BEFORE THE
POSTAL RATE COMMISSION
Washington,
D.C. 20268-0001
Postal
Rate and Fee Changes,
2000
Docket
)
)
No. R2000-1
AMERICAN BANKERS ASSOCIATION AND
NATIONAL ASSOCIATION OF PRESORT MAILERS
JOINT INTERROGATORIES TO USPS WITNESS MILLER
(ABA&NAPM/USPS-T24-30-42)
(March 22,
Pursuant
Practice,
to Sections
the American
Association
of Presort
interrogatories
instructions
25 and 26 of the Commission's
Bankers
Association
Mailers
(NAPM) hereby
and requests
included
with
ABA&NAPM/USPS-24-1-24
2000)
for
Rules
(ABA) and the
submit
the production
these
National
joint
of documents.
ABA&NAPM interrogatories
are hereby
incorporated
by reference.
ABA&NAPM\USPS-T24-30.
What was the
Undeliverable
extent
As Addressed
available),
(Provide
separately
identify
what
including
USPS's Forwarding/return
and projected
for
return
components
without
Mail
limitation,
cost
in FY1998,
in the test
and for
are included
computer
in FY1999
year
forwarding)?
within
per piece
of
(to the
in this
case
Please
such costs,
forwarding
systems,
of
mail
The
processing,
transportation
Addressed
and delivery
for
Undeliverable
As
Mail.
ABA&NAPM\USPS-T24-31.
What was the
Undeliverable
USPS cost
As Addressed
extent
available),
Please
breakout
by rate
total
Mail
of forwarding/returning
in FY1998,
and projected
these
figures
in the
by class
in
test
FY1999
year
of mail,
(to the
in this
case?
and within
FCLM,
category.
ABA&NAPM\USPS-T24-32.
What percentage
As Addressed
projected
figures
in
of First
FY1998,
in the
by rate
test
Class
in FY1999
year
in this
letter
mail
(to the extent
case?
Please
was Undeliverable
available),
breakout
and
these
category.
ABA&NAPM\USPS-T24-33.
Please
result
confirm
that
of the move update
presort
FCLM and automated
savings
in the
this
fact,
test
please
year
explain
the USPS will
requirements
FCLM.
realize
for
Please
in this
case.
why.
2
savings
non-automation
estimate
If
cost
these
you cannot
cost
confirm
as a
ABA&NAPM/USPS-T24-34.
Page I-l
Class
unit
cost
Benchmark,
confirm
of Appendix
estimates
that
these
unit
cost
applicable
explain
why these
you believe
update
that
confirm
your
requirements,
savings,
but
also
the
presort
forwarding/returning
fact,
please
testimony
does capture
does this
include
which
and
included
explain
not only
in R2000-
why not.
cost
savings
mail
If
of move
processing
and delivery
As Addressed
are
FCLM, and which
of transportation
Undeliverable
Please
any cost
requirements
were not
FCLM
FCLM.
FCLM benchmark;
savings
First
Metered
reflect
and automated
Metered
this
savings
forth
the Bulk
do not
estimates
move update
sets
FCLM and automated
to the Bulk
you cannot
u,
of the move update
to non-automated
are not
testimony
inter
presort
as a result
applicable
If
for,
non-automated
differences
1.
I to your
of
Mail?
ABA&NAPM/USPS-T24-35
Please
processing
Class
explain
fully
direct
labor
and Standard
particular,
is
the
the unusual
costs
(WA,
A letter
mail
change
influenced
spike
cost
between
in unit
segment
mail
3.1)
for
First
FY1996 and FY1997.
by any of the
In
following
factors?
a.
Methodological
changes
including
but
not
(1997)
as opposed
between
limited
the
1996 and 1997 CRA,
to measuring
to attributable
(1996)
volume
variable
direct
labor
caused
a one
costs.
b.
Any settlements
of labor
3
disputes
which
time
increase
Other
C.
in mail
processing
labor
costs.
factors.
ABA&NAPM/USPS-T24-36
In your
the
testimony
on page 17, lines
use of an R97-1 methodology
presort
unit
measure
while
in a 10.337
a.
mail
processing
the
cent
please
as your
explain
estimation
for
estimation
Please
processing
it
route
other
costs
three
presort"
that
change
the
in methodology,
the USPS mail
procedures
category
have if
is
that,
ceteris
paribus,
in R97-1 underestimated
overestimated
the
one rate
in other
the
44% different
than
in R97-1.
confirm
methodology
implies,
due to your
modeling
in
due to a change
what credibility
cost
category.
wage rates?
discussion
is mostly
cent
case results
is due to a change
processing
that
non-automation
in a 7.199
same rate
change
mail
processing
the
the
you state
used in this
and how much is
e.g.
difference
C.
for
How much of this
Assuming,
resulted
methodology
measure
factors,
estimating
costs
different
methodology,
b.
for
12-17,
for
non-automation
true
rate
unit
mail
categories
category;
(ii)
4
if
the
"true"
presort,
processing
unit
then:
costs
in the "non-carrier
underestimated
mail
mail
(i)
for
processing
cost
avoidances
for
categories
in the "non-carrier
the other
route
three
rate
presort"
category.
ABA&NAPM/USPS-T24-37
On page 3, lines
IOCS provides
category
unit
route
presort
three
rate
presort,
cases
for
relevant
level."
processing
mail
Please
costs
you note
processing
explain
for
why the
categories:
basic
and automation
five
Class
the
that
"In
unit
costs
rate
presort),
not
presort.
mail?
If
rate
mail
the
so, which
other
three
Are there
rate
the
(carrier
for
automation
IOCS can be used to produce
workshared
at the
categories
but
automation,
digit
some cases,
IOCS can provide
two workshared
and nonautomation
in which
First
17 -18,
digit
any other
category
one(s)?
If
data
not,
why
not?
ABA&NAPM/USPS-T24-38
On page 4, line
5 please
explain
what you mean by "level
of
prebarcoding."
ABA&NAPM/USPS-T24-39
On page 7 of your
"you
rely
upon the
publication
entitled
a. Please
single
estimated
confirm
piece
in the nature
testimony,
test
lines
18-19,
year
finalization
RCR 2000 Decision
that
your
Analysis
RCR percentages
and metered
mail
of a forecast
5
you state
rate"
test
in a
Request
for
are hypothetical,
DAR for
that
year
(DAR).
First
that
2001.
Class
is
b. Please
year
is
confirm
that
the
finalization
rate
of actual
data
is
53%, while
that
the
your
for
test
the
last
year
forecast
69%?
c. Please
confirm
unit
costs
your
test
of processing
year models
a. being
conclusions
single
hinge
an accurate
about
piece
the
reduced
and metered
on the hypothetical
mail
in
number
in
forecast.
ABA&NAPM/USPS-T24-40
On page 7 of your
"the
actual
RBCS leakage
approaching
leakage
testimony,
the
target
percentages
lines
percentages
value."
by year
you state
that
have been decreasing
Please
for
24-25,
1996,
list
the
1997,
actual
and
RBCS
1998 and 1999.
ABA&NAPM-T24-41
In your
testimony
at page 11 you characterize
processing
cost
methodology
Hatfield's
in R97-1 primarily
in that
processing
"fixed
"worksharing
costs“
as differing
into
worksharing
related",
fixed
to be worksharing
costs
Hatfield's
percentages
page 6) to yours
presort
in the
Hatfield's
first
you separate
related.
in his
Figure
I,
related"
instance
Hatfield
However,
III-A
route
presort
mail
and ‘nonassumed all
comparing
(R97-1,
pages 12 and 13,
non-carrier
mail
from USPS witness
USPS witness
in Appendix
and automation
you appear
witness
while
your
USPS-T-25,
(nonautomation
respectively),
to have moved many costs
cost
"proportional"
6
pool
into
witness
your
out
of
two "fixed"
cost
pools.
benchmark
of his
For example,
CRA (non-carrier
total
CRA benchmark
proportional
route
costs
presort)
for
a. Please
confirm
that
(4.6
that
List
for
his
at 4.2 cents
are
91.3%
total
presort
related
why that
up through
fourth
rate
several
from R97-1 as fixed
for
your
pool
pools
to fixed
in
pools.
in a cost
pool
(whether
related).
was classified
and why it
cost
52 cost
such change
or non-worksharing
cost
R97-1,
the
costs
benchmark].
you have made from proportional
explain
non-carrier
you have reclassified
pools
your
CRA benchmark
costs,
each and every
worksharing
while
(automation
each such change
justify
costs
cents)
benchmark
aggregate
cost
case.
b. Please
costs
65.85% of your
Hatfield
proportional
this
presort)
nonautomation
in the
proportional
route
your
are only
[and 80% of your
category
Hatfield's
That
is
as proportional
is suddenly
no longer
so
classified.
ABA&NAPM/USPS-T24a.
Please
group
42
by number of bins
in use by the
For example,
b.
Postal
each grouping
processing
for
cost
concerning
array
Class
of MLOCRs
Letter
for
above underlies
First
Mail.
150 have 90 bins,
the number of sweepers
identified
studies
current
First
100 OCRs have 60 bins,
What assumption
for
Service
the
Class
Letter
your
etc.
per MLOCR
mail
Mail?
Respectfully
submitted,
AMERICAN BANKERS ASSOCIATION
NATIONAL ASSOCIATION OF PRESORT MAILERS
Henry A. Hart
Reed Smith Shaw & McClay
1301 K street
N.W.
Suite 1100 - East Tower
Washington,
DC 20005
Ph: 202-414-9225
Fax: 202-414-9299
Counsel for
National
Association
Of Presort
Mailers
March 22,
Washington,
LLP
Irving
D. Warden
Assoc. General Counsel
American Bankers Association
1120 Connecticut
Ave., N.W.
Washington,
DC 20036
Ph: 202-663-5035
Fax 202-828-4548
Counsel for
American Bankers
2000
D.C.
CERTIFICATE OF SERVICE
Association
I hereby
document
certify
to be served
proceeding
that
I have this
upon all
in accordance
with
date
participants
Section
caused
of record
12 of the
Practice.
Irving
1120 Connecticut
Avenue,
Wash.ington,
D.C.
20036
Ph: (202)
663-5027
fax:
(202) 828-4548
email:
March
[email protected]
22,
2000
N.W.
the
D. Warden
Rules
foregoing
in this
of