DOCKET SECTION
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
~EI>EIVE.L~
Jg 26
6, , v,:,
POSTAL RATE AND FEE CHANGES, 1997
4 00 ?I ‘%I
‘.I
:, i
~ : :, :: I
Docket No. R97-1
i
UNITED STATES POSTAL SERVICE
INTERROGATORIES
AND REQUESTS FOR PRODUCTION OF DOCUMENTS
THE DIRECT MARKETING ASSOCIATION, INC. WITNESS BUC
(USPSIDMA-Tl-15-18)
TO
Pursuant to rules 25 and 26 of the Rules of Practice and Procedure and rule 2 of
the Special Rules of Practice, the United States Postal Service directs, the following
interrogatories
Association,
and requests for production of documents to the Direct: Marketing
Inc. witness But:
USPSIDMA-Tl-15-18,
Respectfully
submitted,
UNITED STATES POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
Eric P. Koetting
CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoing document upon all
participants of record in this proceeding in accordance with section 12 of the Rules of
Practice.
475 L’Enfant Plaza West, SW.
Washington, D.C. 20260-I 137
(202) 268-2992; Fax -5402
January 26, 1998
Postal Service Interrogatories
USPSIDMA-Tl-15.
for DMA Witness But
Please refer to your testimony at pages 19-20, and Attachment
1 to
this interrogatory.
(a)
Is it your testimony that the observations
operations,
of letters being handled in flats
and so on, are the result of “misclocking”?
If your answer is negative,
please explain fully.
lb)
Please confirm that the table in Attachment
tally count data in spreadsheet
employee
(4
by the activity the
1 indicates that there are
of letters being handled in flat operations, and so on, based on the
sampled (as opposed to clocked in) activity.
Please confirm that the observations
reported in Attachment
1, are fi
If you do not confirm
“misclocking”
of the
as recorded in IOCS question 19.
Please confirm that the table in Attachment
employee’s
W
DMA17.xls (USPS-LR-H-305)
is observed performing,
observations
(4
1 provides a breakdown
of letters being handled at flat cases,
the result of “misclocking.”
part (d), please
affects the employee’s
explain
sampled activity.
your theory
Please also explain, as
necessary, whether your theory is simpler than alternate explanations
(e.g., that there are some letters in the flats mailstream
pieces are not individually
measured
of how
for the data
since the dimensions
when the letter and flat mailstreams
of
are
separated).
USPSIDMA-Tl-16.
Please confirm
Please refer to your testimony at page 20 and to Tr. 17/8143-8144.
that you have not calculated
the variance
of witness
Degen’s
distribution
key entries
distribution
key to total IOCS costs for the distribution
variable
costs,
(the ratio of IOCS costs for a particular
If you do not confirm,
USPSIDMA-Tl-17.
(4
in a
volume
results of your
of statistical formulas and assumptions.
Please refer to your testimony at pages 25.
Is it your testimony that “not handling costs” are not causally related to mail
handlings in the same cost pool?
W
key) or of distributed
please provide complete
analysis, along with complete documentation
subclass
Is it your testimony
If not, please explain fully.
that witness
Degen’s
not-handling
distribution
is
incorrect primarily because you believe that “not handling costs” are not causally
related to mail handlings in the same cost pool?
(4
Suppose
If not, please explain fully.
it is correct to assume that “not handling
costs” are causally
related to mail handlings in the same cost pool. Would it then be appropriate
to
distribute the “not handling costs” within the same cost pool? Please explain fully.
USPS/DMA-Tl-18.
(4
Please refer to your testimony at page 25.
Please provide the quantitative analysis of variability and/or cost causality,
including all statistical tests that demonstrate the causal relationship between your
cost driver(s)
distribution
lb)
and “not handling
costs,” upon which your “not handling
cost”
is based.
If your answer to part (a) indicates that you have performed no quantitative
analysis of variability
or cost causality, please confirm that your proposed
handling cost” distribution
is based on untested assumptions
“not
regarding patterns
of cost causality.
(4
If your answer to part (a) indicates that you have performed no quantitative
analysis of variability or cost causality, please confirm that your own proposed
“not handling
cost” distribution
witness Degen’s methodology.
is “unfounded”
by the standards
you apply to
If you do not confirm, please explain fully.
Attachment 1
FY96 IOCS ClerkWailhandler Talller by IOCS al9 Response and Shape
All Offices
019
,esponse
Title
A
Manual
F9211 A - Letter Case Distrib
F9211 B - Flat Case Distrib
F9211 C - Parcel Piece Distrtb
F9211 D - ColVCancel MM Pn
F9211 E - Presort Mail Units
F9211 F - Opening Units
F9211 G - Pouch/Rack Units
F921I H - Platform Units
F9211 I - Other Manual
Total Manual
0
c
D
E
F
G
H
I
J
K
L
M
NP
a
R
S
1
U
,etters/Cds
21,395
116
63
398
294
1,167
603
407
2,802
27,251
Fiats
tally count
IPPS
Parcels
No Shape
Total
422
a.601
412
ita
112
939
1,126
450
1,432
13,612
57
54
517
27
6
192
569
67
215
1,704
24
133
2,090
29
10
270
776
232
582
4,154
11,197
4,884
3,418
809
669
4,262
4,702
5,744
11,526
47,111
33,095
13,788
6,500
i ,381
991
6,838
7,782
6,900
16,557
93,832
0
OCR
2,596
Mail Proc BCWBCS
Delivery BCFVBCS
Carrier Sequence BCS
MPLSMfSPLSM
Letter Facer/Canceler
Flat FacedCanceler
Sack Sorting Machine
Parcel Sorting Machine
Flat Sorting Machine
Small Parcel & Bundle
NM0 Machine
Multislide
ACDCS
Central Banding
Culling Machine
Remote Barcoding Mal:
Transporf Equipment
All Other
Blank
3,527
2,666
421
8,217
803
32
155
28
82
405
31
70
88
171
153
16
79
461
3,266
16
28
6
4
135
23
259
251
177
6,020
965
16
107
45
50
61
6
189
353
1,525
5
0
0
a
2
0
42
305
20
441
4
27
25
2
10
2
22
91
126
1
4
0
0
0
2
5
161
1,269
31
462
a7
121
106
7
13
10
68
312
338
2,592
3,409
2,155
404
3,594
732
261
1,356
1,992
4,302
3,460
222
057
1.198
552
346
149
6,583
5,806
29,414
5,205
6,973
4,849
a29
11,954
1,562
557
1,965
3,771
50,640
23,848
2,836
7,151
116,495
200,870
Grand Total
10,455
5,733
360
I ,182
1,462
782
563
la3
6,941
7,023
34.669