BEFORE THE
POSTAL RATE CDMMlSSlDN
POSTAL RATE AND FEE CHANGES,
2000
:
DOCKET NO. R2000-1
INTERROGATORIES
FROM
UNITED PARCEL SERVICE TO UNITED STATES
POSTAL SERVICE WITNESS BOZZO
(UPS/USPS-T1 5-9 through 17)
(March 8, 2000)
Pursuant to the Commission’s
serves the following interrogatories
Bozzo:
UPS/USPS-T1
Rules of Practice, United Parcel Service hereby
directed to United States Postal Service witness
5-9 through 17.
Respectfully
submitted,
John E. Mckeever
L
William J. Pinamont
Phillip E. Wilson, Jr.
Attorneys for United Parcel Service
Piper Marbury Rudnick & Wolfe LLP
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.
INTERROGATORIES
OF UNITED PARCEL SERVICE
TO UNITED STATES POSTAL SERVICE WITNESS BOZZO
UPS/USPS-T15-9.
Refer to the data presented
below for MODS group 1 (OCR):
For each time period for site #I, HRS > 40, TPH > 0, PRODLOW
< TPHlHRS
PRODHIGH,
DPT 5 0, QICAP > 0 and WAGES > 0, yet you drop all of these
observations
from your analysis sample.
UPS/USPS-T1
<
Why?
5-10. Refer to the data presented
#145, for Q195 to Q196:
-l-
below for MODS 2 (LSM), site
INTERROGATORIES
OF UNITED PARCEL SERVICE
TO UNITED STATES POSTAL SERVICE WITNESS BOZZO
For each time period, HRS > 40, TPH > 0, PRODLOW
< TPH/HRS
< PRODHIGH,
DPT > 0, QICAP > 0 and WAGES > 0, yet you drop all of these observations
your analysis sample.
from
Why?
UPS/USPS-T15-11.
Refer to the data presented
below for MODS 12 (SPBS),
site #83, Q294.
FNOT14 I
0
I
QTR
294
I HRS
; TPH
j
I34661.001 3345.00 /
MAN
0.06
/ DPT
/ QICAP
/WAGE
/236611.0 / 1616709.00 / 20.26
For each time period, HRS > 40, TPH > 0, PRODLOW
< TPHlHRS
DPT > 0, QICAP > 0 and WAGES > 0, yet you drop this observation
analysis sample.
from your
Why?
UPS/USPS-T15-12.
To perform your Generalized
multiply data for the first period of each run by (l-p*)“*.
transformation
< PRODHIGH,
Least Squares estimation you
While this may be the correct
in panels without gaps, why do you use the (I -p2)li*
the first period of each run within panels?
transformation
on
What is your source of authority for this
approach?
UPS/USPS-T1
5-I 3. A number of sites appear to have an intermittent
of various MODS operations.
For example, site # 6 has an intermittent
presence
presence of
Manual Parcels (MODS group 7) (from 193 to 194 TPH07 > 0, from 294-295 TPH07 =
0, then in 296, TPH07 > 0 again) and Priority (MODS group 8). Explain why these
operations
appear only intermittently.
-2-
.
INTERROGATORIES
OF UNITED PARCEL SERVICE
TO UNITED STATES POSTAL SERVICE WITNESS BOZZO
UPS/USPS-T15-14.
demand specification?
What other variables did you consider for your labor
Describe each such variable and explain why you decided not
to pursue it.
UPS/USPS-T1
5-l 5. What other econometric
Describe each such econometric
estimators did you consider?
estimator and explain why you decided not to pursue
it.
UPS/USPS-T15-16.
did you consider?
What other error structures,
other than the AR(l)
structure,
Describe each such error structure and explain why you decided not
to pursue it.
UPS/USPS-T15-17.
did you consider?
What other functional forms, other than the translog form,
Describe each such functional form and explain why you decided not
to pursue it.
-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: March 8, 2000
Philadelphia, Pa.
60203