RECEIVE11
UNITED STATES OF AMERICA
Before The
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
Postal Rate and Fee Changes,
2001
NW16
pas,,?;.;c:,it /::,.I:~::~.;;:t
OFFICE
5: Tl;.. Lc::,;i i,:,:i.
Docket No. R2001-1
)
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES
TO UNITED STATES POSTAL SERVICE
WITNESS LINDA A. KINGSLEY
(OCAIUSPS-T39-1-8)
November 16,200l
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
28.2001,
Respectfully
and
included with OCA interrogatories
are hereby incorporated
SHELLEY S. DREIFUSS
Acting 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 the Postal Rate
hereby submits interrogatories
submitted,
I 43PM ‘01
by reference.
Docket No. RZOOI-1
-2-
OCAAJSPS-T39-1.
Please refer to the response to OCAIUSPS-145.
a.
Do you agree with the response of the Postal Service to OCAAJSPS-145(a-i)?
you do not agree with any response,
please provide your response.
If
If you do
agree, please reconcile your response with the response to UPS/USPS-T39-3.
b.
Refer to the response to part a.
i.
Please define “throughput.”
ii.
Please provide a numeric example showing the calculation
If there are alternative calculations
alternative
.
III.
C.
please show these
caloulations.
Please identify the calculation
predominately,
iv.
for throughput,
of throughput.
of throughput
from subpart ii. used, or used
by the Postal Service.
Does the calculation
of throughput
differ based upon the type of
automated
mail processing
equipment?
throughput
for each type of automated
If yes, show the calculation
mail processing
of
equipment
Refer to the response to part a.,. where it states “there are inherent differences
piece characteristics
throughput.”
characteristics”
between First-Class
Mail and Standard
Mail that affect
Please confirm that the phrase “inherent differences
refers to physical characteristics.
in
in piece
If you do not confirm, please
explain.
d.
Refer to the response to part a., where it states “there are inherent differences
piece characteristics
throughput.”
between First-Class
Mail and Standard Mail that affect
in
‘Docket No. R2001-1
i.
-3-
Please identify all inherent differences
automation
compatible,
letter-shaped
processed
barcoded
in mailpiece characteristics
First-Class
Mail and Standard
pieces weighing one ounce that affect throughput
for
Mail
when
on the Delivery Bar Code Sorter (DBCS), the Mail Processing
Bar Code Sorter (MPBCS),
and the Carrier Sequence
Bar Code Sorter
(CSBCS).
ii.
Please indicate whether each inherent difference
characteristics
compatible,
in mailpiece
identified in subpart i. with respect to automation
barcoded First-Class
Mail and Standard
Mail letter-shaped
pieces weighing one ounce has a positive or negative impact on
throughput
when processed
on the DBCS, MPBCS and CSBCS.
Please
explain the basis for indicating ‘any positive or negative impact.
..
III.
Please separately
rank the positive and negative impacts indicated in
subpart ii. from most important to least important for the DBCS, MPBCS
and CSBCS.
iv.
Please identify which (if any) of the positive and negative impacts from
subpart iii. have been specifically
Postal Service in the calculation
compatible,
barcoded
First-Class
estimated, quantified,
of throughputs
or modeled by the
with respect to automation
Mail and Standard Mail letter-shaped
pieces weighing one ounce processed
on the DBCS, MPBCS and
CSBCS.
e.
Refer to the response to part a., where it states that “First-Class
Standard
Mail are sometimes
processed
on different sort plans.”
Mail and
Please confirm
,Docket No. RZOOI-1
-4.
that the phrase “different sort plans” refers to the first pass in Delivery Point
Sequencing
f.
(DPS) on the DBCS and MPBCS.
If you do not confirm, please
Refer to the response to part a.
i.
Please identify any factors (other than inherent differences
characteristics)
related to automation
Mail and Standard
affect throughput
ii.
Mail letter-shaped
when processed
compatible,
barcoded
in mailpiece
First-Class
pieces weighing one ounce that
on the DBCS, MPBCS and CSBCS.
Please indicate whether each factor identified in subpart i. with respect to
automation
compatible,
letter-shaped
First-Class
Mail and Standard
Mail
pieces weighing one ounce has a positive or negative
impact on throughput
CSBCS.
barcoded
when processed
on the DBCS, MPBCS and
Please explain the basis for indicating any positive or negative
impact.
Ill.
Please separately
rank the positive and negative impacts indicated in
subpart ii. from most important to least important for the DBCS, MPBCS
and CSBCS.
iv.
Please identify which (if any) of the positive and negative impacts from
subpart iii. have been specifically
estimated,
Postal Service in the calculation
of throughputs
compatible,
barcoded
First-Class
with respect to automation
Mail and Standard Mail letter-shaped
pieces weighing one ounce processed
CSBCS.
quantified, or modeled by the
on the DBCS, MPBCS and
-5-
Docket No. R2001-1
9.
Refer to the response to part a. To what extent are automation
barcoded “First-Class
ounce] sometimes
CSBCS?
Mail and Standard
processed
Mail [letter-shaped
compatible,
pieces weighing one
on different sort plans” on the DBCS, MPBCS, and
Please provide the frequency,
or an estimate of the frequency,
with
which this occurs for DBCS, MPBCS, and CSBCS processing.
h.
Refer to the response to part a. To what extent do “The First-Class
[for automation
compatible,
barcoded
letter-shaped
pieces weighing one ounce]
likely involve the use of more stackers” as compared to automation
barcoded Standard
Mail letter-shaped
provide the frequency,
sort plans
compatible,
pieces weighing one ounce?
or an estimate of the frequency,
Please
with which this occurs for
DBCS, MPBCS, and CSBCS processing.
i.
Refer to the response to part a., where it states that “First-Class
Standard
Mail are sometimes
processed
of different sort plans for automation
on different sort plans.” Would the use
compatible,
shaped pieces weighing one ounce vs. automation
Standard
Mail letter-shaped
impact on the throughputs
Mail and
barcoded
First-Class
compatible,
letter-
barcoded
pieces weighing one ounce produce a small or large
of the DBCS, MPBCS, and CSBCS?
and provide copies of any studies, reports, other documents,
Please explain
or communications
that support the explanation.
j.
Refer to the response to part a. In the absence of “any testing conducted
quantify the impacts of these differences
on equipment
provide copies of any studies, reports, other documents,
throughputs,”
to
please
or communications
that
Docket No. RZOOI-1
-6.
discuss the impact of different First-Class
Mail and Standard
Mail sort plans on
throughput.
k.
Refer to the response to part a. Please confirm that it is possible for two groups
of 10,000 automation
compatible,
barcoded letter-shaped
pieces weighing one
ounce to be identical in every respect (including content and mailing addresses),
except that one group paid a First-Class
rate and the other paid a Standard
Mail
Regular rate. If you do not confirm, please explain.
I.
Refer to the response to part a. Would your response to the hypothetical
in part a. change if the group that paid the First-Class
posed
rate were entered in bulk?
Please explain.
m.
Refer to the response to part b. Please confirm that “the differences
in part (a)” refer to the “inherent differences
First-Class
n.
Mail and Standard
between
Mail.” If you do not confirm, please explain.
Refer to the response to part b. “[Albsent testing,” please provide copies of any
studies, reports, other documents,.or
different First-Class
0.
in piece characteristics
spelled out
communications
Mail and Standard
that discuss the impact of.
Mail sort plans on productivities.
Refer to the response to part c. Please confirm that it is possible for two groups
of 10,000 automation
compatible,
barcoded letter-shaped
pieces weighing one
ounce and identical in every respect (including content and mailing addresses),
with one group paying a First-Class
Regular rate, to be processed
explain.
rate and the other paying a Standard
Mail
on the same tour. If you do not confirm, please
-7-
,Docket No. RZOOI-1
P.
Refer to the response to part d. Refer also to the hypothetical
OCANSPS-145(a).
compatible,
barcoded
Please quantify the effect on the unit cost of automation
First-Class
and Standard Mail letter-shaped
weighing one ounce caused by the changes in throughput
part a. when such mail is processed
on the DBCS.
the unit cost when such mail is processed
q.
posed in
cited in response to
Please quantify the effect on
on the MPBCS and CSBCS.
Refer to the response to part d. Refer also to the hypothetical
OCANSPS-145(b).
compatible,
barcoded
pieces
posed in
Please quantify the effect on the unit cost of automation
First-Class
and Standard Mail letter-shaped
weighing one ounce caused by the changes in productivity
part b. when such letter-shaped
pieces are processed
pieces
cited in response to
on the DBCS.
quantify the effect on the unit cost when such letter-shaped
Please
pieces are processed
on the MPBCS and CSBCS.
r.
Refer to the response to part d. Refer also to the hypothetical
OCANSPS-145(c).
and Standard
Assuming the automation
Mail letter-shaped
compatible,
posed in
barcoded
First-Class
pieces weighing one ounce are processed
in
one tour, please quantify the effect on the unit cost when such letter-shaped
pieces are processed
on the DBCS.
when such letter-shaped
OCANSPS-T39-2.
a.
Please quantify the effect on the unit cost
pieces are processed
on the MPBCS and CSBCS.
Please refer to the response to OCAIUSPS-149,
parts d and h..
Do you agree with the response of the Postal Service to OCAAJSPS-149?
do not agree with any response thereto, please provide your response.
If you
-6-
Docket No. R2001-1
b.
Refer to the response
to part d.
densities for First-Class
and Standard
purposes
of USSP-LR-J-60,
operations
for First-Class
same.
C.
Regular letter-shaped
the
and Standard
sort
schemes
Regular
mail flow
pieces assumes, for
and
letter-shaped
mail
processing
pieces are the
If you do not confirm, please explain.
Refer to the response
to part d.
volume variable productivities
pieces assumes,
and Standard
operations
OCANSPS-T39-3.
that “experience
a.
that
Please confirm that the identical
for purposes
for First-class
that the identical
and Standard
of USSP-LR-J-60,
Regular letter-shaped
are the same.
Please confirm
Regular letter-shaped
that the costs for First-class
pieces undergoing
the same mail processing
If you do not confirm, please explain.
Please refer to the response to OCNUSPS-165(a),
in operations
marginal
where it states
indicates that cards jam less frequently than letters.”
Do you agree with the response of the Postal Service to OCANSPS-165?
If you
do not agree with any response thereto, please provide your response.
b.
Please
provide
the frequency,
automation
compatible,
compatible,
barcoded
barcoded
or an estimate
cards weighing
letters weighing
of the frequency,
one ounce
of jams for
and automation
one ounce for the DBCS, MPBCS,
and
CSBCS.
OCANSPS-T39-4.
a.
Please refer to the response to OCANSPS-167.
Do you agree with the response of the Postal Service to OCAIUSPS-167?
do not agree with any response thereto, please provide your response.
If you
‘Docket No. R2001-1
b.
-9-
Refer to the response
to part I. Please confirm that full trays of manual letters
from bulk mailers marked for manual processing
not be separated
proposed
into trays of nonmachinable
surcharge
pursuant to DMM M130.1.5
letter-shaped
will
pieces subject to the
and trays of other manual letter-shaped
pieces.
If you do
not confirm, please explain.
C.
Refer to the response to part o., where it states that “The Test Year Before Rates
volume
includes
only the nonstandard
[volume] includes both the nonstandard
pieces and the Test Year After Rates
and non-machinable
[pieces].”
For the
Test Year After Rates, please provide volume of pieces that are nonstandard
the volume of pieces that are nonmachinable.
d.
Refer to the response
sweeper
will
proposed
surcharge
and
Show all calculations.
to part p. Please confirm that neither the feeder nor the
separate
nonmachinable
from other manual
letter-shaped
pieces
letter-shaped
pieces.
subject
to the
If you do not
confirm, please explain.
e.
Refer tomthe response
shaped
to part p.
pieces subject to the proposed
Due” by the feeder or the sweeper.
f.
Refer to the response
appear
through
letter-
will not be marked “Postage
If you do not confirm, please explain.
piece, that does not imply that it was processed
the entire automated
that every nonstandard
automated
surcharge
that nonmachinable
to part r., which states that “Even though a barcode may
on a non-standard
successfully
position
Please confirm
mail processing
(current
operations?
system.”
definition)
Is it the Postal Service’s
piece is “captured”
Please explain.
during
.Docket No. RZOOI-1
9.
-IO-
Refer to the response to part u. Please identify all “processing
title that have, or could have, responsibility
letter-shaped
h.
for handling
and processing
to part u.
Please
identify the “processing
identified in part f. above by job title that have responsibility
on
proposed
nonstandard/nonmachinable
surcharge.
or providing
by job
manual
pieces.
Refer to the response
Due”
personnel”
letter-shaped
instruction,
to the identified processing
for marking “Postage
pieces
Please provide any documentation
personnel”
subject
to
the
assigning responsibility,
personnel
that supports
any
claimed identity.
OCNUSPS-T39-5.
a.
Please
Please refer to LR58ASP.xls
confirm
that 74.99
percent
sheet “volume&lbs.”
of single-piece
First-Class
letter-shaped
pieces weigh 0.5 ounces or less. If you do not confirm, please explain.
b.
Please
confirm
that
19.93
percent
of single-piece
First-Class
letter-shaped
pieces weigh more than 0.5 ounce and less than or equal to 1 .O ounce.
If you do
not confirm, please explain.
OCAIUSPS-T39-6.
a.
Please refer to LR58PRE.xls,
sheet “volume&lbs.”
Please confirm that 38.01 percent of presorted
First-Class
letter-shaped
pieces
weigh 0.5 ounces or less. If you do not confirm, please explain.
b.
Please confirm that 59.30 percent of presorted
First-Class
letter-shaped
weigh more than 0.5 ounce and less than or equal to 1.0 ounce.
confirm, please explain.
pieces
If you do not
0ocket
-11.
No. R2001-1
OCAKJSPS-T39-7.
a.
Please
Please refer to LR58AREG.xls,
confirm
that 35.00 percent
sheet “volume&lbs.”
of Standard
Regular
letter-shaped
pieces
weigh 0.5 ounces or less. If you do not confirm, please explain.
b.
Please
confirm
that 48.48
percent
of Standard
Regular
letter-shaped
weigh more than 0.5 ounce and less than or equal to 1.0 ounce.
pieces
If you do not
confirm, please explain.
OCAAJSPS-T39-8.
OCABJSPS-146,
the Postal
Please
refer to the response
147, 162, 163, 166, and 168-171.
Service
to interrogatories
to the following
interrogatories:
Do you agree with the response of
listed above?
If you do not agree with any
response thereto, please provide your response.
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
November 16,200l
in accordance
document
upon all
with Rule 12 of the rules of