UNITED STATES OF AMERICA
Before The
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
Postal Rate and Fee Changes,
2000
)
RECEIVE9
flUR23
IO 10
AH‘00
Docket No. R2000-1
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES
TO UNITED STATES POSTAL SERVICE
WITNESS: DONALD M. BARON
(OCA/USPS-T12-11-16)
March 23,200O
Pursuant
Commission,
requests
to sections
26 and 27 of the Rules of Practice of the Postal Rate
the Office of the Consumer
for production
OCA/USPS-1-14
of documents.
Advocate
Instructions
hereby submits interrogatories
included with OCA interrogatories
dated January 24, 2000, are hereby incorporated
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
and
by reference.
.
-2-
Docket No. R2000-1
OCANSPS-Tl2-11.
Please refer to your testimony at page 32, lines 14-17, where you
note that witness Raymond
(USPS-T-13)
activity category of each tally.”
(4
assigned
a variable defining the “street time
Regarding the assignment
of these variables:
Did you review the ES tallies to identify whether or not they could be accurately
assigned
to relevant street-time
categories?
If yes, please discuss in detail the
extent and results of your review.
(b)
Of the various
hierarchy,
street-time
resolution,
(4
levels and codes
did you identify any that could not be assigned
activity
category?
if any, concerning
If yes, please
appropriate
discussions
work-sampling
readily to a particular
identify them and discuss
the
assignment.
Did you discuss or establish with witness
ES tallies to street-time
(4
used in the Outside/Street
Raymond any protocols
activity categories?
for assigning
If yes, please describe
fully these
or protocols.
In your opinion, is the nature of the ES tallies and their relation or assignment
street-time
activity categories
answer in detail.
OCANSPS-T12-12.
Time Sampling
open to interpretation?
to
If yes, please explain your
If no, why not?
Based upon your knowledge
and understanding
(STS) study and the Engineered
Standards/Delivery
of the 1986 Street
Redesign
(ES)
study:
(a)
Were the STS and ES studies designed
any similarities or dissimilarities
for similar purposes?
you identify.
Please explain
.
Docket No. R2000-1
(b)
-3-
Were the route sampling
procedures
any similarities or dissimilarities
(4
Did the sampling procedures
distribution
of route types
dissimilarities
Cd)
similar for both studies?
Please explain
you identify.
employed
in the STS and ES studies yield a similar
by ZIP code?
Please explain
any similarities
or
you identify.
Were the processes
for observing
in both the STS and ES studies?
and collecting data on carrier activities similar
Please explain any similarities or dissimilarities
you identify.
(4
In your opinion,
study between
assuming
the Postal Service had implemented
a “new STS”
October 1996 and April 1998 using the same approach
as in the
1986 STS study, would this new STS study have yielded results consistent
those of the ES study?
OCAAJSPS-T12-13.
Time Variability
with
Please explain your answer fully.
Based upon your knowledge
(LTV) study and the Engineered
and understanding
Standards/Delivery
of the 1985 Load
Redesign
(ES)
study:
(a)
Were the processes
for observing
in both the LTV and ES studies?
and collecting data on carrier activities similar
Please explain any similarities or dissimilarities
you identify.
@I
Is the definition
interpretation
of load time under
and assignment
time applied in the LTV study?
you identify.
the ES study,
as derived
through
of ES tallies, consistent with the definition
Please explain any similarities
the
of load
or dissimilarities
.
.
4
Docket No. R2000-1
OCA/USPS-T12-14.
costs using street-time
OCAAJSPS-T12-15.
costs predicted
1998.
percentages
developed
of Base Year 1998 accrued
load time
from the 1986 STS study.
Please provide estimates
of Base Year 1998 accrued
load time
by the LTV model.
OCAAJSPS-T12-16.
Description
Please provide estimates
Please
refer to Docket
of USPS Development
No. R2000-1,
USPS
LR-I-1,
of Costs bv Segments and Components,
Summary
Fiscal Year
Confirm that the survey, “(1) Street Time Sampling (STS)” cited on page 7-2
refers to the 1986 STS study.
Further confirm that the table appearing
shows the street time sampling
percentages
developed
on page 7-3
from the 1986 STS study.
If
you do not confirm, please explain.
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the foregoing
participants
of record in this proceeding
in accordance
jpf-+4%Washington, D.C. 20268-0001
March 23, 2000
upon all
with section 12 of the rules of
practice.
Stephanie
document
S. Wallace