UNITED STATES OF AMERICA
Before The
POSTAL RATE COMMISSION
WASHINGTON, D.C. 202680001
Postal Rate and Fee Changes,
2001
Docket No. R2001-1
1
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES
TO UNITED STATES POSTAL SERVICE
(OCA/USPS-161-166)
October 26,200l
Pursuant
Commission,
requests
to Rules 25 through
28 of the Rules of Practice
the Dffice of the Consumer
for production
OCAAJSPS-1-21
of documents.
dated September
Advocate
Instructions
hereby submits interrogatories
and
included with OCA interrogatories
28, 2001, are hereby incorporated
5-u
SHELLEY S. DREIFUSS
Acting Director
Oftice 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
by reference.
-2-
DocketNo.R2001-1
OCANSPS-161.
Please
refer to the response
groups of 10,000 letter-shaped
each letter-shaped
First-Class
rate.
to OCA/USPS44(b).
pieces are identical in every respect.
piece in each group is automation
However,
compatible,
Assume
two
More specifically,
barcoded
and paid a
one group weighs one ounce and the other group weighs
two ounces.
a.
Assume further that the two groups of letter-shaped
pass on the same Delivery
throughputs
and velocities
pieces are processed
Bar Code Sorter (DBCS).
in one
Please confirm that the
for that pass would be the same for each group.
If
you do not confirm, please identify and describe all factors that would cause the
throughputs
b.
Assume
and velocities for each group to differ.
the same
productivities
identify
facts
above
and
in part a.
for each group would be the same.
and describe
all factors
that would
Please
confirm
that the
If you do not confirm, please
cause the productivities
for each
group to differ.
C.
Assume the same facts above and in part a. Please confirm that the wage rates
for each group would be the same.
If you do not confirm,
please identify and
describe all factors that would cause the wage rates for each group to differ.
d.
Assume the same facts above and in part a. Please confirm that the total cost
and the unit cost for processing
each group on the DBCS would be the same.
If
you do not confirm, please identify and describe all factors that would cause the
total and unit costs for each group to differ.
e.
Assume
the same facts above and in part a., except that each group of letter-
shaped pieces is processed
in two passes on the same DBCS.
Please answer
-3.
Docket No. FUOOI-1
parts a., b., c., and d. assuming
processed
f.
Assume
that each letter-shaped
piece in each group is
in two passes on the same DBCS.
the same facts above and in part a., except that each group of letter-
shaped pieces is processed
in two passes on the same DBCS.
that the total cost and the unit cost for processing
cost of each group if processed
Please confirm
each group would be twice the
in one pass on the same DBCS.
If you do not
confirm, please explain.
cl.
Please confirm that the responses
to parts a. through
where the two groups were processed
(MPBCS)
and a Carrier Sequencing
f. would
on a Mail Processing
be the same
Bar Code Sorter
Bar Code Sorter (CSBCS),
respectively.
If
you do not confirm, please explain.
h.
Please confirm that the responses
where
the two groups
consisted
shaped pieces, respectively.
OCNUSPS-162.
Please
Standard
of 100,000,
rate.
be the same
1 million, and 10 million letter-
to OCAAJSPS-44(b).
pieces are identical in every respect.
piece in each group is automation
Mail Regular
g. would
If you do not confirm, please explain.
refer to the response
groups of 10,000 letter-shaped
each letter-shaped
to parts a. through
However,
compatible,
one group weighs
Assume
two
More specifically,
barcoded,
and paid a
one ounce and the other
group weighs two ounces.
a.
Assume further that the two groups of letter-shaped
pass on the same DBCS.
that pass would
pieces are processed
Please confirm that the throughputs
be the same for each group.
in one
and velocities for
If you do not confirm,
please
-4-
Docket No. R2001-1
identify and describe all factors that would cause the throughputs
and velocities
for each group to differ.
b
Assume
the
productivities
identify
same
facts
above
and
in part
for each group would be the same.
and describe
all factors
that would
a.
Please
confirm
that
the
If you do not confirm, please
cause the productivities
for each
group to differ.
C.
Assume the same facts above and in part a. Please confirm that the wage rates
for processing
each group would be the same.
identify and describe
If you do not confirm,
please
all factors that would cause the wage rates for each group
to differ.
d.
Assume
the same facts above and in part a. Please confirm that the total cost
and the unit cost for processing
each group on the DBCS would be the same.
If
you do not confirm, please identify and describe all factors that would cause the
total and unit costs for each group to differ.
e.
Assume
the same facts above and in part a., except that each group of letter-
shaped pieces is processed
in two passes on the same DBCS.
parts a., b., c., and d. assuming
processed
f.
that each letter-shaped
Please answer
piece in each group is
in two passes on the same DBCS.
Assume the same facts above and in part a., except that each group of lettershaped pieces is processed
in two passes on the same DBCS.
that the total cost and the unit cost for processing
cost of each group if processed
confirm, please explain.
Please confirm
each group would be twice the
in one pass on the same DBCS.
If you do not
-5-
Docket No. RZOOI-1
9.
Please
confirm
that the responses
to parts a. through
where the two groups were processed
f. would
be the same
on a MPBCS and a CSBCS, respectively.
If you do not confirm, please explain.
h.
Please confirm that the responses
where
the two groups
consisted
shaped pieces, respectively.
OCAAJSPS-163.
Please
letter-shaped
However,
piece
1 million, and 10 million letter-
to OCANSPS-44(b).
pieces are identical in every respect.
in each
group
is automation
two
More specifically,
and barcoded.
rate, and the other group
Mail Regular rate.
Assume further that the two groups of letter-shaped
pass on the same DBCS.
Assume
compatible
one group weighs one ounce and paid a First-Class
that pass would
g. would be the same
If you do not confirm, please explain.
weighs two ounces and paid a Standard
a.
of 100,000,
refer to the response
groups of 10,000 letter-shaped
each
to parts a. through
pieces are processed
Please confirm that the throughputs
be the same for each group.
in one
and velocities for
If you do not confirm,
identify and describe all factors that would cause the throughputs
please
and velocities
for each group to differ.
b.
Assume
the
productivities
identify
same
facts
above
and
in part a.
for each group would be the same.
and describe
all factors
that would
Please
confirm
that
the
If you do not confirm, please
cause the productivities
for each
group to differ.
C.
Assume the same facts above and in part a. Please confirm that the wage rates
for processing
each group would be the same.
If you do not confirm,
please
Docket No. R2001-1
-6.
identify and describe all factors that would cause the wage rates for each group
to differ.
d.
Assume the same facts above and in part a. Please confirm that the total cost
and the unit cost for processing
each group on the DBCS would be the same.
If
you do not confirm, please identify and describe all factors that would cause the
total and unit costs for each group to differ.
e.
Assume
shaped
the same facts above and in part a., except that each group of letterpieces is processed
in two passes on the same DBCS.
parts a., b., c., and d. assuming
processed
f.
Assume
that each letter-shaped
Please answer
piece in each group is
in two passes on the same DBCS.
the same facts above and in part a., except that each group of letter-
shaped pieces is processed
same DBCS.
in two
group would be twice the
that the total cost and the unit cost
cost of each group if processed
Please confirm
in
DBCS.
If you do not
f. would
be the same
confirm, please explain.
cl.
Please
confirm
that the responses
to parts a through
where the two groups were processed
on a MPB
S and a CSBCS, respectively.
If you do not confirm, please explain.
h.
Please confirm that the responses
where
the two groups
consisted
shaped pieces, respectively.
i.
to parts a. throug
of 100,000,
,:_:
g. would be the same
1 millio , and 10 million letter-
If you do not confirm, plea e explain.
Please confirm that the responses
to parts a. thro
where the group that paid the First-Class
h. would
be the same
rate weighed two ounces and the group
-7-
Docket No. R2001-I
that paid the Standard
Mail Regular
rate weighed
one ounce.
If you do not
confirm, please explain.
OCANSPS-164.
a.
Please refer to the response to OCANSPS-42(b).
Please confirm that barcoded
letter-shaped
First-Class
letter rate and a First-Class
separately
until processing
pieces consisting
of pieces paying a
card rate are typically processed
into Delivery Point Sequence
(DPS).
If you do not
confirm, please explain.
b.
Please confirm that prebarcoded
a First-Class
separately
C.
letter-shaped
letter rate and a First-Class
until processing
pieces consisting of pieces paying
card rate are typically processed
into DPS. If you do not confirm, please explain.
Please confirm that for processing
into DPS, barcoded and prebarcoded
shaped pieces consisting of pieces paying a First-Class
Class card rate become commingled
letter-
letter rate and a First-
only on the second DPS pass. If you do not
confirm, please explain.
OCAAJSPS-165.
Please
refer to the response
groups of 10,000 letter-shaped
each letter-shaped
pieces are identical in every respect.
piece in each group is automation
one ounce.
However, one group paid a First-Class
a First-Class
card rate.
a.
to OCAAJSPS-44(b).
compatible,
two
More specifically,
barcoded,
and weighs
letter rate and the other group paid
Assume further that the two groups of letter-shaped
pass on the same DBCS.
Assume
pieces are processed
Please confirm that the throughputs
in one
and velocities for
Docket No. RZOOI-1
-6-
that pass would
be the same for each group.
identify and describe
If you do not confirm,
all factors that would cause the throughputs
please
and velocities
for each group to differ.
b.
Assume
the same
productivities
identify
facts
above
and
in part a.
for each group would be the same.
and describe
all factors
that would
Please
confirm
that the
If you do not confirm, please
cause the productivities
for each
group to differ.
C.
Assume the same facts above and in part a. Please confirm that the wage rates
for each group would be the same.
If you do not confirm,
please identify and
describe all factors that would cause the wage rates for each group to differ.
d.
Assume the same facts above and in part a. Please confirm that the total cost
and the unit cost for processing
each group on the DBCS would be the same.
If
you do not confirm, please identify and describe all factors that would cause the
total and unit costs for each group to differ.
e.
Assume
the same facts above and in part a., except that each letter-shaped
piece in each group weighed
2 ounces.
assuming that each letter-shaped
f.
Assume
piece in each group weighed 2 ounces.
3 ounces.
assuming that each letter-shaped
Assume
parts a., b., c., and d.
the same facts above and in part a., except that each letter-shaped
piece in each group weighed
9.
Please answer
Please answer
parts a., b., c., and d.
piece in each group weighed 3 ounces.
the same facts above and in part a., except that each group of letter-
shaped pieces is processed
in two passes on the same DBCS.
Please answer
Docket No. R2001-1
-9-
parts a., b., c., and d. assuming
processed
h.
Assume
that each letter-shaped
piece in each group is
in two passes on the same DBCS.
the same facts above and in part a., except that each group of letter-
shaped pieces is processed
in two passes on the same DBCS.
that the total cost and the unit cost for processing
cost of each group if processed
Please confirm
each group would be twice the
in one pass on the same DBCS.
If you do not
confirm, please explain.
i.
Please confirm that the responses
to parts a. through
where the two groups were processed
h. would
be the same
on a MPBCS and a CSBCS, respectively.
If you do not confirm, please explain.
i
Please confirm that the responses
the two groups
consisted
pieces, respectively.
OCAIUSPS-166.
Please
letter-shaped
piece
of 100,000,
1 million, and 10 million letter-shaped
If you do not confirm, please explain.
refer to the response
groups of 10,000 letter-shaped
each
to parts a. through i. would be the same where
to OCAIUSPS-44(b).
pieces are identical in every respect.
in each
group
is automation
compatible
However, one group weighs one ounce and paid a First-Class
group weighs two ounces and paid a First-Class
a.
that pass would
two
More specifically,
and barcoded.
card rate, and the other
letter rate.
Assume further that the two groups of letter-shaped
pass on the same DBCS.
Assume
pieces are processed
Please confirm that the throughputs
be the same for each group.
in one
and velocities for
If you do not confirm,
please
-lO-
Docket No. R2001-1
identify and describe
all factors that would cause the throughputs
and velocities
for each group to differ.
b.
Assume
the
productivities
identify
same
facts
above
and
in part a.
for each group would be the same.
and describe
all factors
that would
Please
confirm
that the
If you do not confirm, please
cause the productivities
for each
group to differ.
C.
Assume the same facts above and in part a. Please confirm that the wage rates
for processing
each group would be the same.
identify and describe
If you do not confirm,
please
all factors that would cause the wage rates for each group
to differ.
d.
Assume the same facts above and in part a. Please confirm that the total cost
and the unit cost for processing
each group on the DBCS would be the same.
If
you do not confirm, please identify and describe all factors that would cause the
total and unit costs for each group to differ.
e.
Assume
shaped
the same facts above and in part a., except that each group of letterpieces is processed
in two passes on the same DBCS.
parts a., b., c., and d. assuming
processed
f.
Assume
that each letter-shaped
Please answer
piece in each group is
in two passes on the same DBCS.
the same facts above and in part a., Except that each group of letter-
shaped pieces is processed
in two passes on the same DBCS.
that the total cost and the unit cost for processing
cost of each group if processed
confirm, please explain.
Please confirm
each group would be twice the
in one pass on the same DBCS.
If you do not
Docket No. R2001-1
9.
-II-
Please confirm that the responses
to parts a. through
where the two groups were processed
f. would
be the same
on a MPBCS and a CSBCS, respectively.
If you do not confirm, please explain.
h.
Please confirm that the responses
where
the two groups
consisted
shaped pieces, respectively.
i.
to parts a. through
of 100,000,
g. would
1 million,
be the same
and 10 million letter-
If you do not confirm, please explain.
Please confirm that the responses
to parts a. through
where the group that paid the First-Class
group that paid the First-Class
h. would be the same
card rate weighed
letter rate weighed
two ounces and the
one ounce.
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
practice.
Washington, D.C. 20268-0001
October 26,200l
in accordance
document
upon all
with Rule 12 of the rules of