BEFORE THE
POSTALRATECOMMISSION
WASHINGTON, D. C. 20268-0001
RECElVELl
RUG22
POSTAL RATE AND FEE CHANGES,
1997
:
I 53 PH ‘97
Docket Neo$?.97r&r c’?YHrS!,lati
OFFICEOiTHC SEC!IElAHY
INTERROGATORIESOFADVO,
INC.
TO UNITED STATES POSTAL SERVICE WITNESS
CARI G. DFGFN (ADVOIUSPS-T17-16)
Pursuant to sections 25 and 26 of the Rules of Practice, Advo, Inc. (Advo) directs
the following interrogatories
to United States Postal Service witness Carl G. Degen.
the witness is unable to respond to any interrogatory,
provided by appropriate
If
we request that a response be
USPS witness capable of providing an answer.
Respectfully
submitted,
Thomas
W. McLaughlin
Burzio & McLaughlin
1054 31st Street, N.W.
Washington, D. C. 20007
Counsel for ADVO, INC.
CERTIFICATEOFSERVICE
I hereby certify that I have on this date served the foregoing document upon all
participants of record in this proceeding in accordance with section 12 of the Rules of
Practice.
Thomas W. McLaughlin
August 22, 1997
ADVO, Inc. Interrogatories
to USPS Witness Degen (USPS-T-12)
Please refer to Tables 2 and 6 of your testimony, relating to FY
ADVOIUSPS-T12-1.
1996 Clerk/Mailhandler
Mail Processing
costs.
Please confirm that the only difference between the estimated
co:sts by subclass
shown in these tables is that Table 2 shows results using the ‘ol~d methodology”
while Table 6 shows results using the “new methodology.”
any other differences
If not, please explain
that affect these estimated costs.
Both Tables 2 and 6 show separate costs for “mixed mail” and “other” that are not
distributed
to the subclasses.
Please explain separately
what these costs
represent.
Do the “mixed mail” and “other” mail processing
costs in Tables 2 and 6 represent
the totality of “mixed mail” and “other” costs, or just a portion of sulch costs?
If the
latter,
(1)
Specifically
describe and quantify what portions of total “mixed mail” and
“other” costs are and are not reflected in these figures.
(2)
Are some portions of total “mixed mail” and “other” costs already distributed
to the subclasses
in these tables?
If so, specifically
the type and amounts of such distributed
distributed,
describe and quantify
costs, explain how such costs were
and quantify the amounts so distributed
by subclass/rate
category
Please confirm that combined
“mixed mail” and “other” costs con:stitute 49.6
percent of the total costs shown in Table 2 (old methodology)
total costs shown in Table 6 (new methodology).
the correct percentages
and 50.3 percent of
If not confirmed,
and explain how they were derived.
please provide
-2Please confirm that the following table accurately
ADVOIUSPS-T12-2.
subject to rounding, the differences
(old methodology)
If you cannot coniirm, please
format that shows the correct differences.
Table 2
FIRST
Letters
Private
Postal
Presort
Presort
TOTAL
between the estimated costs shown in your Table 2
and Table 6 (new methodology).
provide a table in comparable
reflects,
Table 6
CLASS
2.848.071
90,701
1.914
616,490
23,057
3.580,233
2,466.167
78.315
1,662
538,754
23,079
3.107.977
(381,904)
(12.386)
(252)
(77,736)
(472.2526:
-13.4%
-13.7%
-13.2%
-12.6%
0.1%
-13.2%
Priority
Express
Mailgrams
264,768
62,632
62
162,067
24,858
50
(102,701)
(37,774)
(12)
-38.8%
-60.3%
-19.4%
SECOND CLASS
Wthin Countv
Regular
’
Nonprofit
Cla&room
TOTAL SECOND
9.525
244,‘398
44,430
2,485
300.838
7,722
202,342
36,478
2,101
248,643
(1.803)
(42,056)
(7.952)
(384)
(52,195)
-18.9%
-17.2%
-17.9%
-15.5%
-17.3%
THIRD CLASS
Single Piece
Carrier Route
Non-CR
BRR
NP Carrier Route
NP Non-CR
NP
TOTAL THIRD
45,958
144,856
878,996
1.023,852
15,565
212,502
228.067
1,297:077
37,603
120.085
749,735
869,820
12.172
181,653
193,825
1,101,248
(8.355)
(24,771)
(129,261)
(154,032)
(3.393)
(30,849)
(34,242)
(196,629)
4TH CLASS
Parcels
BPM
Special
Library
TOTAL FOURTH
81.349
38,043
40.228
8,503
168,123
57,674
31,673
31,918
7,084
128,349
(23,675)
(6,370)
(8.31’3
(1.419)
(39,774)
-29.1%
-16.7%
-20.7%
-16.7%
-23.7%
USPS
Free for Blind
International
Special Services
58;692
5,305
123.044
216,347
39,583
4,103
89,235
88,425
(19,109)
(1,202)
(33,809)
(127,922)
-32.6%
-22.7%
-27.5%
-59.1%
Mixed
Other
mailing
cards
letters
cards
FIRST
cards
mail
TOTAL
-
-18.2%
-17.1%
-14.7%
-15.0%
-21 .a%
-14.5%
-1 5.0%
-15.2%
2.670.527
3,306.638
2,140,038
2.907.951
(530.489)
(398,687)
-19.9%
-12.1%
12,055.086
10.042,527
(2.012.559)
-16.7%
-3Please refer to Tables 5 and 6 of your testimony
ADVONSPS-T12-3.
Please confirm that the estimated costs by subclass in Table 6 reflect distributed
(4
volume-variable
distribution
0))
costs by subclass under the “new methodology,”
before
of “mixed mail” and “other” costs to the subclasses.
Please confirm that the “Total” column in the last page of your Table 5 reflects
distributed
volume-variable
distribution
of “mixed mail” and ‘otheT costs to the subclasses.
(c)
costs by subclass under the “new methodology,”
Please confirm that the only difference
between the estimated toial costs by
subclass in these two tables is that Table 5 reflects the distribution
subclasses
after
to the
of the “mixed mail” and “other” costs shown in Table 6.
tf you Cannot confirm, please explain fully why not.
Tables 2 (old methodology)
ADVOIUSPS-T12-4
estimated
costs by subclass before distribution
to the subclasses
and “other” costs listed at the bottom Iof those tables.
shows estimated
costs.
costs by subclass after distribution
Please provide a table corresponding
subclass after distribution
methodology.
and 6 (new methodology)
show
of the “mixed mail”
Table 5 (new rnethodology)
of the “mixed mal” and “other’
to Table 5 showing estimated
costs by
of the “mixed mail” and “other” costs under the old
-4ADVOIUSPS-T12-5.
subclass, after distribution
Column 2 of the following table shows the tot,al costs by
of “mixed mail” and “other” costs, from the last column of
your Table 5 (new methodology).
subclass, after mixed mail/other
In column 1, please provide the comparable
cost distribution,
under the u
columns :) and 4, please provide the absolute and percentage
methodology.
differences
costs by
In
by subclass
between the new and old methodology
Qld Method
Table 5
New Method
FIRST CLASS
Letters
Private mailing cards
Postal cards
Presorl letters
Presort cards
TOTAL FIRST
133,288
3,062
1.063.505
35,765
5.891.293
477,893
Priority
Express
84.370
75
Mailgrams
SECOND
4.655,673
CLASS
WIthIn County
Regular
Nonprofit
Classroom
TOTAL SECOND
THIRD CLASS
Single Piece
Carrier Route
Non-CF?
BRR
NP Carrier Route
NP Non-CR
NP
TOTAL THIRD
4TH CLASS
15,161
461,201
80,618
5,632
562,612
78.184
265,772
1.540.108
1.805,880
28,895
366,726
395,621
2,279.685
FOURTH
156,650
73,210
67.076
16,065
313,001
USPS
Free for Blind
International
Special Services
77,044
10,022
206.773
139,761
Parcels
BPM
Soecial
Library
TOTAL
TOTAL
10,042.529
w
% Chane
ADVOIUSPS-T12-5.
differences
-5Please confirm that the following table accurately
between the CRA FY 1996 and Base Year attributable
Cost Segment 3.1, Clerk/Mailhandler
reflects the
costs by subclass for
- Mail Processing - Direct Labor.
If you cannot
confirm, please provide the corrected costs and differences
CS 3.1 -Mail
FIRST CLASS
LetWS
Presorl letters
Cards
Presort cards
TOTAL
FIRST
5.898.081
1,267,220
193,541
49,707
7,408,549
Processina
-Direct
Base Year
4,774,417
1.080.864
140,336
37,457
6,033,074
Labcx
Ghanw
(1.123,664)
(186,356)
Gael;
(1.375.h75)
-19.1%
-14.7%
-27.5%
-24.6%
-18.6%
462,927
71,960
130
477,606
83,202
79
14,679
11.242
(51)
3.2%
15.6%
-39.2%.
15,210
467,201
81,970
5,720
570,101
(1,409)
SECOND
16,619
476,857
87,663
4,919
586,058
1E63;
’ 801
(15,957)
-8.5%
-2.0%
-6.5%
16.3%
-2.7%
THIRD CLASS
Single Piece
Carrier Route
Non-CR
BRR
NP Carrier Route
NP Non-CR
NP
TOTAL THIRD
92,271
258,474
1,638,901
1.897,375
27,957
393,825
421,782
2,411,428
75,564
256,941
1,486,117
1,743.058
27,934
353,421
381,355
2,199.977
(16,707)
(1.533)
(152,784)
(154,317)
(23)
(40,404)
(40,427)
(211.451)
-18.1%
-0.6%
-9.3%
-8.1%
-0.1%
-10.3%
-9.6%
-8.8%
4TH CLASS
Parcels
BPM
Special
Library
TOTAL FOURTH
169,886
82,412
84,986
19,417
356,701
153,080
71.247
65,485
15,647
305,459
(16,806)
(11,165)
(19,501)
(3.770)
(51,242)
-9.9%
-13.5%
-22.9%
-19.4%
-14.4%
USPS
Free
International
Special Services
122,795
11,983
276,453
194,623
92,173
10,378
214,584
116,331
(30,622)
(1,605)
-24.9%
-13.4%
-22.4%
-40.2%
11.903,607
551,786
12.455.393
95.6%
10,102,964
3,144.448
13.247,412
76.3%
PrIl3rity
Express
MallgramS
SECOND CLASS
Wl,hin County
Regular
Nonprofit
Classroom
TOTAL
TO’TAL ATTRIB
INSTITUTIONAL
ACCRUED
% ATRIB.
;;:;q
-15.1%
469.9%
6.4%