BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D. C. 20268-0001
RECEIVED
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POSTAL RATE AND FEE CHANGES, 2001
:
Docket No. R2001-1
INTERROGATORIES OF ADVO, INC.
TO UNITED STATES POSTAL SERVICE WITNESS
MICHAEL BRADLEY (ADVOIUSPS-T16-I-6)
Pursuant to sections 2.5 and 26 of the Rules of Practice, Advo, Inc. (Advo)
directs the following
interrogatories
to United States Postal Service witness
Bradley.
If the witness is unable to respond to any interrogatory,
response
be provided
by appropriate
we request that a
USPS witness capable of providing
Respectfully
Michael
an answer.
submitted,
Thomas W. McLaughlin
Burzio & McLaughlin
1054 31st Street, N.W.
Washington, D. C. 20007
Counsel for ADVO, INC.
CERTIFICATE
OF SERVICE
I hereby certify that I have on this date served the foregoing document upon all
@f the Rules of
participants of record in this proceeding in accordance with section
Practice.
November
30. 2001
ADVO, INC. INTERROGATORIES
ADVO/USPS-T16-1.
TO USPS WlTNESS MICHAEL BRADLEY
Please refer to section V, line 17 of your testimony where you
refer to the Commission’s
systemwide
load time formulation
as:
LT = H {(VL + VF + VP)/AS} *AS,
where load time (LT) is a function of the volumes of letters, flats, and parcels (VL, VF
and VP ) and actual stops (AS).
(4
Does your critique of the Commission’s
described
in section C of your testimony also apply to your use of this
function for deriving incremental
(b)
costs?
Is your critique of the Commission’s
stop level data?
(4
H function formulation
Please explain fully.
H function specific to the use of
Please explain fully.
Could system level load time be represented
using data aggregated
higher than the stop level? Please explain fully.
ADVOWSPS-T16-2.
refer to systemwide
Please refer to page 34 line 20 of your testimony where you
average load time as:
LT = (Y(VL/AS)EL (VF/AS)EF (Vp/AS)Ep
*AS.
Please confirm that this function can also be written as:
LT = a (V,)EL (vFyF
(VP)@ *AS (f-EL-~-&p).
If not, please explain why not.
ADVOlUSPS-T16-3.
For purposes
any route i can be explained
of this question,
please assume that load time for
by
LT, = a (v&
(I/,)&F
(v,)Ep
*ASi (f-EL-&F-Ep),
where VLi, VFi, and Vpi are route letter, flat and parcel volumes, and ASi is the number
of actual stops on the route. Under this assumption, would you agree that the route
level parameter values a, .sL, eF, and ap for this function could be estimated using
route level data for LT, V,, VF , VP and AS if such data were available?
explain why not. If you disagree with the above formulation,
why.
If not, please
please separately
explain
-2-
ADVONSPS-T16-4.
Assume two subclasses A and 6 with volumes of letters, flats
and parcels on route i such that !I,; = VLAi + VLsi, VFj = VFAi + VFsi and V, = VpAi +
Vpsi
Please confirm that route i load time can then be represented
previous function in ADVOIUSPS-T16-3
using the
as:
LTi = a (Vui + VLBJeL (VFai + VFB;)EF (VpAi + Vpsi)Ep *AS, (‘-EL-EF-Ep).
If not, please explain why not.
ADVONSPS-T16-5.
For purposes
stops are explainable
by route level subclass volumes and possible stops (PS) such
of this question, assume that route level actual
that for route i :
ASi = f(VAi > Vsi z Psi),
where VAi = VLAi + VFAi + VpAi and Vsi = VLsi + VFsi + VpBi.
Under this assumption,
explained
please confirm that route i load time can then be fully
by that route’s volume variables
combination,
and possible
shown by shape and subclass
stops from:
LTi = a (VLAi + VL,i)EL (VFAi + VFsi)EF (Vpai + Vp,JEp
f (Vuj
*
+ VFAi + VpAj , VLsi + VFSj + VpBi I Psi) (‘-EL-EF-Ep)
If not, please explain why not. If you disagree with the above formulation,
separately
please
explain why.
ADVOIUSPS-T16-6.
Consider
M number of total routes in the postal system. Please
confirm that system level load time can be represented
from routes 1 through
M, each route load time estimated
respective
volume and possible stop variables
route-level
please explain why not.
as the sum of the load times
as a function of the
indicated above.
If not,