DOCKET SEC-flON
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON,
D.C. 20268-0001
POSTAL RATE AND FEE CHANGES, 1997
Docket
i
RESPONSE OF UNITED STATES POSTAL
INTERROGATORIES
OF THE OFFICE OF
REDIRECTED
FROM WITNESS
(OCAIUSPS-T5-17-23
The United States Postal Service
to the following
T5-17-23
interrogatories
SERVICE WITNESS DEGEN TO
THE CONSUMER
ADVOCATE
ALEXANDROVICH
AND 26)
hereby provides
responses
of the Office of the Consumer
and 26, filed on September
No. R97-1
9, 1997 and redirected
of witness
Advocate:
Degen
OCAIUSPS-
from witness
Alexandrovich.
Each interrogatory
is stated verbatim
and is followed
Respectfully
UNITED
by the response
submitted,
STATES
POSTAL
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
f’&-l
/
-
Eric P. Koetting
475 L’Enfant Plaza West, SW.
Washington,
D.C. 20260-I 137
(202) 268-2990;
Fax -5402
September 23, 1997
‘k
SERVICE
Response of United States Postal Service Witness Degen
to Interrogatories
of Office of the Consumer Advocate
(Redirected from Witness Alexandrovich)
OCA/USPS-T5-17.
Please provide the cost components
of segment
FY 1996 CRA and the BY 1996 segments and components
reports
separately for MODS offices, non-MODS offices, and BMC’s.
OCA/USPS-T5-17
Neither
Response.
the FY 1996
produce
adjusted
nor the BY 1996
component
costs
breakdown,
one might
cost totals.
This is fairly
straightforward
LR-H-201,
group
cost inputs
are reported
file ~~03.~1s.
and component
to this response
shows
CRA methodology
by office
approximate
principal
3 of the
group.
apply split factors
group
the total
can be used to generate
the calculations
To obtain
to
an
to the component
for the BY 1996 costs,
by office
For FY 1996,
was designed
in W/S 3.0.1
since the
page 2, in
IOCS tally costs
split factors.
for these approximate
by office
Attachment
breakdowns.
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Response of United States Postal Service Witness Degen
to Interrogatories
of Office of the Consumer Advocate
(Redirected from Witness Alexandrovich)
OCANSPS-T5-18.
Please refer to the description
of accrued mail
processing costs (section 3.1.2) on page 3-6 of library reference H-l.
This
section describes the roster designation
codes, uniform operation codes,
and activity codes used to define accrued mail processing costs.
a. Please identify the library reference, program name, and line numbers of
the program that calculates the accrued mail processing cost for clerks
and mailhandlers
for (1) the FY 1996 CRA costing methodology
and (2)
the BY 1996 costing methodology.
b. Please provide a citation to the portion of the library reference which
documents
the program that calculates the accrued mail processing cost
for clerks and mailhandlers
for (1) the FY 1996 CRA methodology
and
(2) the BY 1996 costing methodology.
c. Please refer to witness Degen’s costing methodology
for non-MODS
offices.
Please list all differences
between the FY 1996 CRA calculation
of accrued costs for cost component
3.1 and witness Degen’s
methodology
for developing
non-MODS accrued costs.
d. Please refer to witness Degen’s costing methodology
for non-MODS
offices.
Please list all similarities
between the FY 1996 and CRA
calculation
of accrued costs for cost component
3.1 and witness
Degen’s methodology
for developing
non-MODS accrued costs.
e. If documentation
or programs have not been provided as library
references in this docket, but were provided in whole or in part in a
previous docket, please provide the citations requested in parts a and b
of this interrogatory
to such previous dockets.
f. In addition to any citations to library references or other documents
provided in parts a, b and e of this interrogatory,
please provide citations
to relevant portions of library references H-l 96 and H-2 15.
OCANSPS-T5-18
Response.
a. The referenced
section
methodology
of LR-H-l
inputs
only to the FY 1996 costing
in that the “sum of mail processing
sum of tally dollar weights
weighting
is relevant
is performed
for FY 1996
(variable
in program
are obtained
F9250).
ALB095,
from
costs”
refers to the
The IOCS tally cost
LR-H-21.
LIOCATT
output,
The IOCS cost
which
may be
Response of United States Postal Service Witness Degen
to Interrogatories
of Office of the Consumer Advocate
(Redirected from Witness Alexandrovich)
found
in LR-H-196
reapportionment
components
program
reapportionment
components
is described
MODSPOOL
is performed
c. The differences
costs
3.1.2
with
primary
difference
in LR-H- 196, file ~~03.~1s.
cost pool amounts
for the BY 1996
part I. See
and pages l-2 to l-3 of LR-H-146.
in W/S 3.0.1,
costs
in LR-H-201,
Some
among
file wsO3.xls.
to part a.
USPS-T-l
by contrasting
are defined
to the FY 1996
the description
2 at pages 6-7 and LR-H-146
is that mail processing
methodology
Some
among
in detail in LR-H-146,
may be obtained
section
in contrast
and I-forms.xls).
of BY 1996 clerk and mailhandler
b. Please see the response
BY 1996
in W/S 3.0.1,
of the mail processing
methodology
especially
files wsO3.xls
of FY 1996 clerk and mailhandler
is performed
Development
costing
(see especially
part I. The
costs at MODS offices
in the
of MODS operation
numbers,
in terms
definition
in LR-H-l
based on IOCS uniform
operation
codes.
d. The similarities
section
3.1.2
main similarity
offices
codes
may be obtained
with
USPS-T-12
by comparing
at pages 6-7 and LR-H-146
is that mail processing
are derived
the description
costs
part I. The
at BMCs and non-MODS
using IOCS tally costs for the IOCS uniform
listed in section
3.1.2
of LR-H-1.
in LR-H-l
operation
Response of United States Postal Service Witness Degen
to Interrogatories
of Office of the Consumer Advocate
(Redirected from Witness Alexandrovich)
e. Not applicable.
f.
The relevant
response
citations
to LR-H-196
to part a, above.
and LR-H-201
are provided
in the
Response of United States Postal Service Witness Degen
to Interrogatories
of Office of the Consumer Advocate
(Redirected from Witness Alexandrovich)
OCAIUSPS-TS-19.
Please refer to the description
of accrued window
service costs (section 3.2.2) on pages 3-S and 3-10 of library reference H-1,
This section describes the roster designation
codes, uniform operation
codes, and activity codes used to define accrued window service costs.
a. Please identify the library reference, program name, and line numbers of
the program that calculates the accrued window service cost for (1) the
FY 1996 CRA costing methodology
and (2) the BY 1996 costing
methodology.
b. Please provide a citation to the portion of the library reference ,which
documents
the program that calculates the accrued window service cost
for (1) the FY 1996 CRA methodology
and (2) the BY 1996 costing
methodology.
c. Please refer to witness Degen’s costing methodology
for non-MODS
offices.
Please list all differences
between the FY 1996 CRA calculation
of accrued costs for cost component
3.2 and witness Degen’s
methodology
for developing
non-MODS accrued costs for window
service.
d. Please refer to witness Degen’s costing methodology
for non-MODS
offices.
Please list all similarities
between the FY 1996 CRA calculation
of accrued costs for cost component
3.2 and witness Degen’s
methodology
for developing
non-MODS accrued costs for window
service.
e. If documentation
or programs have not been provided as library
references in this docket, but were provided in whole or in part in a
previous docket, please provide the citations requested in parts a and b
of this interrogatory
to such previous dockets.
f. In addition to any citations to library references or other documents
provided in parts a, b and e of this interrogatory,
please provide citations
to relevant portions of library references H-l 96 and H-21 5.
OCANSPS-T5-19
Response.
a. The referenced
section
methodology
in that
dollar weights
performed
“all window
(variable
in program
of LR-H-1 is relevant
F9250).
ALB095,
service
only to the FY 1996 costing
costs”
refers to the sum of tally
The IOCS tally cost weighting
LR-H-21.
The IOCS cost inputs
is
for FY
Response of United States Postal Service Witness Degen
to Interrogatories
of Office of the Consumer Advocate
(Redirected from Witness Alexandrovich)
1996 are obtained
from
196 (see especially
reapportionment
components
is performed
program
reapportionment
components
service
for the BY 1996
part I. See
costs
in LR-H-201,
Some
among
file ~~03.~1s.
to part a.
LR-H-146
by contrasting
at MODS offices
defined
in terms
of MODS operation
based on IOCS uniform
may be obtained
LR-H-146
the description
part I. The primary
costs
numbers,
with
service
costs
at BMCs and non-MODS
offices
operation
is that
methodology
in contrast
are
to the FY 1996
the description
part I. The main similarity
tally costs for the IOCS uniform
in LR-H-l
codes.
by comparing
3.2.2
difference
in the BY 1996
operation
section
LR-H-l.
cost pool amounts
in W/S 3.0.1,
may be obtained
with
file wsO3.xls.
and pages l-2 to l-3 of LR-H-146.
service
d. The similarities
in LR-H-196.
among
in detail in LR-H-146,
window
definition
costs
of BY 1996 clerk and mailhandler
c. The differences
in LR-H-
Some
clerk and mailhandler
MODSPOOL
is performed
3.2.2
may be found
and 1forms.xl.s).
is described
b. Please see the response
section
which
in W/S 3.0.1,
of the window
methodology
especially
output,
files wsO3.xls
of FY 1996
Development
costing
LIOCAlT
are derived
in LR-H-1
is that window
using
codes listed in section
IOCS
3.2.2
of
Response of United States Postal Service Witness Degen
to Interrogatories
of Office of the Consumer Advocate
(Redirected from Witness Alexandrovich)
e. Not applicable.
f.
The relevant
response
citations
to LR-H-196
to part a, above.
and LR-H-201
are provided
in the
Response of United States Postal Service Witness Degen
to Interrogatories
of Office of the Consumer Advocate
(Redirected from Witness Alexandrovich)
OCA/USPS-T5-20.
Please refer to the description
of accrued administrative
and support activities
costs (section 3.3.2) on pages 3-14 and 3-l 5 of
library reference H-l.
This section describes the roster designation
codes,
uniform operation codes and activity codes used to define accrued
administrative
and support activities costs.
a. Please identify the library reference, program name, and line numbers of
the program that calculates the accrued administrative
and support
activities
cost for (1) the FY 1996 CRA costing methodology
and (2) the
BY 1996 costing methodology.
b. Please provide a citation to the portion of the library reference which
documents
the program that calculates the accrued administrative
and
support activities cost for (1) the FY 1996 CRA methodology
and (2) the
BY 1996 costing methodology.
c. Please refer to witness Degen’s costing methodology
for non-MODS
offices.
Please list all differences
between the FY 1996 CRA calculation
of accrued costs for cost component
3.3 and witness Degen’s
methodology
for developing
non-MODS accrued administrative
and
support activities
costs.
d. Please refer to witness Degen’s costing methodology
for non-MODS
offices.
Please list all similarities
between the FY 1996 CRA calculation
of accrued cosl:s for cost component
3.3 and witness Degen’s
methodology
for developing
non-MODS accrued administrative
and
support activities
costs.
e. If documentation
or programs have not been provided as library
references in this docket, but were provided in whole or in part in a
previous docket, please provide the citations requested in parts a and b
of this interrogatory
to such previous dockets.
f. In addition to any citations to library references or other documents
provided in parts a, b, and e of this interrogatory,
please provide
citations to revelant portions of library references H-l 96 and H-21 5.
OCANSPS-T5-20
Response.
a. The referenced
section
methodology
in that
of LR-H-1 is relevant
“all administrative
the sum of tally dollar weights
(variable
only to the FY 1996 costing
and support
F9250).
work
costs”
refers to
The IOCS tally cost
Response of United States Postal Service Witness Degen
to Interrogatories
of Office of the Consumer Advocate
(Redirected from Witness Alexandrovich)
weighting
is performed
in program
inputs
for FY 1996 are obtained
found
in LR-H-196
is performed
of the administrative
methodology
especially
program
reapportionment
components
is described
MODSPOOL
is performed
c. The differences
3.3.2
administrative
defined
costs
in terms
definition
section
3.3.2
administrative
in LR-H-196,
LR-H-146
part I. See
and pages l-2 to l-3 of LR-H-146.
of LR-H-1.
costs
in LR-H-201,
by contrasting
Some
among
file ~~03.~1s.
at MODS offices
LR-H-146
the description
part I. The primary
may be obtained
costs
file ~~03.~1s.
in detail in LR-H-146,
difference
in LR-H-l
is that
in the BY 1996 methodology
numbers,
operation
in contrast
are
to the FY 1996
codes.
by comparing
the description
part I. The main similarity
at BMCs and non-MODS
IOCS tally costs for the IOCS uniform
3.3.2
costs among
for the BY 1996
of MODS operation
with
Some
to part a.
based on IOCS uniform
d. The similarities
may be
cost pool amounts
in W/S 3.0.1,
may be obtained
with
which
and I-formsxls).
of BY 1996 clerk and mailhandler
b. Please see the response
section
files wsO3.xls
in W/S 3.0.1,
The IOCS cost
output,
of FY 1996 clerk and mailhandler
Development
costing
LR-H-21.
from LIOCATT
(see especially
reapportionment
components
ALB095,
operation
offices
in LR-H-1
is that
are derived
using
codes listed in section
Response of United States Postal Service Witness Degen
to Interrogatories
of Office of the Consumer Advocate
(Redirected from Witness Alexandrovich)
e. Not applicable.
f.
The relevant
response
citations
to LR-H-196
to part a, above.
and LR-H-201
are provided
in the
Response of United States Postal Service Witness Degen
to Interrogatories
of Office of the Consumer Advocate
(Redirected from Witness Alexandrovich)
OCANSPS-T5-21.
Please confirm that the total component
3.1 costs
increase by $791 ,019,OOO under the base year costing methodology,
as
compared to the library reference H-l methodology
for FY 1996.
If You do
not confirm, please provide the correct figure and its derivation.
In any
event, please provide a breakdown
of the cost change by MODS, nonMODS, and BMC’s.
OCAAJSPS-T5-21
The magnitude
increase
Response.
of the component
of $792.015
17 for an approximate
million).
breakdown
3.1 increase
is confirmed
Please see Attachment
of the cost change.
(I calculate
an
1 to OCA/lJSPS-Tl2-
Response of United States Postal Service Witness Degen
to Interrogatories
of Office of the Consumer Advocate
(Redirected from Witness Alexandrovich)
OCANJSPS-TS-22.
Please confirm that the total component
3.2 costs
decrease by $106.586.000
under the base year costing methodology,
as
compared to the library reference H-l methodology
for FY 1996.
If you do
not confirm, please provide the correct figure and its derivation.
In any
event, please provide a breakdown
of the cost change by MODS, nonMODS, and BMC’s.
OCAIUSPS-T5-22
The magnitude
decrease
T12-17
Response.
of the component
of $106.585
million).
for an approximate
3.2 decrease
is confirmed
Please see Attachment
breakdown
(I calculate
1 to OCAIUSPS
of the cost change.
a
Response of United States Postal Service Witness Degen
to Interrogatories
of Office of the Consumer Advocate
(Redirected from Witness Alexandrovich)
OCAAJSPS-T5-23.
Please confirm that the total component
3.3 costs
decrease by $685,425,000
under the base year costing methodology,
as
compared to the library reference H-l methodology
for FY 1996.
If you do
not confirm, please provide the correct figure and its derivation.
In any
event, please provide a breakdown
of the cost change by MODS, nonMODS. and BMC’s.
OCAIUSPS-TS-23
The magnitude
decrease
T12-17
Response.
of the component
of $685.427
million).
for an approximate
3.3 decrease
is confirmed
Please see Attachment
breakdown
(I calculate
1 to OCANSPS
of the cost change.
a
Response of United States Postal Service Witness Degen
to Interrogatories
of Office of the Consumer Advocate
(Redirected from Witness Alexandrovich)
OCANSPS-T5-26.
Please refer to page 3-2 of library reference H-l.
This
states that segment 3 accrued costs are classified into mail processing,
window service, and administrative
and support activities.
On page 7 of
USPS-T-l 2, witness Degen states, “The compensation
totals for the BMC
and non-MODS groups are partitioned
into the mail processing,
administrative,
and window service components
using IOCS dollar totals for
the collections
of IOCS operations codes that defined the components
in the
old methodology.”
a. Please confirm that the definition of accrued costs for each of his
partitions for non-MODS offices is the same as the segment 3
components
described in library reference H-l, page 3-2. If you do not
confirm, please explain any differences.
Provide citations to the lines of
computer code that implement any changes between the two
methodologies.
b. Please confirm that for non-MODS offices, witness Degen’s
administrative
partition is equivalent to component
3.3, administrative
and support activities,
as described in H-l.
If you do not confirm, please
explain and list all differences
between the two.
OCAAJSPS-T5-26
a. The definition
conceptually
not the same.
Response.
of the component
similar
costs for the non-MODS
to the FY 1996 methodology,
The partition
of BY 1996 non-MODS
that the IOCS costs for each component
clerk and mailhandler
group
(finance
components.
compensation
numbers),
See LR-H-146
IOCS tally dollar weights
compensation
obtained
amounts
at l-3.
offices
but the cost totals
costs is different
are used to distribute
amount
for the non-MODS
from the Pay Data System,
The difference
is
are
in
the total
office
to the cost
arises because
the
are based on clerk and mailhandler
by craft and CAG, so the total dollar value of
Response of United States Postal Service Witness Degen
to Interrogatories
of Office of the Consumer Advocate
(Redirected from Witness Alexandrovich)
tallies
taken
compensation
b. Confirmed
methodology
noting
at non-MODS
amount
offices
for non-MODS
that the non-MODS
is conceptually
the difference
for the non-MODS
is not controlled
administrative
similar
in the method
office
finance
groups
to the total
numbers.
component
to the component
for computing
described
in the BY 1996
3.3 description,
the component
costs
in part a of this response.
DECLARATION
I, Carl G. Degen,
answers
declare
are true and correct,
under penalty
of perjury
that the foregoing
to the best of my knowledge,
and belief.
Carl G. Degen’
‘,/
information,
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, SW.
Washington, D.C. 20260-I 137
(202) 268-2990; Fax -5402
September 23, 1997