IIECEIVEtj
BEFORE THE
POSTAL RATE COMMISSION
POSTAL RATE AND FEE CHANGES,
2000
DOCKET
:
JIJH19 5 03
f?i ‘00
NO. R2000-1
INTERROGATORIES
FROM UNITED PARCEL SERVICE
TO MAGAZINE PUBLISHERS OF AMERICA, INC., et al.
WITNESS RITA D. COHEN
(UPS/MPA-Tl-2
through 5)
(June 19,200O)
Pursuant to the Commission’s
serves the following interrogatories
al. witness Rita D. Cohen:
Rules of Practice, United Parcel Service hereby
directed to Magazine
UPSIMPA-Tl-2
Publishers
of America,
Inc., et
through 5.
Respectfully
submitted,
Q-.&.& F. IKE&
Jghn E. McKeever
William J. Pinamont
Phillip E. Wilson, Jr.
Attorneys for United Parcel Service
Piper Marbury Rudnick & Wolfe LLP
3400 Two Logan Square
18th & Arch Streets
Philadelphia, PA 19103-2762
(215) 656-3310
(215) 656-3301 (FAX)
and
1200 Nineteenth Street, NW
Washington, DC 20036-2430
(202) 861-3900
Of Counsel.
INTERROGATORIES
OF UNITED PARCEL SERVICE TO
MAGAZINE PUBLISHERS OF AMERICA, INC., et al. WITNESS COHEN
UPSlMPA-Tl-2.
On page 9, line 9, of your testimony,
served as co-chair of the Periodicals
Review Team.
List the identities of the organizations
(4
Operations
Operations
you indicate that you
participating
in the Periodical
Review Team and the number of team members from each listed
organization.
(b)
Operations
Confirm that the summaries
and opinions reflected in the Periodicals
Review Team Report (referred to as the “Team Report”) generally reflect
the views of all of the Operations
UPSlMPA-Tl-3.
Review Team members.
On page 21, lines 21-22, of your testimony,
“USPS witness Bozzo, USPS-T-l
you opine that
5, presents a state-of-the ati analysis of the volume
variability of 10 MODS cost pools” (emphasis
added). Please identify the characteristics
of Dr. Bozzo’s study that, in your opinion, qualify it as a state-of-the
art econometric
study.
UPSlMPA-T1-4.
On page 22, lines 8-10, of your testimony,
“Witness Bozzo has squarely addressed
Commission
R97-I]
from acceptance
(4
facility-specific
these defects [which prevented the
of Dr. Bradley’s econometric
in his analysis and testimony
you state that
approach
in Docket No.
.”
In Docket No. R97-I, the Commission
was concerned
about unobserved
effects changing over time (Docket No. R97-1 Opinion, Volume 1, at 86,
and Volume 2, Appendix
F at 10).
-2-
INTERROGATORIES
OF UNITED PARCEL SERVICE TO
MAGAZINE PUBLISHERS OF AMERICA, INC., et al. WITNESS COHEN
(0
USPS-T-15?
Does Dr. Bozzo address this concern in the analysis he presents in
If your answer is yes, explain in detail the basis of your response, and
provide appropriate
citations to USPS-T-15
response with your statement
If your answer is no, reconcile your
on page 22, lines 8-10, of your testimony,
referenced
above.
In Docket No. R97-1, the Commission
lb)
validity of the proportionality
Appendix
assumption
expressed
concern about the
(see Docket No. R97-1 Opinion, Volume 2,
F at 17-19).
0)
USPS-T-15?
Does Dr. Bozzo address this concern in the analysis he presents in
If your answer is yes, explain in detail the basis of your response, and
provide appropriate
citations to USPS-T-15.
response with your statement
If your answer is no, reconcile your
on page 22, lines 8-10, of your testimony,
referenced
above.
UPSlMPA-Tl-5.
On page 22, lines 24-25, of your testimony,
you state that Dr.
Bozzo has “worked with witness Degen to make sure his quantification
grounded
in operational
realities.”
In describing
was firmly
activities at mail processing
operations,
Mr. Degen describes the highly dynamic way in which mail is allocated across parallel
processing
operations
reflect this institutional
(USPS-T-16,
pages 18-20).
Where, if at all, does Dr. Bozzo
reality in the analysis he presents in USPS-T-l
detail the basis of your response,
and provide appropriate
-3-
5? Explain in
citations to USPS-T-15.
INTERROGATORIES
OF UNITED PARCEL SERVICE TO
MAGAZINE PUBLISHERS OF AMERICA, INC., et al. WITNESS COHEN
Reconcile
any contradictions
24-25, of your testimony,
of your response with your statement on page 22, lines
referenced
above.
-4-
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the foregoing
mail, postage prepaid, in accordance
document
with Section 12 of the Commission’s
by first class
Rules of
Practice.
c~q$&&&%/
Job% E. McKeever
Attorney for United Parcel Service
Dated: June IQ,2000
Philadelphia, Pa.
64420