,-.
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C.
20268-0001
Special
Services
Fees
and Classifications
s,Jcls
rOM~,SS,OH
pOgCLah'E
d5ECRElhRY
OFFICE OF T'E
)
Docket
No.
MC96-3
OFFICE OF THE CONSUMER ADVOCATE RESPONSE TO
MOTION OF NASHUA PHOTO AND MYSTIC COLOR LAB
TO ENLARGE SCOPE OF PROCEEDING
(July
25, 1996)
The Office
response
to
of
the
to
Classification
Advocate
Inc.
Scope
Modification
July
15,
Reply
Mail
(ERM) and
1996.
However,
choice
of
objectives.
OCA does
not
believe
filed
two
order
in
any way to
Rather,
to
months
investigate
those
OCA urges
ago,
costs
Respect
included
Nashua/Mystic
costs
the
a vehicle
that
should
in
for
to
the
the
to
file
company
achievi.ng
to
service
Postal
Business
proc:essing
OCA parte;
be subject
a special
Replly
of
instant
Service's
a proceeding
its
Consideration
Business
of
for
files
Lab Motion
an investigation
that
of
Color
Proceeding
lower
on the
in
is
alleged
regret
almost
it
of
OCA supports
the
COCA) hereby
and Mystic
with
with
Nashua/Mystic
_--.
Photo
Enlarge
Mail,
bulk.
Consumer
Nashua
(Nashua/Mystic)
of
the
BRM in
with
thei.,
proceeding,
possible
not
delay
connected
Request.
under
§ 3662
.
,-.
Docket
of
No.
title
2
MC96-3
39 to
may elect
to
air
their
structure
facts,
is
in
discounts
or
delivery
the
costs.
cost
discount
cents
mail
that,
differential
was based,
5.09
Id.
cents.
passing
Witness
through
processing
and delivery.
objections
of
Commission
concluded
the
"Willette's
cost
Thompson,
90 percent
that,
Service
processing
para.
and
para.
5077,
OCA's
of
the
12-cent
para.
of
13.4
The
5054.
avoidance
of
of
"Courtesy
mail
figure
represients
Id.
(emphasis
a 13.4-cent
on a delivery
part,
recommending
validity
operations."
calculation
in
of
proposed
Id.,
by the
a CEM shell
basic
Willette."
Id.,
Postal
of
on a cost-avoidance
and delivery
Willette's
policy
OCA's
CEM."
Commission
out
PRC Op. MC95-1,
on "the
part,
"based
processing
Witness
proposed
..-.,
in
borne
downstream
recommendation
by witness
observed
actually
avoiding
in
the
two phases.'
Commission's
with
CEM was
developed
added).
its
in
if
example,
associated
for
Commission
both
For
change,
savings
the
costs
based
classification
proceeding
with
reflect
Commission
Alternatively,
contention,
harmony
that
concerns.
this
The Nashua/Mystic
004800
cost
rate
costs
5057.
several
Envelope
avoidance
design
avoided
In
witness,
by both
spite
of
the
remains
1 The first
phase would address
the Postal
Service's
proposals;
the second would address
Nashua/Mystic's
proposal.
This was the approach
followed
in the consolidated
proceedings
Docket No. MC81-2 and Docket No. R81-1.
.---
mail
the
interveners,
Mail
of
worthy
of
e-.
Docket
of
No.
MC96-3
recommendation
Id.,
para.
that,
with
for
as a discounted
5082.
"the
Postal
the
is
at
Id.
The Commission
avoidance
over
the
The Commission
(footnote
logic
sorting
NTC's
virtually
several
costs."
witness
all
"non-transported
n.
stated
its
remarked
non-transported
it
Docket
associated
corresponding
figure
(emphasis
of
by the
added).
simi1;a.r
Telephone
in
cost
Company
the
Court
evident
Peterson
in
No.
delivery
and transportation
said
will
in
save
from
R94-1,
:para.
5075
MOAA, and as
transportation
the
testimony
Tr.
17A/8403-04,
costs
(NTC)
cases.
PRC Op. R94-1,
are
and
of
avoided
mail:"
Non-transported
mail
was defined
as
delivered
by the customer
to a post
is sorted
on premises
and placed
by
office
into
an on-premises
post box
addressee.
,_-,
avoidan#ze
and reclassification
mail
is
Mail."
was persuaded
proposed
approval
rate
"As
Indeed,
cost
as the
21
favorably
that:
First-Class
Commission
by Niagara
omnibus
of
categories
V-36,
sponsored
omitted),
dictates,
as large
subclass
at
has
proposals
last
least
Automation
Service."
the
and delivery
mail-processing
of
category
Significantly,
CEM pieces
any
004801
3
metered
mail
office
which mail
the receiving
post
for pick-up
by the
[T]o the best of my knowledge,
information,
post offices
operate
in a
numerous
to the post office
in Niagara,
including
Each post office
office
in Niagara,
WI.
mail
slot
in which local
telephone,
gas,
and belief,
manner
the post
has a local
electric
and
similar
that
by
,I-.
Docket
No.
MC96-3
4
@04802
other
companies
insert
monthly
metered
bills
which
bills
are sorted
on premises
and placed
into
on
premises
post boxes for customer
pick up.
Because
this
mail
is not transported
by the USPS and therefore
incurs
no transportation
costs
nor carrier
costs,'
and
because
this
class
of mail
is not cancelled
by the
USPS, the rate
charged
for this
service
should
be less
than the standard
first
class
rate.
Witness
for
his
Peterson
renewed
Class:
"The
three
Commission
of
serious
proposal
local
mail
a
processing
and any other
costs
be developed,
and
could
might
be amenable
Id.,
para.
that
to
Class
delivery
almost
service.
This
of
op.
para.
R87-1,
has
are
entirely
the
has
a classification
MC95-1
within
First
advanced
in
concept
para.
estimates
actually
avoided
if
No.
50137.
of
by
implementation
for
convinced
that
The
mail':Local
were
discounts
worthy
local1
only'
feasible,
it
First-Class
5089.
misgiving
evaluation
Niagara
nconcrete
recommending
costs
delivered
if
Docket
subclass
PRC Op. MC95-1,
indicated
mail"
in
mail”
which
is
consideration."
again
“local
proposal,
proceedings,
The Commission
--..-__
for
Commission
mail.
.__
was commended
Postal
long
been
unsuitable
through
for
post
was expressed
Service's
devising
average
ratses
for
office
box
in
Commission's
BRM cost
the
or
development
First-
firm
mail
holdout
in
PRC
6143:
[Ilt
is illogical
to find
that
it costs
on average
3.6
cents
to deliver
First-Class
Mail of which
approximately
50 to 60 percent
are delivered
outside
of
a postal
facility
while
it costs
3.9 cents
to deliver
a
-.-~~
.---
,-.
Docket
No.
MC96-3
piece
of
delivered
BRM mail
to lock
Nashua/Mystic's
the
to
bulk
the
scope
Nashua/Mystic's
disputes
the
have
at
hand
to
data
likely
by weeks,
resolution
the
could
expand
or
even
of
the
such
extend
over
the
resolution
were
does
Postal
Service's
that
this
not
to
actual
of
pending
does
not
case
data.
convince
the
production
of
several
weeks
could
just
seem
the
and volume
able
the
of
It
expect
an enlargement,
a period
months.
discovery
revenue,
proceeding,
appears
entertain
protracted
BRM cost,
the
to
One would
Nashua/Mystic
to
Unfortunately,
to
Service.
rates
operation,
proceeding
lead
are
discounted
downstream
instant
anticipating
if
Perforce,
extending
be investigated.
Postal
even
Commission
longer.
in
well-organized
Consequently,
would
of
not
Service,
in excess of 90 percent
are firm
holdouts.
BRM, another
request
with
Postal
of
and should
merit
expanding
of which
boxes or
interest
processing
have
804503
5
be delayed
to
request
or
postpone
fear so ltong
a
time.
In
based
but
BRM rates
with
separate
.--\
--..__-
the
for
the
caveat
that
complaint
the
alternative,
proceeding
OCA supports
conclusion,
in
two
.---~
downstream,
such
proceeding
Commission
phases.
Nashua/Mystic's
bulk
a proposal
under
may
elect
pursuit
processing
of
be considered
39 U.S.C.
to
3662.
structure
of
its
in
In
this
the
costBRM,
a
./-
Docket
No.
MC96-3
6
084894
Respectfully
submitted,
DAVID RUDERMAN
Attorney
SHELLEY S. DREIFUSS
Attorney
CERTIFICATE
I hereby
document
accordance
certify
upon
all
with
that
I have
participants
section
OF SERVICE
3.B(3)
this
date
of
record
of
the
special
SHELLEY S.
Attorney
Washington,
D.C.
July 25, 1996
,--
~.-..--
--.
20268-0001
in
served
this
the
foregoing
pro,ceeding
rules
in
'of practice.