BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
POSTAL
RATES AND FEE CHANGES
DOCKET
INITIAL BRIEF OF THE
CONTINUITY SHIPPERS ASSOCIATION
Aaron Horowitz
General Counsel
Continuity
Shippers Association
200 Corporate
Woods Parkway
Vernon Hills, IL 60061
Dated:
September
12,200O
NO. R2000-1
TABLE
A.
B.
C.
OF
CONTENTS
1
THE TEST YEAR BPRS UNIT COST, UPDATED
FOR A FY 1,999 BASE YEAR, IS 99.2 CENTS
1.
The Postal
Service
Has Not Rebutted
But's
Testimony
on the Costs for BPRS
2.
Test Year BPRS Costs Increase
0.3
When Using 1999 as a Base Year
3.
The Mail
4.
Other Considerations
BY1998 Data Rather
For Mail Processing
5.
Conclusion
Processing
Cost
Update
3
Cents
4
is Unreliable
5
Also Support Using
than the Unreliable
1999 Data
I
STANDARD A REGULAR AND BPRS
SHOULD HAVE THE SAME COST COVERAGE
8
1.
History
8
2.
Systemwide
3.
Standard
A Parcels
Cost Coverage for
of Returned
Cost
Standard
Coverage
is
A Parcels
Not Appropriate
for
Should Have the Same
Both the Outbound and Return
BPRS
Legs
10
11
4.
The Nine Factors
Under the ACT Support
the
Same Cost Coverage as Standard
A Regular
13
5.
A Lower
Standard
15
6.
The Minor
CONCLUSION
Cost Coverage for BPRS than
A Regular
Could Be Supported
Modification
to BPRS Has No Impact
17
19
BEFORE THE POSTAL RATE COMMISSION
WASHINGTON, DC 20268-0001
I
I
I
I
POSTAL RATE AND FEE CHANGES
Docket
No. R2000-1
BRIEF OF THE
CONTINUITY SHIPPERS ASSOCIATION
The Continuity
for
the
A.
Bulk
Shippers
Parcel
Return
available
for
its
brief
most
recent
on the
rate
("BPRS").
presents
Base Year
processing
CSA witness
overstated
Year
by the
because
using
cost
to conduct
BPRS unit
the
costs
where
the
data
based
Service,
except
mail
processing
costs
data
are
on a
analysis.
using
Postal
these
Tr.
collection,
Collection:
cents.
But
(CSA-T-1)
BPRS costs.
cents.
areas:
But used
Test
as presented
brief
except
data
CSA
FY 1999 as the
for
mail
are unreliable.
The Postal
Service
Has Not Rebutted
But's Testimony
on the Costs for BPRS
1.
11.6
use of the
rates,
this
witness
updated
costs
the
of determining
The CSA presents
1998 Base Year which
also
supports
purposes
unreliable.
costs
Service
submits
THE TEST YEAR BPRS UNIT COST, UPDATED
FOR FY 1999 BASE YEAR, IS 99.2 CENTS
The CSA generally
1.2
Association
as a proxy
In this
23/10644
mail
for
case,
processing
BPRS window
the
Postal
Service
overstatement
is
occurred
has again
at least
in
three
costs
by
and transportation.
Service
Service
the
The overstatement
(But).
The Postal
The Postal
shows that
overstates
users the
Standard
acceptance
costs.
collection
A single
Tr.
piece
parcel
23/10644
(But).
While
weighing,
window
for
already
Standard
included
Including
Service
costs
estimate
Postal
are
standard
proportional
in both
places
The Postal
the
characteristics
mail
processing
0.3
cost
cents
only
on all
BPRS users
being
21 BMCs, i.e.
But presents
did
is based
receiving
20/21
derives
from
95.2
are
fixed
the
Tr.
the
percent.
Postal
that
a fixed
used
and a
the
adjustment,
to reflect
not
making
these
the
(Buc).
Service's
of BPRS parcels
This
are
assumption
basis
23/10647
since
based
(But).
basis.
are
is
inter-
and there
one of the
on a national
of BPRS parcels
2
fact
23/10646-10647
Tr.
approach
percent
BPRS,
parcels.
factor
on a national
returns
for
the
Service
to
of BPRS overstated
intra-BMC.
= 95.2
receive
on 91.9
Postal
percent
returns
model
applied
As But notes,
cents.
model
Standard
then
to tailor
by 6.34
a. more logical
not
Special
characteristics
that
4.8 percent
this
For the
failed
the
assumption
surveyed
factors.
of BPRS parcels.
The other
BMC, while
the
cost
to reflect
Service
Again
Service,
to reflect
inappropriate
than
Postal
The Postal
processing
inputs
counting.
BPRS mail
(But).
To tailor
and lighter
adjustment
overstated
(and
due component.
to double
23/10644
adjusted
the
BPRS postage
B mail
at the
are performed
amounts
costs.
correctly
Postal
the
Tr.
processing
are performed
activities
Service
Standard
smaller
Standard
testimony
within
practice,
modifications
users
costs)
CRA adjustment.
however,
unit
the
Special
Service
BPRS parcels
the
these
by 6.6 cents.
BPRS mail
postage
A parcels,
costs
used the
Special
and collecting
Processing:
processing
As is
in
these
Mail
the
rating
eight
BPRS
But's
inter-BMC,
and
8.1
percent
mail
are
intra-BMC.
processing
costs
for
Transportation:
transportation
Service
is
the
the
same as that
clearly
wrong.
Zones
6-8,
volume
is
will
by 3.8
that
the
for
While
returned
rarely
cents.
parcel
to four
itself
mailers
above
zone 5."
unit
The Postal
of inter-BMC
BPRS parcels
parcels.
Post
stated
that
(But).
(But).
post
of Parcel
to decrease
23/10647
23/10647
zone distribution
Service
use zones
Tr.
is
overstates
Tr.
inter-BMC
shift
cents.
Service
23 percent
Postal
of this
BPRS by 0.3
The Postal
costs
assumed
The effect
cubic
that
"are
This
feet
are
61 percent
located
USPS-T-26
is
sent
of BPRS
in an area
at 37;
to
Tr.
that
13/5114
(Eggleston).
But's
testimony
is based
assumption,
and the
Use of this
more reasonable
transportation
translates
parcels
no BPRS parcels
middle-ground
BRPS parcels
to a 2.9
cent
reduction
in
percent
of 3.1
recalculation
reduction
of 0.9
cents).
of the
which
cents.
Tr.
unit
23/10648
Tr.
23/10648
above,
Service
filed
FY 1999 as the
Excluding
the
mail
estimates
are
overall
updated
processing
costs
almost
exactly
Test
the
3
cents.
for
This
all
BPRS
results
that
are
in an additional
(But).
estimate,
January.
unit
(But).
Cents
Year
unit
See LR-I-469,
Base Year.
zone 5.
reduces
of BPRS parcels
Test Year BPRS Costs Increase
0.3
When Using 1999 as a Base Year
The Postal
cost
Service's
go beyond
by 3.1
the
proportion
was discussed
Postal
assumption
inter-BMC
parcels,
BPRS using
that
for
inter-BMC
2.
assumption
of the
costs
(91.9
But's
on an average
these
cost
figures
for
BP2-99.xls.
new Postal
same as those
filed
Service
in
Test
Year
FY 1999 costs
additional
factor
unit
as the
0.1
for
window
using
FY 1999 data.
Thus,
The Postal
is
the
still
the
delivery
and the
increases
of mail
result
accepted.
mail
3.
costs
The Mail
The testimony
the
unsubstantiated
establish
are
not
by over
processing
similar
and could
that
section
for
the
describes
Processing
presented
by Dr.
Stuart
for
40 percent
between
are based
Elliott
be indicative
the
Special
Standard
explained
of the
that
true
4
analysis
decrease
cent
in
increase
for
These
increases
why this
huge increase
should
for
BPRS cost
not
is
be
updating
BPRS
data.
is
Unreliable
Elliott
(RIAA-ST-l),
Postal
Service
Standard
mail
B mail
Standard
this
cost
and
(RIAA/USPS-l),
processing
processing
Because
1998 and 1999.
upon Special
by 1.7
however,
recent
Update
from
its
due costs.
approach
Cost
speculation
costs
1.0
and therefore
most
costs
increases.
a more reasonable
using
under
collection
that
the
The
entirely
Service
postage
costs,
anomaly
The Special
not
Postal
the
adjustment
excluded
in the
using
S.
increased
CSA believes
the
processing
reliable.
increase.
the
cents
transportation
to wage rate
FY 1999 data
costs
are
The CSA accepts
of an unexplained
processing
costs
decreases
increase
The next
CSA presents
use of the
includes
relate
The update
the
cent
by 0.1
Attachment
no increase
decrease,
cost.
0.1
primarily
significantly.
is
and thus
BPRS unit
the
These
update
small
increase
USPS-T-26,
from
there
Service
accurate,
overall
derives
acceptance.
analysis.
Given
costs
Base Year.
cent
But's
cents.
collection
costs
costs
rose
BPRS mail
costs,
increase
increase.
they
show a
was anomalous
In fact,
the
mail
processing
three
years.
In addition
to the
cost
Using
the
processing
differ
from
This
cost
the
confirmation
quite
percent
higher
little
CPA unit
must
Because
unreliable,
update
percent
At this
processing
contain
the
model,
by 0.9
Tr.
Since
update.
Standard
Test
This
the
unit
modeled
cost
the
were
proportional
BPlxls.
was more than
FY 1999 update
40
had
(Degen),
the
updated
for
processing
anomaly.
Elliott's
higher
cost
P
provides
See LR-I-469,
CRA unit
data
conclusion
CSA increases
the
Standard
and CPA unit
1.4.
Standard
Attachment
This
however,
costs
Special
Service
percent.
45/20071-20072
the
the
Postal
model
cost.
Standard
Special
the
four
the
modeled
CSA follows
Service's
4.
since
Postal
USPS-T-26,
FY 1999 data,
FY 1999 Special
to reflect
Postal
costs
the
the
the
the
data,
actual
that
to more than
on the model,
cost
the
Service's
Using
Elliott,
1999 Special
was 1.04.
by only
Postal
anomaly
than
effect
factor
cost
increased
shows a clear
that
operations
reasonable.
CRA adjustment
made by Dr.
suggest
for
(Elliott).
FY 1998 Base Year
for
the
had been decreasing
41/18032-18033
means that
modeled
that
Standard
arguments
CRA adjustment
mail
This
Tr.
also
1 (Eggleston).
both
Special
models
anomalous.
proportional
at
for
consecutive
Service's
are
costs
unit
Year
mail
and ignores
processing
wage rate
increases
unit
mail
costs
estimated
BPRS mail
it.
are
To
by 1.8
in the
processing
cents.
Other Considerations
BY1998 Data, Rather
late
update,
date,
which
the
Also Support Using
than the Unreliable
Postal
contained
Service
the
5
finally
enormous
1999 Date
presented
mail
processing
the mail
unit
cost
increase.l
explanation
that
In response
of the
there
Service's
After
the
the
Postal
mail
in
being
number
would
Service
made an error
only
review
and scrutinize
seeking
process
alternative
evidence.
Service
is
late
at a late
another
reason
updates,
available,
the
that
stated
tallies
Elliott
completely
caused
there
in the
RPW as the
Postal
Service
was no
Postal
hour
effectively
the
Commission
most
He stated
half
not
have
testimony.
have the
presented
that
that
the
what
the
opportunity
submissions
such
disregard
reliable
the
time
to
The truth
by others
prevented
recent
(about
did
minute
should
to
45/20053.
parties,
changing
decided
Degen testified
tallies.
20 percent
parties
The ever
witness
Tr.
last
evidence
and use the
i.e.
in the
interested
mandates
examine
Service
increased
Degen's
effectively
the
asserted).
The CSA, and other
Service's
he shows that
rebutted,
Postal
originally
an
IOCS direct
Dr.
of tallies
again.
Service
of
for
have suggested.
completely
costs
number
request
Postal
Specifically,
numbers
processing
Postal
the
the
requirements.
the
explanation
review
in
explanation.
increase
Commission's
increase,
in endorsement
this
similar
exorbitant
was an increase
by a change
disproved
to the
to
and present
by the
Postal
examination.
the
evidence
Postal
that
This
Service's
is
BY1998 data.
1 In its initial
response
to the Commission's
request
for an 1999
update on BPRS, the Postal
Service
outlined
numerous difficulties
it
faced in doing so.
The Postal
Service
stated
that it would need to
establish
a new proxy for collection
costs
(or update based on a new
wage rate ratio).
The Parcel
Post transportation
model could not be
The transportation
model is used
simply updated using the new inputs.
Although
for both the transportation
and delivery
cost components.
not stated
by the Postal
Service
directly,
the same inability
to
update using new inputs
also applied
to the mail processing
model.
6
5.
Conclusion
In total,
costs
by 0.3
processing
as shown in
the
cents
costs
the
Postal
Service
to
cents
are
99.2
increased
following
1999 update
per
BPRS parcel
through
the
1.8
only
increased
(where
percent
chart.
TABLE 1: BPRS UNIT COST 1999 UPDATE
(costs rounded to nearest tenth of a cent)
Icontingency)
Detail may not sum to total due to independent rounding.
’ Tr. 23/I 6644 (But)
* USPS-T-26 (Eggleston), LR-I-469, BP2-99.~1~
3 Mail Processing based on CSA unit cost multiplied by 1.8 percent wage increase.
7
BPRS
mail
wage increase),
B.
STANDARD A REGULAR AND BPRS SHOULD HAVE THE SAME COST COVERAGE
BPRS parcels
The cost
coverage
outbound
trip.
1.
should
History
mail
piece
ounce
ground
to
This
air
(But).
The $2.95
Despite
with
1996.
the
United
for
States
(Docket
Postal
rate).
other
Class
single
less
than
Mail
Commission
paid
rate
Tr.
least)
complaint
was settled
through
possible
solutions
existed,
of
of the
Service
during
the
i.e.
did
1995 and
Association
(now the
a complaint
with
in October
rate.
creation
of BPRS
reducing
the
and PostCorn agreed
8
23/10652
Postal
"Commission")
the
$1.79
up to two
as part
anomaly
filed
(for
288 percent.
the
Marketing
in
from
(for
$1.03
Third
percent
piece
including
rate
(the
the
66.25
Mail
the
average
Tr.
No. MC97-2,
Advertising
the
increased
and promises,
piece
Service
charged
BPRS users).
(at
challenging
The Postal
of
Priority
of
A single
Rate
were
case,
(no more than)
coverage
starts
as on the
2-3 day delivery).
of
parcels.
trip
In contrast,
for
Commerce or PostCorn)
No. MC97-4)
PostCorn's
(although
Postal
rate
range
Case Docket
the
R94-1
day delivery)
within
Standard
Ultimately,
Association
the
Third
a cost
Reclassification
address
is
$0.05
many false
returns
by an average
was comprised
cost
return
was 14 percent.
or 7-11
transportation
attributable
piece
(which
A outbound
A Parcels
In the
increased
was only
pounds,
same on the
rate.
service
Standard
A merchandise
The highest
.
one pound,
$2.95.
rate
of
Standard
classes
range
(But)
Parcel
piece
all
single
23/10652
1996
of Returned
single
for
trip
be the
Class
8-16
not
return
to BPRS, Standard
increase
the
the
Prior
Third
Class
are
to a price
single
of
the
$1.75
per
BPRS
agree
on)
the
4 Resp.
the
The parties
retUrn.
attributable
to USPS/CSA-Tl-6.
cost
coverage
was a new service
as required
On October
percent.
comport
costs
and the
showing
30,
Postal
Tr.
1998,
the
the
of $1.038
costs
Service
Commission's
result
Postal
in
of
revised
No. C99-
was no agreement
system
in Docket
wide
No. R97-1
was conducting
that
average.
because
a cost
BPRS
study
(But).
Service
$0.93,
that
methodologies
a cost
the
(much less
Docket
coverage.
there
Service
23/10648
attributable
The Postal
with
reviewed
even discuss,
cost
be at or around
was not
by MC97-4.
or the
not
In particular,
should
The BPRS rate
study
cost
did
coverage
issued
and a cost
cost
figure
from
the
its
BPRS cost
coverage
to $1.038
R97-1
of 168 percent.
of
188
to
case.
Unit
The chart
TABLE 2: STANDARDA SINGLE PIECE/BPRS (1991-2000)
FATE/AITRIBuTABLE
COSTS/COST
C-S
shows that
been
users
of Standard
overpaying
for
Discussions
mailers
based
complaint
Docket
ensued
on the
No. C99-4.
Postal
reduction
Service
rejected
the
cost
In the
complaint
BPRS rate
study.
Postal
Service
have
and affected
The CSA finally
study.
BPRS rate
the
parcels
based
on the
case,
the
based
The Postal
BPRS cost
cost
a
study.
Commission
on the
Service
filed
recommended
a
shown in the
Board
of Governors
recommendation.
appropriate
cost
coverage
for
BPRS has not
been
reviewed
Systemwide
2.
The Postal
systemwide
Cost
Service
average
USPS-T-39
the
the
the
Commission's
In sum, the
previously
between
BPRS cost
in
return
USPS/CSA-Tl-24.
many years.
to redress
13 cent
A and BPRS to receive
argued
because
at 17 (Mayo).
Postal
Coverage
Service's
that
that
BPRS coverage
was the
In Docket
pricing
is Not Appropriate
original
for
should
intent
BPRS
be close
to
of BPRS.
NO. MC97-4 when BPRS was created,
witness
Mohammad Adra
(USPS-T-2)
testified:
The Postal
Service
proposes
for BPRS a simple
flat
fee of
$1.75 that is based on the cost estimates
developed
by
A per-piece
and per-pound
fee
witness
Pham, USPS-T-l.
structure
of $.60 per-piece
and $1.50 per-pound
was first
considered
and consequently
used to derive
the flat
rate.
The resulting
average per piece revenue of $1.75 (using an
average weight
of 0.768 pounds per piece)
was adopted as
Using Pham's $1.12 per piece cost estimate,
the flat
fee.
the flat
fee of $1.75 yields
a cost coverage
of 157
Docket No. MC97-2, USPS-T-2 at 13.
percent.
Adra's
testimony
calculations.
was for
on coverage
There
systemwide
is
was thus
no statement
limited
that
coverage.
10
the
to the mathematicaJ
original
intent
of BPRS
Further,
does
not
recognize
due consideration
average
calculation
that
mail
be.
is
reasons
same as that
coverage
becomes
for
result
factors
of the Act,
of mail.
Second,
Third,
considered
the
based
coverage
witness
on the
cost
coverage
cost
Mayo erroneously
because
the
her
of the
concludes
outbound
leg
for
coverage
BPRS
is
mail.
Mayo justifies
circumstances
no
as such.
appropriate
A regular
or
of a mathematical
should
the
as a benchmark)
of validity.
or is
what
below,
Standard
type
source
average
stated
Service
For example,
Standard
that
does not
proposed
Legs
higher
A outbound
BPRS should
cover
cost
its
parcel.
have a higher
costs.
USPS-RT-
6-7.
The issue
on the
These
the
the
average
(even
Standard
A Parcels
Should Have the Same
Cost Coverage For Both the Outbound and Return
Postal
22 at
particular
only
systemwide
average
to balance
has no independent
question
For the
of whether
outbound
leg
parcels
BPRS will
Service
are
cover
most
as Standard
implementing
to the
cost
USPS-T-39
at
15,
outbound
leg
is
the
against
which
significant,
A mail.
regulations
become BPRS cover
proper
(A) and Standard
attributable
a yardstick
Perhaps
which
relevant
Standard
proposals.
gives
parcels
is not
its
notwithstanding,
parcels
itself
Thus,
why using
systemwide
to that
as systemwide
the
reasons
necessity
is viewed
3.
it
several
First,
the
systemwide
the
are
make sense.
does not
give
there
for
the
Tr.
Postal
is
BPRS.
(A) does cover
its
costs.
only
the
CSA and Postal
Mayo‘s
testimony
significant
because
the
return
leg.
Service
itself
defines
Postal
Service's
shown in the
BPRS return
11
for
23/10649.
really
costs
coverage
both
to measure
the
This
under
their
label.
The "class
BPRS
of
mail"
endorsement
label
is
17,
"Standard
1999,
Service
required
p.
Mail
50452.
looks
like
by the
(A)."
Fed.
label
share
the
return
prepared
(A) machinable
Postal
that
180,
by the
September
Postal
e.g.
only
of machinable
and mailed
In fact,
has not
parcels,
and receive
while
the
12
are
Standard
A can
available
in COSO,
Standard
under
same lowest
Mail
BPRS use the
priority
A has a delivery
a delivery
BPRS
the
"BPRS is
as defined
returned
Standard
established
that
out
or Nonprofit
parcels
return
maximum weight.
mailed
states
as Regular
Third,
meet all
16 ounce
parcels
and the
BPRS returns
and thus
BPRS. DMM S924.1.2
transportation
Service
A parcel
First,
leg,
A mail,
parcels."
A mail.
Standard
outbound
DMM provides
the
same ground
approved
characteristics.
on the
under
initially
Standard
outbound
of Standard
be returned
the
the
A mail
for
64, No.
BPRS return
COSMETbEJNC.
=
200CORPORATEWOOOSPARKWAY
VERNON
HIttS,lt60061
numerous
requirements
only
the
STANDARD MAIL(A)
Furthermore,
Second,
for
this:
60061
Standard
Service
Reg. Vol.
A BPRS return
2;
parcel
Postal
standard
as
standard,
for
BPRS.
The lack
of a delivery
23/10649
(But).
The fact
that
"special
service"
category
should
Regardless,
of
itself,
Postal
rather
than
"special
Standard
designated
cost
it
A regular,
as Standard
same cost
coverage
4.
transported
as Standard
show that
the
current
The cost
applied
cost
coverage
to Standard
the
BPRS as a
cost
coverage.
in and
coverages
for
the
board.
A regular,
on return
mail
does not,
is
as Standard
processed
A regular,
labels,
it
is
should
have the
A regular.
The Nine Factors
Under the Act
Same Cost Coverage as Standard
of the
the
The cost
over
Tr.
A regular
service
Standard
A regular
The application
high.
is
like
to create
determining
a special
all
of BPRS.
Standard
coverage.
are
looks
the
in
a higher
value
decided
adjust
BPRS is
if
the
Service
that
services"
In summary,
lowers
be significant
fact
dictate
numerous
like
the
not
the
standard
Title
39 policies
coverage
should
A regular
Support
the
A Mail Regular
for
nine
BPRS of 168 percent
be 132.9
mail.
and the
percent,
the
is
too
same coverage
Exhibit
USPS-T-32,
factors
as
USPS-32B
(Mayes).
The first
on which
all
balancing
factor
the
the
proceeding,
other
other
the
of "fairness
factors
coverage
proposed
(Mayo),
contradict
this
the
service
§3622(b)(l).
BPRS coverage
percent
The "value
by the
Postal
provides
and is
the
the
basis
As shown in
of 168 percent,
Service
foundation
for
this
and the
(USPS-T-39
at
146
15)
factor.
of service"
provided
are based,
factors.
current
and equity"
to the
in
factor
sender
2 looks
and recipient.
13
at the
inherent
53622(b)
worth
(2).
The
of
value
of the
coverage
the
priority
in
BPRS service
Postal
frequency
of the
meet the
postal
is
reflect
the
earlier,
applied
Establishment
Service
are priced
Overall
factor
There
return
favors
is
delivery
of
to cover
relief
impact
is
Standard
of BPRS parcels.
That
BPRS rates.
equate
Tr.
14
Third
rate
No. R94-1.
to the
general
now known to be warranted.
realistic
does not
Docket
on alternative
may explain
in the
A and the
relief
no economically
higher
and
to more closely
increase
in
costs.
As described
a draconian
interim
3.
on consumers
53622(b)(4).
parcels)
and indirect
institutional
BPRS rate
to
more
of BPRS would
of rates
the
would
direct
by factor
impact
provided
the
however,
lower
return
the
each piece
predecessor
Further
considerably
demand,
the
to remedy
to these
5 considers
83622(b)(5).
as required
contingency)
of BPRS only
Factor
the
contingency)
"bear
BPRS mail
on average,
(the
and BPRS users.
or its
low
ground
determines
(without
of service.
rate
by the
receive
only
of BPRS parcels
by decreasing
cost
piece
Service
return
considers
served
actual
single
BPRS parcels
Postal
to it
(without
also
indicated
and processing;
that
BPRS was created
previously
Postal
per
rate,
4, which
that
(But).
of $1.32
$0.327
mailers,
public
pickup
At that
Factor
Class
mailer's
attributable"
(3).
contribute
and the
requirement
costs
53622(b)
used;
Tr 23/10649
A BPRS rate
than
proposed.
of transportation
is
BPRS parcels.
than
Service
terms
transportation
is much lower
services.
alternative
available
the
32/10652
alternatives
demand for
to value
to the
BPRS.
of service.
(But).
This
Factor
6 looks
preparation
of the
parcels,
that
the
half
Postal
of the
Service
costs
continue
Tr.
considerations
A leg
For the
original
represents
is
23/10650
merchandise
to the
§3622(b)(7).
per piece
fee
structure.
understood
fee
and informational
apply.
of the
service
both
the
53622(b)
at its
(8).
highest
original
mailer
parcel
on the
the
delivery
is
of the merchandise
on its
by-product
return
on the
outbound
and original
outbound
to the
BPRS leg,
of an unsuccessful
original
the
mailbox
recipient,
customer
at the
the
recipient.
Standard
customer
the
"value"
sales
house.
addition,
rather
recipient
may have to use a collection
than
his
not
just
going
The return
shows that
than
he did
own mailbox
outbound
Further,
ordered.
recipient
rather
(But).
A leg
closing
a
of the
transaction.
Tr.
(But).
For the
is
that
32/10652
and easily
fact
establish
structure.
on the
forward
8 do not
mailer,
the
fee
Tr.
and the
Cost Coverage for BPRS Than
A Regular Mail Could be Supported
By comparison,
service
forward
scientific
factor
for
the
BPRS.
of BPRS
parcels
BPRS returns
through
mailer's
processing
of the
up the
the
(But).
cultural,
The "value"
Standard
straight
32/10653
A Lower
Standard
5.
pick
reduced
through
The bulk
have no effect
the
of
of costs
machinability
a straight
will
Educational,
sale.
are
7 favors
structure.
for
BPRS mailers
The CSA proposal
will
reduction
83622(b)(6).
mail.
requirement
Factor
This
at the
want
Standard
the
delivery
leg
for
the merchandise
to the
A leg
mailbox,
the
the
15
the
BPRS parcel.
of the
parcel
original
ordered.
original
box or some other
to enter
delivers
location
In
The difference
return
legs
is
further
mailer.
Cosmetique
customer
continues
whether
the
potential
next
23/10650
of the
outbound
pay for
pay around
No. C99-4
the
of the
In short,
next
and
a BPRS
the
shipment,
is
through
returns
or
no
customer
3/4
of a business
mid-
cancels
does the
of the
time,
relationship.
non-BPRS
returns).
value
are
the
Tr.
to the
By contrast,
does not
want
company
of the
significantly
the
returned
No. C99-4
return
shipment.
customers
(11 percent
BPRS; the
other
2
return
only
of the
are
percent
USPS/CSA-Tl-5.
This
shows
leg.
return
leg
through
than
of
of a cosmetic
whole,
Resp.
shown by
Customers
sent.
shipments
under
merchandise.
less
23/10651-10652
There
the
On the
outbound
outbound
is more clearly
each purchase
(But).
Docket
A leg
merchandise
for
l/l33
of Cosmetique's
shipments
Standard
the
$20.00
Tr.
outbound
support
the
(and there
returns,
membership.
outgoing
to whether
from mid-1997
27 percent
conclusion
customers
13 percent
is
data
of the
the
according
membership
Cosmetique's
the
of Cosmetique,
and receives
their
and in only
for
experience
membership
their
service
(But).
Cosmetique
a high
of the
BPRS returns
in 73 percent
marks
price
Docket
its
cancels
sale).
The value
the
their
continue
BPRS return
value
tracks
membership,
customer
the
shown by the
customer
1999 shows that
their
in
the
is
of low value
While
re-use
there
of the
profit
is
because
some value
return
made from
the
to the
product,
successful
customer
that
value
sales.
(But).
are
equal
also
additional
to or lower
requirements
coverage
than
16
the
on BPRS parcels
outbound
Standard
that
A leg.
TX.
BPRS parcels
10,000
must
a year;
delivery
and the
to the
6.
The minor
the
that
or inefficient
the
customer:
the
and
received
after
value
of
(1)
formally
for
the
the
minor
the
allowing
frequency
of
of BPRS returns.
Service
periods
increased
That
the
it
the
is
unopened
before
and after
to BPRS is
postage
from
label.
BPRS returns
Cosmetique
BPRS, and before
shown.
to
impracticable
return
of a BPRS return
versus
Service
and redeposited
where
to seek
nor
modification
Postal
resealed
mailer
creation
modification
at least
the
BPRS service.
original
of opened
time
can determine
had opened,
Postal
(21 the
The percentage
receive
to BPRS has neither
to the
for
must
to BPRS Has NO Impact
customers
mailstream
mailer
up by the mailer
Modification
relative
parcels
into
or pick
two changes:
return
the
Service
modification
the
involved
Postal
mailer
The Minor
decreased
machinable;
be
Docket
and
No. C99-4
Resp.
OCA/CSA-Tl-14:
Table 3:
Percentage
of Opened v. Unopened
Third Class Single
Piece/BPRS
Pre-BPRS
3/97-10/97
BPRS
10/97-9/99
Unopened
44.09%
Opened
55.91%
CSA-T-1
at
9.
nor
the
minor
the
Postal
only
Tr.
(Buc).
is
the
shows that
modification
modification
mailer
Opened
54.47%
The data
Service's
23/10651
Cosmetique
Returns
neither
handling
the
Moreover,
same whether
Opened
52.44%
Unopened
45.53%
the
to BPRS to include
actual
codified
BPRS-Modification
10/99-12/99
the
the
establishment
opened
of opened
Postal
Service's
value
return
17
Unopened
47.56%
of the
of BPRS,
returns
affected
The
returns.
pre-existing
practice.
BPRS service
to the
has been opened
or unopened.
Cosmetique
states
same manner.
that
it
23/10651
(But).
the
volume
of returns
recovery
centers
creation
of BPRS or the
has not
Service's
minor
of the
determination
Cosmetique
returns
receives
or decreased
modification
in the
from
as a result
the mail
of the
to BPRS.
Docket
resulted
from
was no additional
cost
the
use of a return
from
the
third
minor
were
$3.15,
plus
$3.45
the
single
way regardless
per
piece
return
--
of whether
also
rate
addressed
C99-4
No.
anomaly
the
Standard
return
the
a return
from
parcels
label
18
were
Postal
associated
R94-1.
fee.
This
returned
was attached
Prior
return
B inter-BMC
label
the
one more vestige
who used a merchandise
merchandise
even though
simply
It
customers
$0.30
BPRS fee
there
label.
modification,
charged
the
class
BPRS label
that
with
twice
increased
and unopened
OCA/CSA-Tl-7.
The creation
the
opened
Tr.
Further,
Resp.
processes
label
rate
is
in
or not.
to
of
almost
the
same
C.
CONCLUSION
For the
Association
reasons
requests
to the
Board
Return
Service
and a cost
costs).
Return
stated
that
the
of Governors
should
herein,
be $1.32,
of 132.9
Such a rate
properly
Service
and is
Continuity
Commission
finding
coverage
the
that
the
consisting
percent
in accord
issue
(or
reflects
with
a Recommended Decision
rate
of
for
the
$0.992
$0.328
the
Shippers
value
the policies
Bulk
in
Parcel
FY 1999 costs
towards
institutional
of the
Bulk
Parcel
and purposes
of the
Act.
Dated:
September
12,
2000
Respectfully
Submitted,
.
&
i&la%+-,
Aaron Horowitz
200 Corporate
Wo
Vernon Hills,
IL
(847) 913-3360
Attorney
Shippers
CERTIFICATE
on all
section
Dated:
Parkway
60061-3167
for the Continuity
Association
OF SERVICE
I hereby certify
that I have this
day served the foregoing
participants
of record
in this proceeding
in accordance
12 of the Rules of Practice.
September
12,
2000
19
brief
with