BEFORE THE POSTAL RATE COMMISSION
20268-0001
WASHINGTON, D.C.
RECEIVEC
SEP 3 12 54 PH ‘97
DOCKET NOPgsr&97&rCv~.,:!':;.;,r,~
POSTAL RATE AND FEE CHANGES, 1997:
OFFICEOFTHE~~~~~~~~~~~~
AMERICAN POSTAL WORKERSUNION, AFL-CIO
FIRST SET OF INTERROGATORIES TO
UNITED STATES POSTAL SERVICE WITNESSES
(APWU/USPS-T9, T29, & T31)
The American
United
the
States
following
documents
Postal
Workers
Service
interrogatories
pursuant
of Practice
Postal
to Rules
Union,
to respond
AFL-CIO,
fully
and requests
requests
the
and completely
for
production
25 and 26 of the Commission's
to
of
Rules
and Procedure.
ctfully
submit
d,
dlQi!g&l
Schwartz and Anderson,
1300 L Street NW Suite 1200
Washington,
DC 20005-4126
(202)
898-1707/FAX
(202) 682-9276
Counsel
for
American
Postal
P.C.
Workers
YJnion, AFL-CIO
CERTIFICATE OF SERVICE
I hereby
certify
that
document upon all
who have
Date:
August
29,
I have this
day served
the
following
1997
--
INTERROGATORIES OF AMERICAN POSTAL WORKERSUNION, AFL-CIO
TO UNITED STATES POSTAL SERVICE WITNESS TAYMAN
APWU/USPS-T9-1.
worksheet
with
In you library
reference
the name SPTDC- 97.XLS which
"SVCWIDE PERS OTHER PROGRAMS." In it
increase
30,000
in clerk
in 1998.
and mailhandler
The increase
there
workyears
is attributed
(LR H-1,2) you have a
has a sec!tion
is
an estimated
of 20,OClO in 1997 and
to "equipment
slippage".
(a)
Please
explain
what the
(bl
Please
provide
all
term "equipment
slippage"
means.
estimated
derived.
increase
in clerk
workpapers
that
and mailhandler
titled
show how the
workyears
was
INTERROGATORIES OF AMERICAN POSTAL WORKERSUNION, AFL-CIO
TO UNITED STATES POSTAL SERVICE WITNESS DANIEL
APWU/USPS-T29-1:
figure
bulk
The text
of 9.5391
metered
in the text
cents
mail.
is
incorrect
the calculation
cents
used in the text,
changed
workpaper;
calculation
for
for
the mail
5 on that
and that
reference
only
per piece.
relevant
per piece
Footnote
The library
piece.
at page 1 of Exhibit
it
USPS-29C uses a
processing
page indicates
should
LR-H-106
cited
in the
in the footnote,
Please
supply
calculation
9.5391
cents
that
per piece,
show the
or led
reason
for
to the use of the
.--
cents
footnote
per
has
10.5814
for
as well
of
the figure
be 10.5814
the figure
the
costs
the
as all
figure
the
the use of the
changed
calculation.
INTERROGATORIES OF AMERICAN POSTAL WORKERSUNION, AFL-CIO
TO UNITED STATES POSTAL SERVICE WITNESS BERNSTEIN
APWU/USPS-T31-1.
On page 81, line
21 ff.,
you state:
the type of mail that is most likely
to shift
from
single
piece to workshare mail is probably
relatively
low
cost single
piece mail.
As a result
when the sorkshare
discount
is increased,
the mail that shifts
from single
piece to workshare probably
has a cost that is less than the
average cost of all single piece mail, a consi'deration
that
is relevant
to both Ramsey pricing
and Efficient
Component
Pricing."
On page 85,
lines
1-3,
you state:
"A key assumption
of the price calculation
is that when a
piece of mail shifts
from single-piece
to workshare,
the
postal
marginal
cost of the mail falls
from the single piece
marginal
cost of $0.2324 to the workshare marginal
cost of
thereby
saving
the
Postal
Service
saves
[sic1
$0.0991,
$0.1333 per piece."
Please
(a)
on page 85 for
mail
is
confirm
the mail
the marginal
cost
marginal
cost
that
shifting
from
single-piece
Please
(b)
page 85 for
explain
cost
that
shifting
from
single-piece
mail,
on page 81 should
figure
you used
to workshare
and not
the lower
be used for
mail
to workshare
why the marginal
you said
cost
from single-piece
of single-piece
marginal
cost
from single-piece
of single-piece
shifting
cost
the marginal
shifting
you said
the mail
is the marginal
that
mail,
you used on
to workshare
and not
on page 81 should
to workshare.
figure
the
mail
lower
be used for
mail