Before The
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20266-0001
Postal Rate and Fee Changes,
2001
Docket No. R2001-1
)
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES
TO WILLIAM P. TAYMAN, JR. (OCAAJSPS-T6-33-37)
October 31,200l
Pursuant
Commission,
requests
to Rules 25 through
28 of the Rules of Practice
the Office of the Consumer
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
of the Postal Rate
by reference.
-2-
Docket No. R2001-1
OCAAJSPS-TG-33.
Please turn to your testimony at page 3, lines 14-20.
“...the
competitive
increasingly
functions
nature
of the markets
make the congressionally-mandated
in which
goal of break-even
You state that
the Postal
extremely
Service
difficult to
achieve.”
(a)
Please cite which markets you view as increasingly
(b)
Please state the degree of competition
(4
Is it your testimony
competitive.
in each of the markets.
that firms have a difficult time breaking
even in competitive
markets?
(d)
In approximately
what year did the markets you cite in your response to part (a),
above, become increasingly
OCAAJSPS-TG-34.
two economic
competitive?
Please refer to your testimony
scenarios,
USSlM/Trendlong
correct that these are the two economic
assumptions
revenues
about
forecasts
Please refer to your testimony,
DRI-WEFA
USSIM/Trendlong
(b)
0601.
Is it
which underlie the Postal Service’s
state of the economy
forecasts--USSIM/Control
appear to be different from those referenced
(4
0501, and ClSSlMlControl
You cite
and on which
projections
of
and costs are based?
OCANSPS-TG-35.
underlying
the future
at page 23, lines 15-19.
Appendix
A, Exhibit USPS 6T. The
0601 and ClSSlMITrendlong
in your testimony
at page 23, lines 15-19,
0501 and CISSIM/ControlO601.
Is this a typographical
error?
If you answer is “no” please explain whether all internal projections
culminate
0501--
in revenue, cost, and contingency
that ultimately
estimates are internally consistent.
Docket No. R2001-1
OCANSPS-TG-36.
discuss
-3-
Please refer to your testimony
18 cost segments
at page 24, lines 16-17, wherein
for the Base Year through
the Test Year.
If different
those in Table 16 at page 23, please delineate for each case the underlying
forecast
elements
that drive the information
in the tables
you
from
DRI-WEFA
accompanying
the cost
segments.
OCNUSPS-TG-37.
wherein
Please
you cite three scenarios--a
forecast. and a Pessimistic
(4
refer to your testimony
Economic
Forecast,
30,
a Later Recession
Forecast.
Please explain the source of each forecast, including, for example, the availability
for review and inspection,
lb)
Baseline
at page 53, lines 19 through
the publication,
and publication
date.
Is it correct that the Postal Service revenue and cost projections
based
on the Baseline
Forecast?
Please confirm,
in this case are
and if you are unable
to
confirm, please explain.
(4
Please
state what the revenue
Recession
and cost projections
would
be under
a Late
forecast.
Please state what the revenue and cost projections
would be under a Pessimistic
forecast.
(4
Are there other available
forecasts
which are more optimistic
and which were
available to you at the time of the filing of testimony?
(0
If your answer to “e” is “yes”, please state what the revenue and cost projections
would be.
(9)
Are there other available forecasts
which are more pessimistic
available to you at the time of the filing of the testimony?
and which were
-4-
Docket No. RZOOI-1
(h)
If your answer to “g” is “yes”, please state what the revenue and cost projections
would be.
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the foregoing
participants
of record in this proceeding
practice.
Washington, DC.
October 31,200l
20268-0001
in accordance
document
upon all
with Rule 12 of the rules of