COMMENTS OF THE APWU, AFL-CIO BEFORE THE PRC
REGARDING THE NOTICE OF MARKET DOMINANT PRICE ADJUSTMENT – Docket No. R2013-10
The American Postal Workers Union, AFL-CIO (APWU) hereby objects to the methodology used by the Postal Service in calculating workshare discounts in this price adjustment. The Postal Service provides limited explanation or justification for its change in calculating the size of the discount that is to be compared with the avoided cost number. In the past, that discount has always been compared with the single piece letter rate. The Postal Service has now split the single piece letter rate into a stamped letter rate and a metered letter rate and is calculating the discounts from the lower rate. The effect of this change is to adversely affect rates and services provided to users of postal services who do not take advantage of the discount rates. These discounts are, therefore, in violation of Sections 3622(e)(2) and 3622(e)(4)(C) of the Act.
Darryl J. Anderson, Esq.
Counsel for American Postal Workers Union, AFL-CIO
O’Donnell, Schwartz & Anderson, P.C.
1300 L Street NW Suite 1200
Washington, DC 20005-4126
Voice: (202) 898-1707
DAnderson@odsalaw.com
October 18, 2013
via: PRC
Doh! I was domain searching at namecheap.com and went to type in the domain name: http://www.postal-reporter.com/blog/apwu-objects-to-the-methodology-used-by-usps-in-calculating-workshare-discounts/ and guess who already purchased it? You did! lol j/k. I was about to buy this domain name but noticed it had been taken so I figured I’d come check it out. Wonderful blog!