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EHRLICH v. U.S. | Case No. 17-01245-RAJ. | 28... | 20180727g05| Leagle.com
ORDER RICHARD A. JONES District Judge. This matter comes before the Court on Plaintiff s Motion for Leave to File Second Amended...20180727g05
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This complaint is mentioned. Bad customers who complain and it goes to court. Good read.
I copied and pasted what seemed relevant. Sorry it’s Long
USPS report
, the Commission identified eight non- compensatory Market Dominant products that did not generate sufficient revenue to cover their attributable costs in FY 2019: (1) Periodicals In- County, (2) Periodicals Outside County, (3) USPS Marketing Mail Flats, (4) USPS Marketing Mail Parcels, (5) Inbound Letter Post, (6) Media Mail/ Library Mail, (7) Stamp Fulfillment Services,
and (8) Market Dominant negotiated service agreement (NSA) with PHI Acquisitions, Inc.104
The Commission found that additional transparency was necessary to hold the Postal Service accountable with respect to Periodicals
In-County and Periodicals Outside County. The Commission stated it would continue to explore cost and service issues related to flats
advanced remedy in light of the repeated failure of USPS Marketing Mail Parcels to cover its costs.109
Third, the Commission evaluated Competitive products for compliance with 39 U.S.C. §
3633(a) in FY 2018. The Commission found that Competitive products complied with sections 3633(a)(1) and (3) because Market Dominant products did not subsidize Competitive products, and Competitive products collectively covered
an appropriate share of the Postal Service’s institutional costs.110 The Commission also determined that revenues for six Competitive products did not cover their attributable costs and, therefore, did not comply with 39 U.S.C.
§ 3633(a)(2).111 The Commission directed the Postal Service to take corrective action, such
as monthly reporting and providing additional transparency on investigations of cost estimates and rate and revenue discrepancies.112
Fourth, the Commission evaluated FY 2018 service performance for each Market Dominant product and found that service performance results decreased for most products compared
to FY 2017.113 The Commission noted that the Postal Service met its service performance targets for USPS Marketing Mail High Density and Saturation Letters, USPS Marketing Mail Parcels, Bound Printed Matter Parcels, and
most Special Services products.114 However, service performance targets were not met for
all First-Class Mail products, both Periodicals products, USPS Marketing Mail High Density and Saturation Flats/Parcels, USPS Marketing Mail Carrier Route, USPS Marketing Mail Letters, USPS
in Docket No. RM2018-1.
106
For USPS Marketing Mail Flats, the Commission found that this product remains in violation of 39 U.S.C. § 101(d) and that the Postal Service has failed to comply with the Commission’s FY
2010 ACD directive to increase cost coverage. In the FY 2018 ACD, the Commission directed that in the next generally applicable Market Dominant rate adjustment, the Postal
Service must propose a rate increase for USPS Marketing Mail Flats that is at least 2 percentage points above the USPS Marketing
Mail class average.
Parcels, the Commission found that revenue was not sufficient to cover attributable cost in FY 2018 and strongly recommended an
107
108
For USPS Marketing Mail
Public inquiry dockets are established by the Commission to provide a venue to explore issues of general interest. Three public inquiry dockets
were before the Commission in FY 2019 that dealt with matters related to service performance, Inbound Letter Post, and city carrier costs.
City Carrier Costs
Another public inquiry docket concerning
city carrier costs was also pending before
the Commission in FY 2019. In FY 2017, the Commission established Docket No. PI2017-1
to evaluate the Postal Service’s progress in
its ongoing efforts to update its city carrier
cost models and data collection capabilities
as required by the Commission.187 This docket has focused on the feasibility of a top-down, single-equation model to improve the Postal Service’s variability estimates of city carrier cost drivers.188 The Commission issued several CHIRs and provided an opportunity for interested persons to comment.189
transfer Inbound Letter Post small packets and bulky letters from the Market Dominant Inbound Letter Post product to the Competitive product list in Docket No. MC2019-17.186
On November 2, 2018, the Commission issued
an interim order in this proceeding. The Commission stated that based on the Postal Service’s CHIR response and comments received, additional data are necessary to evaluate whether the Postal Service’s city carrier costing models can be improved.190 Accordingly, the Commission directed the Postal Service to provide an expanded dataset of city carrier delivery data, as well as report quarterly on the status of developing the expanded dataset.191 In FY 2019, the Postal Service began providing data as requested in that order. This proceeding is currently pending before the Commission.
Postal Service explains that the existing SPR attributable cost model is based on a study presented in Docket No. R97-1.209 It notes that there have been substantial changes in the activities performed by SPR carriers since that time, which require an update and refinement of that study.210
The Postal Service asserts that the new study makes several improvements to the analysis
of SPR.211 First, to ensure that its structure reflects current operational practice and management, the new study is based upon ongoing consultations with Postal Service carrier operations experts.212 Second, the new study uses ongoing operational databases, which greatly expands the scope of the analysis, and includes data from all SPR locations in the country.213 Third, the new study explicitly accounts for the December peak in package volumes to determine product costs and allows for other seasonal variation throughout the year.214 Fourth, the study incorporates the differences in wages for different types of SPR carriers when forming cost pools.215 Fifth, for the first time, the new study explicitly models Sunday package delivery costs based upon actual packages delivered.
