'RECEIVE[)
BEFORE THE
POSTAL RATE COMMISSION
Washington,
D.C. 20268-0001
Postal
Rate and Fee Changes,
2000
)
)
Docket
No. RZOOO-1
AMERICAN BANKERS ASSOCIATION AND
NATIONAL ASSOCIATION OF PRESORT MAILERS
JOINT INTERROGATORIES TO USPS WITNESS DANIEL
(ABA&NAPM/USPS-T28-14-23)
(March 22, 2000)
Pursuant
Practice,
to Sections
the American
Association
of Presort
interrogatories
25 and 26 of the
Bankers
Association
Mailers
(NAPM) hereby
and requests
instructions
included
ABA&NAPM/USPS-24-1-24
with
for
Commission's
Rules
of
(ABA) and the National
submit
the production
these
joint
of documents.
The
ABALNAPM interrogatories
are hereby
incorporated
by reference.
ABA&NAPM/USPS-T28-14
In his
testimony,
USPS witness
processing
costs
by eliminating
cost
which
he claims
pools
"First
- Class
this
page I-l),
Sharing
Letters
Related
Work-Sharing
Related
from the
Cost".
Unit
reduces
appears
Cost.
related.
(See Miller's
as column
He then
labels
mail
R97-1 procedure
are not worksharing
Summary" table
procedure
Unit
Miller
(2),
column
certain
In his
Appendix
"Mail
I at
Proc Work-
(3) Delivery
a.
In your
estimation
you adjusted
Is witness
label
from
Miller's
something
your
delivery
C.
by eliminating
Please
work,
costs
costs
he included
that
all
your
that
you report
in your
cost
from
CRA cost
in R97-l?
from his
are worksharing
confirm
pools
he has concluded
namely
have
Hume's delivery
terminology
which
in R2000-1,
any cost
6, 1 and 10 which
segments
costs
R97-1 USPS witness
methodology
b.
of delivery
column
(3 1
independent
reported
lY
unit
related?
view
all
are "work-sharing
the delivery
unit
related".
ABA&NAPM/USPS-T28-15
In LR-I-95
as well
as your
testimony,
confirm
that
nowhere
do you develop
the
single
piece
or bulk
metered
mail.
letter
USPS-T-28,
delivery
please
costs
of either
ABA&NAPM/USPS-T28-16
On page 20,
volume
numbers
RPW volumes.
the
Is it
line
11, of your
you use for
Is this
development
consistent
with
calculation
consistent
of unit
mail
testimony
with
of unit
numbers
costs
that
delivery
the volume
processing
the volume
you state
numbers
costs
Miller?
Standard
A unit
MP and D costs?
ABA&NAPM/USPS-T28-17
On page 25 of your
testimony
you state
2
rural
unit
are
used for
by witness
used for
the
delivery
costs
for
DPSed and non-DPSed
corresponding
data
for
city
letters.
Please
provide
the
carriers.
ABA&NAPM/USPS-T28-18
On page 32,
lines
2-5,
made in R97-1 are not
adjustments
because
you state
included
"they
in the
occurred
the
classification
Kashani
after
changes
BY volume
the
conclusion
of the
BY" .
a. What changes
b. Are they
If
are you referring
included
to from
in the Kashani
R97-l?
rollforward
to FY1999?
Tolley
rollforwards
to FY1999?
delivery
costs,
not why not?
c.Are
they
If
not
included
in the
why not?
ABA&NAPM/USPS-T28-19
In the
support
labor
development
labor
of your
(CPA, cost
(CRA, cost
segment
segment
7.5)
6.2)
included
why is
and other
some
support
excluded?
ABA&NAPM/USPS-T28-20
Please
percentage
digit
confirm
of First
from LR-I-95,
Class
and (3) automated
sequenced
categories
a.
(1) basic
5 digit
(DPSed) is greater
for
Standard
Please
list
"Rural
A Regular
the
automation
letters
than
for
letter
corresponding
3
DPS", page 1, that
that
the
the
(2) automated
are delivery
corresponding
3
point
rate
mail.
DPS percentages
for
city
carrier
letter
b.
mail.
Are your
cost
rural
DPS percentages
segments
explain
anywhere
applied
in LR-I-95?
If
to city
carrier
so, please
why.
ABA&NAPM/USPS-T28-21
Please
forward
explain
your
LR-I-102
in detail
sample
to the
weight
test
year
the procedures
and cost
data
data
found
you used to roll
for
in your
base year
1998 in
testimony
and LR-I-
91.
ABA&NAPM/USPS-T28-22
Refer
to LR91 tables
Cost by Function,"
Function,"
"Single-Piece
Presort
LR92 tables
All
"Std.
All
Shapes Test
Cost by
A Reg. All
Shapes Test
Year Unit
Shapes Test
Year Unit
and W Std.
A ECR All
Cost by Function."
(all
are in cents)
costs
Single-Piece
Delivery
(City
Unit
Presort
Std.
A ECR
+ Rural
in office
+ City
Delivery
Street
+ Vehicle
Delivery)
O-l
ounce
5.2
4.3
5.0
4.77
l-2
ounce
8.1
9.5
6.4
5.33
56%
121%
28%
12%
8 Change
A Reg.
Cost:
Delivery
Services
Year Unit
Year unit
Cost by Function,"
Std.
Shapes Test
4
Please
explain
single
piece
why the unit
and presort
corresponding
delivery
costs
for
the
are disproportionately
delivery
unit
costs
for
Std.
2"d ounce
higher
than
for
the
A Reg and Std A ECR?
ABA&NAPM/USPS-T28-23
Refer
to LR91 tables
Cost by Function,"
Function,"
Presort
LR92 tables
by Function,"
Function."
costs
Letters
"Std.
and m Std.
(all
"Single-Piece
Test
A ECR Letters
(City
Test
Cost by
Year Unit
Year Unit
Std.
Presort
+ City
Delivery
Street
Delivery)
ounce
5.2
4.28
4.5
4.5
l-2
ounce
8.2
9.62
5.0
6.04
58%
125%
11%
34%
% Change
single
piece
corresponding
A Reg.
+ Vehicle
O-l
explain
Cost by
A ECR
in office
+ Rural
Please
Cost
Cost:
Delivery
Services
Test
Year Unit
are in cents)
Std.
Unit
Test
Year unit
A Reg. Letters
Single-Piece
Delivery
Letters
why the unit
and presort
delivery
delivery
costs
are disproportionately
unit
costs
for
5
Std.
for
the
2"d ounce
higher
than
for
the
A Reg and Std A ECR?
ABA&NAPM/USPS-T28-24
From your
1 (0.1245)
total
and Table
same two numbers
piggybacks
unit
2
for
second
for
(0.1477)
direct
and indirect
included,
cost
above 1 ounce in Table
in LR-I-91,
volume
costs,
without
ounces
variable
first
premium
please
with
labor
present
costs
premium
the
without
pay factors
pay factors.
ABA&NAPM/USPS-T28-25
a.
Do your
user
b.
piggyback
costs
for
factors
include
each weight
increment
By adding
USPS witness
Smith's
costs
each weight
increment,
for
are you breaking
factors
down total
and other
indirect
equipment
and facility
in your
piggyback
study?
costs
and indirect
are you double
piggyback
costs
costs,
counting,
premium
or
pay
as calculated
by witness
you are breaking
down totals,
Smith?
If
C.
your
please
provide
piggyback
basis
to b. is that
answer
a spread
or indirect
over
you provide
sheet
cost
showing
factor
each Sz ounce and full
for
Tables
those
totals
on a per piece,
by major
unit
ounce cost-weight
cost
increment
1 and 2 of LR-I-91.
ABA&NAPM/USPS-T28-26
Intuitively,
mail
mail,
cost
since
how could
more than
shapes
the
vary
the
2nd ounce of
2"d ounce of First
more with
the
6
latter
First
Class
than
Class
presort
single
piece
the
former,
since
the
avoids
former
several
does not
is viewed
as being
work activity
steps
"cleaner"
that
First
mail,
and since
Class
single
it
piece
avoid?
ABA&NAPM/USPS-T28-27
Refer
Unit
to LR-I-91,
Cost by Function,"
by Function,"
Unit
Tables
and LR92,
Cost by Function,"
Cost by Function."
"Single-Piece
Unit
A Reg. Letters
"Std.
costs
A ECR Letters
l-2
ounce
19.8
12.93
First
69.2%
Class
Year Unit
Std.A
Reg.
presort
costs
Standard
A Regular
letter
between
in marginal
1.47
5.9
the
letter
costs
1.97
5.5
190.6%
what weight
marginal
reduction
Year
Cost:
4.45
explain
Cost
A ECR
11.7
Please
Test
Presort
ounce
a.
Test
Year
are in cents)
O-l
% Change
Year Unit
Tables
Std.
Processing
Test
Letters
Single-Piece
Mail
Test
and "Presort
and " Std.
(All
Letters
related
-6.8%
factors
would
to have a 191% increase
first
would
and second
exhibit
across
the
34%
cause
a
in
ounce while
an absolute
same weight
increment.
b.
Please
explain
what weight
related
7
factors
would
cause a
a
First
Class
increase
that
presort
letter
in marginal
a First
to have nearly
cost
Class
between
single
piece
the
3 times
first
letter
the
and second
ounce
has.
ABA&NAPM/USPS-T28-28
Refer
to LR-I-91,
Section
All
Shapes Test
Year Unit
Piece
detail.
Explain
(29.6
how mail
C) vs lSt ounce
1 Page 1 Table
Costs
By Function",
processing
(12.4
costs
for
c) can be higher
vary
1, titled
a.
Do RCR costs
b.
Do MLOCR costs
vary
by this
C.
Do RBCS costs,
that
is manual
"Single-
supporting
the
2"d ounce
by about
139%?
by weight?
weight
increment?
video
encoding,
vary
by
weight?
d.
Do BCS costs
e.
If
your
answer
explain
that
vary
fully
would
by this
is "yes"
increment?
to any of the
and provide
support
weight
your
all
above,
engineering
please
study
data
answer.
ABA&NAPM/USPS-T28-29
In LR-I-91,
presort
letters,
second
Section
2, Table
2, supporting
explain
how unit
mail
ounce of workshared
mail
detail
processing
can be 191% higher
for
costs
for
the
than
the
first
ounce costs?
a.
Does this
business
ounces
mean MLOCRs and BCSs pass a standard
letter
mail
weighing
at a speed 1.91
times
8
between
slower
size
one and two
than
an identical
letter
weighing
engineering
answer
b.
If
studies
is in the
your
the
answer
(that
the charge
machine
through
three
exists
your
to support
exists
why should
set
within
the
equal
there
first
to 0)
is
the time
excess
window
letters
through
for
automation
letters
provide
machinery
than
any documentation
a
that
answer.
on the machine,
three
ounces
machinery,
do? Please
to support
cause any more physical
of automation
from wear and tear
ounce
not
ounces
on a piece
Please
downtime
your
from
assuming
time)
one ounce letter?
weight
if
any
is processed?
Do letters
Apart
claim
be any different
speed difference
wear and tear
d.
this
provide
in the affirmative,
charge
(idle
such mail
support
to a. is
is why is
due to the
capacity
that
Please
affirmative.
depreciation
ounce
C.
one ounce or less?
provide
your
answer.
detail
for
do heavier
cause any more
e.g.
jams,
than
any documentation
one
that
ABA&NAPM/USPS-T28-30
a.
In Table
explain
how in-office
city
greater
for
letter
than
b.
2, supporting
for
a presort
a presort
letter
For both
single
piece
delivery
street
unit
delivery
weighing
vary
9
letters,
costs
weighing
and presort,
costs
presort
please
can be 182%
between
1 and 2 ounces
one ounce or less.
please
widely
explain
between
why city
the
first
and
second
ounce,
but
vary
only
slightly
for
rural
delivery
costs.
ABA&NAPM/USPS-T28-31
Please
Standard
refer
Mail
Increment."
(A),
Mail
On page 5 state
for
Measurement
from
group.
are also
PERMIT bulk
mail
used in this
there
is general
those
reported
a. Please
Periodicals,
data
source
different.
those
estimates
The CBCIS draws
These data
the method
Although
between
and Performance
for
system.
although
of revenue,
and Standard
Volume,
acceptance
consistency
estimates
RPW sample.
analysis
somewhat
by necessity,
"Official
by the Revenue,
domestic
"First-Class,
Volume by Shape and Weight
that
The primary
CBCIS and the
the
USPS LR-I-102
First-Class,
(A) are developed
the
for
and Periodicals
and weight
pieces,
is
to document
not
the official
input
sources
used here
exactly
are,
equal,
estimates
and
here."
explain
what you mean "...by necessity,
explain
what you mean by "... there
somewhat
different."
b. Please
consistency
reported
estimates
official
between
here."
differ
the
Please
is general
official
estimates
and those
provide
the degree
to which
from the official
estimates?
10
estimates.
your
What are the
ABA&NAPM/USPS-T28-32
Please
from
using
explain
what advantages
PERMIT system
over
in weight
studies
are gained
BRAVIS.
ABA&NAPM/USPS-T28-33
Please
Standard
refer
Mail
(A),
Increment."
Mail
to document
and Periodicals
and stamped
are obtained
estimates
from
office
a. Please
size
provide
procedure
b. Please
non-PERMIT
result
all
statistical
estimates
reported
First-Class
estimation
you use FY 95 data
you use FY 96 data.
e. Could
for
explain
for
there
These
to the
that
estimates
results
c. For the
period
model.
offices
in biased
sample
d. Please
at non-PERMIT
this
of revenues
offices.
provide
of data
and Standard
done to make sure
of estimates,
sets
estimates
regression
errors
offices
"First-Class
stratum."
does not
and parameter
that
revenue
any studies
non-PERMIT
"First-Class,
Volume by Shape and Weight
a linear
are used to assign
appropriate
for
USPS LR-I-102
On page 10 you state
(A) metered
offices
for
your
R-squared,
explain
for
model
8 such as standard
of revenues
whereas
regression
the
and etc.
for
non-PERMIT
Standard
Mail
why you use different
not use data
over
FY 94 to FY 97
estimation.
be other
(A)
estimations?
why you did
your
in Table
size,
Please
for
variables
11
that
may account
for
the
variations
in the
quarter
effect
revenues?
For example,
or geographic-location
month-of-the-
effect.
ABA&NAPM/USPS-T28-34
Please
Standard
refer
Mail
(A),
for
meet the
standards
provide
USPS LR-I-102
and Periodicals
for
that
any of these
the discard
"First-Class,
Volume by Shape and Weight
On page 12 you state
Increment."
Please
to document
"Observations
three
groups
that
can not
are discarded."
rate.
ABA&NAPM/USPS-T28-35
Please
Standard
refer
to document
Mail
USPS LR-I-102
and Periodicals
(A),
Increment."
for
Volume by Shape and Weight
On page 12 you state
are complex
"First-Class,
that
and depend on the
information
explain
rules
"The data
editing
contained
rules
in the
PERMIT
record."
a. Please
b. Furthermore,
different
how these
provide
editing
are determined.
any studies
rules
on the
showing
integrity
the
effect
of the
of
data.
ABA&NAPM/USPS-T28-36
Please
Standard
Increment."
refer
Mail
to document
(A),
for
USPS LR-I-102
and Periodicals
"First-Class,
Volume by Shape and Weight
On page 12 you discuss
12
the
filling
of missing
data.
a. Please
provide
percentages
a summary of missing
missing
and non-missing
data
in terms
data
for
of
different
mail
categories.
b. Further,
you state
office
are computed
the
year."
simple
data
11. ..the average
over
Are there
averaging?
missing
that
the
available
schemes that
Have you tried
other
than
revenues
for
accounting
might
the
periods
be superior
any other
simple
averaging?
for
USPS LR-I-102
in
to such
schemes to fill
ABA&NAPM/USPS-T28-37
a.
Please
refer
Standard
Weight
to document
Mail
(A),
and Periodicals
Increment."
inflation
11
. ..to certain
estimates."
Explain
published
RPW estimates.
this
is
inflation
unbiased
Volume by Shape and
On page 16 section
of data
VIII,
across
all
you discuss
GFY 98 published
what you mean by
of the
"First-Class,
Please
strata
results
mail
categories
RPW
GFY 98
"certain"
provide
the
any studies
that
to RPW estimates
level
and weight
increments.
b.
Please
Standard
Weight
refer
Mail
(A),
the
to the
total
factor
for
USPS LR-I-102
and Periodicals
Increment."
classes
control
to document
Volume by Shape and
On page 9 you state
PERMIT transactions
revenue
is
to pieces
13
that
"For
in each stratum
in each stratum.
applied
"First-Class,
all
are inflated
The computed
and weight
data
revenue
as well,
while
maintaining
including
Please
rate
provide
statistically
the
element,
full
shape,
any studies
unbiased
array
with
that
of rate
and weight
show that
respect
increment
14
characteristics
to the
increment."
this
inflation
is
shape and weight
Respectfully
submitted,
AMERICAN BANKERS ASSOCIATION
NATIONAL ASSOCIATION OF PRESORT MAILERS
Henry A. Hart
Reed Smith Shaw & McClay LLP
1301 K street
N.W.
Suite 1100 - East Tower
Washington,
DC 20005
Ph: 202-414-9225
Fax: 202-414-9299
Irving
D. Warden
Assoc. General Counsel
American Bankers Association
1120 Connecticut
Ave., N.W.
Washington,
DC 20036
Ph: 202-663-5035
Fax 202-828-4548
Counsel for
National
Association
Of Presort
Mailers
Counsel for
American Bankers
March 22,
Association
2000
Washington,
D.C.
CERTIFICATE OF SERVICE
I hereby
document
proceeding
Practice.
certify
to be served
that
I have this
upon all
in accordance
with
date
participants
Section
caused
the
of record
12 of the Rules
foregoing
in this
of
Irving
1120 Connecticut
Avenue,
Washinaton.
D.C. 20036
Ph: (262) 663-5027
fax:
(202) 828-4548
email:
March
N.W.
[email protected]
22,
2000
16
D. Warden