DOCKET SECTION
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
POSTAL RATE AND FEE CHANGES, 1997
)
RECE!lJCY,
i !.I
“’ I I J 11:pi,/ “91
Dockq:,No. ,R9,7-,I
~I
RESPONSE OF NASHUA PHOTO INC., DISTRICT PHOTO INC.,
MYSTIC COLOR LAB, AND SEATTLE FILMWORRS, ZINC.
TO INTERROGATORIES
OF UNITED STATES POSTAL SERVICE (USPSINDMS-T2l l-14)
(February 11, 1998)
Pursuant to sections25 and 26 of the Postal Rate Commission rules of practice, Nashua
Photo Inc., District Photo Inc., Mystic Color Lab, and Seattle FilmWorks, Inc., hereby
provide the responsesof witness John Haldi to the following interrogatories of the United
StatesPostal Service: USPSINDMS-T2-11-14, tiled on January 28, 1998. Each interrogatory
is statedverbatim and is followed by the response.
Respectfully submitted,
Alan Woll
John F. Callender, Jr.
WILLIAMJ. OLSON,P.C.
8180 GreensboroDrive, Suite :1070
McLean, Virginia 22102-3823
(703) 356-5070
Counsel for NashuaPhoto Inc. ,, District Photo Inc.,
Mystic Color Lab, and SeattleFilmWorks, Inc.
I hereby certify that I have this day served the foregoing document upon all participants
of record in this proceeding in accordancewit
February 11, 1998
Responseof Dr. John Haldi to USPSINDMS-T2-11
Page 1 of 1
usPs/NDiw-n-11.
Pleaserefer to your testimony at pages32 to 37 where you discussyour
treatment of distance-relatedtransportation cost. You recommend not marking
up distance-relatedtransportation cost for the purpose of Priority Mail rate
design. You also statethat “costs avoided and costs incurred are (and should be
treated as) the opposite side of the samecoin.” NDMS-T-2 at 35.
(4
In your opinion, should other non-trunsponation costs avoided
under workshare discount programs also not be marked up in the
rate design process? If so, pleaseexplain fully, and identify all
cost elementsyou would not markup in Priority Mail. If not,
pleaseexplain fully, including your complete rationale for limiting
your recommendation.
@I
Is it your testimony that transportation-relatedcosts for other
classifications, such as bound printed matter and parcel post, not
be marked up? Pleaseexplain fully.
Reswnse:
(a)
I am not aware of any intermediate labor costs that are or would be avoided
when Priority Mail is entered at somepoint closer to the final destination, and I
am aware of no other cost elementsregarding when the decision to impose a
markup must be made.
@)
I have not testified about BPM or parcel post.
Responseof Dr. John Haldi to USPWNDMS-T2-12
Page 1 of 1
USPVNDMS-‘I%12.
Pleaserefer to your testimony at page 6, lines 14 through 15, where you state:
“When a packageof prints weighs more than one pound, certain companiessend
such packagesdirect, via Priority Mail.” pmphasis original] Pleasespecify the
meansby which companiesother than these “certain companies”send their
packagesof prints weighing more than one pound.
In addition to use of Priority Mail, the options are (i) to split the contents into two
Standard A Regular packages,each of which weighs less than one pound, or (ii) send
the package via an alternate delivery service, such as UPS. Those companiesthat do
not send individual Priority Mail packagesuse one or both of the above options.
Responseof Dr. John Haldi to USPSINDMS-l2-13
Page 1 of 1
USPSINDMS-‘E-13.
Pleaserefer to your table at the top of page 16 of your testimony. Please
confirm that, under the Postal Service’s proposal, for mailers using electronic
manifests, the rate differentials you have identified would be:between a FirstClass Mail service without delivery confirmation service and,a Priority Mail
service with delivery confirmation service. If you do not confirm, pleaseexplain
fully.
Reswnse:
Confirmed.
Responseof Dr. John Haldi to USPWNDMS-T2-14
Page 1 of 1
USPsrnMs-m-14.
Pleaserefer to your testimony at page 17, lines 6 to 7, where you state that the
Postal Service developed an econometric model “to estimate the price elasticity
of Priority Mail.” Pleaseconfirm that the model in question estimatesone ownprice elasticity for Priority Mail as a whole. If you do not confirm, please
explain fully.
ResDonse:
Confirmed.
DECLARATION
I,
John Haldi,
foregoing
answers
knowledge,
Dated:
declare
are
true
information,
February
11,
under
and correct,
and belief.
1998
penalty
of perjury
to the best
that
of my
the