BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
POSTAL RATE AND FEE CHANGES, 1997
i(CEIYL:~
J5H 22
rI ,+./ ~1 ‘$3
r ,~T,.,,<j:: ,‘f~
,,;
(,:ii;,:~~.i i,,, ,,:,(~,:,:,,(:i
#
i
Docket No. R97-1
UNITED STATES POSTAL SERVICE
INTERROGATORIES
AND REQUESTS FOR PRODUCTION
THE AMERICAN BUSINESS PRESS WITNESS
(USPS/ABP-T3-l-34)
OF DOCUMENTS
CAVNAR
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
Press witness Cavnar:
to the American
Business
USPSIABP-T3-l-34.
Respectfully submitted,
UNITED STATES POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
w
B-7,
Susan M. Duchek
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-I 137
(202) 268-2990; Fax -5402
January 22, 1998
n&-IA-P-
USPGABP-T3-1.
For each year fiscal year (or calendar year if fiscal year is unavailable)
from 1986 to present,
Publishing Corporation
USPS/ABP-T3-2.
please
provide
a list of publications
and mailed at second-class
published
by lntertec
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 interrogatory
number
1 the following information:
(4
The number of issues mailed.
(b)
The average number of editions (versions) per issue.
w
An indication of the kind or type of each version.
USPWABP-T3-3.
For each fiscal year (or calendar year if fiscal year is unavailable) from
1986 to present, please provide the total volumes mailed at second-class
periodical regular rates for each publication listed in response to interrogatory
regular or
number
1.
USPYABP-T3-4.
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 required
number 1.
presort rates for each publication
regular or periodical
listed in response to interrogatory
USPS/ABP-T3-5.
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
3-digit
interrogatory
city&digit
presort
rates for each publication
regular or periodical
listed in response
to
number 1.
USPWABP-TJ-6.
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 carrier route presort rates for each publication listed in response to interrogatory
number 1.
USPSIABP-TB7.
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 destination
to interrogatory
delivery office discount rates for cacti publication
For each fiscal year (or calendar year if fiscal year is unavailable) from
1986 to present, please provide the volumes mailed at second-class
destination
interrogatory
listed in response
number 1.
USPS/ABP-T3-8.
regular
regular or periodical
SCF discount
rates for each publication
rtegular or periodical
listed in response
to
number 1.
USPSYABP-T3-9.
For each fiscal year (or calendar year if fiscal year is unavailable) from
1986 to present, please provide the volumes mailed at second-class
2
regular or periodical
regular high density discount rates for each publication listed in respon’se to interrogatory
number 1.
USPS/ABP-T3-10.
For each fiscal year (or calendar year if fiscal year is unavailable)
from 1986 to present, please provide the volumes mailed at second-class
periodical
regular saturation
interrogatory
discount rates for each publication
regular or
listed in response
to
number 1.
USPSIABP-T3-11.
For each fiscal year (or calendar year if fiscal year is unavailable)
from 1986 to present, please provide the required presort volumes mailed at secondclass regular
publication
or periodical
regular
prebarcoded
listed in response to interrogatory
USPSJABP-T3-12.
letter size discount
rates for each
number I.
For each fiscal year (or calendar year if fiscal year is unavailable)
from 1986 to present, please provide the volumes mailed at secorld-class
periodical
regular prebarcoded
response to interrogatory
USPS/ABP-T3-13.
flat size discount
rates for each publication
listed in
number 1.
For each fiscal year (or calendar year if fiscal year is unavailable)
from 1986 to present, please provide the 3-digit cityl5digit
class regular or periodical regular prebarcoded
publication
regular or
listed in response to interrogatory
3
volumes mailed at second-
3-digit letter size discount rates for each
number 1.
USPS/ABP-T3-14.
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 secondclass regular or periodical regular prebarcoded
publication
listed in response to interrogatory
USPWABP-T3-15.
5-digit letter size discount 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&digit
class regular
publication
or periodical
regular
prebarcoded
listed in response to interrogatory
USPS/ABP-T3-16.
volumes mailed at second-
flat size discount
rates for each
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
mailed at second-class
publication
regular
or periodical
listed in response to interrogatory
USPSJABP-T3-17.
regular
rates for zones
l&2
for each
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
mailed at second-class
weight
regular or periodical regular rates for zone 3 for each publication
listed in response to interrogatory
USPSIABP-T3-18.
weight
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
4
mailed at second-class
regular or periodical regular rates for zone 4 for each publication
listed in response to interrogatory
USPS/ABP-T3-19.
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 aidvertising weight
mailed at second-class
regular or periodical regular rates for zone 5 fair each publication
listed in response to interrogatory
USPS/ABP-T3-20.
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
mailed at second-class
regular or periodical regular rates for zone 6 for each publication
listed in response to interrogatory
USPS/ABP-T3-21.
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
mailed at second-class
weight
regular or periodical regular rates for zone 7 for each publication
listed in response to interrogatory
USPSJABP-T3-22.
weight
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 8 for each publication
listed in response to interrogatory
number 1.
5
USPS/ABP-T3-23.
For each fiscal year (or calendar year if fiscal year is unavailable)
from 1986 to present, please provide the average percentage
mailed at second-class
regular or periodical regular rates for each publication
response to interrogatory
USPS/ABP-T3-24.
of nonadvertising
content
listed in
number 1.
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)
5-digit pallets
(b)
3-digit pallets
(4
SCF pallets
(d)
ADC/SDC
w
BMC pallets
(f)
Mixed-BMC
USPWABP-T3-25.
pallets
pallets.
For each fiscal year (or calendar year if fiscal year is unavailable)
from 1986 to present, for those volumes mailed on pallets at second-class
periodical regular rates for each publication
listed in response to interrogatory
regular or
number
1, please provide the average number of pieces per pallet by the following pallet presort
levels:
(a)
5-digit pallets
6
(4
3-digit pallets
(4
SCF pallets
(d)
ADCKSDC pallets
W
BMC pallets
(9
Mixed-BMC
USPWABP-T3-26.
pallets.
For each fiscal year (or calendar year if fiscal year is unavailable)
from 1986 to present, for those volumes mailed on pallets at second-class
periodical regular rates for each publication listed in response to interrogatory
regular or
number
1, please provide the average pallet weight by the following pallet presort levels:
(4
5-digit pallets
(b)
3-digit pallets
(cl
SCF pallets
(4
ADCEDC
W
BMC pallets
(9
Mixed-BMC
USPSJABP-T3-27.
pallets
pallets.
For each fiscal year (or calendar year if fiscal year is unavailable)
from 1986 to present,
please provide the volumes
mailed in sacks at second-class
regular or periodical regular rates for each publication listed in response to interrogatory
number 1 by the following sack presort levels:
(a)
Carrier route(s) sacks
(b)
Firm sacks
(c)
5-digit sacks
(d)
3-digit unique city sacks
(4
3-digit sacks
(9
SCF sacks
(9)
ADCLSDC sacks
PO
Mixed sacks.
USPS/ABP-T3-28.
For each fiscal year (or calendar year if fiscal year is unavailable)
from 1986 to present, for those volumes mailed in sacks at second-class
periodical regular rates for each publication listed in response to interrogatory
regular or
number
1, please provide the average number of pieces per sack by the following sack presort
levels:
69
Carrier route(s) sacks
(b)
Firm sacks
(4
5-digit sacks
W
3-digit unique city sacks
(4
3-digit sacks
(9
SCF sacks
(9)
ADClSDC
(h)
Mixed sacks.
sacks
8
USPWABP-T3-29.
For each fiscal year (or calendar year if fiscal year is unavailable)
from 1986 to present, please provide the volumes mailed in trays at second-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
(cl
5-digit trays
(4
3-digit unique city trays
(4
3-digit trays
(9
SCF trays
(9)
ADWSDC
(h)
Mixed trays.
USPS/ABP-T3-30.
trays
For each fiscal year (or calendar year if fiscal year is unavailable)
from 1986 to present, for those volumes
periodical
mailed in trays at second-class
regular rates for each publication listed in response to interrogatory
regular or
number
1, please provide the average number of pieces per tray by the following tray presort
levels:
(4
Carrier route(s) trays
@I
Firm trays
(c)
5-digit trays
(4
3-digit unique city trays
9
(e)
3-digit trays
(9
SCF trays
(9)
ADWSDC
0.0
Mixed trays.
USPS/ABP-T3-31.
trays
For each fiscal year (or calendar year if fiscal year is unavailable)
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.
USPS/ABP-T3-32.
For each fiscal year (or calendar year if fiscal year is unavailable)
from 1986 to present, for those volumes mailed in bundles at second-class
periodical regular rates for each publication
listed in response to interrogatory
regular or
number
1, please provide the average number of pieces per bundle.
USPYABP-T3-33.
For each fiscal year (or calendar year if fiscal year is unavailable)
from 1986 to present, please provide the volumes mailed at second-class
periodical regular rates that were plant loaded in USPS provided transportation
publication
listed in response to interrogatory
USPSIABP-T3-34.
regular or
for each
number I.
Please also provide all data furnished in response to interrogatories
1 through 33 above in electronic format.
10
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.
-LA,, 2?? AL---~
Susan M. Duchek
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-I 137
January 22, 1998
upon all