RECElVEll
BEFORETHE
POSTAL RATE COMMISSION
POSTALRATEANDFEE CHANGES,2000
1
,
Jun 2 4
34 PM‘00
Docket No. R2000-1
UNITED STATES POSTAL SERVICE
INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO
TIME WARNER, INC. WITNESS STRALBERG
(USPS/-II’&Tl-l-8)
Pursuant to rules 25 and 26 of the Rules of Practice and procedure, the United
States Postal Service directs the following interrogatories and requests for production of
documents to Time Warner, Inc. witness Stralberg: USPS/l?+Tl-l-8.
Respectfully submitted,
UNITED STATES POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
Susan M. Duchek
475 L’Enfant Plaza West, S.W.
Washington, DC. 20260-I 137
(202) 268-2990 Fax -6402
June 2.2000
USPS/TW-Tl-l .
On page 28 of your testimony,
“some of the mail unloaded
may be ‘direct’
simply need to be cross-docked
This activitv
a)
takes little time.”
containers,
including
pallets, that
and staged for loading onto outbound
[emphasis
trucks.
added)
What is the basis for this conclusion?
Please cite all studies you
have conducted
the costs of cross-docking
‘direct’
b)
lines 1-2, you say that
or reviewed
regarding
containers.
What is your understanding
travel for cross-docked
with respect to the average length of
direct containers
length of travel for containers
as compared
being moved to opening
to the average
units and
sorting operations?
c)
Have you ever observed
the staging of cross-docked
inside the plant due to insufficient
d)
e)
in proportion
Has the staging
of cross-docked
direct containers
added to the
of the dock area?
What impact have the additional
forklifts
needed to move cross-
docked pallets had on the level of congestion
USPS/TW-Tl-2.
to cross-docked
containers?
congestion
f)
dock space?
Has dock space at plants increased
‘direct’
containers
On page 28 of your testimony,
“What defines the time constraints,
however,
on the dock?
lines 13-l 6, you say that
and requires
initial bursts of
activity
to get the mail unloaded
more burst of activity
is separated
a)
to meet dispatch
schedules,
from the direct mail in the opening
Is it your contention
that there would
load a truck that would
b)
and started on its processing,
Please reconcile
only contain
your conclusion
bursts of activity
on the platform
and later
is the ‘working
mail’ that
units.”
be no exigency
‘direct’
to unload or
containers
that working
of mail?
mail alone creates the
with the testimony
of witness
Degen (USPS-T-1 6) at page 50, lines 1 l-1 2 where he describes
limited unloading
and loading time required to keep the trucks
the
on
schedule.
USPS/TW-Tl-3.
If a forklift
picks up a pallet and moves it from point A to
point B, then returns to point A with nothing
the time would that forklift
USPSITW-Tl-4.
that waiting
USPSITW-Tl-5.
driver be observed
If a platform
time would
on its forks, what proportion
worker
is waiting
not-handling
for a truck,
we expect to observe him/her
On page 29 of your testimony,
mail?
what portion of
handling
mail?
lines 14-l 6, you say that
“As illustrated
above, ‘allied’
in MODS facilities
incur very large
‘not-handling’
costs, in spite of being much less automated
than the piece
distribution
operations
operations
they support.”
of
a)
b)
Please indicate
workers
clocked
handling
mail.
the approximate
amount
into platform
operations
What does being less automated
have to do with the expected
platform
c)
of time that you believe
should be observed
than piece distribution
amount
of not-handling
nature as piece sortation
automated?
distribution
time in
operations,
If your answer
counterpart
have the same essential
except that they are less
is yes, please indicate
to waiting
the piece
for trucks.
On page 29, lines 2-8, you say that “‘working
the need for high staffing
most responsible
operations
and other allied operations?
Do you mean to imply that allied operations
USPSITW-Tl-6.
not
levels in allied operations”
for the extensive
specify the mail processing
amounts
and that “this mail is
of ‘not-handling’.”
cost pools corresponding
mail’ drives
Please
to your use of the term
‘allied operations.’
USPSITW-Tl-7.
testimony,
to distribute
On page 29, lines 9-10, at the end of section
you say “These observations
allied ‘not-handling’
how the observations
bear directly
issue of mixed mail costs.
on the question
and ‘mixed mail’ costs.”
you make in section
C of your
of how
Plea‘se indicate
C of your testimony
bear on the
USPS/TW-Tl-8.
On page 4, lines 3-6 of your testimony
visits to postal facilities
in the preceding
the rapid move to letter automation
would
years I had become concerned
mail.”
changes
mail.”
and your reasoning
costs for automated
by reporting
higher
Please list the changes that the Postal
Service has made to the CRA methodology
costs for non-automated
that
lead to claims of great savings,
which the Postal Service would only be able to justify
costs for non-automated
you say that “In
that have led to “reporting
Please be specific
higher
with respect to the
as to why each change has reduced the CRA
mail, while increasing
the costs for non-automated
mail.
CERTIFICATE OF SERVICE
I hereby certify that I have this day served the foregoing document upon all
participants of record in this proceeding in accordance with section 12 of the Rules of
Practice.
Susan M. Duchek
475 L’Enfant Plaza West, SW.
Washington, D.C. 20260-I 137
(202) 268-2990 Fax -5402
June 2,200O