**BEFORE THE**

**POSTAL RATE COMMISSION**

**WASHINGTON, D.C. 20268-0001**

**)**

**POSTAL RATE AND FEE CHANGES, 2000 ) Docket No. R2000-1**

> **)**

**FIRST SET OF INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS
BY THE ASSOCIATION OF ALTERNATE POSTAL SYSTEMS TO THE UNITED STATES
POSTAL SERVICE WITNESS JOSEPH D. MOELLER**

**(AAPS/USPS-T35-1-10)**

Pursuant to the Commission's Rules of Practice, the Association of
Alternate Postal Systems hereby submits the attached interrogatories and
requests for production of documents to the United States Postal Service
witness Moeller. If any request should be answered by a different
witness, it should be referred to that witness.

Respectfully submitted,

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Bonnie S. Blair, Esq.

THOMPSON COBURN LLP

700 14^th^ Street, N.W., Suite 900

Washington, D.C. 20005

> Counsel for the Association
>
> of Alternate Postal Systems
>
> **[CERTIFICATE OF SERVICE]{.underline}**

I hereby certify that I have this date served the foregoing documents in
accordance with Section 12 of the Commission's Rules of Practice.

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Bonnie S. Blair, Esq.

Dated: February 23, 2000

FIRST INTERROGATORIES AND REQUEST

FOR PRODUCTION OF DOCUMENTS

OF ASSOCIATION OF ALTERNATE POSTAL SYSTEMS (AAPS)

TO THE UNITED STATES POSTAL SYSTEM

WITNESS JOSEPH D. MOELLER (USPS-T-35)

(AAPS/USPS-T35-1-10)

AAPS/USPS-T35-1. At pages 19 and 20 of your testimony, you assert that
the Postal Service has addressed the objections to the proposed ECR
pound rate reduction raised by "private alternatives" in Docket No
R97-1.

(a). Is it your understanding that the objections raised by AAPS were to
the form of the proposed rate or to the fact that, as proposed, the
effective rate against which its members compete would actually be
reduced?

(b). Please confirm that the proposed rates for saturation ECR pieces
are lower than current rates for pieces weighing 5 ounces and above at
both SCF and DDU entry.

(c). Please confirm that the proposed rate for saturation ECR pieces at
both SCF and DDU entry can be lower than current rates by more than 10%.

(d). How would yet another proposed reduction in the pound rate, and a
resulting rate reduction in the postage rate for saturation ECR pieces
weighing 5 ounces or more, meet the objections raised by competitors in
prior cases?

AAPS/USPS-T35-2. Does your table at the top of page 21 mean that, on
average, pound rated ECR pieces contribute approximately 10.3 cents to
institutional costs?

AAPS/USPS-T35-3. You conclude at page 21 that the pound rate must be too
high, because revenue from one 8-ounce piece is the same as the revenue
from two 4-ounce pieces. If indeed this is an incorrect relationship,
wouldn't that "anamoly" also be eliminated by raising the piece rate
instead of lowering the pound rate?

AAPS/USPS-T35-4. Please enumerate the cost functions that are
significantly different in amount between processing one 8-ounce
saturation piece entered at the DDU and two 4-ounce saturation pieces
entered at the DDU

AAPS/USPS-T35-5. You state at page 23 that at the Basic level, an ECR
piece would have to weigh more than 6 ounces to realize a rate reduction
and that the percentage of ECR pieces over 6 ounces is 6.4%. What is the
percentage of saturation ECR pieces that weighs five ounces or more?

AAPS/USPS-T35-6. Would you expect that with a rate increase for
piece-rated pieces and lighter weight pound rated pieces, accompanied by
a rate decrease for heavier pound-rated pieces, the percentage of pieces
that will actually experience a rate decrease as pieces migrate to
pound-rated pieces will increase?

AAPS/USPS-T35-7. Has the Postal Service estimated the revenue that will
be lost as light weight saturation pieces paying the full piece rate
migrate to pound-rated pieces where the postage cost per ounce will be
much lower?

AAPS/USPS-T35-8. Have you read the "SAI Study" of alternate delivery
commissioned by the Postal Service that was the subject of significant
controversy in recent cases? If so, when? Also, if you have read it,
please explain how you relied upon its discussion and conclusions
concerning the impact of the proposed rates on alternate delivery
companies.

AAPS/USPS-T35-9. Has the SAI Study been updated since the close of the
record in Docket No. R97-1. If so, please make a copy of the study
available.

AAPS/USPS-T35-10. Since the close of the record in Docket No. R97-1, has
the Postal Service conducted or caused to be conducted any study of
competition from the private sector for the carriage of saturation
advertising material? If so, please make a copy of that study available.
If there is such a study and the Postal Service intends once again to
object to its release, in response to this question please provide the
name and employer of the person or persons that conducted the study, a
summary of its content and a copy of the study plan or outline of its
scope.