BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON,
D.C. 20268-0001
@XIvE~
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POSTAL oifib,:T,,i r,iC!aTARY
bFF,CE
1
POSTAL RATE AND FEE CHANGES, 1997
RESPONSE
OF UNITED
The United
interrogatories
August
September
No. R97-1
STATES POSTAL SERVICE TO INTER,ROGATORIES
OF UNITED PARCEL SERVICE
(UPS/USPS-18-20
and 21(b))
States
Postal
Service
of United
Parcel
Service:
22, 1997.
Docket
An objection
hereby
provides
responses
UPS/USPS-18-20
to interrogatory
to the following
and 21(b),
UPS/USPS-21(a)
filed on
was filed on
2, 1997,
Each interrogatory
is stated verbatim
and is followed
Respectfully
UNITED
by the response,
submitted,
STATES
POST.4L
By its attorneys:
Daniel J. Foucheaux,
Jr.
Chief Counsel, Ratemakiing
,&
Susan
475 L’Enfant Plaza West, S.W.
Washington,
D.C. 20260-I 137
(202) 268-2990;
Fax -5402
September
5, 1997
*..-lea
M. Duchek
SERVICE
Page 1 of 1
Response
UPS/USPS-18.
of United States Postal Service
to
Interrogatories
of UPS
Please refer to the response
to Interrogatory
(4
In the MODS data system,
If so, specify all information
(b)
In the PIRS data system, is any information
If so, specify all information that is collected
of mail.
UPS/USPS-18
(4
In MODS,
information
are designated
is collected
operation
collected for different mail shapes?
on the basis of thss different shapes
numbers.
mail shapes through
MODS distribution
Machine,
the use of
operation
numbers
MODS information
collected
include work hours and piece handlings
In PIRS, data is collected
on parcels in the various
Non-Machinable
letters and flats, trays are recorded
operations.
for different
as letter, flat, or parcel operations.
for these operations
Sorting
is any information collected for different mail shapes?
collected on the basis of the different shapes of mail.
Response:
MODS distribution
(b)
UPS/USPS-T14-4(a)
Outsides,
BMC parcel operation
and Irregular
Parcel Post).
(Parcel
For
for the BBM Letter Tray and BBM Flat Tray
Hours are also recorded for these operations.
Page 1 of 1
Response
of United States Postal Service
to
Interrogatories
of UPS
UPS/USPS-19.
Please refer to the response to Interrogatory UPS/USPS-T14-4(e),
which states that MODS and PIRS data are reviewed at headquarters
and that
anomalous values are identified and reported to the individual facilities involved “for
appropriate resolution.”
When anomalous values are identified, are -those values ever
changed for purposes of MODS data, or is the anomalous data edited or changed in
any way after it is identified and reported to the individual facilities?
UPS/USPS-l9
Anomalous
districts
Response:
values in MODS and PIRS data may be identified
or individual
the adjustment
431.1
facilities.
processes
Anomalous
by hezldquarters,
values in the data would be resolved
for either work hours or volumes
areas,
through
See M-32, at section
Page 1 of 1
Response
of United States Postal Service
t0
Interrogatories
UPS/USPS-20.
Please refer to the response
of UPS
to Interrogatory
(4
Please identify the “additional
base year.
(b)
Are the criteria used by district and area management
along with operations
support personnel at headquarters for purposes of deciding whether to
designate additional locations for inclusion in MODS set forth in writing? If so,
please produce all such criteria. If not, please indicate the nal.ure of the factors
considered in making the decision whether to designate additional locations for
inclusion in MODS.
UPS/USPS-20.
(4
locations”
that reported
UPS/USPS-T14-10.
MODS (data during the
Response:
Please see the response
to TWNSPS-T12-17
for a listing of MODS locations
by
type.
(b)
The criteria
used by district and area management
personnel
at headquarters
additional
locations
factors
considered
inclusion
whether
in MODS are not set forth in writing.
in making the decision
and the existence
to designate
on available
of other MODS locations.
Center, the delivery
the additional
the Processing
location
and Distribution
unit may be designated
The nature of the
an additional
location for
data reporting
For example,
if a
and
as a IMODS location
may use the same data reporting
Center.
support
to designate
unit were located within the same building as a Processing
Distribution
because
of deciding
in MODS would be base primarily
technology
delivery
for purposes
along with operations
technology
as
Answer
of United States Postal Service to the Interrogatories
United Parcel Service
to United States Postal Service
of
UPS/USPS-21
(b) The response states that in the Postal Service’s rollforward
model, “advertising
costs are treated as ‘Other’ costs and not explicitly identified
with any particular class of mail ” (emphasis added). Please provide, separately
for Priority Mail, Express Mail, Parcel Post, and International
Mail, those
advertising costs that are included in the “Other” costs in the Postal Service’s
rollforward model (I) for FY 1997 and (ii) for FY 1998.
UPS/USPS-21
(b) Response:
There has been no change
concerning
previous
the treatment
dockets,
in the Postal Service’s
of advertising
factors
requirement
See Witness
witness.
single amount for advertising
component
presentations,
is included
provided
Tayman,
year followed
No. R97-1 presentation,
in the “Other”
pattern and includes
is no class specific
as in
of the revenue
to the classes
advertising
the same pattern.
model shows the advertising
Postal Service
to UPS/USPS-5,
costs as identified
to classes
In the Postal
the base year advertising
amount
this
of mail b;ased on the
total amount was distributed
cost development
As stated in the response
For each outyear,
In previous
cost line; hence, the rollforward
the total advertising
that is “rl~lled-forward”
USPS-T-g.
in the base year.
the base year advertising
Docket
In Docket No. R974,
in the testimony
is distributed
distribution
of mail and each rollforward
Service’s
model
there is a single amount for advertising
using the appropriate
advertising
costs.
rollforward
follows
in the “Other”
total amount
the same
co,st line.
There
beyond the base year.
the Commission
with particular
rollforward
classes
of mail
Answer
of United States Postal Service to the Interrogator-ies
United Parcel Service
to United States Postal Service
See USPS LR-H-215.
Postal Service
This is the methodology
presentations.
described
of
above for previous
CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoing document
upon all
participants
of record in this proceeding in accordance
with section 12 of the Rules
of Practice.
475 L’Enfant Plaza West, S.W.
Washington,
D.C. 20260-I 137
(202) 268-2990;
Fax -5402
September
5, 1997