RECEIVED
Jun19 4 58
BEFORE THE
POSTAL RATE COMMISSION
Washington,
D .C. 20268-0001
Postal
Rate
and Fee Changes,
PM ‘00
p0STf.iRKT!:CCldH!:.‘3C>H
OFFlCEOFTHESCCRETAtlY
2000
Docket
No. R2000-1
AMERICAN BANKERS ASSOCIATION AND
NATIONAL ASSOCIATION OF PRESORT NAILERS
JOINT INTERROGATORIES TO E-STAMP WITNESS PRESCOTT
(ABA&NAPM/E-STAMP-TZ-l-12)
(June
Pursuant
Postal
Rate
National
to Sections
interrogatories
witness
able
of Presort
and requests
for
or produce
the
to do so,
interrogatory
Practice
submit
of the
and the
these
joint
If
of documents.
directed
requested
of
Association
hereby
production
is
the
Rules
Bankers
Mailers
to whom an interrogatory
interrogatory
2000)
25 and 26 of the
the American
Commission,
Association
19,
is unable
documents
or request
to answer
and another
should
the
be referred
the
person
is
to such
person.
If
data
of detail
format
requested
requested
shall
should
include
part
for
be accompanied
material
or electronically,
used.
of the
Such workpapers
witness's
in
in
the
(1)
(2) susceptible
should
to requests
backup
available
available
or
and detail
all
mechanically
of paper
of detail
format
Responses
numbers
any data
requested,
or level
are not
responses
exact
format
substantially
to being
or level
similar
converted
to the
be provided.
explanations
or the
by workpapers.
whether
should,
The terms
prepared
and without
if
and should
derivation
of
"workpapers"
manually,
consideration
to the
type
necessary,
be prepared
as
"show what
the
numbers
what
were,
numbers
were
The witness
result."
is possible
primary
for
Docket
should
a third
source
added
party
Tr.
Letter
wherein
Mail
Please
confirm
Table
1 assumes
workpapers
how he took
to achieve
Please
cost
b.
that
refer
his
so that
data
from
final
to Tables
savings
If
for
IBI
confirm
Table
2 assumes
it
a
results."
1 and 2 of your
First
basic
feature.
If
Class
ABA&NAPM/ E-Stamp-T2-
non-automated
you cannot
presort
FCLM is
please
ABA&NAPM/E-Stamp-T2sorting
delivered
functions
basic
please
savings
cost
of
in your
savings
of
presortation
IBI
as single
savings
why not.
explain
that
to the
why not.
FCLM is
piece
mail,
USPS as bulk
and that
mail.
If
why not.
Please
confirm
to separate
from non-automated
explain
of the
the
in your
presortation
of cost
confirm
system
explain
3.
confirm,
cost
basic
please
for
Please
USPS collection
confirm,
to perform
2.
the
FCLM has all
FCLM, except
savings
of the
calculation
IBI
you cannot
for
confirm,
your
that
of cost
FCLM has all
FCLM, except
that
automated
calculation
IBI
you cannot
Please
to the
your
that
automated
feature.
explain
1.
you calculate
presort
receives,
data
a final
("FCLM")
a.
delivered
sufficient
to understand
that
to achieve
10/2795-96.
ABA&NAPM/ E-Stamp-T2testimony
numbers
"prepare
and developed
No. R83-1,
to other
If
mail.
the
that
IBI
the
USPS will
FCLM which
you cannot
confirm,
have
it
please
why not.
ABA&NAPM/E-Stamp-T2-
of cost
savings
each instance
a.
for
if
That
IBI
4.
confirm
that
FCLM, you have assumed
you cannot
the
Please
indicia
so confirm,
on IBI
explain
FCLM will
the
in your
following
why not):
be legible.
calculation
(and in
b.
That
all
IBI
software
and will
of the
That
C.
are
been short
accurately
That
the
USPS will
the
proper
size,
to the
postal
of the
of
average
IBI
FCLM to assure
that
the
not
inspect
IBI
FCLM to assure
that
it
paid,
and that
it
IBI
inspect
on such mail
service
confirm
in banded
Please
6
Tables
that
of all
(in
the
case of your
Table
2) is
provided
with
presort
ABA&NAP!.?/ E-Stamp-T2in
three
possible
but
not
barcoded,
recognizes
(barcoded
forms:
not
receives
Category
possible
that
where
it
efficiences
2
mail
in
Category
the
sortation
but
FCLM
not
calculation
that
of
the value
automated
presorted
value
FCLM
FCLM
of the
If
FCLM.
you cannot
the USPS can receive
not
and barcoded.
where
it
receives
and savings
(presorted
the USPS would
receives
non-automated
1) barcoded
presorted),
your
basic
to the
Assume that
7.
of one unit
IBI
is
why not.
or 3) presorted
savings
but
identical
explain
the
it
trays.
presorted
1) and of automated
please
that
FCLM is
1 and 2 assumes
Table
fact,
IBI
and sleeved
confirm
of presortation
even if
that
case of your
this
and
by means of a label.
Please
5.
FCLM to assure
the
confirm
has been honestly
and dimensions,
FCLM in your
degree
IBI
(in
presortation
use
inspect
shape
ABA&NAPM/ E-Stamp-T2savings
unauthorized
not
not
ABA&NAPM/ E-Stamp-T2-
cost
or other
authorized
weighed.
has been placed
delivered
no fraud
from
sealed.
the USPS will
has not
e.
entail
the USPS will
That
have been produced
indicia.
envelops
d.
FCLM will
but
recognize
3 mail
presorted,
If
not
schemes which
the
USPS
1 mail
where
barcoded),
savings
(presorted
2) presorted
Category
of one unit
FCLM
is
of more than
and barcoded)
can be utilized
it
it
not
two units
due to the
by the USPS
when it
receives
possibility
such Category
in your
cost
savings
ABA&NAPM/E-Stamp-TZ-8.
in USPS witness
following
Miller's
automation
b.
"presorted
non-automation
C.
"presorted
BMM", p.
on subtracting
single
rate
savings
a 3 rate
category
7 and p.
confirm
in LR-I-81
category
for
8, Table
7 and p.
that
or
the
1
8, Table
in Table
in
automation"
aggregate
aggregate
1 and 2?
1
1
presorted
category
Tables
nowhere
a cost
BMM", p.
Please
this
testimony:
8, Table
for
that
there
BMM", p.
ABA&NAPM/E-Stamp-T2-9.
‘cost
is
used in your
"presorted
in your
confirm
testimony
a.
calculated
measurements
Please
classifications
Did you consider
3 mail?
line
(automation
(non-automation
the
1,
3 is based
presort)
from
a
presort).
ABA&NAPM/E-Stamp-T2-10.
a.
Please
confirm
Table
1 includes
5 digit
b.
estimated
cost
and 1.239
cents,
Please
cost
confirm
avoidance
Please
aggregate
to 3 digit
which
USPS witness
you use in
presortation
and
Miller
due to presortion
of
0.986
cents
respectively.
light
of your
in
line
associated
savings
confirm
category
subject
for
in
avoidance
3 rate
letters
you measure
substantial
that
of Table
1 do not
automation
alone,
digit
the
presortation,
savings
C.
that
and 5 digit
3 of Table
with
for
3 digit
the
cost
measure
but
to a. that
answer
1 do not
automation
alone,
and 5 digit
savings
the
cost
include
measure
but
the
include
presortation.
you measure
avoidance
substantial
cost
in
line
associated
savings
for
7
with
3
presortation.
ABA&NAPM/USPS-TZ-11.
a.
Please
confirm
figure
from
that
LR-I-81
in Table
that
1, you have not
relates
to single
used ~,ny cost
piece
mail,
and
that
your
letter
header
for
not
mail,
1n light
b.
label
single
piece
BMM refers
single
piece
letters.
of your
for
single
line
answer
7 that
piece
"witness
savings
Miller's
related
a.
Please
Table
cost
confirm
how can you claim
you have measured
On page
analysis
to single
9 of your
the
testimony
must be adjusted
"cost
in the
savings
piece
versus
that
nowhere
you state
to eliminate
the
cost
BMM."
in your
testimony,
2, do you make such an adjustment
savings
entered
automation"?
ABA&NAPM/E-Stamp-TZ-12.
that
to a.,
to bulk
associated
with
a single
that
all
the
worksharing
2 are
for
bulk
including
to calculate
piece
the
automation
letter.
b.
Please
confirm
use in Table
piece
entered
entered
cost
mail,
categories
and not
single
mail.
Respectfully
submitted,
AMERICAN BANKERS ASSOCIATION
NATIONAL ASSOCIATION OF PRESORT
MAILERS
Henry A. Hart
Reed Smith Shaw & McClay
N.W.
1301 K street
Suite 1100 - East Tower
Washington,
D.C. 20005
Ph: (2021-414-9225
Fax: (202)-414-9299
Counsel for
National
Association
Of Presort
Mailers
Date:
June
Washington,
19, 2000
D.C.
LLP
Irving
D. Warden
Assoc. General COUnSel
American Bankers Association
1120 Connecticut
Ave., N.W.
Washington,
D.C. 20036
Ph: (2021-663-5035
Fax: (202)-828-4548
Counsel for
American Bankers
Association
you
CERTIFICATE
I hereby
document
proceeding
certify
to be served
that
Henry A. Hart
Reed Smith Shaw & McClay
1301 K Street
N.W.
Suite llOO- East Tower
Washington,
D.C. 20005
Ph: (202) 414-9225
Fax: (202) 414-9299
June
19,
2000
I have this
upon all
in accordance
OF SERVICE
with
LLP
date
participants
Section
caused
the
of record
12 of the
Rules
foregoing
in
this
of Practice.