LxXXET SECTION
..,y;‘;:,..
BEFORE THE
POSTAL RATE COMMISSI
WASHINGTON,
D.C.
Postal Rate and Fee Changes,
1997
1,
;~,I~:--
_,; %
., i
‘* 3
.,~
*~~~~ ,_/;.~
“.
Docket No. R97-1
)
OFFICE OF THE CONSUMER ADVOCATE NOTICE OF THE
FILING OF ERRATA TO OCA-T-600, OCA 602, and OCA 603
TESTIMONY OF J. EDWARD SMITH, JR.
(February 13, 1998)
The Office of the Consumer
to OCA-T-600.
Testimony
Advocate
of J. Edward Smith, Jr. (revised pages attached),
Exhibits OCA 602 (revised pages attached)
The specific changes
hereby gives notice of the filing of Errata
and
and OCA 603 (revised palges attached).
are as follows.
OCA-T-600.
Page 16, line 8 Delete “capital and”
Page 27, line 13 Delete “I have previously
Page 27, line 14 Delete “proportionality”
pointed out that”
and insert “variability approaching
Page 28, Delete footnote 38 and substitute
approaching
100 percent between
“Such plots substantiate
in a pooled model.”
The electronic files are “Page16”
a variability
hours and TPH. “
Page 29, line 1 Delete “of a pooled nature.” Insert “approaching
as could be obtained
100 percent”
and “PG27-29”
100 percent variability,
Docket No. R97-1
2
EXHIBIT 602
Page 4. A new graph is substituted;
the previous one was inadvertently
a new one in logs has been substituted
to be consistent
not in logs, and
with the rest of the exhibit.
The
electronic file is rota-t602exh.
EXHIBIT 603
Page 2.
Delete “Graphs were chosen based on their appearances
purposes;
accordingly,
different mail handling locations were chosen across activities.“;
Page 2. Add the highlighted
effects regression
response
words in “a plot that is in good agreement
such as presented
to the Presiding
Officer’s
by but not endorsed
Information
Request
Page 2. Add “as found in POIR #4” in “Plot for IDNUM=242:
Effects as found
in
M”;
Consistent
with Pooled
Consistent
with Pooled
in POIR Sk”;
Consistent
with Pooled
in POIR W’;
Page 3. Add “as found in POIR#4” in “Plot for IDNUM=2375:
Effects as found
Bradley
in POIR #4.“;
Page 3. Add “as found in POIR #4” in “Plot for IDNUM=621:
Effects as found
with a pooled
by witness
Page 2. Add “as found in POIR #4” in “Plot for IDNUM=5255:
Effects as found
for illustrative
Consistent
in POIR W’;
Page 3 Delete “the logs of” in the last line;
Page 4. Delete “DATA ARE IN LOGS,” as found in the heading;
Page 5. Delete “DATA ARE IN LOGS,” as found in the heading;
Page 6 Delete “DATA ARE IN LOGS,” as found in the heading;
with Pooled
Docket No. R97-1
3
Page 7. Delete “DATA ARE IN LOGS,” as found in the heading;
Page 8. Delete “DATA AREIN LOGS,” as found in the heading;
Page 9. Delete “DATA ARE IN LOGS,” as found in the heading;
Page 10.
Delete “DATA ARE IN LOGS,” as found in the heading;
Page 11. Delete “DATA ARE IN LOGS,”
Page 12.
Delete
as found in the heading;
“DATA ARE IN LOGS,” as found in the heading;
Page 13. Delete “DATA ARE IN LOG FORM,” as found in the heading;
Page 14.
Delete “DATA ARE IN LOG FORM,” as found in the heading;
Page 15. Delete “DATA ARE IN LOG FORM,” as found in the heading;
Page 18. Delete “DATA ARE IN LOG FORM,” as found in the heading;
Page 17. Delete “DATA ARE IN LOG FORM,” as found in the heading;
Page 18. Delete “DATA ARE IN LOG FORM,” as found in the heading;
Page 19.
Delete “DATA ARE IN LOG FORM,” as found in the heading.
The electronic file is rota-t603exhs.
Respectfully
submitted,
‘Kenneth E. Richardson
Attorney
1
looking at essentially
2
short-run four week time frames he nevertheless
3
run considerations.
4
The reason that short-run/longer-run
5
cost incidence will be different, depending
6
run) one is attempting
7
processes
8
amounts of labor. However, the appropriate
9
volumes increase or decrease
10
11
12
13
14
15
16
17
18
19
20
21
measured.
“monthly” or, more precisely, four-week
to measure.
intermingles
Revised
February 13, 1998
periodsZ3 Given the
short-run
and longer-
issues are so important is that estimates
on which type of cost (short-run
It is generally recognized
will permit a slight increase or decrease
is the longer-run
cost-which
or longer-
that most production
with proportionately
mail processing
of
lower
cost to measure as
witness Bradley has not
Witness Bradley states that:
...economists define the long-run as a situation in which all inputs are
flexible and can be adjusted. The short-run would exist when any of
those inputs would not be perfectly adjusted.*4
In commenting
on the longer-run/short-run
issue, witness Bradley indicated:
I am informed that once an automated machine has been accepted
from the manufacturer, it will typically only take one or two accounting
periods to reach the minimum threshold for normal operations. *’
Based on witness Bradley’s comments,
mail processing
activities under consideration
it appears that the longer-run
is approximately
for the
a ‘year, given the
23There are thirteen time periods in a year, so data are close to, but not
exactly, monthly.
” Tr. 1115547.
*’ Tr. 1115356.
16
Revised
February 13. 1998
Question 3 or 4, where I produced
known as a pooled model.
econometric
results for what is
Econometric results for the pooled model give you a variability
of one, or in most cases a little bit greater than one, which could be
consistent with this plot. ”
The plots of the underlying
9
pooled approach
data tend to substantiate
the conclusion
that the
Compelling,
Leading
is correct
10
11
12
13
The data presented
14
variability approaching
15
to assess empirically
16
additional data analyses on the activities and facilities.
17
Flats, Manual Letters, OCR, and LSM. I first plotted the data on ai site specific
18
basis. This resulted in hundreds
19
IDNUM (site location) for each type of activity.
20
in exhibit OCA 603. All plots are presented
21
are three types of plots. The first type of plot substantiates
22
form in Diagram 1. This array of plots would be expected
23
specific facilities.
B.
The Actual Data Plots By Facility Also Are Visually
To A Pooled Regression
Model Conclusion
in exhibit OCA 602 are visually compelling
100 percent between
in (demonstrating
labor hours and mail volume.
witness Bradley’s selection of a regression
I chose the activities Manual
by an
A selection of the plots is presented
in library reference OCA-LR-9.
The second type of plot corresponds
27
In order
line, I performed
of plots, i.e., one for each locaticln denoted
37Tr. 1115581-82.
a
There
the A/B/C/D equation
in the short term for
to the line E in
Revised
February 13, 1998
1
Diagram 1. If witness Bradley’s theory were correct, this array of plots would not be
2
expected.3B Finally, some plots resemble a random “blob” of data. These “blob”
3
plots do not substantiate
4
Since I have plotted actual data rather than having computed
5
the conclusions
6
underlying
7
regressions
are visually compelling
but not precise.
data plotted on a site by site basis substantiate
regressions,
It is clear, however, that the
both fixed effects
and pooled regressions.40
Exhibit OCA 603 also includes plots denoted as IDNUM 9999 for each
6
9
either a fixed effects model or a pooled rnodel.39
activity.
IDNUM 9999 is not a specific location.
a summation
Rather, each point in IDNUM 9999
10
for a specific activity represents
11
data for a given location.
12
activity is representative
13
of all of the points together
14
sites for a given activity.
15
or above capacity, then total data for a site should be representative
16
operations
Accordingly,
of all of the logs of the hours and TPH
a point on the IDNUM 999!3 plot for a specific
of the total hours and total TPH at a given site. The plotting
is representative
Assuming
of hours as a function of TPH, across
that a specific facility may operate either below
of overall
at the site. The plot of the summed data shows that the expansion
path
38Such plots substantiate a variability approaching 100 percent between
hours and TPH.
3gA model can be forced through such plots, but such an exercise does not
necessarily establish a relationship.
40 In each case where I have summarized the form of a dat:a plot, I have used
informed judgment as to its shape.
28
1
for a specific activity appears to be approaching
2
obtained
3
relationship
4
one of the exogenous
5
relationship
in a pooled model.
In performing
Revised
February 13, 1998
100 percent variability, as could be
additional analysis of the hours/TPH
witness Bradley should consider the design capacity for each facility as
drivers of hours, examining the impact on the hours/lPH
as facility size changes.
29
OCA 602
Page 4 of 8
Revised
2113198
LSM; DATA IN LOGS
Plot of HRS*TF’H. Legend: A = 1 obs, B = 2 ohs, etc.
12.
CBA
BIZZZJ
lWZZZ1
FZZZZZ
GZZZZZD
czzzzzz
AVZZZZZD
xzzzzzc
HZZZZZZ
BZZZZZZ
AQZZZZZH
JZZZZZZ
BYZZZZZ
lZZZZZ
CMZZZZH
BKP.ZZZJ
BFWZZC
ABMHZA
CCHEDA
BCBB
AA BEB
D
AA
AA
A
IO"
8’
His,
A
0’
0
2
4
6
8
TPH
NOTE: 17382 obs hidden.
IO
12
14
OCA 603
Page2of19
Revised
2/l 3198
Each computer program run for an activity resulted in hundreds of
graphs--one
generated
for each of the sites. For each activity I present four of the graphs
by the computer
graphs generated
program.
I selected representative
graphs.
for an activity along with the relevant computer
this exhibit are presented
All
programs for
in OCA-LR-9.
For each of the four types of activities presented
for the selection of the four graphs is as follows.
in this exhiibit the basis
Three of the graphs for each
activity are for specific locations and illustrate that a variety of data1 patterns form
the underlying
data used in the study. The three types of plots by location
include,
a plot that is in good agreement
l
with a fixed effects regression.
a “blob” type of plot, indicating that for the location under consideration
there does not appear to be a clear data relationship; and
l
.
a plot that is in good agreement with a pooled effects retgression such
as presented by but not endorsed by witness Bradley in response to
the Presiding Officer’s Information Request #4.
A summary of the three types plots mentioned
above follows:
Manual Letters
Plot for IDNUM=8195:
Consistent
with Fixed Effects.
Plot for IDNUM=3361:
Consistent
with Blob.
Plot for IDNUM=242:
Consistent
with Pooled Effects as found in POIR#4.
Manual Flats
Plot for IDNUM=1374:
Consistent
with Fixed Effects.
Plot for IDNUM=3593:
Consistent
with Blob.
Plot for IDNUM=5255:
Consistent
with Pooled Effects as found in
POIR#kI.
OCA 603
Page3of19
Revised
2/l 3198
OCR
Plot for lDNUM=9961:
Consistent
with Fixed Effects.
Plot for IDNUM=2467:
Consistent
with Blob.
Plot for IDNUM=621:
Consistent
with Pooled Effects as found in POIR#4.
LSM
Plot for IDNUM=7346:
Consistent
with Fixed Effects.
Plot for IDNUM=4347:
Consistent
with Blob.
Plot for IDNUM=2375:
Consistent
with Pooled Effects as found
in POIR#4.
The fourth graph for each activity is designated
graph of this type has been printed for each activity.
location cited for IDNUM 9999.
per site-are
plotted in the graph of IDNUM 9999 are therefore
set of data.
Each point summarizes
of the logs of total hours of mail processing
a specific site. All of the data points-one
One
There is, however, no
Rather, IDNUM 9999 is a computed
The plot for IDNUM 9999 has a number of points.
summation
as IDNUM 9999.
the
labor and the total TPH at
then plotted.
The data
based on all of tlhe sites for a
specific activity data set, with hours and TPH summed for each sik
OCA 603
Page 4 of 19
Revised
2/l 3198
MANUAL LElTER OPERATIONS/ HOURS ON TPH
USING ONLY CONTINUOUS DATA FROM 8801-9613
INCLUDING OFFICES @ LEAST 39 OBSlLAG MODEL
Plotted by Site
__-__-___
-___- __________________
-__ IDN,,,t,,=242 ______________________
- ____________-____
Plot of HRS’TPH. Legend: A = 1 obs, B = 2 obs, etc.
HRS ,
25ObO ^
A
A
zoobo ^
A
A
A
A
AA
AAAAA B
AAABA ACAA A
AAB BBABA
B AACCBBAABB B
A BCAACADABAA AA AA
A AACCCAA A A
A AAAABBABA
A
15060^
IOObO .
5060 ^
0
‘^
0
2000
4000
6000
TPH
8000
10000
12000
14000
16000
OCA 603
Page5of19
Revised
2/l 3198
MANUAL LETTER OPERATIONS/ HOURS ON TPIH
USING ONLY CONTINUOUS DATA FROM 8801-9613
INCLUDING OFFICES @ LEAST 39 OBSJLAG MODEL
Plotted by Site
___________________________
- ____________
,,,N,,M=336,
Plot of HRS’TPH.
__________-_______-_-------~.------
Legend: A = 1 obs, B = 2 obs, etc.
HRS ,
140bo ^
A
120bo ^
A
A
AA A
1oobo ^
A
A
AA
BA
A
A
A
A
A
A
k%B
AAAA
AA
A
A A
8060 ^
AA
A
AA BA
A
AAA
A
6060 ^
40do ^
2060 -
0 '.
0
1000
2000
3000
TPH
4000
5000
6000
7000
8000
OCA 603
Page6of19
Revised
2/l 3198
MANUAL LETTER OPERATIONS/ HOURS ON TPH
USING ONLY CONTINUOUS DATA FROM 8801-9613
INCLUDING OFFICES @ LEAST 39 OWLAG MODEL
Plotted by Site
-_---
-__-
_--__
IDNUM=8195
Plot of HRS’TPH.
Legend: A = 1 obs, B = 2 obs, etc
HRS ,
100000 -
A
750bo ”
A
A
AAA
AB
A
A
A
AA
A
BBAAAAB
AABAAAA
B
EAAA C
AB AAA
ACB
A
AA
500bo _
A
A
A
DA
ABA
CAA
ADDB
BAE
ABBHC A
BA
250bo _
0’.
0
5000
10000
15000
TPH
20000
25000
30000
35000
40000
OCA 603
Page7of19
Revised
2113198
MANUAL LE-ITER OPERATIONS/ HOURS ON TPH
USING ONLY CONTINUOUS DATA FROM 8801-9613
INCLUDING OFFICES @ LEAST 39 OBSlLAG MODEL
Plotted by Site
______.__________________ -_-_-
_______ ,,,,,,,J,,=gggg
Plot of HRS’TPH.
_______________-_-
_____________..___--.
Legend: A = 1 obs, B = 2 obs, etc.
HRS ,
1750d000 A
1500d000 ^
A
125OdOOO ”
A
1 ooodooo ^
A
A
A
A
A
7500boo ^
A
A
AA AA
A
A
A AA
5000b00 ”
AAA
B A
AAAAA AC
AA9
BAA
ABABBAAB A
25OObOO ^
ACBCB A
AAFFBAA A
EFJDADAAA
: IZZPBBB
0 ^ CZTB
0
1000000
2000000
3000000
TPH
NOTE: 56 obs hidden.
4000000
5000000
6000000
8000000
OCA 603
Page8of19
Revised
2/l 3196
MANUAL FLAT OPERATIONS
USING ONLY CONTINUOUS DATA FROM 8801-9613
INCLUDING OFFICES @ LEAST 39 OBSllAG MODEL
Plotted by Site
_---____ - _________
-___I___-___-___ ,,,N,,M=,374
Plot of HRS’TPH.
_________- ____
- _____--__-__
- ____I
Legend: A = 1 obs, B = 2 obs, etc
HRS ,
1 oobo ^
A
A
8060 ^
AAAA
A A
B
AAAA
A
A AB
AA
A
A
A
A
AAAABAA
A
BBBC
B AADCBB
AAC ABDCDBBBA
A AABBABA
ACABBAA AAB
AAAAA
A
A
6060 ^
4060 ^
2060 ^
0 ‘^
0
1000
2000
3000
TPH
4000
5000
6000
OCA 603
Page 9 of 19
Revised
2/l 3198
MANUAL FLAT OPERATIONS/ HOURS ON TPH
USING ONLY CONTINUOUS DATA FROM 8801-9613
INCLUDING OFFICES @ LEAST 39 OBSllAG MODEL.
Plotted by Site
___________
---___-
I____- _________
- IDNlJM=3593
Plot of HRS’TPH.
____________________----.----..--------
Legend: A = 1 obs, B = 2 obs, etc
HRS ,
17go A
A
A AA
1560”
A
AA
A
AB
12go ^
A
lOdO”
AA
AAAA
ABAA A
AAA ACAA
AAAAAA
A
AA
A A
75b ^
AA
50b ^
A
25b ^
0’-
0
200
400
TPH
600
800
1000
OCA 603
PageR;v;f;;
2113198
MANUAL FLAT OPERATIONS/ HOURS ON TPH
USING ONLY CONTINUOUS DATA FROM 8801-9613
INCLUDING OFFICES @ LEAST 39 OBSlLAG MODEL.
Plotted by Location
IDNUM=5255 __________-__ __--------- - ..__-----__- ____________-________
- _____
- _______
Plot of HRS*TPH.
Legend: A = 1 obs. B = 2 obs. etc.
HRS ,
3560 ^
A
3060 ^
2560 ^
AA
A
A?
BA
A
AC
DBD
ABABA
AA A
ABA
AA
20do ^
1560 -
A
A
CCBAA
ABBAEBA
1060"
A
A
A
50b ^
0
'^
0
500
1000
1500
TPH
2000
2500
3000
OCA 603
Paae 11 of 19
- Revised
2/l 3198
MANUAL FLAT OPERATIONS/ HOURS ON TPH
USING ONLY CONTINUOUS DATA FROM 8801-9613
INCLUDING OFFICES @ LEAST 39 OBSILAG MODEL
Plotted by Location
_________________-_-
_______ - ___I___
Plot of HRS’TPH.
_____-_-_-
,,,N,,,,,,=gg99
______- _____- ________-_
Legend: A = 1 obs, B = 2 obs, etc.
HRS ,
.9oooboo A
A
A
6OOObOO^
A
A
4000b00 AA
BA
AAA
A;
A
AA AA
2000b00 ^
AAABA
AA
AAABAA
AAAA
A
AADAAABC A A
ABCBAAB
AA
: AAAHGIDB B
FTVPCC
0’. AZZTA
A
0
500000
1000000
TPH
NOTE: 48 obs hidden
A
1500000
2000000
2500000
3000000
OCA 603
Paga12of19
Revised
2/i 3198
OCR OPERATIONS/ HOURS ON TPH
USING ONLY CONTINUOUS DATA FROM 6601-9613
INCLUDING OFFICES @ LEAST 39 OBSlLAG MODEL
Plotted by Location
.-........-.
--_--___-_-__--_
,,,,,,,,,t,,=62,
Plot of HRS’TPH.
--
----_-
Legend: A = 1 obs. B = 2 obs, etc
HRS ,
7000 ^
A
A
A
A
AA
AA
A
AB
AA AB
A
A
AA
A
A
AAAAAA
A BBA
A
A AAAA
B
AA
A BAA
A”
B A
AA
AABB A
BACABA
AA4
AACCACAA
ABB
6060 ^
A
sod0 ^
4000 ^
3060 ”
A
C
AA
2060 ^
1060 ^
AAA
BA
A
O’- A
0
10000
20000
TPH
30000
40000
50000
OCA 603
Page13of19
Revised
2113198
OCR OPERATIONS/ HOURS ON TPH
USING ONLY CONTINUOUS DATA FROM 6601-9613
INCLUDING OFFICES @ LEAST 39 OBSlLAG MODEL
Plotted by Location
- ____
-___-__- _____
- _______________
,,,N,,,t,,=2467
Plot of HRS’TPH.
- __________
-_-__-___- _____.
- ______
-
Legend: A = 1 obs. B = 2 obs, etc.
HRS ,
2060 ^
A
A
A
A
AA
A
AA+?M A
1560 ^
AA E
AAtB
AA
A
AAA
AA
1060 ^
AA
A
A
AAA
AAAAA
AAB
A
A
A
0
A
A
A
50b ^
0'0
1000
2000
3000
TPH
4000
5000
6000
7000
OCA 603
Paae14of19
Revised
2/l 3198
OCR OPERATIONS/ HOURS ON TPH
USING ONLY CONTINUOUS DATA FROM 8801-981:~
INCLUDING OFFICES @ LEAST 39 OBWAG MODEL
Plotted by Location
_-___---_-_-
_____- __________I___-_
Plot of HRS’TPH.
,,,N,JM=g96,
_________________________--
____-_-
Legend: A = 1 obs, B = 2 obs, etc.
HRS,
2500
A
AA
A
BA
AAA
A
AAAA
AM
0
AA
A
A
A
A
AA
AA
A
AAA
A
A A ABhA
BA
A AAAAA
A
BAA
A
AABAA
AAABAAA
2060 ^
1560”
AA A
lodo-
50b ^
0
'"
0
2000
4000
8000
TPH
8000
10000
12000
14000
OCA 603
Page15of19
Revised
2/l 3196
OCR OPERATIONS/ HOURS ON TPH
USING ONLY CONTINUOUS DATA FROM 6601-9613
INCLUDING OFFICES @ LEAST 39 OBSllAG MODEL
Plotted by Location
IDNUM=9999
Plot of HRS’TPH.
-
--
_-.
Legend: A = 1 obs. B = 2 obs, etc.
HRS ,
1200000 -
A
1oooboo _
A
A
A
A
A
6OOdOO~
A”
BA
AAA
A
A
600dOO _
A
A
AA
AA
A A
BAB
A
ABA
B
AA
AA
AA
AA
AB AAA
A
400doo BAAA
A
AAC BAAB
B BAAA
A AC
AAA
AA
AAAA
AA
BABABA
200000 _
AAABABABBAB
CAACDA
A
DEBBC A
: AGGDKC
AJZKC
0’0
1000000
2000000
TPH
NOTE: 3 obs hidden.
3000000
4000000
5000000
OCA 603
Page16of19
Revised
2/l 3198
LSM OPERATIONS/ HOURS ON TPH
USING ONLY CONTINUOUS DATA FROM 8801-9613
INCLUDING OFFICES @ LEAST 39 OBSliAG MODEL.
Plotted by Location
____- _____- ___________
- _______
-_-_ IDN,J,,,=23,5
Plot of HRS*TPH.
____
--
_____________-_---.-- -------
Legend: A = 1 obs. B = 2 obs, etc
HRS ,
A
IOObO ^
A
A
AA
8060 ^
A/&PA
A
BA
Ahi
A
A
A
ABAA
6060 -
AC
A AAAAA
A
A
40cio A
A
A
A
2060 A
A
0'-
0
2500
5000
7500
10000
TPH
12500
15000
1.7500
OCA 603
Page 17of 19
Revised
211398
LSM OPERATIONS/ HOURS ON TPH
USING ONLY CONTINUOUS DATA FROM 8801-9613
INCLUDING OFFICES @ LEAST 39 OBSlLAG MODEL
Plotted by Location
---_-___-_____________
-___--__--I
,,,N,J,,,=&,,
Plot of HRS*TPH.
---
____.
-___- __________.__________
Legend: A = 1 obs, B = 2 obs, etc.
HRS ,
7060.
A
6OdO-
AA
50do^
ABA A
A
A
AB AiAA
A
ABA??
BAABAAA
A BA A
AB
A
A
AAAA
B
BA
A
40do-
3060.
2060"
A
1060 ^
0’-
0
2000
4000
TPH
6000
8000
10000
OCA 603
Page 18 of 19
Revised
2113198
LSM OPERATIONS/ HOURS ON TPH
USING ONLY CONTINUOUS DATA FROM 8801-9613
INCLUDING OFFICES @ LEAST 39 OBWIAG MODE,L
Plotted by Location
_-__________-___
-__- ________________
- ____
-,Df.,,J,,,=73~,6 ______________
Plot of HRS’TPH.
____-_-_____
Legend: A = 1 obs, B = 2 obs. etc
HRS
30000 *-
A
250bo ^
~?AA
AA
AAAABA
AAAAA
BAA0 A
AABABA
CBAAAA
A
AABAAA
AAAAA
A BAA
AAAAA
A
BDA
A00
0CA
AA
A
200bo ~
1sob0 -
ABA?4
c0
1oobo BC
A
A
50do^
0
'^
150000
5000
250 0
10000
TPH
30000
35000
OCA 603
Page19of19
Revised
2/13/98
LSM OPERATIONS/ HOURS ON TPH
USING ONLY CONTINUOUS DATA FROM 8801-981:3
INCLUDING OFFICES @ LEAST 39 OBWAG MODEL
Plotted by Location
-_-----____--_-_-- IDNUM=gggg -I_____ -___---__-_
Plot of HRS’TPH.
Legend: A = 1 obs, B = 2 ohs. etc
HRS ,
,
8OOObOO.
A
A
A
A
soooboo -
A
A
A
A
BA
A
4000600 ”
BAAAA%
BA
A
AAABAA
ACABA
A
ADAAAA
BAAAABA
2000b00 ^
AACBBBA A
B BAAEAAA
A CB
:
Gk%:
AZZMB
0’. H
0
2000000
6000000
4000000
TPH
NOTE: 18 obs hidden
8000000
10000000
12000000
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the foregoing
participants
of record in this proceeding
in accordance
upon all
with section 12 of the rules of
‘Kenneth E. Richardson
Attorney
Washington, D.C. 20268-0001
February 13,1998
document