iiEt:Ei\y;t .I
OFFICE OF THE SECRETARY
POSTAL RATE COMMISSION
WASHINGTON,
D.C. 20268-0001
POSTAL RATE AND FEE CHANGES,
2000
:
3 ?I4 ;‘jf
/;#j 17
., i,~
,,.
Docket No. R2000-I
AMERICAN
BANKERS
ASSOCIATION
AND
NATIONAL
ASSOCIATION
OF PRESORT MAILERS
MOTION
TO COMPEL A MORE RESPONSIVE
ANSWER
USPS WITNESS MILLER
TO INTERROGATORY
ABA&NAPMlUSPS-T24-1
(March 17, 2000)
Pursuant
to Section 26(d) of the Commission’s
Bankers Association
respectfully
and the National
ABA&NAPMKJSPS-T24-1
thereto
are attached
In Table 1 of his testimony,
costs for worksharing
worksharing-related
Exhibit
of Presort Mailers
(“NAPM”)
to provide a more responsive
(a copy of this interrogatory
at Exhibit
OF
Rules Of Practice, the American
Association
move to compel USPS witness Miller
interrogatory
“response”
(“ABA”)
‘/j/j
answer to
and the USPS
A hereto)
USPS witness Miller
mail, and for the benchmarks
sets forth total mail processing
therefor,
savings for such mail.
A copy of Miller’s
ABANAPMKJSPS-T24-1
asked Miller
unit
along with the resulting
Table 1 is attached
hereto as
B
Interrogatory
costs and resulting
worksharing
in R97-1 and of the Commission
Miller’s
the mail processing
savings in his Table 1, using the methodology
for the cost models which he used were not compatible
used in R97-1 and that therefore
of the USPS
in R97-1.
answer to this request was, to say the least, non-responsive.
that the data inputs
is admitting
to reproduce
he could not “simply”
reproduce
Miller
with the models
Table 1. Basically,
that he has made so many changes to the R97-1 methodology,
claimed
Miller
that it is difficult
for him to reproduce
Table 1 using the R97-1 methodology.
of rate cases is increasing
parties to participate
complexity
worksharing
We submit
at such a pace that it is becoming extremely
meaningfully
difficult
for the
in the case. The USPS has added significantly
in this case by utilizing
a drastically
different
methodology
now wants to use this as an excuse to avoid providing
savings measurement
the Commission
methodology
to the
to measure
savings than was used in R97-1 by either the Commission
the results of a worksharing
that the complexity
or the USPS. Miller
and the parties
which is consistent
with
with
that used in R97-1.
We submit that the information
appropriate
under the standard
“reasonably
calculated
is most important
requested
of Commission
to lead to admissible
and relevant
discounts
worksharing
savings set forth in Miller’s
is the measurement
the USPS under its own methodology
USPS pricing
interrogatory
information
savings.
in establishing
The automated
FCLM
Table 1 are less than those found for such mail by
under its
Fronk (T33) stresses this fact in his testimony,
is declining.
[See testimony
of USPS witness
Fronk
at page 20, lines 12-141.
savings have actually
have in fact increased,
consistent
and that such requested
of worksharing
witness,
The only way for the Commission
worksharing
evidence,”
in R97-1 and than found by the Commission
that the value of worksharing
(USPST33)
Rule 25(a) which allows discovery
factors to be used by the Commission
worksharing
arguing
is clearly
in this proceeding.
One of the most important
R97-1 methodology.
by the subject interrogatory
and the parties to evaluate
decreased, as Miller
is to measure such worksharing
with the previous
rate proceeding,
ABA&NAPM/USPS-T24-1
testifies,
whether
or rather
FCLM
whether
they
savings in a manner which is
R97- 1. The revised Table 1 requested
would allow the Commission
compare apples to apples on this issue of FCLM worksharing
2
savings.
and the parties
by
to
By using new cost
methodologies,
and refusing
methodologies
to provide FCLM worksharing
savings using the same
which were used in R97-1, the USPS would have the Commission
parties compare grapefruits
to tangerines.
game with this crucial information
We submit
subject interrogatory
The USPS should not be allowed to play a shell
concerning
that the relevance
is supported
and the
worksharing
and reasonableness
savings.
of the information
by the spirit of Commission
requested
in the
Rule 54(a), which requires
the USPS, where its rate request proposes to change the cost attribution
principles
by the Commission
with its request an
alternate
in the most recent general rate proceeding,
cost presentation
not changed its attribution
to include
showing what the effect on its request would have been had it
principles.
Indeed, the Commission
addressed nearly the identical
No. 1197 in which the Commission
granted
issue in R97-1 in its Order
the motion of the Major Mailers
compel the USPS to respond to a very similar
question.
MMA of USPS witness
using the Commission’s
methodology
“fundamental
to reproduce,
omnibus
costs for various
importance
mail processing
Commission
Hatfield
from the previous
mail processing
attribution
required
applied
That Order involved
rate case, Hatfield’s
to
a request by
approved cost
Table II-2 which set forth unit
rate categories of first class letter mail.
of knowing
Association
Noting
the
what impact the Postal Service’s proposed changes in
would have on the cost basis of rate category rates”, the
Hatfield
to respond to the interrogatory.
Order No. 1197 (Docket No.
R97-1) at pages 8 & 9 (issued October 1, 1997).
For the forgoing reasons, ABA&NAPM
1. To order USPS witness Miller
providing
a version of Miller’s
respectfully
to fully respond to ABA&NAPM/USPS-T24-
1 by
Table 1 using the Commission
in
R97-1 and the USPS methodology
using the Commission
methodology
in R97-1; or
2. If the USPS makes a showing of significant
production
request the Commission:
burden, then to at least order
methodology
3
in R97-1, of that portion
of
Miller’s
Table 1 covering the benchmark
Mail Letters”
and “Standard
and “Standard
(A) Non-Profit
and rate categories within
(A) Regular
Letters”
Letters”
(since “First-Class
are less important
“First-Class
Mail Cards”
to ABA&NAPM).
Respectfully
submitted,
AMERICAN
NATIONAL
BANKERS ASSOCIATION
ASSOCIATION
OF PRESORT MAILERS
By:
I
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 2003G
Ph: 202-663-5035
Fax: 202-828-4548
Counsel for
National Association
of Presort Mailers
Counsel for
American Bankers
Date:
March 17, 2000
Washington, D.C,
Association
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.
1
2
3
TABLE 1:
TOTAL MAIL PROCESSING UNIT COSTS AND WORKSHARING RELATED
SAVINGS SUMMARY
A
TOTAL
MAIL
PROCESSING
UNIT COST
(CENTS)
WORK
SHARING
RELATED
SAVINGS
(CENTS)
Nonautomation Letters
10.337
0.091
Bulk Meter Mail Letters m
Automation Basic Letters
5.154
4.919
Bulk Meter Mail Letters
Automation 3-Digit Letters
4.264
0.986
Automation Basic Letters
Automation 5-Digit Letters
3.179
1.239
Automation 3-Digit Letters
Automation Carrier Route Letters
2.991
0.325
Automation 5-Digit Letters
(CSBCSIManual Sites)
Nonautomation Cards
4.055
--
Automation Basic Cards
2.637
1.739
Nonautomation Cards
4utomation 3-Digit Cards
2.166
0.543
Automation Basic Cards
4utomation .5-Digit Cards
1.592
0.689
Automation 3-Digit Cards
4utomation Carrier Route Cards
1.018
0.674
Automation 5-Digit Cards
(CSBCSlManual Sites)
STANDARD (A) REGULAR
LETTERS
Nonautomation Basic Letters
11.208
---
9.491
1.754
Nonautomation Basic Letters
6.234
3.779
Nonautomation Basic Letters
5.262
3.042
Nonautomation 3/5-D Letters
4.001
1.339
Automation 3-D Letters
7.443
---
6.005
1.107
Nonautomation Basic Letters
4.082
2.863
Nonautomation Basic Letters
4.084
2.608
Nonautomation 3/5-D Letters
3.107
1.064
Automation 3-D Letters
RATE CATEGORY
FIRST-CLASS MAIL LETTERS
RATE CATEGORY
BENCHMARK
FIRST-CLASS MAIL CARDS
Nonautomation 3/5-Digit Letters
Automation Basic Letters
Automation 3-Digit Letters
Automation 5-Digit Letters
STANDARD (A) NONPROFIT
LETTERS
Nonautomation Basic Letters
Nonautomation 3/5-Digit Letters
4utomation Basic Letters
Automation 3-Digit Letters
Automation 5-Digit Letters
6
7
8
-_
--
--
* The worksharing related savings include both mail processing and delivery savings. For details
regarding these calculations see the “Summary Pages” in Appendix I (pages 1 and 2), Appendix II (page
1). and Appendix Ill (page 1).