p’:
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, DC 20268-0001
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Docket No. R2000-1
Postal Rate and Fee Changes, 2000
ERRATA TO
SECOND INTERROGATORIES
OF ALLIANCE OF NONPROFIT
TO USPS WITNESS TAYMAN (ANMIUSPS-T9-45-49)
The Alliance
question
Mailers
in its second set of discovery
on February
combined,
of Nonprofit
29, 2000.
In question
(‘ANM”)
has discovered
MAILERS
a minor error in one
requests to USPS witness Mark F. Ramage, filed
ANMIUSPS-T2-19,
and part (j) should be renumbered
parts (h) and (i) should
as (i). The corrected
text of the question is
attached.
Respectfully
submitt.ed,
David M. Levy
Christopher T. Shenk
Sidley & Austin
1722 Eye Street, N.W.
Washington, DC 20006-3704
(202) 736-8214
Counsel for Alliance of Nonprofit Mailers
March 10, 2000
be
ANMKJSPS-TZ-19.
hereby incorporated
the attachment
This question refers to attachment
as part of the question.
are from LR-I-96.
ANMIUSPS-T2-19,
The mail processing
The percentages
which is
cost and volume data in
in the bottom portion are computed
from the data in the top part.
Please confirm that the mail processing
(4
portion have been correctly transcribed.
Please
(b)
Commercial
constitute
reasonably
cost-causing
(c)
presort
condition
and weight,
the three
shown here (Basic, Auto and High Density/Saturation
homogeneous
ECR letter counterparts?
significant
data in the top
If you do not confirm, provide the correct data.
that, for shape,
ECR letter categories
combined)
Nonprofit
confirm
cost and volume
subcategories
vis-a-vis
their respective
If you do not confirm, please provide and discuss all
differences.
The bottom portion of the table in the attachment
indicates
that, for Auto
ECR letters, the Nonprofit Test Year volume (439 million) amounts to 17.4 percent of the
Commercial
volume (2,528 million), while nonprofit
Year amount to 17.9 percent of commercial.
percentages
is unsurprising
dollar-weighted
IOCS tallies in Test
Please confirm that the similarity of the two
in light of the homogeneity
of the mail.
Please explain fully
any failure to confirm.
Cd)
The bottom portion of the table also shows that in Test Year Basic Nonprofit
ECR, letters Nonprofit
Commercial
receive 28.9 percent of the dollar-weighted
ECR letters, yet the volume
amounts
to only 12.3 percent
million).
If Nonprofit
of Nonprofit
attributed
to
ECR Basic letters (888 million)
of the volume of Commercial
and Commercial
amount
ECR Basic letters (7,212
ECR Basic letters have an equal chance of being
-2-
sampled each time an IOCS tally happens to be taken from ECR Basic letters, what is the
probability
of drawing
respective
rate category?
a sample
that is so disproportionate
to the volumes
of each
What is the coefficient of variation (CV) for the mail processing
cost estimate for Nonprofit Basic ECR letters?
(4
For all ECR non-letters
4.6 percent
(based
of Commercial
on dollar-weighted
Nonprofit
combined,
Nonprofit volume (934 million) amounts to
volume (20,502 million) while Nonprofit
IOCS tallies)
and ECR non-letters
amounts
to 12.0 percent
have an equal chance
IOCS tally happens to be taken from ECR non-letters,
sample that is so disproportionate
the coefficient
High Density/Saturation
cost
of Commercial.
of being sampled
If
each time an
what is the probability
to the volumes of each respective
of variation for the mail processing
letters, (ii) Nonprofit
mail processing
of drawing a
category?
What is
cost estimate for (i) Nonprofit Basic non-
non-letters,
and (iii) all Nonprofit
non-letters
combined?
For all ECR combined,
(9
of Commercial
Nonprofit volume (2.9 million) amounts to 8.6 percent
volume (33.6 billion), while dollar-weighted
Nonprofit
(based on IOCS tallies) amounts to 17.3 percent of Commercial.
mail processing
If Nonprofit
cost
ECR mail
has an equal chance of being sampled each time an IOCS tally happens to be taken from
ECR mail, what is the probability
volumes
of each respective
processing
(9)
of drawing a sample what is so disproportionate
category?
What is the coefficient
of variation
to the
for the mail
cost estimate for all Nonprofit ECR mail?
The table in the attachment
For each mail processing
cost estimate
relies solely on dollar-weighted
shown
IOCS tallies.
in the top portion of the table, please
provide the number of direct tallies that underlie and form the basis for the dollar-weighted
-3-
cost estimate.
estimates,
please explain (i) which operations
than-average
million)
with higher-than-average
and their associated
to only 8.8 percent
part
(9, the
of Commercial
if small is defined as anything less than 10 percent.
volume
cost estimates
differences
in the sample?
distributed
(33.6
among
billion).
be described
From a statistical viewpoint,
a relatively small volume for obtaining
processing
0)
tallies have a higher-
volume of all Nonprofit ECR (2.9
basis, the volume of Nonprofit ECR might reasonably
million pieces constitute
cost
cost.
As pointed out in the preceding
amounts
percentage
in proportion to the dollar-weighted
cost, and (ii) why were nonprofit tallies disproportionately
the operations
0.0
If the raw tallies are not distributed
reasonably
that are not likely to offer much variation
On a
as “small,”
does 2.9
accurate
mail
owing to random
How large do the volume and the sample have to be before one can expect
relatively little variation in the cost estimate owing to random variation?
-4-
CERTIFICATE
I hereby
participants
certify
that I have this day served
of record in this proceeding
Practice.
March 10.2000
OF SERVICE
in accordance
the foregoing
with section
document
on all
12 of the Rules of