RECEIVE8
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D. C. 20266-0001
POSTAL
RATE AND FEE CHANGES,
JIJN8 4 26 PM‘DO
Docket
2000 )
No. R2000-1
MOTION OF MPA ET AL. TO INCORPORATE
INTO EVIDENCE USPS RESPONSES TO UPS/USPS-T12-12-17
AND USPS
LIBRARY REFERENCES LR-I-310, LR-I-366 AND LR-I-396,
OR, IN THE ALTERNATIVE,
TO DIRECT THE POSTAL SERVICE TO PROVIDE A
SPONSORING WITNESS FOR SAID LIBRARY REFERENCES
(JUNE 6,200O)
Pursuant
to the Commission’s
Advo Inc., Alliance
Postal Commerce,
Associations,
of Nonprofit
Association
Direct Marketing
Order Association
Association,
of America,
Parcel Shippers
move the incorporation
UPS/USPS-T12-12-17
310, LR-I-386
Rules, Magazine
Mailers,
American
Publishers
Business
of American
Publishers,
Association,
Inc., Dow Jones
The McGraw-Hill
Association
into evidence
and LR-I-398,
Coalition
Companies,
and Time Warner
of Religious
& Company,
or the Direct Testimony
and Crowder
Press
Inc., Mail
Newspaper
Baron’s
responses
to
LR-I-
request that the Postal Service be
witness for said library references.
of Antoinette
Crowder
(MPA-T-5)
of Rita Cohen (MPA-T-1)
or both.
(at 5) both argue that Postal Service
data are unreliable
carrier street time activities,
for
Inc. (“MPA et al.“) hereby
of Postal Service witness
or, in the alternative,
(MPA),
Association
Inc., National
The above parties are sponsors of the Direct Testimony
Delivery Redesign
Media,
(filed June 2, 2000) and Postal Service library references
directed to provide a sponsoring
(at 28-30)
Of America
and inappropriate
but that if the Commission
Witnesses
witness
for determining
Cohen
Raymond’s
proportions
of
were to use that data, it must
also
use the corresponding
volumes
derived
from
that
same
data
collection
to
determine the variability of those activities.
The Postal Service’s
LR-I-310
on May
“Draft Report on Load Time Analysis,”
12, in fulfillment
ADVOIUSPS-T-12-11
of witness
Baron’s
statement
that he was “aware of a preliminary
in approximately
notice of filing of Library Reference
any questions
Baron.”
concerning
this library reference,
The notice does not, however,
“sponsor”
two weeks”
USPS-LR-I-310
of the library reference.
expressly
designated
interrogatories
to
the
data base” and that the
and filed as LR-I-310.
The
(May 12, 2000) states: “If there are
they should
be directed
denominate
witness
USPS-LR-I-310
on the Postal Service’s
with
filing
of
LR-I-310,
to witness Baron concerning
17, filed May 18, 2000).
provided
analysis
to witness
Baron as the
is
itself was not filed
direct case, too late to be
into evidence through the ordinary procedure.
Subsequent
along
to
Witness Baron’s answer to ADVO/USPS-T12-11
on the record at Tr. 18/7094, but Library Reference
until after the close of hearings
in response
load-time variability
that is based on the time study data in the Delivery Redesign
study would be “completed
was filed as USPS
an additional
in LR-I-310.
United
Parcel
this Library Reference
Service
(UPS/USPS-T12-12-
On June 2, the Postal Service filed responses
library
reference,
LR-I-386,
further
In the course of those responses,
use of the Delivery Redesign
data base, as presented
386, as the best basis for determining
witness
directed
refining
from Baron,
the analysis
Baron espoused
the
in LR-I-310 and refined in LR-I-
the volume variability of carrier street time costs
available on the record of this case:
The latest revised regression that is estimated through use of ES volume
and deliveries data, and that produces the results summarized in Tables
3B and 4B presented in my interrogatory UPS/USPS-T12-16
response,
produces volume variabilities that are more reliable than those produced
by the SDR, MDR, and BAM regressions
currently
used by the
Commission
and the Postal Service, or by any other regressions
submitted into evidence to date. Therefore, I believe that these new ES-
based variabilities
BAM variabilities.
Response
should replace the current Base Year SDR, MDR, and
to UPS/USPS-T12-13
(June 2,200O).
Four days later, the Postal Service filed an additional
LR-I-398 (“Derivation
of New Segment 7 Volume Variable Costs, Produced
to UPS/USPS-T12-13
(Baron)“),
which it described
variability
provided
in response
information
witness Baron.”
USPS-LR-I-398
of determining
that the Postal Service’s
witness Baron’s responses
proportions
to
use of the Delivery Redesign data base
determine
to use
of carrier street time activities, MPA et al. have
filing of library references
to interrogatories
We believe
310, 386 and 398 -- along with
and his support of the use of those library
-- amount in fact, if not yet in name, to sponsorship
We also believe, however, that fairness to our witnesses
would be served by an evidentiary
of
who
ruling clarifying the
status before these witnesses take the stand.
Accordingly,
MPA et al. respectfully
UPS/USPS-T12-12-17
move that witness
and USPS library references
into evidence in this case and transcribed
as the Presiding
Officer
shall prescribe.
of these materials
LR-I-310,
LR-I-386
into evidence
and LR-I-398
time be subject to cross-examination
LR-I-310,
Baron’s
LR-I-386
responses
inappropriate
and LR-I-398
if the Commission
deems
at this time, MPA et al.
a sponsoring
witness
for library
so that they may at an appropriate
and incorporation
to
into the record at such later time
Alternatively,
move that the Postal Service be directed to present
references
UPS/USPS-T-12-13
position due to the fortuities of the calendar.
rely on those library references
incorporation
“city carrier volume
volume variability should the Commission
by the Commission
those library references.
be accepted
in Response
(June 6,200O).
been placed in an ambiguous
references’
USPS-
Notice of United States Postal Service of Filing of Library Reference
that data base to determine
references
as containing
to interrogatory
As sponsors of testimony also espousing
for purposes
library reference,
into the evidentiary
record.
future
Respectfully
submitted,
w
Anne R. Noble
Counsel
Magazine Publishers of America,
Suite 610
1211 Connecticut Ave. NW
Washington DC 20036
(202) 296-7277
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served
participants of record in this proceeding in accordance
Practice.
Washington DC
June 8,200O
Inc.
the foregoing document on all
with the Commission’s Rules of