BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
RECEIVC[I
Jl?u 3!1 I; 2,” fd ‘$3
I,:~;, ,,,
POSTAL RATE AND FEE CHANGES, 1997
Docket No. R97-1
[
UNITED STATES POSTAL SERVICE FOLLOW-UP
INTERROGATORIES
AND REQUESTS FOR PRODUCTION OF DOCUMENTS
MAGAZINE PUBLISHERS OF AMERICA WITNESS COHEN
(USPSIMPA-T2-20-23)
Pursuant to rules 25 and 26 of the Rules of Practice and Procedure
TO
and rule 2 of
the Special Rules of Practice, the United States Postal Service directs the following
interrogatories
and requests for production
America witness Cohen:
of documents to Magazine Publishers
USPSIMPA-T2-20-23
Respectfully
submitted,
UNITED STATES P0STA.L SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
Eric P. Koetting
475 L’Enfant Plaza West, SW.
Washington, D.C. 20260-I 137
(202) 268-2992; Fax -5402
January 30. 1998
of
POSTAL SE,RVlCE FOLLOW-UP
COHEN
USPSJMPA-T2-20.
spreadsheet
percent...
INTERROGATORIES
TO MPA WITNESS
Please refer to your response to USPSIMPA..T2-2,
USPS2b.xls
MPA-LR-3.
and to
In your response, you state that “40
of eligible item costs [were] counted.”
Spreadsheet
USPS2b,xls,
from which the 40 percent figure is derived, identifies $60.364 million in
“counted”
(a)
item costs and $91.381 million in “uncounted”
item costs.
Please confirm that the $91.381 million in uncounted
reported in spreadsheet
“uncounted”
flat trays.
item costs
USPS2b.xls includes $34.57 million in costs for
items not subject to counting, i.e., bundles, letter trays, and
If you do not confirm, please provide the figure(s) you believe
to be correct,
Also please provide the derivation of any such figure(s) in
electronic spreadsheet
format.
(b) Please confirm that excluding the $34.57 million in costs for
“uncounted”
not subject to counting yields 52 percent as the percentage
of eligible item costs counted according to spreadsheet
UlSPS2b.xls.
If
you do not confirm, please provide the figure(s) you believe to be
correct. Also please provide the derivation of any such figure(s) in
electronic spreadsheet
Cc)
format.
Please confirm that both the 40 and 52 percent figures exclude
the costs for items eligible for counting that were determined
identical mail.
to contain
If you do not confirm, please explain.
(d) Please provide total direct (identical plus counted) costs .for each item
type eligible for counting and cost pool, in an electronic spnsadsheet
format comparable
USPSJMPA-T2-21.
to spreadsheet
USPS2b.xls.
Please refer to your response to USPSIMPA-T2-9.
“strict association,”
do you mean that 100% of the mail inside ;a given sack
type would have to be of a single subclass?
USPSIMPA-T2-22.
By
Please explain.
Please refer to your responses to USPS/MPA.-T2-9
and
USPSIMPA-T2-10.
(a) Do you believe that an IOCS data collector can determine
sack contains identical mail or non-identical
sack?
whether a
mail without opening the
Please explain.
(b) Are the reasons you give that the contents of mixed sacks may be
different from the contents of identical sacks necessarily
uncounted
applicable to
sacks, for which it is not known whether the contents are
identical or non-identical
mail?
(c) For items subject to the Top Piece Rule, is there any reason why an
observation
of a mailer-prepared
item should be more likely to result in
a direct tally than a Postal Service-prepared
USPWMPA-T2-23.
item?
Please explain fully.
Please refer to your response to USPS/MPA.-T2-12
and to the table provided as Attachment
1 to this interrogatory.
(a) Please confirm that the table provides as Attachment
1 to this
part b,
interrogatory
DMA17.xls,
shows a breakdown
USPS-LR-H-305,
of the tally counts from spreadsheet
by the IOCS question 19 response.
do not confirm, please provide the breakdown
(b) Please confirm that the breakdown
If you
you believe to be correct,
of tallies by the question
19
response indicates that there are letter tallies for employees whose
sampled activity is FSM operations,
sampled activity is LSM operations.
and flat tallies for employees whose
If you do not confirm, please
explain.
(c) Please confirm that the observation
of flat-shape
of letter-shape
pieces at FSMs, and
pieces at LSMs, need not indicate that employees
not... clocked into the operation they are actually performing.”
not confirm, please explain how such “misclocking”
of mail observed in the employee’s
“are
If you do
would affect the mix
sampled activity from question 19.
Attachment 1
FY96 IOCS ClerWMailhandlsr
All Offlces
a19
qesponse
A
F9211
F9.211
F9211
F9211
F9211
F.9211
F9211
F9211
F9211
B
C
0
E
F
G
H
I
J
K
L
M
N-:
R
s
T
U
Tallies by IOCS Cl9 Response and Shape
line
.etters/Cds
Flats
Tally Count
IPPS
Parcels
Manual
A - Letter Case Distrib
B - Flat Case Distrib
C - Parcel Piece Distrib
D - CoWCancel MM Prs
E - Presort Mail Units
F I Opening Units
G - Pouch/Rack Units
H - Platform Units
I - Other Manual
Total Manual
21,395
116
63
396
294
1,167
609
407
2,802
27,251
422
8,601
412
118
112
939
1,126
450
1,432
13,612
57
54
517
27
6
192
569
67
215
1,704
24
133
2,090
29
10
278
776
232
562
4,154
OCR
Mail Proc BCWBCS
Delivery BCWBCS
Carrier Sequence BCS
MPLSM/SPLSM
Letter Facer/Canceler
Flat Facer/Canceler
Sack Sorting Machine
Parcel Sorting Machine
Flat Sorting Machine
Small Parcel & Bundle
NM0 Machine
Multislide
ACDCS
Central Banding
Culling Machine
Remote Barcoding Mac
Transport Equipment
All Other
Blank
2,596
3,527
2.680
421
8,217
003
32
155
28
82
405
31
70
80
171
153
16
79
461
3,266
16
28
6
4
135
23
259
251
177
6,020
965
16
107
45
50
61
6
189
353
1,525
0
5
0
0
8
2
0
42
305
20
441
4
27
25
2
10
2
22
91
126
1
4
0
0
0
2
5
161
1,269
31
462
07
121
106
7
13
10
68
312
50,540
23,846
2,836
Grand Total
2,592
3,409
2,155
404
3,594
732
261
1,356
1,992
4,302
3,460
222
057
1,198
552
346
149
6,563
5,806
5,205
6,973
4.849
a29
11,954
1,562
557
1,965
3,771
10,455
5,733
360
1,182
1,462
782
583
la3
6,941
7,023
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.
ty f&L
Eric P. Koetting
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-I 137
January 30, 1998
upon all