BEFORE
THE POSTAL
20268-0001
WASHINGTON, DC
POSTAL RATE AND FEE CHANGES
prcfp/E!?
RATE COMMISSION
Docket
I
I
No. R2000-1
REPLY BRIEF OF THE
CONTINUITY SHIPPERS ASSOCIATION
The Continuity
the
rate
for
A.
the
actual
for
costs,
Tr.
costs
Service
its
reply
brief
on
("BPRS").
due unit
Service
agrees
BPRS parcels,
overstated
costs.
that
the
downward
reasons,
double
BPRS parcels
postage
the
to reflect
Postal
for
G. But's
weighing
brought
to determine
their
Tr.
these
testimony
Service
this
fact.
one cent
per
1
the
are weighed
included
while
not
incurred
to adjust
its
window
23/10644.
of window
piece.
Tr.
costs.
window
are
Tr.
estimate
acceptance
postage,
In addition,
costs
fails
to the
already
23/10644.
acceptance
and rating
parcels
therefore
acceptance
window
BPRS window
A parcels
and are
Service's
by more than
By using
counts
because
window
Postal
Lawrence
as a proxy
Standard
due unit
rebutted
Reduction:
and rating
the postage
costs
submits
a BPRS parcel.
Service
While
for
has not
A parcels
Postal
weighing
true
for
Standard
the
require
in
Return
- 1.2 Cent
23/10644.
not
Parcel
Service
Collection
costs
Bulk
Association
THE EVIDENCE SUPPORTS BUC'S REDUCTION IN BPRS COSTS
The Postal
on the
Shippers
would
same is
and rated
in
the
the
Postal
for
all
acceptance
For these
acceptance
23/10644.
costs
is
Mail
direct
the
testimony,
proxy
Mr.
Special
reflect
the
Special
Standard
the
Postal
fact
that
wrong.
in
fixed
as the
asserts
because
Mr.
costs
activities
are
such
"fixed"
USPS Initial
Postal
factor
smaller
pools
are
at VIII-8.
analysis
clearly
pools
are
as cube-related
performed
in the
not
adjust
to
than
initial
would
brief,
be
cube-related
The Postal
showed that
proportional
should
downward
1n its
But's
just
In his
and lighter
an adjustment
cost
Brief
Reduction:
Service
23/10646-10647.
that
the
the
Cent
CRA adjustment
BPRS parcels
Tr.
- 6.34
that
fixed
parcels.
weight-related.
simply
But proved
Standard
Service
inappropriate
the
- CRA Adjustment
Processing
or
Service
the
activities
and weight-related
cost
pools:
The
[fixed]
cost
pools
appear
to
fall
into
different
categories:
those in which costs are expected
those in which they are not.
Activities
in the "expected"
cost
pools,
SPBS or the pouching
pools,
should be affected
by
weight
to
factors
the
same degree
that
these
"proportional
Since
witness
cost
pools".
confirmed
that
differences
in the cube and weight
lead to its
modeled
costs
being
about
70 percent
modeled
cost
of
Standard
B
(Tr.
Special
(Eggleston)),
the "expected"
cost
pools
should
have a fixed
CPA adjustment
that
is 70 percent
Special
Standard
B fixed CRA adjustment.
two
and
like
the
cube and
affect
Eggleston
of BPRS
of the
13/5204
similarly
of the
in the fixed
adjustment
Costs
for other
cost pools
cost
registry
are
pools,
like
the
BCS,
FSM,
or
When asked about these
apparent
anomalies,
"unexpected“.
witness
Eggleston
responded,
"It
is my understanding
that
occasionally
costs
show up in cost pools
where they
are
unexpected.
It is my further
understanding
that the reason
for
this
is the following.
The IOCS handling
tallies
record
the mail
actually
being
handled
by the employees
recorded
as working
a given mail processing
operation
(cost
rather
than the mail
expected
to be handled
in a
pool),
given operation."
Tr.13/5128
(Eggleston)
Thus,
if an employee
was clocked
into
the BCS cost
Standard
B
tally,
that
received
a
Special
and
pool,
Special
Standard
mail.
employee
was most likely
handling
2
is
And, if he was actually
handling
Special
Standard
B mail,
it is much more likely
that he was actually
handling
it in
a way that witness
Eggleston
modeled rather
than putting
it
Tr. 23/10646.
through
a bar code sorter.
Mail
Processing
The Postal
Service
inter-BMC
least
on the
mailers.
This
one of the
35-36.
But's
Service's
reasons
only
model
adjustment
of the
brief
are
adjustment
should
Transportation
But's
analysis
transportation
BPRS recipients
made despite
the
not
a national
mailer.
that
brief
that
this
at
to the
Postal
Tr.
23/10647.
and because
incorporates
at
USPS-T-26
information.
initial
are
are
fact
adjustment
this
Reduction:
21 BPRS parcels
is
But modified
it
remains
information,
- 2.9 Cent
the
located
in
For the
But's
But's
- Intra-BMC
above
half
areas
will
that
in the
use zones
in CSA's
unrebutted
results
as well.
3
in
- 0.9
on this
a reduction
Cent
in
zone
half
Postal
above
initial
point,
Commission.
Inter-BMC
v.
fact
rarely
described
remains
by the
the
assumed
of BPRS volume
that
In his
Reduction:
Service's
to reflect
reasons
argument
be accepted
discussed
Postal
BPRS parcels
and more than
Tr.23/10648.
and because
all
- Zone Distribution
BPRS recipients
zone 5.
in our
record
Mr.
survey
of every
that
to incorporate
of inter-BMC
Service's
is
- 0.3 Cent
be accepted.
testimony,
distribution
20 out
makes a reasonable
on the
should
Inter-BMC
assumption
described
Transportation
direct
that
BPRS mailers
model
v.
estimate
analysis
cost
For the
the
estimates
parcels
national
- Intra-BMC
Reduction:
his
BPRS COSTS ARE 99.2
B.
The FY 1999 update
except
for
in
initial
our
Standard
mail
had an insignificant
processing.
CSA Initial
the
FY 1999 mail
brief,
B (on which
The overall
used.
BPRS mail
impact
Standard
something
receive
the
the
the
processing
is
data
based)
FY 1999 is
As discussed
at 3-4.
for
Special
should
not
be
shown below.
increase
decrease
increase
increase
increase
BPRS attributable
class
that
cost
differently
than
Brief
should
they
of
99.2
This
name does not
have the
They remain
Service
handle
would
transform
and use the
cents.
like
to treat
should
change
for
not
what
same coverage.
the
Tr.
handle
is.
one pound,
these
parcels
BPRS labels
have
The Postal
23/10650.
purpose
into
transportation.
BPRS parcels
be allowed.
it
under
A parcels,
on them.
A parcels
themselves
same ground
employees
Standard
A" written
Standard
at 13.
operationally
returned.
Postal
"Standard
nevertheless,
by another
are
same low priority,
same way that
mail
do not
when they
to ensure
Service,
Initial
A parcels
else
In fact,
legs
a unit
Brief
on BPRS costs,
THE COST COVERAGE SHOULD BE THE SAME AS STANDARD A REGULAR
C.
in
0.0
0.9
1.7
1.0
0.1
0.3
supports
impact
processing
of using
Collection
Mail Processing
Transportation
Delivery
Postage Due
TOTAL
The evidence
CENT USING FY 1999 AS THE BASE YEAR
significantly
of pricing.
CSA
Calling
something
The outbound
and return
D.
CONCLUSION
For the
Continuity
piece
$0.992
reasons
Shippers
for
the
in
stated
herein,
Association
BPRS rate
requests
(without
FY 1992 costs
of 132.9
percent
Dated:
September
21,
(or
its
coverage
$0.328
towards
2000
initial
brief,
a recommendation
This
contingency).
and a cost
Regular
and in
per
of
to Standard
institutional
Respectfully
of $1.32
consists
of equal
the
A
costs).
Submitted,
C~
&&
Aaron Horowitzu
200 Corporate
Woods Parkway
Vernon Hills,
IL
60061-3167
(847) 913-3360
Attorney
Shippers
CERTIFICATE
on all
section
Dated:
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
21,
2000
5
brief
with