‘.REcEIVED BEFORE THE POSTAL RATE COMMISSION WASHINGTON, D.C. 20268-0001 POSTAL RATE AND FEE CHANGES, 1997 RUG12 5 00 PM ‘9-l Docket No. R97-1 j RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS TAYMAN TO INTERROGATORIES OF THE DIRECT MARKETING ASSOCIATION, INC. (DMAIUSPS-TS-I-10) The United States Postal Service hereby provides responses of ‘witness Tayman to the following interrogatories T9-l-10, of the Direct Marketing Association, Inc.: DMAIUSPS- filed on July 29, 1997. A partial objection to interrogatory DMA/USPS-G(c) was filed on Augusf 8, 1997. A declaration will be provided shortly. Each 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 Scott L. Reiter 475 L’Enfant Plaza West, S.W. Washington, D.C. 20260-l 137 (202) 268-2999; Fax -5402 August 12, 1997 - RESPONSE OF WITNESS TAYMAN TO INTERROGATORIES THE DIRECT MAIL MARKETING ASSOCIATION DMA/USPS-TS-1. OF Please refer to page 82 of Library Reference H-12. a. For 1997, personnel related other programs comprise 8,613 work years and for 1998 9,933 work years. Please describe the work that these personnel will be performing by cost segment. b. Please provide supporting detail for the basis for your work year estimates. RESPONSE: a. The workyears referenced a., of LR H-12. A narrative description requirement b. LR H-l 0. are detailed by program in Chapter V, Section of each program and the basis for the resource is contained in LR H-IO. Supporting detail for each program’s resource requirement is contained in RESPONSE OF WITNESS TAYMAN TO INTERROGATOFLIES THE DIRECT MAIL MARKETING ASSOCIATION DMAIUSPS-TS-2. a. OF Please refer to page 83 of Library Reference H-12 For 1997, work years for HQ and service wide personnel-related other prograrns personnel are 62,235 and for 1998 they are 84,257 work years, Please describe the work that these personnel will be performing by cost segment and provide supporting detail for the basis for your work year estimates. RESPONSE: a. As specified on page 83 of LR H-l 2, the numbers you have referenced are expressed in thousands calculations, of dollars, not workyears. Program names, supporting and the number of workyears related to these costs can be found in Chapter V, secti0ns.c. and f. A narrative description the resource requirement is contained in LR H-l 0, of each program and the basis for RESPONSE OF WITNESS TAYMAN TO INTERROGATOR.lES THE DIRECT MAIL MARKETING ASSOCIATION DMA/USPS-TS-3. OF Please refer to pages 89 and 90 of LR H-l 2. a. For all costs on these sheets which are greater than $lCl million, please describe the programs that these costs support. b. Please provide the basis of your estimate. RESPONSE: a. Program names and dollar amounts can be found in Chapter V, sections b. and e. of LR H-12 Supporting and corporatewide calculations for headquarters activities, and depreciation and e. of LR H-12. A narrative description resource requirement administered programs can be found in Chapter VI, Sections a. of each program and the basis for the is contained in LR H-l 0. b. Please see my response to part a., above. --__- ----.. --__- -___- RESPONSE OF WITNESS TAYMAN TO INTERROGATOF:IES THE DIRECT MAIL MARKETING ASSOCIATION DMAIUSPS-T9-4. OF Please refer to page 98 of LR H-12. a. For all costs on this sheet which are greater than $10 million, please describe the programs that these costs support b. Please provide the basis of your estimate. RESPONSE: a.&b. Please see my response to DMAJUSPS-T-9-3. RESPONSE OF WITNESS TAYMAN TO INTERROGATOF!IES THE DIRECT MAIL MARKETING ASSOCIATION DMAIUSPS-TS-5. OF Please refer to page 100 of LR H-l 2. a. For all costs on this sheet which are greater than $10 miillion, please describe the programs that these costs support b. Please provide the basis of your estimate RESPONSE: a.&b. Please see my response to DMAIUSPS-T-9-3 RESPONSE OF WITNESS TAYMAN TO INTERROGATORIES THE DIRECT MAIL MARKETING ASSOCIATION OF DMAIUSPS-TS-6. Please confirm that page 101 of LR H-12 shows non personnel other program costs of $248,264,000 in FY 97 and $867,243,000 in FY 98. That page lists “Program/Functional Managers” as the sources of these cost estimates, a. Are there any work papers supporting these estimates? provide them. If so, please b. When did the managers provide these estimates? C Please provide the names and titles of each of the managers who provided the estimates together with the component number for which they provided the estimates. d. Please describe the activities that these costs will be incurred for. RESPONSE: Confirmed. a. FY 97 program estimates reflect the approved budget which resulted from the Postal Service’s budget process and FY 98 estimates reflect prelilminary amounts from the FY 98 budget process. Workpapers similar to those typically provided to the Commission in support of most aspects of the rate filing which calculate the development of budgetary amounts are not available. The formulatioln of budget amounts is not based simply on mechanical calculations set of workpapers. contained in a comprehensive Instead, budgets are established through a complex management process that has incorporated the Postal Service’s CustomerPerfect! philosophy. As a result, budget targets involve negotiation, judgment, linkage to and support of operating goals, and the tactical allocation and re-allocation of resources to organizational units and programs. b. Estimates were provided for use in the Docket R97-1 rate case at various times between March and June 1997. C. A partial objection to this interrogatory was filed. Please refer to the attached schedule for the titles of the managers who provided the program estimates specified, and the component numbers to which they apply. d. requirement A narrative description of each program and the basis for the resource can be found in LR H-12. Attachment to DMAIUSPS-TS-6 The titles of the “Program/Functional Managers” who provided the non-penonnel other program estimates specified. are listed below by the applicable components Title Manager, Operations Network Redesign Manager, Marketing Infrastructure Manager, Field Computing Service Centers Manager, Stamp Distribution Network Assistant Inspector General for Employee Investigations Manager, Mail Transport Equipment Manager, Service Center Operations Manager, POS I Manager, Expedited 8 Package Information Services Manager, Workload 8 Productivity Analysis Act. Manager, Operating Budget Manager, Environmental Management Policy Manager, lnplant Operations Manager, International Operations Manager, Financial Administration Services Act. Manager, Opera!ions Process Redesign Manager, Year 2000 Program Manager, Expedited 8 Package Services Manager, Service Management Policies Manager, Information Technology Plans and Standards Manager, Address Management Manager, Delivery Policies 8 Programs Act. Manager, Vehicle Maintenance Manager, Payroll Accounting/Records Manager, Safety 8 Risk Manager, Business Mail Acceptance Manager, Logistics Components 107 165. 167, 167. 168. 180,248 108. 165. 165, 175, 165, 167, 168 174 196’ ’ 210 170 169 1246, 81, 142, 143, 177 177 174 187 177,174 174 177 177 99 174 174. 169 174 174 168, 174, 1177.246, 211 174, 177, ;!I0 168, 174. 1177.211 177 168. 170, I77 177 169,211 ’ 165. 167. ‘168, 169, 177 146 RESPONSE OF WITNESS TAYMAN TO INTERROGATORIES THE DIRECT MAIL MARKETING ASSOCIATION DMAIUSPS-TS-7. OF Please refer to page 194 of LR H-12. a. Over what period of time does the Postal Service deprec,iate Mail Processing Equipment? b. Over what period of time does the Postal Service deprec.iate Real Property? C. Over what period of time does the Postal Service depreciiate Motor Vehicles? d. Over what period of time does the Postal Service deprec:iate Customer Service Equipment? e. Over what period of time does the Postal Service deprec:iate Postal Support Equipment? f. What is the useful life of the equipment in a. through e. above? RESPONSE: a. The Postal Service depreciates mail processing equipment over 10 years. b. The Postal Service depreciates real property over 40 ye,ars. C. Depending on the make and model, the Postal Service clepreciates vehicles over periods ranging from 8-l 2 years. d. Depending on the type of equipment, the Postal Service depreciates customer service equipment over periods ranging from 5-10 years. e. Depending on the type of equipment, the Postal Service depreciates postal support equipment over periods ranging from 3-l 0 years. f. The depreciation periods used by the Postal Service are based on the estimated useful life of the equipment. --- --__ RESPONSE OF WITNESS TAYMAN TO INTERROGATORIES MARKETING ASSOCIATION OFTHE DIRECT MAIL DMAIUSPS-TS-8. Please refer to page 519 of LR H-12. The Septemlber 30, 1996 Balance Sheet shows assets of $25,463.9 million for property and equipment. a. Please disaggregate the allowances for depreciation and amortization $9,157.‘7 million to the amount for buildings, for equipment, and for leasehold improvements. of b. Please provide a listing showing the valuation on the books for all buildings that The Postal Service owns in Washington, D.C., New York City, San Francisco, Los Angeles. For each building, please also indicate the year the Postal Service acquired the building C. Please provide any information the Postal Service has pertaining to the market ‘value of each of the buildings under b. above. RESPONSE: a. depreciation b. Please see pages 528-536 of LR H-12 for the amount of accumulated and amortization by type of property and equipment Please refer to the attached listing of owned buildings for the information requested C. accumulated Postal Service buildings are carried on the books at histmorical costs net of depreciation Principles (GAAP). in compliance with the Generally Accepted Accounting The Postal Service does not maintain information market value of its buildings since they are critical components infrastructure and not intended for sale, related to the of our operating 05amQn c?i45now a64sab2J7 ca5wu2 mamma MlsWoo) Nw8mGM 5M65M)ll -Qis OtwtceOI7 %45aoam owJboI6 05462&025 95463Dwt 0645wm2 0846~QJa 5545JGa ,5amtx2 05455N344 m45al.Qa.a 05m2MoB 05wm-035 0608Qcot3 a5mw.oI n O?oo)bOP4 5IWSOP6 mo36uJ4 almacw5 woo94w -On 6&3705dXll 0557SSGe5 0867MlGw 055lBb~ %sfBbw 055l89.Q1~ Loa ANoElCS WSAI*KLFo WBFw3ELe8 LOS ANGflM LOSAWULQ LOS ANDELEa 109Amwlm LMAJamLfiS LoScllMFs LoevldELEa IDSAxYL68 LoSANDmES UIS MIQELQ IDeMaaFLE LosANGElES LOSMQELES IDSIWOEIJZS Loa AllcELES LDSAtKXLElI LOSANazLCS LOS ANawa LosAlmELps loSAmELE5 LOS Almu LO.3 AYTLES LOSAJ0ELEb Lm ANmLEa Loa AmeLES I.05 AwxLEs LOSMQELES S&N FIWCl9CO SilW Fw\IoScO &n PRANcIcGal EANFR4NCASW 6AHFflANcxxo aANr.twKlam B6MIyuMIyGIm. 184,lm %fU w(OlNI BLVll 575SAllJtilKzdD faI6YwlwmravFJu ,WN-ABTRWT Ins. mloNAKIIu mm ClMrnY mva a-ml MDTunAvEwa 1122 N MlWWTAVE ,270ALFIED ST 1343ao 0 265a.WZTlEWAbE nm c6wnm~ BCW. Illi L3mmul% AVE. 44m w. wAe4mQrrmmw It.96 VXFNONAM. 1 lam wPcelllal SL!m ,CS N Flpmm lJMwM?l X81 B CSZWTRALA'IE. NOAbllRESS NOAM%EW NDAWRESS NC AmRESS B!Ml 6 VERYCW AIlE 1405W7lll57. WOO1 S. CWPTOW AS 2570 GLEMJALE =VD lB5AlvAfwo87 owl SWM olloAvmY 5mJ5¶ 1,213.WS Ii ,55w55 3.w2M 1.3a,11 *ma20 ccl&am 023.041 4.725.29 1,.10,91l 2,507.ad z.m.7n M,rm 12,72&705 s.nm.a54 0,114.w I3a5%2301 79.562 7v,5m me% mm %.4a 130.044 53,414 55.440 w.131 30.510 r.ar41a u.Jlk257 O.@ld= a.na4.m trm.a7 Sl.S2S.W4 3o.m 340&u woa~ MO,U33 1,m1,872 l.W.447 I m.ad 3tl.701 2pP.702 -047 mua6 4Qcs+c n I.o% 5J35,2s2 5,7w.715 aom.4w 15.544.%4 D u.em 227.055 .a75.3511 145.582 257822 TsAm z+m*a aam 307.000 3W,OW 2.440.552 zonp4s AuoOeON 8TA CAlyAL ST STA. CATHEMlU STA COLLEOE STA cowm #lA,. OWN0 tZNTRAL UTATIIM !VlKYSmIQR STATUM LEUOT MU GTA’TKI( ~mN-mA OLD SYATIW PUUITARUII STATtON TW.9 L3OlNW STATKIN @ACE WA. ttXl.OATE STAlloY -UYON STATION YANHATTMMLLE 3-R lRmoMuu( SrATlON mPlem8wmE FORT OEOmE STA. RMlo CIYV BTAYIUI PECK SLP STATION YMrrAN W-lCfM ST aAmocfrf6lA..PN0 YWIWY HLLNNX H4JmaTrWLE PKE RAWCJNSrAhWL caobm Pm MJ ~07 A)(BoulA SIA IlNtCtA~Vl McmMNP&oc lMMTIAwPLoc .,AMESAF~E*P&~ c+wKcH -.. . . ..a ze.. L.. _,I_, 61TIEEr NY IIY NY m NV NY NV YV IN NY NV NV w m NY NV NY MT NY NV w m loaY2.swl laDl3dw 1-e IaLm.~ iw+ww lml7.ouB IWZIJM 1wlww lmll-cBy 1w4(-aa 1mMwm wwo~~ iwt-wn ldo37QoI NKWI-M Iw%aM ww-WI WMnma 1aND4w 1w%.wa IWIQW MY m WI NV NY NV NV NV ur NY mm-em iwi-ww lwzo~ ImID-mw WOMOOI l9oz349m lOllB6w 1WIQDoB !Wl-mm 1oon.ww mKnnw OWWIW WBW92Jl 0lmwlw7 *mnw 8Rlrn -1hW owrna% omlbl~ oIIou0m7 armlna7 o2mllta2 timm6a mmfl967 mmwm Ol~lIIW cmlns7s mow974 oeov1D54 11mlllw2e rmnltppp calnw omnwi Kwvle~ Olmrln OwIIIva wolIIm4 wul/IDY7 loJ59.w Y.w.w t21.277,142 231.W5.720 w3721wD 47.92aa RESPONSE OF WITNESS TAYMAN TO INTERROGATORIES MARKETING ASSOCIATION DMAIUSPS-TS-9 OF THE DIRECT MAIL Please refer to page 525 of LR H-12. a. Of the $21.9 million written off between September 30, 1!396 and September 30, 1995, how much of the write-off was from other government agencies? b. Please disaggregate C. Of the $26.2 million Provision for Doubtful Accounts, how much is from other government agencies? d. Please disaggregate the amount in a. above by agency. the amount in c. above by agency. RESPONSE: a. None of the amounts written off in FY 1996 related to go’vernment agencies. b. Please see my response to a. C. The FY 1996 provision for doubtful accounts includes $5.4 million related to the U.S. Government. d, This amount represents that portion of the revenue foregone appropriation receivable for FY 1997 that was not included in the 199’7 appropriation authorization (Public Law No. 104-208). The Postal Service subsequlsntly received this amount in June, 1997, and the accounting records and financial statelments have been adjusted accordingly. RESPONSE OF WITNESS TAYMAN TO INTERROGATORIES MARKETING ASSOCIATION DMAIUSPS-TS-10 OF THE DIRECT MAlL Please refer to page 525 of LR H-12. a. Could the Postal service reduce uncollectibles by reviewing an aging listing of accounts receivable (AR) more often than twice a year? b. Has the Postal Service performed any studies on the costs and benefits of more frequent AR review? If so, please provide a copy of any such studies. RESPONSE: a. frequently The Postal Service currently reviews its accounts receivable more than twice a year. An aged accounts receivable listing is prepared and reviewed every accounting receivables, b. period (28 days). Based on this ongoing analysis of the provision for doubtful accounts is adjusted twice a ye;x Please see my response to part a. 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 I:2 of the Rules of Practice. Scott L. Reiter 475 L’Enfant Plaza West, S.W. Washington, D.C. 20260-I 137 August 12, 1997 -.
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