RECEIVE11 USPS-T-20 JAN12 305PM’00 BEFORE THE POSTAL RATE COMMISSION WASHINGTON, D.C. 20268-0001 Postal Rate and Fee Changes, 2000 TESTIMONY OF DENNIS P. STEVENS ON BEHALF OF THE UNITED STATES POSTAL SERVICE Docket No. R2000-1 1 .- TABLE OF CONTENTS 2 3 AUTOBIOGRAPHICAL SKETCH 4 5 I. PURPOSE AND SCOPE 6 II. BACKGROUND 7 A. Discussion of VMF Operations 8 B. VMAS Database 9 C. Motor Vehicle Service (MVS) 10 1. Maintenance 11 2. Parts & Supplies 12 3. Vehicle Hire 13 4. Vehicle Depreciation 14 Ill. Labor REVIEW OF BASE YEAR 1996 COST DEVELOPMENT 15 A. History of MVS Cost Analysis 16 B. CRA Structure 17 C. Development 18 D. Base Year 1996 Costs 19 IV. DEVELOPMENT of Costs OF BASE YEAR 1998 COSTS 20 A. Construction 21 B. Changes to CRA Structure 22 C. Calculation 23 D. Base Year 1998 Results 24 V. of Base Year 1998 Costs CONCLUSIONS 25 A. Comparison 26 B. Methodology 27 of Cost Pools of Base Year 1998 and Base Year 1996 Methodologies Refinements 1 AUTOBIOGRAPHICAL 1 - SKETCH My name is Dennis P. Stevens and I am an economist with the Postal Service. 2 3 have been in postal costing since 1989 and have been a contributor 4 of postal costs as presented 5 R90-1 and subsequent 6 present position in the Postal Service, I worked in mail processing 7 supervisor. 8 finance industries to a stint as an Army pilot. in testimony and supporting rate cases. My non-postal Virginia Commonwealth 11 a MS in Business with concentrations 12 of the National Achievement 14 Scholarship. University. ranges from management I have a BS in Economics in Economics Scholarship, I was awarded membership University for academic achievement I am thoroughly 15 in Docket No. operations as a in the retail and studies at Harvard University and graduate work at 10 -~ 13 documentation I joined the Postal service in 1983. Prior to my experience I did my undergraduate 9 in the development (minor Mathematics) and Finance. I am a former winner the Angier B. Duke Scholarship several years in the Delivery function. 17 methodologies 18 development and a member of the Dean’s List. 19 broad range of experience 20 insight. in the last In the R97-1 case I assisted in the new presented for CS 8, CS 9, and CS 3. In R90-I, of library references and Harvard in the Phi Kappa Phi Honors Society versed in all aspects of postal costing, concentrating 16 and and testimonies I assisted in the relating to CS 15 and CS 16. My has allowed me to view postal economics with special I 2 1 I. 2 PURPOSE AND SCOPE My testimony details the proposed Postal Service methodological changes to the 3 development 4 20.2, respectively. 5 presents the new calculation 6 relied on statistical surveys of vehicle usage to determine the disaggregation 7 accrued costs for CS 12 and CS 20.2 into six cost pools (or subcomponents). 8 variabilities 9 and mail class distributions of motor vehicle service costs and vehicle depreciation The testimony and distribution provides the rationale for these changes and of these components. of the users of the vehicles. the vehicle use were determined 11 accrued costs for vehicle maintenance 12 costs. 13 variability and distribution 14 Previously, the Postal Service had Volume For instance, if 20 percent of to be caused by rural carriers, then 20 percent of the would be assumed burdened 20 percent of vehicle maintenance on rural carrier costs would adopt the volume key for rural carriers. The Postal Service’s new approach is to derive the subcomponent 15 total accrued costs using the Vehicle Management 16 compiles vehicle acquisition 17 from all vehicle maintenance 18 can be derived directly from the universe of billings, eliminating 19 survey. 20 1992. It is the Postal Service’s position that the VMAS database, 21 provides a more accurate measure of MVS maintenance 22 of total keys of the pools were adopted from the volume variabilities IO Consequently, - CS 12 and CS and maintenance facilities. Accounting share of the System (VMAS). cost data emanated VMAS from local records Using VMAS, the subcomponent user shares the need for a statistical Moreover, the last data survey used to develop MVS costs was completed There are no workpapers or library references 23 Instead the results of my analysis are incorporated 24 workpapers, as indicated in this testimony. in updated every AP, costs and depreciation. directly relating to my testimony. into Witness Meehan’s base year 3 1 -2 ,- II. BACKGROUND A. A Discussion of VMF Operations 3 The USPS operates a fleet of over 200,000 owned vehicles. An additional 4 number of vehicles are leased or hired by the USPS. A number of Vehicle Maintenance 5 Facilities (VMFs) are established 6 manage the vehicle inventory in its assigned area. The VMFs also have the 7 responsibility to report data concerning 8 procurement of repair parts, the buying, storing, and issuing of petroleum 9 the oversight of auxiliary garages. around the country. Each has a responsibility the assigned vehicles, the management The Vehicle Management to and products, and Accounting System IO (VMAS) supports these responsibilities. 11 in the discharging 12 of different locations. 13 owned and leased (hired) vehicles. 14 on USPS-owned 15 commercial 16 the operation of the maintenance 17 issue fuel, tires, and repair parts. VMFs also manage employee work hours, scheduled 18 maintenance, 19 of their responsibilities, The VMFs carry out a wide range of functions often supporting vehicles located at a number The VMFs collect and record data on vehicle usage for both They perform and record all types of maintenance vehicles and record the maintenance (non-postal) sources. on owned vehicles performed by The VMFs manage warranty programs. To support of vehicles, the VMFs procure, store, manage, and and collect financial data. Each vehicle owned by the Postal Service has a specific function. For instance 20 every city carrier motorized regular route has a designated vehicle. When a new route is 21 authorized, the VMF begins the process to acquire a vehicle for the route. A formal 22 request is made for the new vehicle that lists the type of vehicle and its planned function 23 (use). ATTACHMENT '-‘?4 25 acquired. 1 shows the lists of functions for which new vehicles may be Postal headquarters performs the authorization and purchase (or transfer). Once the vehicle is delivered to the requesting VMF, the acquisition costs are charged to 4 1 the receiving site. An account is set up in VMAS. 2 and the vehicle ID number form the basis for the record. This record remains in VMAS as 3 long as the vehicle is in service. The records are updated every AP. If the function of the 4 vehicle changes, for instance, from a city carrier vehicle to a rural carrier vehicle, then the 5 VMF manager would make that change to the record. The budgets for the VMFs are 6 monitored and controlled from the Area Oftices. Critical elements are vehicle use and 7 operating costs. When the vehicle requires servicing, all parts or maintenance work that is 8 needed on the vehicle becomes part of the vehicle record. 9 ATACHMENT Depreciation dollars, the function code, 2 (Page 1 and Page 2), PS Form 4543 front and back, respectively, IO shows the work order form that is used to record maintenance 11 purchased for the vehicle. The form links the employee number (social security number of 12 the employee) which is tied to the employee’s wage and the number of hours that the 13 employee has worked on the vehicle to the vehicles’ history. The data from these forms 14 are inputted into the VMAS database each AP. Therefore, for any and all vehicles in the 15 system, data can be assembled that provide by AP the number and type of vehicles in 16 inventory; what functions those vehicles are assigned; and the vehicles operating 17 expenses. 18 vehicle or aggregated to either VMF or national totals. The VMFs are charged with having 19 a ready source of vehicles and are required to operate their facilities in an efficient and 20 effective manner. Maintenance, parts and supplies and depreciation performed or parts costs are available by 21 22 23 B. VMAS Data Base The Vehicle Management 24 computer-based 25 within the Postal Service. Accounting support for the management System (VMAS) provides improved and reporting of vehicle maintenance This includes the collection, processing, storing, presentation, ---Y 5 I- - 1 and communication of related vehicle maintenance 2 user system operating 3 stations consist of personal computers 4 server with a Windows NT operating 5 network environment. data. VMAS is a client server, multi- primarily at VMFs and selected auxiliary garages. The work operating 1. 7 user interface features. 8 2. 9 information. into a system operating under the USPS “Gold Tape” The following summarizes 6 under Windows 95 networked the major capabilities within VMAS:l Allow VMAS navigation through the use of standard Windows graphical Provide and control various levels of access to VMAS actions and IO 3. Manage Vehicle Information. 11 4. Manage Parts Information. 12 1. Manage Employee 13 2. Manage Fuel/Oil Information. 14 3. Manage Reference Information. Information. 15 Previous to this case VMAS was the source of the Make Model Report that was used to 16 apportion vehicle usage to drivers /users, 17 18 19 - C. Motor Vehicle As indicated Service in the Summarv Descriotion of USPS Develooment 20 Seaments and Comoonents, 21 related costs of vehicle maintenance 22 used in maintaining 23 maintenance 24 postal operations facilities are maintained at vehicle maintenance CS 12, Motor Vehicle Service covers salaries, benefits, and personnel work; expenses for supplies and services vehicles; expenses for fuel and lubricants; expenses services; 1 VMAS Training Guide of Costs by and expenses for rented vehicles. Vehicles for contracted assigned to larger facilities (VMFs) that are 6 Vehicles assigned to outlying stations and 1 under the control of local postal management. 2 branches of those operations 3 contracts with local businesses. 4 (NPOs) service vehicles assigned to smaller oftices that do not have VMFs. 5 facilities may obtain routine maintenance Contractors at offices known as non-personnel costs are to delivered 7 variability 8 determination 9 on the assumption that vehicle maintenance mail volumes. and the distribution Consequently, key of the drivers MVS costs adopt the volume or users of the vehicles. is dependent on vehicle use - miles driven or hours of operation. 11 miles driven by users provided the basis to apportion 12 drivers. Previous postal statistical surveys that showed vehicle use by hours or 1. Maintenance total national vehicle use to the Labor The maintenance activities in this segment involve tuning, lubricating, 15 washing, repairing, and fueling fleet vehicles (including experimental 16 by postal employees including city delivery carriers, special delivery messengers, 17 vehicle service drivers, the Postal Inspection Service, postmasters, 18 administrative 19 subcomponent 20 The of the share of CS 12 costs between the users of the vehicles is predicated IO 14 offices I assume that MVS costs are related to mail volume in the same way that street 6 13 services through employees. vehicles) used managers, and Statistical surveys supported the classification of six categories based on vehicle usage: Citv Delivery Vehicles - Letter Routes. These vehicles are used on carrier 21 motorized routes such as park and loop routes, curbline routes and business and 22 mixed motorized routes. Vehicle maintenance 23 correspondence 24 elemental load, and coverage-related 25 use associated with these components. costs are apportioned with city delivery carrier components in (office, route, access, load) on the basis of the portion of vehicle These apportioned vehicle maintenance 7 1 corresponding -2 3 individual components in Cost Segments 6 and 7. Citv Deliverv Vehicles - SDecial-Pumose Routes. These vehicles are 4 used on parcel relay, parcel delivery, collection, and other support-type 5 Costs are classified as variable to the same degree as the special purpose route 6 costs of city delivery carriers. 7 Rural Deliverv Vehicles. routes. These vehicles are used on both “evaluated” and 8 “other” rural routes. Costs are classified as variable to the same degree as mral 9 carrier salary costs. 2 IO SDecial Deliverv Vehicles. Costs for these vehicles, which are used on 11 special delivery routes, are classified as variable to the same degree as special 12 delivery messenger street time costs. -13 Vehicle Service Vehicles. These vehicles are used on routes within a city 14 and between various postal facilities including post offices, stations, branches, 15 Processing and Distribution Centers/Facilities, 16 Mail Centers. 17 service driver costs.3 18 C costs are classified as variable to the same degree as the costs of the Air Mail Centers/Facilities, and Bulk Costs are classified as variable to the same degree as vehicle Other Vehicles. These vehicles are used for administrative 19 management 20 inspectors, Postal Inspection Service personnel, postmasters, 21 administrative and work by various categories of employees including the carrier route employees. managers, and other Because the number and use of these vehicles are 2 Separate street time costs for rural carriers are not available. 3 Separate street time costs for vehicle service drivers are not available. 8 1 determined by requirements 2 classified as institutional. 3 2. 4 of management, the costs of this subwmponent Parts & Supplies The costs in this component are for parts, supplies, and services used in 5 vehicle maintenance work performed by motor vehicle service personnel as 6 described for maintenance 7 costs for analysis into six subwmponents 8 3. 9 are Vehicle labor. The classification of costs and the grouping of are the same as for personnel costs. Hire The costs covered by component 12.3 are for rental of privately-owned and IO GSA vehicles and exclude equipment maintenance 11 delivery messengers and rural carriers for use of their vehicles. 12 rented vehicles, used to supplement Postal Service owned vehicles for which 13 maintenance 14 dependent 15 volume consistent with total employee time. Therefore, both office and street time 16 of the employees that use them were used to develop volume variability and mail 17 distribution keys for vehicle hire. Based on the statistical surveys only four of the 18 subcomponent 19 hire for rural carriers and for city carriers on special purpose routes were 20 inconsequential; 21 costs are covered by components allowances paid to special The costs for these 12.1 and 12.2, were assumed upon the number of employees using them and thus were related to categories used for vehicle maintenance were significant. Vehicle therefore those hires were included in other vehicles. Citv Deliverv Vehicles - Letter Routes. Costs are apportioned to city delivery carrier components among 22 delivery functions corresponding in Cost 23 Segments 6 and 7 (office, route, access, elemental load, and coverage-related 24 load) on the basis of the costs of those individual components 25 routes. These apportioned on motorized letter costs are separately classified as variable to the same 9 1 -2 degree as the costs of the corresponding individual components in Cost Segments 6 and 7. SDecial Delivetv Vehicles. 3 4 degree as special delivery messenger salary costs. Vehicle Service Vehicles. 5 6 8 institutional. 9 4. Vehicle The costs of this subcomponent are classified as Depreciation For motor vehicle depreciation 11 methodology 12 relying on the relationship costs, CS 20.2, I use the same to determine volume variable costs and distribution function) of the vehicles. -13 Costs are classified as variable to the same degree as vehicle service driver costs. Other Vehicles. IO Costs are classified as variable to the same keys, i.e., between mail volume and the users (underlying For vehicle depreciation five subcomponents are 14 considered: city carrier vehicles, rural carrier vehicles, special delivery 15 messenger vehicles (expedited delivery), vehicle service drivers vehicles, and 16 other (administrative) 17 vehicles. IO 1 Ill. REVIEW OF BASE YEAR 1996 COSTS 2 A. History 3 of MVS Cost Analysis The base year 1996 (BY96) development of MVS costs was the result of a 4 succession 5 regarded as partly volume variable because of its link to city carrier activities in the 6 R76-1 rate filing. City carrier costing was developed on a functional 7 analysis recognized 8 vehicles and that it was (and still is) customary for each motorized 9 individually of refinements that were incorporated into the analysis since CS-12 was first basis. Part of the that city delivery carriers were the main users of postal-owned route to be assigned a vehicle to be used exclusively for that route. Thus the operating IO cost for a motorized city delivery route inherently includes a direct vehicle cost as well 11 as a direct labor cost and both costs can be treated identically with regard to variability 12 analysis. 13 institutional 14 proportionately 15 vehicle expenses 16 for a motorized 17 labor cost components. 18 classes of mail for each labor cost component. 19 In other words, the total cost (consisting components) burdened of both volume variable and of a motorized route effectively consists of the carrier cost by the vehicle cost. If carrier wages amount to $50,000 and amount to $5,000, then the volume variable portion of vehicle costs route can be estimated as ten percent of each of the volume variable As such, the volume variable vehicle costs can be distributed It should be noted that this treatment to results in a vehicle cost burden on carrier 20 office costs as well as on carrier street costs, essentially reflecting the fact that the 21 vehicle belongs to the carrier even when it is not actually in use. 22 total system level, the number of carrier vehicles, and hence the aggregate 23 varies identically with the number of motorized carrier routes - the so-called “system 24 variability”. 25 allocating the portion of total CS-12 cost associated Accordingly, at the vehicle cost, In the original R76-1 tiling, this identical variability was approximated by with city carrier vehicles among the ? 11 ,- 1 five types of motorized 2 these route types. 3 estimated from available accounting 4 p The portion of CS-12 costs associated The R76-1 treatment with city delivery vehicles was data. as just outlined effectively dealt with the volume variable 5 costs of city carrier vehicles, by far the majority of CS-12 costs. 6 filings, similar treatments 7 vehicles used for special delivery messengers, 8 routes, and for vehicle driver routes. 9 functions were treated similarly to the costs of postal-owned were applied to other postal-owned In subsequent rate vehicles: specifically, for collection and other special purpose In addition, the costs for vehicles leased for these vehicles. In each instance, IO vehicle costs were considered 11 costs of the corresponding 12 the burden method. 13 functions were regarded as institutional. 14 12 costs were distributed among the different types of vehicles, and the types of 15 vehicles were distributed among the operating functions (city carriers, rural carriers, 16 etc.). These distributions were based on two reporting systems: the Make-Model 17 Report and the Form 811 Survey (see below). 18 - routes in proportion to the total carrier cost ascribed to each of as volume variable as the volume variable direct labor operating functions. This procedure Costs for vehicles dedicated to managerial has become known as and administrative To determine the appropriate In the R90-1 rates filing, Witness Barker proposed a refinement cost pools, CS- of the city carrier 19 vehicle cost treatment that took acwunt of the differing amounts of use of vehicles 20 among business and residential 21 relied on available data (from the 1986 STS survey) to show, for example, that vehicles 22 were being driven 80 percent of the time on curbline routes and 28 percent of the time 23 on loop routes. 24 direct proportion to the amount of use. The Commission 25 which remains in the existing BY96 workpapers. and loop and curbline route types. He then allocated their operating Witness Barker costs (but not their depreciation) adopted this methodology, A set of vehicle-use factors is in 12 1 developed for this purpose in the CS-7 workpapers 2 used in CS-12 to determine the proportion 3 variable for the carrier components. However, the BY96 workpapers 4 use allocation to vehicle depreciation as well as to vehicle operating 5 allocation is an apparently 6 R90-1 refinement 7 delivery. 9 the operations of vehicle costs to be treated as volume result of a workpaper apply the vehicle This costs. error. Witness Barker’s Report provides summary statistics derived from a census of and maintenance of all postal-owned vehicles. It currently relies on the IO VMAS, an ongoing and largely automated 11 Form 811 system, now discontinued, 12 type of postal owned vehicle with respect to the various operating functions of concern. 13 Given the data from these two sources, allocating costs among operating 14 a two-step process: first determine 15 determine reporting system embracing all VMFs. The provided statistics on the hours of use of each functions was costs for the different vehicle types, and then how the various vehicle types were used. 16 17 18 B. -, did not affect the costs of vehicles used for functions other than city The Make-Model 8 unintentional and the values of these factors are CRA Structure BY 1996 CRA workpapers cover the costs associated 19 Services (MVS) in CS-12 and CS-20. 20 Vehicle Maintenance 21 for maintenance 22 offices), the depreciation 23 VMF operating 24 materials, and overheads, 25 maintenance MVS costs arise from the operation Facilities (VMS’s) operated services performed with USPS Motor Vehicle by the Postal Service, the expenses under commercial contracts (so-called NPO of postal owned vehicles, and the expenses costs., considered of certain in terms of postal employee for vehicle hire. labor, supplies and are treated in CS-12 together with the other vehicle and vehicle hire contract expenses. Vehicle depreciation is treated along - 13 1 with other capital expenses 2 expenses, the present development 3 Personnel, comprising 4 includes contract services; Vehicle Hire; and Capital, comprising 5 and interest expenses. 6 initially developed 7 they are eventually a accounts and labor sub-accounts. in (X-20. Reflecting these several distinct sources of incorporates four major cost components: VMF direct labor and supervision; Supplies and Materials, which vehicle depreciation In common with other cost segments, while CS-12 costs are with regard to operating expenses and related information reconciled of record, on an FY basis with the pertinent USPS expense 9 10 11 C. Development Citv Carrier of Costs for BY 1996 Deliverv Vehicles: Delivery by city carriers uses virtually all types of 12 vehicles. 13 purpose routes. 14 and 90 percent of NPO costs, while special purpose routes account for about 6 percent 15 in each case. Vehicle cost distributions 16 volume variability analysis in CS-7 for carrier labor costs, as specially modified to reflect 17 the time usage of vehicles in motorized delivery operations. ia Cost pools are formed for these vehicles for (1) letter routes and (2) special For BY96, letter routes account for almost 70 percent of VMF costs are based on the distributions established 4 Time usage of vehicles for letter route delivery is found from the functional 19 proportions 20 of the CS-7 workpapers. 21 special purpose routes the proportion 22 associated 23 assumed as 100 percent for travel time. by (STS) in w/s 7.0.4 and, for special purpose routes, from survey results in w/s 7.0.5 This provides for each of five motorized letter routes and for with the functional of driving activity (as distinct from all other) components route time and access time. The usage is For letter routes the accrued cost associated * 4 The time-usage basis for allocating vehicle maintenance costs was originated by Postal Service witness Barker and accepted by the Commission in Docket No. R90-1. 14 1 with each of these components 2 0.24 for loop routes) to obtain a representative 3 time and access time and, independently, 4 considered 5 time, a vector can be developed 6 the five route types. 7 to produce a vector of “final vehicle proportions” a w/s 7.0.4.3): is multiplied by the appropriate time usage factor (e.g., vehicle use cost corresponding to route for travel time. As travel time cost is a burden on all other accrued carrier costs, including load time and office representing the accrued time usage costs for each of The five vectors are added across route types and then normalized (see R97-1, USPS-T-20, Workpapers, 9 IO Final Vehicle Proportions Total Motor (see below) 11 12 Access 0.3821 0.2200 13 Route 0.4967 0.2742 14 Load 0.0374 0.1566 15 Offlce 0.0838 0.3492 16 Total 1 .oooo 1 .oooo 17 ia To distribute costs associated with vehicles used on letter routes, a single 19 distribution vector (identified herein as the “vlr” vector) is constructed 20 Final Vehicle Proportions 21 time, route time, load time, and office time. 22 developed 23 and total motor routes (see R97-I, 24 special purpose routes vector is used to develop a distribution 25 on special purpose routes; the total motor routes vector is used to develop a distribution separately respectively by applying the to the existing (CS-7) cost distributions for access Similar vectors of vehicle proportions are for letter motor routes, letter foot routes, special purpose routes, USPS-T-20, W/S 7.0.4.3 and W/S 12.0.3). The vector for vehicles used 15 - 1 vector 2 vector is used to develop the distribution 3 - In the BY 1996 USPS treatment, of costs for carfare and driveout agreements. as already indicated, the vlr vector is used to 4 distribute the cost pools associated 5 vehicle depreciation. 6 vector that is similarly developed 7 “total motor” vector shown above. a proportions 9 volume variable costs is much lower for the vehicle use distribution with VMF personnel, supplies and materials, and In contrast, vehicle hire costs are distributed with the vhr vector, a from CS-7 carrier cost distributions but based on the Because the vlr vector reflects much smaller of office and load costs than the vhr vector, the resulting proportion of This effect can be seen in the BY96 Segments than for the vehicle 10 hire distribution. 11 report (page 36) and in my TABLE 1: volume variable costs are about 20 percent of 12 total for VMF personnel 13 the total for vehicle hire costs. 14 understates 15 of vehicles for carriers, including both letter routes and special purpose routes, together 16 with vehicle costs for messengers 17 components ia this same figure applies to VMF personnel 19 (component 20 P (identified herein as the “vhr” vector) for vehicle hire costs. The letter foot routes and Components costs and supplies and materials costs but about 45 percent of the difference Indeed, the 20 percent variability substantially in these distributions and drivers. because it reflects the combined costs Examining the relevant CPA shows that the vehicle cost variability for carriers is less than 20 percent; 96) and depreciation (component (component 67) supplies and materials 226). With regard to the existing treatment of other vehicle-dependent 21 volume variability of VMF costs associated 22 percent, that for drivers (component 23 directly from the corresponding 24 drivers (in CS-6). 25 development with messengers 545) is 60 percent. (component 66) is 47 Both these figures derive labor cost variabilities for messengers In these cases, there is no consideration of VMF costs. activities, the (in CS-9) and of time usage in the 16 1 We have used volume variabilities to indicate differences in distributed 2 the components 3 respect to the costs allocated to particular mail classes, as may be appreciated 4 considering 5 costs as two of the constituents 6 cost distribution) the differences Vehicle 7 in the interests of simplicity. The differences in class of mail distributions are also substantial with -. by between oftice costs and route of the vlr vector (reflecting about 6 percent of the office and the vhr vector (reflecting about 35 percent). Demeciation: As noted above, city carrier vehicle depreciation a CS-20) in the BY96 were distributed 9 usage, for both letter routes and special purpose routes. on the vlr vector and therefore however, ” . . . the city-carriers 11 depreciation, 12 carrier carfare expenses 13 depreciation 14 is not supported 15 of recent workpaper 16 correct) distribution 17 the logic that the number of vehicles, and hence their depreciation ia same way as the number of vehicle route carriers. 19 reflect the total system variability. delivery routes distribution costs (in reflect vehicle time The R90-1 testimony stated, 10 20 costs for developed for vehicle hire, and interest [i.e., the vector vhr noted above] is also used to distribute city in Cost Segment 13.” This change in distribution of vehicle costs from the defining R90-1 testimony (vhr) to the BY96 (vlr) workpapers by testimony and appears to be the unintended (and erroneous) The original (and changes made to BY96 for other purposes. of depreciation costs on the basis of the vhr vector corresponds carrier comprises the cost for equipment 22 carriers 23 vehicle depreciation 24 and its cost distribution 25 the burden treatment. to costs, varies in the In other words, depreciation Another way of looking at this is to see that the operating 21 result costs cost of a motorized in addition to the direct labor cost. Thus if the annual pay is $40,000 and the annual vehicle depreciation is $4,000, the can be calculated as a ten percent burden on the carrier labor cost is the same as the carrier labor cost distribution consistent with -. 17 1 Base Year 1996 Costs D. ,F~ Volume Variable costs for BY 1996 are shown below in TABLE 1. 2 3 TABLE 1 4 cs Volume Variable OTHER TOTAL COSTS Percent Vehicle Hire Percent Total CS 12 Maintenance Percent parts & Supplies Percent $51,466,000 19% $57,712,000 19% $12,031.000 45% $121,209,000 20% $220,078,000 61% $271,544,000 100% $245346.000 $303,058.000 81% 100% $14,800,000 $26,831,000 55% 100% .$480.224,000 $601,433.000 80% 100% ia 1 IV. DEVELOPMENT 2 A. Construction 3 OF BASE YEAR 1996 COSTS of Cost Pools A causal connection is necessary for determining volume variable costs. 4 connection 5 function and the vehicles are not bundled with the service itself as with purchased 6 transportation. 7 the functions that rely on postal-owned a vehicle service, rural delivery, and certain management 9 to disaggregate Such a clearly exists where vehicles are necessary to perform a postal operating There is thus a causal basis for attributing CS-12 costs on the basis of or leased vehicles: city delivery, special delivery, CS-12 costs in accordance activities. It is thus necessary with the relative amounts associated with 10 each of these functions. 11 in accordance with functional 12 separations. The VMAS function codes provide a ready basis for this disaggregation 13 and can effectively replace the existing two-step allocation process that uses the 14 Make/Model 15 most of the conceptual 16 carrier vehicles, both because this function accounts for most of the CS-12 total, and 17 because the detail afforded to allocating carrier labor costs provides both a basis and a ia rationale for a corresponding As stated earlier, the VMAS provides costs and operating (user/driver) Report and Form 611 results. separations as well as with make-model Once the CS-12 costs are disaggregated, issues arise in considering the proper treatment of costs for city detail in the CS-12 treatment. 19 20 21 B. Changes to CRA Structure ATTACHMENT 22 Make/Model 23 subcomponents. data 3 shows the output of the VMAS database Report as the basis for the apportionment that replaces the of CS 12 and CS 20.2 into These changes were made to the calculation of MVS and vehicle 19 ,- 1 depreciation 2 workpapers. 3 1. as shown in Witness Meehan’s (USPS-T-l The Make/Model functions or subcomponents. 5 disaggregation 6 costs, maintenance 7 delivery and vehicle service driver costs. 2. 9 1) base year Report was not used to apportion the components 4 a - spreadsheets, of maintenance Instead ATTACHMENT 4 shows the and vehicle dollars into functions: other costs, city carrier costs, rural carrier costs, expedited Office costs for city carriers were eliminated subcomponent. into as a function or Nothing from my examination of MVS and vehicle IO depreciation 11 underlying 12 though our analyses for rural carriers and vehicle service drivers do not 13 allow us to exclude office time, it is nonetheless 14 correct in city carriers to exclude office time where we have identified 15 those costs separately. 16 3. leads to any justification for the inclusion of office time as an cause of volume variable costs for these components. The disaggregation preferable Even and more of parts and supplies and vehicle hire rely on the 17 maintenance ia analysis but is not our best treatment for these costs. 19 limitations on our ability to manipulate the VMAS database 20 concerns and the timetable for the development 21 able to develop parts and supplies and vehicle hire based on the records 22 for these components. 23 VMAS. ,-’ 24 25 4. vector. The proportions This approach is consistent with the BY 1996 Because of due to Y2K of BY 1996, we were not Starting in FY 1999, we will use data directly from provided from ATTACHMENT accrued cost pools for these components 4 are applied to the to develop BY 1996 costs. 20 1 2 3 4 c. Calculation of Base Year 1996 Costs ATTACHMENT 4 shows the disaggregation of maintenance dollars into the subcomponents. 1. OTHER (MAINT) Personnel costs, as shown in ATTACHMENT 5 29, are not used to develop the subcomponent 6 costs for either MVS or vehicle depreciation. 7 vehicles owned by maintenance a for future treatment. 9 2. ALL CITY CARRIERS 10 are redistributed 11 CARRIERS 12 and depreciation 3. to C/N shares of the accrued These costs represent to perform their duties. costs, as shown in ATTACHMENT CARRIERS 4, Line See Section V.B. 4, Lines 36-37, LETTER ROUTES and GIN SPR ROUTES. The new total for ClTY CARRIERS LEmER ROUTES is distributed to its I 13 subcomponents 14 weighting, 15 12.2, and 20.2. using BY96 STS Proportions. as shown in TABLE 2. These results are applied to CS 12.1, TABLE 16 This results in the following 2 17 Given no new evidence to indicate that rural carriers or city carriers on ia 4. 19 special purpose routes require rental vehicles at a higher rate than in the past, 21 - 1 vehicle hire costs, CS 12.3, rely on the same subcomponent 2 workpapers. 3 12.0.3 and 12.3. VMAS data in this area exists but not available prior to the 4 construction 5 enhancements 6 Using the percentages 7 depreciation 8 ATTACHMENT The inputs are shown in USPS T-l 1 Workpaper of the base year workpapers. B at worksheets See Section V.B. where future costing are discussed. developed in TABLE 2, the recalculated and MVS costs are then inputted in T-l 1 Workpaper 5. shares as the BY96 proportions B as shown in for 22 1 D. 2 Base Year 1996 Results Volume Variable costs for BY 19965 are shown below in TABLE 3. 3 4 TABLE 3 5 6 7 v. 6 A. Comparison 9 CONCLUSIONS of Base Year 1996 and Base Year 1996 Methodologies The vehicle-use basis and the total system basis represent two distinct concepts 10 for allocating VMF costs to city carrier activities. 11 material costs are directly proportional 12 assumes that VMF labor and material costs are proportional 13 This methodological 14 directly from accounts as they are charged. 15 16 Secondly, 5 USPS-T-l to the time-use of vehicles while the second question is eliminated the BY 1996 methodology service, changing functions, 1 Workpapers The first assumes that VMF labor and to the number of vehicles. in the BY 1996 treatment is self-updating. as we take costs Vehicles coming into and being taken out of service are reflected in the database 23 1 1996 costing and sampling error. -2 3 Lastly, the BY 1996 methodology The Make/Model required many assumptions report was apportioned as to the functions 4 of vehicles. 5 assumed use of vehicles. 6 actual function assigned to each vehicle. 7 superior, leading to more accurate costing of motor vehicle service and vehicle a depreciation. 9 B. Methodology 10 .- each A/P. This removes the issue of the timeliness of the sampling used in the BY The new methodology based on the survey and bypasses this complexity by using the Clearly in all aspects the new methodology is Refinements As stated earlier, Y2k limitations on manipulations of the database and the 11 timeliness of the base year limited our total use of the VMAS data to develop these 12 costs. Starting with FY 1999 Cost Revenue Analysis (CRA), the computation 13 hire, CS 12.3, and parts and supplies, CS 12.2, will be calculated 14 own vectors of costs by function code. This will enhance the treatment 15 This improvement 16 maintenance 17 number of vehicles as addressed will deflate any arguments directly using their immeasurably. that stem from using CS 12.1, dollars to allocate other components, in Section on vehicle V.A. e.g., issues relating to usage vs. 24 ATTACHMENT 1 VMAS FUNCTION CODES USPS-T-20 -~ 4, 25 ATTACHMENT 2, PAGE 1 of 2 USPS-T-20 VMAS WORK ORDER FORM FRONT 26 ATTACHMENT USPS-T-20 2, PAGE 2 of 2 VMAS WORK ORDER FORM BACK 1121 I I-ililil l 1s 1141 I Iililil I L ) ) 27 ATTACHMENT 3 USPS-T-20 DATE:06/15/1999 78;586;298.49 2.473.381.30 2.168.398.84 54.332.73 . - .- . 28 ATTACHMENT 4- MAINT & DEPREC DOLLARS LlNE BY SUBCOMPONENTS FUNCTION CODE Maintenance USPS-T-20 Demeciation y&i& NUMBER 1 2 3 4 5 6 8' 9 IO 11 12 13 14 15 16 17 18 19 20 21 22 23 24 24 26 27 28 29 I NO Al I AM A0 AV CA IA IE IS MP MS DD PM ss vs IWR DS EX .z? PS I NO FUNCTION CODE ACCIDENT INVESTIGATION ADMINISTRATIVE FIELD MAINT OPERATION AMF VEHICLE CUSTOMER ACCT REP INSPECTION SVC (ADMIN) INSPECTION SVC LAW ENF INSPECTION SVC (OTHER) MOBILE POTRAILER MOBILE SELF-POWERED PO DELIVERY DIST MAINT PLANT MAINT SERVICE STREET SUPERVISION VENDING SERVICE WRECKERS DEAD STORAGE EXPERIMENTAL NON-POSTAL VEHICLE PREPARED FOR SALE 30 31 32 DM PL CD 33 34 35 ‘c”s CITY CARRIERS LEITER ROUTES DISMOUNT ROUTE PARK AND LOOP CURBLINE DELIVERY CITY CARRIERS SPR ROUTES COLLECTION INTRA CITY NON-VMS SERVICE PP PARCEL POST 36 37 CP DT ALL CITY CARRIERS COMBINATION DRIVER TRAINING 38 TOTAL CARRIERS 39 40 RR RURAL ROUTE 41 42 ED EXPEDITED 43 44 45 46 47 48 SP MV BT MT ST VEHICLE SERVICE DRIVER SPOITER MOTOR VEH SVC (MVS) VEH BMC VEHICLE (TRAILERS) MOTOR VEH SVC (MVS) TRL NON-ROAD USE TRAILERS 49 l-r TOTALS: DELIVERY 554314.16 34419.36 3.805.359.11 314,177.29 296.236.02 109.375.67 56,198.99 717,949.44 540.970.56 16.651.99 2551467.57 21,612.OO 2,473.381.30 351.439.16 171.970.68 9,722,343.30 156.020.91 18.961.83 '565.94 10349.18410 110,110.14 1.645,632.26 274.001.69 1.051.265.35 2.595.181.99 13.158.65 1.904.04 54:332.73 16.470.M5.65 1.032.128.00 26.1Q?J.00 1,776 36 I 2.256.659.00 1,349,515.00 458.756.00 3.102,496.00 167.776.00 206.479.00 75.665.00 1.352.00 1,422.OO 4,469,758.00 54.055.00 1.004.125.00 '174;541.00 993.995.00 741.036.00 114.906.00 849 4,604.OO 7.636.532.00 92 ,I ; 5,907 61 971 340 409 9.076 65 * so 17.021.00 10.4W.226.97[ 78.566.296.49 45.696.779.04 6,707,967.00] 77.295.123.00 34.228.957.00 10,591 91,263 41,669 427.970.27 5.160.235.66 2.166.396.84 1.029.055.00 5.477.019.00 1.691.707.00 270 3,626 1.194 14.223.793.53 347.571.86 11.946.059.00 34771.00 12.591 472 157,213,276.67 140.927,658.00 161,666.OO 12.795.646.84 12.795.648.84 10,441.509.00 10.441.509.00 11.241 11,241 2.333.633.04 2.333.633.04 3,712,012.00 3,712.012.00 2.449 2.449 1,245,865.24 17.772.315.95 145.416.72 4.664.641.43 20,739.31 23.669.000.65 2.037,223.00 21,966,674.00 260.397.00 2.601.777.00 17.653.00 27.103,724.00 420 4,171 321 3,974 233 9,119.oo $222,464,648.55 5205,089,504.00 215,898 .4 29 ATTACHMENT 5 USPS-T-20 MVS BASE YEAR INPUTS Base Year 1998 - USPS Version C/S 12 MOTOR VEHICLE SERVICE INPUTS C/S 20.2.2 VEHICLE DEPRECIATION INPUTS COLUMN NUMBER (2) (1) (3) (4) (5) (6) (7) 5(000) 5(000) 5(000) S(OO0) CALCULATIONS UNITS COLUMN SOURCE/NOTES S(OO0) 5(000) $(OOO) r From Stmt of Rev & Exp subacct. 141 12.1.1 TOTAL PERSONNEL 306,653 221,374 12,730 3,475 35,543 19,054 14,477 12.2.1 TOTAL SUPPLIES AND MATERIALS 333,769 240.963 13,657 3,762 36,688 20.740 15,759 COLUMN NUMBER (2) (1) (3) (5) (6) 5(000) 5(000) CALCULATIONS UNITS COLUMN SOURCUNOTES 12.3.1 TOTAL VEHICLE HIRE 5(000) S(OO0) b(000) I I From Stmt of Rev 8 Exp Acct 52459 5(000) 32.664 25,142 1,446 395 4,037 I.644 205.7771 140.3291 9,1631 3,6Q61 26.9691 10,397 CALCULATIONS 20.2.2 1TOTAL DEPRECIATION 15,203
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