DOCKET SECTION
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20266-0001
RECEIVEL~
h
7
15
‘-i 26 P/j ‘97
RESPONSE OF UNITED STATES POSTAL SERVICE
WITNESS NIETO TO INTERROGATORY
OF
THE FLORIDA GIFT FRUIT SHIPPERS ASSOCIATION
(FGFSAIUSPS-T2-12(C))
The United States Postal Service hereby provides the response of witness Nieto
to the following interrogatory
USPS-T2-12(c),
filed on September
filed on September
has determined
of the Florida Gift Fruit Shippers Associ8ation: FGFSA/
3, 1997. An objection to this subpart had been
15, 1997. After consultation with the witness, the Postal Service
that the burden inherent in producing the requested ‘data, the basis
for the objection, was surmountable
and the information
has been provided.
Counsel for the Postal Service provided this response to counsel for Florida Gift
Fruit Shippers at hearings yesterday, but, because of her presence at hearings all
day, was unable to file this information
until today.
The subpart is stated verbatim and is followed by the response.
Respectfully
submitted,
UNITED STATES POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux.
475 L’Enfant Plaza West, SW.
Washington, D.C. 20260-I 137
(202) 268-2970; Fax -5402
October 15, 1997
Jr.
RESPONSE
OF POSTAL SERVICE WITNESS NIETO TO INTERROGATORIES
OF FLORIDA GIFT FRUIT SHIPPERS ASSOCIATION1
FGFSAIUSPS-TZ-12.
Please confirm that TRACS data are used to estimate on a quarterly basis the
percentage of capacity utilized with respect to the four different highway
accounts.
a.
Confirm that the TRACS data for the highway capacity utilization factors
for FY 1995 is accurately reflected in the following table.
(TABLE WAS OMIT-TED)
b.
C.
Provide a similar table showing the highway capacity utilization factors for
FY96.
Provide comparable capacity utilization data for each of the IFYs from
1990 through 1994.
Response
to FGFSAKJSPS-TZ-12.
a.
Answer filed September
18, 1997.
b.
Answer filed September
18, 1997.
C.
Please refer to the attached table on the following page.
1
RESPONSE
OF POSTAL SERVICE WlTNESS NIETO TO INTERROGATORIES
OF FLORIDA GIFT FRUIT SHIPPERS ASSOCIATION
Response to FGFSAIUSPS-T2-12
Attachment 1
TRACS Historical
l
Highway
Capacity
Only PQI available for FY90.
2
Utilization
Factors FY90-FY94
DECLARATION
I, Norma B. Nieto, declare under penalty of perjury that the foregoing
answers are true and correct, to the best of my knowledge, information,
belief.
Dated:
DIF3jQ7
and
CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoing document
participants
of record in this proceeding
in accordance
upon all
with section 12 of the Rules of
Practice.
475 L’Enfant Plaza West, SW.
Washington, D.C. 20260-I 137
October 15, 1997
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