POSTAL PATE AND FEE CHANGES, 1997
Docket
No. R97-1
)
TEE DIRECT MARKETING ASSOCIATION, INC.',9 INTERROGATORIES AED
REQUESTS FOR PRODUCTION OF DOCUMENTSRELATING TO TEE POSTAL
SERVICE'S SUPPLEMENTAL DIRECT EVIDENCE DIRECTED TO
USPS WITNESS DEGEN (DMA/USPS-T12-13-14)
Pursuant
Rules
of Practice,
submits
the
request
Service's
witness
a response
25 and 26 of the Commission's
Marketing
interrogatories
to USPS witness
Postal
designated
the Direct
attached
of documents
to the
to Sections
and requests
Inc.
for
direct
to respond
by some other
qualified
Respectfully
relating
evidence.
to this
hereby
production
Degen (DMA/USPS-T12-13-14)
supplemental
is unable
Association,
If
the
interrogatory,
witness.
submitted,
&GhL
Dana T. Ackerly
II, Esq.
David L. Meyer
Michael D. Bergman
COVINGTON & BURLING
1201 Pennsylvania
Avenue,
Washington,
D.C.
20004
(202) 662-5296
Counsel for the Direct
Association,
Inc.
November
6, 1997
N.W.
Marketing
we
2
Witness
Degen
(USPS-T-12)
DMA/IJSPS-T12-13.
Please refer
to LR-H-146,
shows accrued costs by cost pool.
(a)
Please
within
to the
Table
I-l,
which
confirm
that the IOCS tally
costs for tallies
processing
cost pool are not always equal
accrued cost for the cost pool.
a mail
(b)
Please provide,
in an electronic
spreadsheet
the percentage
difference
between IOCS tally
accrued costs for each mail processing
cost
Cc)
Could a cost difference
of the magnitude
indicated
in
your response to subpart
(b) be due solely
to 10~s
sampling error?
If so, what is the probability
that a
cost difference
of this magnitude is due to IOCS
sampling error?
(d)
Could a cost difference
of the magnitude indicated
your response to subpart
(b) be due solely
to
differences
in salaries
between individual
clerks
mailhandlers?
If so, please explain
fully
the
likelihood
that the cost difference
is due solely
this reason.
format,
costs and
pool.
in
and
to
(e)
IS there any other possible
reason for the difference
between IOCS tally
costs and accrued costs within
a
If so, please explain
fully.
cost pool?
(f)
Assume: (1) clerks
and mailhandlers
sometimes work on
one operation
while clocked into another operation,
and
(2) IOCS data collectors
sometimes record the MODS
operation
that the employee is performing
rather
than
the MODS operation
into which the employee is clocked.
Could this situation
result
in a difference
between
IOCS tally
costs within
a cost pool and accrued costs
If no, please explain
fully.
in the same cost pool?
Please refer
to LR-H-146, page 11-3, step 2,
DMA/USPS-T12-14.
where you discuss
the distribution
of uncounted/empty
single
Please disaggregate
uncounted/empty
item unweighted
tally
items.
and volume-variable
costs by (1) item
IOCS tally
costs,
counts,
or
(2) cost pool, and (3) whether the item is uncounted
tw=,
Please
provide
this
information
in
an
electronic
empty.
spreadsheet
format.
3
CERTIFICATE OF SERVICE
foregoing
I hereby
certify
document
upon
proceeding
Postal
3 of
in
Rate
the
accordance
Commission's
Commission's
that
all
this
participants
with
Rules
Special
I have
Rule
date
of
12
served
record
(section
in
this
3001.12)
of
Practice
and Procedure
Rules
of
in
Practice
the
this
proceeding.
/&diyai~.
Michael
D. Bergman
November
6,
1997
of
the
and Rule