RECEIVES
BEFORE THE
\
I./ 35 PM ‘97
POSTAL RATE COMMlSSleRt
WASHINGTON,
D.C. 20266-QQBffi<L fih~r~COHI~ISSI~”
OF;,CEoi T,,E SECRETARY
POSTAL RATE AND FEE CHANGES, 1997
Docket
j
No. R97-1
RESPONSE OF UNITED STATES POSTAL SERVICE
WITNESS DEGEN TO INTERROGATORIES
OF
ADVO AND THE ALLIANCE OF NONPROFIT
MAILERS
(ADVOIUSPS-T41-2,
REDIRECTED
FROM WITNESS TAKIS,
AND ANM/USPS-T12-l-7)
The United States Postal Service
the following
USPS-T12-l-7
September
interrogatories
hereby provides
of the Alliance
and ADVOIUSPS-T41-2
responses
of Nonprofit
(redirected
Mailers
of witness
and ADVO:
from witness
Degen to
ANM/
Takis), filed on
17, 1997.
Each interrogatory
is stated verbatim
and is followed
Respectfully
UNITED
by the response
submitted,
STATES
POSTAL
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
475 L’Enfant Plaza West, SW.
Washington,
D.C. 20260-I 137
(202) 268-2992;
Fax -5402
October 1, 1997
SERVICE
Response of United
to Interrogatories
States Postal Service Witness Degen
of Alliance of Nonprofit
Mailers
ANM/USPS-T12-1.
Please refer to your response to TW/USPS-T12-2,
where
you acknowledge
that the MODS number and the observed activity may be
inconsistent.
What was the total number of tallies for which the recorded
IOCS activity did not correspond
to the MODS number for which the sample
employee was clocked in?
ANM/USPS-T12-1
It is not possible
defined
numbers.
Response.
to provide
in questions
MODS number
6-7.
to TW/USPS-T12-2
are instructed
operation
since the activities
correspond
(especially
to MODS
part c) indicates
not to guess the employee’s
based on the observed
with the MODS-based
information,
18 and 19 do not directly
My response
IOCS data collectors
the requested
activity.
definitions.
This provides
that
clocked-in
consistency
Please see USPS-T-l
2 at pages
Response of United
to Interrogatories
States Postal Service Witness Degen
of Alliance of Nonprofit
Mailers
ANM/USPS-T12-2.
Please refer to your Attachment
1 to response to
NAA/USPS-T12-2.
For the veers 1990-1995
please provide the total
number of IDCS tallies, broken down by the number of (i) direct, (ii) mixed
items, (iii] identified
mixed containers,
(iv) non-identified
mixed containers
and (VI not-handling
tallies corresponding
to the totals shown at the bottom
of Attachment
1.
ANM/USPS-T12-2
The following
Response.
table contains
processing
tallies
consistent
with
cannot
produce
differences
the requested
for 1993-1995.
Attachment
The definition
1 to my response
the requested
in the formulation
breakdown
1993
1994
1995
Direct
95,425
92,827
91,470
Mixed
Item
6,794
8,194
8,165
of IOCS mail
of mail processing
is
to NAAKISPS-T12-2.
for earlier years
of IOCS questions
Breakdown
of Mail Processing Tallies,
IBY 1996 definition
of mail processing)
Year
breakdown
because
I
of
21 and 24 prior to 1993.
1993-1995
Mixed
Identified
Container
11,589
9,766
10,023
Mixed
Unidentified
Container
7,485
7,171
7,975
Nothandling
90,660
95,469
90,607
Total
211,953
213,427
208,240
f
Response of United
to Interrogatories
States Postal Service Witness Degen
of Alliance of Nonprofit Mailers
ANM/USPS-T12-3.
Please refer to Attachment
1 to your response to
OCA/USPS-T12-14.
That attachment
shows the following
data entries
Bulk Nonorofit
Other:
for
Amount
(BNP-Other)
107
181
369
169
108
99
329
364
63
14
503
31
1,532
5
449
87
MODS 1 and 2
Express
Manp
Mecparc
Priority
Spbs Prio
Bus Reply
INTL
LD41
LD42
LD 48 Exp
LD 48 0th
LD48-SSV
LD 49
Registry
1 Bulk pr
1 SCAN
(a) Please describe what each MODS operation listed here entails.
(b) Please explain how and why Bulk Nonprofit
Other is charged with costs
for the MODS numbers shown.
(c) Do such cost entries represent (i) actual tallies, (ii) the result of a
distribution
process such as LIOCATT, or (iii) something
else?
ANM/USPS-T12-3
Response.
a. Please see Table 4, USPS-T-l
b. For the MODS
distribution
Nonprofit
associated
2, and pages l-l 2 to l-37,
pools shown,
Bulk Nonprofit
of volume-variable
Other activity
with
costs
codes
mixed-mail
tallies
Other will receive
if there are direct
associated
LR-H-146.
tallies
a
with
Bulk
with the cost pool, or if costs
were distributed
to Bulk Nonprofit
Response of United
to Interrogatories
Other activity
codes.
other customer
direct
Since LD48 0th represents
services
will be distributed
tallies
Other in proportion
costs
in several
part II, for details
or special
on all of the tallies
services,
associated
of the costs
BusReply,
subclasses
LD41,
LD42,
or special
key formation
with
the distribution
services,
LD48 Oth, LD48_SSv,
particular
keys are based
Please note that 83.4
from Attachment
are in cost pools which
in LD48 0th
4 cost pools.
of the distribution
with the cost pool.
in your excerpt
to OCA/USPS-T12-14
specific
however,
of
to the relevant
Function
Some of the above pools have associations
subclasses
with
labor in support
not-handling-mail
mixed-mail
Please see LR-H-146,
percent
activities,
to Bulk Nonprofit
and distributed
process.
States Postal Service Witness Degen
of Alliance of Nonprofit
Mailers
do a
1 to my response
have associations
specifically
LD49,
Manp,
1 BulkPr,
Mecparc,
and
1 SCAN.
c. I assume
tallies
that by “actual
with
tallies”
Bulk Nonprofit
above cost pools except
Other activity
to Bulk Nonprofit
the mixed-mail
distribution
distribution
keys.
tallies.
There are direct
codes associated
SPBS Prio, LD48 Exp, Registry,
For those four cost pools,
distributed
you mean direct
the presence
Other,
procedure
and 1SCAN.
of volume-variable
totaling
$214,000,
with all of the
costs
is the result
used in the formation
of the
of
Response of United
to Interrogatories
States Postal Service Witness Degen
of Alliance of Nonprofit
Mailers
ANMAJSPS-T12-4.
For Base Year 1996, what was total number of direct
IOCS ,tallies for Standard A Regular Rate (a) automation
and (b) presort
categories?
ANM/USPS-T12-4
The following
Resoonse.
table contains
Ca,tegory (activity
codes)
Standard (A) Regular
Automation
(X345)
Standard (A) Regular
Presort (X340)
Total
the requested
Number
information.
of Tallies
2,082
Number of Mail
Processing Tallies
(LIOCAlT
definition)
1,269
16,460
11,093
18,542
12,362
Response of United
to Interrogatories
States Postal Service Witness Degen
of Alliance of Nonprofit
Mailers
ANMIUSPS-T12-5.
For Base Year 1996, what was total number of direct
IOCS tallies for Standard A Nonprofit
(a) automation
and (b) presort
categories?
ANMIUSPS-T12-5
Response.
There are no IOCS activity
mail.
The requested
codes for Standard
information
(A) Nonprofit
for Standard
(A) Nonprofit
automation
presort
tallies
rate
is
in the table below.
Category (activity
codes)
Standard (A) Nonprofit
Presort (X350)
Number
of Tallies
4,483
Number of Mail
Processing Tallies
(LIOCAlT
definition)
3,033
Response of United
to Interrogatories
ANM/USPS-T12-6.
direct IOCS tallies
States Postal Service Witness Degen
of Alliance of Nonprofit
Mailers
For Base Year 1996, what was the total
for Standard A Regular Rate ECR mail?
number
of
ANM/USPS-T12-6
Response.
The requested information
is in the table below.
Number
of Tallies
6,344
Number of Mail
Processing Tallies
(LIOCATT definition)
1,986
Response of United
to Interrogatories
States Postal Service Witness Degen
of Alliance of Nonprofit
Mailers
ANM/USPS-T12-7.
direct IOCS tallies
For Base Year 1996, what was the total
for Standard A Nonprofit
ECR mail?
ANM/USPS-T12-7
Response.
The requested
Category
codes)
c
information
(activity
Standard (A) Nonprofit
ECR (.X330)
number
of
is in the table below.
Number
549
of Tallies
Number of Mail
Processing Tallies
(LIOCATT definition)
236
Response
of United States Postal Service Witness
to Interrogatories
of Advo, Inc.
(Redirected from Witness Takis)
Degen
ADVOIUSPS-T41-2.
Please refer to witness Takis’s workpapers,
Section
IV.A, page 1.
(a) For the facer/canceler
operation cost pool (‘CANCEL”),
do the volume
variable costs by subclass/category
shown on page 1 include allocations
of mixed-mail
and not-handling-mail
costs?
(b) For the facerlcanceler
operation cost pool, please provide the following
breakdowns
of volume variable costs, separately for each
subclass/category
shown on page 1 of Takis’s workpaper:
(1) Direct-item
costs excluding costs for counted mixed-mail
items;
(2) Counted mixed-mail
item costs:
(3) Uncounted
mixed-mail
item costs;
(4) Mixed-mail
identified
container costs;
(5) Mixed-mail
unidentified
container costs:
(6) Not-handling-mail
costs;
(7) Any other cost elements not included in l-6 above (please specify).
ADVO/USPS-T41-2
a. Yes.
Response.
The costs
workpapers,
variable
Section
costs
‘1 CancMPP”
constitutes
for the “CANCEL”
IV.A
from Table
cost pool.
a portion
descriptions
b. The requested
cost pool in witness
1, are identical
to the distributed
5 of my testimony,
USPS-T-12,
Please note that facer/canceler
of this cost pool;
of the associated
breakdown
Takis’s
see LR-H-146,
MODS operation
is provided
volumefor the
work
only
page l-19 for brief
numbers,
in Attachment
1 to this response.
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““I
answers
belief.
I, Carl G. Degen, declare under penalty of perjury that the foregoing
are true and correct to the best of my knowledge, information, and
Jl-/-$7
Date
CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoing document
participants
of record in this proceeding
in accordance
with section 12 of the Rules of
Practice.
9-i 1 ‘i,,,L
Eric P. Koetting
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-I 137
October ‘1, 1997
upon all