BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
POSTAL RATE AND FEE CHANGES, 2000
Docket No. R2000-1
i!
RESPONSE OF UNtTED STATES POSTAL SERVICE
WITNESS MEEHAN TO INTERROGATORIES OF
THE ASSOCIATION OF PRIORITY MAIL USERS, INC.
(APMUIUSPS-Tll-15-18)
The United States Postal Service hereby provides the responses of witness
Meehan to the following interrogatories of the Association of Priority Mail Users, Inc.:
APMUIUSPS-Tl
l-15-18, filed on March 23,200O.
Each interrogatory is stated verbatim and is followed by the response.
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, D.C. 20260-l 137
(202) 268-2990 Fax -8402
April 6.2000
Response of United States Postal Service Witness Meehan
to
Interrogatories of APMU
’
please ?fer to yowworkpaper A-4 at pages 17
APMUNSPS-11 l-l!5
through 18.1, qnd confkrn @at ovGtrrn~ pay costs are used to calculate
Cast Combnht 433 : All s&&s plus *her personnel costs from cost
segments l-13,18, 18,.and 19. If you~do confirm, please explain why they
are included. If you do not ccnfirm, please explain.
Response:
Confirmed. Overtime pay costs are part of salaries; therefore, it is properto
include them in the calculation of Component 433.
Response of United States Postal Service Witness Meehan
to
Interrogatories of APMU
APMUIUSPS-II-16
Pleqw refer to your workpaper A-4 at pages 17
thrcugh 18. i , and confirm t@t tl@ nfght djflkential costs are used to
“~calculatef%t Comp&nt 433 -‘All salaries plus other personnel costs
.from cost segments .l-?3, RI, 18, and 19. If you d6 confirm, please explain
why they are included. If you do not confirm, please explain.
Response:
Confirmed. Night differential pay costs are part of salaries; therefore, it is proper
to include them in the calculation of Component 433.
Response of United States Postal Service Witness Meehan
to
Interrogatories of APMU
APMUIUSPS-Tll-17
please refer to your workpaper A-4 at pages 17
through 18.1, bnd conbi that ,hollda$pay co& are used to calculate
” ,Campo~ent433.- Ajl.s+aty plus other personnelCostsfrom cost segments
l-13, 16.18, Eind1% If yqu dd confirm, Pleaseexplain why they are
included. tf you’d0 not confifm, please explain.
Cost
Response:
Confirmed. Holiday pay costs are part of salaries; therefore, it is proper to
include them in the calculation of Component 433.
Response of United States Postal Service Witness Meehan
to
Interrogatories of APMU
APWIUSPS-Tl l-18
Please refer to ~yourworkpaper A-4 at pages 17
through 18.1, &n+confinn:that salary CQstsof non-bargainingunit
employees afi$used to ccilr+il&tecost Component433 - All salaries plus
!Jtherpe@c%titilCostsfrom.&st segments l-1$,16,18, Andylg. If you do
confBni, ple&e explain tiy they are included. If you do not confirm please
explain.
Response:
Confirmed. Salaries of non-bargaining unit employees are part of salaries;
therefore, it is proper to include them in the calculatipn of Component 433.
DECLARATION
I, Karen Meehan, declare under penalty of perjury that the foregoing
answers are true and correct, to the best of my knowledge, information, and belief.
-..
c
cl
_
CERTIFICATE OF SERVICE
I hereby certify that I have this day served the foregoing document upon all
participants of r&Cord in this proceeding in accordance with section 12 of the Rules of
Practice.
Susan M. Duchek
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-l 137
(202) 268-2990 Fax -6402
April 6,200O
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