BEFORE THE
POSTAL RATE COMMISSI0N
WASHINGTON, DC
Special
Services
Fees
and Classifications)
Docket
No.
MC96-3
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES TO UNITED STATES POSTAL SERVICE
WITNESS W. ASHLEY LYONS
(OCA/USPS-TI-I~-I~)
(July
19, 1996)
Pursuant
the
/-.
Postal
hereby
Rate
submits
documents.
the
to
United
incorporated
sections
25 and 26 of
Commission,
the
interrogatories
Instructions
States
Postal
Office
the
of
the
and requests
included
with
Service
dated
of
Practice
Consumer
for
production
OCA Interrogatories
June
19,
1996,
GAIL WILLETTE
Director
Office
of the
PiDAVID RUDERMAN
Attorney
of
l-4
are
submitted,
Consumer
of
Advocate
by reference.
Respectfully
,,,..--.
Rules
Advoca~te
hereby
to
Docket
No.
2
MC96-3
In your
OCA/USPS-Tl-16.
overall
objectives
that
better
Your
testimony
of
Docket
reflectLed
at
testimony
both
at
No.
1,
MC95-1
cost
you
indicate
"were
testimony
the
classifications
and demand
considerations."
2 states,
Specific
pricing
reform
objectives
include
more
equitable
contributions
based prices,
services
to institutional
costs
.
Your
that
at
more
from
marketthe
11 states,
The proposed
changes
in this
filing
that
would
significantly
increase
net income are supported
Board's
policy
objectives
with
regard
to equity
restoration.
b< the
,--
The Postal
Recommended
Preferred
Service's
Decision
Rate
Docket
on the
Standard
Mail
No.
Further
MC96-2
Request
Classification
and Periodicals
for
Ref'orm
a
of
states,
The statutory
target
cost coverage
goal and the
contribution
neutrality
goal were established
because
this
Request
is not intended
to be a revenue
case,
nor
an opportunity
to challenge,
change,
or improve
on the
Commission's
conclusions
drawn from the record
in
Docket
No. R94-1.
.
The Postal
Service
is also
by using
a contribution
neutral
approach,
hopeful
that,
the Commission
and the parties
to
the Postal
Service,
this
case can avoid
the inter-class
cost coverage
disputes
that
generally
occur
in omnibus
revenue
cases.
At
4-5
Since
,"--'.
contributions
Docket
No.
MC96-3
:Erom services
is
to
not
revenue
institutional
neutral
and
costs
have
been
Docket
,,,--.
No.
changed
MC9E'-3
by the
3
Postal
Service,
information,
does
the
(1)
A revenue
(2)
Solely
(3)
A revenue
(4)
An opportunity
Postal
to
the
best
Service
of
view
your
this
knowledge
filing
;and
,as:
case,
a classification
case,
and classification
Commission's
case,
to
challenge,
conclusions
drawn
and/or
change
from
or
the
improve
record
in
on
the
Docket
No.
R94-I?
In your
response,
please
OCA/USPS-Tl-17.
/-
a.
Your
1 states,
and parcel
the
expedited
be net
increase
To your
When will
the
proposal?
classification
neutral,
or
are
for
reform
will
they
be designed
revenues?
knowledge,
expedited
When will
revenue
net
classific,ation
/'-.,
at
item.
Will
the
e.
testimony
listed
and parcel
classifications
and in the future
proposals
follow.
to
C.
each
Reforms
of expedited
under development,
other
reforms
will
proposals
b.
address
what
and parcel
Postal
base
and test
classification
Service
year
will
reform
file
the
expedited
file
the
parcel
be used
proposals?
proposal?
the
Postal
Service
classification
in
Docket
f.
No.
MC96-3
To the
best
proposals
4
of
that
indicating
ability,
are
anticipated
whether
neutral,
plrovide
contributions
the
your
future
added
and test
OCA/USPS-Tl-18.
Your
are
the
each
testimony
In
and/or
reforms
to
to
be revenue
improse
proposed,
contemplated
at
reform
addition
expected
revenues,
for
other
follow.
filings
from
year
identify
to
net
resulting
base
please
identify
filing.
5 states,
the Postal
Service
has typically
made
In the past,
rate
and c:lassifications
changes as part
of a set of
general
rate
change proposals.
In part,
this
praectice
was influenced
by financial
policy
determinations,
by
the convenience
of adjusting
many rates
and fees
simultaneously,
and by the interrelationships
amo:ng
and volumes
of all mail and special
costs,
revenues,
services.
,"--
a.
Based
that
upon
more
your
targeted
convenient?
b.
in
light
If
your
affirmative,
convenient.
testimony,
If
of
the
response
rate
your
does
please
Postal
and classification
response
testimony
to
the
part
identify
is
cited
a of
negative,
in
this
for
this
Servic,e
believe
changes
are
please
explain
interrogatory.
interrogatory
whom they
are
is
more
more
Docket
”
A--‘-
c .
No.
To the
best
Postal
Service
encompass
d.
5
MC9&3
If
your
of
all
If
to
the
f.
best
of
Postal
Service
previous
g.
omnibus
best
Postal
Service
the
its
your
to
"statutory
of
the
cases
that
the
for
of
Postal
will
the
please
cost
If
coverage
No.
cost
your
response
is
explain.
information,
future
filings
of
narrow
rate
Docket
inter-class
and
be more
case.
all.
knowledge
to
ever
Service's
change?
yes,
is
how a limited
benefit
R94-1
is
and classification
inter-class
the
in
rate
your
and why it
the
entirety,
cases
To the
filings
to
expect
classification
rate
interrogatory
rate
allows
an unqualified
To the
this
when
approves
in
does
omnibus
rationale
case
established
than
c of
response
be resolved
filing
information,
future
a limited
Commission
coverages
other
part
file
your
file
explain
classification
MC96-3
/'--
to
in
dispute
e.
to
please
appropriate
to
and
classifications?
mail
response
Include
knowledge
expect
affirmative,
and
your
does
rate
in
the
and
scope
than
cases?
knowledge
anticipate
be targeted
targeted
and information,
future
to
mail
cost
rate
classes
coverage
does
the
and classification
that
goal?"
are
not
Please
meeting
r
Docket
,I.. .
No.
MC96-3
identify
h.
6
in
your
establishes
the
To the
of
best
testimony
response
statutory
your
cited
Service
believe
changes
are
in
and
please
this
identify
services?
those
If
changes
rate
changes
in
and given
the
the
Postal
and classification
the
revenues,
your
who
coverages?
does
targeted
due to
of
and information
among costs,
special
cost
interrogatory,
more
possible
understanding
targeted
knowledge
that
interrelationships
mail
your
and volumes
response
and fully
is
explain
of
all
affirmative,
your
response.
,_.--
CERTIFICATE
I hereby
document
accordance
upon
certify
all
with
that
I have
participants
section
OF SERVICE
3.B(3)
this
date
of
record
of
the
in
served
this
special
DAVID RUDERMAX
Attorney
Washington,
DC
July
19, 1996
20268-0001
the
foregoing
proceeding
rules
of
in
practice.