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-T6-43-56)
November 19.2001
Pursuant
Commission,
to Rules 25 through
28 of the Rules of Practice of the Postal
the Office of the Consumer
requests for production
OCA/USPS-1-21
of documents.
dated September
Advocate
Instructions
hereby submits interrogatories
included
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
Advocate
E. RICHARDSON
and
with OCA interrogatories
28, 2001, are hereby incorporated
Respectfully
Rate
by reference.
-2.
Docket No. R2001-1
Please
OCABJSPS-TG-43.
Please
refer to your response
confirm that your response
Postal Service
provide
to say that all the markets which the
serves today are highly competitive
products
substitutes
is intended
or services
that are “either
for postal services.”
OCAlUSPS-TG-44.
to OCAAJSPS-TG-33(a-b).
as they include
competitors
direct or extremely
attractive
who
indirect
If you do not confirm, please explain.
Please
refer
to
your
response
to
DMAIUSPS-TG-21
indicating the Postal Service has not asked Congress to increase the USPS debt limit in
the last five years.
November
recall that the Postal Service
9, 2001 appearance
General Government
attacks.
Also,
before
Appropriations
the Senate
requested
subcommittee
$5 billion in a
on Treasury
to address the impact of the September
and
11 terrorist
Note also the proximity of the current Postal Service debt to the statutory debt
ceiling imposed by Congress
to the September
which you say at page 8 of your testimony
11 terrorist attacks) “will be uncomfortably
in FY 2002.” [$12,913 billion or 86.1 percent of the statutory
billion or 111.8 percent
management
of the statutory
limit].
prior
close to the statutory limit
limit.]
year before rates basis, the Postal Service could reach the statutory
[$16,772.6
(prepared
Further, “On a test
limit in FY 2003.”
Does the Postal Service
have any plan or intent to request from Congress
during FY 2002 or FY
2003 an increase in the Postal Service’s $15 billion debt ceiling:
(4
If Congress
adverse
subsequent
financial
does not provide the Postal Service any funds to address the
impact
of the
September
use of the mail for bio-terrorism.
11 terrorist
attacks
and
the
Docket No. R2001-1
(b)
-3-
If Congress
to address
provides the Postal Service a total of approximately
the impacts
of the attacks
on facilities,
equipment,
$3 billion
security,
and
operations.
(4
If Congress
consisting
provides the Postal Service a total of approximately
of $3 billion to address
equipment,
security,
and operations
Service for business
the impacts
of the attacks
$5 billion
on facilities,
and $2 billion to compensate
losses due to significant
reduction in volumes
the Postal
incurred
due
to the terrorist attacks.
(d)
If the answer
is affirmative
to any of the parts (a) through
please explain when the Postal Service management
increase
(c), above,
would expect to request an
in the debt ceiling and uses of the funds raised by increasing
the debt
ceiling.
63
If the answer is negative to any of the parts (a) through (c), above, please
explain why the Postal Service management
would not plan or intend to seek an
increase in the Postal Service’s debt ceiling.
OCADJSPS-TG-45.
Postal Service’s
to FY 2003.
Please refer to Table 6, page 8 of your testimony,
outstanding
debt as a percentage
listing the
of the statutory ceiling from FY 1972
Please explain whether the total debt shown on Table 6 is year end, the
average outstanding
OCAIUSPS-TG-46.
program costs.
balance, or another measure.
Please refer to your testimony
You state, “Reduced
program expense
at page 18, discussing
reflects management’s
other
concern
-4-
Docket No. R2001-1
about the Postal Service’s
control costs.
financial
condition
as well as a continuing
There is long term risk, however,
deferral and cancellation
of programs
quality of service, increase
in such an approach,
that would otherwise
responsiveness
commitment
to customers,
to
as it requires
be planned to improve the
and build and maintain
our
infrastructure.”
(a)
Please confirm that your phrase “[rleduced
fact that your testimony
shows declining
program expense” refers to the
as well as your Table 13, Other Programs,
Other Programs
expenditures
on page 18,
from FY 2001 through
the test
which of the Other Programs
listed in
year.
(b)
This interrogatory
LR-J-50,
Chapter
is to determine
V, sections
funds, will provide
b-d, for which
an improvement
in the quality
Postal Service responsiveness
to customers.
the following
describe
programs
responsiveness
and
will be improved
the Postal Service
of service
is budgeting
and/or
increase
Please provide the full names of
the way
for the years
in which
shown
postal
in LR-J-50,
service
or
FY 2001
through FY 2003.
(9
Field
Personnel
transfer
of
Related
Sales
Cost
Function
Reductions
from
Areas
& Other
to
HQ
Programs-(Professional
Employees).
(ii)
Field Non Personnel
HQ
Programs and Unallocated--HQ
Activities-Information
Technology,
Technologies,
FED-Ex Startup, Credit Cards.
Activities,
Ebusiness-Information
-5
Docket NO. R2001-1
(iii)
Unallocated
Personnel
Breakthrough
Productivity
PMPC In House,
(iv)
Cost Other Programs
Please describe
Initiatives,
BPI-District
(Chap.
V, sec. d)-
TNS Tulsa, Facilities
Professional
DARs,
Staff, Retail Init.
the postal service benefits and responsiveness
any other cost reduction
operations
or other programs
of
listed in
Chapter V, sections b-d, of LR-J-50.
Please indicate any other programs that are m
(c)
V, sections
b-d, for which the Postal Service is budgeting funds to provide or will
provide an improvement
responsiveness
costs.
Please refer to your testimony
You state, “Reduced
about the Postal Service’s
control
costs.
deferral
quality of service,
Changes
(4
Postal Service
financial
of programs
increase
Please
at page 18, discussing
program expense reflects managements
condition
as well as a continuing
There is long term risk, however,
and cancellation
infrastructure.”
in the quality of service and/or increase
to customers.
OCWUSPS-TG-47.
program
listed in LR-J-50, Chapter
in such an approach,
that would otherwise
responsiveness
Exhibits
concern
commitment
to
as it requires
be planned to improve the
to customers,
also refer to LR-J-49
other
and build and maintain
A-C
listing
Other
our
Program
for FY 2001 through FY 2003, respectively.
Please indicate which of the Other Programs as listed in LR-J-49, Exhibits
A-C, and for which the Postal Service is budgeting funds, provide or will provide
an improvement
responsiveness
in the
quality
to customers.
of service
and/or
increase
Postal
Service
Docket No. R2001-1
(b)
-6-
For those programs
will provide
Service
in part (a), above, which you indicated do provide or
an improvement
responsiveness
improvement
in the quality
to
of service
customers,
please
and/or
explain
increase
Postal
specifically
what
in service quality or Postal Service responsiveness
will be provided
and which classes of service will be affected.
OCNUSPS-TG-48.
other program
concern
costs.
about
commitment
Please
the
You state, “Reduced
Postal
to control costs.
it requires deferral
refer to your testimony
Service’s
program
financial
at page 18 that discusses
expense
condition
reflects managements
as well
as a continuing
There is long term risk, however, in such an approach,
and cancellation
of programs
that would otherwise
improve the quality of service,
increase responsiveness
maintain
Please
our infrastructure.”
to customers,
also refer to LR-J-49
Exhibit
as
be planned
to
and build and
E listing
Cost
Reduction Program Changes for FY 2001 through FY 2003, respectively.
(4
Please indicate which of the Other Programs
E, for which the Postal Service is budgeting
improvement
in
responsiveness
(W
quality
service
funds, provide or will provide
and/or
increase
Postal
an
Service
in part (a), above, which you indicated do provide or
an improvement
responsiveness
improvement
of
Exhibit
to customers.
For those programs
will provide
Service
the
as listed in LR-J-49,
to
in the quality
customers,
of service
please
and/or
explain
in service quality or Postal Service responsiveness
and which classes of service will be affected.
increase
Postal
specifically
what
will be provided
-?-
Docket No. R2001-1
Please refer to your testimony
OCA/USPS-TG-49.
program costs.
You state, “Reduced
about the Postal Service’s
control
costs.
financial
of programs
quality of service, increase
infrastructure.”
Changes
program expense reflects management’s
condition
as well as a continuing
There is long term risk, however,
deferral and cancellation
at page 18, discussing
responsiveness
to customers,
Please also refer to LR-J-49,
concern
commitment
in such an approach,
that would otherwise
other
to
as it requires
be planned to improve the
and build and maintain our
Exhibit E, listing Cost Reduction
Program
for FY 2001 through FY 2003, respectively.
Please indicate
(4
any other Postal Service initiatives
for which the Postal
Service budgets funds that are not listed in Exhibit E and which will provide an
improvement
in the
responsiveness
quality
will provide
Service
and/or
increase
Postal
in part (a), above, which you indicated
an improvement
responsiveness
improvement
service
Service
to customers.
For those programs
(b)
of
to
in the quality of service
customers,
please
and/or
explain
do provide or
increase
Postal
specifically
what
in service quality or Postal Service responsiveness
will be provided
and which classes of service will be affected.
OCANSPS-TG-50.
program
costs.
Please refer to your testimony
You state, “Reduced
about the Postal Service’s
control costs.
financial
at page 18, discussing
program expense reflects management’s
condition
as well as a continuing
There is long term risk, however,
in such an approach,
other
concern
commitment
to
as it requires
Docket No. R2001-1
-0-
deferral and cancellation
quality of service,
of programs that would otherwise
increase
responsiveness
be planned to improve the
to customers,
and build and maintain
our
infrastructure.”
Please
(4
cancelled
indicate
that would
the Postal
have provided
Service
initiatives
an improvement
and/or increase Postal Service responsiveness
that were
deferred
in the quality
or
of service
to customers.
Please provide any decision analysis reports or other planning documents
03
analyzing
the justification
program’s
potential
for such
for an improvement
increase in responsiveness
in quality
for an improvement
in the quality
Service
responsiveness
customers,
in service
specifically
of service
discuss
the
or an expected
in part (a), above, which you indicated
provided
improvement
that
to customers.
For those programs
(4
programs
to
of service and/or
please
explain
quality or Postal Service
would
have
increase
Postal
specifically
what
responsiveness
would
have
been provided and which classes of service would have,been affected.
ocA/usPs-51.
additional
If the Postal Service reaches
funds to continue
its statutory debt ceiling and requires
normally planned operations,
able to continue to borrow funds from the U.S. Treasury
(4
The existing terms and conditions
under current law would it be
at:
and, if so, please provide the basis for
your response.
(W
Under less favorable terms and conditions
basis for your response.
and, if so, please provide the
DocketNo.R2001-1
OCA/USPS-52.
additional
-9-
If the Postal Service reaches its statutory debt ceiling and requires
funds to continue
continue
normally
planned
providing for controlled
normally
operations;
and organized
planned
operations
but lacks the cash flow to
does the Postal Service
reductions
in service?
have in place plans
If so, please summarize
those plans and indicate the order in which classes and subclasses
of service, including
special services, would be affected.
OCANSPS-53.
service
provided
Is the current FY 2002 budget designed
to all classes
and subclasses
to insure that the value of
of service will be maintained
to the
extent they were provided for in FY 2001 (the test year in Docket R2000-1) and the year
for which the rates established
were expected to reflect the service provided?
please explain which classes and subclasses
If not,
of service now receive a lesser value of
service than in the FY 2001 test year and explain why the budget is not sufficient to
maintain the previous value of service.
OCANSPS-TG-54.
Has the deferral and cancellation
to on page 18 of your testimony
detrimental
that you refer
had an impact upon the value of the service or been
to the service standards
OCANSPS-TG-55.
of programs
of any of the classes or subclasses
Will the deferral and cancellation
value of service or cause the Postal Service to reduce
of mail?
of programs
its current
reduce the
service standards
-IO-
Docket No. R2001-1
through the test year in this case (FY 2003) the year for which the rates are designed to
reflect particular service standards?
Your testimony
OCANSPS-TG-56.
the Postal Service estimated
ECI (Employment
exist.”
at page 64, lines 26-28 states, “In this case
labor costs using existing contracts
Cost Index) and ECI-1 assumption
To determine annual salary increases,
J (Unit Cost Development),
where they exist, and
for wages where contracts do not
Library reference
LR-J-50, Chap. VII, sec.
page 368, applies the ECI only for FY 2001 and ECI-1 for
FY 2002 and FY 2003.
(4
Does the ECI shown on page 368 apply to all employees
non-bargaining)
(b)
for FY 2001?
Page 368 assumes
establishing
(bargaining
and
If not, please explain.
ECI-1 for FY 2002.
the wage level increase
Please
state when contracts
for FY 2002 for the employee
categories
listed on page 368 will be finalized.
(4
Page 368 assumes
establishing
ECI-1 for FY 2003.
the wage level increase
listed on page 368 will be finalized.
Please state when contracts
for FY 2003 for the employee
categories
CERTIFICATE
I hereby
participants
OF SERVICE
certify that I have this date served the foregoing
of record in this proceeding
practice.
Washington, D.C. 20268-0001
November 19. 2001
in accordance
document
upon all
with Rule 12 of the rules of