Testimony Of Robert Cohen On Behalf Of The Postal Rate Commission Before The U.S. House Of Representatives Committee On Government Reform, Subcommittee On The Postal Service

Testimony Of
Robert Cohen
On Behalf Of The
Postal Rate Commission
Before The
U.S. House Of Representatives
Committee On Government Reform
Subcommittee On The Postal Service
 
March 9, 2000
DRAFT
R.Cohen
Testimony
Chairman McHugh, members of the Committee on Government Reform, Subcommittee on the Postal Service, I am pleased to testify here today on behalf of the Postal Rate Commission. I am the Director of the Commission’s Office of Rates, Analysis and Planning. For a number years I have prepared studies for international mail conferences and worked with members of foreign postal administrations. Consequently, the chairman gave me the responsibility of working with the State Department when it became responsible for dealing with the Universal Postal Union (UPU). For this reason he also asked me to testify here today.
First I intend to discuss briefly the Commission’s international mail report. Because Chairman McHugh’s letter of invitation indicated that this hearing will concentrate on U.S. policies concerning the international exchange of documents and parcels, most of my testimony will deal with the recent transfer of authority for UPU policy and representation to the State Department.
The Commission’s Report to the Congress
As you know, legislation amended Title 39 of the U.S. Code in November, 1998, and required the Commission to provide Congress with a comprehensive report on International mail costs, volumes and revenues. The Commission completed its first report and transmitted it to Congress on June 30, 1999.
In order to carry out its new responsibilities, the Commission first asked interested parties for their views on 1) the scope of the report, and 2) on what data the Commission should require from the Postal Service in order to prepare the report. The Commission sent a number of requests for data and information to the Postal Service. The Service provided the data requested by the Commission, but it also pointed out that under existing law, Postal Service business information which a private firm would not normally disclose must be kept confidential. For that reason, the Commission has not made its entire report public. Instead it has provided the public with a version from which a small amount of sensitive information has been redacted. The highlights of the report are contained in the Attachment to this testimony.
After our report was issued, the Commission provided additional analyses in response to a request from Chairman McHugh. One of the more difficult questions still outstanding is the extent to which inbound and outbound mail flow data can, or should, be combined. The Commission has tried to accommodate interested members by providing data in disagregated form so that it can be combined as the user sees fit.
Since the preparation of the report did not involve a section 3624 proceeding, members of the Commission’s Consumer Advocate’s staff worked with the advisory staff on the study. In preparation for its second report the Commission has just completed a formal rulemaking on the scope of the report and the data to be supplied by the Postal Service. The Service will be submitting the data by March 15, and the Commission will commence work on its second report.
A PRC Perspective on the Activities Resulting from the Transfer of Authority to the State Department
In November 1998, at the same time the Commission was given its new international responsibility, Congress also transferred responsibility for UPU policy and representation from the Postal Service to the State Department. Soon after the legislation was enacted, the State Department formed an interagency advisory group consisting of the Justice (Antitrust Division) and Commerce departments, the U.S. Trade Representative, the Postal Service and the Postal Rate Commission. State also held public meetings and sought the views of individuals from the Postal Service and other groups with an interest in UPU policy. Representatives of the