BEFORE THE
'RECEIVEI)
POSTAL RATE COMMISSIO
‘96
WASHINGTON,
D.C. 202&3&o it 91 d 45 PM
POSTAL
ROTEcct4HISS!Oti
OFFICE0; TdE SE(;RElifiy
I
SPECIAL SERVICES REFORM, 1996
Docket
No. MC96-3
RESPONSE OF UNITED STATES POSTAL SERVICE
WITNESS NEEDHAM TO INTERROGATORIES
OF
THE OFFICE OF THE CONSUMER ADVOCATE
(OCA/USPS-T7-21-27)
The United States Postal Service
Needham
to the following
OCAIUSPS-T7-21-26,
interrogatory
interrogatories
and 27(b)-(d),
OCAIUSPS-T7-27(a)
Each interrogatory
hereby provides
responses
of witness
of the Office of the Consumer
filed on July 23, 1996.
was filed on August
is stated verbatim
UNITED
An objection
by the response.
submitted,
STATES POSTAL
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
3-l. w
David H. Rubin
475 CEnfant Plaza West, S.W.
Washington,
D.C. 20260-1137
(202) 268-2986;
Fax -5402
August 6, 1996
to
2, 1996.
and is followed
Respectfully
Advocate:
SERVICE
RESPONSE OF POSTAL SERVICE WITNESS NEEDHAM TO
INTERROGATORIES
OF THE OFFICE OF THE CONSUMER ADVOCATE
OCAIUSPS-T7-21.
Refer to page 25, lines 6-8, of your testimony.
Please confirm
that the additional revenue from the non-resident
fee will be sufficient
to alleviate
the problems caused by non-resident
box service customers.
a.
If you do not confirm,
please provide
the box rates that would
be sufficient.
b.
If you do not confirm,
necessary to alleviate
please provide
the problems.
the amount
revenlue
of additional
RESPONSE:
a and b)
I can confirm
problems,
caused
/---
would
although
thus freeing
provide
Lyons’
no specific
by non-resident
motivate
that the additional
dollar amount
boxholders
some non-residents
up box service
a justification
testimony,
that would
Moreover,
where
the Postal Service
boxholders,
which
for the additional
Landwehr
describes
cover
work
these
all costs
fee
at their local office,
the higher fees would
appropriate.
at 18-l 9. The additional
compensate
alleviate
A non-resident
to seek box service
for box expansion,
witness
would
can be pinpointed.
for residents.
USPS-T-l,
revenue
See witness
revenue
related
in his testimony,
would
also
to non-resident
USPS-T-3.
/--
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RESPONSE OF POSTAL SERVICE WITNESS NEEDHAM TO
INTERROGATORIES
OF THE OFFICE OF THE CONSUMER ADVOCATE
OCAIUSPS-T7-22.
Refer to page 25, lines 6-8, of your
that, “the additional revenue from non-residents
would
Please confirm that
of box service where appropriate.”
non-resident
box customers
will be used to install more
a.
If you do not confirm,
be put.
please explain
b.
If you do confirm, please provide
service where appropriate.”
to what
testimony
where it states
provide funds for expansion
the additional revenue from
post office boxes.
use the additional
revenue
a copy of the plan “for expansion
will
of box
RESPONSE:
Not confirmed.
earmark
7
proposal,
revenue
It is my understanding
for a particular
if implemented,
Please see my response
/--‘
that the Postal Service
purpose.
However,
will lead to increased
to OCAWSPS-T7-21.
does not
I do believe
spending
that my
for box expansion.
RESPONSE OF POSTAL SERVICE WITNESS NEEDHAM TO
INTERROGATORIES
OF THE OFFICE OF THE CONSUMER ADVOCATE
OCA/USPS-T7-23.
Refer to pages
17-25
of your testimony
concerning
post office
box fees.
a.
Please confirm that the current post office box fees are insufficient
to cover
the cost of providing box service.
If you do not confirm, please explain.
b.
Assuming fees are insufficient
to cover the cost of providing box service,
please confirm that it makes sense to limit post office box availability
and to
maintain large waiting lists. If you do not confirm, please explain.
C.
Please describe the policy changes, and the timing of such changes,
regarding the installation
of new box sections to meet customer demand,
assuming adoption of the proposed non-resident
fee.
RESPONSE:
a.
I can confirm
that the current
post office
box cost coverage
is 99.8
percent.
/--Exhibit
USPS-T-l
example,
current
costs,
efficient
In Group
Compare
to increase
See pages 38-39
believes
USPS-T-7
For those
at 3 with
costs,
the cost of
costs
Further,
USPS-T-4
so there
at 44.
is no financial
box fees that do not cover
that it is more practical
the fees to cover
of my testimony.
to cover
(except
and economically
for proposed
the Postal Service
Group
believes
/-
_----
For
fees for Group IC are well above the cost
I, most fees cover
to limit box availability.
the Postal Service
and box size.
in Table VI on page 15 of my testimony,
However,
box service.
Not confirmed.
vary by fee group
box fees in Group II are insufficient
box service.
of providing
incentive
But the results
based on the results
post office
providing
b.
C.
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E).
it is
RESPONSE OF POSTAL SERVICE WITNESS NEEDHAM TO
INTERROGATORIES
OF THE OFFICE OF THE CONSUMER
ADVOCATE
~DCAIUSPS-T7-23
Page 2 of 2
in the customers’
post office
best interests
box service,
to make a high demand
available
to the greatest
extent
service,
such as
possible,
rather
limit its availability.
C.
Policy changes
expansion
and the timing
of these changes
have not yet been formulated.
with
respect
to box
than
RESPONSE OF POSTAL SERVICE WITNESS NEEDHAM TO
INTERROGATORIES
OF THE OFFICE OF THE CONSUMER .ADVOCATE
OCAIUSPS-T7-24.
at what
is made.
Refer to page 25, lines 6-8, of your testimony.
Please explain
level of postal management
the decision to expand post office box service
RESPONSE:
It is my understanding
individual
facility
authorization
that the postmaster
provides
to obtain
important
or officer-in-charge
input for box expansion
more boxes generally
comes
level at each
decisions.
from the District
level of
management.
,‘-
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_-
The
-
RESPONSE OF POSTAL SERVICE WITNESS NEEDHAM TO
INTERROGATORIES
OF THE OFFICE OF THE CONSUMER .ADVOCATE
OCA/USPS-T7-25.
concerning
basis for
estimated
derivation
Refer to page 4, the continuation
of Table I, lines 34-38,
the caller service fee for Delivery Group II. Please explain in detail the
the “estimated
80 percent paying the current size 5 box fee and an
20 percent paying the current subgroup IC caller service fee.”
Show the
of these percentage figures.
Provide all underlying
sources.
RESPONSE:
This is, as stated,
derived
intended
an estimate.
from informal
to be scientific
This estimate
discussions
in nature
with
is based on an average
postmasters.
and is, rather,
This estimate
a “ballpark”
figure.
number
is not
I
/---
RESPONSE OF POSTAL SERVICE WITNESS NEEDHAM TO
INTERROGATORIES
OF THE OFFICE OF THE CONSUMER ADVOCA,TE
OCAIUSPS-T7-26.
a.
Refer to page 25, lines 3-5, of your testimony.
Please provide statistical
data, reports, or other documentation
on the
number of residents “unable to obtain boxes in their own delivery area”,
the alternative,
by Delivery Group.
or in
b.
Please provide statistical
data, reports, or other documentation
on the
number of non-residents
seeking to obtain post office boxes service by
Delivery Group, or in the alternative,
by post office (including ZIP Code).
C.
If you are unable to provide the information
requested in “a” and “b” above,
please state whether you believe the number of residents unable to obtain
boxes in their own delivery area is greater than the number of non-residents
seeking to obtain post office boxes service.
RESPONSE:
,/I--
a and b.
The articles
in Library
unable to obtain
Reference
box service
see the responses
of witness
August
Beyond
2, 1996.
SSR-105
contain
in their delivery
this,
area post office.
Ellard to OCANSPS-TG-18
I cannot
provide
or other documentation
C.
I do not know
which
number
information
would
be greater.
on residents
Also,
please
and 19, filed
any statistical
data,
reports
RESPONSE
OF POSTAL SERVICE WITNESS NEEDHAM TO
INTERROGATORIES
OF THE OFFICE OF THE CONSUMER
ADVOCATE
OCAIUSPS-T7-27.
Refer to your response
to OCAUSPS-T7-10.
a.
Please confirm that there are no restrictions
in the DMM or DMCS that
would prevent the Postal Service from giving priority to residents.
If you do
not confirm, please explain.
b.
Please confirm that non-residents
displaced by residents who receive priority
in box rentals would continue to make a revenue contribution
to the Postal
Service, to the extent such non-residents
obtain box service at another post
office.
If you do not confirm, please explain.
C.
Please explain the basis of your conclusion
that, “determining
priority to residents would appear to be very burdensome.”
d.
Please explain whether the administrative
burden of giving priority to
residents would be greater or less than the administrative
burden now
associated with box rentals to non-residents.
e.
Please explain whether giving priority to residents could be achieved by
establishing,
where necessary, two separate lists: one for residents and the
second for non-residents,
both maintained in the chronological
order of the
request for box service.
f.
Assuming
priority is given to residents over non-residents,
please estimate
the number of non-resident
post office box customers
who would not obtain
post office box service.
when
i,o give
RESPONSE:
a.
Objection
b.
Confirmed,
filed on August
with
reservation.
would
not necessarily
Those
non-residents
contribution
-,
2, 1996.
continue
These “displaced”
non-resident
their box service
that did, of course,
to the Postal Service.
would
However,
at another
continue
boxholders
postal
facility.
to Imake a revenue
the administraltion
of a non
,.
..
RESPONSE OF POSTAL SERVICE WITNESS NEEDHAM TO
INTERROGATORIES
OF THE OFFICE OF THE CONSUMER
ADVOCATE
CCAIUSPS-T7-27
Page 2 of 4
resident
fee would
preclude
a forced
displacement
of the boxholder
population.
C.
Your interrogatory
OCANSPS-T7-10
priority
for box service
service
and renewing
service,
giving
the postal
to residents
With
to residents
would
currently
for providing
over non-residents:
box service.
priority
facility
gave two situations
maintains
respect
initially
to initially
list.
box
a#btaining box
only be moderately
a waiting
obtaining
burdensome
However,
if
not all postal
,/--,.
facilities
maintain
waiting
list would
knowing
check
waiting
lists, and for these particular
be burdensome.
how many potential
These facilities
customers
back at a later date for available
explanations
residency
to potential
customers
prior to being placed
time consuming
facilities,
would
had been turned
box service.
waiting
a
have no way of
away
and tlold to
Additionally,
of why they would
on the residents’
initiating
the
need to establish
list would
be both
and burdensome.
-
. .
./-.
RESPONSE OF POSTAL SERVICE WITNESS NEEDHAM TO
INTERROGATORIES
OF THE OFFICE OF THE CONSUMER ADVOCATE
‘XA/USP:;-T7-27
Page 3 of 4
With
respect
boxholders
to renewing
nightmare.
service
response
and customer
I wish to reiterate
would
be
dissatisfaction
be monumental.
which
non-resident
for residents
the customer
would
to OCAIUSPS-9,
forcing
box service
Inevitably,
from this type of action
Service’s
box service,
out of their boxes to provide
an administrative
resulting
post office
See also the Postal
refers to termination
of bclx
appeals.
that it is not the Postal Service’s
intention1 to take box
/F-“.
service
away from existing
residents
their
d.
Giving
benefiting
local delivery
priority
administratively
mentioned
renewing
customers,
from post office
box service
at a post o-ffice other than
post office.
to residents
burdensome
and providing
box service
burden
box service
in different
in OCAIUSPS-T7-27(c),
administrative
but rather to assess ;a fee for non-
agreements
ways.
giving
However,
priority
practice
would
of providing
are
dlue to the reasons
to residents
for non-residents
than the current
to non-residents
when
be a greatser
box service
non-residents.
-
to
,r--.,
RESPONSE OF POSTAL SERVICE WITNESS NEEDHAM TO
INTERROGATORIES
OF THE OFFICE OF THE CONSUMER ADVOCATE
OCA/USPST7-27
Page 4 of 4
e.
Assuming
before
providing
waiting
that currently
be initiated
would
resident
f.
not provide
to OCANSPS-T6-18
potential
be the problems
do not maintain
significant
fee would
available
to those
by the maintenance
The Postal Service
limited
refers to exhausting
box service
list, there would
offices
could
the interrogatory
relief,
the resident
customers
mentioned
a waiting
list.
of two separate
since the benefits
waiting
list
ori a non-resident
in part c above for
Priority
lists.
for residents
However,
resulting
this
from ia non-
be absent.
has no basis for making
information
is described
and 19, filed August
the requested
in the responses
2, 1996.
estimate.
of witness
The
Ellard
DECLARATION
I, Susan W. Needham,
are true and correct,
Dated:
_/-
declare under penalty of perjury that the foregoing
to the best of my knowledge,
information,
answers
and beliief.
IO ‘ 1%
a
r-
-
.
c-
. ..
CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoing document
participants
of record in this proceeding
in accordance
upon all
with section 12 of the Rules of
Practice.
-Ii. i-i?dLk
David H. Rubin
475 CEnfant Plaza West, S.W.
Washington, D.C. 20260-1137
August 6, 1996
./-
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