OFFICE OF THE SECRETARY
POSTAL RATE COMMISSION
WASHINGTON,
D.C. 20268-0001
POSTAL RATE AND FEE CHANGES,
2000
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Docket No. R2000- 1
AMERICAN
BANKERS
ASSOCIATION
AND
NATIONAL
ASSOCIATION
OF PRESORT MAILERS
JOINT INTERROGATORIES
TO USPS WITNESS MAYES
(ABA&NAPM/USPS-T32-1-6)
(March 17, 2000)
Pursuant
Commission,
Mailers
to Sections 25 and 26 of the Rules of Practice of the Postal Rate
the American
Bankers Association
and the National
hereby submit these joint interrogatories
The instructions
included
with interrogatories
2000) are hereby incorporated
ABA&NAPM/USPS-T32-1
Reorganization
a.
Association
and requests for production
ABA&NAPM/USPS-T24-1-24
of Presort
of documents.
(February
18,
by reference
Please confirm
that ratemaking
criterion
6 of the Postal
Act [(39 U.S.C. § 3622(b)(6)):
does not exclude mailer preparation
of First Class single piece letters
and
flats
b.
refers to “reducing
or attributable
costs to the Postal Service”, not only volume variable
costs
costs
c.
does not specify the technical
d.
does not limit
means by which rates are to reflect criterion
the cost reductions
costs or volume variable
costs
from mailer preparation
to attributable
6
ABA&NAPMIUSPS-T32.2
a.
Please explain
testimony
b.
how you calculated
the 3.4% and 3.8% numbers
on page 20, lines 13 and 16, respectively.
Please confirm
that the percentage
rate increase for one ounce single piece letters
this case, which you reference in the same sentence
cents”,
c.
Please confirm
that the unweighted
letters
“[wlorksharing
Regarding
removes attributable
please confirm
categories)
your statement
additional
institutional
45 billion
not
45
letter mail per year, were such volumes
sector to USPS for processing.
that the costs to the Postal Service of collecting
pieces of letter mail per year would entail
and preparing
an
an increase in
costs.
ABA&NAPMKJSPS-T32-4
over incremental
costs unchanged.“:
costs to the Postal Service of having to process an additional
from private
Please confirm
on page 10, lines 10-11, that
only applies to costs changes at the margin,
pieces of First Class workshared
transferred
in this case is 4.2%, not 3.8%.
costs but leaves institutional
that your statement
the incremental
b.
as a one cent increase “to 34
average rate increase for one ounce First Class
(in all worksharing
ABA&NAPM/USPS-T32-3
billion
in
is 3.0%, not “3.4 percent”.
workshared
a.
found in your
On page 17, lines 10-12, you state that “any excess of revenue
cost means that the Postal Service’s provision
of that subclass benefits
other subclasses.”
a.
Please explain
in full detail what you mean by “benefits”.
b.
Please confirm
that the larger the revenue contribution
by a subclass, the larger the benefit conferred
c.
In your testimony,
d.
If your answer to c. is in the negative,
cost
on other subclasses.
did you consider how to quantify
2
over incremental
these benefits?
would a quantitative
determination
of
those benefits,
if it was made, influence
Apart from the purely technical
e.
measured]
incremental
the rates set in this case?
definition
relating
costs, please confirm
cross subsidy to [perfectly
that your statement
says in
essence that “any excess of revenue over incremental
cost means that the
Postal Service’s provision
the provision
subclasses.”
ABA&NAPM/USPS-T32-5
of that subclass subsidizes
If you do not confirm,
please explain
of other
fully.
You state on page 21, lines 11-12, that “The percentage
increase
for First Class Letters of 3.5% ranks as one of the lowest increases proposed in this case”.
Please confirm
Workshared
that the percentage
Letters
increases as proposed in this case for First Class
first ounce are not 3.5%, but between 3.7% and 4.92X, while the rate
increase for First Class single piece letters is 3.0%.
ABA&NAPM/USPS-T32-6
On page 23, line 5, you indicate
First Class Letter Mail “substantially
exceeds” incremental
that proposed revenues
for
costs. You then in the very next
sentence at line 8, go on to claim that this is “fair and equitable”.
a.
Do revenues that exceed incremental
“substantial”
costs by a moderate
amount meet the incremental
amount but not a
cost test for lack of a cross
subsidy?
Why would it not be as fair and equitable
Mail revenues to exceed incremental
(or more fair and equitable)
costs by a moderate
amount?
3
for First Class Letter
amount rather
than a substantial
Respectfully
submitted,
AMERICAN
NATIONAL
BANKERS ASSOCIATION
ASSOCIATION
OF PRESORT MAILERS
Henry A. Hart, Esq.
Reed Smith Shaw & McClay LLP
1301 K Street N.W.
Suite 1100 - East Tower
Washington, DC 20005
Ph: 202-414-9225
Fax: 202-414-9299
Irving D. Warden
Assoc. General Counsel
American Bankers Association
1120 Connecticut Ave., NW
Washington, DC 20036
Ph: 202-663-5035
Fax: 202-828-4548
Counsel for
National Association
of Presort Mailers
Counsel for
American Bankers Association
Date:
March 17, 2000
Washington, D.C
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the instant
of record in this proceeding
March
17, 2000
document
on all participants
in accordance with Section 12 of the Rules of Practice.