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RESPONSE,OF UNITED STATES POSTAL SERVICE
WITNESS KINGSLEY TO INTERROGATORIES OF
THE ASSOCIATION FORPOSTAL COMMERCE.
(PostCom/USPS-T10-4-5)
The United States Postal Service hereby provides the responses of witness
Kingsley to the following interrogatories of APC.: PostComlUSPS-TlO+6,
filed on
Februaty 24,200O.
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 CEnfant Plaza West, S.W.
Washington, D.C. 20260-l 137
(202) 266-2990 Fax -5402
March 9.2000
RESPONSE OF LINKED STATES POSTAL SERVICE WITNESS KINGSLEY
TO INT~RROGAiCtRlES OF ASSO%IATION FOR POSTAL COMMERCE
POSTCOMIUSPS-Tl0-4
Please refer to witness Smith’s response to DMAAJSPST21-2(f), which states: “I am told that the Postal Service is addressing these
concerns beyond the base year, through the deployment of the OCRs to the FSM
66t and the deployment of the AFSM 100. The AFSM 100s will initially reduce
manual work hours and, as deployment proceeds, start replacing FSM 661s. In the
interim, the OCRs on the FSM 661s will eliminate the need to maintain separate
barcoded and nonbarcoded mailstreams, a requirement that proved operationally
cumbersome. The OCRs on the FSM 661s will also reduce costs by reductions in
operator keying time.”
(a)
Please provide a schedule for deploying OCRs on FSM 661s. If
a deployment schedule is currently unavailable, please explain
when a deployment schedule will be available.
W
On what percentage of FSM 661s do you plan to deploy OCRs?
(c)
What is the annual workhour reduction that would result from
deploying OCRs on one FSM 6617 Please provide all
underlying calculations and disaggregate the workhour savings
into the two categories referenced above: elimination of the
need to maintain separation mailstreams and reduction in
operator keying time.
(4
What is the annual workhour reduction that would result from
deploying OCRs on all FSM 66197 Please provide all underlying
calculations and disaggregate the workhour savings into the two
categories referenced above: elimination of the need to maintain
separation mailstreams and reduction in operator keying time.
(e)
Please confirm that these savings are not reflected in LR-I-126
or LR-I-127. If not confirmed, please provide a citation to where
these savings are incorporated in the roll forward.
(9
Is the Postal Service also planning on deploying OCRs on
FSM 1000~7 If’not, is the Postal Service considering deploying
OCRs on FSM 1000~7 If the Postal Service is considering
deploying OCRs on FSM IOOOs,when will the Postal Service be
making a decision on whether to deploy OCRs on FSM 1000~7
If the Postal Service is planning to deploy OCRs on FSM
0)
IOOOs, please provide a schedule for deploying OCRs on FSM 1000s
and the percentage of FSM 1000s upon which you plan to deploy
f$ESPONSE OF UNITED STATES POSTAL SERVICE WlTNESS KINGSLEY
TO INTERROGATORIES OF ASSOCIATION FOR POSTAL COMMERCE
OCRs. If a deployment schedule is currently unavailable, please
explain~when a deployment schedule will be available.
(ii)
What is the annual workhour reduction that would result
from deploying OCRs on one FSM 10007 Please provide all underlying
calculations and disaggregate the workhour savings into the two
categories referenced above: elimination of the need to maintain
separation mailstreams and reduction in operator keying time.
(iii)
What is the annual workhour reduction that would result
from deploying OCRs on all FSM 1000~7 Please provide all underlying
calculations and disaggregate the workhour savings into the two
categories referenced above: elimination of the need to maintain
separation mailstreams and reduction in operator keying time.
(iv)
Please confirm that these savings are not reflected in LRl-126 or LR-I-127. If not confirmed, please provide a citation to where
these savings are incorporated in the roll forward.
(v)
Please provide throughput per hour and crew size for an
FSM 1000 with an OCR.
Response:
a) The deployment of an OCR on the FSM 661 was completed as of April, 1999.
Please see attached deployment schedule.
b) The percentage of FSM 661s deployed with an OCR is 100 percent.
c) Please see page 5 of Library Reference -1-126, revised February 16,200O. The
calculated savings in this Library Reference, includes reduced costs by
reductions on operator keying time; it does not include any potential benefits of
eliminating the need for separate mail streams. There has been no attempt to
quantify the value, if any, of eliminating the need for separate mail streams.
d) Please see response to c.
e) Not confirmed. Please see page 5 of Library Reference -1-126, revised February
16.2000.
9
Yes, as mentioned on page 11 of my testimony. See response to MPAIUSPST10-4.
(0
There is no deployment schedule available at this time. The plan iS
for 100 percent of FSM 1000s to receive an OCR. See response to
MPAAJSPS-T10-4.
RESPONSE OFUNITED STATES POSTAL SERVICE WITNESS KINGSLEY
TO INTERROGATOklES OF ASSOCldTlON FOR POSTAL COMMERCE
(ii)+(iii) it is premature to project the savings from one and a// OCR
equipped FSM 1000s. The OCR is incorporated with a feeder.
The two cannot be separated. The savings from the Feeder/OCR
will be a function of a number of determining factors which have
not yet been finalized.
(II)
Confirmed
(v)
The OCR throughput would be the same as the FSM 1000 in BCR
mode - approximately 5000 pieces per hour. The crew size is still
being determined since OCR rejects will still need to be keyed and
the performance of the feeders being evaluated has not been
completed. See response to MPANSPS-T10-4.
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RESPONSE OF UNITED STATES POSTAL SERVlCE WITNESS KINGSLEY
TO INTERROGATORIES OF ASSOCIATION FOR POSTAL COMMERCE
POSTCOMIUSPS-TlOS
. Is the Postal Service planning to deploy automatic
feeders on FSM 881 s and FSM 1000~7
(4
If not, why not?
@I
If not, is the Postal Service considering deploying automatic
feeders on FSM 881s and FSM IOOOs? If so, when will the
Postal Service be making a.decision on whether to deploy
automatic feeders on FSM 881s and FSM 1000~7
(c)
If the Postal Service is planning to deploy automatic feeders,
please provide a.schedule for the deployment. If a deployment
schedule is currently unavailable, please explain when a
deployment schedule will be available. Also, please indicate the
percentage of FSM 881s and 1000s upon which you plan
deploying automatic feeders.
(d)
Please provide throughput per hour and crew size for FSM 881s
and FSM 1000s with OCRs and automatic feeders.
(4
What is the annual workhour reduction that would result from
deploying automatic feeders on one FSM 8817 Please provide
all underlying calculations.
(9
What is the annual workhour reduction that would result from
deploying automatic feeders on all FSM 88ls? Please provide
all underlying calculations.
What is the annual workhour reduction that would result from
deploying automatic feeders on one FSM 10007 Please provide
all underlying calculations.
@I
What is the annual workhour reduction that would result from
deploylng automatic feeders on all FSM 1000~7 Please provide
all underlying calculations.
0)
If so, p!ease confirm that these savings are not reflected in LR-I128 or LR-I-127. If not confirmed, please provide a citation to
where these savings are incorporated in the roll forward.
RESPONSE OF UNlTED~ STATES POSTAL SERVICE WlTNESS KINGSLEY
TO INTERROGATORIES OF ASSOCIATION FOR POSTAL COMMERCE
Response:
a) The plan to deploy automatic feeders on FSMs is being currently evaluated.
Please see MPAIUSPS-TlO4.
b) Please see MPAIUSPS-T104.
c) After testing and evaluation are completed, the plan is to deploy automatic
feeders on 100 percent of the FSM 1000s. Please see MPAIUSPS-T104.
d) Not currently available. Please see MPAIUSPS-TlO-5.
e) Not currently available. Please see MPAIUSPS-T104.
9
Not currently available. Please see MPAIUSPS-T104.
g) Not currently available. Please see MPA/USPS-T104.
h) Not currently available. Please see MPAkJSPS-T104.
i) Confirmed.
RESPONSE OF UNITED STATES ,PDSTAL SERVICE WlTNESS KINGSLEY
TO INTERROGATORIES OF ASSbClAilON FOR’POSTAL COMMERCE
. Please refer to the Advanced Flat Sorting Machine
(AFSM) paragraph on page 6 of LR-I-126. In particular, note the final sentence,
which states “Savings for FY 2001 were estimated to decrease 2,715,OOOhours for
clerks (I ,086 machines x 2,500 hours per machine) and cost was estimated to
increase by 410,000 hours for maintenance (I ,086 machines x.377.5 hours).”
POSTCOIWJSPS-TIO-S
(a)
Is the number of AFSM machines mentioned in this paragraph
consistent with the first deployment of AFSM 100s that you discuss in your
testimony?
(b)
Is the “2,500 hours per machine” savings estimate consistent
with the savings that you think should result from deploying one AFSM 100
(c)
Is the “377.5 hours per machine” increase in maintenance
workhours consistent with the increase that you think should result from
deploying one AFSM 1007
(d)
If your response to any of the above was no, please provide
revised estimates of the reduction in clerks workhours and increase in
maintenance workhours that would result from the first deployment of AFSM
100s.
Response:
(a) - (d) LR-I-126 errata was filed on February 18,200O and is now reconciled with
my testimony and includes revised estimates.
DECLARATlON
I, Linda Kingsley, declare under penalty of perjury that the foregoing answers are
true and correct to the best of my knowledge, information, and belief.
CERTIFICATE OF SERVICE
I hereby certii 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.
La-U
Susan M. Duchek
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-1137
(202) 268-2990 Fax -5402
March 9,200O