Will Aunt Minnie show up to testify?
The proceedings in the rate case are in the discovery phase at the moment. Part of the discovery process is the submission of interrogatories, or questions by participants. Most interrogatories, naturally, are submitted by intervenors to the Postal Service. But there are also quite a few questions being asked of other intervenors. Many of these are variations on “Where did you come up with those ridiculous numbers in the testimony you submitted?”
And sometimes interrogatories seem to serve no purpose but to make a point- here’s one, submitted to APWU witness Kathryn L. Kobe by the Major Mailers Association. Kobe had testified that “it seems highly unlikely that the mail that is converting to presort mail is equivalent to the average collection mail that is coming from individual households, nonprofit organizations, and small businesses”. The MMA posed the following questions:
Please assume that you are a dutiful niece who for years sent monthly letters to your Aunt Minnie. Assume further that all these letters exhibited the cost attributes similar to an “average” First-Class single piece letter. Now, in 2005 you and your Aunt Minnie discovered the Internet and you substituted your 12 monthly letters with 12 monthly emails. Please confirm that, as far as the Postal Service is concerned, those letters are lost to the system and First-Class Single Piece has lost 12 “average” Single Piece letters. If you cannot confirm, please explain.
Please assume that you also enjoy calling your Aunt Minnie as well, and in 2005 you decided to sign up for a cell phone. The cell phone company sent you 12 monthly bills in 2005, all of which qualified as Automation letters. Please confirm that, as far as the Postal Service is concerned, those letters are new to the system and First-Class Automation has gained 12 pieces that are similar to an “average” Automation letter. If you cannot confirm, please explain.
Please confirm that, as far as the Postal Service is concerned, the 12 “average” Single Piece letters lost and the 12 “average” Automation letters gained represent a “shift” of letters from First-Class Single Piece to Presorted. If you cannot confirm, please explain.