DOCKET SECTION
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON,
DC 20268-0001
Postal Rate And Fee Changes, 1997
I
I
JNTERROGATORIES
ALLIANCE OF NONPROFIT
TO UNITED STATES POSTAL
(ANMKJSPS- ST-44-1
November 4,19!J7
OF
MAILERS
SERVICE
- 8)
The Alliance of Nonprofit Mailers herebysubmitsthe following interrogatories and
requestsfor production of documents:
ANM/USPS-ST&t- 1. In your supplementarytestimony USPS-ST-44, pleaserefer to USPS44A
(LR-H-109), Table 1. The data in column 6 are referencedto LR-H-106. For the two pagesof
Table 1 that refer to Nonprofit Mail, (i.e., pp. 6-7) and for each entry in column 6, pleaseprovide
a precisereferenceto the page, row and column in LR-H-106. If the entries in Table 1, column 6
of LR-H-109 do not appearin LR-H-106, pleaseindicate how they are computed, and provide
completereferencesto all underlying data neededfor all requisite computations.
ANMAJSPS-ST-44-2. Pleaseindicate how the fractional amountsshown on the last (unlabeled)
row of Table 1, in columns 7,8 and 9 are derived or computed; i.e., assumingthat the number
shown in the ‘Total” row representsthe numerator, what is the denominator, and the source of
the denominator?
ANMLJSPS-ST-44-3.
a.
How many tall& underlie developmentof the cost of StandardA Nonprofit ECR Letters
shown in Table 1, p. 6?
b.
How many tallies underlie developmentof the cost of StandardA Nonprofit ECR Non-
Letters shown in Table 1, p. 7?
c. What is the standarddeviation of the unit cost of Nonprofit Mail walk-sequenceand non-walksequenceleuers and non-letters?
ANM/USPS-ST-44-4. Do the tallies used to develop the costs in Table 1 include tallies for
supervisorsand technicians(Cost Segment2). or are they contined to tallies for clerks and
mailhandlers(Cost Segment3)? Pleaseexplain why tallies for Cost Segment2 are or are not
included.
ANMKJSPS-ST-44-5. Are the StandardA ECR tallies used to develop Table 1 in USPS-44A
identical to the StandardA ECR tallies used for the study in USPS44B? If not, pleasedescribe
all difference,sin the two sets of tallies.
ANMKlSPS-ST-44-6.
a. Pleasedescribeall edits and other checkswhich ChristensenAssociatesperformed on the
IOCS tallies receivedfrom the Postal Service.
b. Pleaseaccount for all tallies that were deleted from the original set of tallies received
from the Postal Servicei.e,
state how many were deleted, and explain why they were
deleted.
c. Pleaseaccount for all tallies that were or could be consideredquestionable(e.g., had
-2-
unusualentries, such as weight of StandardA Mail exceeding 16 ounces),but were
neverthelessleft in the databasethat was usedto develop Table 1.
ANMKJSPS-ST-44-7. Pleaserefer to USPS44A, p. 2, where you state that “this approachis
conservativein the sensethat it assignsto walk-sequencecosts which have the possibility of b&g
causedby walk-sequencemail.” Pleaseexplant what you meanby “the possibility of being caused
by walk-sequencemail.” Specfically, what other possibilitiesexist, and what is the likelihood that
those possibilitiesmight occur?
ANM/USPS-ST-44-8.
a.
How many tallies in the study used to develop Table 1 in USPS-44A were a counted
mixed mail tally?
b. Pleasedescribeall entries in an IOCS mail processingtally that would identity and
distinguish a ,mixcdmail tally from a direct non-mixed mail tally.
c. Pleaseprovide a legend which explantsall entries that can be enteredfor counted
mixed-mail tallies. That is, if the tally taker is instructed to enter somealpha-numeric
combination, pleaseexplant what each possibleentry meansin terms of the counted mixed
mail
Respectfullysubmitted,
David M. Levy
SDLEY & Ausrt~
1722Eye Street, N. W.
Washington, DC 20006
(202) 736-8214
;oee&‘zaL
Washington, DC. 20006
(703) 476-4646
Counsel for Alliance of Nonprofit Mailers
November 4, 1997
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CERTIFICATE
OF SERVICE
I herebycertify that I have this day servedthe foregoing document on all participantsof
record in this proceedingin accordancewith section 12 of the Rules of Practice.
November 4, 1997
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