy
and Planning Civil Aviation Security
Division (ACP-100). Federal hviaoon
,$.dmimstration. 800 tndepeadence
Ave.. SW. Washington. DC 20591;
telephone (2021 267-341.1.
3
48191
meetings and any marenal accepied by
the panel during rhe meeting3 wi,, be
Included in the public dockets [pocket
No. 28079 IPans 107 and 1x9). and
Dockcr No. 28978 [Pan boa,). Any
person who is interesred in purcharing
3 c~‘Py Of tie Lransctipr should contact
rhe COU~Ireporter duecriy. This
inhrnauon
will be avadahle at the
meelings.
8. The F.4A wll review and consider
AI matenal presented by pticipanls at
Lhe public meetings. Position paperr or
marerial presenting views or
information relaed lo Lhepmposed
NpIRUs may be accepted ar the
discretion of the presidinq ofScer and
rubrequendy placed in rhe public
docker. The F..w requesrr r-batpersons
parhcipating in the mce~ngs provide IO
copies oi dl materials 10he presenred
for dlsuibution LOthe panel mcmbcrs:
orhars cop133may he provided 10the
audience ar the discretion ai rhe
paxcipant.
9, Statemenls made by members oitbe
public me&g3 panel are intended m
facilitiw discussion oi’de issues or 10
clari.$ issues. Because the meetings
concermng the nrpan Security (Pam
107 and 1391andA~rc=? Operator
Security IPan 108) are b&g held during
the comment period. Goal decision3
cm~:emmg issues hat the public may
robs cannot be made at the meetig~.
Federal Aviation Administion
ofikials may. however. htk quesdnnr to
clarify statements made by the public
and to ensure a camplele and acc’urae
record. Comments made at the33 public
meetings rvlll be considered by rbe F.4A
when dellberarions be+ cancerzing
whelher 10adopl any or all of the
proposed rules.
48192
ATTACHMENT TO RESPONSE TO NNA/USPS-T34-4
Federal Register I Vol. 62. No. 178 I Monday. September
ACTION:Prooosed Rule
Page
3
15. 1997 I Proposed Rules
it is proposed that preparation of the
SCF sack would become mandatory
Preparalion of en SCF package will
not be permitted under Lhis planned
rule change. A” SCF package would
increase piece distribution for the Postal
Service. Accordingly. SCF sacks would
be permitted lo contain only 5.digit end
3-digil packages.
For nonautomation rate mailings. mail
in SCF sack, would bc eligible for the
basic per-piece rates. For SCF sacks in
auiamalion rate maihngs. S-digit end
unique 3.diglt packages of 6 or more
pieces would qualify for the 315
automation rate. and nonunique 3.digit
packages es well es 5.digit end 3-digit
packages of fewer than 6 pieces would
qualih for the h-sic .:z:omation per
piece reles.
For the interim period when
preparation of SCF sack.swill be
optional. mailers who choose to prepare
SCF sacks must prepare dxm for each
SCF in Lbemailing for which there ue
24 or more pieces of mail prepared in
5-digit and/or 3-dlgit packages. .4t the
mailer’s option SCF sacks may also be
prepared that conlain fewer pieces (a
mmimum of one package).
The standard to prepare required
origin/optional entry 3-digit sacks will
not apply 10 Permdicals publications [or
which SCF sacks are prepared. Instead.
mailers opting to prepare SCF sacks
must prepare required origin/optional
entry SCF sacks. At the time SCF sacks
become a required level olsortation. the
standard lo prepare required origirr/
optional enLry 3-digIt sacks will be
deleted and preparation of rcquircd
origin/optional entry SCF sacks will
become the new standard.
Although exempt from the notice and
comment requiremcnu of the
Ad.minisu;tivc Proccdurc Act (5 U.S.C.
553(b), [cl) regarding proposed
rulemaking by 39 U.S.C. 410(al. the
Postal Service invites comments on the
following proposed revisions of the
Domestic Mail Manual (DMM).
incorporated by reference in the Code of
Federal Regulations. See 39 CFR part
111. r
List of Subjects in 39 CFR Part 111
Postal service.
*UYU*RI: The Postal Service plans Lo
add en SCF sack level LOthe presort
requirements for Periodicals automation
and nonautomation mailings of
nonlelter-size pieces. An SCF package
level will not be added. Only S-digit and
3-digit packages will be permitted in the
SCF sack. SCF sacks will be prepared
after 5.digit and 3.digit sacks. end prior
LOpreparing AOC sacks.
DATES:Comments must be receivkd on
or before October 15. 1997.
ADDRESSES:
Mail or deliver written
commenls 10 the Manager. Mail
Preparation and Smndards. USPS
Headquarters. 475 L’Enfant Plaza SLY.
Room 6800. Washington. DC ?ozo2405. Copies of all wfucn comments
will be available at the above address for
inspection and pholocopymg between 9
a.m. and 4 p,m.. Monday through
Friday.
FORFlmlHHER
lHFORM*T,cmCONTACT:
Lynn M. Martin. (2021 268-6351.
SUPPLEMENTARY
IHFORM*mH:.On July 1,
1996, the Postal Service eiiminaled the
optional preparation of SCF packager
as pert of Lhertreamlming of
end sack
presort requirements under
Classificallon Reiorm. Some Periodic.&
mailers have indicated thawthey believe
hat the inablhty Losack mad 10 the SCF
level has affected the serwce of their
publications. Many mailers of
Periodicals publications have been
preparing 3.digit sacks that contain
iewer than the required 24 pieces, to
ensum good levels oi rcwlce. This
results in increased sack usage by
mailers and increased sack handlings by
the Postal Scwice. Reinstating SCF
sacks would allow Pcrlodicals mailers
,o direct sacks 10 the spphcable
processing plant for scrwce reasons
~ithoul having lo prepare “sliin” 3.digit
sacks. and also provide the opportunity
for the Poslal Service 10receive mail
sorted to a finer level than an area
distribution center (AOC) sack.
Accordingly. the Postal Service is
proposing reinstate. for only non-letler.
size Periodicals publications. an SCF
sack that would be prepared after ail
required S-digit and 3.dIgit sacks. end
prior lo prepanng required AOC sack..
PART Ill-[AMENDED]
It is proposed that preparacmn of the
SCF sack would be optional for the
persod beginning on the date the fine1
rule regarding Lhls notice is published
and ending on the effective dale of the
prepuauon rules that are placed in
effect es a result of the Docket No. R971 rate case proceedings. Upon
2. Revise the following secuons of the
implemenlalion of lhe preparerion rules Oomest~c Mad Manual es set forth
resulting from tie rate case proceedings, below:
2 of
1.2 Presort Levels
iRedesigna.te currenr I.?j through
1.2m as l.Zk through 1.2~ respectively;
insert new 1.2j to read es follows:]
i. Origin/optional envy SCF: The
separation includes packages for one or
more 3-digit .sreasserved by the same
sectional cenlcr facility [SCF) (see Looj)
m rx,hosTse.l;icc xca ;\c mail 1s
i-crificd.‘cntc>:ed. Subjcc: :o s:en&rd.
inis sepacarion LSrequ,red regardless of
the volume of mail.
.
.
1
.
.
1.3 Preparation Instructions
(Redesigna1.ecurrent 1.jj through 1.3~
as 1.3k throul:h 1.3q respectively: insen
new 1.3j to read as follows:]
j An origin/opuonal enlry SCF sack
contams all 5,digit and 3-digit pacitages
[regardless of quenhty) for the SCF in
whose service area the mail is verified.
At the mailer’s option such a sack may
be prepared for the SCF area of each
entry post office. This presort level
applies only to non-letter-size
Periodicals prepared in sacks
*
.
.
.
.
M030 Conleioerr
.
.
.
.
.
M03t Barcoded Labels
1.0 BASIC STANDARDS-TRAY
SACK LABEL5
_
_
.
AND
1.3 Content Line (Line 2)
[Amend Exhibit 1.3s by inserting the
following between 3-digit sack and
A!X sacks for PER F!ats-Automation
lo read es follows:i
Class am mailing UN
.
.
SCF SaCkS
%“rm” remable
Conten,line
I
.
.
377 PER FLTS SCF
BC’
.
.
[Amend Exhibit 1.3a by inserting the
following betwaen 3-digit sacks and
ADC
sacks for PER Flats-3/5 end Basic
LOread as follows:i
page
ATpAcHIIENT
Federal
PER Flats-J/5
SCF sack
.
.
Regisrer
/ Vol.
and Basic
.
384 PER FLTSSCF
NON EC
.
[Amend Exhrblt 1.3.aby lnsening the
following between X-digit sacks and
AIJC iacks for NEWS Flatshutomahm to read as followxl
.
.
SCF sacks
To 1~~~/==-T34-4
62. No. 178 / Monday, September
3 of
3
~0 luXSt,NSE
15. ,997
preparti. required oripinloptional entry
3.digit sacks must not bc prepared and
required orlgmlaptianal entry SCFsacks
must bc prepared.
3.0 SACK PREPARATION (FLAT-SIZE
PIECES AND IRREGULAR PARCELS)
3.1 Sack Preparation
IRedesignate currenr 3 le and 3sf as
3.11 and 3.18 respecrlvely: insert new
,.-I= 10 read 2s iollows:t
Sack size. preparation sequence. and
Lane 1 labeling:
.
.
.
.
.
e. Optional SCF: required at 24 pieces
[n’o mimmum for required origin/
optional entry SCF]. optional with,one
six.piece package minimum except
under 1.5; for Line I. use Looz, column
C.
, proposed Ruies
48193
under 1.7: for Line I. use ~002. Coiumn
C.
.
*
*
.
An appropriate amendment to 39 cm
111.3 IO reflect these changes wili be
published if [he proposal is adopted.
FEDERAL EMERGENCY
MANAGEMENT AGENCY
41 CFR Pari 67.
[mcket No. EM&7227j
Proposed Flood Elevation
Dstemlnatlons
.
.
.
1
.
.
.
PIGENCY:
Federal Emeqency
6’7 NEWSFLTS SCF
Management Agency. FEMA.
BC
ACTION:Proposed ,w,e.
.
.
.
1.0 BASIC STANDARDS
.
.
.
.
SLMY*RI: Technicd dorma~jon or
[Amend Exhibit 1.3a by insening the
cc~mmentsam requested on the
1.7 Exception-Periodic&
following between 3.digit sacks and
proposed base 11% annual chance) flood
AJX sacks for NEWS Flats-315 and
e&a&xx and proposed base flood
AS a general exception to 3.1~. 3.lb.
Basic to read as follows:]
el~svarionmodifications lor ihe
end 3.2a Lhrougb 3.2~. Periodicals may
communities Listed Mow. The base
be prepared in packages containing
NEWS Flats-315 and Basic
flood elevations are the bssis for the
fewer than six pieces. and in sacks
floodplain management measures that
conmbin~ as lew as one such package.
the community is requucd either to
when the publisher determines that
adopt or to show evidence of being
such preparalion unpmves sex-ace.
already in effect in order to qualify or
These low-volume packages may he
.
.
.
.
.
remain qualsed for partlciparion ID the
SCF Sacks ..,......_. 484 NEWSFLTS SCF placed on S-digit. )-digit. and SCF
National Flood Insurance Propam
pallets under MO45
NON EC
(NFIP).
1.8 Optional S&Sack-Periodicals
.
.
.
.
.
DATES:The comment period is ninety
Mailers of Periodicals have the option (90) days following tie second
to prepare an SCF sack level. If mailers
~MM?OO
Periodicals (Nonautomationl
publication of this proposed rule m a
choose to prepam SCF sacks. they rnus~ newspaper of local circuiatlon in each
1.0 BASIC STANDARCS
prepare them for all SCF destinatmns ia community.
.
.
.
,
.
the mailing for w&h there are 2.4or
AOI?RESSES:
The proposed base flood
more pieces prepared in s-digit or 3eievations ior each community are
1.5 Low-Volmc Packagn and Saclo
digit packages. under 3.2. When SCF
available for inspection at the office of
As a general exception LO2.4b through sacks are prepared, required origiol
the Chief becurive OfEcer of each
2.4d and 3.~ through 3.1e. non-letteroptional entry 3.digit sacks must not be community. The respective addresses
size Penodicals may be prepared in
prepared and required ori~n/ophonal
are iisied m rhe following table.
packages containing fewer than SIX
enq SCF sacks must be prepared.
FORFURTHER
lHFORYATlOH
CONTACT:
1
.
*
.
.
pieces. end in sacks contaming as few
Frederick H. Shamrocks.II.. Chiei.
as one such package. when the
Hazard Identification Br&,c.h. Mitigation
3.0 PERIODICALS
publisher detenner that such
9irectorale. 500 C Street SW,
*
.
.
.
preparation improves service. These
Washinaton. DC 20412. I2021 6:&27X
low-volume packages may be placed on
3.2
Sack
Preparation
SUFPLE.MEHTARI
,HFORH*T,OH:
The
5-diglt. 3.digit. and SCF pallets under
Fed,erai Emergency Management Agency
M&5.
IRenumber 3.2~ and 3.2d as 3.2d and
FEMA or Agency) proposes 10make
3.2e respetively: add new 3.1~ to read
1.6 Optional SCF Sack
determinations of base flood elevations
as rollows:]
Mailers of non-letter-size Periodicals
and modihed base flood elevadons for
Sack size. preparation sequence. and
have tie option LOprepare a~,SCF sack
each communitv Listed below. in
Line 1 labeling:
level. If mailers choose to prepare SCF
accordance wi& section 110 of the
.
.
.
.
.
sacks. they r”L1stprepare them for all
Flood Disaster Protection An of 1973.
SCF destinanons in the maling for
c. Optional SCF: required at 24 pieces 42 U.S.C. ,104. and 44 CFR 6i.iIal.
whxh rhere are 24 or more pieces
These proposed base flood and
[no mmimum for required origin/
prepared in s-digit or 3.diglt packages.
optional eny SCFI. optional with one
modified base flood elevations. rogerher
under 3.1. When SCF sacks are
with the floodplain management critena
six-piece package minimum except
RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS TAUFIQUE
TO INTERROGATORIES
OF NATIONAL NEWSPAPER ASSOCIATION (NNA)
NNAIUSPS T34-5
Please provide estimates of the percentages of periodicals the Postal Service
estimates will use the newly proposed basic, 3-digit, 5-digit and carrier route
rates.
RESPONSE
The Postal Service’s estimate of the volumes in various presort categories
for Regular Rate Periodicals and Within County Periodicals are provided in
USPS-T-34,
Workpaper
RR-J and USPS-T-34,
Workpaper WC-J. For percent
estimates for Regular Rate Periodicals see my response to lW/USPS-T26-2
[d],
page 3 of 3, redirected from witness Seckar, and filed September ‘9. 1997
The Within County estimated percent breakdown.for
the test year for the
proposed basic, 3-digit. 5digit, and carrier route rates is as follows:
Basic
3-Digit
5-Digit
Carrier Route
16%
1~~
68%
RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS TAUFIQUE
TO INTERROGATORIES
OF NATIONAL NEWSPAPER ASSOCIATION (NNA)
NNMJSPS
T34-6
Please refer to your description of periodicals mail on page 4 of your testimony.
a. Please provide any studies or surveys indicating what percsentage of
within-county periodical mail represents the following categories
described by you: magazines, newspapers, newsletters and bulletins.
RESPONSE
It is my understanding
that the Postal Service has not conducted any
studies or surveys to estimate the percent of Wrthin County periodicals that are
magazines,
newspapers,
newsletters,
The Postal Rate Commission
or bulletins.
published a study, dated June 18, 1986,
and titled “REPORT TO THE CONGRESS:
PREFERRED
RATE STUDY”. that
contains a breakdown of Within County mail for newspapers,
magazines.
newsletters,
and
RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS TAUFIQUE
TO INTERROGATORIES
OF NATIONAL NEWSPAPER ASSOCIATION (NNA)
NNA/USPS T34-7
Please explain your statement on page 20 of your testimony: “pas:sthroughs
used for Within-County rates are by necessity much smaller than other classes
because the cost study used is for Nonprofit mail.”
a. Please confirm that the study referenced in this statement was filed by the
Postal Service as LR-H-l 11. If you so not confirm, please Iprovide this
study.
b. Please explain in detail why it calls for mitigation of passthr’oughs for
within-county.
c. Are you sponsoring LR-H-l 11 in this case? If not, to your knowledge, is
any other ‘witness sponsoring that study for use in this case?
d. If the Postal Service had not decided to assign all non-transportation
costs savings to the piece rate for within-county periodicals, what would
the discounts for the piece and pound rates have been?
RESPONSE
a. Confirmed.
b. The choice of passthroughs
in the proposed rate design for WIthin County
was based on the premise of mitigating rate shock,
by keeping the increase in
each rate cell in a relatively tight band around the proposed average increase of
2.2 percent. The word ‘passthroughs’
for Within County in the quoted statement
on page 20 of my testimony generally refers to all passthroughs
used in the
Within County rate design, because separate cost studies were not conducted
for the Within County subclass. All cost avoidance estimates were based on cost
studies for Nonprofit Periodicals. (See LR-H-III
The passthroughs
and USPS-T-26).
are mitigated, primarily, for two reasons. First, as indicated
above, a goal in rate design was to mitigate rate shock. If larger passthroughs
RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS TAUFIQUE
TO INTERROGATORIES
OF NATIONAL NEWSPAPER ASSOCIATION (NNA)
NNA/USPS T34-7[b] continued, page 2 of 3
had been used, the pound rate for “general delivery” and the piec’e rates for less
finely prepared mail, particularly Basic, would have increased dramatically
Second, I wanted to be conservative
in my choice of passthroughs
due to the
nature of the cost information itself. The Within County rate design employs
Nonprofit cost avoidances.
By its very definition, Within County m;ail is distributed
in a relatively small geographic
area. Consequently,
on the pound side and ‘Basic Non-Automation’
the ‘General Delivery’ mail
mail on the piece side, in most
instances, will receive fewer handlings than non-DDU and basic presort mail for
other categories which can be handled at several facilities. As such, I believe
that Within County DDU dropshipment
the resulting cost avoidances
and basic presort is lower cost mail, and
are likely to be lower.
c. I did not conduct this study. Results of this study are used in the proposed rate
design, and I am available to answer any questions regarding this application of
the study. Other questions about LR H-l 11 can be directed to the Postal
Service. Please see the Postal Service’s response to ABPIUSPS-1
in this
regard
d. The Postal Service did not decide to assign all non-transportation
cost
RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS TAUFIQUE
TO INTERROGATORIES
OF NATIONAL NEWSPAPER ASSOC:IATION (NNA)
NNAIJSPS
T34-7[d] Continued,
Page 3 of 3
savings to the piece rates. Please see USPS-T-34, Workpaper
WC-F, page 1.
The per pound cost savings of $0.045 are recognized with a 30 percent
passthrough
to calculate a per pound discount of $0.014.
I
RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS TAUFIQUE
TO INTERROGATORIES
OF NATIONAL NEWSPAPER ASSOCIATION (NNA)
NNAIUSPS T34-8
What percentage of Periodicals mail consists of letter-shaped mail? What
percentage of within-county mail consists of letter-shaped maiil?
RESPONSE
Letter-shaped
(Letters and Cards) mail makes up 8.33 percent of Periodicals
mail (See Library Reference H-129, Page l-4). Similar information
for Within County mail
-
is not available
DECLARATION
I, Altaf
answers
Dated:
H. Taufique,
declare
are true and correct,
+6
under penalty
of perjury
to the best of my knowledge,
/9 7
----
that the foregoing
information,
and belief.
CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoing document
participants
of record in this proceeding
in accordance
with section 12 of the Rules of
Practice.
G3zAQq/ f-24-A
David H. Rubin
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-I 137
September 26, 1997
upon all