BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
POSTAL RATE AND FEE CHANGES, 2001
RECEIVE11
DEC 6 r/ 19 i?! ‘01
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Docket No. R2001-1
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INTERROGATORIES AND DOCUMENT REQUESTS OF
AMERICAN BUSINESS MEDIA AND THE MCGRAW-HILL
COMPANIES DIRECTED TO UNITED STATES POSTAL.
SERVICE WITNESS ALTAF H. TAUFIQUE
(AEM-MH/USPS-T34-47-49)
Pursuantto the Commission’s Rules of Practice.American BusinessMedia and The
McGraw-Hill Companies, Inc. hereby direct the attachedinterrogatories and document requests
to United StatesPostal Service witness Taufique (ABM-MWVSPS-T34-47-49). If any request
should be answeredby a different witness, it should be referred to that witness.
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Timothy W. Bergin’
Squire, Sanders& Dempsey L.L.P.
1201 PennsylvaniaAvenue, NW
Washington, DC 20004
David R. Straus
Thompson Coburn LLP
1909 K Street,NW, Suite 600
Washington, DC 20006
Counsel for The McGraw-Hill
Companies,Inc.
Counsel for American BusinessMedia
CERTIFICATE OF SERVICE
I hereby certify that I have this date servedthis document in accordancewith Section 12
of the Commission’s Rules of Practice.
gL&
Timothy W. Bergid
Dated: December 6,200l
ld
Au44
ABM-MI-I/USPS-T34-47
PleaseconlIrm the following, and explain your answer Mollyto the extent that you are unable to
confirm:
In Docket R97-1, at pages522-24, the Commission rejected your proposal to
depart from the longstanding practice of setting the editorial pound rate for Periodicals mail at
75 percent of the advertising pound rate for Zones 1 & 2, finding that your approach“might
diminish the ‘widespread dissemination of editorial content through the mail.“’
(4
The basic editorial pound charge (20.3 cents) proposedby you for Outside County
@I
Periodicals mail in this caseneverthelessexceeds75 percent of the proposedadvertising pound
charge (25 cents) for Zones 1 & 2, and reflects an increase(13.4 percent) significantly abovethe
proposedaverageincrease(10.4 percent) for Outside County Periodicals mail.
The reasonfor this disproportionate proposedincreasein the basic editorial pound
(cl
charge is that, as statedat pages 11-12 of your testimony, you have also proposedthe “partial
zoning of editorial pounds” in order to further reward dropshipping of Outside County
Periodicals mail.
Of the TYAR Periodicals mail volume that the Postal Service estimateswould be
(4
entered in the proposed DADC zone for editorial pounds, 84 percent is already being enteredat
the DADC, and the remainder is already being enteredin the DADC service territory, as
indicated in your responseto MPANSPS-T34-IO(a)-(c).
To that extent at least, the proposed“partial zoning of editorial pounds” would not
(e)
reduce Postal Service costs overall, but rather would decreasethe revenuesit received from
Periodicals mailers already entering their mail at the DADC, and shift that revenueburden to
those Periodicals mailers who rely on the basic editorial pound rate.
The sameconclusion applies with respectto TYAR Periodicals mail volume that
(t)
the Postal Serviceestimateswould be enteredin the proposedDSCF and DDU zonesfor
editorial pounds.
ABM-MEUUSPS-T34-48
Pleasereferto yourstatement
in response
to PresidingOfficer’sInformationRequest
No. 3,
Question 3(a), that under your proposal, “regardlessof rate design changes,editorial pounds
would not be burdenedby more than their historical share.”
Pleaseconfll that while your statementmay be true as to the editorial pounds of
(a)
the Outside County Periodicals subclassas a whole, it is not necessarilytrue as to the editorial
pounds of any particular Outside County Periodicals mailer.
Pleaseconfirm that under your proposal, the editorial pounds of all Outside
(b)
County Periodicals mailers who relied upon the basic editorial pound rate (historically set at
75 percent of the Zone 1 & 2 advertising pound rate), rather than the proposedDADC, DSCF,
and/or DDU editorial pound rates,would indeed be “burdened by more than their historical
share.”
With referenceto your testimony at p. 6, lines 21-25, pleasestatewhether you
believe that the public policy of promoting the widespreaddissemination of editorial content
(and thereby “binding the nation together”) should apply with any less force to periodicals
characterizedby a relatively high editorial percentagebut lacking sufficient circulation density
(or comailing opportunity) to be dropshipped economically. Pleaseexplain your answer fully.
(cl
ABM-MWUSPS-T34-49
Pleaserefer to your responseto MPNUSPS-T34-19(c), where you statethat a reasonfor limiting
the proposeddropship discounts for editorial pounds, by passing through only 50 percent of the
cost avoidances,was “[m]aintaining the balancebetween economic efficiency (dropship
incentives for editorial pounds) and dissemination of information (maintaining a reasonable
unzoned editorial pound rate).”
Pleasecontirm that in your view, a greaterthan 50 percent passthroughwould fail
(4
to maintain an appropriate balancebetween economic efficiency and dissemination of
information. If you do not contii, pleaseexplain your answer fully.
Pleaseconfirm that under your proposal, the 50 percent passthroughis not
(b)
intended simply as a temporary measure(until a future rate casewhen greaterpassthroughscould
be phasedin with supposedlyless impact on high-editorial Periodicals mailers who cannot
dropship), but rather is intended to be preservedin future cases,similar to the historical practice
of setting the editorial pound rate at 75 percent of the Zone 1 8c2 advertising pound rate. If you
do not confirm, pleaseexplain your answer fully.
Cc) Pleasespecify the Outside County Periodicals editorial pound ratesthat would
result if you had useda 100 percent passthroughrather than a 50 percent passthrough,and
explain how your calculations can be verified.