BEFORE THE , x--w ,’ POSTAL RATE COMMISSION WASHINGTON ‘RECEIVED’ DC 20268-0001 RUG 9 9 30 AH'96 POSTAL RAT! COHH:S::CH SPECIAL SERVICES FEES AND CLASSIFICATION] INTERROGATORIES David B. Popkin completely, knowledge volume of paper, desired. appreciate receiving While some interrogatories referral to previous Dockets, If necessary and Service in liberally information. into a single similar wording that a new response who has is encouraging interpreting the To reduce numbered to a Library to my to provide to the USPS employee be made to each separate may contain I request fully to respond the interrogatory, question Reference, since I am located at a distance [even though asked. I would from Washington, to previously asked be made to them without it may be the same response] since there are new and it has been a number of years. In the event that the Postal Service required witness. the desired is made in the responses of my interrogatories responses is unable since the Postal requests response a copy of the reference in previous witness be directed Particularly related to answer, to Rules 25 and 26 of the Commission’s and provide that a specific that a reference should Service I request that similar cooperation I have combined I am requesting pursuant Postal by some other qualified the question from the interveners, To the extent witnesses a response requested, States If the designated made by my interrogatories however, DC. interrogatories of the information cooperation the United and Procedure. I request the information /- requests the following interrogatory, requests OF DAVID B. POPKIN TO THE UNITED STATES POSTAL SERVICE hereby Rules of Practice oFF’eS6ki#$~&%t&96-3 time, I request does not respond to all of my interrogatories a waiver of the filing time in which to file follow-up that I may file them all at the same time as calculated event that these mterrogatories within the interrogatories on the last responsesprovidedr--In are not received in time, I move for late a DOCKTCD August 6,1996 ,I--DAVID B. POPKIN, POST 0 07631452 P..: so the DBPIUSPSITI-1 , /-. receipts On Page 14 of your testimony, represent premium used to provide evidence Confirm that return acknowledgment .. services. of delivery, receipts of delivery. With respect receiving delivering the eliminate authorized signature check return receipt form. DC area? or practice [including agencies, large organizations, return receipt of the regulation, details and copies agencies, and deposit accountable of the agreements. regulations, a listing. mail is made without having the delivery is completing post/postal/stamped to any addressee 20 or 22 cents. What is the justification DC area, state of pieces of accountable or addressee this. of accountable receipt mail] to complete If so, provide authorizes details and Does the USPS mail. If so, provide costs to the Postal USPS employee whose delivery of obtain the signature on it without of delivery checking by the than that which would exist if the sender included provide Confirm that the cost of this post/postal/stamped for this type of processing 2 the If not, why not? card with the article and had the addressee done? policy that have a unique ZIP Code, the return receipt and returning being presently Do these or unwritten how can this return receipt provide evidence How is this service any different of the in the Washington of the Washington that the return in this manner. or directives, to the completion agencies organizations signature If not:, what are the In the event that there are one or more addressees since the addressee ,a- outside or of the Form 3811, mail to be delivered etc. which Confirm the Is there a written with respect to the delivery the Form 3811 at the time of delivery, USPS? government to obtain of the USPS who is obtain it in mail at a later time? memoranda, employee If so, provide and leaves it up to the agency Service would be less for mail delivered DBPIUSPS-Tl-2 to this policy7 independent stamp of the individual or external that receive a large number directive, have any agency agreements that they are seek the same day? for the exception. local government by themselves signature of all internal agencies to and take possession is sent to federal to federal with the Form 3811 attached sender representative or allows the accountable organizations mail and return confirm that the employee or their Are there any exceptions but not limited the the action to be taken with respect If not, provide the authority government copies Is it required me with copies permits receipts, for the delivering and mail it back to the sender apply to mail which which for or the authorized addressee etc. which describe requirements need stamp at the time of delivery Provide memoranda, /-- to the it for accuracy, requirements7 the Is there still a requirement the article’? article to return that certified namely, who received the mail and when it was delivered. on the Form 3811 either the signature organization you indicate a the same service as card would be either of the return receipt being charged the full 51.50 rate as opposed [which is the only service to the 20122 cent rate for the post/postal/stamped being provided by the USPS]? refund of $1.28/1.30 in these instances. completing and returning independent requirement accountable evidence receipt copies that the date of delivery is shown? If in fact, it is the addressee to the mailer, that is how can this be considered If there of delivery an to the addressee to the sender require this. Is it a the actual date of utilize to ensure that the actual date of a procedure, how can with the return it be accomplished receipt if the date shown is missing or incorrect Are there instances examples. etc. which shown on the return receipt represent is such is provided mailer and represents of any directives does the Postal Service mail is delivered DBPIUSPS-TI-4 provide Provide What procedures delivery If not, why not? Does the return receipt service also provide for notification of the date of delivery? delivery7 Is the mailer allowed to apply for a acknowledgment? DBPIUSPS-TI-3 /-- the return card still attached? receipt If this were the case and the date shown service What or written over2 where the date of actual delivery the major reason why the return if the is important to the was utilized? If so, on the receipt was incorrect, would this mailer have received the premium service that was paid for? DBPIUSPS-TI -5 learn within provide Are there instances a specific examples. where the mailer utilizes the return receipt service to period of time the fact that the article was actually If this were the case and the addressee delivered? did not complete return receipt within a week or two, would this mailer have received If so, and return the the premium service that was paid for2 DBPIUSPS-Tl-6 postmark did the on all return receipts? this service Postal Wouldn’t that the mailer receives Service eliminate in utilizing the return it be more likely to indicate date? If not, why not? Would it add to the value of evidence that was only available the use the use of this postmark Would a validation /--‘ Why receipt the actual date of delivery to a postal employee? of the red validating add to the high value of service? as opposed If not, why not’? to a handwritten as proof of delivery by providing If not, why not? What are the reasons why the Postal Service does not want to return to the use of this validating it required that return receipts the mail stream7 be postmarked on the address stamp? side when they are entered into If not, why not? 3 - ~.- Is - With respect DBPIUSPS-TI-7 have any tests been conducted that it is handled was necessary equipment tagging? to the tagging to determine as accountable to implement mail? that is now used on the certified the effectiveness If so, provide this tagging details. procedure. that is used for mail distribution contains provide for trapping the necessary receipts article is delivered implementation copies trapping shown of any regulations, of accountable Wouldn’t schedule7 to this Does the memoranda, to provide the address where delivered is different], etc. mail at the time of delivery. how will this service with the return receipt attached? greater level of service if the Form 3811 had a place to indicate ,<--. device to respond directives, to the addressee the same as shown? of the automated Provide effective [when the address Explain why it Provide details as requested Since it is proposed DBPIUSPS-Tl-8 If not, why not? letter size, flat size, and SPR mail? for each of the categories. which relates to providing this mail to ensure What percentage If not lOO%, when will it be so and provide tagging of trapping mail label, be provided when the Would mailers receive a that the delivery If not, why not? Are there plans to add this to the form? that add to the value since if the present form is received for all return address was If not, why not’? lback now without a new address being shown, it would either mean that there was no new address or that an error was made in not showing the new address? DBPIUSPS-TI-9 With respect to the delivery and/or organizations when the volume commercial Service has received piece of accountable eligible to utilize regulation confirm which mail. a rubber Also confirm stamp for “signing” lists the conditions large agencies the return and requirements under which receipt with each and organizations Provide copies are of the this may be done. Also to be signed for when is less than the time that would be required when Also confirm that if the average time is less then the average cost would be less. Explain any nonconfirming DBPIUSPS-TI-10 receipt. agencies that the Postal that may be associated that the averaqe time that it takes for a single return there is only a single article. refunded that these mail to government of mail is high, confirm payment for each of the return receipts there are a large number to be completed ,r--. of accountable Section S915-1.6 only if the USPS fails to furnish be a valid reason for obtaining responses. of the DMM indicates a return receipt. that receipt fees Advise which of the following a refund of the return receipt fee: 4 return are would [l] the article was returned to the sender regardless ..I-- of the reason [2] the return receipt was received the return receipt was received a new address when back undated [4] the return receipt was received one was required [5] the return delivery indicated that there was no record of delivery of the article. January date [6] the return receipt receipt incorrect DBPIUSPS-TI Advise -11 any actions 4, 1991 to improve conducted the quality any studies to determine to which it complies any directives, was not received that have been taken of the return receipt was received regulations, back with an return by the Postal Service service. [3] back without I;r] a duplicate receipt since Has the Postal Service the quality of the return receipt service with the DMM and other requirements7 memoranda, back unsigned If not, why not? and/or the extent Pr’ovide copies of surveys, etc. related to the quality of the return On page 17 of your testimony you indicate that there are three certified receipt service. DBPIUSPS-TI-12 mail transactions per US household. by all households. Is this meant to show that certified If not, please explain the significance On page 3 of your testimony DBPIUSPS-T3-1 in the Villa Rica Post Office if fairly typical. box service for7 Please provide between them and Villa Rica. in Middleburg VA, San Luis AZ, and Blaine WA. Why were these oftices DBPIUSPS-T3-2 increases Have you ever visited chosen offices7 offices If so, or learn during in these How many typical are there? of Fairfield Plantation, forwarding that the number of orders and requests it to? these offices7 What are the What are the criteria that make an office atypical? the number of hold mail orders and temporary What are you comparing with the operations with the Postmaster as being atypical the and differences of the visit, and what did you discuss You indicate that the existence have you done to indicate have you evaluated and the similarities are there in the United States and how many atypical criteria that make an office typical? F-1 How many other offices Prior to this rate case, have you ever communicated three offices? offices that the post office box service Provide details on how you became familiar when did you visit, what was the purpose the visit? of your statement. you indicate a listing of these offices mail is utilized equally Why did you choose that to compare any studies. 5 a resort community, requests. What studies i:s an increased it to? amount? Provide details of .I-- On page 2 of your testimony DBPIUSPS-T3-3 hours daily for mail pick-up. employee Is this typical regulations, and guidelines minimum, on duty in the building7 be open whenever Have any other items been considered DBPIUSPST34 copies Delivery not, why not? of any directives, that exist with respect to of mail. Are these individuals If not, why not? is on duty in the building? DBPIUSPS-T3-5 to allow for greater of the box holders this unique to a non-resident’? that a recent entitled to reiceive maiil delivery while Is it possible indicates case in Blaine for a resident set-vice? which provides Has a similar study been conducted [compared to the If not, why not? resulted in ,a non-resident were accumulated If so, provide Have you done a study details. in Why is and [or is :your testimony in the country, data on the frequency If If so, specify. to take a three week vacation that for all of the offices to pick up their mail vs. the frequency the volume mail either through they were on the route]? the delivery case or were there other cases? not pick up the mail while they were away? office or offices, access to the box result in a greater cost to provide the delivery You indicate which If who as well as reduce the income from the box rent? Is this an isolated anecdotal] been given are individuals failing to pick up mail for over three weeks and four containers that period. on such as it: done in many CMRA? Are they eligible to receive Are there any other means to provide post office box delivery] As a be open when there is no employee or via one of the seven rural routes [assuming Would each of these methods customer that a large number in the Blaine area. they are in the Blaine area? General during the If so, provide details. You indicate own property exceeds an employee may or should the box section section by box holders7 ,*-. security be open for the pick-up box holders with a “key” access to the building not, why not? specific Provide is open 24 Is there an In those offices which are not open 24 hours a day, has any cronsideration to providing strictly the country? area, or district] in a post office should should the box section Under what conditions throughout If not, how do you provide [issued by headquarters, the hours that the box section ,I-. of offices on duty all 168 hours in the week? hours that there is no employee duty? you indicate that your box section or even for any whiclh is utilized by residents which is utilized by non-residents to pick up their mail? with respect to the number of times that the mail volume of the box due to the failure to pick up the mail ‘on a daily basis? why not; if so, provide copies and details of the study. 6 If not, You indicate DBPIUSPS-T3-6 ,,-- that when non-residents do pick up their open it in the lobby and, after review, summarily discard resulting requirements. in lobby clutter and additional your testimony strictly anecdotal] even for any specific residents discard envelopes which indicates office or offices, vs. non-residents custodial and packaging materials Have you done a study [or is in the country, data on the frequency mail in the lobby materials. ,and packaging that for all of the offices which provides will open their envelopes mail, they often and volume that and, after review, If not, why not; if so, provide or summarily copies and details of the study. You indicate that all communications DBPIUSPS-T3-7 by long distance. a long distance instances possible ,,--. anecdotal] office charge telephone company7 call to a resident that there are many non-residents nearby exchange which indicates which telephone areas? If not, what do you mean? could result in a long distance Have you done a study charge7 Is it of local calls to a number [or is your in the country, data on the number number vs. a local telephone each of the categories? Are there that would still be a local call due to an exchange that for all of the offices provides are, of necessity, call1 to them would result in a number of ZIP Code areas or due to the availability or offices, distance do you mean that a telephone by the telephone where a telephone area covering of other By long distance, with non-residents testimony or even for any specific of non-residents number strictly whlo have a long and the times that wmererequired If not, why not; if so, provide copies and details to of the study. You indicate DBPIUSPS-T3-0 due to the sporadic covered nature in interrogatory DBPIUSPS-TJ-9 holders routinely which indicates The question above. be sent to the non-resident’s You indicate left inI the box are ineffective of resident Is leaving written vs. non-resident correspondence If not, how else can it be done? non-residence address? that the use of the box is difficult to control Have you done a study [or is your testimony that for all of the offices in the country, data with respect to this claimed Can written since many box Explain what strictly anecdotal] office with respect l:o residents If not, why not; if so, provide copies and details of the study. 7 the only or even for any specific problem was If not, why not? allow other parties to use their boxes for mail order purchases. offices, which provides non-residents7 communications with the box holders? you mean by this statement. /--.. of mail pick-up. DBPIUSPS-T3-5 written way to correspond correspondence that written or vs. ,..-- You indicate DBPIUSPS-T3-10 incidence of lost or forgotten anecdotal] office which or offices, residents indicates which box keys. by inadequate provides Have you done a study [or iis your testimony data with respect You indicate that forwarding problem List all of the conditions conditions, in the country, with respect to advise as well as mail that arrives how inadequate communications strictly or even for any specific anecdotal] respect to this claimed problem with respect to residents to the mail that is after the closing. increased which indicates office or offices, is frustrated under which a box and the action to be taken by the post office with respect Have you done a study [or is your testimony the offices to this claimed or even for any specific of mail when boxes are closed with box holders. in the box at the time of closing each of these in the country, strictly If not, why not; if so, provide copies and details of the study. communication may be closed contained 1 use of the box resullts in higher than normal that for all of the offices vs. non-residents? DBPIUSPS-T3-I that infrequent the problem. that for all of which provides vs. non-residents? For data with If not, why not; if so, provide copies and details of the study. ,- DBPIUSPS-T3-12 You indicated that non-residents you done a study [or is your testimony offices in the country, strictly are often late in paying box fees. anecdotal] or even for any specific office respect to this claimed problem with respect to residents which indicates or offices, which that for all of the provides vs. non-residents? Have data with If not, why not; if so, provide copies and details of the study. DBPIUSPS-T3-13 the present requested Confirm that the Villa Rica post office has sufficiient time to meet the needs this service. of both the residents post office boxes at and non-residents Confirm that by adding 226 new boxes by November who have that this need will still be met and will likely be met for even a greater time. DBPIUSPS-T3-14 corporate Confirm ,*--. Confirm that all of the residents who reside wiithin the Middleburg VA limits have only the General Delivery or post office box service to obtain their mail. that residents living delivery as well as rural delivery outside the corporate if on one of the two routes. available. Would each of these [compared to the post office box delivery] - limits methods result have the same methods for mail If not, advise other means that are in a greater cost to provicle the delivery as well as reduce the income from the box rent? If not, why not? Middleburg Confirm that non-residents have less box holders If not, why not? DBPIUSPS-T3-15 You indicate Act requests. is your testimony strictly even for any specific that the San Luis post office What proportion would be eligible for resident of these requests box fees vs. non-resident anecdotal] office which indicates or offices, problem with respect to residents options for delivery. along with less than the 15 to 20 plrospective it had city delivery7 Information have the same which rec,eives Would box holders many Freedom of would be from box holders who box fees? Have you done a study [or that for all of the offices in the country, provides vs. non-residents? if data with respect or to this claimed If not, why not; if so, provide copies and details of the study. You indicate DBPIUSPS-T3-16 unable to fill out the necessary is provided fees? ,,<--. to box holders that the San Luis post office has many customers forms without who would assistance. be eligible for resident Have you done a study [or is your testimony all of the offices in the country, with respect to this claimed What proportion strictly or even for any specific problem with respect who are of this assistance box fees vs. non-resident anecdotal]/ which indicates office or offices, to residents box that for which provides vs. non-residents? data If not, why not; if so, provide copies and details of the study. DBPIUSPS-T3-17 With respect to any surveys referred to in the preceding which you have made and which are not made for all offices feel the number of offices that you surveyed With respect DBPIUSPS-T7-I non-resident is representative to the determination post office box fee, advise whether digit ZIP Code and therefore where there is no box section in the c:ountry, explain I would each of the following be subject would require to the it: [a] I that I live in has its own unique 5- would not match any box section utilized in the postal facility why you of the entire country. of whether live in a large city such as New York City and the building interrogatories available [b] also in a large city corresponding to my ZIP Code [c] a firm has its own unique 5-digit or even 3-digit ZIP Code and therefore! will not match any post ,-- office box section my business example, [d] location Paramus I want to obtain a personal box at the post office that corresponds [e] if the box section has a different NJ 07652 delivery ZIP Code than the delivery vs. 07653 box section] [fj if I reside 9 ---~ _. .. * ,., ,, to area [for or establish a business . .c--- at a temporary which is sewed limits location. by delivery of a municipality delivery [g] if I reside within the corporate from another having limits of a municipality office [h] if I reside in an area within the corporate a postal facility and I am not eligiblse to obtain city or rural [i] same as h except there is no postal facility. Is an individual DBPIUSPS-T7-2 rural delivery by a carrier without paying office? If so, explain. operating the non-resident who lives in a house which is eiligible to receive out of a given post office eligible fee at any other postal facility to obtain city or box service other than ,the given post If carriers operate out of several postal facilities all having the same 5- digit ZIP Code, may the resident fee be paid at any of these facilitif!s regardless from which the specific carrier operates? offrce which has no city or rural delivery holders Witness service. Landwehr of the one refers to the San Luis AZ post He also states that a large proportion do not reside in the San Luis service area. What is the service of box area for a post office that does not have any delivery service such as San Luis? DBPIUSPS-T7-3 ,,r-. Explain the rationale respect to not being considered establish behind discriminatory7 other fees or surcharges the non-resident post office Have there been any plans or discussions with respect to other classes to of users to obtain the same service such as has been done with the non-resident post offrce box fee [this could include - but not limited to - charging to purchase charging a surcharge single letter, charging complete extra for non-residents for small mailers to mail single letters vs. large mailers sending extra for earlier delivery of mail on a given carriier route]? With respect to registered mail, where require a mailer to declare the full value of the article? have to check or ascertain in the postal the same If so, provide as registered mail without DBPIUSPS-TB-2 regulations does it What method does the Postal Service the actual value of an article being mailed? mailer who does not declare the full value of the article potentially registered st,amps at the post office, details and status. DBPIUSPS-TB-I ,--.. box fee with What penalty does a suffer if an article is mailed insurance? Your testimony on page 25 appears to indicate mail is slower than for non-registered that the delivery mail. Please explain and clarify. 10 time for Can Priority Mail be sent registered? _ .-- What are the delivery Confirm that the proposed a $5000 registered standard Mail and Priority Mail, and Priority Mail. sent to the 5’h zone intra-BMC, be cheaper than a registered particular Priority weight, fee for a $5000 insured letter is $7.65 or $38.05 less. mail [B], First-Class First-Class distance, Mail or First-Class being sent standard Mail and Priority Mail package. may be obtained on Mail and that registration may be obtained on category7 article. Confirm that Mail be registered7 this - Express package responses,. being would packages fall into this registered mail [being to a registered rates [as opposed to registering package article will be Why would any mailer the Imail]? If not, has this been considered? is the mailer of a high value article for which expedited to achieve mail parcels service ithan an insured provided Clarify any nonconfirming Can Express “double-whammy” of all insured Mail] would receive better delivery that the security standard where a $5000 insured What percentage and intra-BMC parcel is $45.70 and for that insurance are there any instances want to use the higher insurance DBPIUSPS-T8-4 Confirm Other than 69 and 70-pound mail. Confirm greater than an insured ,.--. for First-Class that is registered? DBPIUSPS-TB-3 ,’ standards delivery Mail over Priority is desired required Why to pay a Mail and insurance fee over registry fee? DBPIUSPS-TB-5 understand. registry You indicate Wouldn’t that the use of $100 increments $1000 increments rates, be equally simple? at the higher values, Were any other increments for insurance such are simple to as are utilized in the other than $100 considered? If not, why not; if so, why weren’t they adopted? DBPIUSPS-TB-6 On page 56 of your testimony, cover the average claim for Express Mail document you indicate reconstruction. valid claim made in FY 19957 Was any consideration the ability to purchase DBPIUSPS-T8-7 /-- higher values? certified that the $1.50 certified mail fee coupled with the Would it be even easier to mail and return receipt fees were each 34 ceints making a one ounce mail - return receipt letter cost an even $1.007 11 -. limits as well as If not, why not; if so, why weren’t they adopted? On page 73 you indicate if the certified more than What was the maximum given to other maximum $1.50 return receipt fee would be simple and easy to remember. remember tha:t $500 would If not, why not? On page 87 of your testimony, DBPIUSPS-T6-8 ,. --- return receipt for merchandise this would be to prohibit handling Priority of First-Class Mail. Confirm whether that for articles weighing postage] Mail. for limiting the Cronfirm that the effect of without paying the! extra cost for or less, the mailer must determine it Standard Mail] or pay the extra Mail [even though postage the cost to send it Priority Mail. response. With for stamped 11 ounces slow up the mail by sending Explain any nonconfirming the rationale 11 ounces or less for which the expedited Mail is desired for the merchandise be the same as First-Class DBPIUSPS-TB-9 Mail and Standard its use for articles weighing to deliberately would to Priority you indicate respect cards, to the proposal to charge will this apply to all stamped a 2-c:ent fee [in addition cards? Does the definition to of stamped cards include any card which is prepared and sold by the Palstal Service which has a stamp imprinted on it and which is valid for mailing7 DBPIUSPS-T&IO handling ,,..-.. card? With respect and delivering this card? If there is a difference to the current If not, provide an,y exceptions. postal card, what is the average What is the average cost for handling cost for and delivering a post in the costs between a post card and ,a postal [stamped] card, explain the difference. DBPIUSPS-T&I all respects I Express With respect to the elimination Mail will receive equal or better delivery Specify any instances, delivery or location better provide delivery days of the week or holidays, of the addressee, etc., if any, where Special than an Express assuming same time, [b] both articles the delivery office [a] both articles are available For both Mail article. confirm types of offices, Deliivery mail would parts receive center at the from the area mail proce’ssing at the same time, and [c] both articles type of of this. interrogatory, arrive at the area mail Iprocessing for dispatch that in service tlhan Special Delivery will. conditions, service responses of Special Deliver1 service, arrive at the delivery center to office at the same time. DBPIUSPS-TB-12 On page 131 of your testimony, you indicate has been upgraded. Provide full details of this upgrading. DBPIUSPS-TB-13 In the last omnibus that First-Class Mail service r--. the purchase rate case the Commission of printed stamped envelopes. It is impossible 12 approved specific for the public to purchase rates for printed stamped envelopes handling proposed adopted charges in this by the only source proceeding Postal proceedings7 are ultimately be available in these proceedings7 Service to adopt any by the Commission any surcharge and or other Have there been any discussions or other costs not approved in these If so, advise specifics. that I have this date sewed record in this proceeding David 9. Popkin to the public without surcharge of postage and Will all of the rates being approved If no, quantify. CERTIFICATE I hereby certify due to the irnposition to obtain these envelopes. and which by the Board of Governors costs not approved by the at these prices which were approved i accordance Auguk6UA OF SERVICE the foregoing with section documenl: upon all participants 12 of the rules of practice. of
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