RECEIVEC
POSTAL RATE D.C.
COMMISSION
WASHINGTON,
20268-0001
Docket No. R2001-1
POSTAL RATE AND FEE CHANGES, 2001)
FIRST SET OF INTERROGATORIES
OF
ASSOCIATION
OF AMERICAN PUBLISHERS
TO USPS WITNESS TOLLEY (AAPAJSPS-T%l-10)
Pursuantto Section 25 and 26 of the Commission’s Rules of Practice and Procedure,the
Association of American Publishers (AAP), hereby submits the following interrogatoriesand
requestfor production of documentsto USPS witness Tolley (USPS-T-7). If the designated
witness is unable to respondto any interrogatory, we requesta responseby some other qualified
witness.
w7
Drinker Biddle & Reath LLP
1500 K Street,NW
Suite 1100
Washington, DC 20005
Telephone: (202) 842-8800
Counsel for Association of
American Publishers
CERTIFICATE
OF SERVICE
I hereby certify that I have this date servedthe foregoing document, by First-Class Mail,
upon the participants in this proceeding.
Date: October 24,200l
INTERROGATORIES
OF ASSOCIATION
OF AMERICAN
TO UNITED STATES POSTAL SERVICE WITNESS
PUBLISHERS
TOLLEY
On page 146 of your testimony (USPS-T-7) you statethat “Bound printed
matter is advertising, promotional, directory or editorial material which weighs between 1 and 10
pounds and is permanently bound.” With respectto this statement:
AAPAJSPS-T7-1
(4
Pleaseconfirm that Bound Printed Matter (“BPM”) also consistsof books.
@I
Pleaseexplain why your testimony fails to mention that BPM also consistsof
books.
Pleaseconfirm that your testimony is in error and that there no longer is a
(cl
minimum weight requirement for BPM and that BPM mail may weigh up to 15 pounds.
On page 148 or your testimony you statethat “[a] downward shift in
volume beginning in 1998Ql contributed to a 12.15percent decreasein the volume of Bound
Printed Matter.” With respectto this statement:
AAPAJSPS-T7-2
Pleaseprovide an explanation for the 12.15percent decreasein volume since
1998QlY
Is the decreasein volume due a to a decreasein the number of catalogssentas
@I
BPM? If your answer is no, pleaseidentify all factors that contributed to the decreasein volume.
Cc) Has the Postal Service compiled any information or data to show what the effect
the rate increasesin the R2000-1 rate casehave had on BPM volume. If yes, pleaseprovide all
such information or data. If no, pleaseexplain why the Postal Service has not compiled such
information or data.
On page 149 of your testimony, you statethat “[tlhe growth in catalog
salesis indicative of growth in the volume of catalog deliveries and is favorable to Bound Printed
Matter.” With respectto this statement:
AAPNSPS-T7-3
Pleaseidentify all information, data, reports or studies that you relied upon to
(4
support this statement. Pleaseprovide all such information, data, reports or studies.
Has the Postal Service gatheredor collected any information or data that shows
(b)
that the number of catalogssent as BPM has increasedduring the live yearsending in 2001Q3?
If yes, pleaseprovide that information or data.
Pleaseidentify and provide all documents,studiesreports, data or other
evidenceupon which you relied to conclude that the “Other Factors” describedon page 148of
your testimony in any way support or relate to the trends in catalog mail that you describeon
page 149 of your testimony.
AAPNSPS-T7-4
m3342onl
Pleaseprovide the Trufic World and Trc@c Management articles referred
to on page 148 and 149 of your testimony.
AAPNSPS-T’I-5
.Pleasestatethe volume of the BPM subclassthat consistsof catalogsfor
eachof the years 1995-2000. Include sourcereferencesto support your response.
AAPNSPS-T7-6
Pleasestate the volume of the BPM subclassthat consists of books for
each of the years 1995-2000. Include sourcereferencesto support your response.
AAPNSPS-T7-7
Pleasestatethe volume of the BPM subclassthat consistsof phone books
for each of the years 1995-2000. Include sourcereferencesto support your response.
AAPNSPS-T7-8
Pleasestatethe volume of the BPM subclassthat does@ consist of either
catalogs,books or phone books. Include sourcereferencesto support your response.
AAPIUSPS-T’l-9
Line 21 of Page 149 of the PDF version of your testimony found on the
PRC website, as well as the hard-copy of Page 149 obtained by AAP, is not legible. Please
provide a legible copy of Page 149 of your testimony.
AAPNSPS-T7-10
na342on1
-2-