SMC-RT-1
ilECEI:‘E!)
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D. C.
POSTAL RATE AND FEE CHANGES,
:
1997
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Docket No. R2000-1
REBUTTAL TESTIMONY OF
BERNARD
BRADPIECE
ON BEHALF OF THE
SATURATION
Communications
MAIL COALITION
with respect to this document
should be sent to:
John M. Burzio
Thomas W. McLaughlin
BURZIO & MCLAUGHLIN
1054-31st Street, N.W.
Washington, DC 20007-4403
Counsel for the
Saturation Mail Coalition
August 14, 2000
::,
TABLE OF CONTENTS
AUTOBIOGRAPHICAL
SKETCH
1
2
PURPOSE OF TESTIMONY
I.
II.
Ill.
THE COSTS FOR PRIVATE CARRIER DELIVERY ARE
SUBSTANTIALLY
BELOW EXISTING AND PROPOSED POSTAL
RATES FOR STANDARD A ECR SATURATION MAIL
3
HIGH POSTAL COSTS MAKE PUBLICATIONS DISTRIBUTING BY
MAIL TOO EXPENSIVE FOR MEDIUM TO L4RGER ADVERTISERS
6
THE POSTAL SERVICE IS VULNERABLE
MAIL VOLUMES FROM FREE PAPERS
CONCLUSION
TO LOSING SATURATION
10
12
REBU-ITAL TESTIMONY OF BERNARD BRADPIECE
AUTOBIOGRAPHICAL
My name is Bernard Bradpiece
Pennysaver
Group, a saturation
distributed
and I am the President,
CEO, and owner of the
mailed weekly free paper with a circulation
1,300,OOO in the States of Maryland
Metro Community
SKETCH
and northern Virginia.
News, a 290,000 circulation
I am also the owner of the
saturation weekly free paper that is
in Erie and portions of Niagara Counties in New York by private carrier.
I came to America and bought the Maryland Pennysaver
publication
moved here from the United Kingdom and sought an entrepreneurial
would help me and others pursue the American
owning your own business.
consultant
Before 1996, I worked as an independent
and provided
business
11
businesses
that included
12
Publishing,
Ltd. (now known as Midland Independent
13
and Spode Potteries,
14
For each of these businesses,
I5
strategies
to restructure
I6
operating
performance
and Derby International,
business
operations
Newspapers),
the manufacturer
I was responsible
President
I9
Manhattan
20
my own business
21
petrol filling stations.
22
Cranfield
and
international
known as turnaround
for British Aerospace,
work to
Ingersoll
Royal Worcester
of Raleigh bicycles.
for creating and executing
or balance sheets in order to improve
and/or attract new capital.
for Citi Bank and culminating
in 1991as the Managing
Bank, head of UK Corporate
Finance.
as Vice
Director for Chase
Prior to 1983, I created and owned
involving the sale and service of automobiles
and operation
I have a Masters Degree in Business Administration
of
from the
School of Management.
My papers are members
24
Papers), the Alliance
2.5
the Steering Committee
of the AFCP (the Association
of Independent
of Free Community
Store Owners and Professionals,
for the Saturation
Mailers Coalition.
I
venture that I felt
From 1983 to 1991, I worked for various bank groups with positions
I8
23
services commonly
the parent corporation
in 1996.
dream of starting, building,
IO
17
of
and I am on
-2PURPOSE OF TESTIMONY
I
As a newcomer
to this country, and the mailed free paper business,
2
never tracked or participated
3
William 8. Tye, an economist
4
John White who operates
in a postal rate proceeding.
hired by the Newspaper
a distribution
I have read the testimony
of America,
and
company owned by a daily newspaper
and
who is testifying on behalf of the Association
6
clarifying that Mr. White is in fact employed
7
description
8
represented
9
business.
Association
of Alternate Postal Systems.
by a newspaper
group,
of his position could have led to the unintentional
a small independent
The purposes
IO
1.
II
ECR saturation
I2
AAPS-T-1
I have
business,
of my testimony
I do represent
It is worth
His own
misinterpretation
that he
a small independent
are:
To rebut the NAA and AAPS argument that “the USPS proposal [for Standard A
a.
mail] would significantly
harm [AAPS members or other competitors].”
at p.7. My testimony will show:
Data that compares
the costs to deliver a free paper by private carrier
I4
and the costs to deliver that same paper under existing and proposed
IS
saturation
I6
by the USPS, the costs of private carrier will still be one-third
I7
USPS distribution.
b.
I8
of
mail rates.
Even with the modest pound rate reduction
The high costs I am paying for postal distribution
mailed paper less competitive
the cost of
have made my
19
saturation
in securing
20
business
21
decline in the account
22
largely unable to sustain price increases for the last four years.
of medium and larger advertisers.
sought
and holding the
Our paper has seen a
base of these customers
and we have been
To rebut the NA4 position that the record does not show that the USPS is being
23
2.
24
threatened
by ECR competitors
or loss of ECR business,
25
vulnerable
to loss of saturation
mail business by saturation
26
or together with other mailers to convert all or portions of their saturation
27
coverage to private delivery.
NAA-T-1 at p.45.
I will show the USPS is
mailers acting individually
mail delivery
-31.
THE COSTS FOR PRIVATE CARRIER DELlVERY ARE SUBSTANTlALLY
BELOW EXISTING AND PROPOSED POSTAL RATES
As somewhat
I
of a newcomer
to a business
relationship
to find that the statute gives our fiercest competitors
with the USPS, I was
2
surprised
3
in determining
4
vendor.
5
provide proper sworn evidence of their own costs to justify the self-serving
6
unsubstantiated
the business
relationship
In addition, the newspapers
assertions
and authority
and pricing levels I must pay with my largest
and private delivery concerns
they make about competitive
In my industry, there are publishers
7
standing
have chosen not to
and
harm.’
like me who distribute
papers both by mail
8
and by private carrier.
Because of the great cost disparity between private carrier and
9
mail, and the high pound rate, papers that use the mail are often lighter weight papers
IO
or papers in rural, less dense areas, where the cost of setting up a private carrier
II
force are greater.
My competitors’
12
testimony
in this case has been somewhat
coy in criticizing
1:
USPS data on costs for “thinness of tallies.”
14
examples
I5
distribution
of heavier pieces is so high and so totally out of proportion
I6
distribution
costs for similar pieces.
of saturation
It is no wonder to me that there are few
pieces mailed at the heavier weights as the cost for mail
Here is an example from my own experience
I7
of the great cost disparity
I8
private carrier distribution
I9
purchased
20
had thoughts
21
the service I received from the USPS and prefer to keep my organization
22
publishing
and marketing
23
acquisition,
any thoughts
1
and existing and proposed
to alternate
postal rates.
between
I recently
a free paper in the area of Buffalo, New York. When I acquired the paper, I
of converting
my distribution
the paper.
of converting
From my own research,
to the USPS as I have been satisfied with
When I analyzed the distribution
focused on
costs of my new
to postal delivery vanished.
I believe it would be difficult for the newspaper
industry
to show
competitive harm. Because of their significantly lower delivery costs, carrier delivered newspa! pers
enjoy average operating profit margins of 31.56% (Ink md Studv, Press Association 1998--Daily
Newspapers
Circulation
51,400 to 60,500).
-4Printed on the following
page is a chart comparing the private delivery costs to
deliver a typical paper with what I would pay under current postage rates and under
the proposed
postage
rates.
Some highlights
1.
distribution
7
8
9
to note in this comparison
The name of the paper is Metro Community
in Erie County and part of Niagara County.
piece but has built up a substantial
2.
and the chart:
insert distribution
News in New York with
The paper itself is a lightweight
business.
The costs for hand delivery labor reflected below show a set price of
$56.00 per thousand
paid to the carrier, as well as a separate fee of $1.20 per
IO
thousand
to a route supervisor.
The carrier of this paper is paid $5.60 per thousand
II
for every insert in the paper.
I2
piece in the paper and its distribution.
I3
are not set based on weight.
This compensates
the carrier for actually inserting the
The carrier is paid a flat rate per insert.
14
3.
I5
costs a publisher
16
costs in smaller market areas are likely to be less.
Prices
The rates paid for labor in these counties of New York are on par with the
would encounter
17
4.
Currently,
I8
saturation
with destination
I9
thousand.
The proposed
20
thousand
21
to hand deliver a paper weighing
22
compared
23
difference.
24
5.
in other major metropolitan
my starting postage rate for my Pennysaver
increase.
a total of $406.23.
27
28
be $334.90
The combined
carrier and supervisor
almost 11 ounces is $105.84
for postage
The per thousand
cost
per thousand
for my mailed 3.3087 ounce piece.
That same paper weighing
26
product with full
increase on the piece rate will take me to $120 per
to the $120 per thousand
rates would be $369.23
The labor
delivery unit discount up to 3.3087 ounces is $114 per
or a $6 per thousand
2s
areas.
A dramatic
almost 11 ounces under today’s postage
plus another $37.00 for inserting and labeling for
costs under the proposed
postage
for postage plus inserting and labeling for a total of $371.90.
rates would
COST COMPARISON
Typical
-5OF POSTAL AND PRIVATE CARRIER FREE PAPER
Piece weight
Product
in oounds
Paper with 8 Inserts
Hand Delivery Costs
Paper
Inserts
Paper*
Inserts3
Carrier
56.00 perM’
5.60 perM
Postal costs
Current
Proposed
114.00 perM
120.00 perM
0.450 per lb
0.537 per lb
+.OOYpiece
+.028/piece
Current
Postaae
369.23
Suoervisor
1.20 perM
0.48 perM
Paper
Grocery Tab
Grocery Tab
Grocery Tab
Grocery Tab
Car Service Flyer
Retail Circular
Retail Circular
Total Weight
Carrier
56.00
5.60
5.60
5.60
5.60
5.60
5.60
5.60
5.60
Suoervisor
1.20
0.48
0.48
0.48
0.48
0.48
0.48
0.48
0.48
TOTAL
Proposed
Total
406.23
57.20
6.08
6.08
6.08
6.08
6.08
6.08
6.08
6.08
105.84
Total
perM
perM
perM
perM
perM
perM
perM
perM
oerM
perM
lnsertina and Labelina Costs4
Paper
9.00 perM
3.50 perM
Inserts
Postal Rates
InsetVLabelina
37.00
0.084
0.046
0.132
0.084
0.044
0.010
0.020
0.022
0.682 (10.91 oz.)
Postaae
334.90
Postal Rates
Insert/Labelina
37.00
Total
371.90
Total Costs PerM to Deliver 10.91 Ounce Paper By:
$105.84
Hand Delivery
Current postal rates
$406.23
$371.90
Proposed postal rates
perM = per 1,000
Plus inserts up to 3.2985 ounces
Cost for inserts after paper and inserts exceed 3.2985 ounces
Labeling costs required by postal regulations--NOT
a required cost for hand delivery.
-6AAPS Witness White states in his testimony,
1
delivery’s
“Lowering
2
further damage alternate
3
shared mail packages
4
companies
5
data from their industry to support their position that the USPS proposal will hurt their
6
members,
7
USPS competitors
refuse to share their costs with this regulatory
8
the rates proposed
by the USPS, my postal cost of distribution
9
times higher than my competitors.
to arbitrarily
out of business.”
ability to compete.
the pound rate would
.with prices that could allow
price below our costs, forcing alternate
AAPS-T-1
at p.5. AAPS and NAA do not provide any cost
let alone allow mailers to price below their costs.
It is no wonder that
body.
Even under
will still be two to three
The reality is that even the proposed
10
are too high. The USPS should be charged with generating
II
and its customers
12
changes
can better meet the challenges
postal prices
price reductions
of the dramatic
so that it
technological
we all now face.
Based on the evidence,
I3
delivery
or lack thereof, produced by my competitors
and my
14
own analysis of a cost comparison
15
proposed
16
adversely affect private competitors
of the USPS” or tilt the playing field to favor
17
saturation
publishers
18
carriers
II.
19
between private delivery and existing and
postal rates, it is hard for me to fathom how the USPS proposal
mailers over advertising
and distributors
“could
who use private
HIGH POSTAL COSTS MAKE PUBLICATIONS DISTRIBUTED BY MAIL
TOO EXPENSIVE FOR MEDIUM TO LARGER ADVERTISERS
AAPS Witness White maintains that the USPS proposal for ECR saturation
20
will “significantly
harm” AAPS members.
AAPS-T-1
at p.7. Although
21
declines to offer any specific information
22
newspaper
23
impact of rates on competitors
24
pattern of an enterprise
25
from private enterprise
26
objective of diverting mail from private enterprise competitors.”
mail
NAA Witness Tye
about the costs, prices, or margins of the
industry, he criticizes the USPS filing for not offering any evidence of the
and concludes,
“The rate proposals
conform to a
seeking to use rate levels and rate design to shift volume
competitors.”
Tye accuses the USPS of having a “stealth
NAA-T-1 at pp. 21 and
-71
47. Both Witnesses
2
submitting
3
NM-T-1
White and Tye criticize the USPS for not doing its job in
these rate proposals
by “considering
the impact of rates on competitors.”
at p.46.
I understand
4
that this regulatory
upon the general
body has an obligation to consider “the effect of
5
rate increases
public, business
6
private sector of the economy engaged
7
USC §3622(b)(4))
8
health and stability of the USPS as a viable enterprise
9
delivery industry.
but also a desire
mail users, and enterprises
in the delivery of mail other than letters,” (39
and an obligation to preserve the long-term
In this section of my testimony,
and competitor
in the mail
I will show that the present
10
saturation
II
shopper
12
competitive
I3
provide a small amount of relief to my paper but will have little impact on our
I4
competitors.
15
objective”
I6
in the
mail rates and the high pound rate have made it difficult for my mailed
to be competitive
in our market area, which in turn makes the USPS less
as a distribution
supplier.
The USPS proposals
in this rate case will
They will certainly not help us, or the USPS, achieve any “stealth
of diverting advertising
The Pennysaver
from private enterprise.’
Group free paper is distributed weekly to approximately
I7
1,300,OOO throughout
Maryland and northern Virginia.
I8
consumers,
I9
low income and high income demographic
20
markets,
we offer complete
saturation
coverage.
To serve our advertisers
We do not distinguish
areas, rural, suburban,
and
between
or metropolitan
In the four years I have owned and operated the paper, postal rates may
2
As substantiation for Tye’s conclusion that the USPS is targeting “the heavier pound rated
ECR traffic for diversion,” he points to a meeting that occurred between Witness Moeller and
representatives
of the Saturation Mailers Coalition and the Mail Order Association of America in
November, 1998. I recently attended a meeting between Witness Moeller and representatives
of
the Association of Free Community Papers at the AFCP’s annual conference.
The mailed free
papers in attendance at the meeting were not telling Witness Moeller how the proposed rates would
help them divert business from competitors.
Instead, many of the mailers in the room were
questioning why the USPS rates for saturation papers would still be so high. One publisher, who
has a small paper in an area that is largely rural and distributes his circulation 50-50 by mail and
private carrier, states that when advertising brokers call him to place advertising in his paper that
they comment that they know he must charge them more than they are paying to place advertising
in papers that are distributed by private carrier because of the high postal distribution costs he pays.
If I was to characterize the message the USPS is hearing from its saturation mail customers, and in
particular mailed free papers, it is “if you want to keep our business you need to contain your costs.”
-aI
have been relatively stable but competitive
2
become
increasingly
3
demand
more for their dollar.
competitive
conditions
and our medium to large customers
As a free paper or shopper, our advertisers
4
5
that fits their pocketbook
6
and Virginia Pennysavers,
7
Buckel.
8
small businesses
and individuals,
9
Baro. AISOP-T-2
at p.3.
SMC-T-1
and trade areas,
at pp. 6-10.
II
large local businesses.
12
information
like those described
are able to
and our Maryland
as SMC Witness Harry
are the mom and pop
by A/SOP Witness Orlando
however, it needs a mix of small, medium, and
Both advertisers
and consumers
want a paper with
on a wide variety of the shops and services in their area,
conditions
and high postal distribution
costs have
14
made it more difficult for our paper to retain the business of our medium to large
15
customers.
16
substantially
17
have seen from our retail and service advertisers
18
the pages of our paper.
The proposed
postal rates, and the reduced pound rate, will not
change this equation.
But it will help stem the erosion of business
who purchase
ROP advertising
we
on
Once again, I want to give this regulatory body facts, based on my personal
19
20
has
a zoned market buy
The shopper business,
Our core group of customers
In recent years, competitive
I3
can purchase
operate very much as described
For a shopper to be successful,
IO
have not. Our marketplace
experience,
to substantiate
my position.
When I acquired the Pennysaver
21
paper, our advertising
22
roughly 75% with display ads and 25% with classifieds.
23
placed by individuals
and consumers
24
businesses
individual
25
Display advertisers
including
Fierce competition
26
27
resulted
28
of revenue,
Classified
ads include ads
but they are also the ads run by the smallest of
service providers
are, in general,
revenue was split
and home-based
bigger concerns
for the business
than classified
businesses.
advertisers.
of medium to larger advertisers
in an erosion of our display ad customer
our paper has focused on consumer
base.
To compensate
and small business
has
for this loss
customers,
and
-91
today our pages are divided roughly one-third between
2
approximately
two-thirds
3
too expensive
to effectively compete for any significant
4
Insert advertising
5
Sunday newspaper.
6
extended
7
privately delivered
8
9
display advertising.
classified
ads and
High postal costs have made our paper
volumes of insert advertising.
is primarily delivered by private carriers--usually
wrapped
But this loss of the medium size or larger advertiser
to our display advertising
advertising
has
base and has made us less competitive
publications
The USPS proposal for saturation
with
and newspapers.
rates, and the modest change in the pound
rate, will do little to change my paper’s competitive
position when it comes to the
IO
insert advertiser.
II
and make us better able to retain the business of our display advertisers.
I2
this mix of advertisers,
I3
continue to deliver customers
I4
zoned, classified
15
Witnesses
16
rate, have not increased
17
evidence
18
they charge their customers.
19
that my display advertising
20
business
21
within your
It will, however, help us keep our overall prices down for advertisers
we can keep our loyal readers interested
to the smallest of businesses
By retaining
in our paper and can
that rely on our low cost,
ads to stay in business.
Tye and White complain that ECR rates, and in particular the pound
in real world terms since 1996. They do not offer any
about what their industry has been able to do by way of increasing
On behalf of my saturation
mailed shopper,
the prices
I can tell you
rates today are the same as they were when I started the
in 1996.
I must grudgingly
confess that our prices are not the same today out of charity
22
to our customers
or choice.
23
pass on a price increase of approximately
24
sensitive
25
customers
could not or would not pay more.
26
advertiser
instructed
21
the same budget the advertiser
our business
After my acquisition
of the business, we attempted
3.5%.
was in this competitive
We immediately
market.
to
found out how price
Our small business
In the face of a price increase, the small
us to reduce the size of the ad, or its frequency
had before the price increase.
or VOlUme to keep
Our medium to large
-lO1
advertising
customers
responded
2
either kept their prices the same or risked the loss of their business.
My experience
3
by showing us they had other media choices,
is the same as other free paper publishers.
revenues
We have not been
4
able to increase
5
we have been forced to increase efficiencies
by productivity
gains and mechanization.
6
The revenue growth of our paper has come from increasing
volumes and productivity,
7
not increasing
we have had to make
8
due with compression
9
has seen a 2% decline in our profit margin.
prices.
of our margins.
Over the last four years
saturation
I2
change the competitive
I3
My paper in Buffalo will still be distributed
I4
Maryland and northern Virginia,
I5
would help slightly offset the significant
I6
costs at the piece rate.
I7
margins,
the Pennysaver
Group
of the market, the USPS proposal to increase the basic
II
III.
In the face of declining
To fund growth and capital expenses,
From my perspective
IO
by simply raising prices.
We
rate by over 5% while modestly decreasing
the pound rate will do little to
playing field between a mailed free paper and other media.
by private carrier.
For my papers in
I would hope that the slight reduction
in the pound rate
increase I will be seeing in my overall postage
THE POSTAL SERVICE IS VULNERABLE
MAIL VOLUMES FROM FREE PAPERS
TO LOSING SATURATION
NAA criticizes the USPS proposal for ECR mail, and the USPS filing, as being
18
without justification.
As a newcomer
19
very much on the USPS, it appears my competitors
20
raise my postal rates to help them increase their prices and profit margins, and in turn
21
to justify charging
22
emotionally
23
role and by pointing to those AAPS members that are not owned by newspapers
24
other publishers
25
the role of asking this regulatory
26
as possible.
their advertisers
appealing
to these proceedings,
and a mailer that depends
are petitioning
this Commission
to
more. They may attempt to make this request
to the Commission
but are “independently
by pointing to the newspapers’
editorial
or
owned,” but both come to this Commission
body to keep their mailed competitors’
in
prices as high
-llI
NAA Witness Tye asserts that the increase in ECR volumes “undercuts
that the USPS is being threatened
2
argument
3
competitors
4
increased
5
competition
6
be able to compete with their prices under existing or proposed
7
ability to set insert prices for advertisers
8
delivery in the paper with the higher costs of mail will continue to allow them to set
9
prices for inserts that I cannot match in any 100% mailed shopper.
do not choose to share with this Commission
from mailed TMC programs
behalf of my own circulation
II
Commission
12
private carrier.
Our newspaper
how much of these
volumes might be due to their own TMC programs.
IO
I3
by ECR competition.”
any
I face vigorous
in my market area and I cannot and will not
ECR rates,
by averaging their lower costs of subscriber
Speaking
that much of that circulation
is very vulnerable
to being switched
to
As a mailer and a major customer of the USPS, I would hope one of the
Commission’s
I5
USPS to continue to provide universal delivery service, at reasonable
I6
of a changing
I7
vendor has been the USPS, I know that postal prices, and the uncertainty
18
Service’s future in an internet world, has forced me to consider alternatives.
paramount
concerns
communications
in setting fair .and equitable
environment.
rates is to allow the
and current economic
21
publications
conditions,
rates, in the face
Certainly, as a business
I am happy with the level of service we get from the USPS.
20
22
on
of 1,300,OOO that is currently in the mail, I can assure this
14
19
Their
mailers like the Pennysaver
whose primary
of the Postal
But at current prices,
Group and similar
have to explore other ways to deliver their papers.
Under present rates, the Pennysaver
Group is paying 23% of its total revenues,
23
and 48.5% of our costs of good sold, to the USPS. With the USPS taking such a big
24
bite out of every sale, I am certainly open minded to considering
25
accomplish
26
27
other ways to
the delivery of my paper.
It is my preference
Virginia papers.
to remain a USPS customer for the Maryland
But as my experience
and northern
in owning a private carrier paper in Buffalo
-121
continues,
2
consider
3
I will be learning about the distribution
if postal rates increase,
Through my participation
or competitive
business and refining a “plan B” to
conditions
change.
in SMC, I anticipate networking
4
mailers that distribute
5
products
6
to represent our industry before the USPS, this regulatory body, and other lawmakers.
7
It is a short and logical step to explore the formation of a cooperative
8
venture to deliver our papers or other shared mail advertising
9
may compete
saturation
mail advertising.
in the marketplace,
It remains my preference
Although
more with fellow
we have come together
to be a postal customer.
information
our businesses
and
as an association
private delivery
programs,
I am participating
IO
case and sharing confidential
II
Commission
12
be based on the USPS listening to the needs of its saturation
I3
paper, and other shared mailers, will identify those portions of our distribution
I4
would be cheapest to convert to, and most cost-effective
15
delivery.
16
metropolitan
in this rate
about my company to give this
a good basis on the record to approve USPS proposals
that appear to
mail customers.
But my
that
to service by, alternative
For heavier papers or shared mail pieces, and those in densely populated
areas, the USPS is very vulnerable
to loss of this business.
CONCLUSION
I7
Postal distribution
costs for saturation
18
greater than the comparable
I9
grows as the weight of the piece increases.
20
under existing, or proposed,
21
rural and remote parts of this country.
22
mail advertising
are already much
private carrier costs for similar pieces.
The cost disparity
For heavier pieces, USPS distribution
rates is out of the question for all but the most spread out
Many free papers, like our Pennysaver
Group, like the service we receive from
23
the USPS and would like to remain USPS customers.
But the existing rate structure,
24
and the high prices we pay as our papers grow and become more successful,
25
us to leave the mail to become competitors
26
proposals
of the USPS.
tempt
I believe the USPS
in this case were made as a result of listening to businesses
like mine.
-131
The USPS is trying to keep our business
2
saturation
3
competitive
4
5
in the mail. The USPS proposals
mail will help my paper retain customers.
environment,
I respectfully
for
It will do little to tilt or change the
but it will help.
request the Commission
higher than the rates proposed
by the USPS.
to approve a rate for saturation
mail no
- 14CERTIFICATE
OF SERVICE
I hereby certify that I have on this date served the foregoing document upon all
participants of record in this proceeding in accordance with section 12 of the Rules of
Practice.
August
14, 2000