,.-.
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
POSTAL RATE AND FEE CHANGES,
1997
:
DOCKE:T NO. F!97-1
,,-.
DIRECT TESTIMONY OF
MICHFLEL A. NELSON
ON BEHALF OF
THE UNITED STATES POSTAL SERVICE
.CONTENTS
AUTOBIOGRAPHICAL
SKETCH....................................1
PURPOSE AND SCOPE OF THIS
TESTIMONY .....................
I.
- Volume
.......
...3
Labor
Distribution
Code (LDC) 24 overlap..
............
Express
Mail
collection
box load time ..............
Letter
route
driving
time ..........................
Special
purpose
routes
.............................
Special
delivery
messengers
........................
...5
...5
...6
...7
Analytical
A.
B.
C.
D.
E.
II.
Other
A.
B.
C.
D.
E.
...2
Refinements
Variable
Costs
Work ..........................................
Express
Mail
interfacility
service
..................
Express
Mail
collection
box access
and fixed
stop
Allocation
of Cost Segment 9 fixed
costs..
............
Expr,ess
Mail
rate
category
cost differentials........1
Cost basis
for pickup
fees...........................1
.
...8
..a
time8
.
0
0
,,-,..
USPS-19A
- Spreadsheet
USFS-19B
- Data
USPS-19C
- Econometric
USEIS-19D
- Express
USFS-19E
- Cost
--
Refinements
Collection
And Analysis
Procedures
Analyses
Mail
Basis
Rate
For
Category
Pickup
Fees
Cost
Differentials
,.r---
AUTOBIOGRAPHICAL
1
My name its Michael
2
,,r-.
3
tra.nsportation
4
Vermont
5
1984,
6
Assiociates,
7
Mas:sachusetts.
A.
Research
an economic
9
assiignments
directed
and
10
transportation.
11
applying
12
microeconomics,
13
specialized
14
Service,
15
Doc!ket
16
principal
17
carrier
18
Kolbe
19
regarding
20
railroad
21
Commission,
22
(Finance
Docket
23
Industries
of
24
(Finance
25
consolidation
26
No.
27
Doc:ket
or
research
investigator
for
R84-1.
No.
Nos.
of
the
30800),
of
the
32133),
portions
Do&et
No.
control
of
31522
Southern
acquisition
and
the
field
to
of
served
of
provided
issues
31505,
respectively),
extensive
1
A.
Lawrence
testimony
in
six
Commerce
Pacific
by Rio
Soo Line
of
in
as
Interstate
C&NW by Union
with
Parcel
delivery
CM&W and
Pacific
solve
United
city
acquisition
and
and
Commission
testimony
the
of
developing
of
statistical
before
consulting
general
and
also
River
research,
R90-1,
I have
and/or
including
the
this
the
proceedings
merger
Boston,
numerous
studies
underlying
competitive
32000),
the
February
in
On behalf
and
to
econometrics
before
R87-1
Stamford,,
Charles
on operations
and/or
in
at
involves
testimony
No.
in
problems.
F!Jl86-2B,
Docket
in
typically
statistics
time
firm
projects
analytical
in
Associate
based
I provided
Prior
participated
methodologies
street
offices
consulting
My work
No.'s
with
Massachusetts.
I was ;a Senior
I have
I am an independent
analyst
systems
and Wellesley,
8
Nelson.
SKETCH
Grande
railroads
DRGW (Finance
MKT by Union
Pacific
testimony
regarding
the
Docket
(Finance
the
1
anticompetitive
effects
2
Pacific
and
3
assisted
in
4
statements
5
bodies,
6
transportation
Santa
the
8
Institute
9
master's
the
(Finance
proposed
of
before
No.
other
my bachelor's
of
verified
and
reports
(Transportation
11
School
12
operations
13
public
of
degree
Technology
degrees
in
from
one
from
In
in
and one
with
Management,
sector
1977.
MIT,
Systems)
and
legal
articles;
in
Massachusetts
I received
Civil
two
Engineering
from
the
Alfred
concentrations
in
systems
P. Sloan
economics,
analysis
and
management.
--.
PURPOSE AND !XOPE OF THIS
14
testimony
costs
the
1978,
tran~sportation
research,
This
I have
regulatory
technical
Southern
journals.
10
15
of
30400).
numerous
various
many
merger
Docket
preparation
authored
I received
7
Fe
presented
and
of
presents
the
Cost
Segments
6 (City
7 (City
Delivery
16
the
in
17
Activity),
18
(Special
19
the
20
data
21
activities,
22
driving
time
23
include
improvements
24
compute
volume
25
other
26
that
have
27
(see
Exhibit
Delivery
results
of
collections
of
related
special
on motorized
variable
information.
been
This
introduced
the
purpose
as well
testimony
in
the
USPS-19A).
--
These
of
also
cost
methods
as the
documents
segment
Office
and
9
presents
and
route
activities
routes.
accuracy
costs,
it
refinements
messenger
of
Activity)
particular,
special
letter
portions
Carriers,
Street
analytical
to
of
Delivery
In
delivery
in
development
Carriers,
Messengers)
a series
TESTIMONY
new
carrier
and
refinements
used
to
development
of
changes
spreadsheets
-.
.T--
1
I.
Analytical
.2
Specific
3
implemented
4
described
5
using
analytical
6
and messenger
in
- Volume
Variable
refinements
the
computation
These
below.
data
derived
that
of
four
have
volume
refinements
from
Costs
been
variab:Le
have
been
new field
costs
are
implemented
surveys
of
carrier
activities:
7
- Motorized
a
- Special
9
- Expedited
Letter
Route
Purpose
Survey
Route
Mail
Survey
Survey
- LDC 24 Survey
10
,/--
Refinemen,ts
11
These
surveys
12
A.
Labor
13
In
general,
14
charged
to
15
messenger
16
costs.
17
the
activities
18
that
perform
19
and/or
20
In
21
carrier
22
with
23
Express
24
of
25
purpose
are
described
Distribution
Code
special
(delivery
which
LDC 24,
craft
employees
Significant
of
of
activity
in
for
route
to
LDC 24
craft
activ:ity
Cost
for
(and
Cost
Express
Segment
attributing
carriers
Comnonents
CS 9)
6.l
the
street
associated
with
USPS Devew
(Fiscal
Year
3
:routes
Mail
observations
can
have
been
has
served
costs
of
Express
of
1996),
CS 9
from
delivery
98 that
This
of
to
Express
special
Mail
However,
result
assigned
reflecting
Type
9.
a portion
of
and
is
Segment
employees
Mail
on :Route
,-.
and
24 overlap
distribution
involving
Mail
ts
account
Exprsess
time
USPS-19B
messenger
only
IOCS tallies
past,
(LDC)
in
interfacility
street
"proxy"
carrisr
Exhibit
accrues
charges
delivery
the
in
items.
of
be associated
attributed
as a type
,special
Mail
Costs by
USPS-LR-H-1.
to
1
distribution
2
activities
3
also
4
largely
5
situation
6
subject
7
caused
8
Segment
and
are
appear
has
carrier
to
6 and
11
been
observed
directly
12
24 Survey,
13
performed
14
special
purpose
15
carrier
street
16
the
17
respectively)
18
data
19
parameters,
20
is
Cost
these
properly
23
they
are
in
this
matched
apply,
and
with
the
the
overlap
which
this
the
have
Cost
have
been
and
Special
in
these
pools
develop
other
problem
and
to
directly
(in
Route
Segment
7.
Survey,
The
information
1 and Workpaper
procedures
accrued
is
use
variability
needed
costs
eliminated.
2.
are
to
which
As a
which
has provided
much of
2The Support
Route Cost Survey,
the information
used to attribute
the costs
of special
predates
the proliferation
of Express
Mail
purpose
routes,
distribution
and delivery
responsibilities
among such
carriers.
4
LDC
is
accrue
Purpose
Cost
and
activities
observed
analysis
of
LDC 24 have
Survey
that
Workpaper
cost
to
messenger
to
and
special
Mail
activities
keys
the
accrue
of
surveys
USPS-C,
approach,
in
both
and
Similarly,
analyzed
different
Exhibit
in
Expedited
carrier
distribution
shown
that
9.
Survey
and
of
activities
Mail
Analysis
LDC's
Mail
are
result
double-count,
messenger
the
Segment
time
Expedited
22
(in
route
9 (which
The net
delivery
activities
respectively).
in
therefore
9.
collections,
carrier
from
or
such
and
Segment
Mail).
by Express
Segment
route
LDC 24,
Cost
and
be borne
new data
purpose
With
Elxpress
an overlap,
Cost
to
in
distribution
costs
the
costs
to
been
However,
charged
as accrued
10
21
activities.'
routinely
distributed
In
9
delivery
of
f--
-
I.
result,
2
previously
3
removed.
B.
5
To date,
6
boxes
7
all
a
boxes
9
does
proxy
for
used
4
Express
has
in
the
boxes
11
to
their
volume
12
particular,
the
13
collection
boxes
14
that
15
empty.3
16
always
contain
17
during
a day
is
for
analysis
procedures
20
each
box
type,
21
time
factors
22
with
sweeps
to
24
In
No.
of
with
respect
when
collection
swept,
boxes
to
boxes
be swept
Mail
and
be
almost
repeatedly
overflowing.
operational
park-and-loop
and
of
Mail
the
accrued
application
volume-variable
driving
R90-l,,
differences,
separation
development
Express
route
Mail
Express
such
to
approach
In
that
for
and may have
determine
C. Letter
Docket
regular
include
and
Express
many pieces
commonplace
these
23
analysis
contain
avoid
this
boxes
reveal
of
collection
characteristics.
data
been
allocation
However,
between
time
has
collection
Mail
collection
new survey
19
25
load
and
Mail
Express
boxes.
ordinary
mail,
of
between
activity
time
a proportional
and
By comparison,
To account
load
using
differences
reasonably
unneeded
Express
for
rarely
street
sweeping
costs
and
to
6 is
box
collection
account
collection
it
of
load
ordinary
not
Segment
estimated
collection
Mail-related
collection
cost
been
and
Express
Cost
Mail
10
18
/--
the
collection
costs
of
costs
new
for
new load
associated
boxes.4
time
the
Commission
driving
LR-USPS-H-153.
for example,
'See,
'See Exhibit
USPS-19A.
5
time.
adopted
That
a new
analysis
was
1
less
developed
2
(a)
3
activities
other
4
limitation
to
5
d~istribution
6
related)
7
account
8
other
it
contained
(noncurbline)
11
types
12
separately.
13
points
14
estimated
15
deliveries'
16
keys
17
in
18
the
19
deliveries'.
the
role
might
regarding
looping;
points,
it
reflected
for
did
the
such
occurrence
be desirable
of
parking
(b)
not
point
even
given
utilize
points;
its
a
underlying
(weight-
and
similar
because
(c)
driving
it
did
not
activities
on
types.
new analytical
driving
motorized
procedures
between
time
letter
routes
The different
are
are
than
routine
causality
the
10
that
the
route
of
than
looping
cost
for
accurate
no information
key
Under
9
and
accounted
for
and
is
in
identified
and volume
looping
which
formation
of
routine
of
types
of
on all
and
studied
at
parking
occur
variability
is
points/dismounts',
driving.
the
role
loops
mail
employed,
points
that
collection-related
developed
the
parking
activities
fo?,
routine
I have
that
SSee Workpaper
1.2.
6See Workpaper
1.14.
'Deviation
deliveries
are nonroutine
those
sometimes
made for expedited
The effect
of volume
on the number
estimated
in Exhibit
USPS-19C.
8See Workpaper
1.10.
9!;ee Workpaper
1.9.
of
is
"deviation"
New distribution
the
weight
accounted
cause
f,or",
of
mail
as is
deviati,on
delivery
stops,
such
items
or large
parcels.
of such stops
is
as
,-.
1
D.
2
The time
3
distribution
4
(costs
5
.updating.
6
,time
7
date.
9
,-
purpose
routes
proportions
(by
keys
are
used
to
approximately
the
analyze
of
10
estimate
11
new econometric
12
related
13
These
14
presented
drive
variability
in
15
E.
16
To date,
aggregate
18
has
19
driving
20
time),
21
characteristics
out
time
used",
analyzing
spent
at
of
A refined
is
for
of
SPR load
regarding
keysI'.
Exhibit
need
and
coverage-
delivery
stops.
USPS-19C,
and
analyzed
in
USPS-LR-H-160.
Special
17
in
in
somewhat
developed
time
route
analyze
are
developed
the
described
are
variability
are
and
are
to
distribution
time-to-stop
class
purpose
and
used
are
delivery
models
models
special
variability
new data
and
proportions1D
and major
old,
models
coverage-related
my analysis,
function)
17 years
Similarly,
and
In
8
I---
Special
delivery
messenger
as
obscured
time
as well
a
function
functional
vs.
messengers
run
of
stop
as differences
been
delivery-related
differences
delivery
(e.g.,
has
time
in
time
accountables
parameters.
cost
vs.
related
causality
nondelivery
to
vs.
the
This
(e.g.,
stop
mail
nonaccountables)
.
loSee Workpaper
1.5.
"See Workpapers
1.6,
1.7 and 1.8.
I'In Docket
No. R90-1,
t,he Commission
adopted
changes
in the
methods
used to compute
SPR driving
time-to-stop
variability
Access
Test
(PAT)".
I have
from the results
of the "Parcel
reviewed
those
changes
and concluded
that
they reasonably
correct
for the influences
of walk and travel
activitiles
in
the original
PAT. In my analysis,
I use the adjusted
drive
time-to-stop
variability
estimate
of 0.6342.
7
1
Also,
2
somewhat
3
In
4
substantial
5
variable
6
and
7
development
8
coverage-related
9
stops=,
the
data
used
keys".
11
II.
my analysis,
new data
enhancement
costs
of
Other
A.
13
To date,
to
16
activities.
17
volumes
18
entirely
19
result,
20
quite
21
activities.
22
of
23
piece
in
developed
functional
that
have
become
provide
detail.
driving,
customer
activities
are
identified.
This
new econometric
models
and
creation
of
for
the
delivery
includes
analyzing
time
spent
new delivery
a
volume
with
Mail
interfacility
at
delivery
distribution
there
has
service
been
no explicit
interfacility
Express
Mail
from
Such
moving
in
these
c,ther
small
Mail
movements
different
from
types
most
vehicles
service,
of
carrier
piece
established
characteristics
carrier
are
do not
and
caused
vary
volume.
Exhibit
USPS-19C and USPS-LR-H-160.
Workpapers
2.5,
2.6 and 2.7.
8
messenger
requirements.
cost
they
dedicated
modest
on schedules
other
but
or
involve
distribution
have
to
movements
typically
In particular,
Mail
analysis
distribution
movements
by Express
Express
I'See
I'See
are
associated
the
Express
15
keys
Work
12
differentiate
distribution
variability
and
14
develop
outdated.
collection
10
to
As a
that
are
messenger
by the
measurably
existence
with
/--
/-
/--
1
In
2
associated
with
3
separately
in
4
B.
5
The method
my analysis,
Express
messenger
interfacility
Cost
Segment
Mail
collection
6
Commission
7
costs
a
proportion
to
the
fraction
9
boxes
of
all
collection
(a)
the
involved
form
10
the
fact
11
at
12
sweeps
13
distribution
14
volume-related
15
pieces
16
properly
17
types
the
same points
volume
Express
requirements
of
and
reasons.
nor
the
of
be viewed
as causing
boxes
swept.
18
In
my analysis,
19
associated
with
20
identified
separately
21
C. Allocation
22
The allocation
does
driving
sweeps
in
of
Cost
of
not
of
clearly
identify
24
legitimate
25
accounted
for.
The lack
26
allocation
is
demonstrated
27
evident
purpose
in
the
when
new survey
Mail
data.
9
where
both
time
7 and Cost
Segment
are
9.
costs
costs
in
Cost
costs,
costs
for
functional
Over
Mail
boxes
variable
by the
made for
collection
9 fixed
a foundation
(b)
can
stop
product-specific
of
or,
Express
service
fixed
Segment
fixed
of
for
be located
never
stop
Mail
volume
to
essentially
and
Segment
account
by outbound
Express
Cost
not
tend
a vehicle
residual
23
did
volume
in
collection
governed
Express
time
Mail
together;
the
the
access
serviced
are
Neither
existence
are
are
time
and
Express
Mail
boxes
stop
Service
to
This
of
often
fixed
Postal
Express
types
boxes
and
costs
if ied
9.
collection
boxes.
are
Mail
such
ident
Segment
access
by the
that
two
are
variable
of
and
activities
Cost
box
allocation
that
of
7 and
used
analyze
carrier
distribution
previously
to
and
11% of
Segment
and
have
such
an
diversity
messenger
has
been
9
no
1
vehicle
stops,
2
are
3
movements
not
4
sweeps
of
ordinary
5
caused
by multiple
6
example,
pickup
7
conducted
for
8
Express
9
the
associated
11
type
12
causal
13
messenger
14
identified
15
of
D.
sulzh
23% of
to
mai:
entails
Mail
diversity
in
foundation
for
and
its
handled
beyond
there
the
costs
16
See Exhibit
17
E.
18
See Exhibit
Cost
Mail
rate
category
USPS-19D.
basis
for
pickup
fees
USPS-19E.
15See Workpapers
2.1
and
2.2.
10
cost
in
light
fixed
that
as
by
of
is
are
differentials
far
pickup
this
no
portion
as incremental.
Express
that
by messengers
In
are
is
as well
show
post.
and
For
and
post
data
to
the
stops,
service
services.
activities,
allocating
at
activities
own fee,
parcel
messenger
time
These
new survey
or
spent
pickup
and parcel
pieces
Priority
street
boxes.15
Mail
the
Mail,
subclasses
the
time
as interfacility
Express
collection
Indeed,
the
activities
service
of
are
with
Priority
majority
service
almllst
dedicated
Mail.
10
and
properly
of
I-.
Exhibit
USPS-19A
SEESALISH~~T
New spreadsheets
time
on motorized
distributions
street
In
addition,
containing
(W/S 7.0.5),
further
w/s
9.
letter
(W/S 9.0.3,
time
spreadsheet
7 and
been
created
routes
These
detail
as
well
and
with
cost
special
as in
changes
analysis
other
new spreadsheets
analysis
of
messenger
on W/S 9.0.5.1-
have
special
changes
driving
cost
delivery
been
made
purpose
spreadsheets
and
of
with
distributions
substantial
the
for
(W/S 7.0.4.X,
on W/S 7.0.6.17)
9.0.5.5).
1.
have
REiLU'JFMENTS
in
are
Cost
in
routes
Segments
described
in
below:
7.0.4.x
Line
1
Accrued
3
Drive-to-stop
previously
Salesman
variability
cost
input
from
W/S 7.0.4.1.
variability
- the figure
of 0.5 has
by the Conlmission,
and is based on the
Model".
It is the best available
estimate
parameter.
the
been used
"Traveling
for this
4
Stop-to-activity
variability
- As documented
19C, econometric
analysis
was undertaken
to
to which
the number c,f vehicle
stops varies
carrier
activities.
in Exhibit
USPSmeasure the degree
with
the number of
5
Deviation
delivery-to-piece
variability
- As documented
in
Exhibit
USPS-1X,
econometric
analysis
was undertaken
to measure
the degree
to which the number of deviation
delivery
stops
varies
with
the number of pieces
requiring
deviatj.on
delivery.
6
variability
of routine
loops/dismounts
- As documented
in
an estimate
was developed
of the degree
to which
Workpaper
1.14,
the number of routine:
loop/dismount
points
varies
with
volume
(weight).
6,
EXHIBIT
Activity-related
Rule.
drive
costs
= L1 x L3 x L4,
Activity-related
Workpaper
1.2.
drive
costs
distributed
Volume-variable
are distributed
Workpaper
1.9.
deviation
delivery
in W/S 7.0.6.17,
w/s
on the
activities
Chain
based
on
costs
= L9d x L5. These costs
based on the data developed
in
Volume-variable
routine
loop/dismount
costs
are distributed
in W/S 7.0.6.17
distribution
of mail
weight
developed
2.
to
based
USPS-:L9A
PAGE 2
costs
= L9g x,LS.
These
based on the estimated
in Workpaper
1.10.
7,.0.5
l-7
Development
of
accrued
8
Drive-to-stop
9
Stop-to-activity
variability
- As documented
in Exhibit
USP,S19C. econometric
analysis
was undertaken
to measure
the degree
to which
the number of vehicle
stops varies
with
the number of
carrier
activities.
variability
costs.
- See USPS-T-19,
Section
I.D.
‘-.
10
14-16
17
19-25
26a
Individual
delivery-to-piece
variability
- As documented
in
Exhibit
USPS-19C.
econometric
analysis
was undertaken
to me,lsure
the degree
to which
the number of individual
delivery
stops
varies
with
the number of pieces
requiring
individual
deliwry.
Delivery
stop time variabilities
- As documented
in Exhibit
USPS-lYC,
econometric
analysis
was undertaken
to measure
ths?
degree
to which
the time spent at individual
delivery
stops
varies
with
the number of such stops made, the number of
accountable
pieces
delivered
and the number of nonaccountable
pieces
delivered.
Activity-related
Chain Rule.
drive
costs
= L6C5 x LB x L9,
Activity-related
Workpaper
1.3.
drive
costs
distributed
Volume-variable
individual
delivery
driving
These costs
are distributed
in W/S 7.0.6.13,
developed
in Workpaper
1.8.
to
based
activities
on the
baseei
on
costs
= LlO x L'22C5.
based on the d.ata
EXHIBIT
USPS-19A
PAGE 3
Lines
35
Volume-variable
accountable
delivery
costs
are distributed
in W/S 7.0.6.4
in Workpaper
1.7.
36
Volume-variable
nonaccountable
These costs
are distributed
developed
in Workpaper
1.6.
= L15 ,x L22C6. These
on the data developed
delivery
costs
= L16 x L22C6.
W/S 7.0.6.3
based son the data
Volume-variable
fixed
time
at stop costs
= LlO x L14 x L22C6.
These costs
are distributed
in W/S 7.0.6.10
based on the data
developed
in Workpaper
1.8.
44
3.
in
costs
based
w/s
1-3
9.0.3
Develo,pment
of
accrued
4
Drive-to-stop
5
Stop-to-activity
variability
- As documented
19C. econometric
analysis
was undertaken
to
to which
the number of vehicle
stops varies
messenger
activities.
6
Customer
delivery-twpiece
variability
- As documented
in
Exhibit
USPS-lYC,
econometric
analysis
was undertaken
to measure
the degree
to which
the number of customer
delivery
stops
varies
with
the number of pieces
requiring
customer
deli.rery.
,/.---
10-12
13
14a14f
15
variability
costs.
- unchanged.
in Exhibit
USPSmeasure
the degree
with
the number of
Delivery
stop time variabilities
- As documented
in Exhibit
USPS-19C.
econometric
analysis
was undertaken
to measure the
degree
to which
the time
spent at customer
delivery
stops varies
with
the number of such stops made, the number of accountable
pieces
delivered
and the number of nonaccountable
pieces
delivered.
Activity-related
Chain Rule.
drive
costs
= L3C5 x L4 x L5,
Activity-related
Workpaper
2.1.
drive
costs
distributed
volume-variable
customer
delivery
driving
costs
= L6 x (C5L14c + (C6L14c x LlO)).
distributed
in W/S 9.0.5.1
based on the
Workpaper
2.5.
to
based
activities
on the
based
and fixed
time at
These costs
are
data developed
in
on
stop
EXHIBIT
USPS-19A
PAGE 4
Llinem
20
Volume-variable
accountable
delivery
costs
are distributed
in W/S 9.0.5.4
in Workpaper
2.6.
21
Volume-variable
nonaccountable
These cmts
are distributed
developed
in Workpaper
2.7.
4.
a.
on
significant
The
the
This
costs
allocation
of
and
to
collection
of
and
accrual
costs
is
W/S 7.0.4.1,
the
retained
L33a-L33m).
transferring
enhances
costs
following
of
following:
letter
validity
route
of
the
costs.
collection
the
the
appearing
in
W/S 7.0.4.1,
-.
common features:
time
at
ordinary
vs.
Express
Mail
boxes;
- new,
Express
Mail
-
of
have
- separate
practice
support
include
collection
(see
W/S 7.0.5,
street
9.0.3
route
previous
The analyses
7.0.5
letter
changes
spreadsheets
the
collection
a new
estimate
variable
of
route
replaces
time,
spreadsheet
analysis
letter
b.
delivery
costs
= L12 x LUC6.
W/S 9.0.5.5
based on the data
in
c:
ySoreadsheet
Other
ccz3tS = Lll
x L14C6.
These
based on the data developed
of
is
separate
collection
of
estimate
coverage-related
variable
with
estimate
to
the
of
volume
boxes
(see
fixed
time
time),
degree
the
variability
Workpapers
at
for
1.13
stop'
and
(replacing
which,
along
number
of
with
collection
time
2.4);
at
and,
former
driving
stops
volume.
IThe time associated
with
sweeps of empty Express
Mail
collection
boxes is used as a measure
of the fixed
time associated
with
sweeps of Express
Mail
collection
boxes,
and as a proxy
for the
fixed
time
associated
with
sweeps of ordinary
collection
boxes
(see Workpapers
1.1 and 2.4).
is
EXHIBIT
c.
The
enhanced
to
of
by refining
different
d.
time
to
the
of
of
of
e.
W/S 9.0.6,
analogous
presented
training
support
messenger
rather
treatment
in
carrier
the
street
as support
A description
vehicle
applicability
use
of
training
a pre-existing
computation
treated
route
the
(W/S 7.0.4.3)
vehicle
use
is
factor
components.
rectify
omission
In
letter
the
The analysis
refined
in
analysis
USPS-19A
PAGE 5
for
of
than
logical
portion
error,
of
office
in
W/S 6.0.3
which
is
resulted
activity
in
the
costs.
in-office
training
mail-related,
activities
following
are
the
carriers.
individual
USPS-LR-H-161.
activities;
line
item
spreadsheet
changes
is
Exhibit
USPS-19B
LVLIIA COT,T,ECTION AND ANAT,YSIS
PROCRDlm
1. General
The
using
analyses
data
derived
messenger
the
from
activities.
data
library
described
from
in
USPS-T-19
four
field
have
surveys>
The procedures
these
surveys
are
been
of
used
presented
implemented
carrier
to
gather
in
the
and
and
analyze
following
references:
Motorized
Letter
Special
Route
Purpose
Expedited
LDC 24
using
Route
Mail
survey
of
these
(i)
log
activities,
relevant
(ii)
each
forms
were
the
course
of
information
departure
involved
record
or
then
their
expedited
completed
associated
for
USPS-LR-H-157
USPS-LR-H-153
USPS-LR-H-158
USPS-LR-H-154
USPS-LR-H-159
the
gathering
to
needed
record
might
cause
piece),
and
street
vehicle
Express
in the
a dedicated
pieces
was
These
log
clock
times
stops,
the
Mail
Study,
development
were
stop
and
other
recrorded.
carriers/mes!sengers!
the
mail
ID numbers
classification
such
work.
example,
'A fifth
data collection,
the
to provide
information
needed
rates.
See USPS-LR-H-155.
street
that
with
information
regarding
survey
by the
with
of
out,
associated
regarding,
USPS-LR-H-152
clocking
item
normal
USPS-LR-H-156
worksheets
Before
delivery
USPS-LR-H-151
information
in-office
information
Log
and
to
data.
I a parcel
(e.g.
Survey
surveys
and
to
Survey
Survey
forms
classification
assigned
(SPR)
(EXP)
(LDC)
Each
(MLR)
during
forms
of
provided
arrival
activities
was unliertaken
of Express
Mail
EXHIBIT
undertaken
at
numbers
those
of
any
A number
of
data
stops,
delivered
steps
were
from
- careful
development
(previously
assigned)
ID
undertaken
this
to
process,
of
ensure
including
forms
the
the
quality
of
the
following:
and procedures,
including
pretesting;
- extensive
integrity
and
involvement
adherence
- comprehensive
- field
After
of
the
keypunched,
the
of
editing
data
further
rigor
and
the
supervisors
survey
of
were
data
from
taken
results.
in
and
procedures2.
the
the
These
p,rocedures,
<and,
proce:s;
follow-up
received
reporteed
weighting
in
and other
steps
(ensure
training;
surveys
w'ere
to
procedures;
teleconference
call-backs
raw
of
to
monitoring
- use
..r-.
the
items.
resulting
field
and
USPS-19B
PAGE 2
field
analysis
steps
are
and
to
.include
described
ensure
data
further
below.
2.
Data
EdLl.ng
Three
types
modifications
of
computerized
simple
other
in
,/---.
specific
editing
the
procedures
patterns;
potential
of
(b)
were
performed
original
survey
for
correcting
manual
inconsistencies;
review
that
data.
These
data
to
and,
in
included
problems
address
(c)
resulted
that
missing
treatment
(a)
fit
data
of
or
outliers
tabulations.
'For example,
when the initial
MLR Survey
revealed
an
unanticipated
diversity
in the composition
of routine
looping
a supplemental
worksheet
was developed
points
and dismounts,
sent to relevant
survey
participants.
See Workpaper
1.14.
and
EXHIBIT
used
a.
vzed
to
apply
Procedw
systematic
- The
edits
to
the
- If a piece
is Express
Mail,
services
other
than COD or return
- If piece
change
checked,
add a c:heck for
survey
change
receipt
critseria
- Assign
a (check to
the street
form (contains
no other
delivery
activity
- For numerical
colons
with
decimal
values
points
greater
change
value
-k.
were
data:
any checks
to missing
for special
values.
weight
is greater
than 11 oz. and First
,the check for First
Class
to a missing
Priority
Mail.
- If piece
weight
is
Bound Flrinted
is checked,
Bound Printed
to a missing
- Zone Rate/Other.
- Interpret
presence/abse,nce
following
USPS-19B
PAGE 3
Cla:ss
valua,
is
and
than 10 lb.
and Fourth
Class
the check for Fourth
Class
and add a check for Fourth
Class
"individual"
an assigned
is shown.
other
(e.g.,
or "deviation"
ID number
(or
than time
values,
9:5 is changed
to
time values
as decimals
of colons
and the values
or minutes
observed.
delivery
a check)
if
but
replace
9.5).
based
on the
b. -1
Review
- A manual review
was performed
to identify
circumstances
where missing
information
could
be supplied
or
potential
inconsistencies
could
be rectified
using
information
available
on the survey
forms.
For example,
if a carrier
reported
but failed
to report
office
hours,
total
hours
and street
hours,
manual
review
could
permit
the value
for office
hours
to be
filled
in (e.g.,
using
subtraction).
Outlllrs 'c
- In the development
of time proportions
(only),
a very small
number of observations
were excluded
because
they
contained
total
elapsed
amounts
of driving
time,
travel
time
and/or
time at stops
that
appeared
to be excessive
in comparison
to normal
work day limits.
c.
3.
&j&tina
The
survey
Procedures
sampling
data
procedures
explicitly
used
provided
in
for
the
gathering
different
of
the
probabi.lities
subject
of
--.
EXHIBIT
selection
For
for
different
example,
large
sampled
with
Survey,
while
messenger
use
of
collection
such
survey
and
sam:pling
used
rates
ensures
that
universe
the
from
the
case
aro,se
due
to
type
to
of
the
for
the
spent
an individual
working
of
route.
To account
included
time
terms
combination
observed
were
in
to
that
type
the
for
that
weight
inverse
operate
the
that
the
the
efficient
appropriate
weighting
factors
inverse
of
are
representative
to
have
the
This
of
the
the
each
carrier/route
because
activities,
will
of
consideration
identify
Basically,
the
be observed
route
is
by
works
SPR Survey
carrier/route
to
amount
sampled
time
probability
IOCS to
period.
be
tc
on that
weighting
sampled
the
IOCS tallies
proportional
actually
proportion
in
with
SPR Survey.
an additional
employee
this,
EXP
sampled
observations.
different
employee
the
drawn.
sampling.
in
in
survey
IOCS tallies
on a particular
amount
the
study.
intenti.onally
facilitates
reflect
estimates
of
the
general,
SPR Survey,
use
time
intentionally
In
develop
they
the
were
necessitates
that
resulting
combinations
ref1lect
that
applied
which
In
but
be applied.
bee:n develtoped
probability
sampling
under
were
high
in
stratified
universes
units
probability
resources,
factors
the
delivery
routes
low
of
weighting
of
disproportionately
disproportionately
'The use
portions
USPS-19B
PAGE 4
the
type
of
factors
type
of
time
it
was
Exhibit
The
econometric
carrier/messenger
analyses
surveys
USPS-19C
performed
are
on
summarized
data
from
the
below:
Model
3:
at
Delivery
Stops =
f(# stops,
#
Accountables,
#
llx!aEmTime
Model
stops
Theory
The number of
vehicle
stops
is
caused by the
number of
activities
that
must be performed
Model
Specification/
Rationale
Quadratic/
Plot
data,
simplicity,
flexibility
Dependent
Independent
Variables
'Jariable
Model
Deliveries
fo
1:
=
STOPS = # vehicle
stops
on sampled
run
ACTS = #
activities
undertaken
on
sampled
run
of
2:
=
The number of
stops required
to
perform
individual
delivery
is caused
by the number of
pieces
requiring
individual
delivery;
‘high
volume"
stops
are
fixed,
and do not
vary with
piece
~OlUlW
The time
spent
performing
individual
delivery
is caused
by the number of
stops
that
must be
made for
individual
delivery,
as we:11
as the numbers
of
accountable
and
nonaccountable
pieces;
"high
volume"
stops
differ
from other
stops
in these
relationships
Quadratic/
Plot
of
data,
simplicity,
flexibility,
alternative
model
Quadratic/
Simplicity,
flexibility,
alternative
DELS = $4 delivery
points
receiving
1-4 individual
delivery
pieces
sampled
run
= ~Cumulative
time at individual
delivery
stops
c,n
sampled
run
VOL = # pieces
delivered
to
points
receiving
1-4 individual
delivery
pieces
sampled
run
model
TIME
on
Ni = # individual
deliver-y
stops
sampled
run at
location
i
<XI
on
--.
EXHIBIT
USPS-19C
PAGE
,-
Model
stops
1:
=
fo
ACTS**2
Model
Deliveries
f
Model 3:
Time at
Delivery
Stops =
f(# stops,
#
Accountables,
#
Nonaccountab&
2:
=
voL'*2
VA = # aocountable
pieces
tc
individual
delivery
stops
on
sampled
run
vo = #
nonaccountable
pieces
t0
individual
delivery
stops
sampled
run
VA+'2:
on
VOff2
Separate
models
'estimated
for 1-4
:piece and 5+ piece
,stops
,(each
estimate
separate model)
MLR,
SPR, EXP (LDC
24 portion),
EXP
(LDC 22, 23, 27
portion),
LDC
MLR, SPR, EXP (LDC
24 portion),
EXP
(LDC 22, 23, 27
portion),
LDC
SPR, EXP (LDC 24
Iportion)
Alternative
None'
Same, but without
limitation
t0 1-4
piece
stops'
:Ssme, but with
:single
N variable
(and N**2),
with
snd without3
:separate
estimation
for 1-4
snd 5+ pc. stops
Datasets
used to
Model
'The preferred
model was al.so estimated
on a preliminary,
incomplete
dataset.
'This
alternative
model was only estimated
on a preliminary,
incomplete
dataset.
'This
alternative
model was also estimated
on a preliminary,
incomplete
product
eliminated
the
dataset
with
a specification
that
included
The cross-produmzt
terms
(VA*VO, VA*N, VO*N).
(due to lack of an operational
foundatimx)
estimation
of
the
alternative
model
on
the
full
cross-
term,s
prior
dataset.
were
to
2
EXHIBIT
Model
Econometric
technique
from
the
results
preliminary
presented
below.
weighted
sum of
output
to
Similarly,
is
output
the
It
is
ts3 Cost
programs
in
and/or
noted
SPR and
special
the
sum
of
Segment
9.
used
in
USPS-LR-H-160.
that
for
EXP (LDC 22,
purpose
=
route
by
preferred
alternative
models,
in
econometric
as
are
27 portion)
analysis
by
as well
Mode.1 1 and
EXP (LDC 24 portion)
the
Data weighted
inverse
of
sampling
rate
models,
both
23,
Model 3:
Time at
Delivery
Stops =
f(# stops,
#
Accountables,
#
2:
Data weighted
inverse
of
sampling
rate
by
from
da,ta
a weighted
Computer
presented
=
Data weighted
inverse
of
sampling
rate
The econometric
Model
Deliveries
f
I.:
stclps
miviries)
USPS-19C
PAGE 3
Cost
and
analysis
Model
2,
results
is
Segment
7.
LDC results
are
a
EXHIBIT
SUMMARYOF
..---,
w
1:
WONOMETRIC
stoos
=
USPS-19C
PAGE 4
ANAT~XSES
(Activitid
Complete Data/
Preliminary
H
M!d.el
i-'-
Data
EaJL
Preferred
Adi.
R
Model
N
EaJL
%
Total
EC&
sraes'
- MLR
0.9831
206
0.99538
0.9831
213
0.99440
[I - EXP
SPR 27
0.9583
0.9647
571
52
0.96460
1.00909
0.9376
0.9606
684
65
0.92280
1.05
0.00628
0.99372
-
EXP 24
24
c -- LDC
0.8967
0.9634
112.9
220
0.94985
1.01018
0.9196
0.9049
1399
261
0.94962
0.96750
0.07899
0.92101
12zzl
Output
output
to
to
w/s
w/s
7.0.4.x,
7.0.5,
output
to
w/s
9.0.3,
C3L4
p3Gq
= 0.9944
CPLP = 0.9995
C9L5 = 0.9661
(BY value
(BY value
= 0.9996)
= 0.9657)
'Estimated
from activity
and activity/stop
data contained
USPS-LR-H-157,
USPS-LR-H-158
and USPS-LR-H-159.
'Model value
of 1.007
truncated
to 1.0 due to absence
of
operational
foundation
for diseconomies
of scale.
in
EXHIBIT
OF ECONOHmC
2:
Preliminary
Alternative
.N
Adi.
R-
td!d.d
- MLR
r-
- EXP
LDC 24:
24
output
output
output
to
to
to
Deliveries
Data/
Model
YaJL
USPS-19C
PAGE 5
ANAT,YSES (cont'd)
= f(VoM
Complete
Data/
Preferred
Model
Adi.
RH
YaL-0
%
DELS
Rt.Type
EaL
0.7261
116
0.94421
0.8799
117
0.995'75
0.98904
0.5912
334
0.831.71
0.9102
373
1.06
0.95472
0.95472
0.3064
35
0.41286
0.9465
44
0.70963
0.9099
0.5638
172
979
0.91965
0.66254
0.9550
0.9461
1197
201
0. 96206
0.96091
0.97685
0.93866
W/S 7.0.4.x,
w/s 7.0.5,
w/s 9.0.3,
C3L5 = 0.9848
(BY value
= 0.9852)
CPLlO = Cl.9519
C9L6 = 0.9396
(BY value
= 0.9395)
<Model ,value of 1.015
truncated
to 1.0 due to absence
of
operational
foundation
for diseconomies
of scale.
'Weighted
mean of SPR and EXP :27; weight
= # DELS
(from WP 1.3).
OWeighted mean of EXP 24 and LDC 24; weight
= # DELS (:Erom WP
2.1).
,-iGzq
EXHIBIT
C ANALYSRS
Model
T1'm e =
3.
IStows.
Adi.
1. Preliminary
N/Cross-products
Stops)
N
VA
vo
2. Complete
(All
Stops)
N
VA
"0
3.
Accountables.wntables)
R2
N
281
0.5025
Data/Single
N
0.2772
317
0.0485
0.1277
0.4547
N
4. Complete
Data/Single
(5+ PC. Stops)
N
VA
vo
N
5. Complete
PC. stops1
N
(CQnt'd.)
0.0689
0.1907
Complete
Data/Single
PC. Stops)
N
VA
VO
(l-4
r-.
0.3092
Data/Single
(All
USPS-19C
PAGE 6
0.1721
321
-0.0518
0.1398
0.4915
0.8612
%
TINE
70
Total
m
0.5300
0.1251
0.2624
Data/Ni
(l-4
Data/Ni
(5+ PC.
VA
VO
6. Complete
Stops)
70
VA
0.6846
0.0520
VO
0.3002
N
r-7
0.9527
'Model values
of 1.0148
operational
foundation
"Model
value
of -0.0907
operational
foundation
of the VO variables
in
and 0.0503
prorated
due to lack
of
for diseconomies
of scale.
treated
as 0 due to absence
of
for negative
volume variability.
Neither
this
model is statistically
significant.
EXHIBIT
output
out.put
output
to
to
to
w/s
w/s
w/s
C9L14
C9L15
C9L16
7.0.5,
7.0.5,
7.0.5,
2
adi.
kfQd&
7. Preliminary
N/Cross-products
stops)
N
"A
vo
8. complete
(All Stops)
N
Data/Single
(All
R
0,.5720
N
(BY value
(BY value
(BY value
= 0.8963)
= 0.0592)
= 0.0445)
XaL
857
0.5570
0.2369
0.0403
Data/Single
N
0.6058
1052
0.7982
VA
0.0980
vo
-0.0145
9. Complete Data/Single
(l-4 PC. Stops)
N
VA
vo
N
i?- Complete Data/Ni
PC. stops1
N
VA
0.6324
1049
0.7048
0.1550
0.0237
10. Complete Data/Single
(53. PC.
Stops)
N
VA
vo
-
= 0.9117
= 0.0479
= 0.0461
N
0.2034
127
%
Total
YaL
0.7411
0.1168
-0.0555
(l-4
vo
OL!tput
output
output
to
to
to
w/s 9.0.3,
w/s 9.0.3,
W/S 9.0.3,
C9LlO
C9Lll
C9L12
= 0.6860
= 0.1342
= 0.0219
(BY value
(BY value
(BY value
= 0.6865)
= 0.1334)
= 0.0237)
USPS-19C
PAGE 7
Exhibit
USPS-19D
L RATE CATRGORY COST DIFFRRFIYTIALS
The
Express
source
rate
for
categories.
each
of
Express
the
Mail
of
intervening
This
it
makes
observation.
the
in
this
the
those
significant
related
transportation
lT,his analysis
differentials.
order
to
and
based
to
this,
it
on differences
to
in
causal
costsI,
omits
any
to
has
during
the
the
1980
Mail
in
reliably
categories
are
study
rate
scarce.
meas.ure
throutgh
been
direct
necessary
to
the
field
develop
current
cost
differentials
analyzed
with
respect
cost
There
unit
factors.
the
with
now extremely
differentials
between
factors.
differentials
in
Express
is
category
cost-causing
associated
categories.
costs
rate
Mail
involved
have
employed
determine
rate
Express
funsztions
that
impossible
rate
of
primary
etc.).
mailstream
or
the
volumes
different
Basically,
methodology,
factors,
for
as the
now outdated,
and piece
methodology
Mail
served
among
PO-to-Addressee
with
Express
determined
,,-.
the
Because
Under
costs
in
has
is
distribution,
impractical
new methodology
respect
category
than
associated
ca~usal
rate
now be repeated.
other
among
times
changes
categories
costs
which
labor
period,
not
(1960)
differentials
stuldy,
outgoing
Because
:Study
coist
This
(acceptance,
could
Cost
determining
tabulation
,-
Mail
four
rate
is
Therefore,
Express
(quantification
Mail
of
are
categories
no evidence
acceptance
with
of
or
distribution
aside
from
rate
to
categories
transportation
cost
a
EXHIBIT
differ
from
related
one
another
primarily
with
respect
associated
with
USPS-19D
PAGE 2
t'o delivery-
costs.
The delivery-related
categories
are
different
Costs
determined
delivery
methods,
f Unit
CQst
through
Express
($000)
2.
Delivery/Total
3.
Delivery
i$OOO)
4.
Piggyback
5.
Delivery-Related
costs
($000)
6.
Piece Volume
(ooo)8
7.
Delivery-Related
Cost/Piece
($1
Mail
Cost
costs
Cost
27,488
98,098
associated
by Mf=thod
6+7
24.747
of
9.
51,217
712
863
23,401
51,074
5,380
1.41854
1.410:24
1.41823
1.49538
1.19693
2.227
33,188
76.375
6,439
0.1.15
19,017.852
1.745
99725
21,882.762
Deli verv
Ff.QL3i
5,479
,945s’
19,307.%2
with
lQ
025g3
.ooss'
Cost
Window
service
in Lines
1-4,
'Source:
FY96
'Source:
Cost
?Source:
Cost
%ource:
Cost
'Source:
FY96
*Total
distributed
unit
rate
as follows:
Deleted
segment:
1.
the
different
9s206
4,171.824
3.490
and platform
operations
are reported
and consoli.dated
in Lines
S-7.
IOCS tally
,analysis.
Segment
7, W/S 7.0.3.
Segment
9, W/S 9.0.4.
Segment
10 spreadsheets.
IOCS tally
analysis.
based on results
of Express
Mail
1.543
separately
Study.
118,229
64,380
1.836
EXHIBIT
,-
sast se-
USPS-19D
PAGE 3
6+7
Ct.9
*. Pcs.
A.
PO--to-PO
B.
PO-to-Addressee
C.
Same Day Airport
D.
Custom
9.
Fracfion
A.
PO-to-PO
1.0000
B.
PO-to-Addressee
0.2906
C.
Same Day Airport
1.0000
D.
Custom
0.8761
287.914
18,432.792
Designed
and
provide
the
differentials
between
the
basis
the
4,171.824
15.874
67.114
0.2996
0.3440
0.0658
0.0237
0.1002
0.0000
delivery-related
mean delivery-related
for
across
establishing
rate
the
0
cost
cost
per
"per
piece"
for
669.802
each
piece
Cost
Per
of
rate
$1.836
cost
Piece
Neal2
($1.721)
PO-to-PO
$0.115
PO-to-Addressee
$I..858
Same Day Airport
$CI.115
($1.721;
Custmn
5c1.492
($1.836)"
Designed
63.422.242
categories:
Delivery-Related
-'er
$0.022
service
and platform
operations
are reported
separately
and consolidated
in Lines
5-7.
in Lines
1-4,
lOReflects
omission
of delivery-related
costs
from per-piece
charge.
Cost basis
for per delivery
charge
= $0.492.
PWindow
/--.
21,815.648
0.042
586.814
Designed
category
19.001.978
0.042
The differences
.-
287.914
Exhibit
USPS-19E
COST RASIS
The general
approach
scheduled
pick-ups
(by
for
type)
route
is
based
special
carrier/messenger
survey:;
previous
1.
SPR Indiv.
Time/Stop'
Del.
2.
SPR Drive
Time/Stop
(Indiv.
Dels.)
calculate
delivery
Information
the
to
on driving
carriers.
replaces
FOR PICKUP
is
use
FFWS
costs
time/stop
fo.r
on-call
plus
time
messengers
and
spatial
drawn
from
the
rescent
this
approalch,
to
support
of
messenger
delivery
Stop
and
at
stop
purpose
whi'ch
(costs
as a proxy.
301.69
i
3.
SPR
Drive
Time
Time/Stop
o.71732
(Ll
x
216.40
216.40
288.28
315.57
504.68
531.97
1.33102
1.33102
L2)
4.
SPR Pickup
(seC.)3
5.
Total
Time
SPR Pickup
at
Stop
Time
(L3 +
L4)
6.
Street
Support
Factor4
7.
Productive
Hourly
Rate
City
Delivery
Carriers
8.
9.
-
26.083
26.083
City
Delivery
Carrier
Piggyback
Ratio
1.31468
1.31468
SPR Pickup
Cost
L7 x LS)/36001
$6.3985
$6.7445
'Source:
lSource:
3Source:
'Source:
[CL5 x L6 x
USPS-LR-H-157;
Cost Segment
USPS-LR-H-157;
Cost Segment
USPS-LR-H-158.
7, W/S 7.0.5,
CSL22/C6L22.
USPS-LR-H-158.
7, W/S 7.0.1.
Includes
related
volumetime
EXHIBIT
10.
SDM Cwt.
Time/Stop'
Del..
11.
SDM Drive
Time/Stop
(cust.
Dels.)
Time
12.
SDM Drive
L2)
(Ll
13.
SDM
Stop
14.
Total
L:L31
15.
support
16.
Productive
Hc~urly Rate Special
Delivery
Messengers
17.
Special
Delivery
Piggyback
Ratio
18.
SDM Pickup
C0e.t [CL14 X L15
x L16 x L171/36001
Time/Stop
Pickup
(sec. ) '
Time
SDM Pickup
at
0.6828’
x
Stop
Time
CL12 +
Eactclra
Messenger
170.41
170.41
515.69
505.60
686.10
676.01
1.57627
1.57627
24.411
24.411
1.49520
1.49520
$10.9648
$10.8035
% SPR'
0.5974
0.7902
% Messcngerl’
0.4026
0.2098
$8.2369
$7.5961
Wtd.
Ave.
5Sourc'e:
6Sourc'e:
'Sourc'e:
%ourc'e:
associated
In/Out)
9Sourc'e:
10Sourc:e:
Cost
USPS-19E
PAGE
USPS-LR-H-158;
Cost
Segment
9,
USPS-LR-H-158;
Cost
Segment
9,
with
activity
and
6430
(Obtaining
USPS-LR-H-157;
USPS-LR-H-157;
USPS-LR-H-159.
W/S 9.0.3,
USPS-LR-H-159.
W/S 9.0.4.
Includes
related
volumetime
C5L14c/C6L14c.
Includes
portion
codes
6519
(Training),
6522
Mail,
etc.).
USPS-LR-H-158;
USPS-LR-H-159.
USPS-LR-H-158;
USPS-LR-H-159.
of
C6
(Clocicing
2