#.
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20266-0691
POSTAL RATE AND FEE CHANGES, 1997
Docket No. R97-1
/
RESPONSE OF UNITED STATES POSTAL SERVICE
WITNESS DEGEN TO INTERROGATORIES
OF
UNITED PARCEL SERVICE
REDIRECTED FROM WITNESS PATELUNAS
(UPS/USPS-T151
- 4)
The United States Postal Service hereby provides responses of witness Degen to
the following interrogatories
of United Parcel Service:
UPS/USPS-T’151
- 4, filed on
July 29, 1997, arid redirected from witness Patelunas.
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
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-I 137
(202) 268-2992; Fax -5402
August 12, 1997
Re!sponse of United States Postal Service Witness
to Interrogatories
of United Parcel Service
(Redirected from Witness Patelunas)
UPS/USPS-T1
Degen
5-l.
Please refer to your response to DMA/USPS-T7-19
(redirxected from
witness Crum) in Docket No. MC97-2.
Please confirm that costs for moving
empty equiprnent are distributed
to classes and subclasses of mail in
essentially
the same proportion
as the IOCS observations
for postal
employees handling mail, without regard to the type of equipment
being
moved.
If not confirmed,
please explain in full.
UPS/USPS-T1
5-1 Response.
Not confirmed.
I assume
costs
associated
with
The “equipment”
distribution
account
key methodology,
the type of equipment
the employele
for moving
IOCS activity
being moved
item or a container,
distribution
“costs
by the response
handling
at II-8 to 11-10.
will take into
was observed
handling
to IOCS Question
an item or a container,
the cost pool but cannot
type for lack of information.
Under the new
of these costs
if the employee
as indicated
refers to
code 6523.
the distribution
will take into account
10-l 1, and I-R-H-146
equipment”
can be items or containers.
was not observed
the equipment
empty
21.
an
If
the
take into account
Also please see USPS-T-l
2 at
Response of United States Postal Service Witness
to Interrogatories
of United Parcel Service
(Redirected from Witness Patelunas)
UPS/USPS-T1
Degen
5-2.
Are certain types of equipment
(the moving of which is ciaptured
“moving empty equipment”)
used uniquely or significantly
for unique
classes, shapes, or other types of mail? If so, specify what types of
equipment
are used for what classes, shapes, or other types of mail.
UPS/USPS-T1
Yes.
classes
5-2 Response,
Most of the “items”
of mail.
my testimony,
distributions.
in
have a significant
This is why the distribution
USPS-T-l
2, makes
The following
Blue & Orange Sack
Green Sack
Orange or Yellow Sack
Brown Sack
White Sack
International
Sack or
with
shapes
key methodology
the significant
or
described
use of the item type in mixed-mail
table describes
Table of Item Type and Associated
association
associations.
Shape or Class of Mail
Shape/Class
Association
Letter shape
Fiat shape
IPPlParcel shape
Second-Class
regular rate, Third-Class
regular rate
Express Mail
First-Class Mail
Priority Mail
Second-Class
Mail
Third-Class
Mail
International
Mail
bulk
in
Response of United States Postal Service Witness
to Interrogatories
of United Parcel Service
(Redirected from Witness Patelunas)
UPS/USPS-T1
5-3.
Please provide a breakdown
of moving
type of empty equipment
being moved.
UPS/USPS-T’I
in activity
empty
by equipment
does not include
equipment
table is only meant
some degree
1 to this response
code 6523
key methodology
moving
empty
equipment
costs
by
5-3 Response.
Please see Attachment
dollars
De!gen
costs-see
to indicate
type.
a distribution
types
of IOCS tally
Since the new distribution
procedure
the response
that empty
for all of the equipment
for a breakdown
equipment
included
specifically
to UPS/USP!j-T15-1
costs
are present
in IOCS.
for
-this
to
Attal:hment
1, Response to UPS/USPS-T1 5-3
FY ‘Y996 IOCS dollars, Activity Code 6523, by equipment
Clerks and Mailhandlers,
Mail Processing
r
IIOCS dollars
1($000), Activity
Page 1 of 1
type
I
1% of Activity
1
Response of United States Postal Service Witness
to Interrogatories
of United Parcel Service
(Redirected from Witness Patelunas)
Degen
UPSAJSPS-T15-4.
Has any analysis or other study, investigation,
or inquiry been
performed to determine if the costs associated with moving empty
equipment
could be distributed
to specific classes or shapes of mail which
give rise to those costs?
If yes, please provide these studies and explain.
UPS/USPS-T1
Yes.
5-4 Response
The mail processing
testimony,
cost distribution
USPS-T-1 2, and in LR-H-146,
methodology
is the result
described
in my
of such a study.
DECLARATION
I, Carl G. Degen,
answers
declare
are ‘true and correct,
and belief.
under penalty
of perjury
that the foregoing
to the best of my knowledge,
inflxmation,
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-l 137
August 12, 1997
in accordance
upon all
with section 12 of the Rules of