BEFORE THE
POSTAL RATE COMMlSSlDN
WASHINGTON, D.C. 20268-0001
POSTAL RATE AND FEE CHANGES, 2000
Hnn IS Lj 56 p/i ‘@J
‘L1-1:\ : ,,
Jil.>:,: ‘,, ,, :,;
,I,!‘.
Docket No. R2000-1
j
RESPONSE
OF UNITED STATES POSTAL SERVICE
TO INTERROGATORIES
OF
THE ASSOCIATION OF PRIORITY MAIL USERS, INC.
REDIRECTED FROM WITNESS ROBINSON
(APMUIUSPS-T34-20
and 26 (a)(ii) and (iii) and (b)(ii) and (iii))
The United States Postal Service hereby provides its responses
interrogatories
of the Association
to the following
of Priority Mail Users, Inc.: APMU/USPS-T34-20
and
26 (a)(ii) and (iii) and (b)(ii) and (iii), filed on March 2, 2000, and redirected from witness
Robinson.
An objection to APMUAJSPS-T34-26(a)(i)
and (iv) and (b)(i) and (iv) was
filed on March 13, 2000.
Each interrogatory
is stated verbatim and is followed by the response.
Respectfully
submitted,
UNITED STATES POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
La/b
Susan M. Duchek
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-l 137
(202) 268-2990 Fax -5402
March 16,200O
RESPONSE OF THE UNITED STATES POSTAL SERVICE TO
INTERROGATORY
OF THE ASSOCIATION OF PRIORITY MAIL USERS
(REDIRECTED FROM WITNESS ROBINSON, USPS-T-34)
APMUIUSPS-T34-20.
Please provide as a library reference
carriers now in effect.
the contract(s)
with commercial
air
RESPONSE
The Air System
contract
will be provided
in USPS Library
Reference
l-228,
RESPONSE OF THE UNITED STATES POSTAL SERVICE TO
INTERROGATORY
OF THE ASSOCIATION OF PRIORITY MAIL USERS
(REDIRECTED FROM WITNESS ROBINSON, USPS-T-34)
APMU/USPS-T34-26.
a. What is the per-pound terminal handling charge and the perpound/mile charge for Priority Mail currently paid for
air taxis,
(0
(ii)
intra-Alaska
commercial air,
(iii)
intra-Alaska
air to the Bush, and
any other air operators (other than regular commercial
(iv)
airlines) used by the Postal Service to transport Priority Mail?
b.
Do any existing contracts with any of the above expire
prior to the end of Test Year? If so, please stipulate the
contract and date.
C.
Please identify any constraints on Postal Service
procurement
of air transportation
services in Alaska imposed
by law.
RESPONSE
a.(i)
Objection
filed on March
a. (ii) The Postal Service
to mainline
13, 2000.
assumes
intra Alaska
by the U.S. Department
by commercial
air service.
air that you are referring
The mainline
of Transportation
rates promulgated
in effect as of March 8,
2000 are:
Priority
pound
Linehaul:
per ton-mile
or $0.0007563
per
mile
Non-priority
pound
$1.5126
Linehaul:
$0..9517
per ton-mile
or $0.0047585
mile
Priority Terminal
Non-priority
Handling:
Terminal
$0.2519
Handling:
per pound
$0.2165
per pound
per
RESPONSE OF THE UNITED STATES POSTAL SERVICE TO
INTERROGATORY
OF THE ASSOCIATION OF PRIORITY MAIL USERS
(REDIRECTED FROM WITNESS ROBINSON. USPS-T-34)
Linehaul
rates are subject
adjustment
is expected
to a quarterly
sometime
Linehaul:
$9.9746
Terminal
Handling:
$$0.3591
per ton-mile
a.(iv)
Objection
filed on March
13, 2000.
b.(i)
Objection
filed on March
13. 2000.
b.(ii)
The mainline
September
30, 2000.
expected
b.(iii)
Service
are:
or $0.0049873
per pound.
of a base rate
The base rates will stay in effect until
The fuel adjustment
is quarterly,
with one
in March 2000.
The DOT bush rates expire on April 1, 2000.
reviewing
proposed
b.(iv)
Objection
filed on March
C.
Without
purporting
relevant
statutory
provisions,
following
general
information.
the Alaska
established
service
per pound-mile
DOT rates are the combination
and a fuel adjustment.
The next
in March 2000.
a. (iii) The DOT bush rates for intra-Alaska
linehaul
fuel adjustment.
carriers
rates which
provided
have not been finalized.
13, 2000.
to represent
selected
by DOT.
The DOT is currently
any definitive
interpretation
the Postal Service
can provide
The Postal Service
is required
of the
the
to use
by DOT and pay them the rates
The Postal Service
by the DOT-regulated
can only contract
carriers
is insufficient
when the
to meet
RESPONSE OF THE UNITED STATES POSTAL SERVICE TO
INTERROGATORY
OF THE ASSOCIATION OF PRIORITY MAIL USERS
(REDIRECTED FROM WITNESS ROBINSON, USPS-T-34)
the needs of the Postal Service.
Postal Service
contacting
change
or add service.
Service
needs,
scarcity
individual
preceded
and asking
provide
can contract
this option
by the
them to
what the Postal
for air taxi service.
has the option to use contract
however,
of roads.
carriers
If they cannot
the Postal Service
The Postal Service
transportation;
This is usually
surface
is limited by such factors
as the
CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoing document upon all
participants of record in this proceeding in accordance with section 12 of the Rules of
Practice.
irr.B4
Susan M. Duchek
475 L’Enfant Plaza West, SW.
Washington, DC. 20260-l 137
(202) 268-2990 Fax -5402
March 16.2000