THE
BEFORE
RECEIVEtr
POSTAL RATE COMMISSION
WASHINGTON,
D.C. 20266-0001
POSTAL RATE AND FEE CHANGES, 1997
hc 18
Docket No. R97-1
1
RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS BRADLEY
TO IN-fERROGATORIES
OF UNITED PARCEL SERVICE
(UPS/USPS-T13-20-23)
The United States Postal Service hereby provides responses
Bradley to the following
interrogatories
UPS/USPS-T13-20-23,
filed on August 4, 1997.
Each interrogatory
of United Parcel Service:
is stated verbatim
and is followed by the response.
Respectfully
submitted,
UNITED STATES POSTAL
By its attorneys:
Daniel J. Foucheaux. Jr.
Chief Counsel, Ratemak.ing
.kc--3u.
Susan M. Duchek
475 L’Enfant Plaza West, SW.
Washington, D.C. 20260-I 137
(202) 268-2990; Fax -5402
August 18, 1997
of witness
&Au-
SERVICE
4 55PM'97
Page 1 of 1
Response of United States Postal Service Witness Bradley
to
Interrogatories of United Parcel Service
UPS/USPS-T13-20.
In reference to Table 15 of your testimony and thee HCSS database
(WP-I), please identify the HCRID observation number correspondiing to each of the
eliminated observations in Table 15 by category.
UPS/USPS-T13-20
Response:
A complete listing of the eliminated observations
and their account numbers is presented
on pages 131 through 134 of my [Docket No. MC97-21 Workpaper
convenience,
WP-7.
However, for
I reproduce the relevant HCRlDs here and arrange them by the regression
categories listed in Table 15. Also, please note that the duplication of certain HCRlDs is
not an error.
This duplication
segment for those HCRIDs.
occurs because there is more than one contract cost
Attachment to UPS/USPS-Tl3-20
A Listing of the HCRIDS for Omitted Observations
Arranged by Regression
P3bLl
9237b
12078
12243
02481
w.362
1w163
5rft4
PSZM
05760
80660
U?b2
E&b7
EJIPJS
82Mz
82672
BP%.3
WM?
82671
59361
l&Lx0
oowa
5wb6
262,‘
82M8
12902
32057
lLSO1
3158A
397bn
32MB
523M
31&D
397bn
STJOD
6WM
WPBO
323&D
6lnm
mm
SW61
OLU"
l&(31
50504
1.3539
&Lb1
37666
16332
16352
wno
67306
025bJ
04330
2SBLO
L923b
12910
83bL7
5201~
ME45
177%
30161
17?U
17%
Pw41
sub1
2m2
1bLfU
32LAV
so2w
3OlCU
92&O
12801
ROZO
38127
72023
lb430
12514
03OAB
92610
54510
56611
70011
w602
7x375
94019
95¶05
‘1141
323Ku
I&""
‘YP"
381 lb
07013
38120
175111
17511
370111
902“
90218
W2b2
llJ29
2%8U
25‘W
L&.&W
191Pu
Page 1 of 2
Categories
Attachment to UPS/USPS-T1 3-20 Page 2 of 2
98Ova
25013
80223
80395
16392
LSZBR
3nul
2lnlS
71332
B-3261
74735
32ZAR
1SlYU
271AV
061BE
5774D
9OlpD
27LlO
19L92
51010
19NJ
OZOAR
37D32
6754X
511m
38oPX
38OW
38OLIX
SKW
3e.ow
021N
6154R
a1011
53101
335w
453MY
2oua
202AP
202M
ObDB11
189CR
9024X
2008Q
ZOOYI
ZOOTP
2OM
ZOOM
2OOYP
LMO7
173FP
6100R
027A1
‘9‘"R
226*x
19531
Page 1 of 1
Response of United States Postal Service Witness Bra’dley
to
Interrogatories of United Parcel Service
UPS/USPS-T1 3-21. Your testimony in Docket No. R87-1 (USPS-T-g) included an analysis
of time series data for selected inter-SCF and inter-BMC contracts (Tr. 1218670). Please
state whether you have subsequently conducted any variability-related analyses of USPS
purchased transportation costs based on time series data. If so, please describe the
particulars of all such analyses, including the mode of transportatioln, the time period
covered, the econometric model or other estimation methodology applied, the data sources
used, the results of the analyses performed, and any conclusions drawn from the analyses.
UPS/USPS-T13-21
Response:
I have not conducted
transportation
any subsequent
variability-related
costs based on time series data.
analyses of USPS purchased
Page 1 of 1
Response of United States Postal Service Witness Bradley
to
Interrogatories of United Parcel Service
UPS/USPS-T13-22.
With reference to equation (1) at page 6 of your testimony, please
confirm that the variability of a particular contract or route j might be different from the value
of the R, coefficient if that contract’s CFMj and RLj characteristics differ from the mean
values CFM and RL, respectively.
UPS/USPS-T1 3-22 Response:
I would caution against applying the equation to an individual contract for the purposes of
calculating
a variability.
The estimated variability measures the responsiveness
across all contracts in the cost pool. As the Commission
of cost
stated in Docket No. R87-1:’
‘We believe that, using the translog model with
the extensive data set available, the variability
levels estimated reflect the entire range of costaffecting changes.
Nevertheless,
as a mechanical
matter, I agree that if the equation is evaluated at values
for an individual contract whose CFM and RL characteristics
the calculated variability will not equal 6,
‘SC?!%PRC Op., Rf37-1, at page 308.
differ from the mean values,
Page 1 of 1
Response of United States Postal Service Witness Bradley
to
Interrogatories of United Parcel Service
UPS/USPS-T1 3-23. In reference to page 14 of your testimony, please confirm whether the
HCSS data set represents substantially all of the purchased highway transportation
contracts for which Cost Segment 14 -- Highway costs were accrued during FYI995 and
explain the source of any differences between the total dollar amounts recorded.
UPS/USPS-T1 3-23 Kesponse:
Confirmed.
contracts
Differences
will arise between the total dollar amounts recorded across all
in HCSS and the amounts
recorded
captures the annual rate at which contractors
actual payments.
exceptional
in the cost accounts
because
HCSS
are paid and the cost ac:counts capture the
The actual payments will differ from plan because of factors like
service and extra trips.
DECLARATION
I, Michael D. Bradley, 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 doclument upon all
participants of record in this proceeding in accordance with section 12 of the Rules
of Practice.
/
Susan M. Duchek
475 L’Enfant Plaza West, S.W
Washington, D.C. 20260-I 137
(202) 268-2990; Fax -5402
August 18, 1997
/f!?-2Q