ORDER NO. 1238

UNITED STATES OF AMERICA

POSTAL RATE COMMISSION

WASHINGTON, DC 20268-0001

Before Commissioners: Edward J. Gleiman, Chairman

W.H. "Trey" LeBlanc III

Commissioners Dana B. Covington, Sr.,

Ruth Y. Goldway, and George A. Omas

International Mail Report Docket No. IM99-1

ORDER APPROVING REQUESTED ACCESS TO

GLOBAL PACKAGE LINK DATA

(Issued April 21, 1999)

On April 9, 1999, the Commission issued Order No. 1236, requesting
additional data with which to prepare the report on the costs, volumes,
and revenues of international mail services required by 39 U.S.C.
§ 3663. In item no. 8, the Commission requested the Postal Service to
provide the data for the Global Package Link (GPL) model and the model
itself. On April 14, 1999, the Commission received the Preliminary
Response of the United States Postal Service to Item 8 of Order No. 1236
("Response"). In that Response, at 1, the Postal Service states that

a very few customers account for most of the \[GPL\] volume. It would
not be possible for the Postal Service to give the Commission the data
it is requesting without divulging the identity of these customers and
the volumes they send to each country. This information is proprietary
to these customers and is considered by them to be a trade secret.

For this reason, the Postal Service proposes that it not relinquish
custody of the GPL data and model. Instead, it proposes that the
Commission examine the GPL data and model at Postal Service
headquarters. According to the Response, at 2

\[t\]his would allow the Commission to have access to the relevant data
but the data would not leave Postal Service custody. Postal Service
personnel would be available to answer any questions the Commission
might have about either the data or the model, and to walk the
Commission through the operation of the model. In this manner the Postal
Service would not have to divulge customer information that is
proprietary, but the Commission would have access to all of the
information it may believe it needs to understand and evaluate the
Postal Service's procedures and to prepare its report.

The Postal Service states that the GPL data and model would be available
for review beginning on Friday, April 16, 1999. Response at 3.

The Commission is willing to cooperate with the unusual procedures that
the Postal Service proposes as a starting point in its evaluation of the
accuracy of the Postal Service's estimates of the costs, volumes, and
revenues of GPL service. The Postal Service's concern is not
unreasonable: that the volumes of GPL mail sent by specific customers to
specific countries could be inferred from GPL input data, and that GPL
customers regard this customer- and country-specific data as
commercially sensitive. The Commission is quite capable of providing
protective conditions that maintain the confidentiality of commercially
sensitive data, as the Service knows, since it has often provided data
to the Commission under such circumstances. However, the Postal Service
has offered this procedure as an alternative to it "generating new
copies of the data and the model to give to the Commission," Response at
2, and the prospect of rapid access and assistance justifies acceptance
of its proposal.

It is hoped that the Postal Service's explanations of the GPL data and
model will enable the Commission to adequately evaluate the accuracy of
GPL costs, volumes, and revenues without having custody of the data. If,
after trying these procedures, the Commission concludes that performing
its evaluation of GPL costs, volumes, and revenues off-site is
impractical or ineffective because of the nature of the GPL data and
model, it will ask the Postal Service to provide the required
information under protective conditions similar to those that
customarily apply in Commission record proceedings.

Accordingly, the Commission will direct its technical staff and Postal
Service technical personnel to arrange a meeting at their earliest
mutual convenience for an examination of the GPL data and model.

It is ordered:

At this time the Postal Service is excused from its obligation under
Order No. 1236 to submit a response to Item No. 8.

By the Commission

(S E A L)

Margaret Crenshaw

Secretary