:“KET SECTION
1:::2E;i’ ,E~
1,)
BEFORE THE
POSTAL RATE COMMISSION ~~3 23 12 ,-‘: ~fj ‘93
WASHINGTON, D.C. 20268-0001
POSTAL RATE AND FEE CHANGES, 1997
j
Docket No. R97-1
RESPONSE OF
DOW JONES & COMPANY, INC. TO
INTERROGATORIES AND REQUEST FOR
PRODUCTION OF DOCUMENTS OF
UNITED STATES POSTAL SERVICE
(USPSIDJ-35)
(February 23,1998)
Pursuantto Rules 25 and 26 of the Commission’s Rules of Practice,Dow Jones&
Company, Inc. (“Dow Jones”) hereby replies to the interrogatoriesand requestfor production of
documentsposedby the United StatesPostal Service(USPSDJ-35) on February 9, 1998.
Each interrogatory is statedverbatim and is followed by the response.
Respectfully submitted.,
d
JTi2??MNY
Michael 4. McBXde
SamuelBehrendsIV
Brenda Durham
JosephH. Fagan
LeBoeuf, Lamb, Greene& MacRae, L.L.P.
1875 Connecticut Avenue, N.W., Suite 1200
Washington, DC 20009-5728
(202) 986-8000 (Telephone)
(202) 986-8102 (Facsimile)
February 23, 1998
vs for Dow Jor&&ComDanv.
RESPONSE OF
DOW JONES & COMPANY, INC. TO INTERROGATORIES AND
REQUEST FOR PRODUCTION OF DOCUMENTS
OF UNITED STATES POSTAL SERVICE
USPWDJ-35. In responseto USPSDJ-25-30, Dow Jones& Company, Inc. indicates it does not
use pallets, sacksor trays in preparing its publications for mailing.
a.
Pleasedescribegenerally how its mailings are preparedand h.owthat preparation
has changedfor each of the last ten years.
b.
Pleaseindicate, by year, the changesin make-up such as changesin average
bundle size, changesin containerization, and the averagenumber of bundles and piecesper
container.
C.
Pleaseindicate in percentageterms, what savings,if any, Dow Jones8r Company,
Inc. has experiencedin its mail preparation costsdue to changesin the make:-upof its mailings.
d.
Even if a percentagecannot be calculated for such savings,as requestedin subpart
(c) above, pleaseindicate whether or not Dow Jones& Company, Inc. have experiencedsavings.
RESPONSE:
a.
Mailings of The Wall Street
and Barron’s are processedthrough
automatedmailing equipment which bundlescopies in quantities of six or more basedon the
level of sortation. The bundles are then strappedand wrapped in plastic for delivery to entry post
offices. For many entries, bundles are containerizedbasedon volume.
The basic preparationprocesshas not changedduring the last ten years.
Beginning in 1994, as the result of the installation of post-pressequipment, Dow Joneswas able
to significantly improve the number of copies of The Wall Street Jod
and Barron’s qualifying
for carrier presort rates. Over the sameten year period, an increasingpercentageof bundled
copies have beencontainerized. &response to USPS’DJ-35(b).
b.
Dow Jonesdoes not have any information from this period for the average
number of bundles and piecesper container.
Information is available for averagebundle size and percentageof mail copies
containerized for some of the indicated years. This information is derived from a single one-day
snapshotduring each applicable year.
-2-
RESPONSE OF
DOW JONES & COMPANY, INC. TO INTERROGATORD5S AND
REQUEST FOR PRODUCTION OF DOCUMENTS
OF UNITED STATES POSTAL SERVICE
II- . .
1987
24.0
Not Available
1988
24.1
45.8%
1989
24.6
47.7%
1990
24.4
49.6%
1991
23.7
51.1%
1992
23.6
53.2%
1993
22.9
59.0%
1994
20.8
60.0%
1995
20.2
Not Available
1996
17.9
Not Available
1997
Not Available
Not Available
C.
DOW Jonesdid not experienceany savingsin mail preparationcosts due to
changesin the make-up of its mailings during the past ten years. To the contrary, Dow Joneshas
experiencedadditional mail preparationcosts. Dow Joneshas invested significant funds in
automatedequipment, software and additional labor in order to qualify additional copies for
carrier-sort discounted periodical rates.
d.
&
responseto USPWDJ-35(c).
-3-
DECLARATION
declare
under
I, f1Wk.U &c&V/
the foregoing
answers are t&e and correct,
information
and belief.
knowledge,
DC5 31297.1
23040 00743
penalty
of perjury
that
to the best of my
CERTIFICATE OF SERVICE
I hereby certify that I have this day servedthe foregoing document upon all participants
of record in this proceeding in accordancewith section 12 of the Rules of Pra.ctice.
%iiAtG&~
Josephkf. Faganu
Dated: February 23, 1998