RECEIVE!)
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
POSTAL RATE AND FEE CHANGES, 2000
Docket No. R2000-1
j
REVISED RESPONSE OF UNITED STATES POSTAL SERVICE
WITNESS PATELUNAS TO INTERROGATORIES
OF
THE MAJOR MAILERS ASSOCIATION
(MMAJUSPS-ST44-4
and 5)
The United States Postal Service hereby provides the revised responses of
witness Patelunas
MMAJUSPS-ST44-4
to the following interrogatories
of the Major Mailers Association:
and 5, filed on July 24, 2000. The original responses
on August 1, 2000. The original responses
contained
some incorrect amounts, as
pointed out during hearings on August 3, 2000. Tr. 35/16744-45
revised responses
were filed
and 16749. The
reflect the correct amounts shown in the cited sources.
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 L’Enfant Plaza West, SW.
Washington, D.C. 20260-i 137
(202) 268-2990 Fax -5402
August 8,200O
Response
of United States Postal Service witness Patelunas
to Interrogatories of
Major Mailers Association
Revised a/al00
Please refer to the attachment to this interrogatory
MMAIUSPS-ST44-4
marked “Attachment to MMAIUSPS-ST44-4”
that compares the updated test
year after rates volume variable costs by subclass from EXHIBIT USPS-ST-44W
with the original (revised) test year after rates volume variable costs by subclass
from USPS-T-326.
(a)
Please confirm that all of the cost figures, differences and percent
differences are correct. If you cannot confirm, please make any
necessary corrections and explain each of those corrections separately.
(b)
Please provide a full, detailed explanation
affect:
1)
2)
3)
4)
First-Clas$
First-Clas$
Standard
Standard
for each of the changes that
Single Piece
Presorted
Mail (A) Regular
Mail (A) ECR
Response:
(a)
Not confirmed.
I am not able to explain where some of the amounts in
column (I), Updated Vol Variable Costs, of the Attachment
4 were found.
to MMA/USPSST44-
I am providing the correct amounts from Exhibit USPSST44W
and for each amount in column (1) that changes, the Difference in column (3)
and the % Difference
in the last column will also change.
from Exhibit USPSST44W
The following amounts
should replace the amounts displayed
Updated Vol Variable Costs, in the Attachment
in column (1).
to MMA/USPS-ST44-4:
Response
of United States Postal Service witness Patelunas
to Interrogatories of
Major Mailers Association
Response
continued:
First-Class Mail
Single-Piece Letters
Presort’and Automation
Total Letters
Total First-Class Mail
Letters
Priority Mail
Revised 8/8/00
13565,268
5,081,634
l&646,902
19,364,335
3,194,542
Total Standard
Mail (B)
1,987.663
Total All Mail
39,755,198
Special Services
Insurance
COD
Total Special Services
79,549
16,629
1,546,107
41,301,305
Total Mail & Services
311,709
Prior Years Loss Recovery
69,644,860
Grand Total
It should be noted that the Prior Years Loss Recovery amount is found in
Exhibit USPS-ST44A.
Also, the line stubs in Attachment
to MMA/USPSST444
do not exactly match the lines stubs shown in Exhibit USPS-ST44W.
amount shown for Periodicals
summation
Outside County in the attachment
of the following lines in Exhibit USPS-ST44W:
The
is the
Nonprofit, Classroom
and Regular Rate. The amount shown for Special Services Other in the
attachment
is the summation
of the lines for Special Handling and Special
Services Other in Exhibit USPS-ST44W.
(b)
Please see my response to AAP/USPS-ST44-9.
mac!lment
to MMNUSPS-ST444
Response
of United States Postal Service witness Patelunas
to Interrogatories of
Major Mailers Association
Revised alaloa
MMA/USPS-ST44-5
Please refer to the attachment to this interrogatory
marked “Attachment to MMA/USPS-ST44-5”
that compares the updated test
year before ratesvolume variable costs by subclass from EXHIBIT USPS-ST44W with the original (revised) test year after rates volume variable costs by
subclass from USPS-T-32B.
(a)
(b)
Please confirm that all of the cost figures, differences and percent
differences are correct. If you cannot confirm, please make any
necessary corrections and explain those corrections.
Please provide a full, detailed explanation
affect:
1)
2)
3)
4)
for each of the changes that
First-Class Single Piece
First-Class Presorted
Standard Mail (A) Regular
Standard Mail (A) ECR
Response:
(a) Not confirmed.
I am not able to explain where some of the amounts in
column (I), Updated Vol Variable Costs, of the Attachment
4 were found.
to MMAIUSPS-ST44-
I am providing the correct amounts from Exhibit USPS-ST44T
and
for each amount in column (1) that changes, the Difference in column (3) and the
% Difference
in the last column will also change.
Exhibit USPSST44T
The following amounts from
should replace the amounts displayed
Updated Vol Variable Costs, in the Attachment
in column (1)
to MMALJSPS-ST44-4:
Response
of United States Postal Service witness Patelunas
to Interrogatories of
Major Mailers Association
Response
continued:
Total All Mail
Revised alaloo
40,460,067
Total Special Services
1,595,434
42,055,501
Total Mail & Services
Prior Years Loss Recovery
311,709
70,378,144
Grand Total
It should be noted that the Prior Years Loss Recovery amount is found in
Exhibit USPS-ST44A.
Also, the line stubs in Attachment
to MMAIUSPS-ST44-4
do not exactly match the lines stubs shown in Exhibit USPS-ST44T.
shown for Periodicals
Outside County in the attachment
following lines in Exhibit USPSST44T:
is the summation
Nonprofit, Classroom
(b)
is the
of the lines for Special Handling and Special Services Other in
Exhibit USPSST44T.
Please see my response to AAP/USPS-ST44-9.
of the
and Regular Rate.
The amount shown for Special Services Other in the attachment
summation
The amount
‘DECLARATION
I, Richard Patelunas, declare under penalty of perjury that the foregoing answers to
interrogatories are true and correct to the best of my knowledge, information, and belief.
Dated:
g o
A-
0D
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.
JkL ?fdiiA
Susan M. Duchek
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-t 137
(202) 268-2990 Fax -5402
August a, 2000