RECEIVEC
POSTAL RATE AND FEE CHANGES,
2000
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POSTAL
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INTERROGATORY
FROM UNITED PARCEL SERVICE TO
MAGAZINE PUBLISHERS OF AMERICA, INC., ET AL.
WITNESS CROWDER, MPA-T-5
(UPSIMPA-T5-1 through 3)
(June 19,200O)
Pursuant to the Commission’s
Rules of Practice, United Parcel Service hereby
files and serves the following interrogatories
America, Inc., et al., witness Crowder:
directed to Magazine
UPS/MPA-T5-1
Publishers
of
through 3.
John E. McKeever
fi
William J. Pinamont
Phillip E. Wilson, Jr.
Attorneys for United Parcel Service
i
’
Piper Marbury Rudnick &Wolfe
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.
LLP
MAGAZINE
INTERROGATORY
OF UNITED PARCEL SERVICE TO
PUBLISHERS OF AMERICA, INC., ET AL., WITNESS CROWDER
(a) Confirm that your evaluation
UPSIMPA-T5-1.
performed
in comparison
is, if the Commission
ratemaking
purposes”
represent
work is
to the Postal Service’s 1986 Street Time Survey (STS). That
follows your advice to “reject the use of the ES data for
(MPA-T-5,
STS data in its place.
accurately
of Mr. Raymond’s
page 5) the only alternative
will be to use the 1986
(b) Confirm that the 1986 STS data do not necessarily
BY1998 city carrier costs, nor is it necessarily
more accurate than
ES.
At page 6 of your testimony
UPSIMPA-T5-2.
that “Mr. Raymond’s
(MPA-T-5,
page 6) you state
work sampling study was not designed for ratemaking
purposes and was conducted
costing
prior to any thought that it be used in ratemaking.
this, standing alone, does not automatically
While
invalidate use of the data for costing, it
does raise a warning flag.” (footnote omitted)
Are you aware of any other Postal Service data systems that were not
(a)
designed for ratemaking
L
costing purposes
but are used for those purposes?
If so,
identify them.
(b)
Are you aware that data from the Management
(MODS) was not designed for “ratemaking
(4
Witness Bradley (USPS-T-18)
database
Data System
costing purposes?”
makes use of the Highway Contract
Support System (HCSS) for costing purposes.
electronic
Operations
He describes the database
system to manage [the Postal Service’s] purchased
-2-
as “an
highway
MAGAZINE
transportation
INTERROGATORY
OF UNITED PARCEL SERVICE TO
PUBLISHERS OF AMERICA, INC., ETAL., WITNESS CROWDER
contracts.”
was not “designed
USPS-T-18,
for ratemaking
UPSIMPA-T5-3.
at page 12. Would you agree that this system
costing purposes?”
At page 20 of your testimony,
in reference
Service’s selection of cities and routes to include in activity samplings,
“Although
[ad hoc sampling]
does not meet ratemaking
may be appropriate
costing standards
that are used to create workload
are used for “ratemaking
standards
to the Postal
you state that
for industrial engineering
.” Is it your testimony
projects, it
that the data
are or can be of lower quality than data that
costing”?
-3-
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.
Attorney for United Parcel Service
Dated: June 19,200O
Philadelphia, Pa.
t