BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, DC. 20268-0001
OCTIO II 41PH '01
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Docket No. R2001-1
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POSTAL RATE AND FEE CHANGES, 2001
RECEIVE11
RESPONSE OF UNITED STATES POSTAL SERVICE
WITNESS L. PAUL LOETSCHER TO INTERROGATORY
OF
MAGAZINE PUBLISHERS OF AMERICA, INC. (MPAAJSPST41-1)
The United States Postal Service hereby files the response of witness L. Paul
Loetscher to the following interrogatory
MPA/USPS-T41-1,
of the.Magezine
Publishers
of America, Inc.:
filed on October 4,200l.
The interrogatory
is stated verbatim and is followed by the response.
Respectfully
submitted,
UNITED STATES POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
qf&& f72&
Brian M. Re;me‘r
Attorney
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-l 137
(202)268-3037 Fax-5402
[email protected]
October 18,200l
RESPONSE OF UNITED STATES POSTAL SERVICE
WITNESS L. PAUL LOETSCHER TO INTEROGATORY
OF
MAGAZINE PUBLISHERS OF AMERICA, INC.
MPA/USPS-T41-1:
Table 2 of USPS-LR-J-114 disaggregates Periodicals Outside-County mail volume,
weight, and number of containers by entry facility type, container type, and container
size. Using the data used to produce Table 2, please provide an estimate of the
number of Periodicals Outside-County sacks there are by sack size (i.e., number of
pieces in sack), sack presort level, and entry facility. If the study did net collect enough
detail to provide such an estimate, please provide an estimate of the number of sacks
by sack size and sack presort level using the most recent data available. Please also
describe the data source you used to develop the estimate.
RESPONSE:
Table 2 of LR-J-114
does not disaggregate
Periodicals
Outside-County
weight and numbe,r of containers
by entry facility, container
Table 2 of LR-J-114 disaggregates
Periodicals Outside-County
number of containers
by entry facility type, container
The study presented
in LR-J-114
distribution
did not collect
in LR-I-87/R2000-1
sacks by sack size, and presort level. This distribution
in LR-J-114.
T41-1. As preparation
rules have changed
distribution
size.
mail volume, weight and
the data needed
is used to estimate
sack counts presented
type and container
type and container
of sacks by size, presort level and entry facility.
study presented
mail volume,
presort level.
to estimate
the
To provide an estimate, the
the FY1999
distribution
of
is then applied to the estimated
The results are presented
in Table 1 - MPANSPS-
since LR-I-87/R2000-1
here may not be reflective of the current distribution
was conducted,
of sack sizes.
the
,..
n
.
-.
.
.
.
DECLARATION
I,
that
the
foregoing
of my know ledge,
Dated:
declare
L. Paul Loetscher,
answers
informat
ot c. 0 t: et- I
are true
ion,
8.2cx3d
under penalty
of perjury
and correct
to the best
and belief.
CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoing document upon all
participants
of record in this proceeding
Practice.
475 L’Enfant Plaza West, SW.
Washington, D.C. 20260-l 137
October 18,200l
in accordance
with section 12 of the Rules of