UNITED STATES OF AMERICA
Before The
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
Postal Rate and Fee Changes,
2000
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Docket No. R2000-1
1
OFFICE OF THE CONSUMER ADVOCATE
MOTION TO PERMIT LATE FILING AND FOLLOW-UP INTERROGATORY
TO UNITED STATES POSTAL SERVICE WITNESS PATELUNAS
(OCA/USPS-ST-44-52)
August II,2000
Pursuant
Commission,
permitted
to Sections 21, 26 and 27 of the Rules of Practice of the Postal Rate
the Office of the Consumer
to file a follow-up
submits a follow-up
interrogatory
interrogatory
included with OCA interrogatories
incorporated
Advocate
(“OCA”) hereby (1) moves that it be
to Postal Service witness
and request for production
OCA/USPS-1-14
Patelunas
of documents.
and (2)
Instructions
dated January 24, 2000, are hereby
by reference.
Motion
Under Rule 26(a) follow-up
receipt
of the answer
response
interrogatories
to the previous
to OCA/USPS-ST44-28(b)
This follow-up
interrogatory,
Interrogatory
estimate for FY 2000.
therefore,
are to be filed within seven days of
interrogatory.
In this case, Mr. Patelunas’s
was filed by the Postal Service on August 2,200O.
is filed two days out of time.
OCA/USPS-ST44-28(b)
asked
about
the accuracy
of the cost
That estimate resulted in a forecast net loss of $325.5 million as
-2-
compared
with the earlier forecast
witness Patelunas
ways to accomplish
of net income of $65.6 million.
stated, among other things, that the Postal Service “is still looking for
its FY 2000 financial goal of a $100 million net income.”
After the seven day period expired,
senior Postal Service management
case commitment
OCA become
interrogatory
evaluating
In his response,
the OCA became
very recently
has indicated
aware
of reports
that
that the original
rate
of a $66 million net income in FY 2000 has not changed.’
aware
of this information
within the seven day period,
would have been filed timely.
the reliability of the updated
test year revenue deficiency.
Combined
This issue is of significant
the follow-up
importance
FY 2000 forecast as a step in determining
to
the
with the fact that the request is only two days
out of time, the OCA submits that circumstances
the filing of the follow-up
Had the
warrant granting the motion to permit
interrogatory
Respectfully
submitted,
Director
Office of the Consumer Advocate
SHELLEY S. DREIFUSS
Attorney
1333 H Street, N.W.
Washington, D.C. 20268-0001
(202) 789-6830; Fax (202) 789-6819
Business Mailers Review, August 7, 2000, p. 2.
Docket No. R2000-1
Please
OCANSPS-ST44-52.
refer to your response
to OCALJSPS-ST44-28(b).
The August 7, 2000, issue of the Business Mailers Review reported that “Acting Chief
Financial
Officer Dick Strasser
$66 million has not changed.
to BMR that the rate case-filing
explained
He sent a letter to the management
forecast
committee
of
reiterating
that commitment.”
(a)
Please confirm that such a letter was sent by Mr. Strasser.
(W
Please provide a copy of the letter and any other documents
Postal Service managements
current expectation
related to
of net income or loss
for FY 2000.
(4
If you do not confirm, please explain the origin of the information
by Business Mailers Review and provide
current
position
of Postal Service
all documents
management
of record in this proceeding
in accordance
with Section
practice.
+
Stephanie
Washington, DC.
August II,2000
20268-0001
$66 million.
OF SERVICE
I hereby certify that I have this date served the foregoing
participants
related to the
on the original forecast
that FY 2000 would finish with a net income of approximately
CERTIFICATE
reported
b-vS. Wallace
document
upon all
12 of the rules of