BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 2026~8-0001
Docket
POSTAL RATE AND FEE CHANGES, 1997
No. R97-1
FLORIDA GIFT FRUIT SHIPPERS ASSOCIATION
INTERROGATORIES TO UNITED STATES POSTAL SERVICE
WITNESS:lYICHAEL D. BRADLEY
FGFSA/USPS-T-13-1-39
July
Flc#rida
following
Gift
Fruit
interrogatories
28,
Shippers
1997
Association
to USPS Witness
M. W,
Attorney
Florida
Gift
Association
hereby
submits
Bradley.
Fruit
V
Shippers
the
INTERROGATORIES TO WITNESS BRADLEY
FGFSA/USPS-T-13-l
Please
refer
to LR-H-82
HCSS (discussed
the
file
used
highway
a.
develop
explain
give
why they
Is
the
to
in
to the data
in
the
four
TRACS
routes
served
to the
in the program
description
by those
routes
used to
TRACS.DESIGN(HWYl)?
of
all
differences
and
differ.
cost
account
information
the
TRACS.,DESIGN.(HWYl)?
why they
for
contained
in TRACS.DESIGN(HWYl)
design
a full
highway
identica:L
frames
by HCRID) identical
the TRACS sample
please
sample
in thss HCSS and the
(as indicated
not,
the
how the data
at page 12) relate
accounts
Are the contracts
create
b.
to
testimony
transportation
contracts
If
in your
and describe
If
for
which
please
not,
each
contract
routes
identifies
explain
all
in
differences
HCSS
in
and
differ.
FGFSA/USPS-T-13-2
In your
contracts
a.
Are
different
the volume
b.
Are
different
testimony,
specify
multiple
different
days?
of
page
Table
vehicle
capacity
If
19,
does the
of
diff:erent
it
is
noted
that
some
capacities.
vehicles
so,
3,
used
difference
on the
same
in capacity
route
on
relate
to
mail?
vehicles
segments
on the
capacities
same route?
regularly
used
on
C.
Tor
those
capacities
contract
(Table
increase
vehicles
cost
3)
does
the
segments
the
with
ability
variability
multiple
to
of
use
purchased
vehicle
different
size
transportation
costs?
FGFSA/USPS-T-13-3
Please
actual
that
confirm
highway
that,
in
rather
miles,
you use highway
miles
HCSS, the
than
great
in your
data
for
circle
route
distance
length
is
miles,
and
analysis.
FGFSA/USI?S-T-13-4
At page 49 of your
use the variebilities
observations
Are these
b.
If
also
recommend that
thereby
calculated
you recommend that
on the data
the commission
set with
the unusual
removed.
a.
Intra\SCF
testimony
variabilities
the Commission
shown in Table
were to adopt your recommendation,
the
TFACS system
Vans and Trailers,
reflecting
15?
the
and for
separate
develop
separate
Inter-SCF
variabilities
would you
samples
for
vans and Trailers,
shown in your
Table
15?
FGFSA/WPS-T-13-5
Please
are included
provide
in your
the
total
analysis,
number of contracts
with
a breakdown
in
between
force
Inter
which
SCF,
Intra
BMC and Inter
Bmc.
in August,
1995,
time
the contracts
which
or,
if
Confirm
that
you do not
these
confirm,
contract
were in force
explain
the period
of
were in force.
FGFSA/USPS-T-13-6
Provide
a copy of
the
BASIS SURFACE TRANSPORTATION SERVICES
CONTRACT GENERAL PROVISIONS in use during
form provided
in Docket
No. R80-1,
August,
1995.
See the
TR 17,870.
FGFSA/USPS-T-13-7
When each contract
is being
(a) How is the capacity
capacity
('b)
capacity
(c)
for
each Contract
What
negotiated
being
or renegotiated:
purchased
related
to the needed
Route?
of
projections
volume
is
used
to
ascertain
the
to be purchased?
Is there
any analysis
made of actual
capacity
utilized
by
the day and week?
(d) Is the capacity
estimates
of
average
purchased
volumes
for
each Contract
to be carried
Route based on
each day of
a normal
week?
(e) What period(s)
of average
capacity
are used for
utilization
the preparation
on each Contract
of estimates
Route?
FGFSA/USPS-T-13-8
Describe
being
for
the
purchased,
the
investigation
as related
Contract
Route
made to
to actual
over
determine
the
or anticipated
a period
of
capacity
volume of mail
time.
FGFSA/USPS-T-13-9
How does
respond
the
the
to changes
Contract
capacity
in the
purchased
for
of mail
volume
each
actually
Contract
Route
transported
over
Route?
FGFSA/USPS-T-13-10
How is the underutilization
account
at the
time
of purchased
of negotiation
for
capacity
replacement
taken
into
contracts?
FGFSA/USPS-T-13-11
Prcsvide
of each class
tme
of
the volume
and subclass
Contract
Route
profile
- pieces,
o:E mail
for
the
using
weight
and cubic
the purchased
fiscal
year
feet
capacity,
covered
by
by
your
analysis.
FGFSA/USPS-T-13-12
In the
to
contracting
ascertain
Contract
Route?
how much
process,
capacity
what
projections
volume
should
be
purchased
are used
for
each
FGFSA/USPS-T-13-13
Desc!ribe
capacity
mail
the
investigation
purchased
over
made to determine
as related
a period
of
to
the
behavior
of
and projected
volume
of
have on unused
capacity
of
a function
of
actual
time.
FGFSA/USPS-T-13-14
What effect
purchased
do changes
in volume
transportation?
FGFSA/USPS-T-13-15
Describe
of
estimate:5
how the
mail
capacity
being
purchased
is
volumes.
FGFSA/USPS-T-13-16
Your
testimony
is
transportation
network
You
that
also
in force"
on
the
state
and that
that
the
is basicly
"approximately
operational
purchased
network
"general
the
"changes:
in
footnote
6 on page 8 of your
the
same as in 1986"
highway
(p.7,1.22)
"have not had a major
network".
as those
capacity"
of
the same number of contracts
changes
transportation
nature
Please
words
impact
describe
are
used
is
in
the
your
testimony.
FGFSA/USPS-T-13-17
Quantify
-.---
- pieces,
weight
-
and cube
- added
to
the
highway
--__
transportation
network
Service
to divert
mail.
Quantify
Inter
SCIF, Intra
as a result
of
First
Class
Mail,
by type
of
surface
BMC and Inter
the
as well
efforts
of
as other
transportation
the
Postal
preferential
- Intra
SCF,
BMC
FGFSA/USPS-T-13-18
was your
analysis
designed
"to
measure
the
impact
of volumes
on cost"?
If
so,
(a) What mail
(b) How are mail
volumes
volumes
taken
did
into
you take
account
into
account?
in your
analysis?
FGFSA/USPS-T-13-19
Do the
represent
the
cubic
foot
which
mi.les
calculated
capacity
you
of all
use
in
purchased
your
analysis
transportation
contracts?
,How are the cubic
actually
transported
foot
under
miles
the
determined
by you related
to mail
contracts?
FGFSA/USPS-T-13-20
Provide
contra&
types
the
actual
listed
mail
volumes
in your
Table
transported
in each of the
5
3 in 1990 and 1996.
FGFSA/USPS-T-13-21
On page 21 of your
testimony
you state
that
the HCSS data
are
"for
suitable
estimating
transportation
Please
costs".
relates.
If
volumes
which
variability
the
"variability"
explain
relates
you took
into
of
to what
to mail
the
volume,
purchased
"variability"
provide
the mail
account.
FGFSA/USP-T-13-22
Explain
"exceptional"
differences
between
"emergency"
and
these
and
contracts
the
terms.
FGFSA/tJSPS-T-13-23
Explain
contracts
why
contracts
is the cost
illness,
exceptional
cost
"assumed
is
When these
the
variability
to
of
be: one hundred
replace
a break
of the basic
contracts
the
exceptional
of
percent".
so,
or driver
Is the cost
reduced?
If
fn.12)
(p.22,
down of equipment
contract
"attributable"?
cost
to what mail
is
of
the
attributed?
FGFSA/USPS-T-13-24
In your
were
for
emergerxy
Explain
contracts.
Table
2 (page 17),
emergency,
3.7%
and 7.6% of
Inter
the
reason
for
of
this
13.67% of
Intra
Inter
BMC observations
BMC observations
wide
SCF observations
difference
were
in
for
the
were
for
emergency.
emergency
FGFSA/USPS-T13-25.
Where there
the
is an imbalance
in-bound
bound,
mail
volume,
or backhaul,
empty backhaul
is merely
the backhaul
to the same
a part
that,
if
similarly
haul?
(b) Has there
been a change
haul
(that
due to
is,
the
advantage
for
Please
Intra
changes
of
in
the
capacity
caused
explain
destination
entry
of
in-
that
an
haul?
with
volume,
in the costs
of
answer.
in the volume
pattern
on the
and is attributable
the changes
of
BMC transportation,
the
varies
volume
your
and
of the out-bound
haul
with
volume
mail
Do you believe
of the cost
the out-bound
that
the out-bound
of
be empty.
varies
changes
volume
the out-bound
a portion
movement will
(a) Do you believe
that
between
for
mail
the
mail
discounts?
entry
If
the
haul
in-bound
to the BMC)
points
so,
to
quantify
take
the
change.
FGFSA/USPS-T13-26.
Do you agree
(capacity)
in the
that
over
of trucks
volume
time
the Postal
to accord
of mail
with
on particular
Service
can change
the underlying
the size
secular
changes
routes?
FGFSA/USPS-T13-27.
As a hypothetical,
volume
inbound
of
mail
assume that
outbound
from
to the BMC on a reg~ular
on a particular
Intra-BMC
the
exceeds
BMC greatly
basis,
including
route
the
peak days.
the
volume
a.
Do you agree
that
the volume
of outbound
appropriate
size
(capacity)
of
Exp.lain
b.
If
fully
conmcur that
Explain
C.
van,
size
fully
for
that
the
route?
secular
could
accommodate
growth,
be expanded,
that
growth
do you
up to the
in
volume.
the Postal
Service
any disagreement.
increased
an expanded
volume
that
exhibits
of the truck
to
has in fact
to carry
d.
the size
mail
Assume than on a particular
agree
truck
determines
any disagreement.
the volume of outbound
maximum
the
mail
the
Intra-BMC
the capacity
of
mail
Service
the outbound
volume,
return
to
the
mail?
Explain
BMC with
fully
In your
opinion,
inbound
trip
inbound
trip,
to the
large
is
of the truck
outbound
Postal
the
route
can not
from
to accommodate
the
dispatch
a large
but have a much smaller
much smaller
volume
of
Do you
truck
vehicle
inbound
any disagreement.
the
substantial
excess
capacity
to the BMC caused more by the small
or is the excess
outbound
BMC.
volume?
10
capacity
Please
volume on the
more causally
explain
on the
fully.
related
FGFSA/USPS-T13-28.
Do you agree
capacity
that
at any pa.rticular
in a particular
route
is
point
in
fixed?
the
amount
so, please
explain.
time,
If
of
FGFSA/USPS-T13-29.
In Docket
capacity
average
a.
b.
the Postal
No. RBO-1,
purchased
weekly
for
a given
route
peak-day
volume
on that
Is it
your
route
is still
understanding
matched
volume?
Explain
Consider
an Intra-BMC
first
portion
portion
being
ca!pacity,
fully
being
inbound
would
the
heaviest
daily
volume
heaviest
daily
volume
your
Service
that
stated
is
matched
average
any negative
amount of
the
expected
on a highway
weekly
peak-day
answer.
consists
from
to the BMC.
to
purchased
to the expected
outbound
the
route.
capacity
roue that
that
of a round-trip,
the
BMC and
For purposes
peak-day
volume
:in both
directions
return
of purchasing
of
(i)
the
combined,
or (ii)
the
consist
in one direction
the
the
only?
Please
explain
answer.
FGFSA/USPS-T13-30.
In Docket
No. RSO-1,
the
Postal
Service
11
said
that
excess
capacity
is
caused
demand,
by a complex
set
of
inflexibilities
intermediate
in
stops
factors,
the
on routes..
including
supply
of
(USPS-T-6,
irregularity
of
transportation
pp. 17-18,
and
cited
at 1 0408
in the Op. & RD.)
a.
unu;sed
capacity
Ple,ase explain
b.
on
its
Postal
Service
highway
any negative
trucks
on an Intra-BMC
route
send a large
capacity
truck
outbound
the outbound
volume.
That
same truck
BMC, even if
the
inbound
truck
the
return
supply
negative,
volume
from
the
supply
of transportation."
Please
articulate
found
on a largely
emlpty
capacity
causally
empty
on the
the
time?
the
needs to
the BMC because
light,
need
and the
to
all
relate
return
have
event
your
the
to the BMC.
12
same
in
answer
(or back
cost
of
is
in the
principles
the volume of
and the
truck,
truck
of an inflexibility
economic
trip
of
back to the
an example of an "inflexibility
and explain
you are aware that
empty capacity
In
transportation?
supply
to have
Service
must travel
is very
Would
capacity.
please
much of
the Postal
to the BMC be an example
of
continue
answer.
Suppose that
has; much unused
C.
does the
To 'your knowledge,
mail
of which
actually
haul)
returning
to
the
that
FGFSA/USPS-T13-31.
Please
refer
statement
to equation
(1) at p.
"[tlhe
that
value
6 of
your
the
0,
of
testimony,
and your
coefficient
is
the
variability."
a.
Would
it
be
coefficient
changes
estimates
in cubic
coefficient
changes
b.
Are
correct
more
foot
of
interpreting
the volume
of mail?
of transportation
miles
For
of cost
of cost
Please
mail?
of cost
of
highway
in the volume
with
costs
value
with
with
respect
your
respect
respect
to
(ii)
the
respect
to
answer.
a proxy
for
to changes
view
of the
transportation
of
the
your
@, as
with
of
than
explain
coefficient
PILease explain
variability
the
(CFM) of capacity,
the
the variability
to changes
(i)
the variability
estimating
respect
C.
miles
in the volume
between
say that
the variability
estimates
you
to
in
linkage
costs
with
and the variability
mail
to changes
in cubic
foot
of capacity.
intra-BMC
use for
cubic
highway
foot
(i:) the round-trip
transportation,
mil.es
mileage
do the
(CFM) in your
on an Intra-BMC
data
equation
route,
which
you
(1) reflect
or
(ii)
the
13
-. .--..____
-.-----
__-~-
one--way mileage,
either
inbound
or outbound?
FGFSA/USPS-T13-32.
a.
As a hypothetical,
particular
assume that
Intra-BMC
BMC averages
X thousand
factor
on the
feet,
(iii)
thousand
return
over
cubic
feet,
truck
legs.
required
volume
of mail
volume
moving
reasoning
b.
For
the
assume
that
a secular
increase
in
for
route
this
on the
both
average
increases
your
route
volume
of
from the
(ii)
leg
is
the
the
the
0.8X
factor
averages
the
1.8X
be determined
chiefly
inbound
Please
by
outbound
capacity
described
volume
in
of
as
and
the
by the
leg,
or the
explain
preceding
of various
of
drop
mail
shipped
of dropship
mail
outbound
on the
cubic
feet,
changes,
plus
introduction
14
cubic
the
answer.
of mail
to 1.3~ thousand
thousand
the
the
load
fluctuates
on both
leg,
of a
average
volume
would
as the result
in
the
outbound
directions?
underlies
to
factor
feet,
outbound
in the volume
response
load
average
opinion,
growth
leg
the load
In your
that,
outbound
directions
of the
in
on the
inbound
and (iv)
hypothetical
further
the
cubic
or
both
much as +40 percent
inbound
route
(i)
while
part
a,
such as
a significant
to the BMC (e.g.,
discounts),
leg
the
from
volume
the
the
BMC
in the
inbound
direction
diminishes
both directions,
cubic
Daily
of
what
likelihood
the
additional
Further
assume
likely
average
Postal
of
the
truck
part
a
b were
Service
to
to
such
occur
in capacity,
as well
though
was no change
in the
total
transported?
(ii)
Would
mail
there
actually
systemwide
how would
shift
a
preceding
part
the
on the
empty
affirmative,
equation
that
shift
such
c, in your opinion,
please
(i)
-. .-_--__
Isn't
it
show a change
in cost,
cubic
foot
structure?
even
miles
you describe
as
that
of
such a
If
not,
is the mail
leg to the BMC causally
usually
found
provide
a full
on the
described
that
happens
responsible
inbound
explanation.
15
-,. .~..___
in
it?
systemwide
capacity
the
described
change
as a change in operating
inbound
need to
accommodate
(1) would
as a corresponding
you describe
Following
travel
in your
opinion,
would
systemwide.
the data
up to
leg?
as
that
(over
range
In your
on the outbound
shift
feet
1.8X thousand
still
volume.
the
of mail
that
in volume
daily
cubic
averages
that
capacity
volume
preceding
d.
the
the
volume still
fluctuations
k40 percent
increase
C.
the total
feet).
is
to 0.5X thousand
-
leg?
in
to
for
If
FGFSA/lJSPS-T13-33.
(a)
Please
describe
described
about
(i)
to
keys
please
for
miles
which
explicitly
sampled
mail
truck
are used to develop
whether
costs.
In your
up to the
used by TRACS
container
level,
volume from the container
and
service
(iii)
for
the
you are knowledgeable
and formulas
volume
or van,
of transportation
the TRACS programs
highway
procedures
to expand sampled mail
whole
with
attributable
the methodology,
the
familiarity
and LR-H-04
state
to expand
(ii)
your
in LR-H-82
distribution
answer,
fully
to
compute
each class
level
cubic
up
foot
and subclass
of
mail.
(b)
Are
you
familiar
TRACS sample
is
with
and knowledgeable
For
selected?
know how many TRACS samples
the BMC (including
Cc)
samples
taken
or
purpose?
LR-H-84
If
for
so, please
any
kind
describe
16
the
routes,
of trucks
are taken
Have you ever used any #of the data
H-82
Intra-BMC
are taken
the BMC, and how many samples
about
way the
would
you
outbound
of trucks
from
inbound
to
at the BMC itself)?
contained
of
analysis,
the nature
in the CDs in LRor
any
other
of such analysis.
FGFSA-USPS-T-13-34
the
Please
provide
subject
of
including1
all
a list
of all
your publications
transportation
expert
and
witness
that
deal
transportation
with
economics,
testimony
FGFSA/USPS-T-13-35
Please
list
transportation
all
courses
economics
that
in
transportation
and/or
you have taught.
FGFSA/USPS-T-13-36
For
routes,
Intra-BMC
each
please
provide
foot
capacity
for
a.
For
each
proportion
of
the
of
and
the
interior
highway
vehicle
transportation
dimensions
and cubic
3 most commonly used vehicles.
the
total
Inter-BMC
3
indicate
.vehicles,
cubic
foot
capacity
approximate
the
which
those
vehicles
represent.
b.
For each of the 3 vehicles,
capacity
varies
of
the
lading
f.rom state
capacity
to
and identify
in
the
state
indicate
If
vehicle.
indicate
state,
the
please
with
the
the maximum weight
the
lowest
maximum weight
maximum weight
such limitation
FGFSA/USPS-T-13-37
If
a trailer
used
in
Inter-BMC
transportation
is
fully
bed-
loaded
with
Bulk
road weight
feet
of
Rate Regular
of the loaded
limit
the
Standard
that
mail
can
response,
please
provide
(give
the
height,
width
limit
of the
lading
mail,
cubic
or
on the
foot
and length
the
will
vehiclerestrict
be loaded
the
in the
B
trailer?
capacity
which
the cubic
limit
In
of
measurements)
trailer
over-the-
the
trailer
and the
you take
into
your
weight
account.
FGFSA/USPS-T-13-38
Confirm
in
postal
the maximum allowable
highway
dividing
road
that
the
weight
confirm,
feet
of
limit
please
used
calculated
by
capacity
of
the
trailer
by the
over-the-
lading
of
the
trailer.
If
you do not
the
fully
of a trailer
can be properly
transportation
cubic
density
explain.
FGFSA/USPS-T-13-39
If
the density
transportation
exceeds
transporting
a.
could
loaded
b.
reflect
the maximum allowable
that
the excess
or restrict
in the
excess
the
that
it
density
density
quantity
Fully
trailer?
Do you agree
the
of mail
transported
density
in highway
of the vehicle
the mail:
Do you agree
limit
of a sub-class
explain
would
of this
of other
your
18
sub-class
mail
that
of
might
mail
be
response.
be reasonable
of this
sub-class
and appropriate
of
mail,
along
to
with
actual
cubic
the highway
feet,
in determining
transportation?
the
Fully
19
allocation
explain
your
of
the
response.
costs
of
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
day of July,
Rules
document
in this
has this
proceeding
of Practice.
1997.
M. W. Wells,
Attorney
20
Jr.
V
date
in