.
.
UNITED STATES OF AMERICA
Before The
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
Postal Rate and Fee Changes,
2001
RECEIVED
OCT31 2 16 PI (01
POSi!*i;‘I-;’ i;:;l%.:,,;‘,~~
OFFICCOF ii:i: st:~‘~irdi(y
Docket No. R2001-1
)
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES
TO UNITED STATES POSTAL SERVICE
(OCA/USPS-167-171)
October 31.2001
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
hereby submits interrogatories
and
included with OCA interrogatories
are hereby incorporated
submitted,
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
by reference.
Docket No. R2001-1
-2-
OCANSPS-167.
a.
Please refer to the response to OCAAJSPS-63.
Refer to the response to part a. Please confirm that “letters with insufficient
addresses”
generally enter the postal system as collection mail. If you do not
confirm, please explain.
b.
Refer to the response to parts b. and d.
i.
Please provide the base year and test year volume, or an estimate of the
volume, of First-Class
letter-shaped
Service via “Retail acceptance
ii.
mail that is entered with the Postal
personnel;”
For the base year and test year, please provide the percent, or an
estimate of the percent, of total First-Class
entered via “Retail acceptance
III.
letter-shaped
mail that is
personnel;”
For the base year and test year, please provide the total volume, or an
estimate of the total volume, of mail entered via “Retail acceptance
personnel.”
C.
Refer to the response to parts b. and d.
i.
Please identify methods other than “Retail acceptance
which First-Class
ii.
letter-shaped
personnel”
by
mail is entered with the Postal Service;
Please provide the base year and test year volume, or an estimate of the
volume, of First-Class
letter-shaped
mail that is entered via each of the
methods identified in subpart i.
d.
Refer to the response to part b. Please confirm that “culling equipment”
the Advanced
explain.
Facer Canceler
System (AFCS).
If you do not confirm,
refers to
please
-3-
Docket No. R2001-1
e.
Refer to the response
AFCS specifically
aspect
ratio
mailstream.
f.
to part b. Please confirm that there is no feature of the
designed
to separate letter-shaped
requirements
(DMM
section
pieces that fail to meet the
C810.2.2.)
Refer to the response
to part b. Please confirm that there is no feature of any
other mail processing
equipment
specifically
designed
(DMM section C810.2.2.)
Refer to the response
to part b. Please confirm that there is no feature of any
mailstream.
equipment
If you do not confirm, please explain.
specifically designed
nonmachinable
to separate letter-shaped
pieces
surcharge from the letter-shaped
If you do not confirm, please explain.
Refer to the response
belts” located?
equipment?
to part b. In what mail processing
operation
are “culling
Are culling belts a part of, or separate from, any mail processing
Please
explain
destined for manual processing
how culling
belts separate
from the letter-shaped
letter-shaped
pieces
mailstream.
Refer to the response to part b. Please confirm that culling belts are not capable
of separating
surcharge
letter-shaped
pieces
subject
from other manual letter-shaped
explain how the culling belts accomplish
j.
letter-shaped
mailstream.
that are subject to the proposed
i.
to separate
from the letter-shaped
mail processing
h.
the letter-shaped
If you do not confirm, please explain.
pieces that fail to meet the aspect ratio requirements
cl.
from
to the proposed
pieces.
nonmachinable
If you do not confirm, please
this separation.
Refer to the response to part b. Please confirm that as “mailhandlers
letters from the collection mailstream,”
they will not separate
cull manual
letter-shaped
pieces
-4-
Docket No. R2001-1
subject
to the proposed
shaped pieces.
k.
nonmachinable
surcharge
Refer to the response to part b., where it states that letter-shaped
confirm that the automation
equipment
subject to the proposed nonmachinable
shaped pieces.
accomplished
pieces “can be
sorted to reject stackers.”
will not separate letter-shaped
Please
pieces
surcharge from other manual letter-
If you do not confirm, please explain how this separation
by the automation
is to be
equipment.
Refer to the response to part b., where it states “As letter trays arrive from bulk
mailers or other processing
letters from automation
facilities, mailhandlers
compatible
letters.”
separate full trays of manual
Please confirm that full trays of
manual letters from bulk mailers will be marked for manual processing
to DMM section M130.1.5.
m.
letter-
If you do not confirm, please explain.
diverted to the manual mailstream once
I.
from other manual
pursuant
If you do not confirm, please explain.
Refer to the response to part b., where it states “As letter trays arrive from bulk
mailers or other processing
letters from automation
facilities, mailhandlers
compatible
letters.” Please confirm that the full trays of
manual letters arriving from other processing
trays of nonmachinable
separate full trays of manual
letter-shaped
facilities will not be separated
into
pieces subject to the proposed surcharge
and trays of other manual letter-shaped
pieces.
If you do not confirm, please
explain.
n.
Refer to the response to part b., where it states “As letter trays arrive from bulk
mailers or other processing
letters from automation
facilities, mailhandlers
compatible
letters.”
separate full trays of manual
Please confirm that within the full
DocketNo.R2001-1
-5.
trays of manual letters arriving from other processing
be separated
surcharge
into nonmachinable
letter-shaped
and other manual letter-shaped
facilities, the letters will not
pieces subject to the proposed
pieces.
If you do not confirm, please
explain.
0.
Refer to the response to part c., where it states that “the Test Year After Rates
volumes include an estimate of the additional pieces meeting the proposed
nonomachinable
definition.”
What proportion of the difference
between the Base
Year and Test Year After Rates volumes for nonstandardlnonmachinable
First-
Class Single-Piece
(as
and Nonautomated
Presort Letters is nonmachinable
opposed to nonstandard)?
P.
Refer to the response
to part d.
Where
nonstandard/nonmachinable
shaped pieces are not identified by “Retail acceptance
every
operation
(RBCS); Outgoing
q.
(e.g.,
Entry
Activities;
Outgoing
personnel,”
Remote
please identify
Bar Code
Primary, Carrier Delivery, etc.) where letter-shaped
separated
from
the
letter-shaped
mailstream
determined
to be nonmachinable.
surcharge.
Please explain how the determination
for
manual
and subject to the proposed
acceptance
personnel,”
Sorter
pieces are
processing
is to be made.
letter-
Mail Entry Unit (BMEU)
please identify every operation
(e.g., Entry Activities;
Outgoing RBCS; Outgoing Primary, Carrier Delivery, etc.) where letter-shaped
pieces are separated from the letter-shaped
and
nonmachinable
Refer to the response to part d. Where nonstandardlnonmachinable
shaped pieces are not identified by “Business
letter-
mailstream for manual processing
Docket No. R2001-1
r.
-6-
and determined
to be nonmachinable
nonmachinable
surcharge.
and subject to the proposed
Please explain how the determination
is to be made.
Refer to the response to parts f. - j., where it states that “Pieces originally
determined
to be machinable
subsequently
at the retail window or BMEU but determined
to be nonmachinable
similar to the existing nonstandard
“existing nonstandard
surcharge
through the entire automated
during processing,
are intended to be treated
surcharge
Please confirm that some
pieces.”
pieces” are currently processed
mail processing
system.
successfully
If you do not confirm,
,please explain.
S.
Refer to the response to parts f:- j.
i.
Please provide the base year volume, or an estimate of the volume, of
“existing nonstandard
successfully
ii.
surcharge
pieces” that are currently processed
through the entire automated
mail processing
system;
For the base year, please provide the percent, or an estimate of the
percent, of “existing nonstandard
processed
successfully
surcharge
pieces” that are currently
through the entire automated
mail processing
system.
t.
Refer to the response to parts f. - j., where it states that “processing
assume the pieces have been appropriately
marked ‘Postage Due.“’
personnel
charged at entry and will not be
Please confirm that only retail and BMEU acceptance
will mark Postage Due on letter-shaped
nonmachinable
surcharge.
personnel
pieces subject to the proposed
If you do not confirm, please identify every operation
(e.g., Entry Activities; Outgoing Remote Bar Code Sorter (RBCS); Outgoing
-7-
Docket No. R2001-1
Primary, Carrier Delivery, etc.) where letter-shaped
pieces will be marked
Postage Due.
U.
Refer to the response to parts f. - j., where it states that “processing
assume the pieces have been appropriately
marked ‘Postage Due.“’
proposed nonmachinable
BMEU, such letter-shaped
surcharge.
V.
charged at entry and will not be
Please confirm that if letter-shaped
surcharge
personnel
pieces subject to the
are not identified at the retail window or
pieces will not pay the proposed nonmachinable
If you do not confirm, please explain.
Refer to the response to parts f. - j.
i.
Please provide the base year and test year volume, or an estimate of the
volume, of nonstandardlnonmachinable
letter-shaped
mail that is marked
Postage Due;
ii.
For the base year and test year, please provide the percent, or an
estimate of the percent, of nonstandardlnonmachinable
letter-shaped
mail
that is marked Postage Due;
III.
Please provide the base year and test year volume, or an estimate of the
volume, of manual letter-shaped
iv.
mail that is marked Postage Due;
For the base year and test year, please provide the percent, or an
estimate of the percent, of manual letter-shaped
mail that is marked
Postage Due.
W.
Refer to the response to parts f. - j. Please confirm that because not all
nonstandardlnonmachinable
BMEU acceptance
personnel,
letter-shaped
pieces will be identified by retail and
the Test Year After Rates revenue estimates for
-a-
Docket No. R2001-1
the proposed
nonmachinable
surcharge
are overstated.
If you do not confirm,
please explain.
OCANSPS-168.
Please refer to the response
groups of 10,000 flat-shaped
each flat-shaped
two ounces.
to OCA/USPS44(b).
pieces are identical in every respect.
piece in each group is automation
However, one group paid a First-Class
compatible,
Assume
two
More specifically,
barcoded,
and weighs
rate and the other paid a Standard
Mail Regular rate.
a.
Assume further that the two groups of flat-shaped
pass on the same Advanced
that the throughputs
group.
Assume
the same
productivities
identify
Flat Sorting Machine (AFSM) 100.
and velocities
in one
Please confirm
for that pass would be the same for each
If you do not confirm, please identify and describe all factors that would
cause the throughputs
b.
pieces are processed
and velocities for each group to differ.
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 AFSM
100 would be the
-Q-
Docket No. R2001-1
same.
If you do not 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 flat-shaped
in each group
weighed
assuming that each flat-shaped
f.
weighed
parts a., b., c., and d.
piece in each group weighed 3 ounces.
Please
4 ounces.
assuming that each flat-shaped
answer
piece
parts a., b., c., and d.
piece in each group weighed 4 ounces.
Assume
the same facts above and in part a., except that each group of flat-
shaped
pieces is processed
in two passes on the same AFSM
answer parts a. through f. assuming
processed
h.
answer
Assume the same facts above and in part a., except that each flat-shaped
in each group
9.
Please
3 ounces.
piece
that each flat-shaped
100.
Please
piece in each group is
in two passes on the same AFSM 100.
Assume
the same facts above and in part a., except that each group of flat-
shaped
pieces is processed
in two passes on the same AFSM
confirm that the total cost and the unit cost for processing
twice the cost of each group if processed
100.
Please
each group would be
in one pass on the same AFSM 100. If
you do not do not confirm, please explain.
i.
Please confirm that the responses
where the two groups were processed
to parts a. through
be the same
on a Flat Sorting Machine (FSM) 881 and
a Flat Sorting Machine (FSM) 1000, respectively.
explain.
h. would
If you do not confirm, please
Docket No. R2001-I
j.
-lO-
Please confirm that the responses to parts a. through i. would be the same where
the two groups consisted of 100,000, 1 million, and 10 million flat-shaped
respectively.
pieces,
If you do not confirm, please explain.
OCAIUSPS-169.
Please refer to the response
groups of 10,000 flat-shaped
to OCA/USPS44(b).
pieces are identical in every respect.
two
More specifically,
each flat-shaped
piece in each group is automation
First-Class
However, one group weighs two ounces and the other group weighs
rate.
compatible,
Assume
barcoded
and paid a
three ounces.
a.
Assume further that the two groups
of flat-shaped
pieces are processed
pass on the same AFSM 100. Please confirm that the throughputs
for that pass would be the same for each group.
identify and describe
in one
and velocities
If you do not confirm, please
all factors that would cause the throughputs
and velocities
for each group to differ.
b.
Assume
the same
productivities
identify
facts
above
and
in part
for each group would be the same.
and describe
all factors
that would
a.
Please
confirm
that I 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 AFSM
100 would
be the
-II-
Docket No. R2001-1
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 flat-
shaped
pieces is processed
answer
parts a., b., c., and d. assuming
group is processed
f.
in two passes on the same AFSM 100.
that each flat-shaped
Please
piece in each
in two passes on the same AFSM 100.
Assume
the same facts above and in part a., except that each group of flat-
shaped
pieces is processed
in two passes on the same AFSM
confirm that the total cost and the unit cost for processing
twice the cost of each group if processed
100.
Please
each group would be
in one pass on the same AFSM 100. If
you do not confirm, please explain.
9.
Please
confirm that the responses
where
the two groups
respectively.
h.
were
processed
where the two groups consisted
pieces, respectively.
Please
groups of 10,000 flat-shaped
each flat-shaped
Standard
f. would
be the same
on a FSM 881 and a FSM 1000,
If you do not confirm, please explain.
Please confirm that the responses
OCABJSPS-170.
to parts a. through
to parts a. through
rate.
group weighs three ounces.
be the same
of 100,000, 1 million, and 10 million. flat-shaped
If you do not confirm, please explain.
refer to the response
to OCANSPS-44(b).
pieces are identical in every respect.
piece in each group is automation
Mail Regular
g. would
However,
compatible,
one group weighs
Assume
two
More specifically,
barcoded
two ounces
and paid a
and the other
-12-
Docket No. R2001-1
a.
Assume further that the two groups of flat-shaped
pieces are processed
pass on the same AFSM 100. Please confirm that the throughputs
for that pass would be the same for each group.
in one
and velocities
If you do not confirm, please
identify and describe all factors that would cause the throughputs
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
same.
each group on the AFSM
100 would be the
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 flat-
shaped
pieces is processed
answer
parts a., b., c., and d. assuming
group is processed
f.
Assume
shaped
in two passes
on the same AFSM
that each flat-shaped
100.
Please
piece in each
in two passes on the same AFSM 100.
the same facts above and in part a., except that each group of flatpieces is processed
in two passes on the same AFSM 100.
confirm that the total cost and the unit cost for processing
Please
each group would be
-13-
Docket No. R2001-1
twice the cost of each group if processed
in one pass on the same AFSM 100. If
you do not confirm, please explain.
9
Please
confirm that the responses
where
the two groups
respectively.
h.
were
processed
Please confirm that the responses
pieces, respectively.
OcA/usPs-171.
to parts a. through
piece
g. would
be the same
of 100,000, 1 million, and 10 million flat-shaped
If you do not confirm, please explain.
groups of 10,000 flat-shaped
However,
be the same
on a FSM 881 and a FSM 1000,
Please refer to the response
flat-shaped
f. would
If you do not confirm, please explain.
where the two groups consisted
each
to parts a. through
pieces are identical
in each
one group weighs
group
two ounces
to OCA/USPS44(b).
in every respect.
is automation
Assume
More specifically,
compatible
and paid a First-Class
two
and
barcoded.
rate, and the other
group weighs three ounces and paid a Standard Mail Regular rate.
a.
Assume further that the two groups of flat-shaped
pieces are processed
pass on the same AFSM 100. Please confirm that the throughputs
for that pass would be the same for each group.
in one
and velocities
If you do not confirm, please
identify and describe all factors that would cause the throughputs
and velocities
for each group to differ.
b.
Assume
the same
productivities
identify
above
and
in part a.
for each group would be the same.
and describe
group to differ.
facts
all factors
that would
Please
confirm
that the
If you do not confirm, please
cause the productivities
for each
-14-
Docket No. R2001-1
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
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
same.
each group on the AFSM 100 would be the
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 flat-
shaped
pieces is processed
answer
parts a., b., c., and d. assuming
group is processed
f.
in two passes on the same AFSM
that each flat-shaped
100.
Please
piece in each
in two passes on the same AFSM 100.
Assume
the same facts above and in part a., except that each group of flat-
shaped
pieces is processed
in two passes on the same AFSM
confirm that the total cost and the unit cost for processing
twice the cost of each group if processed
100.
Please
each group would be
in one pass on the same AFSM 100. If
you do not confirm, please explain.
9.
Please confirm that the responses
where
the two groups
respectively.
h.
were
to parts a. through
processed
f. would
be the same
on a FSM 881 and a FSM 1000,
If you do not confirm, please explain.
Please confirm that the responses
where the two groups consisted
pieces, respectively.
to parts a. through
g. would
be the same
of 100,000, 1 million, and 10 million flat-shaped
If you do not confirm, please explain.
Docket No. R2001-1
i.
-15-
Please confirm that the responses
to parts a. through
where the group that paid the First-Class
group that paid the Standard
rate weighed
Mail Regular rate weighed
h. would
be the same
three ounces
two ounces.
and the
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 31,200l
in accordance
document
upon all
with Rule 12 of the rules of