ORIGINAL
RECEIVED
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, DC 20268-000~
Special
Services
Fees
pOSTnL
ji,tTECO!y':3N
OFF,CE
or iHE SrtF:LT-~~
and Classifications)
Docket
No.
MC96-,3
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES TO UNITED STATES POSTAL SERVICE
WITNESS SUSAN W. NEEDHAM
(OCA/USPS-T8-44-53)
(August
9, 1996)
Pursuant
,-
the
Postal
hereby
Rate
submits
documents.
the
to
United
incorporated
sections
Commission,
25 and 26 of
the
interrogatories
Instructions
States
Postal
the
Office
of
Rules
the
and requests
included
with
Service
dated
of
Practice
Consumer
for
production
19,
1996,
by reference
Respectfully
submitted,
sQ&dG
GAIL WILLETTE
Director
Office
of the
Consumer
SHELLEY DREIFUSS
Attorney
,-..
Advocate
OCA Interrogatories
June
Advocate
of
of
l-4
are
hereby
to
Docket
No.
MC96-3
2
,,-.
OCA/USPS-T8-44.
which
you
Please
refer
to
in
provide
answer
a copy
to
of
the
Methods
OCA/USPS-T8-23
Handbook
as a Library
Reference.
OCA/USPS-T8-45.
The
Please
"ninety-eight
refer
percent
was a reference
to
of
to
your
regular
non-merchandise
answer
to
return
return
OCA/USPS-T8-26.
receipt
customers”
receipts.
There
you
state:
Notwithstanding,
that
customers
presently
do not make
relatively
high use of this
option
[receiving
the delivery
address1
does not imply
that
they will
not receive
better
service,
or services
they do not need or want.
The return
receipt
proposal
would provide
address
confirmation
to all
return
receipt
customers
and represents
a value-added
enhancement
to the basic
service.
In any event,
if given
the option
between
a pure fee increase
or a fee increase
with
a value-added
service
enhancement,
I am confident
that
customers
would choose the latter.
,-.
a)
It
is
this
the
not
clear
case:
how one receives
a customer
return
receipt
overwhelmingly
proposes
,.---.
to
for
chooses
provide
chosen
not
to
Please
try
again
service
at
and not
the
to
present
not
to.
primarily
fee
Now the
information,
explain
him
an address
of
$.40
Postal
which
how this
a fee
enhancement
can obtain
an additional
and charge
receive,
a service
the
the
increase.
on
but
Service
customer
additional
constitutes
in
has
$.40.
better
Docket
No.
MC96-3
3
/-"Hasn't
b)
the
customer
"value-added
c)
already
service
Please
explain.
Please
explain
essentially
enhancement"
why a customer
product,"
such
compelled
to
as return
purchase
voted
by not
who is
receipt
purchasing
purchasing
service,
an added
against
service
it?
a "premium
should
such
the
be
as address
correction.
OCA/USPS-T8-46.
product
Could
offered
when
mailer
for
his
a "premium
a fee
piece
that
of
mail
product"
provides
is
be'defined
ancillary
entered
into
as a
benefits
the
to
a
in
mailstream
,Y-.
any
of
the
provide
Periodical
First,
your
definition
OCA/USPS-T0-47.
Please
the
PILease
explain
different"
is
increase
how you
in
fees
/--
your
response
in
the
to
determined
you
refer
not,
please
product."
your
response
that
to
providing
to
the
OCAIUSPS-T8-17.
the
service
"address
to
if
justify
propose.
to
affirmative.
do not
If
classes?
enhancement
that
Please
Standard
a "premium
refer
a sufficient
OCA/USPS-T&48.
You answer
of
or
make specific
your
answer
However,
the
reference
to
OCA/USPS-T8-28.
citations
to
the
given
selling,
in
Docket
No.
MC96-3
4
,<-shipping
and manufacturing
citations
specific
to
OCA/USPS-T&49.
analysis
of
costs
these
pricing
postal
cards.
Please
provide
costs.
The following
the
of
interrogatories
criteria
in
your
relate
testimony
to
at
the
pages
108-
113.
a)
USPS-T-SC
at
shows
per--piece
the
the
page
per-piece
produce
10
cost
If
Year
Cost
revenue
for
postal
cards
Please
confirm
as $0.075.
an implicit
(19.7/7.5).
(Base
cost
you
coverage
and Revenue
of
to
as $0.197
that
263% for
are
unable
confirm,
that
the
GPO manufacturing
page
106 of
Analysis)
and
these
postal
please
cards
explain
/--why.
b)
Please
cards
confirm
shown
$4,352,568
at
for
attributable
5C at
FY 1995)
costs
page
1.
If
are
for
you
your
postal
are
costs
testimony
a subset
cards
unable
of
postal
(specifically
the
shown
to
for
total
at
confirm,
Exhibit
please
USPS-Texplain
why.
C)
Please
confirm
postal
cards
would
/-
to
that
without
be 309 percent
confirm
please
the
the
FY 1995
implicit
proposed
(19.7/(7.5-1.175)).
explain.
2-cent
cost
coverage
stamped
If
you
for
card
fee
are
unable
Docket
d)
No.
MC96-3
Were you
aware
proposed
the
attendant
taken
e)
into
of
the
Act.
If
you
were
not
would
not
for
Request,
please
regarding
the
and
OCA/USPS-T8-51.
cards
manufacturing
pay
does
are
unable
cover
to
cards
explain
pricing
Cards
aware
of
are
costs.
Please
at
not
attributable
please
stamped
would
remain
the
would
the
Please
page
your
bearing
that
the
manufacturing
explain
please
in
and your
your
why.
the
testimony
errata.
Postal
110 of
confirm
criteria
a new special
explain
directly
was
same as in
change
category
its
cards.
above
and provide
for
and
pricirg
account
for
when you
how it
above,
into
a fee
rate
Subclass?
the
abov'e
cards
the
of
it
proposal
the
currently
confirm,
explain
how you
your
You state
their
please
criteria
eliminate
Post
stamped
aware
for
a-c
of
now take
stamped
in
considered
previously
Would
cards,
so,
when you
If
proposal
If
previously
how you
were
contained
service
fee?
a proposal
you
facts
new special
formulating
stamped
postal
the
account
OCA/USPS-T8-50.
Postal
of
2-cent
explain
f)
5
service,
Cards
from
the
why or
why not.
testimony
that
their
rate
postal
costs.
cards
If
you
Docket
No.
6
MC96-3
OCA/USPS-T8-52.
What
OCA/USPS-T0-53.
In
witness
Patelunas
problem
is
without
the
a)
Is
this
b)
If
you
between
Postal
citation.
percent
answer
to
in
this
are
you
not
postal
Service
cards
interrogatory
is
presorted?
OCS/USPS-T5-11
to
the
simply
case:
postal-private
what
postal
"A remedy
states:
proposed
of
misidentification
treat
cards
:as cards
distinction."
are
proposing?
proposing
to
and private
witness
does
Please
eliminate
cards,
explain.
all
please
and provide
distinctions
indicate
which
an appropriate
Docket
No.
MC96-3
. ,--,
CERTIFICATE
I hereby
document
accordance
upon
certify
all
with
that
I have
participants
section
3.B(3)
OF SERVICE
this
date
of
record
of
the
in
served
this
special
SHELLEY DREIFUSS
Attorney
Washington,
DC
August
9;1996
./-
20268-0001
the
foregoing
proceading
rules
of
in
practice.