fiECEly~[t
BEFORE THE
POSTAL RATE COMMlSSlON
WASHINGTON,
DC 20266-0001
lpi? 26 c? 42 /‘h ‘00
P3sr:~~;;,i-i
Docket No. R2000-1
Postal Rate and Fee Changes, 2000
FIRST INTERROGATORIES
OF ALLIANCE OF NONPROFIT
TO USPS WITNESS UNGER (ANMlUSPS-ST43-1-4)
The Alliance
interrogatories
43).
ANM
OCWUSPS-1-14
of Nonprofit
and document
incorporates
Mailers
requests
by
(“ANM”)
respectfully
to USPS witness
reference
the
MAILERS
submits
the attached
Dennis R. Unger (USPS-ST-
instructions
in
OCA
interrogatories
(filed Jan. 24, 2000).
Respectfully
&&r’i’&d$P
submitted,
~.
David M. Levy
Christopher T. Shenk
Sidley &Austin
1722 Eye Street, N.W.
Washington, DC 20006-3704
(202) 7366214
Counsel for Alliance of Nonprofit Mailers
April 26, 2000
QUESTIONS
ANMIUSPS-ST-43-1.
In Section IV of your testimony,
In particular,
discuss the issue of flat sorter productivity.
Area productivity
declined
work hour, a decline
impression
you note that the Southeast
changes
in productivity
per work hour to 545 total pieces handled
of some 28 percent.
have had a very significant
of a loss in productivity.”
(Emphasis
impact, but have contributed
b.
Have these “beneficial
operational
Produce
changes”
all
data
operational
changes”
over this period?
indicating
the
operational
If so, please explain how.
extent
more efficient when performed
You contend
changes.”
been effective to offset fully
to which
have offset the apparent decline in productivity
ANMIUSPS-ST-43-2.
to the
added.)
Please identify and describe each such “beneficial
the apparent decline in productivity
per
You note that “beneficial
a.
C.
on page 13, you
trend has followed the national trend, and over the past four years has
from 711 total pieces handled
operational
beginning
that sorting
on FSM 881 equipment,
these
“beneficial
over this period.
mail to carrier route is
but note that throughput
of the
machine is affected by the change from one set of five digit zones to another.
a.
Do the guidelines
now in place assure that decisions
machine utilization are offset by greater savings generated
b.
Describe
these guidelines
produce copies of all such guidelines
C.
personnel
Provide
examples
and the process
negatively
affecting
in other areas?
in which they are used, and
in current use.
of how tradeoff
utilization are evaluated to determine
decisions
regarding
if they were truly effective.
machine
and
d.
regional
Produce copies of all such evaluations
management
performed
for Florida, Georgia, Alabama,
Postal Service headquarters
since 1993 by or for (1)
Mississippi
or Tennessee
or (2)
management.
ANMIUSPS-ST-43-3.
In your testimony
on page 13, lines 26 through 30,
you discuss utilization of the FSM 1000 equipment.
a.
Please explain what you mean by the statement,
have moved all volume for given operations
b.
“many processing
plants
to this equipment.”
Explain the causal link, if any, between
the stated phenomenon
and the
rising cost of handling periodical mail.
Produce all data that support your response to part b.
C.
ANMIUSPS-ST-43-4.
of achievement
of operating
as an organizational
circumstances,
as processing
On page 15, lines 8 through 12, you raise the issue
budget and net income.
Please confirm that giving primacy
goal to meeting the “bottom line operational
lead to sub-optimized
performance
in a particular
cost segments
(such
periodicals).
a.
If you do not confirm, please explain fully.
b.
If you do confirm, please identify all standards
the Postal
budget” can, in some
Service
to avoid harming
and procedures
either the cost or quality
adopted by
of serving
particular
classes of mail.
C.
Please produce all data, studies, analyses
for a third party to verify your responses
to parts a and b.
-2-
and other documents
needed
CERTIFICATE
I hereby
participants
certify that I have this day served
of record in this proceeding
Practice.
April 26, 2000
OF SERVICE
in accordance
the foregoing
document
on all
with section 12 of the Rules of