BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON,
D.C. 20268-0001
RECEIVEII
h
\
Docket
11
‘i WI f’bl ‘96
No. MC96-.3
TES POSTAL SERVICE INTERROGATORIES
AND REQUESTS FOR
OF DOCUMENTS
TO MAJOR MAILERS ASSOCIATION
WITNESS
BENTLEY (lJSPS/MMA-1-22)
Pursuant
to rul
25 and 26 of the Rules of Practice
States
following
and Procedure
Postal Service
directs
of documents
interrogatories
Respectfully
UNITED
ancl rule 2
the
to Major
submitted,
STATES POSTAL SERVlC:E
By its attorneys:
Ghief Counsel,
I hereby certify
participants
of record
of Practice.
Ratemaking
that I have this day served the fo&going
doscument upon all
in this proceeding in accordance wim, section 12 of the Rules
‘z
+
‘-\
% gf$dJ
Susan M. Duchek
475 L’Enfant Plaza West, SW.
Washington,
D.C. 20260-l
137
(202) 268-2990;
Fax -5402
October 11, 1996
\
,,,.,.--,,I.
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON,
D.C. 20268-0001
R@J, JH’~
bcl 16
,55q
~fib,'-y;H,,E?a*
F$cpEOFT"L
SPECIAL SERVICES REFORM, 1996
Docket
I
No. MC96-3
UNITED STATES POSTAL SERVICE INTERROGATORIES
AND REQUESTS FOR
PRODUCTION
OF: DOCUMENTS
TO MAJOR MAILERS ASSOCIATION
WITNESS
BENTLEY (USPS/MMA-l-15)
Pursuant
to rules 25 and 26 of the Rules of Practice
2 of the Special
following
Mailers
Rules of Practice,
interrogatories
Association
the United
and requests
witness
Bentley:
States
for production
and Procedure
and rule
Postal Service
directs
the
of documents
to Major
(USPS/MMA-l-15).
Respectfully
UNITED
submitted,
STATES POSTAI- SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
j4cLd7%aa
Susan M. Duchek
CERTIFICATE
I hereby certify
participants
of record
of Practice.
OF SERVICE
that I have this day served the foregoing document
upon all
in this proceeding in accordance with section 12 of the Rules
&dL-
2-77.&&d
Susan M. Duchek
475 CEnfant Plaza West, SW.
Washington,
D.C. 20260-l
137
(202) 268-2990;
Fax -5402
October 11, 1996
USPWMMA-1.
a.
Please provide
a list of the current
members
of the Major Mailers
Association.
b.
Please identify
Association’s
C.
Mailers
which
members
are sponsoring
Major
are sponsoring
your
Mailers
in this docket.
of those
members
in this docket.
Please supply
Association’s
of those
intervention
Please identify
testimony
USPWMMA-2.
which
all information
members
and statistics
use of the following
special
concerning
services
Major
or categories
of mail:
a.
post office
boxes;
b.
certified
C.
return
receipts;
d.
return
receipts
e.
insured
f.
postal
9.
registered
mail;
for merchandise;
mail;
cards;
and
mail.
USPSIMMA-3.
a.
Please confirm
classification,
that Major Mailers
rate, or fee proposals
Association
for:
is not Imaking any
.
.
-3i.
post office
ii.
certified
111.
return
receipts;
iv.
return
receipts
V.
insured
vi.
postal
vii.
registered
detail what
USPWMMA-4.
mail;
cards; and
mail.
a.
without
the Postal Service’s
disclosing
information
methodology
If not, please explain
proposal
showing
to establish
new rates and
the consequences
city carrier
of your
of using
(delivery costs.”
to reject each of the Postal Service’s
in detail what
you are proposing
that the
do.
you indicate
this case on a record that shows
city delivery
costs
in
is making.
you state that the purpose
for attributing
At page 2 of your testimony,
not “decide
Association
(a), please explain
in this docket?
Commission
USPS/MMA-5.
Major Mailers
Are you asking the Commission
proposals
b.
any part of subpart
At page 1 of your testimony,
the Commission-approved
apportioning
for merchandise;
proposal(s)
“is to oppose
classifications
should
mail;
If you are unable to confirm
b.
testimony
boxes;
that the Commission
the consequences
only by use of a nonapproved
costing
of
.
.
-4methodology.”
If the Postal Service
Commission’s
methodology
consequences
of apportioning
had provided
in a library
reference,
city delivery
Please explain
USPS/MMA-6.
At page 2 of your testimony,
apportions
methods
should
costs
the record then show
for one set of services
services
other specific
postal
b.
To what
other specific
cases are you referring?
C.
Please explain
costs
in Docket
explanation,
which
services
costs
please specify
Please explain
e.
When you speak of a significant
specify
different
attributable
your
and component
in
occur.
you consider
difference,
percentage
upper and lower bounds
significant.
In giving
each cost segment
d.
dollar differences,
has apportioned
on Reconsideration.
differences
in detail what
the Postal Service
in this case that is significantly
the Commission
No. R94-1
such significant
absolute
are you referring?
in detail each way in which
from each way in which
from the
in other cases.”
To what
attributable
in one case that
differen-t
a.
apportions
the
you state “I do not believe that the
in ways that are significantly
used for other postal
using the
in detail.
use a methodology
attributable
would
costs
costs under the Commission’s
methodology?
Commission
FY 1995
a significant
are you referring
differences,
for what
difference.
or both?
you consider
to be
to
Please
-5USPSMMA-7.
On page 2, lines 14-l 5 of your testimony,
Postal Service’s
use of its methodology
rates significantly
in this proceeding.
a.
Have you performed
Service’s
proposals
you indiicate
“may not impact
that the
the Service’s
proposed
.”
any analysis
of the impact
in this docket
on the Postal
of using the Commiission’s
methodology?
b.
If so, please provide
spreadsheets,
C.
USPS-MMA-8.
Commission
that analysis,
workpapers,
including
all supporrting
and other related
documents.
If not, why not?
On page 2, lines 16-l 7 of your testimony,
should
use “consistent
cost allocation
you indicate
methodologies
that the
in all of its rate
proceedings.”
a.
Is it your testimony,
methodology
in this case (PRC-LR-1
recommended
Remand,
explain
b.
decisions
R94-1
(initial),
in Docket
and R94-1
cost allocation
and 2) is “consistent”
Nos. R90-1
(initiah,
with
R90-1
on Reconsideratian?
its
on
Please
in detail.
Is it your testimony,
that the Commission’s
methodologies
in its recommended
(initial:),
on Remand,
R90-1
Reconsideration
--
that the Commission’s
R94-1
are “consistent”?
cost allocation
decisions
(initial),
in Docket
and R94-1
Please explain
Nos. R90-1
on
in detail.
-6C.
Why do you believe that the Commission
allocation
d.
allows
USPSJMMA-9.
of improved
costing
in detail how use of consistent
for correction
What
cost
cost methodologies
methodologies.
cost methodologies
of errors.
On page 2, line 18, of your testimony,
Commission-approved
a.
in detail how use of consistent
for consideration
Please explain
e.
use consistent
methodologies?
Please explain
allows
should
you refer tcl “the
cost methodology.”
is the Commission-approved
cost methodology’?
Please explain
in detail.
Is it the cost methodology
b.
recommended
decision
Please explain
in detail.
Is it the cost methodology
C.
Please explain
docket?
USPSMMA-10.
“should
approved
in Docket
Please explain
to provide
cost apportionment.”
--
on Reconsideration?
used by the Commission
in this docket?
used by the Commission
in some other
in detail.
On page 3 of your testimony
require the Service
No. R94-1
in its
in detail.
Is it the cost methodology
d.
used by the Commission
--
you state that the Commission
the information
using the Cmommission’s
-7a.
Do you believe the Commission
Service
b.
If so, why do you believe this should
USPS/MMA-1
First-Class
I.
affect
methodology
in detail
how the specific
“revenue
On page 4, lines 18-20
burden”
“revenue
burden”
Postal Service
of First-Class
as applied
to the Postal Service’s
on the record
Would
of your testimony,
to have access to calculations
by a Postal Service
it be “helpful
Commission’s
b.
in detail.
of
Mail is at issue in this docket.
the respective
have been helpful
a.
in light of PRC-LR-1
proposals
Mail and
Mail.
USPSJMMA-13.
presented
be required
in detail how the respective
Please explain
in this docket
would
Please explain
Please explain
Mail and Standard
USPSMMA-12.
require this of the Postal
in this docket?
and PRC-LR-2?
Standard
should
of the Commission’s
base year and test year costs,
to have access to calculations
methodology
of the
as applied to the Postal Service’s
presented
witness?
in detail.
Please explain
“it
witness.”
year and test year costs,
on the record
Is it your belief that the Postal Service
the “calculations
you state that
of the Commission
has a better
methodology”
base
by” a Commission
understanding
than the
of
-aCommission
or its staff?
If so, please explain
in detail
all bases for
witness
in presenting
your belief.
c.
What
would
be the role of the Postal Service
“calculations
of the Commission’s
as applied
Postal Service’s
base year and test year costs?”
Service
be expected
witness
calculations
underlying
Postal Service
theories
Service
underlying
witness
witness,
witness
to replicate
has disclosed
the
of the
Would
the Postal
the Commission’s
or provided
in detail.
all data and information
methodology,
position
such as you, to present
to the validity
Please explain
the Commission
be in a better
Would
methodology?
any errors?
of the
methodology?
to attest
to the
WoLrld the Postal
to the accuracy
the Commission’s
including
needed to replicate
Service
be expected
be expected
If the Postal Service
to attest
the Commission
witness
methodology,
d.
methodology
why would
than any othelr
the Commission’s
a Postal
intervenor
methodology
on
the record?
USPS/MMA-14.
Service
On page 4, lines 3-4 of your testimony,
has failed to incorporate
Service’s
Cost and Revenue Analysis(CRA)
classification
a.
the Commission’s
proceedings
Reports
you state, “The Postal
R90-1
methodology
or its filings
into the
in other rate and
before the Commission.”
Is it your testimony
that the Commission’s
R90-1
methodology
is the
-9approved
should
b.
Commission
Commission’s
initial
(59.2
for Classroom
Publications
b.
that those
cost coverages
RPW revenues
and FY 1995
explain
percent
2.6 attributable
No. R90-1
your present
costs
Piece
using FY 1995
from PRC-LR-2.
in detail.
for Classroom
cost).
FY 1995
Publications
cost
($10.3
If you do not confirm,
please
in detail.
coverages
that
of 59.3
revenue/S256.7
USPS-T-5C, page 1 shows
percent
attributable
for Third-Class
cost).
FY 1995
cost
Single Piece ($152.3
If you do not confirm,
please
in detail.
Please confirm
coverages
that USPS-T5C,
of 83.8
percent
page 1 shows
for Library
or
cost
Single
were derived
that USPS-T-5C, page 1 shows
of 81.8
Please confirm
explain
attributable
in the
No. lR90-l?
Third-Class
Please confirm
revenue/S1
d.
(81 .l percent),
percent).
Please confirm
in Docket
of your testimony,
please explain
reflected
in Docket
Rate (83.8
coverages
C.
decision
and Library
do not confirm,
in detail.
methodology
on remand
On page 6, lines 14-17
percent),
a.
recommended
decision
that the Postal Service
Please explain
to the Commission
the recommended
coverages
methodology
have used in this docket?
Are you referring
USPS/MMA-15.
costing
FY 1995
Rate ($46.7
cost
revenueE55.7
If you
-lOattributable
e.
cost).
Please confirm
that the Postal Service’s
No. R94-1
(Exhibit
Third-Class
Single
the attributable
If you do not confirm,
USPS-T-7X,
projected
Rate “were
If you do not confirm,
in detail.
revenues
page 2) for Classroom
Piece, and Library
costs.”
please explain
in Docket
Publications,
sufficient
to cover
please explain
in detail.