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DOCKET SECTION
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POSTAL RATE AND FEE CHANGES,
1997
TESTIMONY
CAROLYN A.
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1
Docket
No.
R97-1
OF
EMIGH
CONCERNING RATES FOR NONPROFIT
STANDARD MAIL
(A)
ON BEHALF OF
NATIONAL
FEDERATION
OF NONPROFITS
Please
about
addrsss
questions
this
(document
to:
George E.
Nonprofit
Suite
1250
Miller
Service
Group
400
24th
Washington,
Street,
D.C.
N.W.
20037
202/466-6620
Robert
S. Tigner
National
Federation
Nonprofits
of
Suite
822
815 15th
Street,
Washington,
N.W.
D.C.20005-2201
202/466-6620
December
30,
1997
Counsel
for the National
Federation
of Nonprofits
TABLE OF CONTENTS
Page
Autobiographical
Sketch.
... .................. ........ ..
1
......... ..........
results.
3
I*
Overview
A.
Fair
and equitable
nonprofit
Congressional
policy
reflect
B.
Evidence
C.
This
postal
discriminatory
D.
Conclusion......
II.
Analysis
of
discriminatory
rate
of
rates:
historical
pricing......................
4
may not prevent
proceeding
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
pricing..
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Proposed
Disparate
Rates
of
Change.........
13
My name
is
profit
Service
legal,
economic,
to
I was
and
Institut
the
School
and
Bologna,
I have
House
of
Advisor
Advanced
also
economist
In
with
In
Avignon,
program
provides
services
at
of
1250
the
Clare-
a concentration
1969,
In
The John
Studies
in
I studied
France.
at
International
studied
the
industrial
graduate
level
am a third
of
1972
at
1972,
the
I com-
Hopkins
in
in
in
business,
to
1980,
the
to
Interstate
Majority
the
The
Univer-
Washington,
MC.
application
industry,
DC
In
in
the
and Foreign
and
the
School
The
late
of
Dr.
Law at
W. Edwards
statistical
United
Senate,
methods
Sta,tes
Senate
I was Economic
as professional
Investigations
Commerce
-l-
the
University
to
government.
I served
Leader.
eco-
Washington
of
and
I served
Oversight
at
Louis,
(antitrust
George
student
St.
the
organization
at
year
Representatives.
to
1970
Non-
DC 20037.
a member
relations.
graduate
was my mentor
From
in
that
headquarters
College,
CA,
the
consulting
Washington,
Pitzer
Francaises
University
management
its
in
Italy.
currently
Deming
House
of
at
Washington
in
international
two-year
firm
and management
Claremont,
dOEtudes
sity
and
a consulting
400,
from
in
I am a principal
NSG has
NW, Suite
graduated
economics
nomics)
("NSG"),
accounting,
Colleges,
pleted
Emigh.
organizations.
Street,
mont
A.
Group
nonprofit
24th
Carolyn
Committee.
Subcommittee
and
Policy
staff
of
the
Since
profits
the
I have
1981,
(formerly
interests
the
of
federal
Congress,
assisted
the
Nonprofit
nonprofit
Mailers
mailers
agencies,
National
state
Federation
Federation)
before
the
to
United
government,
of
and
Non-
represent
States
self-regulatory
organizations.
NOS.
the
ferred
I have
testified
R84-1,
R90-1,
Commission
mail
before
R94-1
conducted
the
and
in
in
1986
rates.
-2-
Postal
various
as part
Rate
Commission
regional
of
its
in
hearings
study
of
Docket
that
pre-
I.
Dverv&
A.
Fair
-ofit
rates:
con-s
resuJ&.
A regulated
rates.
rate
Two pieces
teristics,
pay
and
the
In
same
the
weight,
was--and
still
the
rate
Postal
of
mail
rate
within
tandem
Standard
should
each
Forgone
set
"institutional"
the
no more
than
their
pay
but
category,
respective
expects
a lower
rate
-3-
do
(or
i\ mail
the
direct
Act,
stream
costs
Congress
(or
costs
to
the
nonprofit
that
the
directed
"overhead")
costs
of
the
mark
to
the
comparable
objective
than
mail
than
than
mail
stream.
comparable
that
First,
consistently
of
than
one-half
less
:reasons.
Standard
The policy
mail.
A mail,
"attributable"
Reform
overhead
be charged
rate
the
A mail
Revenue
two
pieces
less
charac-
service--should
Standard
produce
nonprofit
fair
equal.
to
Thus,
the
of
for
tend
tlo produce
same handling
rates
shaped
Service's
everyone
will
different
uniformly
commercial
with
Thus,
purpose
pay
mailers
at
mail
the
category
in
to
nonprofit
profit
nonprofit
process
the
regulators
assign
and
is--substantially
in
level
commercial
commercial
Second,
same
the
counterparts.
to
the
being
more
cost
having
things
to
commercial
"direct")
of
of
be perceived
other
nonprofit
lighter
handle
mail--each
all
expect
should
receiving
rate,
historically
their
of
each
case
ratepayers
scheme
was
comparable
rates
comparable
that
to
rate
non-
commercial
should
commercial
serves
up used
rate.
a nonprofit
commercial
move
piece.
That's
Standard
costs
because
A mail
stream
may be no more
Standard
respect
periodic
to
rate
than
with
the
expect
this
kind
profit
rate
and
cally,
the
and
one-half
to
handle
the
of
mark
the
the
nonprofit
up for
overhead
mark
in
nonprofit
rates
tended
commercial
rate.
of
symmetry
its
rate
rate.
Forgone
Althouigh
the
This
identical
for
they
were
close
enough
At
least
it
Commission
the
the
been
up of
commercial
seemed
treated
one-half
executed
the
two
a non-
the
in
compapart
in
by it.
not
been
rate,
a sense
of
and
the
Postal
A mail
even-
Service
of
have
commercial
evoke
Postal
groups
in
Historiof
might
to
of
came to
was captu,red
years
that
roughly
between
and comparable
the
the
move
Mailers
escalators
nonprofit
to
as a result
counter,part.
about
and
rate
over
rates
differential
experience
Act
respective
nonprofit
commercial
has
Reform
both
in
comparable
nonprofit
Revenue
Rate
lower,
comparable
commercial
ness.
cost
adjustments
cases,
tandem
the
is
direct
A rates.
With
rable
the
Standard
fair-
handedly.
B.
.
SoftOrv
An analysis
Postal
Service
Standard
gories,
commercial
Postal
A mail
the
of
.
. .
nu~l.ng
the
rate
proposes
for
reveals
proposed
rates
.
are
management's
of
each
in
that,
rates
increase
of
of
or
the
almost
change
for
decrease
26 rate
that
the
categories
of
of
cate-
90 percent
the
nonprofit
and
comparable
from
the
historical
asymmetrical.
proposal
-4-
departs
both
relationship
and
from
acted
has
between
the
the
relationship
Revenue
departed
tunate
One reason
be compelled
scheme.
the
is
to
find
The
Postal
tionship
in
comparable
rections.
rate
Reform
it
to
postal
of
nonprofit
comparable
piece
of
commercial
parate
rates
these
proposed
In
lower
the
same
postal
change
make
en-
Service
fairness
is
unfor-
organizations
back
the
into
policy
will
the
rate
subsumed
in
explicit.
departs
adjust
from
some
commercial
mail
the
of
historical
the
r,stes
pieces
in
proposes
and
roll
In
mail.
to
back
these
management
proposes
enormous.
Table
is
instances,
:rate
rate
for
postal
both
category,
quantifies
the
commercial
pieces
rates
handling,
of
management
nonprofit
but
be discriminatory
Because
Fostal
it
rela-
of
other-
opposite
di-
increase
the
the
rate
for
instances,
between
I below
a
the
the
two
dis-
quantifies
differentials.
other
the
as to
of
to
management
a piece
that
of
fairness
more
and
for
differential
inject
proposal
seeks
is,
to
Act
nonprofit
That
when
the
nonprofit
Congress
Service
that
sense
uncorrected,
for
Forgone
That
A rates
reasons.
a way
is
Standard
envisionsid
Act.
historical
of
commercial
Congress
Reform
that,
One way
Revenue
wise
this
a number
and
that
Forgone
from
for
nonprofit
of
the
and
proposes
commercial
proposed
on its
face.
change
between
to
pieces
differential
Part
II
raise
of
within
is
this
or
so large
document
comparable
nonprofit
characteristics
are
and
mail.
hence
costing,
-5-
virtu-
ally
identical
ular
rate
for
nonprofit
category,
strongly
the
suggests
against
nonprofit
mercial
pieces.
(1)
and
commercial
proposed
that
the
asymmetrical
resulting
Standard
in
l?StandardA
schedule
favor
costs
of
the
Consider
basic
to
that
the
minimum
for
gory,
yet
nonprofit
the
order
piece
workers
to
process
(2)
co-l.
of
change
size
by the
Q&
or
to
of
to
for
serves
will
have
each
and
by 4 percent.
characteristics.
-rate
mail
is
of
That's
that
equipment
It's
or
classic
catemes:
.
to
disconcerting
the
the
has
price
rate
rate
rate
-6-
postal
of
catefor
for
the
the
24 percentage
the
same
gouging.
Poswhzm33&3
. .
is
the
commercial
mad-
particularly
and
amount
that
a whopping
essentially
fails
A rates.
raise
back
that
only
in
mail
to
roll
grates-
what
sorting
do a comparable
piece
by 20 percent
profit
nroa,
.
mail
Standard
com-
non-automated,
That's
a nonprofit
to
piece
for
the
commercial--presort:s
proposes
piece
mail.
qualify
mail
for
automated
management
differential
handling
for
postal
commercial
point
letter
required
postal
in
for
mailer--nonprofit
Whether
work
rate
processing
extent
purpose,
roll&&
proposed
category
qualify
discriminates
.
the
rate
treatment
comparable
postal-e a rate
a partic-
pricing
rate
A mail
within
mail
management's
disparate
that
treatment
qualify
Postal
within
for
processing
management
least
to
nanced
slow
the
sorting
down
the
tremendous
one
for
penalize
the
comparable
distinguish
profit
as opposed
seeks
percent,
as great
as the
and
in
prosort
posed
case
In
contrast,
but
percent
Service's
for
A mail
of
and
piece.
a piece
of
a mail
Route
Subclass
for
letters.
raise
the
for
both
of
rate
that's
of
coming
route,
nonprofit
both
commercial
like
and
and
commercial
compilation
the
called
serves
nonprofit
a non-
A mail,
"Revenue,
-7-
within
three
of
the
postal
and
and
man-
commercial
four
times
The magnitude
the
cost
a penalty,
to
not
a reward,
Standard
A mail.
nonprofit
Standard
A
their
end
45 percent
Presort"
according
Pieces,
of
of
rate
and
the
the
nonprofit
versus
to
of
prebarcode
commercial
about
"Automation
Standard
dis-
equipment
There,
, kept
reclassification,
pays
would
is
category
inflation.
on top
sounds
both
this
tha,t
rate
between
increase
increase,
they
good
purpose.
automation
rate
makes
processi:ng
the
an amount
speed.
but
Again,
fi-
automated
proposal
A mail,
at
who
the
mail
ment.
or
opti;num
management's
a commercial
is
that
at
The automated
equip-
mailers
mail
Standard
of
reductions,
for
process
mrofits
Since
bargain.
Standard
to
by carrier
that
mailers,
face.
to
by eight
that
read
between
Carrier
agement
produce
nonprofit
o,ne exception
Enhanced
to
commercial
on its
The
costs
categories
sorting
rate
increase,
postal
promise
cannot
promised
of
exception,
A rate
automated
rate
could
on that
criminatory
Standard
by the
repeatedly
equipment
With
the
37
Postal
weight by
Classes
of
Mail"
for
fiscal
year
1997
(revised
as of
December
10,
1997).
Discrimination
appears
particularly
categories.
Presumably
postal
rate
lated
that
prior
equipment
would
who produce
almost
requiremerrts
to
their
ratepayer
produce
cost
qualify
The
and
process
this
means
with
the
to
miscalcu-
automated
sorting
want
the
meet
the
nonprofits,
stringent
versus
bear
With
one
bear
37 percent
brunt
of
of
postal
costs
rate
of
between
A mail
TWO facts
tend
First,
the
to
confirm
Postal
this
the
Service
explanation
rate
the
case.
and
the
of
Despite
- a -
A mailers
three
and
nonprofit
commercial
discriminatory
evidence
apparently
numerous
to
pticing
of
its
it
inflation.
steadfastly
for
that
increases,
pricing
facie
to
Assuming
asymmetrical
itself
prima
has
of
ECR
non-
expense
cost
Standard
the
both
equipment.
.
. .
dlscrlmlnatorv
pieces
in
suggests
forward
in
comparable
in
increase
of
exceptions,
within
have
legitimate
processing
two
would
equally
reflects
the
category
sorting
~~~de.nce
or
rate
management
automated
really
than
more
Ba
proposals
to
automation
gr,ossly
they
rates
automation
mailers
automated
(3)
a straight
mail
mail,
Postal
increase
times
Standard
the
commercial
that
treatment
is
letters.
mail
rate
Now,
the
miscalculation.
for
profit
in
automation
counterpart's
exception
Subclass
savings.
their
for
in
management
investment
one-half
commercial
management's
four
huge
blatant
pricing.
of
refused
bias.
to
biased
opportunities
provide
pricing
to
respond
what
to
nonprofit
accounts
change,
for
po'stal
Second,
perience
been
there
is
cost
these
the
unable
a limit
to
access
accuracy
of
nonprofit
has
economists
both
unearth
to
what
postal
these
if
nonprofit
of
computer
time
and
specialists,
management
has
disparate
is
also
of
data
rates
obfuscated.
professional
Rate
ex-
Commission
Admittedly,
uncover
base
computations
of
and
is
because
establish
the
the
p,rohibitive
to
discover
of
thousands
computer
could
divert
hundreds
contributions
its
they
could
cost
data
to
discover
to
of
pay
for
how postal
produce
these
change.
possible,
covered
to
its
the
answer
of
dollars
that
however,
tracks
even
from
that
if
management
nonprofits
they
the
postal
were
public
to
not
might
able
to
pay
has
be able
raise
for
so
hundreds
extensive
analysis.
the
parable
were
could
charitable
manipulated
rates
skillfully
hide,
experts
mailers
dollars
lay
Postal
explanation.
management's
of
cost
of
full
Service's
thousands
If
the
and
years
and
explain
asymmetrical
dodged,
many
to
mailers.
Perhaps
It
ducked,
Service
Postal
attempts
anomalous
with
Postal
to
the
discovery
proposed
management
Ph.D.
at
have
interveners'
rationale
pieces
of
differences,
these
cards
except
for
disparate
rates
nonprofit
and commercial
one
think
openly
perhaps
mismanagement
such
would
on the
miscalculation,
- 9 -
or
mail
postal
what
table.
mismanagement
or
that
of
c:hange
were
for
legitimate
management
would
however,
would
there
it
be to
If
misestimation?
is
com-
there
grossly
unfair
to
Because
propose
postal
unable
to
nonprofits
management
derive
treatment
of
the
C.
postal
has
a complete
nonprofit
inforces
This
that
prima
rate
bear
been
forthright
explanation
and
facie
not
alone
for
commercial
evidence
may
such
price
not
costs.
and
Standard
of
proceeding
those
experts
are
disparate
A mail,
it
re-
discrimination.
. .
Drevents
.
.
DricirlS
It
pensive
game,
postal
at
lack
nipulation
least
there
are
arrived
Rate
commercial
The
on the
nonprofits
to
mail
in
of
direct
category
costs
of
its
replicate
cost
postal
faces
extent
to
an ex-
rates,
whereby
data.
Non-
management's
limits
which
too.
the
rates
of
and
change
For
ma-
example,
Commission
forthrightly
for
categories,
game seem to
the
wherewithal
and
computations,
whether
its
attributable"
the
to
into
nonprofit
bury
same rate
regardless
equitable,"
to
deteriorated
may compel
coherently
how it
nonprofit
and
notwithstanding
characteristics.
the
having
of
the
handling
compilations
gardless
respect
divulge
disparate
rules
has
data.
such
similar
case
Commission
Service
at
their
cost
limits
Postal
with
resources
its
Postal
rate
may successfully
the
of
The
data
a postal
management
profits
the
that
seems
Standard
to
proposed
of
have
unravel
the
rates
whether
to
come
they
nonprofit
A class
-10
of
-
Postal
of
or
management's
Service
change
"bear
Absent
this:
postal
mail
mail,
to
the
wins
iare
"fair
direct
with:in
regardless
each
reand
and
rate
of
in-
whether
they
rates
or
fees
mercial
of
represent
charged"
Standard
the
Postal
to
Reorganization
appears
its
on
The
the
anomalous
proposes
commercial
mail
Congress
intended
in
the
Service
Postal
not
provide
sleeve
is
in
the
Moreover,
rate
equitable
that
D.
relief
this
if
form
track
and
policy
objective
Reform
Asct,
regulation
openly
the
postal
nonprofit
changes
in
that
namely
the
that
comparable
that
(cannot
on the
table
monopolist
compel
or
that
leaves
cards
up
toward
nonprofit
only.
management's
in
of
what
scheme.
that
Forgone
cards
proceeding
embedded
(7)
are
for
pricing
the
when
in
the
and
its
proposed
may
Commission
behavior
produce
yet
were
in
the
Revenue
has
not
made
rate
to
scheme
fair
be guided
Forgone
Reform
before
and
by the
policy
Act.
Conclusion
Postal
management
differences
full
its
as manifested
rates
Congress
lay
postal
Commission,
mailers
pieces
Revenue
regulation
A mail
nonprofit
explanation
circumvent
would
rate
if
comparable
the
to
the
and com(3).
differentials
rates
Notwithstanding
Standard
thwarted
monopolist's
to
nonprofit
rate.
its
for
nonprofit
3622(b)(l),
be a discriminatory
appear
commercial
does
to
of
by Sec.
asymmetrical
management
changes
is
postal
face
pieces
between
Act.
intent
learn
relationships
comparable
A as required
Congressional
unable
"identifiable
disclosure
justify
otherwise
and
its
case
discriminatory
an opportunity
- 11 -
to
rebut,
that
legitimate
pricing.
the
cost
Absent
Commission
at
a
minimum
should
increase
or
the
same
rate
This
is
where
to
recommend
decrease
repeatedly
between
symmetry
nonprofit
in
the
rate
and commercial
rates
of
in
category.
most
nonprofits
possess
approximate
important
produce
exactly
those
assured
the
in
the
almost
automation
one-half
qualities
Commission
that
optimize
- 12 -
rate
of
their
postal
mail
categories,
Standard
ma:nagement
h(andling.
A mail
has
11.
An&.&Zi.ofProDosedDisDarate
Within
the
mail
pieces
rate
categories,
of
are
while
rolled
A rate
rate
directions.
mail
proposes
to
the
for
rate
In
Service
is,
and
within
raise
the
for
to
rate
rate
for
of
those
the
pieces
of
rates
in
category,
a piece
piece
size
adjust
commercial
one
a comparable
letter
two-thirds
proposes
nonprofit
That
C-g.=
subclasses
categories.
Postal
of
op-
postal
of
nonprofit
commercial
mail
be
back.
For
example,
letters
consider
within
nonprofit
using
the
or
the
automation
That
work
sharing,
rate
category:
and
for
level
presort
the
of
With
the
or
neither
automated
are
is
sort
Postal
Service
nonprofit
Despite
these
the
Postal
Service
the
postal
management
to
within
sorted
by three-
the
non-
by like
without
of
rate
has
to
even
and
category
do the
whether
mail,
similarities
go to
proposes
a
:may be processed
three-
sufficient
five-digits.
at
maximum
the
piece
the
lengths
the
basic
amount
of
serves
a
purpose.
fundamental
has
serves
"basic."
non-automation
pieces
piece
for
equipment.
are
pieces
them
called
piece
groups
that
the
those
two
category
the
sorting
residual
to
rate
Whether
purpose,
pieces
presort
process
commercial
Subclass.
those
to
non-automation
there
mailer
respect
level,
to
Regular
Service's
five-digits
density
the
a commercial
Postal
As for
work
nine
comparable
management
and
Standard
the
otherwise
posite
two
Rates
in
order
an absolute
- 13 -
in
to
process
rollback
each
of
that
piece,
four
percent
for
percent
increase
percentage
for
in
where
raise
the
postal
process
it
has
the
in
for
management
claims
equipment
but
19 percent
nonprofit
in
opposite
be observed
in
up the
two
Standard
In
two
of
the
one
it
postal
and
the
Postal
nonprofit
call
using
to
like
the
costs
that
to
In
the
automated
the
effect,
than
no more
three
leave
purpose
mail.
fails
the
non-auto-
a commercial
nonprofit
same piece
same phenomenon--the
moving
mail,
handle
it
the
propo;ses
serves
it
mail
presorted
to
24
before
to
characteristics
sorting
digits,
but
of
.that
serves
and
commercial
mail
it
now costs
a
purpose.
This
--can
process
is
more
that
to
of
essentially
within
management
by 19 percent
commercial
require
tier
rate
of
20
a swing
That's
are
presort
postal
for
a whopping
I below.
that
order
been
that
mail
a piece
needed
the
and
mail
piece.
pieces
second
ratme category,
but
in
two
the
of
nonprofit
See Table
pieces
mation
piece
the
for
handling.
For
mail
commercial
points
similar
rate
the
of
A mail
the
proposed
is
to
increase
within
of
three
the
nine
rate
mail
rates
to
each
to
pieces;
change
In
only
piece
- 14 -
categories
increase
is
one
the
rate
by the
for
letter
rate
for
the
category
intuitively
same
that
make
I below.
so large,
seems
category
categories
however,
of
do what
same rate
See Table
rate
proposes
as well.
propose
nonprofit
subclasses.
remaining
commercial
management
that
two-thirds
and
for
directions
Service
asymmetric
rate
factor.
size
both
differential
one
could
does
logical,
Table
Proposed
Change
for Commercial
I
in Standard
A Mail
Rates
and Nonprofit
Letters
tric
Rates
of
Cu
ComSubclass
Rate Category
----------------
Differential
in Percentage
Points
-_--_____-___
Nonprofit
------
mercial
-------
Regular
non-automation,
basic
presort
-4%
20%
24
Regular
non-automation,
3-/5-digit
presort
0%
19%
19
Enhanced
Carrier
Route
("EC"")
saturation
1%
-17%
18
ECR
high
1%
-16%
17
Regular
automation,
basic
presort
3%
16%
15
ECR
basic
9%
-3%
12
Regular
automation,
digit
presort
0%
11%
11
Not
change
only
fo:r
seven
letter-size
between
Standard
the
mail
type
of
of
but
A mail.
the
is
even
Standard
nine
also
of
of
is
the
of
magnitude
for
of
is
rates
Standard
commercial
differential
the
of
A
differential
and
nonprofit
11. percentage
24.
the
differential
greater.
There
A mail.
asymmetric
categories
change
smallest
largest
propose
rate
note
rates
The
3-
management
the
proposed
The magnitude
size
presort
postal
mail,
and
points,
does
density
for
are
Two rate
- 15 -
Standard
17 rate
categories
A non-letter
categories
are
omitted
for
from
this
this
analysis
centage
because
has
to
increase.
this
the
relatively
be computed
distorts
A third
rate
omitted
base
the
size
because
it
on which
of
the
didn't
the
per-
percentage
exist
prior
to
filing.
With
respect
agement
is
low
to
the
remaining
proposes
rates
opposite
directions
move
in
size
piece
serves
remaining
six
poses
to
mail;
however,
of
change
categories,
the
or
in
the
for
rate
proposed
categories,
rate
of
both
rates
the
them
postal
that
For
the
management
and
increase
man-
non-letter
purpc'se.
nonprofit
of
postal
c:ategories
on whether
commercial
five
for
rate
eight
depending
a nonprofit
increase
I4
pro-
commercial
vary
substantially.
In
mail,
the
sixth
postal
mail
is
in
narrow,
Postal
category
management
commercial
Table
rate
II
move
this
below
Ser,vice's
for
proposes
in
the
case
it's
shows
that
two
magnitude
rates
of
that
make
up Standard
rate
categories
are
omitted
because
postal
management
mercial
mail
categories,,
mathematical
proposes
by the
postal
to
same amount.
management
In
proposes
be expected.
- 16 -
the
and
differential
dif:ferential
for
the
rate
a fourth
both
the
nonprofit
the
fifth
in
20 of
the
To recount,
A mail.
increase
size
pointis.
of
the
In
reasons.
of
and
change
categories
for
a piece
percentage
rate
torted
A non-letter
same direction,
the
proposed
Standard
of
change
rate
a differential
26
three
is
dis-
category,
nonprofit
and
the
and
sixth
comrate
that
would
Table
Magnitude
Between
Nonprofit
as Proposed
II
of the Differential
and Commercial
Standard
A Mail
by the U.S. Postal
Service
Average
Differential
Per Rate Category
-___-______--____-__
Letters,
Regular
Subclasses
(7 rate
categories)
and
Non-le.tters,
Regular
ECR Subclasses
(13 rate
categories)
Given
change
the
for
relative
to
they
to
and
20 percentage
points
in
the
basically
has
similar
processing,
one
would
the
economic
fully
have
that
is
chosen
full
not
discriminatory
buttressed
experts
to
computations
of
were
generated
and
proposed
rates
expect
that
reason
postal
for
through
by the
penetrate
to
for
resisted
is
such
postal
determine
comparable
nonprofits'
discovery
leads
to
at
This
con-
work..
inability
of
how such
pieces
of
data
disparate
nonprofit
rates
and
submitted
Fe
tion
of
L
1997
com-
A mail.
National
30,
the
recognized
management's
Respectfully
December
of
characteristics
have
pricing
further
and
Standard
to
disclosure
pilations
commercial
points
differential
explain
obtain
independent
change
17 percentage
treatment.
conclusion
clusion
postal
could
disparate
efforts
that
mail
management
That
enormous
ECR
Service
Group
Nonprofits
CERTIFICATE
OF SERVICE
I hereby certify
that I have this day served the foregoing
document upon all participants
of record in this proceeding
in
accordance
with section
12 of the Rules of Practice.
-
G
No pgofft
Service
Group
121 0 24th Street,
N.W., Suite
Washington,
D.C. 20037
202/466-6620
December 30, 1997
400