.
.
Before The
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
I
Docket No. MC98-1
Mailing Online Service
RESPONSE OF THE UNITED STATES POSTAL SERVICE
WITNESS GARVEY TO INTERROGATORIES
OF
OFFICE OF THE CONSUMER ADVOCATE
(OCA/USPS-Tl-23-27)
The United States Postal Service hereby provides the response of witness
Garvey to the following interrogatories
OCAIUSPS-Tl-23-27,
of Office of the Consumer
Advocate:
filed on August 4, 1998.
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
/c$ &i/L
Kenneth N Hollies
475 L’Enfant Plaza West, S.W.
(202) 268-3083; Fax: -5402
Washington, D.C. 20260-I 137
August 14, 1998
RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS GARVEY
TO INTERROGATORIES
OF THE OFFICE OF THE CONSUMER ADVOCATE
OCA/USPS-Tl-23.
Please refer to your testimony at page 1, footnote 2. You
state, “The Postal Service will provide full service access via the World Wide
Web, using browser functions in lieu of user-installed software.”
Please describe in detail how a Mailing Online customer would transmit a
a.
Word document “via the World Wide Web, using browser functions in lieu
of user-installed software” during (i) the operations test period, (ii) the
market test period, (iii) the experimental period, (iv) the post-experiment
period.
Please reconcile your testimony with the following. “The Postal Service’s
b.
preferred objective for this experiment is to have it recommended by the
Commission by the end of November, 1998. This would allow the Postal
Service to explore the possibility that major software developers could
integrate Mailing Online into impending updates of software in order to
make the service widely and easily available
.” Motion of the USPS
for Expedition
., July 15, 1998. In particular, why is such integration
necessary if “full service access via the World Wide Web” is available
“using browser functions in lieu of user-installed software”?
Please explain how “integrat[ing] Mailing Online into impending updates of
C.
software [would] make the service [more] widely and easily available.”
RESPONSE:
a.
(i-iii) Using the built-in file transfer capability of standard browser software,
the Mailing Online Web server receives files selected for upload by users
from content resident on their local drives or network.
accomplished
This is
via a series of Hyper Text Markup Language
(HTML) pages
which the user views and interacts with while online using the World Wide
Web. This process is enabled by the capabilities
therefore
does not require additional
point-to-point
of the browser and
software such as might be used in a
file transfer.
(iv) Unknown,
b-c.
Given the fact that the internet is just an access channel, and the World
Wide Web is only a graphical
destinations
MC98-1
interface to the internet, it is important for
on the internet to have effective “signposts”.
Unlike a PC
RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS GARVEY
TO INTERROGATORIES
OF THE OFFICE OF THE CONSUMER ADVOCATE
application
which retains and reloads all user information
internet application
Although
effectively disappears
and settings, an
each time the user signs off.
getting to and navigating the World Wide Web is as simple as
“point and click”, a user must first know how to get to a specific destination
the first time, and then must remember
hyper-linking
characteristic
Web functionality
processors
how to return. The “point and click”
has prompted an integration
into many desktop applications
and even operating
of World Wide
such as word
systems, e.g. Windows
98. Since Mailing
Online access is only available via the World Wide Web, and since its
functions
compliment
but do not replace a user’s desktop applications,
having “point and click” access to Mailing Online conveniently
in the applications
operating
and perhaps even in the desktop
system as well, will certainly make the service more widely and
easily available.
MC98-1
themselves,
embedded
RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS GARVEY
TO INTERROGATORIES
OF THE OFFICE OF THE CONSUMER ADVOCATE
OCAIUSPS-Tl-24.
Please refer to Exhibit 1 to your response to interrogatory
OCA/USPS-Tl-10.
For each date on which more than one transaction occurred, please
a.
provide the number of different mailers who transmitted on that date and
the volume transmitted on that date by mailer.
Please provide the total number of different mailers who have utilized
b.
Mailing Online during the period covered by Exhibit I.
For each separate mailer who has utilized Mailing Online during the
C.
period covered by Exhibit 1, please provide the total number of
transactions that occurred during the period covered by Exhibit 1 and the
dates on which those transactions occurred. (It is not necessary to
identify mailers; merely differentiate them.)
For each separate mailer who has utilized Mailing Online during the
d.
period covered by Exhibit 1, please provide the total number of
transactions that occurred in each calendar month during the period
covered by Exhibit 1.
For each separate mailer who has utilized Mailing Online during the
e.
period covered by Exhibit 1, please provide the average number of
transactions per calendar month during the period covered by Exhibit 1.
RESPONSE.
Answers
Response
pages.
to each of these questions
to OCAAJSPS-Tl-24.
are provided in the Attachment
The body of the Attachment
One of these reports on operations
other four report on activity in Tampa.
to
contains five
test activity in Hartford, while the
Please note that these latter four pages
consist of a single table physically arrayed across all four pages, with columns
representing
MC98-1
each operations
test customer and each row representing
dates.
Attachment
to Response to OCA/USPS-Tl-24.
Page 1
Attachment
to Response to OCAIUSPS-Tl-24.
Page 2
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Page 5
RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS GARVEY
TO INTERROGATORIES
OF THE OFFICE OF THE CONSUMER ADVOCATE
OCAIUSPS-Tl-25.
Please refer to your response to interrogatory OCAIUSPSTl-3(b)-(f).
You state, “Mailing Online mail has been entered through the Dallas,
Texas P&DC Business Mail Entry Unit (BMEU). However, primary processing
was not performed at this plant since the mail was prepared for immediate drop
shipping to plants at Tampa, Florida and/or Hartford, Connecticut.”
Please define “drop shipping” as used here.
I?
Please confirm that some shipments to Tampa contained “calendars to
customers in Chicago and other cities around the country
.” USPS-T7 at 2, line 4. If you do not confirm, please explain.
Does the Dallas P&DC routinely prepare dispatches to Tampa and
C.
Hartford as part of its outgoing sort plan? If not, to where would Dallas
routinely dispatch pieces destined for Tampa or Hartford?
You state “that no exceptional handling was requested” for Mailing Online
d.
mail entered through the Dallas P&DC. Please define “exceptional
handling.”
You state that Mailing Online mail “was prepared in pouches labeled for
e.
drop shipment.” Please describe all transportation received by these
pouches, including the origin and destination of each leg, from the time
the pouches are dispatched from the Dallas P&DC.
RESPONSE:
a.
Drop shipping
pre-labeled
refers here to the enclosure
of prepared
Express Mail pouches prior to acceptance
mailings within
at a local Business
Mail Entry Unit. The pouches are sealed after local acceptance
processing
and dispatched
via Express Mail transportation
office for “open and distribute”
opened at the destination
processing
to another
handling, meaning that the pouches are
facility and the enclosed
stream as appropriate
mail is entered into the
for its class and makeup.
b.
I can only confirm that Witness Wilcox so testifies in USPS-T-7,
C.
I have no knowledge
knowledge
MC98-1
of the sort plans at the Dallas, Texas P&DC.
is immaterial to the Mailing Online operations
test.
Such
RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS GARVEY
TO INTERROGATORIES
OF THE OFFICE OF THE CONSUMER ADVOCATE
d.
For this purpose,
it refers to any handling outside of the usual or any
request beyond the ordinary course of business as defined by an entry
units normal operating
e.
Transportation
procedures.
for the Express Mail drop shipments
and Hartford are detailed on the attached
Attachments
MC98-1
1 & 2.
from Dallas to Tampa
Express Mail Service Leg forms,
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Chat-geQacK
I 22.
E~orass
1, 23.
rlgencv
I
Sub-Control
i 24.
DEPfiRT
I
15.
USPS Notes
PICK
UP FIDDRESS:
CQO@C
Mail
Zone:
CernWal
No.:
ROWINS
411
02548
INFORMfiTION
FIRR 1 >;,
IPlacelTiael
DTC
QCPI-icI RD
DCILLPlS TX 75244-4303
No.:
IPlaceI".:~
XEROX
INTnPC’1409!750VS372
4490
DFW
L
1920iDL930
XEROX WILL
CFILL SPRING
VEILLEY
WHEN saTURDfiY
PICKUP
IS NEEDED.
i
14.
SIC
7399
I
1 13.
Mkt
No.
I
16.
nccount
25.
GiQnature:
Reo:
BUSINESS
DIRNA
FISHER
CTR
!
i
1
’
1SC?flE-DCIY
I
1SERVICE
t
1
1
’
I
’
I
i
I
1
1
i
i
Attachment
1.
I
!
/
i
I
‘I
!
’
!
I
2 to Response to OCA/USPS-Tl-25
._
RESPONSE OF UNITED’STATES
POSTAL SERVICE WITNESS GARVEY
TO INTERROGATORIES
OF THE OFFICE OF THE CONSUMER ADVOCATE
OCA/USPS-Tl-26.
Please refer to your response to OCAIUSPS-Tl-2.
Please
explain the rationale for having the Postal Service hold the permits on which the
mailings are submitted.
RESPONSE:
Two factors influenced this decision: (1) since the Postal Service is collecting the
postage directly from Mailing Online customers,
the transaction
is complete.
it will have funds in hand when
It would not make sense, nor would it be cost
effective, to transfer these postage funds to a third party only to receive them
again when the mail is entered some 24 hours later. (2) Since the files are being
split and routed based on ZIP Codes, and then batched according
destination,
postage paid for one customer transaction
multiple entry points.
challenge
The consequent
if a centralized
accounting
logical holder of such a centralized
accounting
will potentially
would represent
represent
a formidable
system were not being used, and the only
account is the Postal Service since all other
parties are site specific vendors or customers,
MC98-1
to print site
.
4
RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS GARVEY
TO INTERROGATORIES
OF THE OFFICE OF THE CONSUMER ADVOCATE
OCA/USPS-Tl-27.
Please refer to your response to OCA/USPS-Tl-3(d).
Please provide a copy of the pages which will have prices entered upon them,
and any other pages that are changed, from USPS-LR+/MC98-1
once
signatures are affixed.
RESPONSE:
The completed
Reference
MC98-1
and signed contract, including prices, will be filed as a Library
immediately
upon award.
Award is expected to be made within days.
DECLARATION
I, Lee Garvey, declare under penalty of perjury that the foregoing
true and correct, to the best of my knowledge,
Dated:
8/‘yiip
information,
and belief.
answers are
CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoing document
participants
of record in this proceeding
in accordance
with section 12 of the Rules of
Practice.
,i
Kenneth N Hollies
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-I 137
August 14, 1998
upon all