BEFORE THE
POSTAL. RATE COMMISSION
WASHINGTON, DC. 20268-0001
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POSTAL RATE
AND
FEE CHANGES, 1997
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Docket No R97-1
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RESPONSE OF UNITED STATES POSTAL SERVICE
WITNESS FRONK TO INTERROGATORY OF
THE OFFICE OF THE CONSUMER ADVOCATE
(OCIVUSPS-T32-1
.a)
The United States Postal Service hereby provides the response of witness Fronk
to the following interrogatory
T32-1
of the Office of the Consumer Advocate:
.a, filed on July 30, 1997.
Parts b.-e. of interrogatory
OCA/USPS-
OCA/USPS-T32-I,
were redirected to the Postal Service.
The interrogatory
is stated verbatim and is followed by the response.
Respectfully submitted,
UNITED STATES POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
Michael T. Tidwell
475 L’Enfant Plaza West, SW.
Washington, D.C. 20260-I 137
(202) 268-2998; Fax -5402
August 4, 1997
RESPONSE OF U.S. POSTAL WITNESS FRONK TO
INTERROGATORY OF THE OFFICE OF THE CONSUMER ADVOCATE
OCAfUSPS-T32-1.
Please refer ,to page 11, lines 2-4 of your testimony. You
state that based on 1995 Household Diary Study data, First-Class Mall volume
received depends on whether the household is urban or rural.
a. Please confirm that the data backing up this statement is presented in TABLE
4-3, page IV-8, of the 1995 Household Diary Study. See Attachment 1. If
you do not confirm, please provide all documents and data used to support
this statement.
b. Please provide definitions of the various levels of urbanicity (Center of Major
Metro Area, Center, Non-Center, Moderate-Sized City, Suburb, Small Town,
and Rural) used in the HousehIold Diary study. If these urbamcity levels are
defined by ZIP Codes, please provide a file containing ZIP codes and their
associated urbanicity levels.
response was used to categorize
C. If a Household Diary Study questionnaire
urbanicity, please explain and list all questions relied upon to determine
urbanicity.
d. Please provide the raw data file from which 1995 Household Diary Study
tabulations are produced.
e. Please explain how the Household Diary Study urbanicity levels relate to the
Census Bireau’s area classifications. See Appendix A to the Technical
Documentation for Summary Tape File 3 on CD-ROM for the 1990 Census of
Population and Housing. See Attachment 2.
RESPONSE:
(a) Confirmed.
Lines 5-6 on page 11 of my testimony further state that,
“...suburbanites
receive more mail than both city-dwellers
(b)-(e) Redirected to the Postal Service for response.
and rural households.”
Attachment
1 to
OCA/USPS-T32-1
DECLARATION
I, David R. Fronk, hereby declare, under penalty of perjury, that the ,foregoing
Docket No. R97-1 interrogatory responses are true to the best of my knowledge,
information, and belief.
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Date
David R. Fronk
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CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoing document
participants
upon all
of record in this proceeding in accordance with section ‘12 of the Rules of
Practice.
Michael T. Tidwell
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-I 137
August 4, 1997