RECEIVEI)
BEFORE THE
POSTAL RATE COMMISSION
ttov
Docket
POSTAL RATE AND FEE CHANGES, 2001
13
No. R2001-1
INTERROGATORIES
OF
ASSOCIATION
FOR POSTAL COMMERCE
TO USPS WITNESS MOELLER
(POSTCOMlUSPS-T-32-9-10)
Pursuant to Sections 25 and 26 of the rules of practice, the Association
Postal Commerce
submits the attached interrogatories
to USPS witness Moeller:
PostCom /USPS-T-32-9-10.
Respectfully
submitted,
Ian D. Volner
N. Frank Wiggins
Venable, Baetjer, Howard & Civiletti, LLP
1201 New York Avenue, N.W.
Suite 1000
Washington, DC 200053917
Counsel for Association
November
13. 2001
for
for Postal Commerce
POSTCOMIUSPS-T32-9.
USPS-LR-J-60,
Please refer to Table 1 below, USPS-LR-J-132,
USPS-LR-J-61,
and USPS-LR-J-68.
Table 1. Standard Regular Pound Rate, Standard Mail Transportation
Costs, and Standard Mail Crossdocking
Costs
L=
Category
Proposed
Pound Rate
Transportation
Cost Per Pound
Cmssdocking
Cost Per Pound
[l]
(21
$0.706
$0.139
$0.608
$0.042
$0.583
50.027
[I] USPS-LR-I-13: !, \NP 1. Page Z
[2] Calculated From USPS-LR-J-66. Appendix 6, Table 9
[3] Calculated From USPS-LR-J-66, Appendix C, Table 1
[3j
ygiiiz--
$0.046
$0.025
$0.011
TlanSlClOSS
Cost Per Pound
[4]=[2]+[3]
$0.165
$0.067
$0.038
Pound Rate
Mklus
TlallSlCRWS
Cost per Pound
[5]=[1]-[4]
$0.523
$0.541
$0.545
If not confirmed,
(a) Please confirm that all of the figures in Table 1 are correct.
please provide the correct figures and provide citations of the data that you used
to calculate the correct figures.
(b) Please confirm that the Standard Mail dropship cost avoidance
LR-J-68) calculates
crossdocking
and transportation
model (USPS-
costs per pound (rather than
per piece) and that the reason why the dropship cost avoidance model calculates
crossdocking
and transportation
costs per pound (rather than per piece) is that
these costs vary primarily with weight (as opposed to mail volume).
If not
confirmed fully, please explain your response.
(c) Please confirm that the Standard Regular mail processing
estimates
(USPS-LR-J-60,
on a per-piece
USPS-LR-J-61,
basis (not a per-pound
and delivery cost
and USPS-LR-J-117)
are calculated
basis) and the reason for this is that these
costs vary primarily with mail volume (as opposed to weight).
If not confirmed
fully, please explain your response.
(d) Are there any significant Standard Mail costs other than crossdocking
transportation
pieces)?
and
costs that vary primarily with weight (as opposed to number of
If so, please identify and quantify these other costs.
POSTCOMIUSPS-T32-10.
Please refer to your response to VP/USPS-T32-l(b)
where you state, “However, if the rate were available and the pieces were
prepared
processing
as automation
on automation
and thickness,
letters, it is my understanding
equipment
not necessarily weight.
meeting all the requirements
that the criteria for
include dimensions
such as length, height
Thus, the fact that a letter-shaped
for automation
compatibility
happens to weigh
between 3.3 and 3.5 ounces should not affect whether it is processed
automation
equipment.”
and 3.5 ounces is as likely to be processed
Mail automation
on
Please confirm, given the adoption of your proposals,
that you believe a Standard Mail automation
Standard
piece
letter weighing between
on automation
equipment
letter weighing less than 3.3 ounces.
3.3 ounces
as a
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the foregoing document upon
all participants of record in this proceeding in accordance with section 12 of the
rules of practice.
c,41a”s4
N. Frank Wiggins
Venable, Baetjer, Howard & Civiletti, LLP
1201 New York Avenue, N.W., Suite 1000
Washington, DC 200053917
202.962.4957
[email protected]
Counsel for Association for Postal Commerce
November
13, 2001