RESPONSE OF UNITED STATES POSTAL SERVICE
WITNESS STEVENS TO INTERROGATORY OF
THE DIRECT MARKETING ASSOCIATION, INC.
(DMAIUSPS-T20-1)
The United States Postal Service hereby provides the response of witness
Stevens to the following interrogatory of the Direct Marketing Association, Inc.:
DMAIUSPS-T20-1, filed on February 152000.
The 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
Eric P. Koetting
475 L’Enfant Plaza West, SW.
Washington, D.C. 20260-I 137
(202) 266-2992 Fax -5402
February 29,200O
RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS STEVENS TO
INTERROGATORIES OF DIRECT MARKETING ASSOCIATION
DMAIUSPS-T20-1. Please refer to Attachment 4 of your testimony, where you give
depreciation cost and the number of USPS vehicles, derived from the Vehicle
Management Accounting System. Please provide information on the age composition
and depreciated value of the USPS motor vehicle fleet. In particular, please group all
records for motor vehicles by their year of acquisition, and for each year of acquisition
provide 1) the total number of vehicles acquired; 2) the total original cost of the
vehicles; 3) the total number of vehicles still in service in 1996; and 4) the total
depreciated value of the vehicles still in service in 1996. Please provide this information
in both print and electronic spreadsheet forms.
RESPONSE: VMAS removes from its files vehicles and their corresponding records
when they have been disposed of for more than one year. In addition, VMAS
overwrites its tiles. The farthest that we can look back is one year. Because of these
limitations, the data presented in the following table provides a static look at the
database as of AP 5, FY 1999. As a result of vehicles being purged from VMAS during
the first 5 AP’s of 1999 (because they had been disposed of for more than one year),
the total number of vehicles, 204,669, is different from the number shown in my
Attachment 4 (215,898). Consequently, I am only able to provide the requested data
for vehicles that were still on record as of AP 5, FY 1999.
A printed copy is attached. The electronic version is provided as LR-I-206.
-l-
RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS STEVENS TO
INTERROGATORIES OF DIRECT MARKETING ASSOCIATION
SUMMARY OF USPS VEHICLE ACQUISITIONS BY YEAR
Year of
Acquisition
IQ44
1961
1962
1963
1965
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1976
1979
1980
1961
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
TOTAL
Number of
Vehicles
Acquired
Accumulated
Depreciation as of
FY 1999
Acquisition
cost
1
$1,998
1
2
1
1
11
7
6
70
17
5
48
174
567
1373
1268
1521
1688
104
186
3727
5444
4515
1730
696
6708
22213
19971
20423
20408
22437
23490
20667
6062
1362
12210
5575
$474
$6,522
53,878
$255
$55,351
$36.815
$31,326
$373,221
$71,233
$8,346
$106,246
$797,806
$2,020,057
$5,007.958
$5,225,808
86,615.552
$6,928,524
$1.016,755
$1.359,236
$21.285.285
$33.116.880
$33,433,105
$23,354,061
%9,068,706
$98,888,852
S294g618.754
$254,938.343
$287,914.872
5283o472.327
$345,079,768
$361,599.922
$2938537.497
s89,463.226
$30,454.945
$298,175.085
$106,700,737
2046891 $2.896,767.3281
-2-
El,899
$451
$6,196
$3,685
$243
$52,584
$30,166
$29,761
$353,434
$67,675
$7,930
$100,969
$757,836
$1,915,161
$4.755.760
$4,945,279
86,232,902
lb~~474.694
$957,250
Sl,t78,433
517,167.847
$26.829.696
S27s591.726
$21,075.953
$7,938.364
581,692,085
$217,940.526
t168,246.312
$178,327.181
t155,734.698
$179,423.488
$165,323,168
5100,404.802
828g776.247
$9,601,303
$55,510.326
$10,395,989
$1.481.852,037]
DECLARATION
I, Dennis P. Stevens, 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 certify 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.
c FL&
Eric P. Koetting
475 L’Enfant Plaza West, SW.
Washington, DC. 20260-I 137
(202) 268-2992 Fax -5402
February 29,200O