BEFORE THE
POSTAL RATE COMMISSIO)
WASHINGTON, D.C. 20268-0001
RECEIV~[)
,11170 ,,I
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PoSrAk
RATE
C%SSioH
OFFICE
Oi THE
~~~~~~~~~
No. R97-1
Docket
POST= RATE AND FEE CHANGES, 1997
FLORIDA GIFT FRUIT SHIPPERS ASSOCIATION
INTERROGATORIES TO UNITED STATES POSTAL SERVICE
WITNESS: PHILIP A HATFIELD
FGFSA,/USPS-T16-l-15
July
Flo:rida
interrogatories
Gift
Fruit
28,
Shippers
to USPS Witness
1997
Association
hereby
submits
Hatfield.
c
Attorney
Florida
Gift
Association
Fruit
Shippers
INTERROGATORIES TO WITNESS HATFIELD
FGFSA/USPS-T16-1
Is the
total
various
purchased
classes
described
transportation
and subclasses
in your
cost
of mail
not,
explain
(b) If
not,
do you recommend that
the
using
to the
the methodology
testimony?
(a) If
for
attributed
how such costs
attribution
of total
are attributed.
your
methodology
transportation
be used
costs?
FGFSA/USPS-T16-2
Provide
class
and identify
and subclass
transportation
the
of
source
of
the
number
transported
mail
(intraSCF,
inter
in
SCF, intra
of
each
pieces
type
of
of
each
highway
BMC, and interBMC)
FGFSA/USPS-T-16-3
Provide
and identify
subclass
of mail
(intraSCF,
the source
transported
in each type
intraBlYC
interSCF,
of the cubic
and inter
feet
of each class
of highway
and
transportation
BMC).
FGFSA/USPS-T-16-4
Provide
class
and identify
and subclass
transportation
the
of
(intra
source
mail.
of the
transported
SCF, inter
cubic
in
SCF, intra
foot
each
for
miles
type
of
BMC and inter
each
highway
BMC).
FGFSA/USPS-T-16-5
Confirm
that
a P&DC served
you treat
the transportation
by that
BMC as "intermediate
costs
between
transportation
a BMC and
costs".
If
you do not
confirm,
please
explain
fully.
FGFSA/USPS-T-16-6
Are
the
cube-weight
testimony
(beginning
total
purchased
to parcel
which
you
describe
at page 11) used to determined
highway
transportation
costs
in
your
the portion
which
of
is attributable
post?
If not,
account
relationships
do you recommend that
in determining
such relationships
the attribution
be taken
into
of such costs?
FGFSA/USPS-T-16-7
For
a machinable
delivery
parcel
in Dalton,
intra
that
Beach,
Florida,
the parcel
will
for
receive:
Beach to the Jacksonville,
the Atlanta,
IGa BMC to Dalton,
Fl BMC
Ga.
BMC transportation
from
the
Jacksonville
If
you do not
If
you do confirm,
this
Daytona
BMC transportation
from
for
at
confirm
Georgia,
from Daytona
inter
mailed
parcel
confirm,
BMC to the Atlanta
please
explain
is unrelated
originating/destinating
fully
how the
to the
BMC
explain.
intra
BMC transportation
GCD between
each BMC and the
facilities.
FGFSA/USPS-T-16-8
Assume a 20# machinable
City,
Florida,
Tampa, F:Lorida,
parcel
SCF for
SCF.
is placed
delivery
Confirm
to
that
in the mail
an addressee
this
parcel
will
at the Panama
served
receive
by the
intra
BMC transportation
from Panama City,
and from the Jacksonville,
In this
example,
FL to the Jacksonville,
Fl BMC
Fl BMC to Tampa, Fl.
Panama City
is
BMC and from Tampa, and Tampa is also
Zone 3 from
the
Jacksonville
Zone 3 from the Jacksonville
BMC.
What will
be the actual
is provided?
Will
What will
this
be the
the determination
for
highway
transportation
miles
transportation
mileage
taken
service
or GCD miles?
into
account
for
costs?
be the transportation
the methodology
which
be actual
of attributable
What will
using
miles
explained
miles
in your
to be taken
into
account
testimony?
FGFSA/USPS-T-16-9
Assume a 20 lb.
Jacksonville,
address
mail
Florida
served
machinable
for
by the
parcel
delivery
BMC on the
on the
Tampa, Florida
as parcel
mail
for
delivery
SCF, and an identical
at the Jacksonville,
are received
post
Florida
served
at
the
to
an
20 lb.
BMC as DBMC
by the Tampa, Florida
and processed
at the
Jacksonville
parcels
be transported
parcels
receive
from the BMC to the
SCF
same vehicle?
jErom
both
the
(c) Will
basis
SCF as Intra-BMC
to the same address
both
(b) Will
the
entered
day.
same
(a) Will
parcel
entered
Both parcels
SCF.
service
machinable
BMC to the
Jacksonville
the
amount
SCF for
of the cubic
feet
the same highway
BMC to the Tampa SCF?
of the highway
the
transportation
.Intra
transportation
BMC parcel
of the parcel,
costs
be determined
regardless
from
on the
of the distance?
If
how will
not,
(d) Will
the
the BMC to the
of the
the
cubic
cost
amount of the
SCF for
foot
be determined?
be determined?
transportation
the DBMC parcel
miles
If
highway
be determined
of the parcel?
is
so,
costs
If
the mileage
not,
actual
from
on the basis
how will
highway
the cost
miles
or the
GCD distance?
(e) If
why the
parcels,
will
the amounts under
amount
(c) and (d) are not the same, explain
of
transportation
costs
when the
transportation
service
be the
are
different
for
utilized
the
two
by each parcel
same.
FGFSA/USPS-T-16-10
Assume a machinable
SCF for
delivery
SCF. Confirm
will
that
the
the
served
transportation
at the Tallahassee,
Florida
by the Thomasville,
Georgia
to be proved
from Tallahassee
Jacksonville
from the Atlanta
explain
is entered
to an addres:aee
be: intra-BMC
BMC from
parcel
for
to the Jacksonville
BMC to
the
Atlanta
If
BMC to Thomasville.
this
parcel
BMC, inter-
BMC, and intra
you do not confirm,
BMC
please
fully.
(a) Is this
circuitous
route
determined
for
the convenience
of
the USPS?
(b)
rate
making
originating
__.--_-.--._--
Is
~.~._---__
the
transportation
purposes
cost
limited
and destinating
to
postal
-~
assigned
the
to
this
GCD mileage
parcel
for
between
the
facilities?
_----
FGFSA/USPS-T16-11
In your
autobiographical
experiencfe
and you
includes
l'have
sketch
"attributable
worked
YOU
(a)
cost
Are you sponsoring
20?
If
not,
(b)
Please
pertaining
describe
described
for
fully
attributable
state
is
best
qualified
library
your
with
familiarity
are
‘I’OU
and
answer,
used
mail
volume
you
service
familiar
TRACS sample
is
from the container
with
for
each class
For
selected?
know how many TRACS samples
are taken
the BMC, and how many samples
the BMC (including
samples
Intra-BMC
are taken
taken
level,
cubic
the
TRACS (i)
to
up to the
foot
about
to
(ii)
level
miles
of
of mail.
the
routes,
of trucks
state
about
and subclass
and knowledgeable
keys
please
by
expand
to compute
answer
distribution
knowledgeable
formulas
and (iii)
to
the TRACS programs
the
In your
costs.
of these
references?
volume up to the container
Are
observed
any part
mail
transportation
and
in LR-PCR-17 or LR-PCR-
to each of these
procedures
or van,
have
YOU
expand sampled
whc#le truck
your
to parcels
sponsoring
witness
whether
sampled
that
in transportation"
that
witness
highway
methodology,
stat
related
in LR-PCR-17 used to develop
explicitly
(c)
analysis
any o,f the material
and which
questions
you
('IRACS) tests.
is any other
references,
iii,
projects
also
system
page
cost
on various
transportation."
transportation
at
way the
would
outbound
of trucks
at the BMC itself)?
inbound
you
from
to
(d)
Have you ever used any of the data contained
PCR-20 for
please
any kind
describe
of analysis,
the nature
in the CDs in LR-
or any other
purpose?
If
so,
of such analysis.
FGFSA/USPS-T16-12.
In
Docket
No.
Collection,
since
96-3,
stated
Please
collection
b.
C.
that
response
"[tlhe
to
OCA/USPS-39(2),
following
._..
under
Data
were added to TRACS
FY 93:
LL,- Fourth
a.
the
Explain
class
define
BSPS (Bulk
Fourth-class
in
the
TRACS data
system.
BSPS differs
how Fourth-class
collectors
Provide
to
references
collectors
regarding
data under
TRACS instructions
please
Parcels)
BSPS as used
and how TRACS data
entering
Small
all
criteria
from
distinguish
instructions
third-class
between
given
and definitions
the code "LL - Fourth-class
are
not
on file
as a library
to
the
BSPS,
two.
TRACS data
pertinent
BSPS."
to
If
reference,
provide.
FGFSA/USPS-T16-13.
Please refertoLR-H-82,
the
programTRACS.EXPAND.HWY.PQ*95.CNTL(HWY6).
a.
Expl.ain
how
measured
and
cubic
propmortions"
provide
this
utilization
define
language,
"expands
proportions."
25 percent
term
answer,
In
"utilization
explain
capacity
of
non-technical
the
cubic
Explain
fully
the
o:E the capacity
up by a single
the container
cubic
given
subclass
whether
the
truck
or
explanation
feet
to
match
of
the
what is meant by the
feet
of mail
is
not
indicate
in that
additional
Assume (i)
that
was taken
up by two subclasses,
mail
in
the
three-fifths
the
expand
60 percent
container
the
information
cubic
given
is
to
an answer,
information
(ii)
2, and (iv)
empty.
of
program
If
provide
the
in
here is not sufficient
please
of an OTR container
two-fifths
(iii)
of the
the
and the other
each
expand
is required.
By how much would
mail
of
information
that
that
1,
was
remainder
subclass?
was Subclass
feet
and the
of the capacity
was Subclass
container
of mail,
sufficient
all
of an OTR container
By how much would this
is empty.
here
provide
of
to
"adjust[sl
proportions."
the
In your
refers
a plain
program
Assume that
taken
d.
program
"expands."
term
,
please
this
else.
utilization
c.
match
proportions
something
how
to
extent
as used here.
utilization
Please
what
feet
response,
YOU=
b.
to
40 percent
this
subclass?
to provide
remaining
program
If
the
an answer,
please
provide
indicate
the
rationale
al .1 additional
information
that
is
required.
e.
What
is
containers
in proportion
container?
main
for
That
in
not
is,
the
assigning
to the mail
why
is
that
is actually
in a container
mail
container
capacity
empty
in
proportion
to
in
in the
charged
mail
in
for
the
container?
FGFSA/USPS-T16-14.
a.
b.
Please
list
each
of
container,
capacity,
that
Inter-BMC
highway
For
each
container
type
part
a,
indicate
whether
customarily
is only
C.
type
If
any containers
please
can be put
into
uses for
specified
in
the
each Intra-BMC
response
loading
of
to one subclass,
cubic
and
the
to
preceding
container
is
even when the container
full.
are
restricted
customarily
of whether
explain
Service
with
transportation.
confined
partially
regardless
the Postal
along
the
the rationale
a single
container
for
is
limiting
to one subclass,
only
partially
to one subclass
full,
what
container.
-
-__
.FGFSA/USPS-T16-15.
Explain
the
expanding
the
cubic
asserted
empty
the cubic
feet
capacity
of
to exist
capacity
principles
please
as
purpose,
on
accepted
accounting
rationale,
please
occupied
the
that
truck,
underlying
mail
If
actually
the
underlie
a causal
relationship
explain
fully.
purpose
Finally,
the
if
stated
each one fully.
10
-..-_--__
for
in the TRACS sample up to
stated
each one fully.
and describe
rationale,
on a particular
please
underlie
principles
list
by
truck.
mail
and describe
the
as
between
of economics
list
well
~-_-.
is
truck
and
If
any
or rationale,
any generally
purpose
or
CERTIFICATE OF SERVICE
I hereby
been served
accordance
Dated
certify
on all
that
the
foregoing
participants
with
section
this
28th
of record
12 of the Rules
day of July,
document
has this
in this
proceeding
of Practice.
1997.
M. W. Wells,
Attorney
11
Jr.
u
date
in