.
ORIGINN
065143
RECEIVEU
BEFORE THE
SEp 5
POSTAL RATE COMMISSION
WASHINGTON,
D.C. 20268-0001
SPECIAL SERVICES REFORM, 1996
4 3u PH’%
p~s~~i. R!~\TECFHHlSSlO~
OFF,Ci0r THESECRETIRY
Docket
II
No. MC96-3
MOTION FOR LEAVE TO FILE BRIEF RESPONSE
TO THE NASHUA/MYSTIC
OPPOSITION
TO THE USPS MOTION TO RECONSIDER PRC ORDER NO,.
(September 5, 1996)
On August
29, 1996,
filed their Opposition
Nashua
To The USPS Motion
ensure that the Commission’s
Reconsideration
Service
Governors
approved
determine
whether
might
would
senior postal
be made.
managers
When
did not include
the appropriate
in May,
not include
Governors,
As indicated
the following
After
written
1996,
counsel
several
in Docket
intended
Business
Reply Mail, Nashua
and meetings
Nashua/Mystic
were informed
BRM in the proposal
being submitted
but that the Postal Service
in the August
23, 1996,
would
continue
Response
weeks
events
before
the
seeking
to
Reply Mail
being prepared
an overture
communication
of material
Business
that the proposal
to whom
the Postal
No. MC96-3,
to include
To
For
characterizations,
informed
officials
Motion
brief recitation
of the Request
the Postal Service
PRC Order No. 11:29.
of the Postal Service
Postal Service
the filing
in its Request.
management
.c.
contacted
Color Lab (NaghualMystic)
To Reconsider
by any incomplete
leave to submit
Nashua/Mystic
reform
resolution
is not affected
requests
Photo and Mystic
by postal
asked to be directed
to
for reconsideration
with
senior rate policy
that the Postal
for review
to explore
Of The United
Service
by the Board of
their concerns.
States
Postal
/-
AS indicated
Service
in the August
23, 1996,
Response
Of The United
To PRC Order No. 1 131, a Nashua/Mystic/USPS
established
as an adjunct
to an existing
internal
States
working
postal
Postal
group was
management
BRM task
force.
At page 19 of their Opposition,
“[flor
Postal
over a year,
Service
to them
and Mystic
to investigate
are unfair
34, which
Nashua
Nashua/Mystic
was filed on August
30, 1996,
closely
the fall of 1995.
Nashua/Mystic
This activity
seek to create
danger that the Commission
Furthermore,
possibility
contrary
independent
Business
“that
might
conflicts
that group was formed
judgment
the impression
the Nashua/Mystic
Services
docket
of investigating
have
since
that
due to the
proposal.“’
that concern
as a consequence
as to the importance
system
group was established
suggestion
in the Special
to NM/USPS-
and Nashua
BRM accounting
with
the working
consider
the
and Nashua/Mystic
The Postal Service
manifest”
to Nashua/Mystic’s
of mailer proposals
the task force,3
clearly
by the response
the Postal Service
meeting.
to test a “reverse
to persuade
claims that BRM rates being charged
As demonstrated
have had more than an occasional
been working
have each attempted
their respective
and unjust.“’
assert that
over the
led to the creation
of
of management’s
and improving
Reply Mail.
’ Nashua/Mystic
do not indicate whether “the Postal Service,” in this instance is a local
postmaster
or a senior Headquarters
manager whose responsibilities
relate to rate
policy.
* Id. at 21.
F-
’ See pages
19-20 of the Nashua/Mystic
Opposition
005145
-3At page 20 of its Opposition,
page 2 of the Postal Service’s
1131.
lead to the study
DMCS
proposal
Postal Service
task force,
decide
August
There, the Postal Service
Nashua/Mystic/USPS
working
Nashua’s
appears
23, 1996,
Nashua
merely
has sketched
acknowledged
after hearing
or attractive
preferred
Response
which
proposal
No. MC96-3.4
-- could be studied
to the
The
managernent
working
might
-- one which
although
precisely
may
that the internal
from the Nashua/Mystic/USPS
or satisfactory,
task force
do not conform
the possibility
1 on
of the
management
out in Docket
proposal
footnote
To PRC Order No.
made clear that the output
of one or more alternatives
that
to misconstrue
group and the internal
that some other alternative
meritorious
Nashua
might
not precisely
group,
be no less
conforming
to
instead
Respectfully
UNITED
submitted,
STATES
POSTAL. SERVICE
By its attorneys:
Daniel J. Foucheaux,
Jr.
475 L’Enfant Plaza West, S.W.
Washington,
D.C. 20260-l
137
(202) 268-2998;
Fax -5402
September
5, 1996
r
---_
4 Without knowing what will ultimately emerge,
whether any differences will be material.
the Postal
Service
also cannot
say
-4-
CERTIFICATE
I hereby
certify
participants
that
of record
OF SERVICE
I have this day served the foregoing
in this proceeding
of Practice.
475 L’Enfant Plaza West, S.W.
Washington,
D.C. 20260-I
137
(202) 268-2998;
Fax -5402
September 5, 1996
in accordance
document
with
section
upon all
12 of the Rules