RECEIVED
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20266-0001
Nov7
4 37 PM‘01
POSTAL RATE CLiMH,$S,C,i
CFFICEOFTHESECRETARY
POSTAL RATE AND FEE CHANGES, 2001
Docket No. R2001-1
RESPONSE OF UNITED STATES POSTAL SERVICE
WITNESS PATELUNAS TO INTERROGATORY OF
DIRECT MARKETING ASSOCIATION, INC. REDIRECTED
FROM WITNESS TAYMAN
(MPA/USPS-TG-13)
The United States Postal Service hereby provides the response of witness
Patelunas to the following interrogatory of Direct Marketing Association, Inc.:
DMAAJSPS-TG-13, filed on October 19, 2001, and redirected from witness Tayman.
The interrogatory is stated verbatim and is followed by the response.
Respectfully submitted,
UNITED STATES POSTAL SERVICE
By its attorneys
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking:
Susan M. Duchek
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-l 137
(202) 266-2990; Fax -5402
November 7,200l
RESPONSE OF UNITED STATES POSTAL SERVICE
WITNESS PATELUNAS TO INTERROGATORIES OF
DIRECT MARKING ASSOCIATION, INC.
(REDIRECTED FROM WITNESS TAYMAN)
DMAIUSPS-TG-13. Please refer to Exhibit G of USPS-LR-J-49 where you
identify $350 million in FY 01, $400 million in FY 02, and $350 million in FY 03 of
Other Program Breakthrough Productivity savings.
(a) Please describe all initiatives that the Postal Service includes in the
Breakthrough Productivity Other Program.
(b) Please provide in an electronic spreadsheet format a disaggregation of the
Other Program Breakthrough Productivity savings by fiscal year, cost segment,
mail class, and mail subclass.
Response:
(4
The total Other Program Breakthrough Productivitiy savings shown in
Exhibit G of USPS-LR-J-49 consist of the initiatives shown in Exhibits A - C of
USPS-LR-J-49. There are also Cost Reduction Breakthrough Productivity
savings and these are shown at pages 1 - 3. The individual initiatives by cost
segment are:
2
3
6l7
10
11
12
16
16
Total
supv.
Clk/MH.
City Cam
Rural Car.
Maint.
MVS
Sup/Sew.
Admin.
Exhibit A
(FY7001)
Exhibit B
LFY7002l
Exhibit C
~~~2003)
0
172,500
77,500
69,000
123,695
99,932
16,566
9,650
26,154
2,000
46,636
399,637
50,000
110,443
89,225
16,579
8,616
25,138
0
49,663
349,684.
:
0
1,000
99,063
350.063
RESPONSE OF UNITED STATES POSTAL SERVICE
WITNESS PATELUNAS TO INTERROGATORIES OF
DIRECT MARKING ASSOCIATION, INC.
(REDIRECTED FROM WITNESS TAYMAN)
Response continued:
COST REDUCTIONS
G.s
-IaL
f4
Trans.
15
Bldg Oct.
Total
Ex E. Page1
(FEll
Ex. E Page 2
W’OQ2l
Ex. E Page 3
W’OW
100,000
40,000
140,000
30,000
42,000
72,000
60,000
40,000
100,000
Grand Total of
Other Programs &
490,063
Cost Reductions
471,673
449,664
See also the responses of witness Tayman to DMALJSPS-TG-25,30 and 32.
(b)
Please refer to Attachment 1 that accompanies this response. The
attachment shows where the requested information can be found in both
hardcopy and electronic formats.
0
L
It
DECLARATION
I, Richard Patelunas, declare under penalty of perjun/ that the foregoing answers to
interrogatories
are true and correct to the best of my knowledge, information, and
belief.
.
CERTIFICATE OF SERVICE
I hereby certify that I have this day served the foregoing document upon all
participants of record in this proceeding in accordance with section 12 of the Rules of
Practice.
/&LJf.Qd
Susan M. Duchek
475 L’Enfant Plaza West, S.W.
Washington, D.C.,20260-1137
(202) 266-2990; Fax -5402
November 7.2001