DQCKET SECTION
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 202660001
POSTAL RATE AND FEE CHANGES,
RESPONSES
h
I
4 36 PM ‘97
POSTAL
RATCCOHI,,SSICH
OFFICE
OF Ttli‘ SECRETARY
1997
Docket No. R97-1
OF UNITED STATES POSTAL SERVICE WITNESS SCHENK
TO INTERROGATORIES
OF
THE OFFICE OF THE CONSUMER ADVOCATE
AND MOTION FOR LATE ACCEPTANCE
(OCAIUSPS-T27-1 - 6)
The United States Postal Service hereby files the responses of Leslie Schenk to
the following interrogatories
12, 1997: OCAIUSPS-T27-1
The interrogatories
of the Office of the Consumer Advocate, filed September
through 6
are stated verbatim and are followed by the responses,
These responses of witness Schenk and the redirected responses were due to
The need to consult with representatives
have been filed on September 26, 1997.
various departments
here at Headquarters
and witness Schenk’s workload and travel
schedule on matters unrelated to this proceeding
have contributed to the lateness of
these filings. The Postal Service regrets this delay, but believes that it was
unavoidable
Respectfully submitted,
UNITED STATES POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux,
nsel,zz
3
Michael T. Tidwell
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-I 137
October 1, 1997
of
Jr.
RESPONSE
OF THE UNITED STATES POSTAL SERVICE WITNESS
TO THE INTERROGATORIES
OF THE OCA
OCA/USPS-T27-1.
Please refer to your direct testimony
that non-advance
deposit BRM recipients do not pay the
fees through an advance deposit account,
but may have
Postage Due account.”
Please also not the postage due
DMM S922.3.7.
a.
b.
c.
on page
postage
postage
account
SCHENK
3 where you state
due and per-piece
“deducted
from a
explanation
at
Please explain all other differences
between advance deposit accounts
and
postage due accounts.
Include in your discussion
any differences
in administration
of the accounts
(as
administration
is explained at page 7 of your direct testimony).
For all differences
discussed
in response to (a) and (b) herein, explain whether
Postal Service costs differ (e.g., different
administration
costs).
RESPONSE:
a.
Advance
that
deposit
accounts
are maintained
volumes
by the Postal
of mail for which
are a subset
Business
of all trust
postage
accounts.
Reply Mail for which
mail (e.g.,
sufficient
a utility
receives
postage,
due on it).
pieces
are also known
very low volumes
are unlikely
b.
see my response
c.
Postal
Service
due accounts,
differences
Postage
They are accounts
who regularly
is due upon receipt.
Postage
due accounts
receive
due accounts
can be used for
fee is paid, as well as for short
from a customer
agrees to accept
are established
basis for which
postage
of mail, and on an infrequent
to be debited
accounts.
for mailers
bill payments
due accounts
on a non-periodic
Service
no accounting
but the utility
Postage
as trust
which
paid
does not have
the piece and pay the postage
by mail recipients
is due.
basis.
These
Therefore,
who
accounts
these
receive
receive
accounts
on a daily basis.
to part a
costs
will differ
as the workhours
in the incidence
between
advance
per account
of account
deposit
will differ
administration)
accounts
(because
and postage
of the
RESPONSE
OF THE UNITED STATES POSTAL SERVICE WITNESS
TO THE INTERROGATORIES
OF THE OCA
OCA/USPS-T27-2.
Table 9 in LR H-179 lists “Reject
automation
sortation
operations.
Does this comprise
mail? Please explain.
if it does not, please set forth
mail.
SCHENK
Rate of BRM” on two type of
the entire reject rate for BRM
the entire reject rate for BRM
RESPONSE:
Confirmed.
To my knowledge,
in which
BRM are sorted
BRMAS)
sortation
reported
in Table
the only two types
to account
operations
or mailer
on barcode
9 in LR H-l 79 comprise
of automation
are BRMAS
sorters.
the entire
operations
Therefore,
reject
sortation
operation
and other
the reject
rate for BRM.
rates
(non-
RESPONSE
OF THE UNITED STATES POSTAL SERVICE WITNESS
TO THE INTERROGATORIES
OF THE OCA
SCHENK
OCA/USPS-T27-3.
Please refer to Appendix
A: BRMAS Cost Survey - Data
You state that a survey of the five sites was conducted
Collection
and Processing.
in April-May,
1997.
When were the tabulation
of results and analysis thereof
completed?
RESPONSE:
Results
were tabulated
basis as results
results
complete
in daily).
were received
were
done for individual
from the sites
On May 21, 1997
the survey
the final results
and analysis
were tabulated
(they were
the final survey
sent to us.
In the week
and analysis
test sites on an ongoing
forms
instructed
from the last site to
after those
of the survey
to fax or mail
results
results
were
received,
were completed.
RESPONSE
OF THE UNITED STATES POSTAL SERVICE WITNESS
TO THE INTERROGATORIES
OF THE OCA
SCHENK
OCA/USPS-T27-4.
When did you discover that the Postal Service no longer
expected
to have a new version of the BRMAS program in place during the test
vear?
RESPONSE:
I do not recall the exact
date on which
they
to have a new version
during
no longer
expected
the test year, but it was either
I was informed
by the Postal
of the BRMAS
May 22, 23 or 24, 1997
Service
program
that
in place
RESPONSE
OF THE UNITED STATES POSTAL SERVICE WITNESS
TO THE INTERROGATORIES
OF THE OCA
SCHENK
OCA/USPS-T27-5.
Is the Postal Service currently surveying
and analyzing BRMASqualified BRM productivity
at a cross-section
of postal facilities
(or a selection
of
such facilities
have “average”
efficiency)?
a.
b.
c.
d.
If not, why not?
How long would such a survey and analysis thereof be expected to take?
Confirm that using average productivity
at relatively
efficient
sites overstates
BRMAS productivity.
If not confirmed,
please explain.
If (c.) is confirmed,
please provide an estimate of the magnitude
of the
overstated
productivity,
showing derivations
for the estimate.
RESPONSE:
No, to my knowledge
analysis
a.
of BRMAS-qualified
By the time that
available
survey
it was realized
more information,
d.
It is not possible
to estimate
the most
on what
the average
cannot
was not enough
facilities
efficient
of postal
program
would
time to design
or
facilities.
not be
and conduct
so that the data could
-
and analyze
questions
the results
it is supposed
say how long such a survey
the magnitude
a
be available
is. The “average”
of facilities
depends
to address.
would
efficient
Without
in productivities
site, without
productivity
is not available,
on the
take
of the difference
sites and the “average”
productivity
at a cross-section
be done.
a survey
and what
I cannot
between
operation
at a cross-section
a survey
in my testimony
of the survey,
Confirmed.
conducting
that the new BRMAS
of postal
it takes to conduct
c.
is not currently
BRM productivity
at a cross-section
The time
design
Service
in the test year, there
for presentation
b.
the Postal
data
for BRMAS
so this comparison
RESPONSE
OF THE UNITED STATES POSTAL SERVICE WITNESS
TO THE INTERROGATORIES
OF THE OCA
SCHENK
OCA/USPS-T27-6.
Please refer to page 8 of your direct testimony
where you state:
“The cost of BRMAS-qualified
BRM was developed
in part using the results of
another survey done at selected postal facilities.”
At page 10 you state:
“The
BRMAS Cost Survey is discussed
in more detail in Appendix
A.” Does the “BRMAS
Cost Survey” exist as a separate document?
If so, please supply it.
RESPONSE:
The BRMAS
information
my testimony,
spreadsheets
Cost Survey
on the survey
in either
does not exist as a separate
document.
design
was conducted
and how the survey
the main text,
Appendix
All background
are provided
A, or in the accompanying
in
DECLARATION
I, Leslie M. Schenk, hereby declare, under penalty of perjury, that the foregoing
Docket No. R97-1 interrogatory responses are true to the best of my knowledge,
information, and belief.
&Lm
!.
Date
-
i-41
Leslie M. Schenk/
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the foregoing document upon all
participants of record in this proceeding in accordance with section 12 of the Rules of
Practice.
&3M
Michael T. Tidwell
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-l 145
Tel: (202) 268-2996 / x5402
October 1, 1997