POSTAL RATE COMMISSION
WASHINGTON,
DC 20266-0001
POSTAL
RATE AND FEE CHANGES,
1997
DOUGLAS F. CARLSON
INTERROGATORIES
TO UNITED STATES POSTAL
WITNESS MICHAEL K. PLUNKETT
(DFCIUSPS-T40-16-22)
September
SERVICE
l&l997
Pursuant to sections 25 and 26 of the Roles of Practice, I, Douglas
interrogatories
to United States Postal Service witness
If the witness
that the witness
is unable to provide a complete,
F. Carlson,
Michael K. Plunkett.
responsive
answer to a cluestion,
redirect the question to a witness who can provide a complete,
In the alternative,
hereby submit
I request that the question be redirected
I request
responsive
answer.
to the Postal Service for an institutional
response.
The instructions
incorporated
contained
in my interrogatories
to witness
Fronk (DFWUSPS-T32-1-7)
herein by reference.
Respectfully
Dated:
September
submitted,
15, 1997
DOUGLAS
F. CARLSON
are
DFCIUSPS-T40-16,
a.
agreement,
individual,
Do any instances
understanding,
or procedure,
or government
Forms 3811, Domestic
exist in which the Postal Service,
pursuant to a written or unwritten
regularly or routinely delivers to any plrivate company,
agency other than the Postal Service letters, flats, or parcels with the
Return Receipt, still attached and allows the recipient,
under the visual supervision
of a postal employee,
at a later time and not
to sign the Forms 3811, indic:ate the date of
receipt on the Forms 3811, and then return the Forms 3811 to the Postal Service for return to the
sender2
b.
reconcile
If your answer to part (a) is yes, please explain fully, cite all known examples,
your response
with applicable
and
postal regulations.
DFCIUSPS-T40-17,
a.
agreement,
Do any instances
understanding,
any private company,
or procedure,
individual,
the Forms 3811, Domestic
allows the recipient,
exist in which the Postal Service, pursuant to a wlritten or unwritten
regularly or routinely (1) delivers letters, flats, or parcels to
or government
agency other than the Postal Service,
Return Receipt, prior to or simultaneously
at a later time and not under the visual supervision
with delivery,
(2) removes
and then (3)
of a postal employee,
to sign
the Forms 3811, indicate the date of receipt on the Forms 3811, and then return the Forms 3811 to
the Postal Service for return to the sender?
b.
reconcile
If your answer to part (a) is yes, please explain fully, cite all known ~examples, and
your response
with applicable
postal regulations.
DFCIUSPS-T40-16.
a.
agreement,
Do any instances
understanding,
private company,
381’1, Domestic
exist in which the Postal Service, pursuant to a written or unwritten
or procedure,
individual,
regularly or routinely delivers letters, flats, or parcels to any
or government
agency other than the Postal Service, with the Forms
Return Receipt, either still attached to or already removed
from the letters, flats, or
parcels, and then allows the recipient to sign the Forms 3811 under conditions
Forms 3811 from being under the visual supervision
of a postal employee
that prevent the
while the recipient
is
signing them?
b.
reconcile
If your answer to part (a) is yes, please explain fully, cite all known examples,
your response
with applicable
and
postal regulations.
DFCIUSPS-T40-19.
a.
Please confirm that POM 5 822.112 provides that return receipts mlust be mailed not
later than the first workday
after delivery.
If you do not confirm, please explain.
2
b.
Please confirm that the POM 5 822.112 requirement
return-receipt
c.
service.
in part (a) adds value to
If you do not confirm, please explain.
Please refer to the two options presented
and confirm that the POM § 822.112 requirement
valuable
described
in the introductory
described
portion1 of DFCIUSPS-T40-I
in part (a) tends to Imake option (1) more
to many mailers than option (2). If you do not confirm,
please explain.
DFCIUSPS-T40-20
a.
Please refer to your response to DFCIUSPS-T40-8
a delivery record for return receipt for merchandise
in DMM 5 59151.2.
If you do not confirm,
for return receipt for merchandise
is not attributed
to a special service that is listed
please explain fully and, if applicable,
would be attributed
given that return receipt for merchandise
and confirm that the cost of creating
to a special sewice
can be purchased
explain why costs
listed in DMM g S915.1.2,
independently
of any other special
service.
b.
Please confirm that all costs for return receipt for merchandise,
creating a delivery record at the delivery post office, are attributed
merchandise.
If you do not confirm,
including
exclusively
the cost of
to return receipt for
please explain.
DFCIUSPS-T40-21
a.
Will delivery-confirmation
b.
When a customer
window,
service provide proof of mailing?
who purchases
manual delivery-confirmation
Please explain
service leaves the
will he have a dated receipt proving that he mailed the item on a particular
c.
Will delivery confirmation
provide a record of delivery at the deliven,
date?
post office that is
similar to the record of delivery that is created for certified mail or return receipt for merchandise?
DFCIUSPS-T40-22
a.
customer
Please confirm that, under the Postal Service’s
in Docket No. R97-1, a
who sends a piece of mail via Priority Mail will have the option of purchasing
delivery confirmation
$1.45.
proposal
for $0.35 as well as a return receipt for the proposed
If you do not confirm,
b.
delivered,
Suppose
confirmation
information
return-receipt
to whom the mail piece was
the date of delivery, and the address of delivery (if the address is different
This mailer also desires only whatever
service may or may not provide.
described
mail via Priority Mail (using delivery confirmation
from the
proof of mailing that the delivety-
Please confirm that a mailer who desires only the
in this question will be able to obtain that information
to obtain tlhis information
fee of
please explain.
a mailer desires only a return receipt showing
address on the mail piece).
manual
for $1.80 if he sends his
and return receipt) but will be required to pay $3.00
if he sends his letter via First-Class
3
Mail (since he will need to purchase
certified
mail and return receipt).
Please explain your answer.
on the proof of mailing that certified
If you confirm
C.
(Note that this mailer places no value
mail provides.)
in part (b), please explain why a customer
who uses IFirst-Class
Mail
should be required to pay $1.20 more than if he used Priority Mail, just to obtain the same
information.
d.
Please explain why a customer
the services
customer
of certified mail and directly obtain delivery confirmation
who uses First-Class
not want to purchase
e.
should not be available
delivery-confirmation
service should not be offered for
for non-merchandise
that is sent via First-Class
and would be available
that would provide the same services
for all First-Class
service might or might not be offered in conjunction
Mail. In your answer,
with delivery-confirmation
Please explain why the services described
would not provide a valuable
as return receipt
consider
that this
service.
in parts (e), (f), and (g), if they were
OF SERVICE
I hereby certify that I have this day served the foregoing
of record in accordance
to offer a
service to customers.
CERTIFICATE
document
upon the required
with section 12 of the Roles of Practice and sections
3(C) of the Special Rules of Practice.
DOUGLAS
September
Emeryville,
Mail
Please explain why the Postal Service would support or oppose a proposal
for merchandise
participants
mail even if he does
Mail and return receipt.
new service called ‘Retlurn Receipt Service’
available,
certified
Please explain why a service that is identical in function to return resceipt for
merchandise
h.
and a return receipt, while a
mail.
who wish to use First-Class
f.
g.
certified
Mail must pay for the more-expensive
Please explain why the proposed
customers
who uses Priority Mail should have the option to forgo
15, 1997
California
4
F. CARLS;ON
3(B) and