DOCKET SECTION
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20266-0001
7
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POSTAL RATE AND FEE CHANGES, 1997
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Docket
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RESPONSE OF UNITED STATES POSTAL SERVICE
TO INTERROGATORY
OF ADVO, INC.
AND MOTION FOR ITS LATE ACCEPTANCE
(ADVOIUSPS-30)
The United States Postal Service hereby provides the response to the following
interrogatory
of Advo, inc.: ADVO/USPS-30,
interrogatory
is stated verbatim and is followed by the response.
The Postal Service additionally
asks that this response be accepted today, four
days (two business days) out of time.
appropriate
filed on October 10, 1997. The
Because of some confusion in determining
personnel to respond to the discovery request, and due to the
participation
of the majority of the Postal Service’s Finance Department
last week, the response could not be prepared until today.
in training
The Postal Service
regrets this delay, and will fax a copy of the response to counsel for Advo this
afternoon
in order to mitigate any prejudice that it may have caused.
Respectfully
submitted,
UNITED STATES POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-I 137
(202) 268-2970; Fax -5402
November 3, 1997
the
RESPONSE
OF THE UNITED STATES POSTAL SERVICE
TO INTERROGATORIES
OF ADVO
ADVOIUSPS-30.
Please refer to the response to ADVO/USPS5a.,
which asked
for information on average number of possible deliveries for each city carrier
route type for FY94, FY95, and FY96. The response provides data on total
annual possible deliveries rather than average by route type.
a. Please provide the number of routes by route type for FY94, FY95. and FY96
in a format similar to that used in the response to ADVOIUSPS-5a.
b. For each route type listed in the response, please provide a description of
the route type (e.g., motorized business letter route).
RESPONSE:
a. Shown below are estimated numbers of routes by carrier route type, obtained
from the Carrier Cost System.
Route
I!&s
1500
1502
1506
1540
1551
1552
1557
1560
1562
1571
1573
1575
1620
1640
1642
1720
1730
1740
1770
Fy94
1,626
1,580
Fy95
1,763
1,565
16,440
149
493
1,280
93,358
29,446
3,963
1,483
325
549
7,214
813
16,869
167
486
1,232
93,315
29,718
3,434
1,535
242
586
7,354
768
298
11
264
310
Fy96
1,754
1,638
12
16,298
52
453
1,261
92,622
29,633
3,784
1,462
260
581
7,328
821
58
244
222
260
RESPONSE
b. The description
1502
1506
1540
1551
1552
1557
1560
1562
1571
1573
1575
1620
1640
1642
1720
1730
1740
1770
OF THE UNITED STATES POSTAL SERVICE
TO INTERROGATORIES
OF ADVO
of each route type is given below
Description
Business 1-Trip Foot Regular
Business l-Trip Motorized Regular
Business 2-Trip Motorized Regular
Residential Foot Regular
Business l-Trip Foot Auxiliary
Business 1-Trip Motorized Auxiliary
Residential Foot Auxiliary
Residential Park & Loop Regular
Residential Curb Regular
Residential Park 8 Loop Auxiliary
Residential Curb Auxiliary
Mixed Park & Loop Auxiliary
Mixed Foot Regular
Mixed Park & Loop
Mixed Curb Regular
Business 2-Man Foot Regular
Business 3-Man Foot Regular
Business 4-Man Foot Regular
Residential 2-Man Foot Regular
CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoing document
participants
of record in this proceeding
Practice.
475 L’Enfant Plaza West, SW.
Washington, D.C. 20260-I 137
November 3, 1997
in accordance
upon all
with section 12 of the Rules of