. This docwmenthas bepn conditlo"all~ accented 89 E, late fi'lins pending consideration of accsptance. -! ! 'RECElVaj , BEFORE TEE -_ -- .. Special Services Docket Fees and Classifications) No. MC96-3 AMERICAN POSTAL WORKERSUNION, AFL-CIO INTERROGATORIES TO THE UNITED STATES POSTAL SERVICE WITNESS SUSAN W. NEEDHAM (APWU/USPS-T&3-1-45) '-, (August 12, 1996) Pursuant the Postal ~10, hereby production to sections 25 and 26 of the Rules of the Practice the American Rate Commission, submits the following of Postal Workers 'Union, AFL- interrogatories and requests for of documents. AMERICAN POSTAL WORKERSUNION, AFL-CIO BY PA p Schwartz & Anderson, O'Donnell, 1300 L Street NW, Suite 1200 Washington, D.C. 20005-4126 (202) 898-1707 P.C. ,, CERTIFICATE OF SERVICE I hereby certify that I have this date served document upon all participants of record in this accordance with the rules of practice. Washington, August 12, D.C. 1996 20005-4126 the following proceeding in -. Docket -2- MC96-3 APWU/USPS-TEI-1 that the Service Postal is Service's "best viewed viewed b. the proposal to evaluate the proposal that rates If viewed Delivery special delivery service 'dI change"? in they Special do the Delivery applied? Service policies 39 U.S.C.53621 to eliminate as a classification to evaluate the proposal rates and is ,and factors apply:? Did you What was the result of change, fees as if in they Special do the Delivery policies 39 U.S.C.53622 applied? Service is #and -Factors apply:? Did you What was the result of analysis? At page APWU/USPS-TS-2 "Special treatment basis as if the proposal related that fees Special indicate change." to eliminate change, and you analysis? c. that testimony, to eliminate to eliminate as a classification related your as a classification as a classification If viewed 116 of proposal Why is the proposal a. "best At page in for receive your and/or - delivery dispatch statement received -- mail 118 of your testimony, you is to preferential intended and trans:?ortation." that special preferential delivery treatment receive Please mail indicate <explain is intended in transportation. ~- the to Docket -3- MC96-3 At page APWU/USPS-TB-3 "Delivery that from the regular pieces in a regulations their by regular route timely that regular direct route Why is it sometime ‘yo'u requires these special manner." Please identify aw regular carriers to deliver delivery and to deviate delivery all from pieces. 45, 48, 50, 52 and 53 you refer Manual Transition source special indicate deviations to deliver or permit an appropriate testimony, schedule At footnotes Mail your carriers schedule APWU/USPS-T8-4 the Domestic 118 of What is this Book. for these have a copy of this book made a Library APWU/USPS-T8-5 At pages 119-120 document? Could footnotes? to you Reference? of your testimony, ycu state that "Once a special delivery piece reaches its destination post it is distributed to a special delivery messenger or office, carrier to route be either delivered appropriate the immediately or with the remainder of the addressee's mail." a. regular Please route identify carrier any and all to routinely regulations deliver special that delivery permit mail. a Docket -4- MC96-3 Please 5. regular route remainder identify any and all carrier to deliver of the addressee's AFWU/USPS-T8-6 regulations special delivery that permit mail with a the mail. At page 120 of your testimony, footnote 51, you ‘_ . refer to section your statement delivery 624 of that the "Any messengers Postal postal Operations Manual employee, including and postmasters, to support special may make special delivery runs. 'I Postal a. employees postal operations level Operations in duty time i.e., for special 1. by these postal specifies -- that postmasters (POAs) who are paid at on the clock" certain and the USPS employee who makes deliveries time not officially delivery 624.12 CAG H-L offices administrators and "any other Manual postai postmaster during off- -- are paid fees runs. What is the fee schedule employees? If there for special delive.ry is no fee schedule, runs how is the fee determined? Why .2. operations for the a time fee f'ee in addition spent paid to postmasters (POAs) who are paid administrators IS this level? is on the to the pay these special delivery at and the postmaster employees run? postal Are receive these .-_ Docket employees off-duty fee paid for 3. Why would time employees this -5- MC96-3 paid for spent to on the special employees in the Manual section 624.122.a? were delivered during Manual 624.122.a? section postal employees in were delivered during Manual 624.122.b? 624.122.d Special Postal Delivery 1. employed, hired pursuant Act run? (FLSA)? receive to for the Postal base year IS Is this '. I the time certain to De:Livery pay Postal to mail Operations in fees to Operations De1Liver-y mail to Postal 624.112, non-postal fees Operations to Postal of Special Manual sections in Postal Service pursuant How many pieces pay of Special the base year pursuant that delivery Service How many pieces Operations specify Postal base year the 624.122.b? b. the the base year pursuant Manual section section employees Are these run? How much did 5. ,run? :"during on the clock"? on the special pay these delivery delivery make deliveries Labor Standards How much did 4. postal spent the Fair the on the special not officially the time with addition spent a USPS employee time i.e., consistent in the time Operations 624.122.c, employees are pai.d and for runs. How many Special or used in the Delivery contract base year? messenger6 How many pieces were of Docket special delivery did Postal the messengers mail'did in the Delivery Special Delivery total costs of costs and/or the the Postal Did the Postal Delivery If expenses? expenses reimbursed for these the time contract pay they these spent on Service Did identify and provide the pay the* Postal messengers so, please costs contract Service At what rates? base year? paid for H'ow much Delivery so, how much did the Postal the Special Service to Special messengers If and/or in the base year? fees base year? runs? reimburse of their pay in contract during Service they deliver Service Special in -4 -6- MC96-3 for all any types total amounts in th-1 base or expenses year. 2. a fee for base How many highway making a Special deliver in the Delivery mail a fee? How much did Delivery runs to highway in the base contract runs ? the route If Delivery How many pieces year? so, base year? base year did they year? ca.rriers contract for of the Postal contract Did for the run for Special a fee? deliver route Delivery Service Postal how much did the Postal mail How many pieces in the base year route were paid a CAG A-G office carriers Service Service Did the Postal fees in the did of without pay in the time they spent At what rates? carriers they Special receiving for Special in CAG A-G offices pay these on Special pay in total Servicfe highway Delivery during reimburse Docket the highway ‘contract expenses? If route so, Service paid for carriers please reimbursed expenses -. -7- MC96-3 identify these costs any of their all and provide the types total or expenses How many highway 3. for costs of and/or costs and/or the Postal amounts in the base year. contract route were paid carriers .a fee for base making a Special How 'many pieces year? deliver in Delivery the mail base year did they How much did Delivery runs to highway the base contract If runs? carriers contract expenses? If expenses 'reimbursed C. paid the Service route the time for so, route please these and provide costs pursuant for Special these highway the Service types total Service Operations Delivery pay in total any of their or expenses to Postal pay Service all Special receiving they spent on Special identify they in CAG II-L offices Service for in the did of fees Did the Postal carriers mail without pay in carriers Postal How much did the Postal fee payments year? in the base year At what rates? the highway Delivery HOW many pieces so, how much did the Postal the base year? Service a fee? Postal for a CAG H-L office Special contract Did year? route for the run for of deliver a fee? in Delivery of amounts during reimburse costs and/or co:sts and/or ,the Postal in the base year. spend in Special Manual Delivery 624 in the base Docket -a- MC96-3 If d. why have does the Special anv postal there may make Special been Special Delivery Operations Manual Postal Delivery Delivery employee -_ Units Messenger Messengers direct and formalize Delivery since the runs, ISSs? Why establishment delivery rules for of Special service? 'd With reference APWU/USPS-TB-I line 12, page 122, line Once the a. there through any other routinely way for delivered If b. permit regular routine Delivery APWUIIJSPS-TB-a page 123, line please yes, expedited Messenger or her normal other after course testimony is out on his subsequently arriving than by Special identify delivery the letter testimony at: page 121, 9: carrier of delivering Your to your or her route, mail Delivery any and all other to be service? regulations by anyone other carriers matter is that has left that a Special to begin his mail. at page 122, line 11 through 1, provides: of both air mai and First ovOver time, the general upgrading Class Mail diminished the relative advantage of special 'Today. special delivery is often delivered by delivery. Therefore, carriers during the normal course of their routes. the service provided by special delivery for First-Class Mail often approaches regular First-Class Mail service, or First- Docket - MC96-3 1 -- -9- Class Mail service in conjunction with a special s'ervice such‘ as registry or certified service (or registered or certified with restricted delivery and/or return receipt service), without much of the value added of those special services, despite the premium price for special delivery." (footnote omitted) From a. "general the upgrading relative you have to that present, mail the ‘. . Class Mail statistics statement during by carriers how has diminished delivery"? any and all the supports specifically and First of special provide delivered the of both air advantage Please b. often 1968 or other that the Special normal evidence Delivery course of "is their routes." c. Does regular service delivery beginning delivery d. restricted expedited (Special Mail four by 8:OO a.m. service daily and ending provide delivery expedited trips, as late first as: midnight, on Sundays and holidays? Does registry delivery delivery Delivery) APWU/US?S-T8-9 history Class - e.g.~ up to delivery with First or certified and/or return sex-vice without service receipt (with 'or without service) payment of an call for additional fee? With respect on page 123 and Table to XXX, your Special discussion Delivery of revenue P!evenue, on Docket MC96-3 - -io- page 124: a. Does international If Table international If Table international XXX1 does not (Special XXX1 does not (Special "expres" Delivery the revenue from international Please XXXI? annually Special provide the from 1970 through With APWU/USPS-TB-10 revenue from Delivery) mail? include revenue Delivery) mail, include revenue Delive-y) Revenue annually Is Government d. history (Special "expres" C. include XXX1 "expres" b. Special Table destinating from destinating why not? mail, from destinating please from 1970 through provide the 1995 including "expres" (Special Delivery revenue included in Table Special Delivery revenue Government Delivery) nail. 1995. respect to your discussion on page 125 and Table XxX11, Special Delivery of volume 'Volumes, on page 126: a. Does international b. "expres" If international C. international Table Table Table (Special include Delivery) XXX11 does not "expres" If XXX11 (Special Delivery) XXX11 does not "expres" (Special include include Delivery) volume from destinating mail? volume mail, volume mail, from destinating why not? from destinating please provide the Docket Special the Delivery revenue Volume annually from 100% volume Table Government XxX11's Special calls, Mail, Delivery a. matter arrives documents c!. Express Mail mail from 1970 through testimony 1995. you sta:,e to special delivery, Mail, long distance the that si;ch as phone messaging." Priority calls, provide Mail delivery and service First-(Class after Mail the mail office? faxes and e-mail deliver original packages? What percentage Personal APWU/USPS-T8-12 1991 and Please First-Class expedited Can telephone Fax machines? in 19847 alternatives at the delivery and/or increase mail. volume been excluded Volume annually Mail, for Delivery) Delivery since and electronic provide b. Special Mail, Do Express routinely 75% volume At page 127 of your Priority faxes, (Special 1995 including in 1994. are many available Express the figures APWU/USPS-TS-11 "There for increase from 1970 through "expres" Why has Government e. from international What accounted d. the -ll.- MC96-3 of USPS delivery points computers? At page 128 of your testimony provides have telephone? more expeditious delivery you assert and -- is that either -Docket -12- MC96-3 equivalent in price or only marginally more expensive than $,p,&cial Delivery. HOW much would a. package cost to the furthest Is it cheaper Express Mail? Mail to send it If not, If Mail Delivery what is the point so, please pound package than Express the -. and Express Mail system? Priority Mail at which Speci,al ic is than by Delivery Mail? been done of Special provide it to any package over one pound, by Special is cheaper pound Mail? Priority for seventy How much would and processing that a copies of all mean, median Delivery mail by data and analysis. If and mode weight for why not? not, e. Special f. holiday please not true Mail? Priority that Have any studies d. mail Delivery true sent same seventy same transportation always weight? to send the not Is it c. pay to zone by Express zone by Special the Priority furthest customer b. utilize the a customer Please Delivery provide mail matter One of Special delivery. the for Delivery's special Have any studies by day of the week delivery provide each year from 1970 th:rough copies of all data features is Sunday and been done of Special and by holiday and analysis. delivery? If 1995. no't, Delivery If so, why not? Docket -11- MC96-3- When was Special APWU/USPS-TS-13 by the Postal Delivery When was the Service? last service last Special promoted Delivery, stamp issued? At APWU/USPS-TS-14 Special Delivery conclude that reliability to Special service "lags speed What formal done on the customers decreases value to of support in special the product your data you compare for Express Miil and behind with respect to statistics Mail Express showing and the the actual Delivery. analysis Delivery statement delivery testimony has the service at page Postal Service to Postal Service 130 volume have proven that is low in the minds of most customers.' of all that "Large the value Please of provide and analysis. APWU/USPS-TB-16 line Special far provide of and speed of Special your standards Please and APWU/USPS-T8-15 referring? 129 of Delivery reliability reliability 130, the and speed." actual copies page 9, of your When you use the term "expedited testimony, to what class mail" or service at page are you Docket -14- MC96-3 APWU/USPS-T8-17 done on the customers Service well all . value of to support services as Special data What formal Special your analysis‘ Delivery statement draw a recipient's Delivery service has the service Postal Service to Postal Service at page 130 that attention indicia? other to the mail Please provide and analysis. Isn't a. it reasonable has become more unique, to conclude its that as Special Postal piece as copies 1', of Delivery use draws even more attention to the mailpiece? When a uniformed b. piece of Special ' the service Delivery Postal APWU/USPS-T8-18 First-Class Class service service is no longer formal that dominate" the been isn't Messenger that the most deli.Jers a 'plersonal.ized has to offer? to your testimony has been upgraded, "upgraded" respect has the Express postal Delivery on page 131 that in what way has Fi.rst- so that "special delivery needed"? With analysis statement Service service APWU/USPS-TB-19 what mail, With respect Mail Mail Special Postal Mail market to your and in testimony Service First reliability on pag.2 131, done to Class Isupport mail and speed"? the "virtually Please Docket -lS- MC96-3 provide‘copies of all APWU/USPS-T8-20 the Postal you provide your criterion for At page 131 of your testimony to elimination full communication criterion Delivery the Is service. it that in evaluating development changes. page country 131, began or years lines to the need for means, Please of this to be g:iven 17 - 19, develop special a. To what year b. What do you mean by "advanced new equal your testimony and employ delivery are you referring advanced diminis1kad.n in this communication quote? means” in quote? Has the APWU/USPS-TB-22 Delivery If you suggest criteria. At "AS the states: for classification to the other a sixth Special rationale APWU/USPS-T8-21 this and analysis. Rate Commission consider proposal weight data market analysis any such analysis please provide APWU/USPS-TB-23 Postal Service and strategy recommendation has been performed a copy of the data Has the Postal performed or data and/or collected a Special since 1975? to do so, analysis. Service conducted a Special Docket Delivery the -16- MC96-3 market analysis Commission's copy of the data or data and/or the Commission's If please provide the pronouncements the past all specify provide a conducted following 1987 suggestion to do so? or data collected to do so, analysis. weighed of this On what findings." when it "carefully Please provide a 'Special the service data you indicate Commission's and concurs specifically weighed copies the of all past with did the Commission's susch data and of it. 1975 Special Please please recommendations and/or "carefully Service rely APWU/USPS-T8-26 in of its has been performed pronouncements"? analysis Service strategy of the viability Service any such analysis On pages 135-136 of your testimony Commission's Postal with a copy of the data Postal If to do so, Postal 3994 reiteration APWU/USPS-T8-25 that to do so? fol,lowing analysis. analysis any such analysis recommendations collected Has the APWU/USPS-TB-24 market strategy 1987 suggestion has been .performed Delivery with On Delivery page 132 of your testimony Service was a "viable what has changed to cause it you indicate special no longer that service." to be viable Docket -17- MC96-3 or capable of continuing On page 132 you quote from the Postal APWU/USPS-TEi-27 1975 analysis market delivery Mail, Urgent these products that to certain us with On page Please users "new products", and Mailgram. and provide the recommendation strategy Message Service APWU/LJSPS-TB-28 citizens. and referring mail, speculate effectiveness. of indicate all its of &oh of status. 133 of your special delivery are for assumption this Beta describe 128 and bases special including Please current Service's testimony usually you older on your part. On page 128 of your testimony APWU/USPS-T8-29 specific information customer base does not that does exist and provide on "the Please exist." on the governmental copies of all data APWU/USPS-TS-30 You refer at page 133 of your testimony. Can these non-governmental methods deliver you indicate special indicate special delivery all that delivery information cu:stomer base and analyses. to "advanced communication methods" To what methods are you referring? packages? Docket -la- MC96-3 In general, APWU/USPS-TS-31 Postal Service to classification taken for or by the Special Postal "As a rapid communications usefulness and Please a. communications could be costs have been taken attributable of Special package costs by the for 'Special C. also If of Special studies Did the Delivery Service's Service usefulness "rapid you conclude delivery with that h.as outlived more rapid and offerings." and technologically-advanced to which you are referring. Postal delivery? data, the offerings" Service Delivery's compete cannot communications Delivery Postal special vehicle, identify Was the b. of all any attributable At page 136 of your testimony technologically-advanced the actions for Service? APWU/USPS-TS-32 its per unit by the costs what What actions per unit can be taken attributable to reduce Service? to reduce unit Specifically, Service Delivery what actions per service? Postal Service Delivery reduce _ limited consider the for Postal package evaluation to letter Special Service delivery, of the "usefulness" size material, Delivery's did utility consider please or did for Special provide Icopies or analysis. Postal Service's Service include evaluation any analysis of the of ita "usefulness" usefulness Docket Global Fastnet, for please -lP- MC96-3 provide Priority copies of all Mail and Same Day Delivery? data, studies At page 136 of your testimony the "knows of no way to revitalize On what Service analyses studies, when reaching the and/or that Please Special Delivery service. studies, analyses and/or recommendation to please all APWU/USPS-T8-35 and XXX11 showing Year APWU/USPS-TS-36 relative marketplace to other Please provide annual References service". Service copies of Express other rely all such than SSR-107, Service Delivery to make the Service'? If so, References. tables Mail comparable Revenue to Tables XXX1 and Volume from market share of Express Mail 1995. Does the decreased demand for that was no way to revitalize provide Special such Library Postal this the Postal upon by the Postal eliminate 1970 through you indicate data. SSR-115 and SSR-116 relied Fiscal there Were any Library APWU/USPS-TR-34 identify data did conclusion so,.. or analysis. APWU/USPS-T8-33 Postal i If Service this type products indicate of product? a reduction of Docket MC96-3 -2o- - Has the number of letter APWU/USPS-TB-37 more than one delivery Please 1970? provide all per day increased available APWU/USPS-T8-38 Please describe a result Point the of Delivery delivery Delivery would be opt:imum office Mail be sent did in Section the Postal Service Manual if there destinating ----- in should or analyses. a letter Sequencing. letter before Mail Service consider International comply with Section is no domestic How are an since As carriere~leave the introduction of Point Sequencing, what carrier to leave the deliveries? of the APWU/'JSPS-TB-41 or decre#ased be sent Certified? Can Registered? Postal 755.3 with Point In recommending elimination APWU/USPS-Ta-40 Service for Can Express APWU/USPS-T8-39 Express time to begin Delivery than routes studies Under Delive-y Sequencing? the data, Sequencing, earlier office Point delivery --~ trip carrier Express Mail obligations; Delivery as stated How wj~ll Manual? 755.3 of the International Special Express Mail its of Special Delivery Mail Eagle the Mail Service. and Priority Network city Mail not handled Docket -21- MC96-3 differently Eagle from such mail Network Prior classifications Please Service identify Did Please explain attributes International supplying C. elimination case, Postal what special Service sought services to OI eliminate? the Postal Mail Service make a decision and de-emphasize your answer and provide Special to Delivery any related data, or studies. With respect APWU/lJSPS-T8-44 a. Mail Rate Commission case in whic'h the Postal II each such recommended decision. the use of Express analyses in an Express .. the Postal requested Service? b. to this has the APWU/USPS-TS-43 promote is destinating city? APWU/USPS-TB-42 mail that Explain costs of this Postal process by for Special Delivery Postal "Expres" a full which the Service Mail Service supplied to revenue for Mail. how the International Provide "Expres" the IISxpres" Explain to International accounting international Service Mail obtains service. of the cost/revenue service. impact of _ Docket MC96-3 -22- APWU/USPS-TB-45 expenditures and Special for Please provide 1970 through Delivery comparative 1995 for Express annual Mail, advertising Priority Mail Service. -- -- ---
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