‘.
-.
JUGINAU
..-
zs g
BEFORE THE
$2
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
I
SPECIAL SERVICES REFORM, 1996
:;_$
-4,”
,5-T”
G>u”
$;$
Docket No. MC@3
2
9
ZJ
,”
5
t
c
2
s
RESPONSES OF THE UNITED STATES POSTAL SEF!VICE
TO INTERROGATORIES
OF NASHUA/MYSTIC
(NM/USPS-8-l 1, 13, 20, 22-27)
In accordance
with Presiding
Officer’s
Ruling No. MC96-3/10
1996), the United States Postal Service hereby provides responses
interrogatories
of Nashua/Mystic,
(September
to the following
filed on August 8, 1996: NM/USPS-8-11,
13-20,
22-27.
Each interrogatory
is stated verbatim and is followed by the Iresponse
Respectfully
submitted,
UNITED SWES
POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr
Chief Counsel, Ratemaking
Michael T Tidwell
475 CEnfant Plaza West, S.W.
Washington, D.C. 20260-1137
(202) 268-2998; Fax -5402
September 23, 1996
------.
11,
I
RESPONSES OF THE UNITED
TO INTERROGATORIES
STATES POSTAL SERVICE
OF NASHUA/MYSTIC
NM/USPS-0.
a.
Since
Docket
NO. R94-1,
(i) has the Postal
Service
revised,
corrected
or updated
any previous
study
dealing
with
BRM,
including
but not limited
to the study submitted
as a library
reference
in Docket No. R94-1; and (ii)
has the I?ostal
Service
initiated
or commissioned
any new study
or analysis
dealing
with BRM?
b.
Unless
the answer to both (i) and (ii)
above is an unqualified
negative,
please
(i)
identify
all
BRM studies
or analyses
completed,
and submit
copies
of each
completed
study
so
identified
as a library
reference,
and (ii)
identify
all
BRM
studies
or analyses
underway
and describe
fully
the scope and
status
of any study
not yet complete,
and state
the target
schedule
fmor completion
of all
such studies
nc~w in progress
(include
any studies
in the planning
stage
as well
as those
actually
underway).
a.
(i)
No.
(ii)
Yes.
(i)
No studies
(ii)
,As part
of
Business
Reply
planning
to
b.
scope
have
the
completed
comprehensive
Mail,
study
It
the
of
is
calendar
that
expected
year.
management
Postal
Business
and timing
determined.
end of
its
been
Service
Reply
study
to
Mail
review
of
is presently
costs.
presently
be completed
are
The
being
by the
RESPONSES OF THE UNITED
TO INTERROGATORIES
STATES POSTAL SERVICE
OF NASHUA/MYSTIC
NM/USPS-g.
a.
What was the total
number of BRM advance
deposit
accounts
1994 and Base Year
1995?
Please
provide
data
that
comparable
to the
64,244
BRMAS accounts
[and. 128,488
accounts]
estimated
by USPS witness
Mallonee
and referenced
interrogatory
NM/USPS-17.
b.
Of the total
number of BRM advance deposit
accounts
identified
in
preceding
part
please
state
the
number
or
the
(a),
percentage
that qualified
for the BRMAS rate in Base Year 1995,
and explain
the basis
on which the estimate
is derived.
C.
For Base Year 1995, please
state
the total
from the accounting
fee for BRM advance deposit
the $205 per account
shown in rate
schedule
d.
state
For Base Year 1995, please
issued
and total
revenues
derived
the $85 per account
shown in rate
a.
of BRM advance
deposit
approximately
131,917.
The number
accounts
of
these
C.
The total
d.
--_--
1995
a.
from
was
during
were
FY 1994 was
The number
to
is
not
NM/USPS-17
above
BRM advance
BY from
deposit
$185
in approximately
from
,accounting
$26,603,496.
to
were approximately
increased
deposit
BRMAS acc!ounts
approximately
the
there
The fee
-~
part
revenue
resulting
fees.
in
of BRM advance
See response
present.
to
For BY 1995,
issued,
-.----
at
See response
increased
which
accounts
b.
BY
accounts
BRM permits
fee;
-Ii.e.
in BY 1995 was approximately134,369.
available
for
revenues
derived
accounts;
i.e.,
SS-2.
the number of
from the permit
schedule
SS-Z!.
The number
in
are
BRM
in
fee
$205.
229,151BRM
$18,720,176
$15 to
The
fee
$85 (during
permits
in permit
the
BY.
RESPONSES OF THE UNITED STATES POSTAL SERVICE
TO INTERROGATORIES OF NASHUA/MYSTIC
NM/USPS-lo.
a.
What
was the
total
volume
of
BRM in
1994
and Base
Year
1995?
b.
What was the number,
or percent,
the pre-barcoded
rate of 2 cents
accounts
in
Base Year 1995?
C.
What was the number,
or percent,
of total
BRM pieces
the "other"
(non-pre-barcoded)
rate of 10 cents per
advance
deposit
accounts
in Base Year 1995?
that paid
piece
for
d.
What was the number,
or percent,
of total
BRM pieces
the rate of 44 cents per piece
(when advance deposit
were not used)
in Base Year 1995?
that paid
accounts
of total
BRM pie'ces that paid
per piece for advance deposit
RESPONSE:
a.
--
-__---
The total
estimated
1,250,481,913
of
volume
to
have
pieces,
BRM in FY 1994
1,067,614,836
been
respectively.
b.
53 percent
C.
This
fee increased
42 percent.
cents per piece
to 10 cents per
d.
5 percent.
cents per
This
fee increased
piece
to 44 cents per
-~
during
pieck.
during
piece.
-
and
By
By
BY 1995 is
pieces,
and
1995
1995
from
from
9
40
RESPONSES OF THE UNITED
TO INTERROGATORIES
STATES POSTAL SERVICE
OF NASHUA/MYSTIC
NM/USPS-11.
In Docket
Mallonee,
No.
Jr.,
R94-1,
the
USPS-RT-8,
rebuttal
at p.
testimony
of
fn. 2, stated
3,
witness
that
BRMAS participants
are required
to use different
add-ons
depending
upon their
use of postcards,
pieces,
or 2 ounce pieces.
Please
explain
how the BRMAS account
holder
sender
puts into
a BRM envelope
and can tell
BRM letter
will
,weigh 1 or 2 ounces.
Donald
L.
z1p+4
1 ounce
can control
in advance
what the
whether
a
RESPONSE:
BRMAS
envelopes
questionnaires,
reply
cards,
piece.
such
the
items
fall
same inserts,
returned
within
the
compatible
to
will
l-ounce
with
be
recipients.
cards,
the
very
piece
great
rare.
will
or other
for
account
no BRMAS account
holder
confidence
is
this
limit,
that
pieces
the
in unusual
These
holder.
absolute
case
items
automationholder
are
excemeding
many
is
expecting
certainty
many
for
the
solicited
the
exceed
in
additional
Except
approved
can say with
with
enclosure
specifically
BRMAS pieces
Such
provided
specific
BRMAS account
While
pieces
for
solicit
specifications
receive.
incoming
project
weight
or
or money orders.
and machinable
to receive
no
to
out
statements
etc,
as checks
are
expected
sent
Many BRMAS mailers
enclosures,
cases,
often
are
that
able
to
1 ounce
remittance
RESPONSES OF THE UNITED
TO INTERROGATORIES
(Response
to
Others
(weight
between
instance),
pieces
continued)
BRMAS recipients
identical
weigh
NM/USPS-l1
also
outside
who
and size)
are
able
pieces
(ballots
to project
expected
to
expect
mail
1 and 2 ounces
the
STATES POSTAL SERVICE
OF NASHUA/MYSTIC
weight
receive
essentially
(and little
else)
which
in a union
'election,
for
with
great
range
will
confidence
be very
that
rare.
RESPONSES OF THE UNITED
TO INTERROGATORIES
STATES POSTAL SERVICE
OF NASHUA/MYSTIC
NM/USPS-13.
a.
In Docket No. R94-1,
the rebuttal
testimony
of witness
Donald
L. Mallonee,
Jr.,
USPS-RT-8,
at p. 5, stated
that
"Most sites
that utilize
BRMAS continue
to process
BRMAS mai:L pieces
on a
Please
confirm
that
witness
separate,
unique
sort
program."
Mallonee's
statement
is as true today as when it was written.
b.
If you are unable
to confirm,
please
explain
circumstances
that have changed with respect
mailpieces
are handled
at "most sites."
fully
to
and cite
all
the way BRMAS
RESPONSE:
Each
site
program.
would
which
runs
Since
ZIP+4
be extremely
sorted
on this
time
required
to
have
unique
5-digit
sort
print
ar
program.
sort
to
ZIP
Codes
not
program.
have
taken
for
if
letters
It
would
BRMAS bills.
would
sortations,
on a non-BRMAS
densities
time-consuming
were
primary
BRMAS continues
which,
facilitate
In
a unique
each
other
greatly
additio,n,
when
held
processiing
sort
piece,
than
BRMAS
extend
many
out
this
it
the
sites
during
mail
RESPONSES OF THE UNITED
TO INTERROGATORIES
STATES POSTAL SERVICE
OF NASHUA/MYSTIC
NM/USPS-14.
In Docket
Mallonee,
No.
Jr.,
R94-1,
the
USPS-RT-8,
rebuttal
at p.
testimony
explained
6,
of witness
that
Donald
L.
Inaccurate
BRM billing
occurs
when
BRMAS customer
information
is
not
maintained
and
kept
current.
Modifications
to customer
account
characteristics,
such
as assigning
new BRMAS bar codes to reflect
the use of
postcards
as well
as letters,
[and1 removing
customers
that drop out of the program
may affect
the counting
and rating
process.
a.
How many customers
year 1995?
dropped
b.
What form
customers
program?
C.
How many BRMAS accounts
d.
(i) changed
from
In base year
1995, how many BRMAS accounts
or vice-versa;
or (ii)
started
receiving
letters
to postcards,
post cards
in addition
to letters,
or vice-versa?
e.
On average,
reprogrammed
or forms
are
that
qualify
out
used
for
were
how many times
at local
sites?
of
the
BRMAS program
to identify
and
and participate
added
in
a year
base
must
in
base
keep track
of
in
the
BRMAS
year
1995?
BRMAS software
be
RESPONSE:
a.
The Postal
permit
Service
it
not
in
national
estimate
to
participating
in
the
has not
how
BRMAS at
program
surveyof
Due Delivery
performed
Clerks
at
all
the
the
Postal
would
many
a study
customers
beginning
beginning
Business
be required.
that
of
of
Centers
would
who
were
FY 1995
were
FY
1996.
and Postage
A
RESPONSES OF THE UNITED STATES POSTAL SERVICE
TO INTERROGATORIES OF NASHUA/MYSTIC
Response
b.
to
NM/USPS-l4
No standard
a Copy
a form
The Postal
in
used
Service
it
to
fiscal
Attached
in
has
the
to this
Southern
response
Maryland
is
Postal
for
letters
performed
has not
1995,
performed
that
would
were
added
post
a study
which
would
how many BRMAS accounts
to postcards,
receiving
a study
1995.
Service
indicate,
not
how many BRMAS accounts
estimate
year
The Postal
from
are used.
Center.
permit
d.
forms
of
Business
C.
continued)
cards
or vice-versa;
in
addition
(i)
or
to
changed
(ii)
started
lett'ers,
or
vice-
versa.
e.
It
varies,
which
depending
customers
are added
and whether
changes,
into
on such factors
a single
or dropped,
multiple
presently
3 new BRMAS customers
is not
Whether
weeks
known whether
there
and whether
this
is nationally
changes
Maryland,
took
effect
consolidation
at any given
for
time.
three
instance,
in
instance,
in
there
are
that
added
is a need to reprogram
at Southern
when the
option
is
For
estimated
Maryland,
It
can be consolidated
effort.
Southern
Erequencywith
or make letter/card
changes
reprogramming
it
as the
relation
every
two
weeks.
representative.
times
every
would
depend
to
one
two
on
another
of reprogramming
was a feasible
Other
may input
facilities
sort
RESPONSES OF THE UNITED
TO INTERROGATORIES
Response
to
NM/USPS-14
program
on specific
---
continued)
changes
a month,
with
STATES POSTAL SERV'ICti
OF NASHUA/MYSTIC
the
date.
several
times
expectation
a week or only
that
the
changes
several
take
times
effect
RESPONSES OF THE UNITED STATES POSTAL SERVICE
TO INTERROGATORIES OF NASHUA/MYSTIC
NM/USPS-IS.
In Docket
Mallonee,
No.
Jr.,
R94-1,
the
USPS-RT-8,
rebuttal
at p.
7,
testimony
of
stated
that
witness
Donald
L.
While
there
is a procedure
through
which
the customer
presents
postage
paid mailpieces
for reimbursement,
the
Postal
Service
sometimes
performs
these manual counts
as
a customer
service.
a.
Does the Postal
Service
continue
to perform
these manual
as a customer
service?
If the answer
is negative,
explain
when the Postal
Service
discontinued
providing
counts
as a customer
service.
counts
please
manual
b.
Does the Postal
Service
have any policies
relating
to
will
perform
these manual counts as a customer
service?
please
describe
them in detail.
when it
If so,
C.
that
a Postal
Service
employee
is performing
a
Assume
(i)
manual
count
to help a customer
obtain
a refund
for postage
and (ii)
while the employee
is so engaged,
paid BRMmailpieces,
Would that tally,
and
an IOCS tally
is taken on that employee.
the costs
associated
with that
tally,
be charged
to BRM?
RESPONSE:
a.
Yes.
b.
NO.
C.
Yes
RESPONSES OF THE UNITED
TO INTERROGATORIES
STATES POSTAL SERVICE
OF NASHUA/MYSTIC
NM/USPS-16.
In Docket
Mallonee,
No.
Jr.,
R94-1,
the
USPS-RT-8,
rebuttal
at p.
testimony
of
stated
that
8,
witness
Donald
L.
While BRMAS software
is now resident
on all Postal
Service
bar
code
sorters,
it
does
not
currently
interface
effectively
with
the MMC DBCS software
and therefore
Cannot be used to count and rate BRMAS mailpieces.
a.
IS it still
true that
MMC DBCS software?
b.
In POStal
machines,
Service
please
BRMAS does not
facilities
describe
interface
with
effectively
that
are equipped
only
how BRMAS mail
is handled.
with
MMC
RESPONSE:
a.
Yes
b.
Currently,
there
now have
these
MMC machines,
sort
BRMAS and use
volumes.
This
would
be an option
some
cases,
plant
may
the
MPBCSs which
Although
software.
very
Many of
MMC machines.
also
are
to
elect
sites
the
to
that
are
compatible
could
still
with
not
use the
reports
volumes
this
counting
are
to
this
relatively
mail
have
only
MMC DBCSs
the
work
BRMAS software,
manually
process
received
does
end-of-run
not utilize
the
which
sites
BRMAS software
avoid
where
few facilities
BRMAS
on the
machines
record
but
to
bin
would
mail.
In
small,
the
manually.
--
RESPONSES OF THE UNITED
TO INTERROGATORIES
STATES POSTAL SERVICE
OF NASHUA/MYSTIC
NM/USPS-17.
In Docket
Mallonee,
No.
Jr.,
R94-1,
the
USPS-RT-8,
rebuttal
at p.
testimony
of
fn. 5, stated
8,
witness
tha-t
Donald
L
665,010,200
[pieces]
divided
by 64,244
BRMAS accounts
(assuming
half of the BRM advance deposit
accounts
are for
BRMAS) divided
by 312 days per year
(6 days a week)
=
33.18 pieces
per account/day.
a.
Postal
Service
have
data
show
Does
the
that
the
any
distribution
of the
volume
of BRM mail
by account?
To
illustrate
the type of data desired,
how many BRM accounts
receivedmore
than l,OOO,OOO pieces per year;
how many accounts
receivedbetweenlOO,OOO
andl,OOO,OOO
pieces
per year;
andhow
many received
less
than
100,000
pieces
per year?
Please
provide
all
BRM distribution
data,
whether
in the above size
that are in the possession
of
ranges or any other
size ranges,
If no such
the Postal
Service
for the last three
fiscal
years.
please
so state.
data exist,
b.
Please provide
the basis for witness
Mallonee's
assumption
that
"half
of the BRM advance deposit
accounts
are for BRMAS."
If
any kind
of surveys
or other
data underlie
this
statement,
please
identify
them and provide
copies
thereof.
RESPONSE:
a.
A nationwide
No.
and one has
b.
not
been
of
evolved
from
with
in the
Finance
persons
of
the
basis
basis
of
recollection.
the
testimony
for
this
estimate
accounts
would
be necessary,
performed.
The estimate
was preparing
--__..
survey
a discussion
in
Mr.
Mallonnee
Department
during
the
Docket
R94-1.
estimate
has
since
No.
has been
escaped
time
he
No record
preserved.
his
had
powers
The
of
RESPONSES OF THE UNITED STATES POSTAL SERVICE
TO INTERROGATORIES OF NASHUA/MYSTIC
NM/USPS-18.
In Docket
Mallonee,
No R94-1,
the
Jr ., USPS-RT-8,
rebuttal
at pp.
testimony
8-9,
stated
of witness
that
Donald
L.
Seasonal
fiuctuations
in BRM volumes
produce
a further
reduction
in volume for some days.
Sites
may not choose
to repeatedly
change
their
distribution,
counting
and
rating
procedures
as individual
BRMAS customer
volume
fluctuates.
Instead
these sites
would use manual counting
of BRMAS mailpieces.
(fn.
omitted)
a.
Please
confirm
that
the above statement
is as true
today
as
when it was written.
If you are unable
to confirm,
please
explain
fully
and cite all circumstances
that have changed with
respect
to the way the Postal
Service
handles
BRM accounts
with
fluctuating
low volume.
b.
What is the volume level
(or range of volume)
below which
would generally
use manual counting
of BRMAS mailpieces?
c.
Is it a correct
interpretation
of the above-quoted
statement
that
for
some BRM accounts
the Postal
Service
may generate
and on
automated
BRMAS statements
on some days of the year,
other
days of the year opt to use manual counting
of the BRMAS
If so, does the Postal
Service
nevertheless
always
mailpieces?
charge such accounts
the barcoded
fee of 2 cents per piece,
or
does it charge the 10 cents per-piece
fee when the Volume
iS So
low that
it is more
economical
to count the pieces
manually?
If the fee does not depend on the way the mail
is
actually
handled,
please
explain
fully
all
reasons
why not.
sites
RESPONSE:
a.
The Postal
Service
has no basis
statement
applies
any
Volumes
for
fluctuate
college
volumes
periods
mail
twice
concluding
today
BRMAS customer
of
a year
which
for
this
in
1994.
volume
might
four
that
than
One example
time.
office,
admissions
of
differently
“seasonal”
for
for
to
normally
would
receive
six
weeks
be a
large
at
a
RESPONSES OF THE UNITED
TO INTERROGATORIES
Response
to
NM/USPS-18
time.
The
little
or
continued)
rest
it
of
volume
b.
That
might
time
has
machine
and then
is
account
volume
for
from
the
placed
it
back
at
all
on other
use numbers
volume
as five
pieces
would
would
receive
a BRMAS account
sort
program
for
on the
program
depending
on
as
either
or off
the
for
day
sort
program
for
or months,
approved
for
normally
for
not
programs.
program
of
is
time.
Since
Mail
the
for
not
as
firm
sites
unusual
to be as low
taken.
a week.
for
days.
BRMAS, if
is
on
Some
on a machine
2 days
a period
150 BRMAS
used
It
a
50 pieces
BRMAS accourlt
an account
sort
and
may use
action
If
accounts
10 pieces.
before
manually
all
sort
a particular
per
not
have
site
automation
for
machine
is the number
be on the
weeks
been
to
local
and constraints.
Another
this
and then
would
choose
as low as 20 or
the
a week,
practices
times.
holdouts
locally,
processing
might
since
A site
made
a 200-stacker
a cut-off,
have
the
be removed
and operating
accounts,
are
year,
As the
determination
site
for
the
increases.
mailflows
C.
of
no volume.
diminishes,
a period
STATES POSTAL SERVICE
OF NASHUA/MYSTIC
three
days
The account
a period
of
These
intervals
these
Processing
time
accounts
chooses
RESPONSES OF THE UNITED
TO INTERROGATORIES
Response
to
NM/USPS-18
to
fact
would
continued)
switch
interval
the
the
of
be charged
automation
automation
up getting
same
mailstream
discounts,
processed
manual
processing
this
does
has been approved
accordingly
The
rate
to
low volume,
customer
processing.
for
account
because
that
STATES POSTAL SERVICE
OF NASHUA/MYSTIC
is
true
pays
manually
for
during
the
for
that
whichmeets
discounted
or
not
the
period
the
portion
for
negate
an
the
BRMAS and
of manual
of
the
specifications
rates,
mechanically.
but
ends
RESPONSES OF THE UNITED
TO INTERROGATORIES
STATES POSTAL SERVICE
OF NASHUA/MYSTIC
NM/USPS-19.
In Docket
Mallonee,
No.
Jr.,
R94-1,
the
USPS-RT-8,
rebuttal
at p.
testimony
of
stated
that
9,
witness
Donald
L.
As plants
developed
BRMAS sort programs
they discovered
that
many bar
code
sorter
stackers
received
minimal
volumes
Consequently,
the
BRMAS report
generation
process,
combined with the time used to process
BRMAS mail
pieces,
actually
took longer
and used more resources
than
did the manual sorting,
counting,
and billing
system used
prior
to BRMAS implementation.
(fn.
omitted)
a.
Please
define
the
term
"minimal
volumes"
as used
here.
b.
Please
confirm
that
the above statement
is as true
today
as
when it was written.
If you are unable
to confirm,
please
explain
fully
and cite all circumstances
that have changed with
respect
to BRMAS accounts
with
low or "minimal"
volume.
C.
Please
require
qualify
explain
fully
why the Postal
Service
and the DMM do not
BRM mail
in order
to
a minimum volume
of incoming
for the BRMAS rate.
RESPONSE:
a.
"Minimal"
volume
be 50 pieces;
could
The Postal
Service
BRM specifications
the
another,
used
for
any differently
Service,
recommendations
at
has no basis
applies
through
which
of the
DMCS, and based
the
were
its
10.
of
concluding
which
recommended
in
to
inconsistent
are
volume.
that
than
DMM, sought
not
at
a "minimal"
regardless
today
Commission,
upon
experienced
some facrlitles,
BRMAS is
many facilities,
The Postal
to the volume
At
facility.
statement
C.
in relation
a particular
At
b.
varies
this
1994
establish
with
reflected
decisions.
the
in
RESPONSES OF THE UNITED
TO INTERROGATORIES
STATES POSTAL SERVICE
OF NASHUA/MYSTIC
NM/USPS-22.
In Docket No. R94- -1, the Postal
of Hien D. Pham, USPS-RT-I.
Pham stated
that
Service
In that
submitted
testimony,
rebuttal
at p.
testimony
5, witness
the BRMAS operation
performs
the counting,
rating
billing
of BRM pieces,
which
in fact
constitute
special
service
features
of BRM, above and beyond
pertaining
to regular
First-Class
Mail.
a.
b.
Does the BRM special
other
than
counting,
enumerate
all
other
and
the
those
service
have any distinguishing
rating
and billing?
If
distinguishing
features.
so,
features
please
Please confirm
that the fee which mailers
pay for BRM is based
on the attributable
costs
which the Postal
Service
incurs
to
count,
rate and bill
BRM pieces,
and which according
to witness
Pham, "constitute
the unique
special
service
features
of BRM,
above andbeyondthose
pertaining
to regular
First-Class
Mail."
If you do not confirm,
please
explain
fully
the basis
for the
per-piece
BRM fees.
RESPONSE:
a.
One of
the
objectives
review
of
Business
there
are
service
other
b.
The
which,
which
mailers
to
the
No. R90-1
fee
that
the
Postal
to
determine
both
whether
unaccounted
costing
pay
today
Docket
for
and
non-BRMAS
for,
pricing
fees.
The current
in
was unable
BRM are
No. R94-I determination
"across-the-board"
was recommended
Service
is
management
BRM.
Commission's
Docket
internal
previously
for
baseduponthe
recommend
ongoing
Mail
additional,
distinguish
fees
the
Reply
features
purposes,
of
Docket
in
increases
BRMAS fee
No.
to persuade
R90-1.
the
is
the
the
same
Because
Commission
RESPONSES OF THE UNITED
TO INTERROGATORIES
(RESPONSE to
continued)
m/usPs-22
in
Docket
No.
appropriate,
that
it
a 2-cent
BRMAS fee
Commission
concluded
in Docket
to
PRC Op.
is able
including
the
service,
"the
attributable
rate
of
Pham, 'constitute
features
of
regular
-
First-Class
Service
above
Until
the
R90-1
Postal
of BRM,
provision
unable
Service
unique
beyond
No.
:review
and which
those
not
No. R94-1
of
to
state
BRM is based
Postal
the
and
is
was
the
with
pay for
BRM pieces,
witness
Docket
15461.
associated
mailers
which
on the
a comprehensive
Postal
and bill
BRM,
at
costs
fee which
costs
rely
R94-1
to complete
a study
whether
I--
that
was "constrained
Service
count,
R94-1
the
analysis."
that
STATES POSTAL SERVICE
OF NASHUA/MYSTIC
on the
incurs
to
according
to
special
service
pertaining
to
Mail."'
-.
Answer of United States Postal Service to
Nashua Photo Inc. and Mystic Color Lab
NM/USPS-23.
For Base Year 1995, what was the total cost attributed to BRM?
NM/USPS-23
Response.
The Base Year 1995 (FY 1995 CRA) total cost attributed to BRM
was $105,393 thousand.
Answer of United States Postal Service to
Nashua Photo Inc. and Mystic Color Lab
NM/USPS-24
Does the Postal Service use the IOCS to determine attributable
a.
costs of BRM?
If the answer to the preceding question is affirmative, please
b.
describe the activities tallied as chargeable to BRM, and state the number of
tallies used to determine BRM attributable costs in Base Year 1995.
Does the Postal Service use any information other than, or in
addition to, IOCS tallies to determine BRM attributable costs? If so, please
describe fully and state how attributable costs of BRM are determined.
C.
NM/USPS-24
Response.
a.
The IOCS is used to determine the attributable
costs of BRM in the
b.
See Library Reference SSR-17, page 218, sections S and 6 for the
CRA
definition of the tallied activities that are chargeable
to BRM. There were 602
unweighted tallies and 39,686 dollar weighted tallies for BRM in Base Year 1995
(FY 1995 CRA).
C.
The CRA uses no other basis for BRM other than IOCS
Answer of United States Postal Service to
Nashua Photo Inc. and Mystic Color Lab
NM/USPS-25
a.
With respect to the fees paid by BRM users with an active
business reply advance deposit account, in Base Year 1995 did the 10 cent perpiece fee for “other” pieces (&., pieces not pre-barcoded) on averaqe cover all
attributable costs of such other pieces?
b.
With respect
business advance deposit
fee for “other” pieces (&.,
of such other pieces when
emplovees?
to the fees paid by BRM users with an active
account, in Base Year 1995 did the 10 cent per-piece
pieces not pre-barcoded) cover all attributable costs
they are handled and counted individuallv bv USPS
If the answer to either of the preceding questions is negative,
please provide all evidence on which the Postal Service relies to show that BRM
fee of 10 cents per piece does not cover attributable cost, either on average or
when BRM pieces are handled and counted individually by USPS employees.
C.
Was the 10 cent per-piece BRM fee designed to cover all
d.
attributable costs when non-barcoded BRM pieces are handled and counted
individually? Unless the snswer is an unqualified affirmative, please state the
costs that the 10 cent fee was designed to cover.
NM/USPS-25
a.
response
In the CRA, the attributable
costs for BRM are not captured
separately for “BRM users with active business reply advance deposit accounts”
nor are the costs captured separately for “pieces not pre-barcoded”
b.
In the CRA, the attributable
costs for BRM are not captured
separately for “such other pieces when thev are handled and counted
individuallv bv USPS employees”.
See also the response to part a of this
question.
C.
Not applicable.
See responses to parts a and b of this question,
Answer of United States Postal Service to
Nashua Photo Inc. and Mystic Color Lab
NM/USPS-25
d.
Response continued
Confirmed
RESPONSES OF THE UNITED STATES POSTAL SERVICE
TO INTERROGATORIES OF NASHUA/MYSTIC
NM/USPS-26.
a.
Is it the Postal
Service
view that BRM fees derived
from the 10
cent per-piece
fee for "other"
(non-pre-barcoded
and/or
nonmachineable)
pieces with advance deposit
account
shouldbe
used
to cover
attributable
costs
associated
with
pre-barcoded
pieces?
b.
Unless
the answer to the preceding
question
is an unqualified
negative,
please
(i) state
fully
all circumstances
that justify
a higher
fee for some BRM to cover attributable
costs of other
and (ii)
explain
whether
such a
BRM that
pays a lower
fee,
practice
constitutes
good rate design.
RESPONSE:
As the
internal
view
should
Postal
Service
management
as to
whether
continue
to
moves
review,
this
be the
is
closer
it
the
case.
to
the
completion
will
be able
case
and,
if
to
articulate
so,
whether
of
its
a
this
.
RESPONSES OF THE UNITED STATES POSTAL SERVICE
TO INTERROGATORIES OF NASHUA/MYSTIC
NM/USPS-27.
With respect
to "other"
BRM pieces
(i.e.,
pieces
not pre-barcoded
and/or
not machineable),
does the Postal
Service
have in place
any
established
procedures
designed
to avoidhandling
and accounting
for
each BRM piece
individually?
Unless your answer is an unqualified
negative,
please
describe
each such procedure
and provide
citations
to the DMM or a library
reference
with all applicable
instructions
for use and implementation
of each such procedure
by post offices
and field
personnel.
RESPONSE:
Non-machinable/non-barcoded
Postal
Service
in
BRM has
mechanized
incoming
cases
and racks
Incoming
Letter
and Flat
for
BRM.
before
local
delivery
agreements
manifest"
which
This
mail
agreements.
have
then
to the customer.
with
customers
uniformity
be
manual
a holdout
Sorting
would
procedures;
requires
or
to
however,
in
for
to
BRM
also
there
the
mail
for
have
a holdout
precise
zone.
counted
have entered
established
is
no
the
Most
be manually
Some plants
and have
by
operations.
schemes
have
processed
"reverse
national
terms
into
policy
of
these
CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoing
participants
of record in this proceeding
in accordance
document
with section 12 of the Rules
of Practice.
-z/it!2-M
Michael T Tidwell
475 CEnfant Plaza West, SW
Washington, D.C. 20260-1137
September 23, 1996
upon all