BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, DC 20268-0001
Docket No. R2000-1
Postal Rate and Fee Changes, 2000
EIGHTH INTERROGATORIES
OF ALLIANCE OF NONPROFIT MAILERS
TO USPS WITNESS TAYMAN (ANMIUSPS-TS-70-74)
The Alliance
interrogatories
of Nonprofit
and document
ANM incorporates
Mailers
(“ANM”)
respectfully
submits
the attached
requests to USPS witness William P. Tayman (USPS-T-g).
by reference
the instructions
in OCA interrogatories
OCAIUSPS-1-14
(filed Jan. 24, 2000).
Respectfully
submit
d,
3kAfh
David M. Levy +
Christopher T. Shenk
Sidley & Austin
1722 Eye Street, N.W.
Washington, DC 200083704
(202) 736-8214
Counsel for Alliance of Nonprofit Mailers
March 23, 2000
QUESTIONS
ANMIUSPS-T9-70.
Please refer to your answer to ANMIUSPS-TS-9.
alludes to the creation
Finance function
responsive
of a “new forecasting
organization
Your answer
within [the Postal Service’s]
in Fiscal Year 1999,” but fails to identify any “standards”
to the question.
or “policies”
Please identify every change in standards or policies adopted
by the Postal Service since July 1, 1998, to increase the accuracy and reliability of its test
year revenue requirement
ANMIUSPS-TS-71.
ANMIUSPS-TS-34.
and other documents
studies.
projections.
Please
These questions
refer
to
ANMIUSPS-TS-7(f)
and
its follow-up,
sought, among other things, any studies, analyses,
that support the asset lives assumed
In response to ANMIUSPS-TS-34,
in the Postal Service’s
cost
you state:
It is my understanding that service life estimates are developed
at the time of the initial equipment buy in conjunction with the
criteria defined in my response to ANMIUSPS-TS-7(f).
A
review of the response to ANMIUSPS-TS-33
which provides a
listing of certain assets and their services lives and salvage
values should be sufficient for a third party to assess the
reasonableness
of established asset lives.
(a)
equipment
When “service life estimates
buy,” are any documents
underlying those estimates?
(b)
ANMIUSPS-TS-33”
Asset Life Listing.
generated
are developed
at the time of the initial
that reveal the analysis or assumptions
If so, please produce them.
Please confirm that the only information
is Library Reference
LR-I-224,
Personal
produced
in “response
to
Property and Motor Vehicle
Please
Cc)
curves or retirement
confirm
that LR-I-224
history actually experienced
does
not reveal
the lives, survivor
by the Postal Service for any asset or
group of assets
(4
Please provide the survivor curve actually experienced
by the Postal
Service for each line entry in LR-I-224.
ANMIUSPS-T9-72.
produce
the documents
documents
Please
requested
refer to ANMIUSPS-TS-36,
to ANM/USPS-TS-9,
exist. In response to ANM/USPS-TS-36,
such documents
exist.”
among the personnel
asked
you to
or verify that no responsive
you state that “I am unaware that any
Please confirm that a search was made for such documents
and departments
ANMIUSPS-T9-73.
which
most likely to possess them if they exist.
Please refer to ANMIUSPS-TS-44(d).
Your answer
is “I am
unaware of any studies or analyses related to limiting the size of the mail processing
force.”
Please confirm that a search was made for such documents
and departments
among the personnel
most likely to possess them if they exist.
ANMIUSPS-TS-74.
unaware of any studies.”
the personnel
work
Please refer to ANMIUSPS-TIO-28.
Your answer
is “I am
Please confirm that a search was made for such studies among
and departments
most likely to possess them if they exist.
-2-
CERTIFICATE
I hereby
participants
certify
that I have this day served
of record in this proceeding
Practice.
March 23. 2000
OF SERVICE
in accordance
the foregoing
with section
document
on all
12 of the Rules of