RECEIVE9
UNITED STATES OF AMERICA
Before The
POSTAL RATE COMMISSION
Postal Rate and Fee Changes
JUH
23 1217
Pi!
‘00
Docket No. R2000-1
)
ANSWERS OF THE OFFICE OF THE CONSUMER ADVOCATE
TO INTERROGATORIES
OF THE MAJOR MAILERS ASSOCIATION
WITNESS: JAMES F. CALLOW (MMA/OCA-TG-1-5)
(June 23,200O)
The Office of the Consumer
Callow to interrogatories
Advocate
MMA/OCA-TG-1-5,
hereby submits the answers
dated June 9, 2000.
stated verbatim and is followed by the response,
Respectfully submitted,
TED P. GERARDEN
Director
Office of the Consumer
Advocate
EMMETT RAND COSTICH
Attorney
1333 H Street, N.W.
Washington, D.C. 20268-0001
(202) 789-6830; Fax (202) 789-6819
of James F
Each interrogatory
is
ANSWERS OF OCA WITNESS JAMES F. CALLOW
TO INTERROGATORIES
MMA/OCA-TG-I-5
Please refer to page 8 of your prepared testimony, specifically
MMA/OCA-TG-1
Table 1 and the graph identified as Figure 1, both entitled “Comparison Of First Class
Please provide a similar table and graph
Letters And Total Average Cost Coverage.”
showing, for the same time periods, the implicit cost coverages (separately) for FirstClass Single Piece and First-Class Presorted Letters and the average total cost
coverage
RESPONSE
TO MMA/OCA-TG-1
Figure 1: Comparison of Single-Piece and Presorted FirstClass Letters and Total Average Cost Coverage
-Sngl-PC
+Presort
-Total
1988
1989
1990
1991
1992
1993
1994
1995
Years
1996
1997
1998
1999
2000
2001
ANSWERS OF OCA WITNESS JAMES F. CALLOW
TO INTERROGATORIES
MMA/OCA-TG-1-5
MMAIOCA-TG-2
Please refer to page 9 of your prepared testimony, specifically
Table 2 and the graph identified as Figure 2, both entitled “First Class Letter Mark-Up
Index.” Please provide a similar table and graph showing, for the same time periods,
the implicit mark up indices (separately) for First-Class Single Piece and First-Class
Presorted Letters.
RESPONSE
TO MMA/OCA-TG-2
Figure 2: Single-Piece and Presorted
Mark-Up Indices
First-Class
Letters
3’ooo
m
i 2.000
11-j
-Sng1-PC
f 1.500
+Presorl
I
+Tolal
1.000
1988
1989
1990
1991
1992
1993
1994
1995
YeWS
1996
1997
1998
1999
2000
2001
J
ANSWERS OF OCA WITNESS JAMES F. CALLOW
TO INTERROGATORIES
MMA/OCA-TG-1-5
MMAIOCA-TG-3
Please refer to page 11 of your prepared testimony, specifically
Table 3 and the graphs identified as Figure 3. both entitled “First-Class Letter Cost
Coverage Index.” Please provide a similar table and graph showing, for the same time
periods, the implicit cost coverage indices (separately) for First-Class Single Piece and
First-Class Presorted Letters.
RESPONSE
TO MMAIOCA-TG-3
Figure 3: Single-Piece
and Presorted First-Class
Cost Coverage Indices
Letters
1.800
1.600
E
e
1.400
ii
F
:
1.200
:
g
3
Sngl-PC
+Presort
-Total
1.000
0.800
0.600
1988
1989
1990
1991
1992
1993
1994
1995
Years
1996
1997
1998
1999
2000
2001
ANSWERS OF OCA WITNESS JAMES F. CALLOW
TO INTERROGATORIES
MMA/OCA-TG-1-5
MMAIOCA-TG-4
Please refer to page 13 of your prepared testimony, specifically
Table 4 and the graph identified as Figure 4, entitled respectively “Comparison Of FirstClass Letter Mark-Up Index To Average And Recommended
Mark-Up Indices” and
“Comparison
Of First-Class Letter Mark-Up Index To Average And Recommended.”
Please provide a similar table and graph showing, for the same time periods, the
implicit mark-up indices (separately)
for First-Class Single Piece and First-Class
Presorted Letters, compared to the average and recommended mark-up indices.
RESPONSE
TO MMA/OCA-TG-4
Figure 4: Comparison
of Single-Piece
and Presorted FirstClass Letters Mark-Up Indices to Recommended
and
Average Indices
2.750
,
I
2.500
-Sngl-PC
c 2.000
i: 1.750
+Pres0rt
-Recom'd
:
i
i
I
-Average
1.500
1.250
1.000
0.750
0.500
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
ANSWERS OF OCA WITNESS JAMES F. CALLOW
TO INTERROGATORIES
MMA/OCA-TG-1-5
MMA/OCA-TG-5
Please refer to page 14 of your testimony, specifically Table 5 and
the graph identified as Figure 5, entitled respectively “Comparison Of First-Class Letter
Cost Coverage Index To Average And Recommended
Indices” and “Comparison Of
First-Class Letter Cost Coverage Index To Average And Recommended.“.
Please
provide a similar table and graph showing, for the same time periods, the implicit cost
coverage indices (separately) for First-Class Single Piece and First-Class Presorted
Letters, compared to the average and recommended cost coverage indices.
RESPONSE
TO MMAIOCA-TG-5
Figure 5: Comparison
of Single-Piece
and Presorted FirstClass Letters Cost Coverage Indices to Recommended
and
Average Indices
1.750
1~500
2
E
;
z
z
g
L)
-Sngl-PC
1,250
+PresorI
P
1.000
4_
g
J
0.750
0.500
1988
-Recom'c
*Average
1989
1990
1991
1992
1993
1994
1995
Years
1996
1997
1998
1999
2000
2001
DECLARATION
I, James
interrogatories
F. Callow,
MMA/OCA-TG-1-5
the best of my knowledge,
Executed
declare
6 -23
--oa
under
penalty
of perjury
of the Major Mailers Association
information
and belief.
that the answers
to
are true and correct, to
CERTIFICATE
I hereby
participants
OF SERVICE
certify that I have this date served the foregoing
of record in this proceeding
Practice.
Washington, DC 20268-0001
June 23.2000
in accordance
document
upon all
with Section 12 of the Rules of