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UNITED STATES OF AMERICA
Before The
POSTAL RATE COMMISSION
WASHINGTON,
D.C. 20268-0001
Postal Rate and Fee Changes,
2000
Docket No. R2000-1
)
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES
TO UNITED STATES POSTAL SERVICE
WITNESS: LINDA A. KINGSLEY (OCA/USPS-TIO-1-2)
March 17,200O
Pursuant
Commission,
requests
to sections
26 and 27 of the Rules of Practice
the Office of the Consumer
for production
OCAAJSPS-1-14
of documents.
Advocate
Instructions
hereby submits interrogatories
submitted,
TED P. GERARDEN
Director
Office of the Consumer Advocate
EMMETT
Attorney
1333 H Street, N.W.
Washington, D.C. 20268-0001
(202) 789-6830; Fax (202) 789-6819
and
included with OCA interrogatories
dated January 24, 2000, are hereby incorporated
Respectfully
of the Postal Rate
RAND COSTICH
by reference.
-2-
Docket No. R2000-1
OCA/USPS-TIO-I
(4
Please refer to your testimony
at page 8, lines 9-10
What portion of the 88.3 percent of all letters that were barcoded are First-Class
(0
Automation
Presort Letters and Parcels, and
(ii)
Automation
Carrier Route Letters.
(iii)
Please provide the volumes for the mail identified in subparts (i) and (ii) of
this interrogatory.
(b)
What portion of the 88.3 percent of all letters that were barcoded
are Standard
(A) Regular
0)
Automation
Category
Letters, and
(ii)
ECR Subclass
(iii)
Please provide the volumes for the mail identified in subparts (i) and (ii) of
Letters.
this interrogatory.
(c)
Show all calculations
used to derive the “88.3 percent,”
and provide citations for
all figures used in the calculations.
(4
Please confirm that data exists to calculate
in AP 1 through AP 12 of FY 99. If you do not confirm, please explain.
barcoded
63
the percent of all letters that were
Please confirm that data exists to calculate
barcoded
the percent of all letters that were
in AP 1 through AP 13 of Fiscal Years 1996, 1997 and 1998.
If you do
not confirm, please explain.
(9
Please calculate the percent of all letters that were barcoded
Periods
(AP) identified
calculations
for the Accounting
in parts (d) and (e) of this interrogatory.
and provide citations for all figures
Show
used in the calculations.
all
Also
Docket No. R2000-1
please
-3-
provide the data identified
hardcopy and electronic
OCAAJSPS-TIO-2.
in parts (d) and (e) of this interrogatory
in
formats.
Please refer to Chapter
Ill, entitled “Staffing
and Complement,”
of
your testimony.
(4
Please confirm that the single-piece
(0
day of the week,
(ii)
week of the month, and
(iii)
month of the year.
First-Class mail volume fluctuates
by the
If you do not confirm, please explain.
(b)
Please describe
in percentage
the average for subparts
representative
Cc)
Processing
terms the range of fluctuation
above and below
(i), (ii) and (iii) in part (a) of this interrogatory
and Distribution
Please confirm that workshared
0)
day of the week,
(ii)
week of the month, and
(iii)
month of the year.
for several
Centers.
First-Class mail volume fluctuates
by the
If you do not confirm, please explain.
(4
Please describe
in percentage
the average for subparts
representative
(4
Processing
identified
in parts
above and below
(i), (ii) and (iii) in part (c) of this interrogatory
and Distribution
To the extent that fluctuations
Class single-piece
terms the range of fluctuation
for several
Centers.
in volume result in shifts in the proportion
and workshared
of First-
volume, please explain, for each time period
(a) and (c) of this interrogatory,
how plant managers
of
Docket No. R2000-1
Processing
proportion
(9
-4-
and Distribution
of single-piece
Centers plan for and accommodate
and workshared
Please confirm that there are operating
other written guidance
to plant managers
shifts in the proportion of First-Class
other written
confirm,
managers
guidance
please
volume.
manuals,
and provide
instructions
and workshared
manuals, handbooks,
to plant managers
explain
handbooks,
and
on how to plan for and accommodate
single-piece
do confirm, please identify such operating
such shifts in the
and provide
copies
If you
instructions
copies.
of any documents
on how to plan for and accommodate
volume.
and
If you do not
advising
any periodic fluctuations
plant
in mail
volumes.
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
March 17,200O
in accordance
with section
document
upon all
12 of the rules of