BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON,
D.C. 20268-0001
POSTAL RATE /{ND FEE CHANGES, 1997
I
/
RECE\VED
u, PM “91
\cr: \d J ~‘posl~~ RATECOHHiss’oH
3FF,CEo; 1y.ESECRE1bRY
Docket No. R97-1
0BJE:CTION OF THE UNITED STATES POSTAL SERVICE TO
UNITED PARCEL SERVICE INTERROGATORY
UPS/USP,S-T29-I 1
(August 14, 1997)
The United
interrogatory
States Postal Service
UPS/USPS-T29-11.
hereby
The information
and would involve revealing pre-decisional
objects
to United
requested
Parcel Service
is irrelevant,
proprietary
matters upon which postal management
has
not acted.
UPS/USPS-T29-11
states, “Please provided the results to date (costs, revenue:s,
volumes, etc.) of the Priority Mail pre-barcoding
experiment that is the subject of Docket
No. MC96-I.”
The requested
made any proposals
experiment.
testimony
information
is completely
irrelevant.
in this case which relate in any way to the Docket No. MC96-.l
As indicated in the Postal Service’s proposed
of witness Fronk, the experiment
experimental
asked,
in this docket,
c:lassifications
Further, the Commission’s
requirement
to make
and discounts
and in the
at 4. The Commission
any recommendaticjns
is thus
regarding
the
resulting from Docket Nlo. MC96-1.
experimental
that the results of experiments
rate schedules
currently is set to expire on April 28, 1998.
See Request, *Attachment 8, at 6 and 70; USPS-T-32,
not being
The Post:al Service has not
rules do not establish
any affirmative
be reported or filed wtith the Commission
2
or otherwise
made public.
Docket No. MC96-1,
the Commission
flexibility in conducting
The Commission
the necessity
c:onditions warrant.”
impose any conditions
for changes.
PRC Op., MC967,
or prerequisites
concerning
during the course of the experiment.
information
concerning
information
is not relevant,
willingness
decision
ongoing
experiments,
would
Accordingly,
experiment
classifications
postal
management
and discounts
that the experiment
in other
has been
be made permanent,
Revealing
would reveal ilnformation that is proprietary
proceedings
effect
or
such
of the mailing public.
what the future
made
where
on thle Postal Service’s
to either
course
request
that the experiment
of the
that
and pre-decisional.
the
be changed, or
the results of the experiment
thus
Tomthe extent that the
Postal Service decides to request that the subject classifications
made permanent,
did not
Forcing the Postal Service to reveal
has not decided
be discontinued.
forms if
reporting of any data gathered
have a chilling
No decision
will be.
in
the Commission
at 28. The Commission
to test new product offerings, to the detriment
Also,
in
stated, “Actual experience
the Service to adjust its practices and amend its data, collection
experimental
generated
In its recommended
recognized that the Postal Service should have
the experiment.
the field may indicate
encourages
See 39 CfR 53001.67.
and discounts
be
the results of the experiment would be available at that point through
the Postal Serrvice’s filing and through appropriate
discovery.
To the extent that i:he
Postal Service decides not to go forward, then the data collected during the experiment
..
would remain proprietary
Finally, to the degree that revealing specific volumes by site
3
would reveal volumes associated with a particular mailer or mailers, the Postal Servic;e
considers
that information
The proprietary
to be commercially
nature and commercial
special concern given that it is being requested
sensitive.
sensitivity
of the iinformation
by UPS, the Postal Service’s primaIry
competitor for the business that is the subject of the experiment.
must be questioned
are of
UPS’s motives furthler
given the obvious lack of relevance to the issues in this docket.
Respectfully
submitted,
UNITED STATES POSTAL
SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemak.ing
Susan M. Duchek
CERTIFICATE
&?.A--
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.
475 L’Enfant Plaza West, S.W.
Washington, DC. 20260-I 137
(202) 268-2990; Fax -5402
August 14, 1997