BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268
POSTAL RATE AND FEE CHANGES,
Docket
1997
p,1; E;',I7.{I
fiTR j
( 1.5 I';/ y
No. R97-1
REPLY BRIEF OF THE
AMERICAN PUBLIC POWERASSOCIATION
Eugene E. Threadgill
Suite 200
1493
Chain Bridge Rd.
McLean, Virginia,
22101
(703)
(703)
April
10,
1998
734-1918
734-1943
,,
,,I_,.; ;,m,,u
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTOND.C 20268-0001
POSTAL RATE AND FEE CHANGES, 1997
DOCKET NO. R97-1
REPLY BRIEF OF THE
AMERICAN PUBLIC POWERASSOCIATION
The arguments
offered
66-701,
in opposition
Public
Power
reductions
Postal
by the Postal
to the
Association
in card
Service
is
rationale
expressing
its
changes,
the absence of a firm
implies
that
Postal
exercise
all
Service
by the Commission
consent
of its
discretion
any of
the
APPA's
to those
strong
no
Although
to
opposition
has
V-
across-the-board
consequence.
proposed
the
Brief,
by the American
supporting
are of little
not
(Initial
presented
(APPA)
rates,
Service
changes
objection
to
the
to recommend some or
of APPA's proposals.
PRIVACY -
observation
The
regarding
V-69.
Even if
that
known
fact
that
sorority,
is
a group
Postal
Service
privacy
as "an exaggeration".
a card
anyone at that
destination.
searching
possible
without
privacy.
privacy
difference
for
an opening
It
received
an office
illegal
privacy
at
or
a home,
business,
that
between
should
a violation
there
a letter
be reflected
1
or
can be read
by
by an inspector
cannot
of
is a vast
and a card.
in
the well
a fraternity
A letter
activity.
constitutes
is unquestionable
in
witness'
USPS Init.Br.at
A card can be examined
which
of communications
APPA's
comment was an exaggeration,
witness'
home,
criticizes
the
be read
right
of
difference
That
a significant
in
total
rate
difference
between
cards
and letters.
COMMUNICATION QUANTITY - The Postal
vast
difference
in the amount of information
by a letter
and a card
degree
Docket
since
has not
standards
Service
of
rate
to
suggest
setting
the
final
communication
such
rates
for
requirement
structuring
themselves
having
that
Some of
No.
it
did
not
The Postal
in the
but
in
The relative
provided
should
by the
be reflected
accordance
with
the
implemented
mail
itself
a
was
has
half
burdens
carrier
routes,
burdens
merely
an
recognized
on the
a
ounce
illustration
significance
is
both
in
carriers
be reflected
half
It
transportation
APPA's reference
the
2
on carriers,
routes,
may not
for
"weight
at V-70.
and upon other
costs.
rate
that
the volume variable
USPS Init.Br.
imposes
of volume variable
states
in determining
and walk
those
Service
costs".
weight
as they walk their
international
Service
in
Docket
be ignored
of the services
difference
any
and letters,
should
which
to
difference
cards
criterion
only
and delivery
of park
functions.
calculation
53623;
two subclasses.
The Postal
seem to be a driver
APPA's perception
the
or
of §3622(b)(2).
processing
mail
those
rate
RELATIVE WEIGHT should
between
to the public
substantial
time
to 53622.
a difference
is a statutory
over
to
pursuant
the
can be conveyed
is a tremendous
value
that
values
two subclasses
a very
there
that
at V-69.
pursuant
making
communication
appears
in
for
argues
that
USPS Init.Br.
case
does not deny that
quantity
"diminished
No. MC95-1".
MC95-1 was a classification
establish
Service
that
in
the
to the USPS
letter
in
the
Postal
of
weight
::ijilY”
differentials
in areas
HISTORICAL
states
No.
reparations
R97-1
serving
f-c:. "2
years
USPS Init.Br.at
suggested
it
years,
times,
of
At
including
proper
the
Act,
much
card/letter
higher
relationship.
Tr.
for
letters
and cards,
the
Service
15 cents
19
rate
increase
resulting
pre-Docket
of
to
line,
card
Service
basis
APPA,
or
witness,
or
that
than
of those
under
recent
the
Postal
were increased
relationship
when
far
to a
historical
early
53622,
the
letter
in
is APPA's perspective
than
to the
3 cent
was only
the
in
post
Quite
more than half
cards
of
mailers."
its
sought,
process
for
distribution
by postcard
It
contained
a rate
the
and a 2 or
for
It
Postal
112 years.
the Commission
that
the
applied
to
more consistent
rates
proposed
by the
recommended a 15% increase
and a 27% increase
Tr.
had been
applied
would
excessive
If
20/10251.
to
both
in the card rate
rate
four
cent
3
(from
an across-the-board
15%
letters
the
have been 17 cents,
No. R90-1 card/letter
and that
for
rates.
proceeding.
rates
cents.
rate
rates
relationship
In Docket No. R90-1,
letter
being
ratio
compel
in this
in 1st Class
were
making
the
making
historical
has
throughout
20/10249-51.
rate
time
relationship.
that
The
for
postcard
rate
over
any compelling
endured
were wrong
Reorganization
criteria
no
a penny
a very
offer
of xwr,lng'
any reparations
rates
represented
discretion
a forum
is APPA's view that
the
Postal
as
relationships
contrary,
has total
witness]
V-67.
that
card/letter
it
CARD/LETTER RELATIONSHIPS -
"Nor did he [Appa's
Docket
with
where
and cards,
not
relationship
increase
19
cents.
was already
in
the
card
The
out
rate
made in
Docket
"reparations"
No.R90-1
was truly
are requested,
at those excessive
a step
restoring
means of public
increases
a reasonable
fail
card
to
Those
its
rates
two
Trial
would
the
between
factors
Commission
does
in
reflect
elasticity
rate
not
state
application
of
are
Brief,
cards
tremendous
difference
and
letters.
any
objection
those
factors
reasonable
rate
rate
differentials
to
its
between
53622(b)(3).
The Postal
proposal
the
"maintains
proposed
Init.Br.
arguments
between
at
in
V-21.
favor
the proposed
for
the
price
used
by
costs.
requests
and
10259-60.
the
The USPS
regarding
in
its
the
decision
either
2-cent
Service
a 2 cent
Trial
and
that
the
cost
measurable,
provided,
is
as required
merely
card discount
letters".
to
or
cent
2.5
that
letter
by
their
and parallels
Postal
appears
and presort
4
its
and work-sharing
real,
response
single-piece
both
single-piece
non-automated
The Postal
In
APPA demonstrated
services
Service's
the current
of
-
to
the postal
discount
demand
20/10256,
Commission
testimony,
recognition
differentials
that
relationships.
between
give
in
criteria
APPA's
by the
testimony
coverages,
over attributable
to
the
cost
Tr.
technical
mark-ups
and
fail
low-value
demonstrated
excessive
standard
Briefs,
proposed
to
and take
a very
- In both
APIA
WORK-SHARING RATE DIFFERENTIALS
Initial
No
the Commission
for
generate
cards
in deciding
recommending
public.
communication.
and
proposed
the
in card rates,
COST COVERAGEAND DEMAND ELASTICITY
submitted,
to
but APPA does urge
look backwards
toward
punitive
rely
Service
upon
its
differential
rates.
USPS
Init.Br.
at
V-6
et
seq.
Service's
very
avoidance
measurements
differences
between
category
confusing
Unit,
useful
presort
unit
explained,
regarding
to recognize
mail
there
category.
of
Postal
and cost
are large
mail
See APPA Init.Br.
has been
assigning
comparative
Op. at IV-96,
n
contributions
measure.
to
And the
at
widely
institutional
cost
In R87-1 Op. at 370, 14038 the Commission
per-piece,
cost
to the single-piece
contributions
method
the
benchmarks
that
provided
per-piece
as a hands-on
responsibilities.
that
fail
and the basic
recognized
arguments
the services
The use of
7-13.
As APPA has
institutional
Commission
stated
costs
stated
is
a
in MC95-1
4212:
This record has reconfirmed
the Commission's
long-held
view
that workshare
discounts
should reflect
the costs that the
Postal
Service
avoids by worksharing,
so that the category
makes the same per-piece
contribution
that
it would have made had it not
A 3 cent differential
unit
cost
partial,
for
Basic
contribution
Presort
than
but not total,
to institutional
costs
undergone
worksharing."
provides
a slightly
single-piece
recognition
mail,
of actual
greater
and
provides
and non-deniable
cost
differentials.
AUTOMATION ELIGIBILITY
the
Automation
with
the
elimination
categories,
cards
not
imposed
of
the
in Docket
5-digit
had a much more adverse
than upon letter
requested
that
mailers.
the
but has suggested
restored,
levels,
Conditions
CONDITIONS - APPA has pointed
a
relaxed
Tr.
that
automation
carrier
upon bulk
20/10261-2,
and
5-digit
No. MC95-1,
and
impact
users
rate
of post
APPA has
subcategories
is presorted
eligibility
condition
5
,,
together
sort
10268-70.
carrier
where mail
out that
,,,,,,r.,-
be
to those
could
be
employed.
The Postal
technical
obstacles
conditions
suggested
proposal,
would
Service
which
to
such
a
by
APPA,
but
implies
be generated
that
there
that
require
some modification
provide
some relief
has
not
mailers
responded
that
which
mitigation.
its
discretion
conditions
to
in order
use cards
to the lowest
to
problems
exercise
which
any
eligibility
condition
of card automation
to the public
of
are no operating
the Commission
to bulk
of describing
modification
by such an eligibility
APPA requests
keep the costs
has the capability
in
to
order
to
level.
CONCLUSION
In summary,
card
rates
contrary
have had a very
and upon the small
An
cent
18
to the objective
card
relationship
publicly
rate,
close
to the early
reflect
weight
differences,
would
Tr.
an
rate,
20/10264.
cent
18
single-piece
Commission
eligibility
reflect
provide
card
should
conditions
to qualify
for
automation
sequencing
barcodes.
direct
to allow
rates
rate,
major
a
15
compatible
the
5-digit
with
and
in demand
should
those
Service
and carrier
a
to the public.
Basic
with
Postal
only
quantity,
benefits
cent
have
relationship,
difference
the Commission
public
the public.
would
card/letter
great
rate,
rates
serve
communication
the
Based on the record,
a set of Automation
and the
privacy,
and would
letter
American
current
upon the general
which
and a 33 cent
more closely
elasticity,
impact
owned utilities
would
price
adverse
of 53622(b)(4),
recommend
Presort
card
base rates,
to amend its
presorted
the sectional
cards
and carrier
Respectfully
American
submitted,
Public
Power Association
FM,
bEw
e E. Threadgill
1493
Chain Bridge Rd. Ste.
McLean, VA 2210i
(703)
(703)
734-1918
734-1943
200
(fax)
CERTIFICATE OF SERVICE
counsel
for the American Public
Power
I, Eugene E. Threadgill,
Association,
hereby certify
that on April
10,
1998,
copies of the
foregoing
document have been served upon the USPS, the OCA, and all
intervenors
in accordance with the Rules of Practice.-