DOCKET SECTION
~
BEFORE THE
POSTAL RATE COMMlSSlON
~
WASHINGTON, D.C. 20266-0001~
POSTAL RATE AND FEE CHANGES, 1997
*ECEIVE[)
j
RESPONSE OF UNITED STATES POSTAL1 SERVICE
WITNESS DEGEN TO INTERROGATORIES
OF
TIME WARNER, INC.
~
(TW/USPS-T12-36-40)
~
The United States Postal Service hereby provides responses of witness Degen to
the following interrogatories
September
of Time Warner, Inc.: TWUSPS-Tl2-3640,
filed on
27, 1997.
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-l 137
(202) 268-2992; Fax -6402
October 9, 1997
--
~---------
Response
of United States
to Interrogatories
Postal Service Witness
of Time Warner Inc.
Degen
TW/USPS-T12-36.
Please refer to your answer to TW/USPS-T12-24a.
in
which you give the relationship
between tally costs and volume variable
costs in a cost pool.
a. Please provide the sum of the tally costs in each cost pool.
b. Please provide, for each cost pool, the sum of tally costs in each of the
data sets ADW.MODS,
WORK.SSVCNU,
WORK.DIRECT,
WORK.MIXED
and OUT1 .NOTHAND,
created in MOD1 DIR for MODS facilities,
and the
corresponding
data sets created for BMC’s and Non-MODS
facilities.
c. Do all tally costs for CAG A-J clerks and mailhandlers
add up to the
accrued costs for Segment 3? If no, why not?
d. Do all BMC tally costs for clerks and mailhandlers
add up to the accrued
clerk and mailhandler
wage costs at BMC’s?
If no, why not?
TW/USlPS-T12-36
Response.
a. Please see LR-H-146,
pages VI-5 to VI-7,
cost.s for each mail processing
b. Please see Attachment
c. No.
1 to this response
cost for Segment
3.
(in the BY 1996
d. Since the BMCs are assigned
cost weighting,
BMCs should
to obtain
total
total
be approximately
to add up to
allowance
to the tallies
divided
Segment
(in the
into cost pools
3 costs.
their own CAG for the purposes
of tally
compensation
at
equal to the sum of BMC tally costs.
equal because
using program
data.
and uniform
total distributed
the BY 1996 clerk and mailhandler
They are not exactly
not determined
are not designed
or the compensation
methodology)
for IOCS tally
for the requested
Lump sum costs
are added to the compensation
FY ‘I 996 methodology)
‘WGT,”
cost pool.
Please note that the total tally costs
the accrued
costs
column
the BY 1996
ALB095,
LR-H-21,
BMC cost pools were
which
computes
the
Response
tally dollar
weights.
pool costs.
between
of United States
to Interrogatories
The BMC tally costs
I believe
program
Postal Service Witness
of Time Warner Inc.
the discrepancy
ALB095
are 100.14%
Degen
of the BMC cost
is due to rounding
and the procedure
in LR-H-146,
differences
part I.
,:,
Attachment
,, .,“m,,
1 - Res~ponsc to TWIIJSPS-TIZJB
MS5 IOCS Tally Costs (SoooS)
LDC
11
11
12
12
13
13
13
13
14
14
14
14
15
15
17
17
17
17
17
17
17
17
18
19
18
16
16
16
18
18
18
41
42
43
44
4s
49
40
46
49
79
MODS
MODS
BMC
BMC
BMC
BMC
BMC
eh4c
BMC
BMC
Non-MOD
Non-MOD
Non-MOD
cost Pool
Lx%
ccr
km
km
1 SackS.-m
mkpaK:
rpbs ozl
WbsPriO
mnl
mm
WnP
P"0rity
LDIS (MODlPOOL)
LDl5 (BCSIOSS Key)
1bulk pr
lcarw.wP
1 OpBulk
1 OpPrel
1Phttonn
1 Pouching
1 Sacks.-h
lsca"
1 EEqmt
1 Mix
1sup cnh
1 Suppo1t
BusReply
br=
Mailgnm
RegisQ
Rewrap
,"ti
LD41
LD42
LD43
LD44
LD4E_A,dm
'-D&-W
LD46-Om
LD46-SpS
LD4-9
LD79
Window
Admin (incl2ADM-Out)
SSM
Allied Ot
PSM
SPB
NM0
PiHOw
z eresks
Window
Admln
Mail Prr~
Window
Admin
SSVCNU
0
0
0
0
0
0
0
72
0
264
0
0
0
0
0
8
126
588
603
207
121
166
0
119
0
921
1,171
0
68
17,967
0
3.058
0
0
5,432
229
698
0
1,151
4.166
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Direct
383.193
133,931
398.608
440,595
6,045
4,496
73,463
20,291
307,134
9al.lW
26,376
73,195
6,744
36,Tl6
4.569
149,500
67,415
220,497
83,089
119,067
27.901
11,477
991
12,381
424
6,167
15,660
26,407
72
31.447
3,969
57,599
10,030
4,653
253,902
77317
19,533
674
30,971
27,673
142,772
19,753
0
0
12.674
67,890
52,095
26,267
11,059
30,743
0
0
0
1.375.539
0
0
Mied
Not Handlmg
72.625
248.067
z:511
a2:302
53,488
216,459
26,332
165,721
11.144
30,027
2,116
4.846
29.761
83,868
6,342
2c+@9
40,371
179.480
426,102
56.405
10,626
29,584
26,733
80,708
4,616
1,388
0
0
6.721
3.054
40.021
123,646
52.858
132,519
142.162
342.961
244,866
561.192
97,643
210,272
36,726
67,702
14,733
35,453
14,565
26,203
9,013
91,895
0
203
3,026
171.495
1,657
13,980
6,353
55.888
0
379
13,602
80,765
1,129
9,166
16,017
56,699
1,521
13,396
575
4,544
56,943
269,073
51,321
3.663
2,952
139.436
l&r
3.513
6,514
84.609
2,370
65,074
9,123
116,316
116,641
4.994
0
0
0
0
3.41 I
7,031
57.649
62,=
1,801
12,515
12,123
13,242
5,389
7.765
41,210
76,772
0
114.627
0
0
0
0
186,306
652,167
0
0
0
0
Windcw
721,751
0
0
0
0
0
0
0
0
960
0
0
1.136.083
0
Page1 of1
--.-_____
--.--.--
Admin
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
-
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
629.265
0
0
0
0
0
0
0
0
126,239
0
0
516.705
TOti
704.064
t38:713
668,555
632,647
49,216
11,462
187,119
55,034
526,965
1,363,951
66.788
180,636
12.949
36,i-i.a
16,345
316,230
272,917
706.226
689.750
427.410
152.452
61,843
41,780
113,407
627
163,611
32,469
=,w
519
143,601
14.164
133,563
24,947
9,972
565,351
132,750
167,622
4,571
125,245
99.502
268,214
141,401
721,751
629,265
23,316
198,105
66,411
51,652
24,213
146.725
114,627
960
126,299
2.214,032
1,136,a33
516,705
Response
TWNSPS-Tl
Z-37.
which you indicate
activity code 6523
of United States
to Interrogatories
Postal Service Witness
of Time Warner Inc.
Degen
Please refer to your answer to TW/USPS-T12-26b.
in
three types of question 18 responses that may lead to
being assigned to a not handling tally.
a. Besides the three types of question 18 responses that you have
men,tioned, are there any other ways in which activity code 6523 may be
assigned to a not handling tally? If yes, please describe each such
scenario.
b. Plea:se provide, for each cost pool, the volume variable 6523 not
handling costs that resulted from IOCS clerks selecting the empty
equipment
categories
in, respectively,
question 18b part 2, question 18d
part 2 and 189. Additionally,
please provide the 6523 not handling costs
that resulted from any other combination
of responses by IOCS clerks
that you may have identified in response to part a above.
c. Please confirm that the responses to question 18b part 2 to which you
refer apply only in the case of an Expediter or a Dock/Ramp/Transfer
Clerk working on a platform and doing something
related to empty
equipment
without actually handling it. If not confirmed,
please explain.
d. What kinds of not handling activities associated
with empty equipment
would (1) Expediters;
and (2) Dock/RampTTransfer
Clerks normally
engage in?
e. Please confirm that the responses to question 18d part 2 to which you
refelr apply only in the case of an employee at a distribution
or related
operation that is not handling empty equipment
but is on his way to, or
on hlis way back from, obtaining equipment for use in the operation or
disposing of excess equipment
used in the operation.
If not confirmed,
please explain.
f. Please confirm that question 189 titled ‘administrative
and other
activities”,
applies only to employees whose activity cannot be
associated
with any of the mail processing functions
described in
questions
18b through 18f, and that the selection of “handling empty
equipment”
is indicated if “the selected employee is handling or moving
empty equipment
but is not performing
a platform or distribution
and
Please also explain how the description
related mail processing
activity.”
“handling empty equipment”
can be interpreted
to include “not handling”
empty equipment.
Response
TW/USPS-T12-37
a. I reviewed
of United States
to Interrogatories
IOCS responses
coukf
ALB040,
LR-H-21,
that would
lead to the assignment
was not recorded
equipment.
Examining
tallies
to various
assigned
the comments
activity
fields
recorded
(Explediter
to a city carrier
I observed
as “other”
(the most recent
in the question
in
activity
of the tallies
of
year in which
for this
18 subparts
has been in place since
that
work
percentages
in CODES were inspected
category
tally
a piece of empty
based on the distribution
in 1991
16F
1992.
has its own
Please see
details.
b. Please see Attachment
c. Not confirmed.
codes
codes
This procedure
for further
that in these cases,
activity
Each ‘other”
distribution.
question
‘E’ of question
handling
were classified
of activity
18b part 2, 18d part 2, 18e, and 189 also received
are assigned
LR-H-14
Option
code 6523
as actually
which
I am informed
purpose).
assignment
the IOCS tally data (LR-H-23),
code 6523.
manually
tally.
of activity
if the carrier
some not-handling
and was unable to find any other
lead to the automatic
to a clerk or mailhandler
questions
Degen
Response.
program
code 6523
Postal Service Witness
of Time Warner Inc.
1 to this response
According
to LR-H-49,
18b, part 2, if the question
of Dock/RampTTransfer
for the requested
data.
page 58, CODES branches
18b. part 1, response
Clerk) pi ‘H’ (“Other
to
is ‘G’
Platform
Work).
Response
of United States
to Interrogatories
In Attachment
1, I further
from
18b, part 2, by the response
question
d. Some inbound
Acti,vities
related
handling
empty
inventorying
exarnples
context
equipment.
the loads of empty
noting
that
employee’s
question.
Clearly,
(or empty
equipment)”
Appendix
Degen
equipment
to question
18b. part 1.
exclusively
empty
may cause expediters
as working
these
equipment.
observations
equipment.
or
with
workers
but not
could
be
There may be other
I am not aware.
sampled
“at a distribution
activity
activity
be classified
reflects
for “handling
See the description
A, for a description
in this
empty
of MODS operation
of empty
part of the
“not-handling-mail
equipment.”
the fact that
empty
189 only if the
in an earlier
for an employee
to be “handling
is shorthand
operation”
will reach question
cannot
merely
or related
in IOCS.
it is an oxymoron
contradiction
equipment”
contain
For instance,
that the data collector
apparent
the empty
clerks to be recorded
refers to the sampled
Corrfirmed
work.”
trucks
to these trucks
of which
e. Confirmed,
separated
or outbound
dock/ramp/transfer
f.
Postal Service Witness
of Time Warner Inc.
However,
“handling
equipment
number
equipment-related
the
empty
and related
549 in LR-H-147,
work
activities.
Attachment
1 -Response
Breakdorm of volume v&Me
LDC!GCJp
11
11
12
12
13
13
13
13
14
14
14
14
17
17
17
17
17
17
17
17
18
18
16
18
16
16
16
16
41
42
43
44
46
48
46
48
49
cost Pd
bcs
ccr
fsm
km
lSackS_m
macparc
spts cml
spbsPri0
manf
mad
manp
Priority
Ibulkpr
IcaIIcMPP
1 Op6ulk
10pPruf
1 Platform
1 Pouching
ISackS-h
ISWil
1 EEqmt
1 Mist
ISUpport
BusReply
EweMailgram
Regisby
R-P
Inn
LD41
LD42
LD43
LD44
LDM-Adm
LD46-Ew
LD46-Oth
LD46-SpS
LD49
to TWIUSPS-TlZ-37
cost3 (SWO) disbibuted to scbtity code 6523 Clllies
rt
I
I
Handling
43.4641
10,716
36,637
16942
4,312
1.064
7,525
3.307
16,950
27,062
2.204
7,691
614
10,742
25,269
57,654
=vJf=
36.493
7,737
2,732
12,019
3,243
713
acs
1,105
0
694
462
3,293
550
0
20.808
2,@3
0
14
641
225
5,470
DWRmpTTians
16bpt2='D'
0
0
0
0
66
0
0
0
0
0
0
41
0
93
67
354
4,337
149
340
40
241
125
0
0
120
0
1
0
116
0
0
0
0
0
0
17
0
0
Clk
m
16bpt2='E'.
0
0
0
0
462
0
32
0
0
0
0
92
0
0
0
120
6,380
375
171
62
0
306
121
0
0
0
15
0
385
0
0
El
0
0
0
13
0
0
Platfwrr!
16bpt2='D'
Not Handlina
Allied Lab
16bpt2='E'
184
49
67
0
826
55
54
0
3.5
513
131
203
0
653
614
1.655
21,344
1,169
1.M
379
5366
467
33
0
33
0
0
46
69
0
0
2.603
0
0
0
90
a
0
Page 1 of2
0
0
0
0
172
0
26
0
0
0
16
0
0
101
0
92
2,761
462
630
149
329
20
76
0
0
0
1
0
137
0
0
137
0
0
0
19
19
0
16dpt2='H
14.06a
4,713
17,167
6,219
623
20s
2,706
1,539
9.262
12.978
776
2.800
144
2,594
9,277
19,924
7,263
Il.113
2.108
641
2,450
1.725
119
56
145
41
29
73
761
408
133
15,761
2.@33
0
0
464
133
146
Adm/DUwr
16g=rs
lt!g='T
16gpt2='Z
642
66
0
0
351
0
133
0
641
a6
0
0
134
0
53
0
294
0
303
57
1
0
84
27
35
0
356
0
1,043
62
1,242
52
121
1.890
654
0
102
0
164
0
56
4.668
335
62
54
50
0
0
9
0
0
0
0
0
53
0
a7
0
0
0
0
0
940
a4
100
36
0
0
0
0
103
6
0
0
0
0
Mist
I
I
1ea='l'or'J
01
0
68
0
0
0
0
0
0
0
0
0
0
31
0
53
0
59
0
0
0
232
62
0
0
0
0
0
0
0
0
0
101
0
0
16
9
0
T&l
58.445
15,476
54.4.51
25.294
7,189
1,327
10.476
4.900
26,542
40.912
3,132
11.13s
933
14,673
36,552
61.147
110,939
50.520
13,082
4.168
25.126
6,516
1.250
662
1,416
41
739
634
4,867
958
133
40.617
4,336
0
14
1,371
395
5.616
:
I
:
I
Attachment
1 - Response
cost Pml
LDClGroup
LD79
79
MODS Mail Pr~c
to TWUSPS-Tl2J7
I
Handling
I
DWRmplTrans
16bpt2=‘D’
Clk
Allied Lab
067 Pl.atfwn
16bpt2=‘E’
iBbptZ=‘D’
16bpt2=‘E’
16dptZ=‘H
1,956
444,406
0
6,111
0
6,596
164
39,551
203
5,393
127
150.767
SSM
EMC
Allied Gt
EMC
PSM
EMC
SPB
BMC
NM0
EMC
Platform
EMC
EMC Mail Pmc
813’
15,974
724
5,745
2.063
.9:822
34.143
0
0
0
0
0
106
106
0
0
0
0
0
473
473
0
0
0
0
0
3.594
3,594
0
0
0
0
0
331
331
0
3,035
0
1,032
671
0
4.738
Non-MODS Mail Prcc
83.586
1,375
153
9,043
396
26.961
562.137)
7,592
9,225
52,167
6,121
162,506
Total Mail Prcc
1
Page 2 of 2
AdmlO6wr
lag--f6
l&,=‘T
1%.pt 2 = ‘z’
33
36
14.506
602
Mist
I
16a = ‘I’ or ‘J
91
735
T&l
2,610
670,891
0
0
0
0
0
0
0
a
0
0
0
0
0
0
0
14
0
0
0
0
14
813
19,023
724
6,776
2.735
13;326
43.399
0
0
251
121,766
802
l,mOl
636,076
14,506
.
8
Response
of United States
to Interrogatories
Postal Service Witness
of Time Warner Inc.
Degen
TW/USPS-Tl
Z-38. Please refer to your answer to l-W/USPS-T1 2-27b.
Which 3-digit MODS numbers are used, in AO’s stations and branches
included in the MODS data base, to describe:
a.
b.
c.
d.
e.
f.
manual distribution
of letters from 5-digit to carrier route;
manual distribution
of flats from 5-digit to carrier route;
distribution
of carrier route presorted bundles to the respective
carriers;
distribution
of small parcels and rolls to carriers;
loading and unloading mail at the platform;
culling and other preparation
of collection
mail before it is sent to the
maini processing
facility?
TWIUSPS-Tl2-38
a.-d.
These activities
at Stations
‘LD43”
e.-f.
Response.
are described
and Branches-Composite”),
which
240C
is associated
(“Distribution
with the
cost pool.
M,y understanding
at stations
numbers,
by MODS operation
is that allied labor activities
and branches
along with
See LR-H-146,
other
are generally
Function
recorded
4 support
page l-25, for the relevant
such as these performed
under LDC 48 operation
and miscellaneous
MODS operation
work.
numbers.
Response
of United States
to Interrogatories
Postal Service Witness
of Time Warner Inc.
Degen
TW/USPS-Tl2-39.
Please refer to your answer to TW/USPS-T12-28b.
in
which you speculate that observations
of pallets inside containers
may refer
to empty pallets being transported
in rolling stock.
Please assume that an
IOCS clerk observes an employee handling an all purpose container
(APC)
with some empty sacks and nothing else inside.
a. Would this give rise to a 6523 (empty equipment)
tally, or a tally
showing a container with sacks in it?
b. If a tally shows a container with items in it being handled, is there any
way of knowing from the data base whether those items contained mail
or not? If yes. how?
c. Is it generally true that an observation
of a container with one or more
empty items and nothing else inside gives rise to a mixed mail container
tally, rather than a “handling empty equipment”
tally? If no, please
explain.
TW/USPS-T12-39
Response.
a. The answer
21.
depends
If the response
code 6523
would
on how the data collector
indicated
that the APC was empty,
be assigned.
Otherwise,
56Xx-57Xx
mixed-mail
activity
distribution
methodology
would
container
volume
b. No.
if the data collector
occupied
question
volume
21.
The new cost
as an identified
the percentage
of the APC
in IOCS.
to part a, activity
tally if the container
If the data collector
occupied
is that a
by the sacks.
in my response
a handling-container
then activity
be assigned.
treat this observation
recorded
to question
my understanding
code would
Such data are not collected
c. As indicated
responded
by the item(s),
recorded
code 6523
is recorded
is assigned
as empty
percentage(s)
the new cost distribution
in
of container
methodology
to
Response
of United States
to Interrogatories
Postal Service Witness
of Time Warner Inc.
would
treat the tally as an identified
would
treat the tally as an unidentified
mixed-mail
mixed-mail
Degen
container,
container.
otherwise
it
Response
of United States
to Interrogatories
Postal Service Witness
of Time Warner Inc.
Degen
TWIUSF’S-T12-40.
Please refer to your answer to VW/USPS-T12-28~.
in
which you comment that it may be difficult to count a pallet with trayed or
sacked non-identical
mail without delaying the mail.
a. Please confirm that whether the IOCS clerk does or does not count such
a pallet, he has no way of indicating that the pallet contained trays or
sackis, rather than loose bundles or pieces.
If not confirmed,
please
explain how he would so indicate and how that information
can be
retrieved from the IOCS data base.
b. Please confirm that when an IOCS clerk observes a pallet containing
trays or sacks with identical mail, giving rise to a direct tally, he has no
way of indicating that the pallet contained sacks or trays, rather than
loose bundles or pieces.
If not confirmed,
please explain how he would
so indicate and how that information
can be retrieved from the IOCS
data base.
c. When an IOCS clerk observes a pallet containing
sleeved trays or sacks,
how does he determine whether it contains identical mail?
l-W/USPS-T1
2-40.
a. Confirmed.
b. Confirmed.
c. If there is information
data collector
presumably
inspiecting
(from
to believe
that the pallet could
the data collector
(if possible)
speaking,
this would
contained
identical
pieces
could
mail.
pallets
also a “cannot
determine”
See the description
etc.) that would
contain
identical
make the determination
However,
determination
after
option
of variable
it would
make sense
Please note that there is
for the identical
F9216,
Strictly
that the pallet
I do not believe
solely for this purpose.
lead the
mail, then
from some of the sacks or trays.
not be a positive
to break down
21.
sack or tray labels,
mail part of question
LR-H-23.
-
---~
I, Carl G. Degen, declare under penalty of perjury that the foregoing
answers are true and correct to the best of my knowledge, information, and
belief.
__.----
---
_--~~
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-I 137
October 9, 1997
in accordance
upon all
with section 12 of the Rules of