UNITED STATES OF AMERICA
Before The
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
Postal Rate and Fee Changes, 2001
Docket No. R2001-1
)
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES
TO UNITED STATES POSTAL SERVICE
(0cA/usPs-99-105)
October 19.2001
Pursuant
to Rules
Commission,
requests
25 through
28 of the Rules
the Office of the Consumer
for production
OCAIUSPS-1-21
of documents.
dated September
Advocate
Instructions
of Practice
of the
Postal
Rate
hereby submits interrogatories
and
included, with OCA interrogatories
28, 2001, are hereby incorporated
Respectfully
submitted,
p-E
b-J+/
SHELLEY S. DREIFUSS
Acting Director
Office of the Consumer Advocate
FREDERICK
Attorney
1333 H Street, N.W.
Washington, D.C. 20268-0001
(202) 789-6830; Fax (202) 789-6819
by reference.
E. DOOLEY
-2-
Docket No. R2001-1
OCAIUSPS-99.
The
following
refers
to the
attachment
to the
response
of
DFCIUSPS-1.
(a)
Please provide a copy of “Video Report - Air Carrier Reliability,”
Final Report Number TV-VR-01-001,
lb)
Please provide
Center Network,”
Project Number 01 NAOOlTROOl.
a copy of “Transition
issued g/28/01,
issued g/7/01,
Planning
for the Priority Mail Processing
Final Report Number
MK-AR-01-003,
Project
Number 00NA016MK000.
OCA/USPS-100.
The following table comes from information
in response to DFCIUSPS-5
Priority
and First-Class
and DFCIUSPS-6.
Single Piece Rate Mail - ODIS
provided by the USPS
Docket No. R2001-1
(a)
-3-
Please confirm that the percentage
Overnight
of mail delivered within the given standard for
Priority Mail has declined
versus FY 2001 - 82%).
source documents
from 1999 to 2001 (e.g., FY 1999 - 85%
If you are unable to confirm, please explain and cite all
used in preparing
your response
and provide a copy if one
has not been previously filed.
(b)
Please confirm that the percentage
Overnight
First-Class
of mail delivered within the given standard for
Single Piece Mail has declined from 1999 to 2001 (e.g., FY
1999 - 93% versus FY 2001 - 91%).
and cite all source documents
If you are unable to confirm, please explain
used in preparing
your response
and provide a
copy if one has not been previously filed.
w
Please confim7 that the percentage
two-day
Priority
of mail delivered within the given standard for
Mail has declined
versus FY 2001 - 68%).
source documents
from 1999 to 2001 (e.g., FY 1999 - 74%
If you are unable to confirm, please explain and cite all
used in preparing
your response
and provide a copy if one
has not been previously filed.
Cd)
Please confirm that the percentage
two-day
First-Class
of mail delivered within the given standard for
Single Piece Mail has declined
1999 - 87% versus FY 2001 - 84%).
and cite all source documents
from 1999 to 2001 (e.g., FY
If you are unable to confirm, please explain
used in preparing
your response
and provide a
copy if one has not been previously filed.
(e)
Please confirm that the percentage
three-day
Priority Mail has declined
versus FY 2001 - 67%).
of mail delivered within the given standard for
from 1999 to 2001 (e.g., FY 1999 - 76%
If you are unable to confirm, please explain and cite all
-4-
Docket No. R2001-1
source documents
used in preparing
your response
and provide a copy if one
has not been previously filed.
(0
Please confirm that the percentage
three-day
First-Class
of mail delivered within the given standard for
Single Piece Mail has declined from 1999 to 2001 (e.g., FY
1999 - 85% versus FY 2001 - 79%).
and cite all source documents
If you are unable to confirm, please explain
used in preparing
your response
and provide a
copy if one has not been previously filed.
kl)
Please confirm that a comparison
of the average days to deliver overnight
indicates that for FY 1999 to FY 2001, First-Class
Priority Mail (e.g., FY 2001: First-Class
Mail takes less time than does
SP - 1 .I versus Priority - 1.3 days).
you are unable to confirm, please explain and cite all source documents
preparing
(h)
mail
If
used in
your response and provide a copy if one has not been previously filed.
Please confirm that a comparison
of the average
indicates that for FY 1999 to FY 2001, First-Class
Priority Mail (e.g., FY 2001: First-Class
days to deliver two-day
mail
Mail takes less time than does
SP - 2.0 versus Priority - 2.5 days).
you are unable to confirm, please explain and cite all source documents
If
used in
preparing your response and provide a copy if one has not been previously filed.
0)
Please confirm that a comparison
of the average days to deliver three-day
indicates that for FY 1999 to FY 2001, First-Class
Priority Mail (e.g., FY 2001: First-Class
Mail takes less time than does
SP - 3.0 versus Priority - 3.4 days)?
you are unable to confirm, please explain and cite all source documents
preparing
mail
If
used in
your response and provide a copy if one has not been previously filed.
Docket No. R2001-1
(j)
-5-
Please provide copies of all studies, reports and/or analyses
reasons
why postal patrons
piece weighing
choose
Priority
Mail, paying
performed
on the
more to mail a mail
up to 13 oz. as Priority Mail (up to 1 lb. = $3.50), as opposed
mailing the same item at the lower First-Class
to
Single Piece rate (13 oz. = $3.10
($0.34 +(12*$0.23))).
0cA/usPs-101.
Parts of the following
Mayo as OGVUSPS-T36-7.
interrogatory
She responded
that she was not aware of any processing
centers with scanners that are not compatible
object of this interrogatory
information
is to determine
Processing
(4
with the signature
and Distribution
Center
Therefore,
Certified
Program.
equipment
please refer to an advisory
at the Los Angeles
(Report Number AC-MA-01-002).
and Distribution
that is not compatible
Center (P&DC) that
with the Signature
Capture
Include in your response the volume of Certified Mail impacted
lack of compatible
The
has in its possession
Mail Observations
Please identify each and every Processing
has scanning
capture program.
if the PoStal Service
of which witness Mayo was unaware.
report issued May 2, 2001 regarding
were asked of USPS witness
scanning
equipment
specific
cites to all source
documents
include
a copy of each
source
during FY 2000 and FY 2001.
used in preparing
document
referenced
by the
Provide
your response
if one
and
has not been
previously filed in this docket.
lb)
For each P&DC that employs the old scanning equipment
this interrogatory,
identified in part “a” of
please explain whether or not the P&DC currently participates
in the Signature Capture Program.
Provide specific cites to all source documents
Docket No. R2001-1
-6.
used in preparing
referenced
(c)
your response
and include a copy of each source document
if one has not been previously filed in this docket.
Referring to part “b” of this interrogatory,
currently
participate
in the Signature
the problem of incompatible
resolved,
Capture Program,
equipment
and (2) how the resolution
expected,
for each and every P&DC that does not
please identify: (1) when
links with the national database
will be accomplished.
please explain why no resolution
If no resolution
will be achieved.
cites to all source documents
used in preparing
copy of each source document
referenced
will be
Provide
your response
is
specific
and include a
if one has not been previously
filed in
this docket.
(4
Please
currently
identify each and every non-P&DC
handles
incompatible
Certified
reference
(e)
Capture
used in preparing
Program.
your response
equipment”
that is
Provide specific cites to all
and include a copy of each
used if one has not been previously filed in this docket.
For each non-P&DC
that employs the old scanning
“d” this interrogatory,
participates
please explain
in the Signature
source documents
source document
(0
unit or facility that
Mail and uses the “old scanning
with the Signature
source documents
Postal Service
Capture
used in preparing
referenced
whether
participate
identified
or not the non-P&DC
Program.
your response
Provide
specific
in part
currently
cites to all
and include a copy of each
if one has not been previously filed in this docket.
Referring to part “e” of this interrogatory,
not currently
equipment
in the Signature
when the problem of incompatible
for each and every non-P&DC
Capture
equipment
Program,
that does
please identify: (1)
links with the national database will
-7-
Docket No. R2001-1
be resolved, and (2) how the resolution will be accomplished.
expected,
please explain why no resolution
If no resolution
will be achieved.
cites to all source documents
used in preparing
copy of each source document
referenced
your response
Provide
is
specific
and include a
if one has not been previously filed in
this docket.
(9)
For each year, FY 2000 and FY 2001, please provide: (1) the number of Certified
Mail
transactions
percentage
in which
of Certified
equipment”
scanning
Mail transactions
used; and (3) information
scanning
“old
equipment”
was
in which “old scanning
used;
(2)
equipment”
the
was
sufficient to show the revenue impact of using the “old
that was not linked to the national
specific
cites to all source
include
a copy of each
documents
source
used in preparing
document
referenced
database.
Provide
your response
and
if one has not been
previously filed in this docket.
OCNUSPS-102.
For each of the past three years and for each category
or type of
Express Mail for which the Postal Service collects data, please provide nationwide
from ODIS, EMRS, and any other applicable
(a)
The percentage
by the applicable
systems showing:
of the time mail is delivered within the number of days specified
service standard;
(b)
The average number of days to delivery; and
(cl
The full calculation
interrogatory
represents.
data
including
for each
figure
a description
requested
in parts
“a” and “b” of this
of what each figure used in the calculation
Please provide cites to source documents
for all figures presented
in
-a-
Docket No. R2001-1
calculations
and provide copies of the document
if one has not been previously
filed in this docket.
OCANSPS-103.
For each of the past three years and for each category
(a) Express Mail, (b) Priority Mail and (c) First-Class
nationwide
service standard.
for mail delivered
In your response,
including a description
Please
provide
cites to source
systems showing
by the applicable
- volume, percentage
within 1 to 15 days after the applicable
each figure requested
represents.
beyond of the number of days specified
Please provide the frequency
for each of the fifteen days.
calculations
single piece letters, please provide
data from ODIS, EMRS, EXFC and any other applicable
the amount of mail delivered
or type of
and average -
service standard,
broken out
please include the full calculation
for
of what each figure used in the calculation
documents
and provide copies of any documents
for all figures
presented
in
that have not been previously filed in
this docket.
OCANSPS-104.
The following refers to the Postal Service responses
5 and DFCYUSPS-6.
Postal
Service’s
Please provide the full calculation
response
calculation
represents.
presented
in calculations
including
Please
a description
provide
and provide
to DFCNSPS-
of each figure provided
of what each figure
cites to source
documents
copies of any documents
in the
used in the
for all figures
that have not been
previously filed in this docket.
OCALJSPS-105.
For each of the past three years and for each of the data systems
that collect data on (a) Express Mail, (b) Priority Mail, and (c) First-Class
Mail, please
DocketNo.R2001-1
-9-
provide a definition of (1) the point of entry into the data collection system (for example,
deposit of an envelope
into a mailbox) and (2) the point of exit from the data collection
system (for example, arrival of a piece of mail at the destination
physical
delivery
documents
(4
to the addressee’s
residence).
Please
Postal Service facility or
provide
cites
to source
and provide copies if one has not been previously filed in this docket.
If the point of entry and/or the point of exit used in the data system(s)
differs from
that used to calculate
provide
alternative
definitions
each alternative
system(s).
Postal Service’s
used to calculate
definition
service standards,
please
the service standards
differs from the definition
Please provide cites to source documents
the
and identify how
used in the applicable
data
and provide copies if one
has not been previously filed in this docket.
(b)
Referring to part “a” of this interrogatory,
for each alternative
documents
for the adoption
that discuss
the reason(s)
Please provide cites to these documents
previously filed in this docket.
definition,
of different
identify all
standards.
and provide copies if one has not been
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
October 19,200l
in accordance
document
upon all
with Rule 12 of the rules of