UNITED STATES OF AMERICA
Before The
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
Postal Rate and Fee Changes,
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2000)
Docket No. R2000-1
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES
TO UNITED STATES POSTAL SERVICE
WITNESS PATELUNAS (OCA/USPS-ST44-13-32)
JULY 20,200O
Pursuant
Commission,
requests
to Sections
the Office of the Consumer
for production
Instructions
to test
year
included
Advocate
of documents,
purpose of the development
revisions
26 and 27 of the, Rules of Practice of the Postal Rate
of changes
forecasts
and
These
interrogatories
are submitted
to the OCA’s direct case-in-chief
for the
with OCA interrogatories
2000, are hereby incorporated
hereby submits interrogatories
development
of rebuttal
OCAAJSPS-1-14
by reference.
Respectfully
submitted,
TED P. GERARDEN
Director
Office of the Consumer
SHELLEY
Attorney
1333 H Street, N.W.
Washington, D.C. 20268-0001
(202) 789-6830; Fax (202) 789-6819
S. DREIFUSS
u
Advocate
dated
and
for the
in supporting
testimony.
January
24,
2
Docket No. RZOOO-1
OCANSPS-ST44-13.
Attachment
Please
compares
refer to the Attachment
the “after-rates”
to this interrogatory.
effects on costs for the “Statements
and Expense” filed by witness Tayman as Exh. USPS-9A
“Statements
2000.
of Revenue
and Expense”
(a)
Please
cost segment as compared
explain
Mailhandlers
in full
why
the
12,2000,
the
in the “after-rates”
with the
on July 7,
effect on the
to all the other segments.
“after-rates”
effect
on
Clerks
and
costs is so slight in your exhibit (a 0.9% after- rates effect)
versus a 1.7% after-rates
from
of Revenue
filed by you as Exh. USPS-ST-44A
This question focuses on the marked difference
“Clerks and Mailhandlers”
on January
The
Attachment
effect in witness
that
no
other
Tayman’s
cost
exhibit.
segment
(Observe
displays
this
phenomenon.)
(b)
If this effect is due to a non-volume-variable
“cost reduction”
program”
change,
provide
testimony
or exhibits,
please
so state.
Also,
citations
or any Postal Service library references,
or “other
to your
that shed
light on this phenomenon.
(4
If this effect is due to a “cost reduction”
what distribution
subclasses.
or “other program” change, explain
key was used to distribute the change to the classes and
Attachment to Interrogatory
OCAIUSPS-ST-44-13
NBR
PATELUNAS
NAR
Difference
Postmasters
Managers, Supervisors & Technical
Clerks & Mailhandlers
Cag K Clerks
City Carriers
Vehicle Service Drivers
Spec. Delivery Messengers
Rural Carriers
Custodial & Maintenance
Motor Vehicle Services
Miscellaneious Local Operations
Contract Transport
Building Occupancy
Research & Developmt
Equip. Maint. & Mgmt Training Support
Supplies & Services
HQ, Adminis., Corp. Personnel
Depreciation, Write-Offs, Claims, Interest
Final Adjustments
1839.5
3830.5
19269.6
8.7
13716.2
529.9
0
4507.9
2799.9
738.3
361.4
4774.9
1582.7
45.3
52.5
4077.4
5883.5
4330.2
9.2
1832.8
3790.9
19088.3
8.6
13571
518.3
0
4462.7
2788.6
736.6
361.2
4635
1582.7
45.3
52.5
4070
5883.5
4205.4
8.6
6.7
39.6
181.3
0.1
145.2
11.6
0
45.2
11.3
1.7
0.2
139.9
0
0
0
7.4
0
124.8
0.6
TOTAL ACCRUED COSTS
68357.5
67642.1
715.4
.”
.. -
%
NBR
0.4%
1.0%
0.9%
1.1%
1.1%
2.2%
TAYMAN
NAR
1.0%
0.4%
0.2%
0.1%
2.9%
0.0%
0.0%
0.0%
0.2%
0.0%
2.9%
6.5%
1876.3
3822
19442.5
9.7
13787.1
523
0
4399.9
2791.9
724.3
328
4755.1
1633.7
45.3
48.5
3814.2
5767.2
4274.8
3
1869.4
3782.6
19118.1
9.6
13638.1
511.9
0
4355.6
2780
722.7
327.8
4619.6
1633.7
45.3
48.5
3807.5
5767.2
4150
2.8
1 .O%
68046.6
67190.6
-
. . .^
.-
Difference
%
6.9
39.4
324.4
0.1
149
11.1
0
44.3
11.9
1.6
0.2
135.5
0
0
0
6.7
0
124.8
0.2
0.4%
1.0%
1.7%
1.0%
1.1%
2.1%
1.0%
0.4%
0.2%
0.1%
2.8%
0.0%
0.0%
0.0%
0.2%
0.0%
2.9%
6.7%
856
1.3%
Docket No. R2000-1
3
OCANSPS-ST44-14.
Services”
million,
Please
is $255
from
underlying
Exh. USPS-ST-44A
Cite to testimony,
that your FY 2000 estimate
million higher. than witness
assumptions
also provide
confirm
and
and changes
Exh.
Tayman’s
USPS
($3805.6
&
million - 3550.6
9A, respectively).
that cause such a dramatic
exhibits, or library references
of “Supplies
Explain
increase
all
in this cost.
that shed light on this phenomenon;
any other primary or intermediate
sources for the determination
of this
cost.
OCANSPS-ST44-15.
Services”
million,
Please
is $263.2
from
underlying
USPS-ST-44A
assumptions
also provide
that
your
million higher than witness
Exh.
Cite to testimony,
confirm
and
and changes
exhibits,
Exh.
TYBR
estimate
Tayman’s
($4077.4
USPS
any other primary or intermediate
&
million - 3814.2
9A, respectively).
that cause such a dramatic
or library references
of “Supplies
Explain
increase
all
in this cost.
that shed light on this phenomenon;
sources for the determination
of this
cost.
OCAfUSPS-ST44-16.
& Corporate
Personnel
million - 5414.7
phenomenon;
determination
Costs” is $96 million higher than witness
million, from Exh. USPS-ST-44A
Explain all underlying
this cost.
Please confirm that your FY2000 estimate of “HQ & Area Admin.
assumptions
Cite to testimony,
also
provide
of this cost,
($5510.7
and Exh. USPS 9A, respectively).
and changes that cause such a dramatic increase in
exhibits,
any
Tayman’s
other
or library references
primary
that shed
or intermediate
light on this
sources
for the
4
Docket No. R2000-1
OCANSPS-ST44-17.
Corporate
Personnel
million - 5767.2
Admin. &
Costs” is $116.3 million higher than witness Tayman’s
($5883.5
million, from Exh. USPS-ST-44A
Explain all underlying
this cost.
Please confirm that your TYBR estimate of “HQ &Area
assumptions
Cite to testimony,
phenomenon;
determination
also
provide
and changes that cause such a dramatic increase
exhibits,
any
and Exh. USPS 9A, respectively).
or library
other
primary
references
or
that shed light on this
intermediate
sources
for
the
of this cost.
OCANSPS-ST-44-18.
Please refer to Exhibit USPS-ST-44AB.
“Key Inflation
in the original filing versus the revised filing, the % change
annual
in
Indices”
index for FY 2000,
“CPI-Urban
Wage
and Clerical
In the table comparing
Workers,”
in
has been an
increase of 0.56%, i.e., 3.29% for the revised filing versus 2.73% in the original filing.
Please give a ballpark estimate for the percentage
cost figure for FY 2000 that is directly affected
Workers index.
CPI-Urban
of the $65.1715
billion total accrued
by the CPI-Urban
Wage and Clerical
Also state all cost segments/components
directly affected by use of the
Wage and Clerical Workers index.
OCANSPS-ST-44-19.
Please refer to Exhibit USPS-ST-44AB.
In the table comparing
“Key Inflation Indices” in the original filing versus the revised filing, the annual index for
FY 2000, “ECI-Wages
and Salaries-Private
Industry,”
has not been changed,
3.22 % index figure is used both in the revised filing and the original filing.
a ballpark estimate
for the percentage
of the $65.1715
for FY 2000 that is directly affected by the ECI-Wages
Le., a
Please give
billion total accrued
cost figure
and Salaries-Private
Industry
Docket No. R2000-1
index.
5
Also state all cost segments/components
Wages and Salaries-Private
OCANSPS-ST-44-20.
“Key Inflation
directly affected
Industry index.
Please refer to Exhibit USPS-ST-44AB.
estimate for the percentage
affected
of the $65.1715
by the Public
Please give a ballpark
billion total accrued cost figure for FY 2000
Transportation
index.
Also
segments/components
directly affected by use of the Public Transportation
OCAfUSPS-ST-44-21.
Please refer to Exhibit USPS-ST-44AB.
“Key Inflation
i.e., 6.17%
state
all cost
index.
In the table comparing
Indices” in the original filing versus the revised filing, the % change
annual index for FY 2000, “Transportation
for the revised
filing versus
ballpark estimate for the percentage
FY 2000 that is directly affected
cost segments/components
Services,”
3.78% in the original
of the $65.1715
affected
in
has been an increase of 2.39%,
filing.
Please give a
billion total accrued cost figure for
by the Transportation
directly
in
has been an increase of 4.67%, i.e.,
7.22% for the revised filing versus 2.55% in the original filing.
is directly
In the table comparing
Indices” in the original filing versus the revised filing, the % change
annual index for FY 2000, “Public Transportation,”
that
by use of the ECI-
Services
index.
Also state all
by use of the Transportation
Services
index.
OCANSPS-ST-44-22.
“Key Inflation
Please refer to Exhibit USPS-ST-44AB.
In the table comparing
Indices” in the original filing versus the revised filing, the % change
annual index for FY 2000, “Rent,” has been a decrease
revised filing versus 3.33% in the original filing.
in
of 0.04%, i.e., 3.29% for the
Please give a ballpark estimate for the
Docket No. R2000-1
percentage
affected
6
of the $65.1715
by the Rent index.
billion total accrued
cost figure for FY 2000 that is directly
Also state all cost segments/components
directly affected
by use of the Rent index.
OCANSPS-ST-44-23.
Please refer to Exhibit USPS-ST-44AB.
“Key Inflation
in the original filing versus the revised filing, the % change
Indices”
annual index for FY 2000, “Supplies
& Materials,”
that
is directly
affected
of the $65.1715
by the Supplies
Please give a ballpark
billion total accrued cost figure for FY 2000
& Materials
index.
Also
state
all cost
segments/components
directly affected by use of the Supplies & Materials index.
OCAAJSPS-ST-44-24.
Please refer to Exhibit USPS-ST-44AB.
“Key Inflation
in the original filing versus the revised filing, the % change
Indices”
annual index for FY 2000, “Electricity,”
directly
of the $65.1715
affected
by the Electricity
In the table comparing
in
has been an increase of 2.94%, i.e., 2.69% for
the revised filing versus - 0.25% in the original filing.
the percentage
in
has been an increase of 1.28%, i.e.,
4.42% for the revised filing versus 3.14% in the original filing.
estimate for the percentage
In the table comparing
Please give a ballpark estimate for
billion total accrued
index.
cost figure for FY 2000 that is
Also state all cost segments/components
directly affected by use of the Electricity index.
OCANSPS-ST-44-25.
Please refer to Exhibit USPS-ST-44AB.
“Key Inflation
in the original filing versus the revised filing, the % change
Indices”
In the table comparing
in
annual index for FY 2000, “Gas & Oil,” has been an increase of 13.03%, i.e., 30.69%
for the revised filing versus 17.66% in the original filing.
Please give a ballpark estimate
7
Docket No. R2000-1
for the percentage
directly
affected
of the $65.1715
billion total accrued
by the Gas & Oil index.
cost figure for FY 2000 that is
Also state all cost segments/components
directly affected by use of the Gas & Oil index.
OCAAJSPS-ST-44-26.
Please refer to Exhibit USPS-ST-44AB.
“Key Inflation Indices”
in the original filing versus the revised filing, the % change
annual index for FY 2000, “Air Freight,” has been a decrease
the revised filing versus 1.98% in the original filing.
the percentage
directly
affected
of the $65.1715
index.
in
of 1.08%, i.e., 0.90% for
Please give a ballpark estimate for
billion total accrued
by the Air Freight
In the table comparing
cost figure for FY 2000 that is
Also state all cost segments/components
directly affected by use of the index.
OCAIUSPS-ST-44-27.
Please refer to Exhibit USPS-ST-44AB.
“Key Inflation Indices”
in the original filing versus the revised filing, the % change
annual index for FY 2000, “Interstate
i.e., 3.80% for the revised
in the original
of the $65.1715
directly
affected
filing.
Please give a
billion total accrued cost figure for
FY 2000 that is directly affected by the Interstate Trucking
cost segments/components
in
Trucking Costs,” has been an increase of 1.16%,
tiling versus 2.64%
ballpark estimate for the percentage
In the table comparing
Costs index.
by use of the Interstate
Also state all
Trucking
Costs
index.
OCAIUSPS-ST-44-28.
(a)
Please confirm the following statements:
The Postal
Service’s
reflects more current
revised total accrued
cost estimate
for FY 2000
key inflation indices than the original total accrued
Docket No. R2000-1
8
cost estimate
for FY 2000 filed on January
12, 2000.
If you do not
confirm, then present all reasons for not confirming.
(b)
As a result of the use of more current key inflation indices in the revised
filing (versus the original filing), the revised total accrued cost estimate for
FY 2000 is likely to be more accurate than the original estimate.
If you do
not confirm, then present all reasons for not confirming.
OCANSPS-ST-44-29.
(a)
Please confirm the following statements:
The Postal Service’s
revised total accrued cost estimate for the FY 2001
test year reflects more current key inflation indices than the original total
accrued cost estimate for the FY 2001 test year filed on January
12, 2000.
If you do not confirm, then present all reasons for not confirming.
(b)
As a result of the use of more current key inflation indices in the revised
filing (versus the original filing), the revised total accrued cost estimate for
the FY 2001 test year is likely to be more accurate
estimate.
If you
do not confirm,
then
present
than the original
all reasons
for not
confirming.
OCANSPS-ST-44-30.
For each of the Key Inflation Indices set forth in Exh. USPS-ST-
44AB, state the date that original filing inflation index was generated,
Urban Wage and Clerical Workers,
Public Transportation,
(g) Electricity,
(b) ECI-Wages
(d) Transportation
Services,
i.e., for (a) CPI-
and Salaries-Private
Industry, (c)
(e), Rent, (f) Supplies
& Materials,
(h) Gas & Oil, (i) Air Freight, and (j) Interstate Trucking Costs.
Then state
Docket No. R2000-1
9
how many months later the revised filing inflation index was generated.
information
for all Key Inflation Indices used for FY 2000 and FY 2001 (Test Year).
OCAIUSPS-ST-44-31.
applied
Provide this
the formula
Please refer to USPS-T-9
“Employment
Cost
at 19, lines 3-14.
Index for Wages
Industry, less one percent, (ECI minus 1) for bargaining
effective in the test year.”
Have you applied
your revised estimate of bargaining
and Salaries
for Private
units that do not have contracts
the same formula, i.e., ECI minus 1, in
unit wages for the test year (excluding
contract extends through the test year)?
OCAIUSPS-ST-44-32.
Witness Tayman
NALC whose
If not, explain fully.
Please refer to the following
news item published
in PostCom
Bulletin, July 14, 2000:
STRASSER REVEALS NET LOSS, BOG APPROVES FUNDING. At the
July 11 USPS Board of Governors meeting, Acting Chief Financial Officer
and Executive Vice President Richard J. Strasser, Jr.
that a big
portion of the unplanned costs in fiscal year 2000 was due to workers’
compensation
increases of $100 million, transportation
and fuel cost
increases of $240 million, and cost of living raises of $50 million. Every
penny increase in the price of gasoline adds $5 million to annual
transportation costs.
(4
Has PostCom accurately
of Governors?
reported
Mr. Strasser’s
statements
to the Board
If not, please provide the correct figures and state their
source.
(b)
Have the cited $100 million of workers’
directly
presented
incorporated
into the
in USPS-ST-44A?
FY 2000
compensation
total
accrued
increases
cost
been
estimate
If so, explain how it has been incorporated,
10
Docket No. R2000-1
including
citations to testimony,
other exhibits,
this increase has not been incorporated,
(c)
incorporated
presented
including
into the
in USPS-ST-44A?
FY 2000
citations to testimony,
the
cited
incorporated
total
other exhibits,
million
of cost
If so, explain
to testimony,
accrued
other
CERTIFICATE
of living
raises
cost estimate
exhibits,
and library
been
directly
presented
in
including
references.
If this
document
upon all
OF SERVICE
in accordance
with Section
Practice.
,,e,,,,,_
Stephanie
Washington, D.C. 20268-0001
July 20, 2000
If
explain why not.
I hereby certify that I have this date served the foregoing
of record in this proceeding
estimate
and library references.
how it has been incorporated,
increase has not been incorporated,
participants
cost
been
explain why not.
into the FY 2000 total accrued
USPS-ST-44A?
citations
$50
and fuel increases
If so, explain how it has been incorporated,
this increase has not been incorporated,
Have
If
explain why not.
Have the cited $240 million of transportation
directly
(4
and library references.
.~ecu?
S. Wallace
12 of the Rules of