BEFORE THE
POSTAL RATE COMMISSION
*026*-0001'RECE'VEn
WASHINGTON,
D.C.
b'jc 21
9 12 1111
'96
pos~*i RATifCUHHiSSlO~
SPECIAL
SERVICES FEES
AND CLASSIFICATIONS
HOtiOn
A.
of
Mailers
the
of
OCA's Proposed
Is Proper
and
proceeding
as
Association
Office
OCA asks
the
the
is
Postal
o~THEsECRETART
No.
WC96-3
MAJOR WAILERS ASSOCIATION'S
ANSWER
SUPPORT OF OCA's MOTION FOR EXTENSICNS
IN THE PROCEDURAL SCHEDULE AND
OTHER PROCEDURAL RELIEF
IN
WajOr
Docket
1
0~~,~~
supports
Consumer
the
August
Advocate
(OCA).
""declar[e]
that
12,
1996
Sanction
Necessary
Commission
subject
to
Service
complies
to
a day-for-day
extension
with
[these]
the
instant
un,til
such
time
request
for
Commissiion
Orders...."
In
its
July
reconsideration,
15 response
to
the
Postal
Service's
WWA stated:
In general
will
always
confrontation
rate
cases
like
Docket
No.
be under
pressure
to avoid
with
the Postal
Service
l
l
R94-1,
the Commission
resolving
the
over
this
issue.
l
No such sense
of urgency
attaches
to this
DockLet No. MC96-3
The Postal
Service's
current
revenues
exceed
proceeding.
In any
and they
will
do so for
the near
future.
its
costs,
the Postal
Service
proposes
in Docket
No. HC96-3,
event,
higher
rates
for
only
a few minor
services,
with
minimal
In these
circumstance,
the Commission
will
revenue
impact.
be free
to extend
the 10 month
time
period--as;
Section
3624(c)(2)
contemplates--if
the Postal
Service!
"unreasonably
delay[s]
consideration
of [its]
request...by
failing
to
respond
within
a reasonable
time
to [a]
lawful
order
of the
Commission..
.'I (39 USC 53624(c)
(2)).
-..I
This
Docket
thus
presents
the
1
Commission
with
a,*ra,re
;:
i
WCKFFf7
AUh2 1,1996
opportunity
should
seize
These
B.
same
its
is
refusal
Service
August
In
(Statement,
would
require
single
the
costing
Service
preferred
to
methodology.
provide
the
preferred
new
is
The
information
in
is
system
in
the
those
in
position
wrong."
The
exhibits
using
did
not
arguments.
only
the
asserting
Orders
that
asked
the
Commission
the
did
the
Service
for
the
the
Service
Service's
not
Service's
order
substitution
to
the
2
Commission's
its
Commission
addition
Although
August
mistaken
Commission
in
its
justify
WWA.)
"abandon
its
to
Orders.
in
with
information
request.
attempt
fallacies
to
The
exhibits.
provide
the
Service
withdraw
OCA's
Service's
refusals
compliance
Service
Commission
the
To Obey The
lgUnreasonablell
ABA and
Postal
that
the
subclass
order
to
4)
its
of
of
Commission's
WWA exposed
the
p.
the
and
grant
Postal
excuse
13 Comments
addition,
the
with
to
ABA and
support
to
comply
principles,
Refusal
Order
Is
no merit
attempted
Statement,
(See
Service's
Lawful
to
its
considerations
The Postal
Commission's
There
to vindicate
it.
Service's
to
already-provided
information.
Obeying
Service's
of
the
to
Orders
champion
Commission-approved
of
reviewing
Service's
When
,I--
Commission
ability
comparison
any
the
the
court
two
will
its
not
preferred
methodologies'
make
the
the
intelligent
in
place
a side-by-side
effects,
an
from
methodology
With
methodology.
--can
detract
Commission--and
appraisal
of
the
claims.
the
Postal
Service
asks
established
allocation
method,
information
allowing
a comparison
the
it
Commission
should
between
2
to
be willinq
the
financial
abandon
to
an
supply
impact
Of
(1)
-
its
This
new
technique
concept
is
Regulations
codified,
for
the
which
(1991)),
and
Public
(2)
the
Commission-established
for
example,
Service
in
the
method.
D.C.
Commission
(15
Municipal
DCWR 5200.2
provide:
Whenever,
in a rate
change
application,
a party
proposes
to change
the ratemaking
principles
adopted
in
its
most recent
rate
case,
the party
shall
also
file
with
its
5200.1
filing
[an application
for
changed
rates]
a statement
describing
each proposed
change
in
the ratemaking
principles
adopted
by the Commission
in
showing
the applicant's
last
general
rate
proceeding,
the effect
request
if
of each
no such
such change upon the applicant's
changes
were made.
(Emphasis
supplied.)
In
this
proceeding,
do no more
than
require
reasonable
within
THEREFORE,
requested
by
the
Docket
full
30396-3,
this
disclosure
meaning
of
WMA requests
and
Section
the
Commission's
are,
3624(c)
Commission
to
Orders
therefore,
(2).
grant
the
relief
OCA.
Respectfully
submitted,
(?iiik&60
Nineteenth
St.
N.W.
Suite
400
Washington,
DC 20036
(202)
466-8260
Phone:
counsel
August
21,
I hereby
document
upon
by First-Class
21,
OF SERVICE
certify
that
the U.S.
Mail.
I
have
this
1996
3
-.-
WWA
1996
CERTIFICATE
August
for
day served
the foregoing
nd upon the other
parties