impact of the Great Recession was to count the yearly volume loss once for each year, by class. Id. Table 2 contains the total volume loss due to the Great Recession as determined by the Commission in Order No. 1926. Table 2 The Commission’s determination that is lost once” was vacated on “volume appeal. In the ANM decision, the Court upheld all but the final step of the total volume loss estimation process and vacated the once” rule. ANM at *8. The Court “count rejected the Postal Service’s challenge to the Commission’s use of the modified Thress model and found that Commission’s econometric analysis was well within the wide “the bounds of agency expertise.” Id. at *1, *7. The current issue on remand is how to count volume until the impact of the exigent circumstance ended as determined through the normal” analysis. “new Comments Postal Service proposal Postal Service proposal. The Postal Service asserts that the Commission must the effects of the once’ rule” consistent with the Court’s decision in “eradicate ‘count ANM. Postal Service Comments at 6. The Postal Service argues that removing the once” rule is simple.” Id. The Postal Service develops this “count “computationally simple” analysis using the yearly volume loss estimates developed by “computationally the Commission in Order No. 1926. Specifically, the Postal Service proposes that “the actual annual volume loss in each year is the combination of volume first lost in that year, plus annual volume lost in the previous year.” Id. at 26. In Table 3, which has been reproduced from the Postal Service’s comments, the Postal Service illustrates the impact of eliminating the once” rule for each market dominant class of mail until “count each class reached the normal” cutoff date. Id. at 27. “new
impact of the Great Recession was to count the yearly volume loss once for each year, by class. Id. Table 2 contains the total volume loss due to the Great Recession as determined by the Commission in Order No. 1926. Table 2 The Commission’s determination that “volume is lost once” was vacated on appeal. In the ANM decision, the Court upheld all but the final step of the total volume loss estimation process and vacated the “count once” rule. ANM at *8. The Court rejected the Postal Service’s challenge to the Commission’s use of the modified Thress model and found that “the Commission’s econometric analysis was well within the wide bounds of agency expertise.” Id. at *1, *7. The current issue on remand is how to count volume until the impact of the exigent circumstance ended as determined through the “new normal” analysis. Comments Postal Service proposal Postal Service proposal. The Postal Service asserts that the Commission must “eradicate the effects of the ‘count once’ rule” consistent with the Court’s decision in ANM. Postal Service Comments at 6. The Postal Service argues that removing the “count once” rule is “computationally simple.” Id. The Postal Service develops this “computationally simple” analysis using the yearly volume loss estimates developed by the Commission in Order No. 1926. Specifically, the Postal Service proposes that “the actual annual volume loss in each year is the combination of volume first lost in that year, plus annual volume lost in the previous year.” Id. at 26. In Table 3, which has been reproduced from the Postal Service’s comments, the Postal Service illustrates the impact of eliminating the “count once” rule for each market dominant class of mail until each class reached the “new normal” cutoff date. Id. at 27.