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RECEII/E[I
BEFORE THE
POSTAL RATE COMMISSd@
16 3 z,~ p/j y7
WASHINGTON,
D.C. 20248-0001
Nwni fib’>
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‘- LLHP41&+)H
OFFIC_r
Of 7,’
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POSTAL RATE AND FEE CHANGES,
DOCKET
1997
NO. R97-1
SECOND SET OF INTERROGATORIES
OF
MAGAZINE PUBLISHERS OF AMERICA
TO USPS WITNESS ALEXANDROVICH
(MPAICTSPS-TS-2-3)
(September 16, 1997)
Pursuant
to the Commission’s
submits the attached
interrogatories
Rules of Practice,
to USPS witness
Magazine
Alexandrovich
Respectfully
Publishers
of America
(MPAAJSPS-TS-2-3).
submitted.
Magazine Publishers of America
Suite 610
1211 Connecticut
Avenue, N.W.
Washington,
D.C. 20036
(202) 296-7277
hereby
2
INTERROGATORIES
OF MAGAZINE PUBLISHERS OF .AMERlCA
TO UNITED STATES POSTAL SERVICE WITNESS ALEXANDROVICB
MPANSPS-TS-2
Please refer to Witness Baron’s responses to MPAAJSPS-T17-2
and 3, Table
I of this interrogatory, the FY 1996 Cost Segments and Components
report, ,and the BY 1996 Cost
Segments and Components
report
a.
Please confnm that Table I accurately reflects the before final adjustmems
Carrier attributable
costs to mail classes in FY 1996 and BY 1996
b.
Please contirm that the distribution
to BY 1996
c.
Please explain ti~lly why the distribution
between FY 1996 and BY 1996
d
Was there any change in the distribution
of attributable
of Rural
costs to classes of mail changed from FY 1996
of attributable
key?
distribution
Rural Carrier costs to mail classes changed
If so. please describe the change.
Table I. FY I996 and BY 1996 Attributable
Rural Carrier
#Costs
‘Attributable
Cost
BY 1996
0.3%
39.1%
Free Mail - Blind &
0.0%
0.2%
0.0%
10.4%
0.9%
4.3%
43.0%
1.8%
0.1%
100%
3
MPANSPS-TS-3,
Please refer to Docket No. R90-1, USPS-T-13,
Appedx
F, Section
This section describes the FY 1989 Rural Carrier mail shape adjustment.
This adjustment
reclassified I out of every 6 0106 letters as flats so that 2858R survey data had the same
percentages of letters and flats as the National Mail Count.
a~ Please confirm that the Postal Service made this mail shape adjustment in the current
before distributing
attributable
costs to Classes and Subclasses of mail.
111,
case
by If part a. is confirmed,
please identify
where this adjustment
is documentefd.
c.
If part a. is confirmed,
reclassified as flats.
please provide
the proportion
d.
If part a. is confirmed and the reclassified
I. please explain fully why the proportion
e.
If part a. is not confirmed, please explain fully why the Postal Service did not make the rural
carrier mail shape adjustment.
f.
If part a. is not confirmed.
please state whether there is still a discrepancy between
survey and the National Mail Count in terms of percentages of letters and flats.
of letters in Base Year 1996 that were
proportion
of letters is smaller tlhan in Docket
has decreased.
R90.
the 2858R
4
CERTIFICATE
OF SERVICE
I hereby certie that I have this date served the foregoing document upon all participants
record in this proceeding in accordance with section I2 of the rules of practice
Washington,
D C.
September 16. 1997
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of