BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON,
D.C. 20266-0001
RECEIVEL)
hc 28
J 51 fjj
‘97
POSTA! RATE ci?,+b,i:,:,c,,
OFFICE Oi T,,L ~[cnt’,-~~~
POSTAL RATE AND FEE CHANGES, 1997
RESPONSE
WITNESS
Docket No. R97-1
1
OF UNITED STATES POSTAL SERVICE
NELSON TO INTERROGATORIES
OF
ADVO, INC.
(ADVO/USPS-T19-l-9)
The United States Postal Service hereby provides responses
to the following
August
interrogatories
of witness
of Advo, Inc.: ADVO/USPS-T19-l-9,
Nelson
filed on
14, 1997.
Each interrogatory
is stated verbatim
and is followed
Respectfully
by the re:sponse.
submitted,
UNITED STATES
POSTAL
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
Richard T. Cooper
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-I 137
(202) 268-2993;
Fax -5402
August 28, 1997
-
SERVICE
Response
of
Postal
ADVO/USPS-T19-I.
provide
the full
Service
Witness
Nelson
In regard
to Library
working
definitions
(a)
Devia,tion
(b)
Routine
walking
(c)
Routine
dismount.
to ADVO Interrogatories
Reference
H-151,
please
(as used in the survey)
of:
stop.
loop.
Response:
(a)
It
delivery.
is
assumed
As shown
- Street
Survey
in
Form
that
this
Line
question
21 of
(presented
the
refers
Motorized
on page
34 of
to
deviation
Letter
Route
Library
H-151),
deviation
delivery
involves
delivery
from
not
regular,
designated
vehicle
parking
locations
the
given
\'Routine
walking
address
made from
a stop
parking
location
(c)
location
stops
that
for
are
the
route.
(b)
from
Reference
for
"Routine
a stop
for
that
the
that
the
a regular,
given
is
given
dismount"
is
refers
loop"
route.
to
delivery
a regular,
to
more
designated
than
vehicle
route.
refers
to
delivery
designated
vehicle
to
1 address
parking
made
1
Response
of
Postal
ADVO/USPS-T19-2.
(a)
Motorized
describe
Service
Referring
Witness
Nelson
to
workpaper
your
to ADVO Interrogatories
1.2:
Are the units
in columns
3 and 4 weighted
stops
from
Letter
Route Survey
- Street
Form? If not,
please
the units
and identify
their
source.
(b) Please
provide
a cross-walk
between
the Street
the Activities
in your workpaper
1.2 (i.e.,
line
items
form go into
each of the activities
on the workpaper).
the
Form and
in the
Response:
the
to
(a)
Yes.
(b)
The column
line
number
each
"Activity".
Facility
Street
or
Drop/Pickup"
Form.
labeled
numbers
For
"Variables"
from
the
in
Street
example,
the
corresponds
to
activity
line
Workpaper
1.2
Form
that
correspond
"Express
Mail
12 and
line
contains
14 on the
Response
of
Postal
Service
Witness
Nelson
to
ADVO In,terrogatories
ADVO/USPS-T19-3.
Referring
to your workpaper
1.10,
please
identify
the specific
source
(line
number,
page and library
reference
or workpaper)
of the data in each column.
Response:
Additional
prepared
documentation
and will
be filed
relating
shortly
to
this
workpaper
as a library
is
reference
being
Response
Postal
of
Service
Witness
Nelson
to ADVO Interrogatories
ADVO/USPS-T19-4.
Referring
to your workpaper
1.11,
please
how it was used to develop
the factors
in Alexandrovich's
worksheet
7.0.4.1,
lines
7a, 7b and Ea.
explain
Response:
In
the
general,
driving
activity
"Route/Access
the
to
Among
single
of
the
STS tallies
driving
activity
represented
(note
that
33.33%
on residential
the
value
of
of
the
curbline
exception
0.0057
time
this
change
the
0.0038),
route
driving
route,
identify
type,
are
are
this
from
not
now treated
values
this
route
con this
as
"Collection"
as driving
reduced
in
the
values
information
STS tallies
formerly
now appearing
in
Workpaper
in
1.11
treated
L7a
as
and L7b
the
L8a have
time.
previous
not
as follows:
"Route/Access
are
a
tally
shown
treated
(which
only
been
changed.
Among
used
reflected
Because
formerly
is
each
such
tallies
tallies
routes
of
to
1.11).
collection
"load"
collection
workpaper),
With
the
as
as "Collection",
curbline
Workpaper
to
L7a.
treated
a residential
of
with
used
treated
Within
W/S 7.0.4.1,
formerly
were
formerly
associated
in
(see
33.33%
1.11
"Collection".
tallies
factors
from
Workpaper
STS tallies
and
(FAT)"
tally,
in
within
proportions
develop
data
derived
(FAT)",
from
the
type
Response
ute
of
Postal
Service
Witness
TVD~
Business
foot
Business
motorized
Nelson
to
ADVO Interrogatories
Base
La2
Base Year
LZY
0.00
0.0000
0.3943
34.69
0.2040
0.3840
Residential
foot
0.3479
5.07
0.0176
0.3303
Residential
P&L
0.5676
12.92
0.0733
0.4943
Residential
curbline
0.1689
36.96
0.06434
0.1065
Mixed
foot
0.6725
7.02
0.0472
0.6253
Mixed
P&L
0.5049
23.23
0.1176
0.3873
0.3633
21.88
0.0795
0.2838
Mixed
curbline
IFrom Workpaper
1.11.
2Fonner
L7 x % Driving/loo.
3Former
L7 x (1 - (% Driving/lOO)).
4(0.1689
x 0.3696)
+ (0.3333
X 0.0057i)
Response
of
Postal
Service
ADVO/USPS-T19-5.
the following:
Witness
Nelson
to
workpaper
Referring
(a)
Sources
(b)
Units
for
in
all
the
columns
your
1.14,
please
provide
data.
2 and
3.
(c) Description
to volume/weight.
of
how dismounts
(d) Description
volume/weight.
of
how loops
due
to ADVO Interrogatories
were
were
identified
identified
as being
as: being
due
to
Response:
(a)
to
These
a subset
Motorized
from
data
of
are
supervisors
Letter
Route
an MLR survey
the
contacted
and
asked
to
stops.
The units
It
incorrect.
is
Workpaper
of
1.14
Cc) The
using
the
(d)
using
the
of
is
routine
that
was posed
participated
if
in
the
Street
loops/dismounts
of
the
sampled
supplemental
the
Form
had
route
was
information
(see
Worksheet").
columns
that
the
2 and
some of
incorrect
inputs.
the
3 are
weighted
numbers
values
in
were
A corrected
numbers
these
used
columns
in
version
the
of
attached.
identification
was performed
by route
supervisors
was performed
by route
supervisors
worksheet.
identification
attached
the
Specifically,
provide
spreadsheet
attached
The
in
noted
None
development
Survey.
Point
question
routes
supervisor
20),
(b)
from
that
(Line
"Parking
a follow-up
showed
occurred
attached
from
worksheet.
of
are
1
INDEX
Motorized
Letter
Route Survey - Parking
Point Worksheet
Date Rcrcivcd
l-0: S”pcrvisor
Ra”W
4/Gl!l6
pat-ticipnted in the Mototicd Lctccr Route Survey on
On thal date, the survey shows th;l( a 10181of
11 routine looping / di$mount stop
were made. (See attached - Motori-lrd titter Rautc Survey - Liue 20).
Plcnnc indiatc
how mxny of thcsc stops faU intu each of the following calcgorics:
k Routioc dismounts (ix serving a ringlc address) established due to
recipient mail volume / weight
B. Routine dismounti established due to other fnctorr.
(Describe raalJrs:
)
C. Routioc looping pairrD: rrtablirbcd due to mail vulumc / weight.
D. Routine looping poiuu cstnhlirhcd due 10 ~lher fnctorr
(Describe factors:
__ 11
Total
Plcnsc give n convenient time during a trpical day fur
u* to call you if nccdcd rcprding lhis worksheci
If you need further clarificltion or asristnnc~-in tilling mxt this worksheet you mny contact
survey support personnel at Fwtcr A~~ociatcs, Inc. (a conulting firm ullder contract wilh
USPS l%cadqunrtcn) or USPS Hradquarters, hotb lucxted in the Wnshiugtou. D.C. area:
Tcchnicxl Assiztancc: Poster Associate& Inc. -David Neal (301) 664-71139
Adminislnrtiw
Assistance: USPS lIcndquartcrr
- Dennis SWVCIIS(202) 268-3786
Foslcr Associate% Idc.
4550 Monrgomery Avcnuc, Suite 350N
Ibxhcrda, MD 20814
FAX (3111)664-7810 /VOICE (3Ul) 662-7839
)
-3L7
._,-X4.-?%
/ (85.273.149 7 242,294,460 .L 253,Ji6,338)
I Responses
I
II
i
C.ISMOUNTS
EISMOUNTS
IStops A--Dismounts
i
Due to Volume/Weight
Stops B-Dismounts
Due to Other Factors
-NGCBU
---Parcels
/---nktanr0
hotwee” de!. points
--satety
---Terrain
---School
6ldq.s.
-Office
Eldgs. / Business
--Apts
----COMBINATION:
apts./ofkes.ischoo[si
,---Other
----No Curbside Del.
Toral Dismounts Due to Other Factcrs
Total Dismcunts
LOOPS
Stops C-Loops Due to Volume I Weight
iStops D--Loops Due to Other Factors
----Improves
petformance
---Numerous
Dismounts
----Light Volume
-----Safety
---Separate
Streets
-No
Curbside Del
---NDCBU
-Other
---“Line
rJf travel”
-_-_____“Deliveries across the street”
-+pts
! Tcta! Locpr Cue tc C!ber Factors
jTcta! LOCOS
= 0.4059
1181
I
I
I
1
- I
1
I
162.610.262/
263.516.9661
30,556.1721
li,981,401~
37,271,814
8.502.943
6.3i9.360
.2.53~.4241
50.104,5971
17.796.452
17.516;008
63.192.9E
326.127,249
I
85,273,14S/
327.567,6X(
I
I
38%
I
62?‘0 I
T%l
4%
9%
2%
1%
I
4
7
Response
of
Postal
Service
Witness
Nelson
to ADVO Interrogatories
ADVO/USPS-T19-6.
Referring
to your workpaper
1.14,
and describe
the response
categories
for dismounts
the logic
for each's
separate
categorization:
(a)
NDCBU
(b)
Parcels
(c)
Distance
(d)
Safety
(e)
Terrain
(f)
School
bldgs.
(g)
Office
bldgs/business
(h)
Apts
(i)
Other
(j)
No curbside
between
del.
please
define
and explain
points
del.
Response:
These
"B"
are
on the
the
factors
worksheet
that
attached
were
supplied
to
the
by supervisors.
response
to
See item
ADVO/USPS-T19-5.
Response
of
Postal
ADVO/USPS-T19-7.
and describe
the
logic
for each's
Service
Witness
Referring
response
separate
Nelson
to ADVO Interrogatories
to your workpaper
1.14,
please
categories
for loops
and explain
categorization:
(a)
Improves
performance
(b)
Numerous
dismounts
(c)
Lite
(d)
Safety
(e)
Separate
(f)
No curbside
(g)
NDCBU
(h)
Other
(i)
Line
(j)
Deliveries
(k)
Apts
define
the
volume
of
streets
de1
travel
across
the
street
Response:
These
item
T19-5.
"D"
are
the
on the
factors
worksheet
that
were
attached
supplied
to
the
by supervisors.
response
to
See
ADVO/USPS-
Response
of
Postal
Service
Witness
Nelson
to ADVO Interrogatories
ADVO/USPS-T19-8.
Referring
to your workpaper
the logic
for placing
the data for
"line
of
"deliveries
across
the street"
loops
in the
than the second column).
1.14,
travel"
third
please
and
column
explain
(rather
Response:
These
reported
distinguished
are
in
subsumed
a separate
in
this
within
column
manner.
the
to
"other"
help
category.
ensure
that
They
they
are
are
Response
of
Postal
Service
Witness
ADVO/USPS-T19-9.
Referring
the logic
associated
with
variability.
to
the
Nelson
to ADVO Interrogatories;
your workpaper
1.14,
variables
chosen to
please
calculate
explain
Response:
Variability
is
- The number
of
(263,516,968)
volume.
- The number
related
stops
dismounts
is
Volume
not
of
to
treated
loops
(85,273,149)
is
not
Volume
unknown.
reasonably
number
related
reasonably
be expected
figure
categories.
of
at
any
treated
mail
as 0%.
(242,294,460)
variability
0.4099
than
is
for
such
volume/weight
identifiable
such
stops
way to
is
developed
in
treated
in
Workpaper
mail
as 0%.
Workpaper
volume-related
derived
the
1.14
to
to
stops.
volume
is
On the
dismounts
from
to
Workpaper
the
and applicable
for
other
further
1.14
may
it
volume
variability
the
the
hand,
impllicitly
aggregate
to
such
somewhat
reasons,
be insensitive
in
dismounts
levels
increase
volume-related
shown
omits
variability
higher
margin
for
1.14
Volume
dismount
established
The computation
(0.4099)
volume/weight
way to
is
other
one hand,
volume-related
to
Volume
factors
for
On the
is
imparts
stops
(162,610,282).
a dismount
changes.
than
identifiable
such
in
presented
be expected
of
other
volume/weight
due to
volume/weight
is
any
considerations:
considerations.
The computation
stops
factors
volume.
factor
on these
to
due to
variability
The variability
due
to
in
following
as 100%.
of
based
the
for
mail
- The number
volume.
related
loops
from
due
variability
directly
is
calculated
other
may
once
DECLARATION
1,
the
Michael
foregoing
information
A.
are
Nelson,
true
declare
and correct,
under
to
penalty
the
best
of
of
perjury
my knowledge,
and belief.
Michael
that
Lu.JL.
A. Nelson
CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoing
participants
of record in this proceeding
of Practice.
475 L’Enfant Plaza West, S.W
Washington, D.C. 20260-1137
August 28, 1997
in accordance
doc:ument upon all
with section 12 of the Rules