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BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON. DC 20268-0001
Docket No. R2000-1
Postal Rate and Fee Changes, 2000
FIRST INTERROGATORIES
OF ALLIANCE OF NONPROFIT
TO USPS WITNESS TAUFIQUE (ANMlUSPS-T38-1-6)
The
Alliance
interrogatories
of Nonprofit
and document
ANM incorporates
by reference
Mailers
(“ANM”)
respectfully
MAILERS
submits
requests to USPS witness Altaf H. Taufique
the instructions
in OCA interrogatories
the attached
(USPS-T-38).
OCAIUSPS-1-14
(filed Jan. 24, 2000)
Respectfully
submitted,
(y
David M. Levy ~
Christopher T. Shenk
Sidley & Austin
1722 Eye Street, N.W.
Washington, DC 20006-3704
(202) 736-8214
Counsel for Alliance of Nonprofit Mailers
February 16, 2000
QUESTIONS
ANMIUSPS-T38-1.
This question refers to pages 2-5 of your testimony, where you
state that the Postal Service’s
passage
of legislation
designed
as future proceedings.”
Postal Service’s
proposed
to “avoid rate anomalies
Periodicals
and recommend
mail unless Congress
mail assume the
in the current rate case as well
Please confirm that the Commission
cost estimates
nonprofit Periodicals
rates for nonprofit
cannot
the Postal Service’s
both accept the
proposed
rates for
changes the law. If you fail to confirm, please
explain fully.
ANMIUSPS-T38-2.
Periodicals
Please produce a table showing the rate changes for nonprofit
mail that would follow from the Postal Service’s proposed
existing statutory constraints
comparable
to the schedule on pages 25-26 of Attachment
ANMIUSPS-T38-3.
supporting
on preferred rates remain unchanged.
documentation
rates for nonprofit Periodicals
Please use a format
B to the USPS Request.
Does the Postal Service contend
provide an adequate
cost estimates if the
that its Rate Request
basis for the Commission
mail if the existing statutory
constraints
and
to recommend
on preferred
rates
remain unchanged?
(a)
Attachment
If so, please produce
B to the USPS Request,
could be lawfully recommended
(b)
a table, in a format comparable
to pages 25-26 of
showing the rates that the Postal Service believes
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
rates under the existing statutory
constraints,
ANMIUSPS-T38-4.
This question
refers to page 4, lines 21-22 of USPS-T-38,
where you state that “The statistical systems that are used to estimate cost data for the
various
subclasses
Classroom
will become
subclasses
cost for the Outside
even
are combined
County
more
reliable
if the
Regular,
into a single larger subclass.
subclass
should attain greater
Nonprofit
and
Both the volume and
stability as a result of this
combination.”
(a)
In the phrase “even more reliable,” what measures
of reliability and stability
did you have in mind?
Please produce
(b)
analyses
that support
(or cite, if already filed in this docket) all data, studies and
your belief that the cost data for nonprofit
Periodicals
mail are
already “reliable” by those measures.
Cc)
If the cost data are reliable, please explain why there is a problem with their
stability.
ANMIUSPS-T38-5.
Please identify each characteristic
that the Postal Service has studied, investigated
communications
Please
produce
rapid cost increases
to the subclass.
all memoranda,
correspondence
to nonprofit
Service’s costing systems.
-2-
or other
cost analysts or consultants
since July 1, 1998, concerning
attributed
Produce
or analysis.
created by in-house or outside economists,
for Postal Service headquarters
relatively
attributed
relating to each such study, investigation
ANMIUSPS-T38-6.
mail
or analyzed since Docket No. R97-1 as a
possible cause of the relatively rapid cost increases
all documents
of nonprofit Periodicals
possible
Periodicals
causes of the
mail by the Postal
CERTIFICATE
I hereby
participants
certify
that
I have this day served
of record in this proceeding
February 16, 2000
OF SERVICE
in accordance
the foregoing
with section
document
on all
12 of the Rules of