demonstrate that the budget- and performance-driven operational decision making process ensures efficient processing. Id. at 71-72. In its reply brief, the Postal Service describes what it sees as shortcomings in the OIG Audit Report. Id. at 76-81. The Postal Service asserts that the OIG Audit Report imprecisely and incorrectly uses the term processing.” Id. at 79. It also argues “manual that the report lacks the documentation normally required of studies relied upon in Commission proceedings, and that it gives only general descriptions of the methodology, assumptions and calculations it uses. Id. at 79-80. The Postal Service’s reply brief also introduces arguments that data filed with the Commission in previous dockets support its claim that its treatment of Netflix mail improves the overall efficiency of mail processing. The Postal Service asserts that, while the nominal unit cost of single-piece First-Class Mail letters increased between FY 2005 and FY 2009, it has not increased as quickly as has the mail processing hourly labor cost. While conceding that this analysis is not conclusive, the Postal Service states that the decline in mail processing costs” can be explained by the claims of “‘real’ witnesses Belair and Seanor that one-touch processing of Netflix reduces the cost of DVD mailers. Id. at 74-75. The Postal Service states that MODS data do not reflect the hours in collection mail separation operations that would be implied by the high cost scenarios in the Christensen Study. Id. at 75. It also asserts that the In-Office Cost System (IOCS) is able to identify the cost of Permit Reply Mail (PRM), and that the cost of this type of mail exhibits a lower average cost per piece than the remainder of single-piece First-Class Mail letters. Id. at 76. GameFly disputes the Postal Service’s claim that cost reductions GameFly’s position. underlie its extensive manual processing of Netflix DVD return mail and asserts that the true reason is to minimize disc breakage. GameFly Brief at 67-68. Supported by the analysis of witness Glick, GameFly asserts that, rather than reducing costs, the Postal Service’s manual processing of Netflix mail greatly increases costs. GameFly Brief-NP at 68. It argues that the Postal Service witnesses’ claims of efficiency gains from the
demonstrate that the budget- and performance-driven operational decision making process ensures efficient processing. Id. at 71-72. In its reply brief, the Postal Service describes what it sees as shortcomings in the OIG Audit Report. Id. at 76-81. The Postal Service asserts that the OIG Audit Report imprecisely and incorrectly uses the term “manual processing.” Id. at 79. It also argues that the report lacks the documentation normally required of studies relied upon in Commission proceedings, and that it gives only general descriptions of the methodology, assumptions and calculations it uses. Id. at 79-80. The Postal Service’s reply brief also introduces arguments that data filed with the Commission in previous dockets support its claim that its treatment of Netflix mail improves the overall efficiency of mail processing. The Postal Service asserts that, while the nominal unit cost of single-piece First-Class Mail letters increased between FY 2005 and FY 2009, it has not increased as quickly as has the mail processing hourly labor cost. While conceding that this analysis is not conclusive, the Postal Service states that the decline in “‘real’ mail processing costs” can be explained by the claims of witnesses Belair and Seanor that one-touch processing of Netflix reduces the cost of DVD mailers. Id. at 74-75. The Postal Service states that MODS data do not reflect the hours in collection mail separation operations that would be implied by the high cost scenarios in the Christensen Study. Id. at 75. It also asserts that the In-Office Cost System (IOCS) is able to identify the cost of Permit Reply Mail (PRM), and that the cost of this type of mail exhibits a lower average cost per piece than the remainder of single-piece First-Class Mail letters. Id. at 76. GameFly’s position. GameFly disputes the Postal Service’s claim that cost reductions underlie its extensive manual processing of Netflix DVD return mail and asserts that the true reason is to minimize disc breakage. GameFly Brief at 67-68. Supported by the analysis of witness Glick, GameFly asserts that, rather than reducing costs, the Postal Service’s manual processing of Netflix mail greatly increases costs. GameFly Brief-NP at 68. It argues that the Postal Service witnesses’ claims of efficiency gains from the
Order_No_718.docx