BEFORE THE
POSTAL RATE COMMISSION
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POSTAL RATE AND FEE CHANGES,
2000
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DOCKET NO. R2000-1
ANSWERS OF UNITED PARCEL SERVICE
TO INTERROGATORIES
OF THE
PARCEL SHIPPERS ASSOCIATION
(PSAIUPS-7 through 9)
(July 19, 2000)
Pursuant to the Commission’s
Rules of Practice, United Parcel Service hereby
files and serves the answers of UPS to the following interrogatories
Shippers Association:
PSA/UPS-7
of the Parcel
through 9.
Respectfully
submitted,
$hn E. McKeever
William J. Pinamont
Phillip E. Wilson, Jr.
Attorneys for United Parcel Service
Piper Marbury Rudnick & Wolfe LLP
3400 Two Logan Square
18th & Arch Streets
Philadelphia, PA 19103-2762
(215) 656-3310
(215) 656-3301 (FAX)
and
1200 Nineteenth Street, NW
Washington, DC 20036-2430
(202) 861-3900
Of Counsel.
ANSWER
INTERROGATORY
PSMJPSJ.
Witness Sappington
OF UNITED PARCEL SERVICE TO
OF THE PARCEL SHIPPERS ASSOCIATION
In response to PM/UPS-TG-6,
responded
Parcel Service and therefore
filed on June 27, 2000, UPS
that he did not know the delivery performance
he was not able to compare USPS Parcel Post delivery
service with United Parcel Service’s delivery performance.
standards
Please provide the delivery
for United Parcel Service ground parcel delivery service, and provide the data
which measures the UPS achievement
Response
of United
of its standards.
to PM/UPS-7:
UPS’s delivery standards
for all of its delivery services are available at
http://www.ups.com/wwtransit/engtimetran.html
services/servicemaps/servicemaps.html.
and http://www.ups.com/using/
UPS has filed an objection to the remainder
of this interrogatory.
-2-
ANSWER
INTERROGATORY
PM/UPS-8.
OF UNITED PARCEL SERVICE TO
OF THE PARCEL SHIPPERS ASSOCIATION
UPS witness Sappington
responded
to PM/UPS-TG-9,
which
asked him to compare the growth of United Parcel Service ground parcel shipments
during the 1990s the period in which witness Sappington
had grown substantially,
with Parcel Post growth.
said that Parcel Post volumes
Witness Sappington
in effect said he
had no information
about United Parcel Service’s share of the market in that period nor
its volume growth.
Please supply the information
requested
of UPS witness Sappington
in that interrogatory.
Response
to PSAIUPS8:
UPS has objected to this interrogatory
UPS “ground parcel shipments”
volumes.
However, a comparison
to the extent that it asks for the volume of
and a comparison
of those shipments to Parcel Post
of total UPS volume with total Postal Service parcel
and express volume for the last five years follows:
-3-
ANSWER
INTERROGATORY
FY 1995
FY 1996
FY 1997
FY 1998
FY 1999
OF UNITED PARCEL SERVICE TO
OF THE PARCEL SHIPPERS ASSOCIATION
First Class (Parcels)
Priority
Express
Third (Std. A) (Parcels)
Parcel Post
Other Fourth
Total
First Class (Parcels)
Priority
Express
Standard A (Parcels)
Parcel Post
Other Standard B
Total
First Class (Parcels)
Pridrity
Express
Standard A (Parcels)
Parcel Post
Other Standard B
Total
First Class (Parcels)
Priority
Express
Standard A (Parcels)
Parcel Post
Other Standard B
Total
First Class (Parcels)
Priority
Express
Standard A (Parcels)
Parcel Post
Other Standard B
Total
Postal Service Annual
Domestic Parcel and
Expedited Volume
(thousands)
578,132
868,979
56,690
969,243
218,060
718,132
3,409,236
491,555
959,424
57,573
1,036,750
212,828
736,038
3,494,168
503,602
1,068,181
63,633
I,114578
236,928
751,475
3,738,397
548,613
1,163,831
66,224
1,088,383
266,479
704,955
3,838,485
552,754
1,189,469
68,673
1,124,985
318,982
724,144
3,979,007
-4-
UPS Total Annual
Domestic Parcel and
Expedited Volume
(thousands)
2,867,249
2,930,652
2,811,842
2,886,964
3,024,378
ANSWER
INTERROGATORY
OF UNITED PARCEL SERVICE TO
OF THE PARCEL SHIPPERS ASSOCIATION
In addition, UPS’s volume and revenue for the past five years may be broken down into
the following non-confidential
categories:
VOLUME
(000)
Next Day Air
Deferred
Ground
International
1995
1996
-1997
1998
1999
169,004
181,148
2,517,097
226,941
193,040
193,802
2,543,810
222,758
207,966
195,063
2,408,813
226,435
238,252
198,882
2,449,830
250,444
263,906
216,408
2,544,064
257,556
REVENUE
($000)
Next Day Air
Deferred
Ground
international
The “Deferred”
1995
1996
1997
1998
1999
$ 3,269
$ 2,041
$12,463
$ 2,886
$ 3,734
$ 2,207
$12,940
$ 2,989
$ 4,054
$ 2,314
$12,500
$ 2,934
$ 4,690
$ 2,464
$13,,496
$ 3,237
$ 5,240
$ 2,6g4
$14,379
$ 3,703
category includes UPS Second Day Air and Three-Day
volumes and revenues, a portion of which moves by ground transportation.
Select
The
“Ground” category includes volumes and revenues for all domestic services other than
those included in the Next Day Air and “Deferred”
categories.
category includes United States import and export shipments,
States shipments.
-5-
The “International”
as well as all non-United
ANSWER
INTERROGATORY
PSAIUPS-9.
OF UNITED PARCEL SERVICE TO
OF THE PARCEL SHIPPERS ASSOCIATION
Witness Sappington
responded
he could not compare Parcel Post performance
service with UPS’ performance
performance
information
on UPS performance
Response
to PM/UPS-9:
of the standards
of those standards
and internal operations
to PSAIUPS-TG-10
. ..‘I Please provide the
in PSA/UPS-TG-IO(b).
Objection filed.
-6-
defining value of
because he had no data “. .on the
of private competitors.
requested
by stating that
DECLARATION
I, Linda Shepherd,
foregoing
hereby declare under penalty of perjury that the
answers are true and correct to the best of my knowledge,
information,
and belief.
/&g&!!{ /
-/Linda
Shgpherd
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the foregoing document
mail, postage prepaid, in accordance
with Section 12 of the Commission’s
by first class
Rules of
Practice.
&hn E. McKeever
Attorney for United Parcel Service
Dated: July 19, 2000
Philadelphia, Pa.