POSTAL RATE AND FEE CHANGES, 2001
)
Docket No. R2001-1
FLRST SET OF INTERROGATORIES BY THE
NATIONAL NEWSPAPER ASSOCIATION
TO UNITED STATES POSTAL SERVICE WITNESS
ALTAF H. TAUFIQUE
(NNAAJSPS-T34-1-3)
Pursuant to the Commission’s Rules of Practice,the National Newspaper Association
hereby submits the attached iuterrogatkes to the United StatesPostal Service
Witness AltafH. Taufique (NNMSPS-T34-1-3).
If any requestshould be answered by
* a different witness, it should be referred to that witness.
G :i
P.O. Box 50301
Arlington, VA 22205
Xenia Boone
National NewspaperAssociation
1010N. Glebe Road
Arlington, Virginia, 22201
Counsel
fortheNationalNewspaper
Association
CERTIFICATE OF SERVICE
Commission’sRules of Practice.
FIRST SET OF INTERROGATORIES OF
THE NATIONAL NEWSPAPER ASSOCIATION TO
UNITED STATES POSTAL SERVICE WITNESS
ALTAF TAUFIQUE (NNAAJSPS-T-34-1-3)
NNAKBPS-T-34-l.
Pleaserefer to your testimony with regard to pallets and ~a& on
_I
page 10. Pleaseprovide a list of containerization options, with the exception of sacks,
available for low volume Periodical mailings that cannot be commingled.
NNA/lJSPS-T-34-2. Pleaserefer to page 4 of your testimony where you state: ‘7 am akio
proposing a changeto DMCS 421.45 to limit the destination entry discountsto mail
enteredat the destination facility,” and also to your recognition of the history of cost
increasesfor Periodical mail, referenced on page 6 of your testimony.
a. Pleasecontirm that Periodical mail has receivedhigher-than-systemaverage
rate increasesin the past two rate cases.If you do not contirm, pleaseexplain your
answer.
b. Pleasecon&m that some periodicals are enteredwithin a Sectional Center
Facility (SCF) zone for delivery within an SCF zone without necessarilypassing through
the SW itself. If you do not contirm, please explain your answer.
c. Pleaseconfirm that newspapermail that is typically enteredwithin an SCP zone
for delivery within an SCF zone without necessarilypassingthrough the SCP itselfactually be considered“drop-shipped” in the sensethat mail is depositedcloser to a
destination than required of the mailer. If you do not contii, pleaseexplain your
anSWC3.
d. Pleaseconlirm that through proper bundling and packaging,a Periodical mailer
can prepare mail for entry within an SCF zone for delivery within the sameSCF zone
without requiring opening of the container, sorting or further handling within the SCF. If
you do not confirm, pleaseexplain your answer.
e. Pleasecon&m that the periodicals involved in questionb, c and d would be
denied a destination entry discount under your proposal. If you do not confirm please
explain your answer.
.
FIRST SET OF INTERROGATORIES OF
THE NATIONAL NEWSPAPER ASSOCIATION TO
UNITED STATES POSTAL SERVICE WITNESS
ALTAP TAUPIQUE (NNAKJSPS-T-34-1-3)
NNAKlSPS-T343. Pleaserefer to MPAAJSPS-T-34-8,redirected from you to witness
Mayes, where shecontirms that no cost analyseshave been conductedwith regard to
DSCF rated piecesenteredat the destination facility and those not so entered.
a. If the PostalServicehas conductedno studiesof the cost impact, upon what
costing theory or basishave you made the recommendationto restrict this discount to
pieces enteredinto the destination facility? Pleasedescribethis costing theory or basis in
detail.
., .~_
b. If a mail piece were entered at an associateoffice within an SCF for delivery
within the SCF, is it conceivablethat sucha piece would createno greater attributable
cost than the samepiece enteredat an SCF for delivery within the SCF? If your answeris
yes, please explain the circumstancesunder which that might occur. If your answer is no, .,
please fully explain your answer.
c. Would your answerto 3b dependupon whether transportation normally
traveling betweenthe entry associateoffice and the destination office exists?Please
explain your response.
d. Has the Postal Service consideredgranting the destination entry discount to
any mail enteredanddelivered within the SCF, other than the mail entereddirectly at the
destination facility? If your responseis yes,please explain the terms under which the
discount might be granted.If your responseis no, pleaseexplain why such an option was
not proposedin this case.