RECEIVEO
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
POSTAL
RATE AND FEE CHANGES,
1997
)
Docket No. G!97-1
FIRST SET OF INTERROGATORIES
OF MAJOR MAILERS ASSOCIATION
TO UNITED STATES POSTAL SERVICE WITNESS
JOE ALEXANDROVICH
(USPS-T-5)
Major Mailers Association asks the United States Postal Servil:e to answer the
following interrogatories
pursuant to Rules 25 and 26 of the Commission’s
Practice and Procedure.
In answering these interrogatories,
the witness is requested to
follow the General Instructions that are set forth in Attachment
Requests for data or documents
Instructions
interrogatory,
Rules of
1 to this document
are to be interpreted in accordance
‘with General
G and H. If the designated witness is unable to respond to any
the Postal Service is asked to redirect the question to slnother Postal
Service witness who can answer it
Respectfully submitted,
MAJOR MAILERS ASSOCIATION
%220 Nineteenth St. N.W.
Suite 400
Washington, DC 20036
Phone: (202) 4666260
August 13, 1997
MMA INTERROGATORIES
TO USPS WITNESS
(Joe Alexandrovich:
Set One)
MMAIUSPS-T5-1.
Please provide the BY 1996 Clerk and Mailhandler Mail Processing costs using
the Commission’s
attribution methodology
for First-Class Mail for each of the
following operation codes: 01 mail preparation,
02 outgoing primary, 03
outgoing secondary, 04 incoming primary, 05 incoming secondary and 06
outgoing and incoming.
LIOCAlT
The data should be comparable
to Report AlA850P21,
SYSTEM Schedule B & C - Summary ClerksJMailhandlers
cost by
Basic Function, LIOCATT Format I, which was provided in USPS witness Barker
workpapers,
pages 22,23,37,38,52,53,67,68,82,83,97
and 98 in Docket No. R94-
1
MMAIUSPS-TS-2.
Please provide the BY 1996 Clerk and Mailhandler Mail Processing costs using
the Postal Service’s attribution methodology
following operation codes:
for First-Class Mail for each of the
01 mail preparation,
02 outgoing primary, 03
outgoing secondary, 04 incoming primary, 05 incoming secondary and 06
outgoing and incoming.
The data should be comparable
to Report ALA850P21,
LIOCATT SYSTEM Schedule B & C - Summary ClerksJMailhandlers
Basic Function, LlOCAlT
workpapers,
1.
MMAIUSPS-T5-3.
cost by
Format I, which was provided in USPS witness Barker
pages 22,23,37,38.52,53,67,68.82,83,97
and 98 in Docket No. R94-
Please provide the IOCS BY 1998 weighted tally proportions
operation code for each First-Class category.
similar data utililzed by the Commission
by mail type and
The data should be comparable
in Docket No. R90-1, ,4ppendix F, page
8.
MMAIUSPS-T5-4.
Please provide the indirect piggyback factors for each piece of equipment that
processes First-Class letters. The data should be comparable
utilized by the Commission
in Docket No. R90-1, Appendix
to similar data
F, ipage 6.
MMAIUSPS-T5-5.
What is the average hourly wage rate for clerks and mailhandlers
for BY 1996,
FY1997andTY1998?
MMAIUSPS-T5-6.
What percent of clerk and mailhandler direct labor costs are overhead costs in
the test year a) under the Postal Service’s cost methodology
Commission’s
and b) under the
cost methodology?
MMAIUSPS-T5-7.
Please provided the BY 1996 First-Class volumes by shape for each category.
End of Set One Interrogatories,
but please note attached
General Instructions
For Answering
to
CERTIFICATE
OF SERVICE
I hereby certify that 1 have this day served the foregolng document. by First-Class Mall,
upon the participants requesting such serwce in this proceedings
l,
i/ Jeffrey Plummer
August 13, 1997
ATTACRNENT 1
Page 1 of 3
GENERAL INSTRUCTIONS FOR ANSWERING INTERROGATORIES
A.
If
Request
for
the witness
to whom a particular
Production
of Documents
respond,
the
question
or request
to another
the question
or comply
answer
Service
witness
believes
Interrogatory
its
and his
that
position
promptly
lawyers
Postal
it
should
request.
by facsimile
the
who can
If
the Postal
can respond
is asked to advise
to
redirect
witness
witnesses
or
is unable
Service
the
none of its
or Request,
is directed
or her
with
Interrogatory
to an
MMA counsel
message to Telecopy
of
Number
202-293-4377.
In interpreting
B.
Request
for
Production
hypertechnical
what
is not worded
ava
could
the
but
lable,
other,
use in
witness
lieu
C.
Documents
previously
will
know about
the
information
party
or know about
the
available
requests
supplied
Interrogatory
or
Sim,ilarly,
that
is
an
not
the
availability
of
the
requesting
party
In such cases,
Interrogatory
that
be
Interrogatory
information.
the
that
the
that
unavailable
if
If
the
or
atsle to ascertain
or correctly.
is asked to interpret
for
is often
even if
information
of the
providing
do not
may seek information
different
have asked
precisely
precisely
the witness
somewhat
generously,
would
sought
or Request
please
A witness
is being
Interrogatory
of an Interrogatory
of Documents,
or grudging.
information
Request
the wording
the
of Request
requesting
had phrased
the
party
inquiry
more
information.
or Request
information
that
in this
proceeding,
for
the Postal
please
Production
Service
state
of
has
and identify
ATTACHMENT 1
Page 2 of 3
the
document
in which
any Library
References
information
relevant
D.
term
"documents"
clippings,
tabulations,
created,
should
provide
response
studies,
recorded,
written
"workpapers"
prepared
manually,
all
workpapers
that
are
or Request
all
replication
for
limited
to:
of the
arithmetic
means
any
or use such documents.
prices,
explanatory
newspaper
with
material,
whether
or electronically,
with
letters,
by w:hatever
together
back-up
the witness
Production,
pamphlets,
to understand
of costs,
by or for
together
is not
and workpapers
mechanically
created
or Request
testimonies,
includes
calculations
testimony,
or Request.
or transmitted,
necessary
The term
analyses
contain
to an Interrogatory
but
drafts
stored
material
the
also
Interrogatory
includes,
reports,
permit
that
Identify
of Documents.
memoranda,
forth
was provided.
As used in an Interrogatory
E.
the
to the
to the witness'
Production
information
and Workpapers
The witness
relevant
for
that
and should
rates
or statistical
in preparing
information
steps
set
his
sufficient
to
depicteld
in such
cite
,the complete
workpapers.
In referring
F.
title,
author,
should
cite
testimony
location
publisher
and,
in this
if
number of the
G.
When a witness
request
should
if
possible.
state
identity,
the
location
is
document's
and
custodian.
is asked to provide
be interpreted
th#e document
Unless
please
the
document's
References
of publication.
proceeding,
not published,
telephone
the
and date
page and line,
filed
please
to a document,
as asking
data
for
,or a document,
information
that
ATTACHMENT 1
Page4 3 of 3
is available
about
to the Postal
or has the
determining
within
that
the
Ruling
which
it
Officer's
Docket
provide
that
doing
party
the
is expected
of the
H.
Tostal
Service
make analyses,
principles
5-6)
and other
cited
the Postal
Service
in Presiding
objections
In the
the
information
so would
expected
event
be
an unreasonable
to make the
Commission's
Rules
showing
of Practice
party
in
does
believes
requested
25(c)
:requires
the
to perform
:research
or to
to (comply with
Ruling
No. R94-l/l8
the
(pp.
No. R94,-1 concerning
to compel
and the
Federal
to Postal
clourt
under
and Procedure.
decisions
believes
requlested
Rule
Motion
does not
party
the
Postal
Se:cvice's
party
requested
burden,
required
both
undlar Rule
requested
the
and June
party
the
in
request
in Docket
1994 Response
because
cited
to Compel,
is requested
the
is
P.residinq
requestelI
the
(See also
that
,available
and Procedure?.
and motions
thereto.
Postal
Response
required
In
Presiding
requested
Officer's
Orders
burden.
authorities
burden,
answering
information,
in MMA's June 16,
provide
the
showing
to compile
requests
to Compel.)
"The
the
of Practice
that
Commission
MMA's discovery
Service's
Rules
event
stated
that:
Motion
because
to make the
In the
the
(See also
that
knows
Commission's
follow
be an unreasonable
Commission's
to the
Leave to File
event
information
so would
6),
Service's
In the
reasonable
p. 5; legal
for
witness
25 of the
should
(p.
to Postal
No. R94-1.)
not
of Section
No. R94-l/38,
1994 Response
16,
without
to obtain."
1994 Request
the
"available"
witness
is possible
MMA's May 10,
is
No. R94-l/18
Ruling
and that
to locate
the meaning
of Practice,
Officer's
doing
ability
what information
Service,
Rules
Service
25(c)
party
of the
that
is