OCA-T-9 Docket No. RZOOO-1 DIRECT TESTIMONY OF PAMELA A. THOMPSON ON BEHALF OF THE OFFICE OF THE CONSUMER MAY 22.2000 ADVOCATE TABLE OF CONTENTS I. STATEMENT II. PURPOSE Ill. THE COST MODEL PROGRAM .__.._.._....,,................................................. AND SCOPE OF TESTIMONY 1 ...__..__..........,..................,..,............. 2 ,_.._.__.__,,...,,.............,....,.,................................ 3 Replicating USPS Witness Kashani’s Cost Data Requires Using Five Programs . . .._____..........,..................,,...............,...................,............. A. IV. OF QUALIFICATIONS Page 3 B. OCA Replicates USPS Costs And Incorporates USPS Corrections . . . .. . . . . .. . . .. .. . . . . .. .. .. . . .. .. .. .. . .. . . . .. .. . . .. . .. .. . .. . .. . .. . . .. . .. .. . . 4 C. The OCA Incorporates OCA Witnesses Smith’s and Ewen’s Cost Proposals .,...._._._,....,....................,,................................................. CONCLUSION APPENDIX A APPENDIX B 8 .. . .. .. . . .. . . .. . . .. . . .. . .. . .. . . .. . .. . .. . .. .. . .. .. .. . .. .. . . .. . . .. . . .. . .. . .. . .. . .. . . .. .. . . .. . .. .. .. 11 UNITED STATES OF AMERICA Before The POSTAL RATE COMMISSION WASHINGTON. D.C. 20268-0001 Postal Rate and Fee Changes, 2000 Docket No. R2000-1 ) DIRECT TESTIMONY OF PAMELA A. THOMPSON 1 I. 2 STATEMENT OF QUALIFICATIONS My name is Pamela A. Thompson. 3 Specialist 4 the Postal Rate Commission 5 Commission 6 Docket 7 Commission’s 8 prior years’ losses. 9 methodology I am a senior Postal Rate and Classification for the Office of the Consumer Advocate since March 1990. (OCA). I have testified previously in Docket Nos. R97-1, R94-1, R90-1, MC96-3, No. R97-1, my cost model. testimony In R94-1, I proposed I also proposed for, a contingency 10 proposed the adoption 11 Mail. 12 automation-compatible 13 Compatible 14 Postal Service 15 offered by the Postal Service. A three-cent Envelope provided of two discounted discount prebarcoded envelope. (ACE), consisted as a specialized documentation before this on operating In the for the recovery of in the amount of, and the allocation In Docket single-piece was proposed at MC95-1, and MC93-I, a new methodology a change provision, I have been employed No. R90-1, rate categories for Courtesy The within First-Class Envelope second Mail (CEM), category, of mail pieces to be produced form of the stamped In Docket No. MC96-3, my testimony envelope my testimony an Automation and sold by the products proposed currently to show OCA-T-9 Docket No. RZOOO-1 1 that the Postal Service was attempting 2 target a few special services for price increases. 3 proposed a Courtesy 4 discount for qualifying 5 No. MC93-1, 6 BSPS classification 7 Envelope single-piece reviewed reform framework courtesy and a 12-cent In Docket cost coverage for the new the Postal Service’s proposal. Prior to my employment Waste with the Postal Rate Commission, Management for Chemical 9 Business Planner 10 principally in the areas of strategic planning, pricing and implementation. for a division (CWM). I was an Assistant Controller of International Prior to CWM, I was a Staff Business Machines (IBM) working I received my MBA from Wright State University in Dayton, Ohio, in 1979, and a 11 12 BA, in 1975, from the Christopher 13 I have taken additional computer 14 II. 15 Newport College of the College of William and Mary. science courses from the University of Colorado. PURPOSE AND SCOPE OF TESTIMONY The purpose and scope of my testimony is three-fold. 16 costs as provided in USPS witness 17 Then, 18 incorporate, 19 4) and Ewen (OCA-T-5) 20 test year after rates with the workyear 22 per piece reply envelopes. 8 21 to In Docket No. MC95-1, my testimony Mail (CEM) rate category First-Class my testimony to misuse the classification I incorporate Kashani’s testimony the corrections proposed First, I replicate the USPS and workpapers by USPS witness Kashani. into the base year cost model, the changes OCA witnesses propose. Due to the problems Exhibits to my testimony Finally, I Smith (OCA-T- provide results through the mix adjustment. encountered time frame needed to incorporate (USPS-T-14). in replicating the proposals -2- USPS cost data as well as the for OCA witnesses Smith and Ewen, I OCA-T-9 Docket No. R2000-1 1 was unable to prepare the test year after rate PESSA allocations. 2 year after rate PESSA allocations will be provided as a supplement 3 addition 4 library reference. 5 Ill. to this testimony, a library reference, A. 8 The five programs Replicating Proqrams GRMAT, to my testimony. OCA-LR-I-l, COSTMOD, data file into USPS Witness Kashani’s In a category used to replicate Cost Data Requires the USPS LRCOST, and PRCEDIT. a binary matrix DATAFILE 2 11 BASEYEAR.BIN. 12 (BASEYEAR.BIN 13 and Kashani 14 Starting 15 replicate the USPS cost model input, I use the COSTMOD.EXE 16 programs to replicate the base year cost data.’ contains to generate writes the data equivalent cost the USPS Base Year Manual I incorporate 18 using the LRCOST 19 the former 20 BASE-SDM.BIN. 21 USPS witness Kashani’s segment The instructions Five are DATAFILE, data uses to a file called BASEYEAR.BIN. to that used by USPS witnesses with the data file, BASEYEAR.BIN 17 out the model Using reads data from a base year Subsequently, and cost data 10 1 the test THE COST MODEL PROGRAM 6 7 9 I sponsor However, Input Requirement Meehan report.) and several “script” files that I create to and LRCOST.EXE the USPS’s proposal to move segment 9 components to segment program and a “script” file called “MOVESDM.FAC.” After moving 9 components to segment I use BASE-SDM.BIN (USPS-T-14) 3, I produce the base year file, as the starting point for my replication workpapers. in my “script” files come from information -3- 3 provided by the USPS in USPS-LR-I-6. of Docket No. R2000-1 OCA-T-9 COSTMOD variabilities. and LRCOST I use GRMAT results to a temporary USPS eliminates PRCEDIT.EXE build distribution keys and use the Postal Service’s to view results on the computer output file for future printing. the subclass Standard In the Mail (A), to edit the binary data file, FY99SPA,BIN, Mail (A), single piece rate costs. The amounts screen and to save my interim single year piece 2000, rate. the I use to zero-out residual Standard zeroed-out were values less than positive or negative one.* 8 B. 9 In this docket, I updated all associated OCA Replicates USPS Costs And Incorporates program files to reflect the USPS costing 10 methodology. 11 diskette accompanying 12 witness Kashani’s 13 provide a component 14 “cross-walk.xls” 15 needed as the cost model uses the USPS component 16 A copy of the updated OCA-LR-I-l. workpapers cross-walk programs and my data files are provided on the Electronic are provided copies of my replication in the subdirectory of the segments EXCEL spreadsheet. USPS Corrections USPSREP. 21 and 22 components A cross-walk for segments numbering of USPS I also I use, in the 1 through 20 is not scheme. The VBL2 files provided to the PRC for FY 99, FY 00, and FY 01, in USPS-LR-I- 17 6, indicate that component 18 witness 19 component Kashani indicated 907 receives a direct and indirect mail volume effect. in his response to P.O. Information Request USPS 10, that 907 should not receive two mail volume effects in FY 99, FY 00 and FY 01 .3 2 The components affected are: 2:9, 2:29, 2:30, 2:32, 2:678, 3:228, 6:45. 16:177, 18:199, 18:201, and 18:204. I also used PRCEDIT to input the stamped envelope and P.O. box volumes provided by USPS witness Kashani. See Docket No. R2000-1, Tr. 2/645. 3 P.O. Information Request No. 10 (April 25. 2000). POIR-IO-I. OCA-T-9 Docket No. R2000-1 However, 1 in replicating 2 instance 3 mail volume effect for component 4 where USPS witness his workpapers In preparing workpapers, I found that the only appear to incorporate the indirect and direct 907 is in FY 99. the OCA cost proposal, 5 for component 6 cost model commands 7 witness 8 document. 9 actually Kashani’s I eliminated 907 in FY 99, by eliminating Kashani’s used is provided the DOS batch file CFS.BAT. in Appendix results with my results After having replicated the indirect mail volume effect A of this document. in Exhibits USPS witness Kashani’s IA-ID workpapers, 11 component 12 907 receives only a direct mail volume effect;’ (4) “to better approximate 13 the COBOL 14 (-102,342 15 independent 16 fy99rcc;“’ 30’s treatment model, thousand) volumes for FY 99, FY 00 and FY 01;4 (2) with respect to Higher Level Supervisors;’ (5) include component 41 in “the list of effect for component 678 in VBL2 of for the mail volume P.O. Information Request No. 6 (April 10, 2000), POIRb-2. P.O. Information Request No. 10 (April 25,2000), /CL, POIR-10-5. -5- on component (A) Single Piece and International Id. at 646. 8 the results of is multiplied by 1.003;“’ distributed (3) component amount (6) in the roll forward for the Standard @., POIR-10-2. the the total cost reduction components 7 B to this I incorporated following (1) periodical I compare of Appendix 10 USPS corrections: A list of the POIR-IO-I 253 Mail Docket No. R2000-1 1 volume 2 adjustment.’ OCA-T-9 adjustment, FY99RCC, component 1453 Prior to my initial cost model runs, I compared 3 4 Docket R97-1 with the current USPS data input. 5 assumed 6 intended to be 131. Additionally, 7 of the list of independent 8 VBL2 9 VBL2RIP,DAT, that component of USPS-LR-I-6, 21:173 (USPS component 11 In the OCA proposal, 12 correct treatment \FY99RCC; therefore, the 41. In replicating OCA mail volume ripple file, the USPS data, OCA component 1453) did not receive a duplicate mail volume adjustment.“’ I adjusted the FY 99, FY 00 and FY 01 “ripple” files to reflect the several Information Requests 16 Information Request 17 replicate the USPS COBOL 18 component 30’s, Higher Level Supervisors.” difficulties 6 and 10. in replicating I experienced In USPS 10, interrogatories USPS witness witness Kashani’s 2 and 3, he indicates by 1.003.” /d, POIR-10-6. /d., POIR-10-6 -6- Kashani’s are similar to those reflected in P.O. response to P.O. that to more closely cost model results in his spreadsheet, 253 amount of $102,342,000 d.. POIR-10-2. 10-4, was 678 in 15 12 Request for the mail volume effect of component Many of the difficulties rd., POIR-6-2. in P.O. Information components workpapers. 11 Thus, in my initial cost model runs, I left out 14 9 mail volume 41 was erroneously of component I experienced only one USPS cost model data input from I assumed that component includes component IO 13 331, mentioned receives he multiplies the OCA-T-9 Docket No. R2000-1 In the 1 cost model, the method 2 ($102,342,000) by 1.003 to allocate 3 $240,173 4 and implementing 5 components 6 amounts. 7 model with this as the only segment 8 reduction 9 for component of $82,201,000 66. The $82,201,000 the cost model functions 11 component 12 the $102,342,000 13 omitted), 14 468,469,470,471,41, additional $19,928,000 in and run the cost a cost amount of $213,000 to component 35 using is allocated to portion of (102,342 - 82,201 - 213 --trailing zero’s 40, 421, 422, 423, 467, 227 and 228, using the cost model function “cl.” A similar problem Again, exists for segment 6, component 16 component 17 $124,496,000 and determined that the intended cost reduction 18 be allocated to component 43. 19 component 20 reduction 21 commands. 22 27,534 23 components: amounts 43 and segment I ran the cost model to isolate the cost reduction 46 was $27,534,000. are distributed The zero’s omitted) cost reduction Both the $32,363,000 to their respective The remaining cost reduction - trailing results The remaining segment 3 components: of cost reduction cost reduction “di” and “ds.” of by 1.003 The result indicates 35 and a cost reduction 66 using the cost model functions 46. the $102,342,000 amount of $102,342,000 The $213,000 reduction 35 cost reduction cost reduction is allocated is allocated to the following cost the $102,342,000 35 receiving 3 cost reduction. “di” and ‘Ids.” cost reduction, Increasing 3, component for component the component used to allocate Thus, I isolate the cost reduction 10 15 results. USPS other than segment multiplying an additional will not produce the intended the method of amount of amount of $32,363,000 amount to be allocated and the $27534,000 components amount of $64,599,000 was allocated to the remaining to cost using “di” and “ds” (124,496 - 32,363 segment 6 and 7 6:44, 6:45, 7:48; 7:49; 7:50; 7:52; 7:53; and 7:54 using the “cl” function. -7- 7, Docket No. R2000-1 Another 1 OCA-T-9 instance of a dual distribution 2 effect occurs in “other programs” 3 $798,000 4 $60,647,000 5 component 6 to determine 7 remaining 8 components: 9 command, is allocated 3, component segment to segment 3, component that $638,000 $160,000 is the amount (798,000 - 638,000) 35. A cost of increase In order to properly of reflect the cost reduction and run the cost model to be assigned is allocated to component to the following 35. The segment 3 40, 66, 421, 422, 423, 467, 468, 470, 471, 41, 227 and 228 using a “cl” USPS corrections and the changes 11 Smith (OCA-T-4) 12 into the cost model. 13 constraints, 14 Electronic copies of my results are provided in OCA-LR-I-l. and Ewen (OCA-T-5) Appendix I was unable 15 16 C. 17 After updating The OCA Proposals 18 witness 19 Ewen’s (OCA-T-5) 20 changing 13 in a given cost level 35.13 A cost reduction 3 components. 35 cost effect, I isolate the $798,000 I incorporate 10 for segment to fourteen is allocated to one component Smith’s B, Exhibits to complete Incorporates for the previously (OCA-T-4) proposed (discussed proposed by OCA witnesses in the next section of my testimony) 2A - 2B reflect my results. the test year after rate PESSA OCA Witnesses mentioned changes to elemental -8- variabilities load. proposed the USPS FY 00 VBL6 file Smith’s USPS changes, mail processing several of the MODS variabilities See USPS-LR-I-6. proposed and Due to time allocation. Ewen’s Cost I incorporate OCA and OCA witness OCA witness Smith proposed by USPS witness Van-Ty-Smith OCA-T-9 Docket No. R2000-1 1 (USPS-T-17).‘4 2 to 100 percent: BCS, OCR, FSM, LSM, SPBS OTH, SPBSPRIO, 3 PRIOIRTY, 4 a source 5 development 6 processing 7 provided 8 results 9 EXCEL 10 OCA witness Smith’s proposed and 1CANCMPP.‘5 for USPS inputs intermediate that reference from implementing spreadsheet I-Forms.xls, changes to I-Forms.xls 11 into the USPS-LR-I-80 MODS 1 and 2 office costs.” obtained OCA witness the following MODS POOLS MANF, MANL, MANP, Using information from USPS-LR-I-106, of mail processing in USPS-LR-l-80 changing Base Year cost distributions, After opening worksheet for the I approximate the mail all the EXCEL spreadsheets USPS cost segments, OCA witness worksheet Table II-IA, as Smith’s I manually proposal into the USPS I make “MODS-BASED.” no other for OCA witness Smith (OCA-T-5). Ewen’s proposal eliminates the fixed time stops for SDR, MDR, 12 and BAM stop types. 13 OCAAJSPS-T12-IO,” 14 Factors,” 15 SDR, MDR, and BAM. 16 USPS-LR-l-80, 17 CRA” with the USPS base year manual input. Where there were differences, 18 the OCA’s base year manual input data file, OCABASEYR.BIN. 14 key the Using USPS witness Baron’s response I updated the USPS EXCEL file I-Forms.xls, the category for “Miscellaneous After updating I compared Load Factors, 15 OCA witness Smith does not distinguish between SPBSPROI, because USPS witness Bozzo does not. See OCA-LR-1, MODS.xls 17 Tr. 18/7210. “CS 6&7 Fixed Time/Stops” entry for -9- EXCEL worksheets See USPS-T-17, Table 1: Cost Segment 3 Clerk and Mailhandler 16 worksheet the cost segment the results of the updated to OCA interrogatory spreadsheets in labeled “Outputs for I updated In general terms, the Cost Pools - Part 1 of 2 at 24. the MODS POOLS SPBS OTHER and Docket No. R2000-1 OCA-T-9 1 following changes 2 total costs increased 3 16’s 4 component 5 while other costs declined 6 unchanged; 7 of mail changed, 8 (5) Segment 9 $1,910,470,000, “fixed” costs increased 10 costs increased from $2,627,641,000 11 48’s variable 12 from $1,403,993,000 to $1,162,683,000, 13 to $1,378,567,000; (7) Segment 14 $455580,000 15 from $303,839,000 16 increased 17 costs decreased 18 total costs increased 19 101’s 20 component 21 12, component 22 Segment 23 (16) total occurred costs in the OCABASEYR.BIN: from $181,344,000 increased 35’s variable from costs increased 7, component from $880,255,000 costs declined from $234,818,000 costs 83’s total costs 12, component Segment $6,819,000 to and total 7, component “fixed costs declined total -1 o- total increased 91’s total costs 12, component 94’s total 12, component (12) Segment to $7,503,000; (13) to $3,733,000; from 95’s 12, component Segment 12, (14) Segment to $19,786,000; from $79,518,000 increased from 52’s total costs declined from $16,746,000 costs costs (11) Segment from $4,416,000 increased 86’s (6) Segment (10) Segment 85’s total costs decreased 12, component to $977,417,000, 12, component to $144,076,000; 103’s total costs decreased from $1,747,386,000 7, component to $75,349,000; from 50’s (9) Segment to $21,537,000; increased unchanged; and total costs declined from $1,638,811,000 (8) Segment from $136,180,000 3, - total costs remained to $215,884,000, 7, component from $86,554,000 (3) Segment to classes and subclasses increased to $2,887,887,000; to $259,027,000; 2, component other, and total costs remained costs 14’s to $13,154,698,000, to $1,038,060 42’s cost distribution 46’s variable to $500,391,000; (2) Segment from $11,858,958,000 however, total variable, 2, component to $95,140,000; from $2,333,800,000 from $18,228,000 total to $199,305,000; $113,101,000 (4) Segment 4, component (1) Segment (15) to $69,224,000; $125,110,000 to Docket No. R2000-1 OCA-T-9 1 $132,364,000; 2 to $96,823,000 3 Segment 20, component 4 (19) 5 $46,746,000; 6 $84,485,000 7 platform costs were updated; 8 the Standard 9 reallocated 10 Segment (17) Segment 14, component - the difference is in Standard Segment to $89,384,000; 224’s 20, total costs component $53,698,000 225’s manual input changes were PRCEDIT 12 incorporated 13 ultimately impacted the allocation of PESSA costs. program. OCA witness Smith’s into the cost model through My results are provided costs in Appendix 177. variabilities B to this testimony, 16 IV. using were in the SR1116.FAC Electronic copies of my results are provided in OCA-LR-I-l increased the amount the USPS input to the cost model changes from for platform and non- 16, component proposed to increased of the OCA proposals 15 the further file, which Exhibits 2A and 2B. , subdirectory, \OCAPROP. CONCLUSION Using the updated 17 from total for segment 11 14 decreased (A) single piece costs in FY99, thus, I changed Base year (18) to $13,362,000; and (22) incorporation to $4,392,000, Rate; from $11,309,000 (21) the premium cost calculations from $4,131,000 from $96,829,000 Mail (B) Parcels Zone 222’s total costs increased 20, component (20) 681’s costs decreased cost model programs, I am unable to determine I replicate USPS witness 18 workpapers. However, 19 performed the calculations 20 results differ slightly from those presented by USPS witness 18 and examples of the calculations involving component In OCA-LR-I-l, I provide written explanations cost model programs COSTMOD and LRCOST. Kashani’s how the Postal Service’s cost model 35 and component 43.” Kashani. Thus, my I believe the performed by the Docket No. R2000-1 differences involving effect. OCA-T-9 relate to how the two different one component receiving See, for example, segment 43; and segment Request No. recommended 7, component 10 responds cost changes 3, components Witness to workpaper Kashani’s data the cost changes Due to time constraints, year after rate PESSA within handle response corrections. 6; component to P.O. Information I incorporate his I have used my updated cost provided to me by OCA witnesses I was unable to produce the allocation costs, which will be filed as a supplement -12- a situation a given cost level 35 and 66; segment changes into the OCA cost presentation. model files to incorporate and Ewen. 46. multiple cost model programs Smith of the test to my testimony. APPENDIX 1 2 3 A General Instructions Create a “\tmp” directory on the root of the computer called by the batch file PRTROLL drive you are using. The 4 “LP” program 5 used by the OCA to replicate 6 and calculate 7 included in OCA-LR-1 8 “batch” files in separate subdirectories. Each row of instructions 9 one batch file. Follow each instruction with a carriage OCA witnesses requires the “\tmp” directory. USPS cost workpapers, incorporate Smith and Ewen’s proposals The files USPS corrections, are provided on the diskette To facilitate the cost roll forward process, I used the same DOS 10 requested by the program during execution 11 follow each response with a carriage return. are enclosed listed below represents return (<ENTER>). in quotation marks. The files Again, OCA-T-9 Docket No. R2000-1 1 Commands 2 Cl; 3 LI; Used To Replicate 4 C2 - “OCARIPl.DAT;” 5 L2; 6 C3 - “OCARIP2.DAT;” 7 L3; 8 C4 - “OCARIP3.DAT;” 9 L4 (Includes FY 98 PESSA costs); 10 R99; and 11 R99SPA. 12 Then, use PRCEDIT.EXE USPS Results: to eliminate (zero-out) residual amounts in Standard A Single 13 Piece Mail (row 12) for the following USPS components: 14 2:9, 2:29, 2:30, 2:32, 2:678, 3:228. 6:45, 16:177, 18:199, 18:200, 18:201, and 18:204. 15 Continue the costing model process by executing the following DOS batch files: 16 CFS - “VBLZRCR.DAT 17 R99ADJ - (Contains Workyear Mix Adjustment); 18 ROO; 19 ROOADJ - (Contains Workyear Mix Adjustment); 20 ROI; 21 ROIADJ - (Contains Workyear Mix Adjustment); ;” A-2 Docket No. R2000-1 1 Commands 2 Cl; 3 Used To Implement OCA-T-9 The OCA’s Proposal: Ll; 4 C2 - “OCARIPIDAT;” 5 L2; 6 C3 - “OCARIPZ.DAT;” 7 L3; 8 C4 - “OCARIP3.DAT;” 9 L4 (Includes 10 R99; and 11 R99SPA. 12 FY 98 PESSA costs: Then, use PRCEDIT.EXE o eliminate (zero-out) residual amounts in Standard A Single 13 Piece Mail (row 12) for the followi g USPS components: 14 2:9, 2:29, 2:30, 2:32, 2:678, 3:22 , 6:45, 16:177, 18:199, 18:200, 18:201, and 18:204. Continue the costing modt 15 process by executing 16 R99ADJ - (Contains Workyear M ( Adjustment); 17 ROO; 18 ROOADJ - (Contains Workyear Mix ,djustment); 19 ROI ; 20 ROIADJ - (Contains Workyear Mix rdjustment); A-3 the following DOS batch files: APPENDIX 1 2 B Exhibits IA, IB, IC, and ID show the OCA’s replication of the USPS proposal. 3 Exhibits 2A and 28 provide the results of the OCA’s proposal with the incorporation 4 the USPS changes. of source OCA-LR-I-I \USPSREP 1 (7) (12) 2 (2) Special Services: Registry Certified ,,354,068 36,868,213 7.366 69,628 76,994 467,123 2.030.683 (1,965,858) 64,825 2.081.54, (2.005.952~ 75,595
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