BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0ooj~~
POSTAL RATE AND FEE CHANGES, 1997
INTERROGATORIES
1
REcEiVEI!
i2
il 42 i’li ‘9
Docket No. R97-I
UNITED STATES POSTAL SERVICE
AND REQUESTS FOR PRODUCTION
DOW JONES & COMPANY, INC.
(USPSIDJ-1-34)
OF DOCUMENTS
TO
Pursuant to rules 25 and 26 of the Rules of Practice and Procedure and rule 2 of
the Special Rules of Practice, the United States Postal Service directs the following
interrogatories
and requests for production of documents to Dow Jo,nes & Company,
Inc.: USPSIDJ-1-34
Respectfully submitted,
UNITED STATES POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
L
m.Lb-
Susan M. Duchek
475 L’Enfant Plaza West, SW.
Washington, D.C. 20260-I 137
(202) 268-2990; Fax -5402
January 22, 1998
USPSIDJ-I,
For each year fiscal year (or calendar year if fiscal year iis unavailable) from
1986 to present, please provide a list of publications
mailed at second-class
USPSIDJ-2.
published by your company and
regular or periodical regular rates.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please for each publication listed in response to in,terrogatory number
1 the following information:
(a)
The number of issues mailed.
(b)
The average number of editions (versions) per issue.
(c)
An indication of the kind or type of each version.
USPSIDJ-3.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the total volumes mailed at seco’nd-class
periodical regular rates for each publication listed in response to interrogatory
from
regular or
number
1.
USPSIDJ-4.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volumes mailed at second-class
regular required
number 1.
presort rates for each publication
from
regular or periodical
listed in response to interrogatory
USPSIDJ-5.
For each fiscal year (or calendar year if fiscal year is IJnavailable) from
1986 to present, please provide the volumes mailed at second-class
regular
3-digit
cityl5digit
presort
rates for each publication
regular or periodical
listed in response
to
interrogatory
number 1.
USPSIDJ-6.
For each fiscal year (or calendar year if fiscal year is ,unavailable) from
1986 to present, please provide the volumes mailed at second-class
regular or periodical
regular carrier route presort rates for each publication listed in response to interrogatory
number 1.
USPSIDJ-7.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volumes mailed at second-class
regular destination
to interrogatory
USPSIDJ-8.
delivery office discount rates for each publication
re’gular or periodical
listed in response
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volumes mailed at second-class
regular
from
destination
SCF discount
rates for each publication
regular or periodical
listed in response
interrogatory
number I.
USPSIDJ-9.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volumes mailed at second-class
2
from
to
from
regular or periodical
regular high density discount rates for each publication listed in response to interrogatory
number 1.
USPS/DJ-10.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volumes mailed at second-class
from
regular or periodical
regular saturation discount rates for each publication listed in response to interrogatory
number 1.
USPSIDJ-II.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the required presort volumes mailed at second-class
regular or periodical regular prebarcoded
listed in response to interrogatory
USPWDJ-12.
letter size discount rates for each publication
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volumes mailed at second-class
regular prebarcoded
interrogatory
USPSIDJ-13.
flat size discount rates for each publication
regular or periodical
listed in response to
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the 3-digit cityl5digit
regular or periodical
publication
from
regular prebarcoded
volumes mailed at second-class
3-digit letter size discount
listed in response to interrogatory
3
from
number I.
rates for each
USPSIDJ-14.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the 3-digit city&digit
regular or periodical
publication
regular
prebarcoded
USPSIDJ-15.
volumes mailed at second-class
5-digit letter size discount
listed in response to interrogatory
from
rates for each
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the 3-digit city/5-digit volumes mailed at second-class
regular or periodical
regular prebarcoded
listed in response to interrogatory
USPSIDJ-16.
flat size discount rates for each publication
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the volume, total weight and advertising weight mailed
at second-class
regular or periodical regular rates for zones 182 for each publication
listed in response to interrogatory
USPSIDJ-17.
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volume, total weight and advertking
at second-class
USPS/DJ-18.
weight mailed
regular or periodical regular rates for zone 3 for each publication
in response to interrogatory
from
listed
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the volume, total weight and advertising weight mailed
4
at second-class
regular or periodical regular rates for zone 4 for each, publication
in response to interrogatory
USPSIDJ-19.
listed
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the volume, total weight and advertising weight mailed
at second-class
regular or periodical regular rates for zone 5 for each, publication
in response to interrogatory
USPSIDJ-20.
listed
number I.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the volume, total weight and advertising weight mailed
at second-class
regular or periodical regular rates for zone 6 for eact. publication
in response to interrogatory
USPSIDJ-21,
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volume, total weight and advertking
at second-class
USPSIDJ-22.
listed
number I.
For each fiscal year (or calendar year if fiscal year is unavailable).from
1986 to present, please provide the volume, total weight and advertking
at second-class
from
weight mailed
regular or periodical regular rates for zone 7 for each publication
in response to interrogatory
listed
weight mailed
regular or periodical regular rates for zone 8 for each publication
in response to interrogatory
number 1.
5
listed
USPSIDJ-23.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present,
please provide the average
mailed at second-class
of nonadvertising
content
regular or periodical regular rates for each publication
response to interrogatory
USPSIDJ-24.
percentage
from
listed in
number I.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the volumes mailed on pallets at second-class
regular
or periodical regular rates for each publication listed in response to interrogatory
number
1 by the following pallet presort levels:
(a)
&digit pallets
(b)
3-digit pallets
6)
SCF pallets
(d)
ADWSDC
(6
BMC pallets
(0
Mixed-BMC
USPSIDJ-25.
pallets
pallets.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present,
for those volumes
mailed
periodical regular rates for each publication
on pallets at second-class
from
regular
listed in response to interrogatory
or
number
1, please provide the average number of pieces per pallet by the following pallet presort
levels:
(a)
5-digit pallets
6
(b)
3-digit pallets
(cl
SCF pallets
(d)
ADClSDC
(e)
BMC pallets
(9
Mixed-BMC
USPSIDJ-26.
pallets
pallets
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present,
for those volumes
mailed on pallets at second-class
from
regular
periodical regular rates for each publication listed in response to interrogatory
or
number
1, please provide the average pallet weight by the following pallet presort levels:
(4
5-digit pallets
lb)
3-digit pallets
(4
SCF pallets
(4
ADWSDC
W
BMC pallets
(9
Mixed-BMC
USPSIDJ-27.
pallets
pallets.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, please provide the volumes mailed in sacks at second-class
periodical regular rates for each publication listed in response to interrogatory
1 by the following sack presort levels:
(a)
Carrier route(s) sacks
7
from
regular or
number
(b)
Firm sacks
(4
5digit
(‘4
3-digit unique city sacks
(e)
3-digit sacks
(9
SCF sacks
(9)
ADClSDC
W
Mixed sacks.
USPS/D&28.
sacks
sacks
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, for those volumes mailed in sacks at second-class
regular rates for each publication
listed in response to interrogatory
from
regular or periodical
number I, please
provide the average number of pieces per sack by the following sack presort levels:
(a)
Carrier route(s) sacks
W
Firm sacks
(cl
5digit
(d)
3-digit unique city sacks
(4
3-digit sacks
(9
SCF sacks
(9)
ADC/SDC
(h)
Mixed sacks.
sacks
sacks
8
USPSIDJ-29.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the volumes mailed in trays at secon’d-class regular or
periodical regular rates for each publication listed in response to interrogatory
number
1 by the following tray presort levels:
(4
Carrier route(s) trays
(b)
Firm trays
Cc)
5-digit trays
(4
3-digit unique city trays
(4
3-digit trays
(9
SCF trays
(9)
ADWSDC
03
Mixed trays.
USPSIDJ-30.
trays
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present, for those volumes mailed in trays at second-class
regular rates for each publication
listed in response to interrogatory
regular or periodical
number 1, please
provide the average number of pieces per tray by the following tray presort levels:
(4
Carrier route(s) trays
(b)
Firm trays
(4
5-digit trays
(4
3-digit unique city trays
W
3-digit trays
from
(9
SCF trays
(!a
ADClSDC
(h)
Mixed trays.
USPSIDJ-31.
trays
For each fiscal year (or calendar year if fiscal year is iunavailable) from
1986 to present, please provide the volumes mailed in bundles at second-class
regular
or periodical regular rates for each publication listed in response to interrogatory
number
1.
USPSIDJ-32.
For each fiscal year (or calendar year if fiscal year is unavailable)
1986 to present,
for those volumes
mailed in bundles
at second-class
periodical regular rates for each publication listed in response to interrogatory
from
regular
or
number
1, please provide the average number of pieces per bundle.
USPSIDJ-33.
For each fiscal year (or calendar year if fiscal year is unavailable)
from
1986 to present, please provide the volumes mailed at second-class
regular or periodical
regular rates that were plant loaded in USPS provided transportation
for each publication
listed in response to interrogatory
USPSIDJ-34.
number I.
Please also provide all data furnished
through 33 above in electronic format.
10
in response to interrogatories
1
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 1.2 of the Rules of
Practice.
A
Js?LfcLm
Susan M. Duchek
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-I 137
January 22, 1998
upon all