Before The
POSTAL RATE COMMISSION
WASHINGTON,
D.C. 20268-0001
Postal Rate and Fee Changes,
2001
Docket No. R2001-1
)
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES
TO WILLIAM P. TAYMAN, JR. (OCA/USPS-T6-38-42)
November 13,200l
Pursuant
Commission,
requests
to Rules 25 through
28 of the Rules of Practice
the Office of the Consumer
for production
OCAIUSPS-1-21
of documents.
dated September
Advocate
Instructions
hereby submits interrogatories
submitted,
Acting Director
Office of the Consumer
KENNETH
Attorney
1333 H Street, N.W.
Washington, D.C. 20268-0001
(202) 789-6830; Fax (202) 789-6819
and
included with OCA interrogatories
28, 2001, are hereby incorporated
Respectfully
of the Postal Rate
Advocate
E. RICHARDSON
by reference.
Docket No. R2001-1
OCANSPS-TG-38.
Information
provision
-2-
Please turn to your response to interrogatory
was requested
on the additions to annual revenues based on the additional
of mail service to approximately
Some of the questions
in that interrogatory
given that the answers
to the interrogatory
information
OCANSPS-TG-22(a).
we had expected to obtain.
1.7 million new delivery
are being restated
points per year.
for additional
do not appear to be consistent
clarity,
with the
One would expect that the 1.7 additional
delivery points would generate some deliveries.
new
For example, if each new delivery point
received one piece of mail on 300 days of the year, one could project that there would
be over 500 million additional
pieces of mail per year.
In fact, the additional
mail from
the additional delivery points may be much larger.
(a)
What is the projected
amount of mail that will be delivered to the additional
1.7
million new delivery points per year?
0.‘)
Please state the projected revenue for the Postal Service resulting from the mail
delivered to the approximately
(4
Associated
1.7 million new delivery points.
with the expenditure
of $400 million of capital costs for the additional
1.7 million new delivery points, there would be additions to costs related to the
cost of the capital, e.g. depreciation,
etc.
Is it correct that the Postal Service
does not know how much the expenditure
impact costs, as apparently
of the additional
$400 million will
inferred from your answers to OCANSPS-TG-22(b)
and (c)? If your answer is other than affirmative, please provide the numbers.
(4
Associated
with the expenditure
1.7 million
new delivery
points,
of $400 million of capital costs for the additional
there would
be additions
to operating
costs
related to the cost of labor and supplies, e.g., payments to letter carriers, fuel for
Docket No. R2001-1
-3-
delivery trucks, etc. Is it correct that the Postal Service does not know how much
the addition
of 1.7 million additional
delivery
points will impact operating
related to the delivery of the mail, as one might conclude
OCANSPS-TG(b)
and (c).
If your answer
costs
from your answers
is other than affirmative,
to
please
provide the numbers.
OCANSPS-TG-39.
wherein
Please turn to your reply to interrogatory
you state in reference
projects associated
to the Postal Service
freeze on capital spending
Without facility investment,
(4
cash oufflow is less.”
by what dollar amount
higher and what is the percentage
(b)
for
with the addition of 1.7 new delivery points, that “Annual operating
costs are higher without facility investment but the short-term
(a)
OCANSPS-TG-23(c),
are annual operating
costs
increase in annual operating costs?
Without facility investment,
by what dollar amount is short-term cash outflow less
and what is the percentage
reduction in short-term
Why is short-term
OCANSPS-TG-40.
calculated
example,
information,
retirement,
cash oufflow less?
Please refer to USPS-LR-J-50,
attrition rate, equal to the retirement
may be reasons
cash oufflow?
for separation
an individual
e.g., number
of separations
for the total bargaining
Service
on page 394.
Please
provide
rate for reasons
of 693,878
by employee
A
There
other than retirement;
employment.
and separation
employees
in your testimony.
rate, is presented
from the Postal
may seek alternative
referenced
for
similar
other than
group,
as
delineated.
OCANSPS-TG-41.
again at page 394.
Please
refer to USPS-LR-J-50,
The total of 693,878 employees
referenced
in your testimony,
as shown on that page is not the
Docket No. R2001-1
-4-
total Postal Service employment.
There are other classifications
provide similar data for the other classifications
of responding
meaningful
(a)
to this interrogatory,
classification.
An attrition
rate related
A separation
OCAAJSPS-T6-42.
casual
workers
to retirements
financial exigencies.
participants
leaving
for purposes
similar
to that
other than retirement,
in OCA/USPS-T6-40.
be temporarily
furloughed
career conditional,
or permanently
temporary,
terminated
and
due to
If you do not confirm for each case, please explain.
OF SERVICE
certify that I have this date served the foregoing
of record
and
at 394.
CERTIFICATE
I hereby
by type of employee
Please verify that, if necessary,
could
To minimize the burden
the data may be provided in any appropriate
rate for employees
similar to that requested
Please
To be specific, please provide the following:
provided in USPS-LR-J-50
(b)
of employees.
of employees.
in this proceeding
practice.
Washington, D.C. 20268-0001
November 13.2001
in accordance
document
upon all
with Rule 12 of the rules of