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BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
POSTAL RATE AND FEE CHANGES, 2000
Docket
No. R2000-1
INITIAL BRIEF OF PITNEY BOWES INC.
Communications
regarding this document
should be served on
Ian D. Volner
N. Frank Wiggins
Venable, Baetjer, Howard & Civiletti, LLP
1201 New York Avenue, N.W.
Suite 1000
Washington, DC 200053917
Dated:
September
13, 2000
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
POSTAL RATE AND FEE CHANGES, 2000
Docket
No. R2000-1
INITIAL BRIEF OF PITNEY BOWES INC.
Under the current First-Class
technology
unfairly and improperly
and distribution
single-piece
rate design, users of metering
bear costs associated
with the manufacture
of stamps that they do not cause the Postal Service to incur.
To
redress this manifest inequity, Pitney Bowes Inc. (“Pitney Bowes”) has proposed
a discount of one cent applicable
the
First-Class/First-Ounce
Discount”).
The discount
businesses
and residential
to mailers who use metering technology
single-piece
rate
(the
“Metering
Technology
would further provide stamp users -- especially
mailers
-- with an incentive
efficient and less costly postage evidencing technology.
Discount
are fully met, as Pitney Bowes will show in this Initial Brief.
discount.
for the Metering
show that there are no valid objections
We urge the Commission
to recommend
it.
small
to more
The Postal Service itself
that the theoretic
will further
and factual predicates
to migrate
concedes
Bowes
to pay
Technology
Pitney
to the proposed
TABLE OF CONTENTS
Summary of Position
.
The Metering Technology
Discount.
Argument...............................................
A.
The Legal and Factual Predicates for the Metering
Technology Discount are Fully Satisfied
B.
The Postal Service’s Opposition to the Metering
Technology Discount is Based Upon Claims that
Are Hypothetical and Otherwise Without Merit.
1.
2.
C.
Conclusion
The Claim that Recommendation of a
Metering Technology Discount Will Open
the Floodgates to the Same Discount in
Other Classes and Rate Categories
Is Without Basis.
The Postal Service’s Claim that there
Will Be No Migration of First-Class Mail
Stamp Users to Metering Technology is
Without Merit
The Small Net Reduction in Revenue the Postal
Service Will Experience from the Metering
Technology Discount Can Readily be Absorbed
Without Unreasonably Burdening Other Mailers
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .._._.
7
7
10
14
17
SUMMARY
OF POSITION
It is a basic principle of law and postal policy that activities mailers perform
which enable the Postal Service to avoid and reduce costs should be reflected in
the rates those mailers are required to pay. The use of metering technology
affix First-Class
single-piece
the Postal Service.
mailers now pay.
postage produces clear and measurable
savings to
Those savings are not, however, reflected in the rates those
Under the Metering Technology
Discount,
a portion of those
savings would be passed on in the form of a one-cent discount per piece.
Bowes will show in this brief that the proposed
meets
the
introduction
to
statutory
and
of discounts,
policy
criteria
Metering
for rate
Technology
de-averaging
Discount
through
serves the needs of a critical but under-served
and thus fully meets the fairness
Pitney
and equity criteria of the Act.
the
market,
The Postal
Service does not contend otherwise.
The
predicates
Postal
Service
does
for the Metering Technology
claim is that recommendation
the necessary
introduction
This claim is baseless.
attributable
not dispute
transaction
the First-Class
the validity
Discount.
of the
Rather, the Postal Service’s
of a metering discount will open the floodgates
of such a discount in other rate categories
It completely
to
or classes.
ignores the fact that the lion’s share of
costs of collecting
single-piece
underlying
mail category.
revenues from stamps is assigned
Thus, the only category
to
of mailers
who deserve relief in the form of a Metering Technology
Discount from otherwise
applicable
rate category.
rates are users of the First-Class single-piece
2
The discount
and residential
will result in a very substantial
migration
of small business
mail users from stamps to metering technology.
will further reduce the Postal Service’s stamp production
it to serve all mailers.
costs and better enable
The Postal Service’s claims that migration will not occur is
without merit. As a result, the very modest net revenue deficiency
from
implementation
This migration
of the
Metering
Technology
Discount
that will result
can
be readily
absorbed without undue burden on mailers who do not qualify for the discount.
THE METERING
The Metering Technology
current
First-Class
TECHNOLOGY
Discount will redress the existing inequity in the
rate structure
and further basic policy objectives
move from the costly and cumbersome
efficient use of metering technology.
of the First-Class
the Postal Service
stamps.
single-piece
traditional
stand-alone
Pitney Bowes’
Under the current rate schedule,
rate category
13904.
stamp related costs.
However,
to affix postage
worksharing
Users of metering
to their
costs that
and sale of postage
users of metering technology
-- both
PC Postage devices like
technology
window
mail pieces.
do not need to purchase
service operations
Tr. 23/10561,
when they
10562.
Their
efforts can and should be reflected in the rates that they pay.
The Metering Technology
one-cent
distribution
all users
-- do not cause the Postal Service to incur these
stamps and burden the Postal Service’s
wish
pay the very substantial
meters and the newly introduced
ClickStamp@
as mailers
use of postage stamps to the far more
incurs in the manufacture,
Tr. 29/13899,
DISCOUNT
discount proposed
Discount would do just that and no more.
represents
(very conservatively)
3
The
only 44% of the 2.3
cents attributable
transaction
piece First-Class
rate category.
who use traditional,
Tr. 29/l 3893, 13901.
stand-alone
Postage devices.
deducted
costs that metering technology
significantly
to pay postage.
Discount
Tr. 29/13952.
or other
The discount
characteristics
would
would be readily understandable
mail verification
small businesses
and residential
of the users of the First-Class
23/10560.
The
payment
readily
proposed
evolution
careful
discount
technology.
qualify,
by
would
rate by mailers
distributing
be simple to apply:
single-piece
rate regardless
the Metering
consumers
accessible
and
of the Metering Technology
Technology
and Postal Service
Discount would be
users who make up the overwhelming
single-piece
rate category.
of metering technology
to this category
conservative
market
majority
Tr. 29/13909,
Tr.
makes this form of postage
of mailers.
research
Tr. 23/10560-63.
establishes
that
the
will prompt stamp users to convert to the use of metering
Tr. 23/10585-88.
the Postal
unpresorted
would be
clerks.
The primary beneficiaries
Thorough,
first-ounce
PC
That is the only category of mailer
all metered mail entered at the First-Class
of content
enable
First-Class
Discount
burdened with the Postal Service’s cost of manufacturing,
and selling stamps.
because
The Metering Technology
applicable
who use metering technology
It would apply to mailers
meters as well as the newer Internet-based
Tr. 23/10564.
from the otherwise
avoids in the single-
Service
First-Class
The Metering
Technology
Discount
to better serve all users of its “core
mail. Tr. 23/10584.
4
will thus
product”
--
ARGUMENT
A.
The Legal and Factual Predicates
Discount are Fully Satisfied
for
the
Metering
There are three legal and policy elements that a proposed
satisfy.
First, Section
3622(b)(3)
should not be burdened
incur.
The Commission
costs that the Postal Service “actually saves.”
Commission
assure
recognize
the desirability
by the Postal
predicates
for the Metering Technology
Second, the Commission
has
Bowes
in rate design
understandable
conceded
Witness
in the manufacture
accountable
paper
to the public
53622(b)(7).
that
these
in order to
legal
and
The
Postal
and
policy
Discount are fully met:
has shown
the causal
Fronk agreed
link between
that “costs
and distribution
are not caused
at IV-
Third, the Act requires that the
39 U.S.C.
explicitly
basis, reflect only the
the activities
by the mailer and the costs that the Postal Service
29/13898-13901.
Service
have
Service.
witnesses
performed
this
of “simplicity”
is readily
Service’s
First, Pitney
that mailers
Decision in Docket MC957
in Docket R97-7 at 384.
that the rate structure
administrable
must
implemented
must, on an exact piece comparison
94; see a/so Decision
dictates
has frequently
mandate by the creation of discounts.
insisted that discounts
discount
with costs that they do not cause the Postal Service to
39 U.S.C. $3622(b)(3).
fundamental
of the Act specifically
Technology
by users”
1214925-26; see also, Tr. 1214789.
5
incurred
of postage
of metering
avoids.
Tr.
by the Postal
stamps
and other
technology.
Tr.
Second, witness Miller conceded
an estimated
discount
2.3 cent cost savings that reflects avoided
and distribution
Technology
that the one-cent
costs.”
Tr. 45/19665.
stamp manufacturing
There is no dispute that the Metering
Discount is based solely on avoidable attributable
Postal Service’s
“is based on
own analysis of variability
costs and uses the
in the relevant cost segments.
See,
e.g., Tr. 612631, 2617, 2634-35; Tr. 29113916.
z,
the Postal Service does not claim that the Metering
Discount will, nor could it, cause administrative
problems or consumer
of the mailing
testified
advantage
of the discount “would not need to maintain any inventory of stamps of
administering
postage
determinable
Thus,
statutory
Class
Tr.29/13908.
the discount:
payment
burdened
(See,
at a glance.
metering technology
e.g.,
avoided
DMM
eligibility
Technology
‘and policy predicates.
Discount
It de-averages
so that metering
meets
costs.
no difficulty
would
evidence
be
in
of
readily
technology
in conformity
Technology
6
users
are not improperly
The savings to the Postal
with the Commission’s
actually passes through
The Metering
each of the relevant
the current single piece First-
with stamp costs that they do not cause.
and the discount
to use
mail “just as
displays distinctive
PO30.41);
to take
Tr. 29/13908.
Service have been measured
analysis,
of single-piece
Postal clerks would experience
the Metering
rate structure
choosing
On the other hand, mailers who opt to continue
stamps would pay only one rate for the First-Ounce
they do now.”
public
confusion.
Dr. Haldi
any denomination.”
that the portion
Technology
Discount
“exact piece”
less than the full amount of
maintains
simplicity
of rate
structure
because
difficulty.
it is readily understandable
and can be administered
As a result, the Metering Technology
and the foremost
recommended
of the statutory
by the
criteria,
Commission
be
without
Discount fully satisfies the first
the mandate
“fair
and
?j3622(b)(l).
Indeed, without the Metering Technology
to conclude
that the First-Class
single-piece
that the schedule
equitable.”
39
U.S.C.
Discount it is not possible
rate schedule
is either
fair or
equitable.
B.
The Postal
Service’s
Opposition
to the Metering
Technology
Discount is Based Upon Claims that are Hypothetical
and Otherwise
Without Merit
1.
Discount
The
Claim
that
Recommendation
will Open the Floodgates
Rate Categories
explanation,
is Without
Basis.
Technology
to the Same Discount
in Other Classes and
On rebuttal, witness
Miller asserts, without
that the Metering Technology
Class single-piece
of a Metering
Discount cannot be limited to the First-
rate. His Table 5 (Tr. 45119669) purports to establish that the
Postal Service would experience
a net revenue deficiency
of approximately
$1.7
billion if the Metering
that rate category.
Technology
This “floodgates”
The fundamental
borne by the single-piece
bear
manufacture,
examine
costs of manufacture
cost” of stamp
and rate categories
any
portion
distribution
that question.
costs of collecting
Technology
Class single-piece
Witness
production
of stamps is
he did
and distribution.
Tr.
(and if so, to what extent) the rates
listed in his Table 5 (either original
attributable
cost
associated
He testified that “much of the attributable
That is precisely
is limited to “non-discounted
with
or
the
Dr. Haldi, by contrast, did
revenue from stamps is distributed
Discount
is that the
Mr. Miller admitted
and sale of postage stamps.
Tr. 29/13952.
Class mail.”
of the
argument
and distribution
rate category.
He was unable to state whether
revised)
beyond
argument is meritless.’
First-Class
not “look at the attributable
for the subclasses
were extended
problem with Mr. Miller’s floodgates
lion’s share of the attributable
45/19869.
Discount of one-cent
transaction
to non-discounted
the reason
First-Class
First-
why the Metering
mail” -- the First-
category.
Miller has effectively
conceded
that Dr. Haldi’s
conclusion
is
correct.
The witness admitted that “we took [Periodicals]
out” of Table 5 (when
revised)
because
no attributable
“there
is literally
or virtually
literally
costs
The witness also suggested that there may be differences in costs to the Postal Service
among different categories of stamp users depending upon the stamp distribution
channel. He implies -- although he does not claim --that these differences might warrant
separate stamp discounts. However, witness Miller conceded that he has no idea of the
magnitude of the cost difference among the various methods that the Postal Service uses
to distribute stamps. He also recognized that even if the cost differences were sufficient
to warrant consideration of further de-averaging of the single-piece First-Class category,
very serious revenue protection and administrative problems would arise. Tr. 45/19855.
Thus, the Commission need not consider the issue of a possible discount or discounts for
stamp purchasers.
8
associated
with the manufacture,
subclass
or those
Business
Reply
subclasses.”
mail was
associated
line 8-14).
and sale of stamps assigned to that
Tr. 45/19863.
removed
stamps nor metering technology
(Tr. 45/19865,
distribution
Similarly,
from the revised
Therefore,
(with the exception
table
because
that
neither
is ‘used to pay for postage in that rate category
none or very little of the attributable
with stamps are assigned to that category.
subclasses
he conceded
of the single-piece
costs
The fact is that all of the
First-Class
rate category)
listed on witness Miller’s Table 5 make little or no use of stamps and thus receive
none of, or a negligible
manufacture
assignment
and distribution
of, the attributable
costs arising from the
of stamps.
For precisely this reason Mr. Miller did not purport to claim that his Table 5
represents
an actual measure of the revenue reduction that will result from the
Metering Technology
Discount.
Tr. 45/19668.
In fact, the entire claim is fictional,
as the following colloquy shows:
“Q. And what you are saying is that you don’t have
any idea what the costs are that would be avoided in
these subclasses [listed in revised Table 51 if they
could avoid the costs at all?
A. I think I have said that I didn’t really look at the
attributable costs. I was just saying if they revetied
back basically if they reverted back to stamps
Q. Hypothetically
reverted back.
A. Yes. Exactly.”
Tr. 45/19869.
With literally no evidence to support it, the hypothetical
that mail might “revert back” to stamps is not probative evidence
9
possibility
of the claimed
net revenue deficiency.
has calculated
should be rejected out of hand.
Limiting
single-piece
the Metering
rate
discrimination
The claim of a revenue reduction greater than Dr. Haldi
Technology
category
is, therefore,
other First-Class
to First-Class
categories
Cir., 1982).
First-Class
of stamp
precisely
the same reason,
anti-
mail.
See,
mailers
through
2.
market
It is the only rate
a discount
is warranted.
is possible
the
only for
exclusion
to
has been
The rates of other subclasses
reflect
For
in which it is possible
mail piece with one in which postage
and other
of attributable
stamp
costs because stamps cannot by rule be used, or are
The Postal Service’s
Mail Stamp
bear an overwhelming
costs.
It is the only category
already
and distribution
are not “similarly situated.”
not in practice used by, mailers in those subclasses
Heisler’s
the
using
and distribution
through metering technology.
First-Class
with
mailers
an “exact piece” comparison
the cost of a stamped
categories
mailers because
category
rate de-averaging
First-Class
First-Class
production
consistent
Users, et a/. V. FCC, 680 F.2d 790, 808 (D.C.
manufacture
in which
single-piece
single-piece
single-piece
category
evidenced
entirely
or other subclasses
e.g., Ad Hoc Telecommunications
compare
to users of the First-Class
provisions of the Act. The discount creates no “undue preference”
(39 U.S.C. §403(c))
proportion
Discount
Claim That There Will Be No Migration
Users to Metering
research
or categories.
study
shows
Technology
that,
approximately
4.9 billion pieces of mail originated
50 employees
and by households
at
is Without
a
one-cent
by businesses
Merit.
of
Dr.
discount,
with fewer than
(through PC Postage) will switch from the use
10
of stamps to the use of metering technology.
The estimation
are confined
of migration is conservative.
to 80% of those
Tr. 23/10584-85;
Dr. Heisler’s volumetric
respondents
established
“extremely
likely” to migrate from stamps to metering technology.
Most revealing
criticize
by the terms of the stud?
survey
Tr. 23/l 0590.
value is baseless.
is what Dr. Staisey has omitted from her criticism.
conditions
She does not
in which it was carried out, the
imposed, or the use of a “generic product” description
questionnaire.
conclusion
and (ii) stated that they were
claim that this study is of no probative
the basic survey design, the manner
qualifying
projections
who both (i) met the qualifying
conditions
Dr. Staisey’s
Tr. 29/13910.
Rather,
Dr. Staisey
supports
her purely
judgmental
that the survey results are entitled to no weight whatsoever,
criticisms
of the survey questions
which are trivial, and (b) comments
response
rate which are both confusing and incorrect.
in the
on (a)
about the
Even if the criticisms had
merit -- and they do not -- they would not support her conclusion
that Dr. Heisler’s
market research is entitled to no weight whatsoever.
First, Dr. Staisey’s
claim that consumers
“burdens”
that use of a PC Postage
45/19924)
is not within the range of reasonable
It entirely
ignores
a fundamental
admitted that, by the conditions
2
device
condition
might not fully understand
would
impose
upon them
the
(Tr.
criticism of the survey instrument.
of the survey.
Dr. Staisey
herself
of the survey, qualified PC Postage respondents
In the case of the non-household
meter study, the qualifying conditions included the
requirement that the firm spend at least $10 per month on postage and that postage be
applied primarily by stamps. In the case of respondents who were presented with the IBI
concept statement, additional qualifying conditions -- the respondent must have a
computer, must have Internet access and must have an inkjet or laser printer -- were
imposed. See PB LR-3.
11
-- those
computer,
with whom
the interviews
-- must already
Internet access and a specific type of printer.
assume that these interviewees
computing
were completed
technology
do not adequately
entails is irrational.
Tr. 450994952.
understand
lack of sophistication
To
the “burdens”
that
Similarly, Dr. Staisey’s contention
that
the access charge or the meter rental fee cost must be repeated
iteration of the discount
have a
level (Tr. 45/19924;
on the part of qualified
45119957-58)
assumes
interviewees.
before each
a complete
That assumption
is
entirely unwarranted.
Second, Dr. Staisey’s claim that Dr. Heisler’s testimony does not “explicitly
state the response
rate” associated
surveys (Tr. 45/19926)
the response
is either confused or incorrect.
rate is somewhat
the term “response
conducted
might
of response
representativeness
However,
Dr. Staisey’s definition
rate has no meaningful
application
Tr. 45/19963.
because
of those
who
this was not a general
it would
did
respond
market study.
to
This
to a survey of the type
In a general market study this definition
value
of
At one point, she stated that she used
to have the option to respond.”
by Dr. Heisler.
be of some
elusive.
and non-households
rate” to refer to “the ratio of those who have responded
those who were selected
definition
with the household
provide
an
to the
of response
indicator
general
of the
population.
Rather, the purpose
of this
survey was to test the response to a discount (or more precisely several levels of
discounts)
business
among
consumers
and residential
who
fall within
a defined
population
(small
mailers) and who also have sufficient mail volume and
12
other
characteristics
to qualify
them as realistic
candidates
for migration
to
metering technology.
Consistent
with the avowed purpose of the survey, Dr. Heisler used the
ratio of qualified respondents
size.
to total respondents
See, e.g., Tr. 23/10588.
to develop the potential market
That is what he should have done.
ultimately admitted as much. During cross-examination
of response
the precise response
Tr. 23/10592,
Tr. 45/19964.
[the
This is
rate that Dr. Heisler used to size the market, Tr. 23/10588,
and that
response
Tr. 23/10597-10804.3
definition
she revised her definition
rate and stated that it is the ratio of “those who have completed
survey] out of those who were selected in the sample.”
testimony.
Dr. Staisey
rate
is explicitly
shown
in Dr. Heisler’s
Dr. Staisey is either confused as to the proper
of the proper response rate in this case, or wrong in her claim that the
proper response rate was not “explicitly” stated.
Third, it is certainly true that there is a fairly large range between the lower
and upper bounds
survey.
of the volume estimates
Tr. 23/10622.
that Dr. Heisler derives
from his
However, this does not warrant the conclusion
that the
survey has no probative
value.
intent surveys,
those that the Commission
cases.
Moreover,
forecasting
calculations
3
including
Dr. Heisler
A low coefficient
has explicitly
volumes from an “intent study.”
categorically
exclude
of variation
respondents
who
in all
has relied upon in prior
recognized
Tr. 23/10590,
is inherent
the
difficulties
lines 8-15.
reported
in
His volume
themselves
as
In a final shift of position, the witness asserted that it is not the response rate itself but the
small size of the sample that gives rise to her conclusion. Tr. 45/19967. She was either
unable, or unwilling, to state what size sample she considered necessary to yield
acceptable results. Tr. 45119969.
13
somewhere
in the range between
“extremely
migrate, as well as 20% of the qualified
“extremely
Id.
likely” to migrate.
criticisms of the adjustments
lower boundary,
likely” and “not at all likely” to
respondents
It is noteworthy
that Dr. Staisey
that Dr. Heisler made. Most importantly,
Dr. Heisler’s testimony
overlooks
Heisler study cannot be depended
(Tr. 23/10622),
had no
even at the
shows that a very substantial
mail will migrate from stamps to metering technology
Dr. Staisey conveniently
who reported themselves
volume of
a fact which
in arriving at her extreme conclusion
that the
upon at all.
Dr. Heisler’s careful and thorough market study provides the Commission
- and the Board of Governors
respond
favorably
-- with reasonable
to the Metering
Technology
assurances
Discount.
C.
is contradicted
net reduction
avoided
calculates
the Postal Service
Will
Discount Can Readily be
Other Mailers
that the Postal Service will experience
in revenues from single-piece
attributable
First-Class
mail (after subtraction
costs and giving effect to increased
from stamps to metering technology)
stamp usage to
by the record.
The Small Net Reduction
in Revenue
Experience
From the Metering Technology
Absorbed Without Unreasonably
Burdening
Dr. Haldi’s testimony
that mailers will
The Postal Service’s
claim that there will be no migration from costly and cumbersome
metering technology
-
of $156.5 million.
a
of
volume and migration
Tr. 29/13910-12.
The
actual net revenue effect will almost certainly be somewhat
smaller than Dr. Haldi
calculated
rather than Test Year
because his calculations
are based on FYI998
costs and revenues.
14
This net revenue reduction
is small in both relative and absolute
With Test Year before rates revenues approaching
revenue
reduction
represents
terms.
$68 billion, the $156.5 million
less than 3110th of a percent of total revenues.
Moreover,
as Dr. Haldi pointed out, even if no migration from stamps to meters is
assumed,
the revenue
single-piece
line 4.
recommend
although
a discount
not justify
the Commission
at the level proposed
increasing
the First-Class
Tr. 29/13967,
line 23-13968,
might
properly
hesitate
considerations
are,
moreover,
several
if the effect were to impose
other
cost
and
that justify this discount at the level proposed
a
revenue
related
despite the modest
net revenue effect:
First, the Postal Service
itself has recognized
that remote
resetting
meters yields benefits to it that go beyond rate case cost analysis.
90% of meters, and all PC Postage devices, are remotely reset.
Plan for Manually
set electronic
As a result (subject
issues), it is very likely that all metering technology
realizes
The
a proposed plan to retire the remaining “manually
Plan, 65 Fed. Reg. At 25339.
Service
See Retirement
meters” -- those that must be taken to the post office.
Test Year will be remotely
of
More than
Set Postage Meters, 65 Fed. Reg. 25339 (May 1, 2000).
Postal Service has announced
Postal
to
burden on other mailers, that is not the case here.
There
calculated
would
rate paid by stamp users by one-cent.
Accordingly,
significant
reduction
reset.
Retirement
to scheduling
and other
installed beginning
during the
This will increase the cost savings that the
from metering
technology.
reflected in Dr. Haldi’s analysis.
15
These
savings
are not
Second, the migration of stamp users to remote reset metering technology
will enable
resources
the Postal
and, therefore,
Service
use its window
service
better serve those mailers who, for whatever
reason,
elect to continue to use stamps.
to more effectively
Tr. 23/10565.
These cost savings, as well, are
not reflected in Dr. Haldi’s exact piece analysis.
Third,
offering
an incentive
to mailers
effective means of attracting new customers
official responsible
to migrate
from stamps
and new volume.
for strategic planning has specifically
is an
The senior postal
recognized
this
“When customers do not have to go to the Post Office
to fill their postage meters, they may even use more
postage simply because the new technology
has
made it easier for them to do so. New customers may
be drawn in.”
Tr. 29/13906.
The Postal Service’s First-Class
Mr. Fronk, confirmed this assessment.
rate design witness in this case,
Tr. 10/4793.
In view of the relatively modest calculated
plain, but unquantifiable
other cost and revenue
net revenue deduction
benefits that will flow to the
Postal Service from this incentive, the proposal can be implemented
proposed without unduly burdening other mailers.
16
and the
at the level
CONCLUSION
The C6mmission
comports
furtherance
should
with the requirements
find that the Metering
of the Postal
of basic postal policy objectives.
Technology
Reorganization
Discount
Act and is in
The Metering Technology
Discount
should be recommended.
Respectfully
submitted,
Ian D. Volner
N. Frank Wiggins
Venable, Baetjer, Howard & Civiletti, LLP
1201 New York Avenue, N.W.
Suite 1000
Washington, DC 20005-3917
Counsel for Pitney Bowes Inc.
17
CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoing
all participants
of record in this proceeding
in accordance
rules of practice.
-L
9, VA
Ian D. Volner
document
upon
with Section 12 of the