RECEIVEO
BEFORE THE
POSTAL RATE COMMISSION
20268~ooo1
WASHINGTON, D.C.
AN 12
2 20 PH ‘96
POSTAL NATE cOHHISSION
CJFF,CE oi THE SECRETARY
Special
Services
Fees
and Classifications
)
Docket
No.
MC96-3
OFFICE OF THE CONSUMER ADVOCATE MOTION UNDER
39 U.S.C.
53624(c)
(2) FOR DAY-FOR-DAY EXTENSIONS IN THE
PROCEDURAL SCHEDULE AND THE TEN-MONTH DECISIONAL DEADLINE
(August
12, 1996)
The Office
the
Commission
U.S.C.
§3624(c)
subject
to
Service
complies
1126,
July
T-SA-5J)
the
the
issue
Consumer
a day-for-day
19,
with
Commission's
the
carrier
access
by the
Statement
No.
announces
directives
1126,
the
that
extension
by filing
the
August
Postal
by the
2,
1120,
June
3.8, 1996,
Exhibit
Service's
Commission
CRA (namely
C that
attribution
for
such
(Postal
submit
are
Postal
and
USPS-
based
upon
methodologies,
for
decision
to
the
39
is
Orders
States
1996,
proceeding
as the
of
that
under
time
methodology
United
authority
instant
versions
The need
costs.
its
such
cost
Commission's
to
moves
until
USPS-T-1
established
of
the
Commission
1996,
COCA) hereby
pursuant
declaring
(2),
Advocate
an order,
and a conforming
including
Order
of
attributing
a remedy
Postal
city
is
Service
occasioned
Concerning
Service
Statement)
to
two
defy
which
unequivocal
a CRA incorporating
the
./-?-y--..~
i~,!i;lr qe,:‘I.,“,.
.',
,,
,~
"If ;
Docket
.I-.
No.
MC96-3
Commission's
of
city
2
methodology
carrier
Order
for
access
No.
1120
determining
the
level
of
attribution
costs.
plainly
declares:
1.
The Postal
Service
is to provide
versions
of USPST-SA-J
that
comport
with
Commission
cost attribution
methodology
from R94-1.
2.
The Postal
Service
is to provide
a version
of
witness
Lyon's
(USPS-T-11
Exhibit
C that
reflects
the
Commission
cost attribution
methodology.
On June
28,
1996,
Reconsideration
No.
1126
from
of
directed
1120
to
on or
before
Order
the
Commission's
role
Order
from
Nat'1
U.S.
810,
No.
Assoc.
833
1 Postal
1120,
Service's
No.
1120
presentations
August
5,
Service's
signals
under
1120
of
(1983),
Service
two
a marked
the
at
Postal
11,
Greeting
defining
Statement
the
Card
the
at
lack
to
of
them
specified
in
couched
is
Order
as a
directives,
comply
with
respect
for
Reorganization
Commission
Publishers
Commission's
5.
be excused
Service
explicit
refusal
to
Order
Postal
Although
follow
for
Response.
arguments
"The
cost
1996."
a Motion
and rejected
the
to
filed
and Partial
that:
Postal
orders
Service
ordering
declination1
Commission
,.I-.
Postal
provide
view,
In
the
finally
respectful
OCA's
No.
with
categorically,
Postal
Order
considered
complying
the
in
lawful
the
Act.
quotes
v.
a passage
U.S.P.S,
role:
462
No.
Docket
,--
No.
MC963
!I@4865
3
[Al11 costs
that
in the judgment
of the Rate Commission
are the consequence
of providing
a particular
class
of
service
must be borne by that
class.
The statute
requires
attribution
of any cost for which the source
can be identified,
but leaves
it to the Commissioners,
in the first
instance,
to decide
which methods
provide
reasonable
assurance
that
costs
are the result
of
providing
one class
of service.
Perforce
it
is
the
final
the
cost-causation
outright
but
the
selection
Order
rate
of
not
a costing
principles
defiance
of
the
Postal
Service,
methodology
of
Commission
the
Act.
orders
that
that
best
The Postal
is
not
only
39 charges
the
makes
promotes
Service's
disrespectful,
unlawful.
Subsection
with
Commission,
3622(b)
recommending
NO. 1126
increases
can
only
all
subclasses
at
(1)
of
fair
and equitable
6-7,
the
for
fairness
selected
be evaluated
and
special
by comparing
special
to
be made between
Commission
in
Docket
rates
in
No.
Docket
methodology
must
be used.
attribution
methodology
R94-1
No.
cost
and equity
services
relative
MC96-3,
be the
in
cost
coverages
OCA submits
must
of
Furthermore,
and those
the
Commission
As exp:Lained
rates.
services.
comparison
proposed
title
the
:in
proposed
Docket
No.
coverages
Ear
among
a
established
resulting
MC96-3
from
by the
the
same attri:bution
that
the
Commission's,
comlmon
n'ot
the
Postal
Service's.
,.I-,
~
Docket
,,-.
No.
MC96-3
A latent
furnish
the
coverages.
4
irony
tools
is
present
needed
to
The Postal
setting
rates
Postal
Service
based
the
compare
Service
upon
witness
in
has
MC963
long
Ramsey pricing
Schmalansee
Postal
Service's
refusal
and R94-1
favored
the
cost
policy
of
For
example,
techniques.
testified
in
Docket
No.
that:
In a world
where information
expensive,
one might
want
Ramsey prices
lie or the
between
Ramsey prices
and
might
be a sufficient
and
making.
Tr.
33/15083.
pricing
In
witness,
the
Grady
is difficult
and
to know the region
where
direction
of differences
alternative
prices,
and that
rational
ground
for decision-
the
same vein,
Foster,
Postal
Service's
R94-:L
testified:
Economic
value
of service,
as measured
by relative
elasticities
of demand, can be used in a quantitative
way through
the application
of Ramsey pricing
models.
Though Ramsey pricing
is not used in a formal
sense to
determine
the rates
proposed
here,
the cost coverages
for First-Class
Mail
letters
and third-class
bulk
regular
rate mail which result
from across-the-board
rate
increases
are more in accord
with Ramsey pricing
principles
than were the cost coverages
in recent
Commission
recommended
decisions.
The need to move in
this
direction
was a central
theme in a 1992 GAO
"U.S.
Postal
Service:
Pricing
Postal
report,
entitled
Services
in a Competitive
Environment."
Moving price
relationships
in a direction
which focuses
on economic
value
of service
places
greater
emphasis
on customer
perceptions
than had previously
been the case.
Docket
NO. R94-1,
USPS-T-11
at
19
(footnote
omitted).
to
MC95-1
Docket
No.
MC96-3
The goal
I-
principles,
of
establishing
which
be accomplished
to
one
if
in
instant
cost
the
coverages
in
The R94-1
costing
methodologies,
the
comparison
of
all
other
section
to
Order
modifications
this
all
the
apply
of
the
for
of
280 were
Postal
cost
the
(coverages
from
Commission's
In order
to
an apples-to-apples
special
postal
to
delay
imposed
Postal
parcel
"numerous"
Service's
special
the
Service's.
In Order
of
upon
access
services
and
be made.
since
39.
only
relation
have
other
affected
must
must
selected
own goal,
can
(simultaneous
for
based
Postal
Commission
reclassification
the
has
are
cause
title
delays
in
it
Ramsey
in
principle
rates
that
with
advocated,
Commission
proposed
the
long
this
the
decades
sufficient
No.
set
Service's
the
(2)
unreasonable
to
simultaneously,
to
coverages
in
MC78-1,
for
are
and services
found
No.
request
rise
cost
3624(c)
Docket
not
accordance
has
coverages
Postal
once
Commission
the
in
Service
docket,
cost
classes
Only
order
same format
R94-1.
effectuate
rates
for
the
prices
Postal
all
In
services
,--.
the
another.'
markups)
to
5
a proceeding
unlzler
280,
IYay 18,
a 151-day
post.
direct
has
No.
Service
and
reorganization
in
the
1979,
extension
pro,secutinsg
The e~vents
due
its
giving
"inconvenient"
case,
including
the
the Service
is not espousing
Ramsey pricing
in
2 Obviously,
this
would be a general
rate
case,
with
If it were,
docket.
the OCA has always
opposed
Of course,
rates
being
adjusted.
Postal
Service's
approach
to demand pricing.
Docket
No.
MC96-3
substitution
Postal
of
Service
new testimonies
caused
serious
procedural
schedule
and
new testimonies
filing
these
actions
witnesses.
far
more
004868
6
and witnesses.
delays
by withdrawing
were
to
due to
The Postal
egregious.
Its
portions
their
unavoidable
of
its
of
The
the
direct
case
However,
difficulties
in
12.
in
place.
conduct
defiance
at
and disruptions
take
Service's
Id.
all
of
with
the
instant
Commission
orders
case
is
is
willful
and deliberate.
In
that
all
month
conclusion,
dates
in
decisional
between
August
complies
with
pursuant
the
1996,
Orders
39 U.S.C.
53624(c)
(2),
schedule
as well
as the
procedural
deadline
5,
to
be extended
and the
1120
and
date
by the
number
of
on which
the
Postal
1126.
Respectfully
submitted,
SHELLEY S. DREIFUSS
Attorney
u
OCA moves
tendays
Service
004869
CERTIFICATE
I hereby
document
upon
accordance
certify
all
with
that
I have
participants
section
OF SERVICE
3.B(3)
this
date
of
record
of
the
in
special
served
this
SHELLEY S. DREIFLJSS
Attorney
D.C.
1996
20268-0001
foregoing
proceeding
rules
#g&7&/ $.aqd
Washington,
August
12,
the
of
in
practice.