BEFORE THE
POSTAL RATE COMMlSSlON
WASHINGTON, DC 20266-0001
Docket No. R2000-1
Postal Rate and Fee Changes, 2000
FIRST INTERROGATORIES
OF AMERICAN LIBRARY ASSOCIATION
TO USPS WITNESS KIEFER (ALA/USPS-T37-1-6)
Pursuant to section 20 of the Commission’s
Library
document
Association
(“ALA”)
respectfully
submits
the
Rules of Practice, the American
attached
requests to USPS witness James M. Kiefer (USPS-T-37).
reference the instructions
in OCA interrogatories
OCA/USPS-1-14
Respectfully
interrogatories
ALA incorporates
(filed Jan. 24, 2000).
submitted,
David M. Levy
v
Christopher T. Shenk
Sidley & Austin
1722 Eye Street, N.W.
Washington, DC 20006-3704
(202) 7368214
Counsel for American Library Association
February 16,200O
and
by
QUESTIONS
ALA/USPS-T37-1.
This question
refers to page 23 of your testimony,
state that “the Postal Service anticipates
principles
followed
the adoption
in this rate case to develop
of legislation
recommend
cannot
both
accept
that will codify the
Library Mail rates when preferred
cannot be achieved using the cost coverage formula described
that the Commission
where you
the Postal
in RFRA.”
Service’s
rates
Please confirm
cost estimates
and
the Postal Service’s proposed rates unless Congress changes the law. If you
fail to confirm, please explain fully.
ALA/USPS-T37-2.
Please produce
Rate mail that would
existing statutory
comparable
Attachment
follow from the Postal Service’s
constraints
to the
rate
the rate changes
proposed
on Library rates remain unchanged.
schedule
appearing
in the
Postal
for Library
cost estimates
if the
Please use a format
Service’s
Request
at
B, page 52.
ANMIUSPS-T37-3.
supporting
a table showing
documentation
rates for Library
Does the Postal Service contend
provide an adequate
mail if the existing
that its Rate Request
basis for the Commission
statutory
constraints
on preferred
and
to recommend
rates remain
unchanged?
(4
Attachment
If so, please
produce
a table,
in a format
B to the USPS Request,
showing
the rates that the Postal Service believes
could be lawfully recommended
(b)
comparable
to page
52 of
by the Commission.
If not, please specify in detail what must be added to the Postal Service’s
filing before the Commission
can lawfully recommend
constraints.
-I-
rates under the existing statutory
ALA/USPS-T37-4.
In the Postal Service’s
view, what characteristics
Rate mail cause its unit costs to exceed those of Special Standard
studies, analyses and similar documents
ALA/USPS-T-37-5.
Postal
Service
investigated
or analyzed
since
Docket
cause of the relatively
high unit costs attributed
Service.
Produce all documents
relating to each such study, investigation
communications
Please
relatively
rapid cost increases
costing systems.
produce
to Library
as a
by the Postal
or analysis.
correspondence
or other
cost analysts or consultants
since July 1, 1998, concerning
attributed
No. R97-1
to the subclass
all memoranda,
created by in-house or outside economists,
for Postal Service headquarters
all
of Library Rate mail that the
possible
ALA/USPS-T37-6.
Produce
that support your answer.
Please identify each characteristic
has studied,
Mail?
of Library
possible
causes of the
rate mail by the Postal Service’s
CERTIFICATE
I hereby
participants
certify
that
I have this day served
of record in this proceeding
Practice.
February 16,200O
OF SERVICE
in accordance
the foregoing
with section
document
on all
12 of the Rules of