.
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON,
D.C. 20268-0001
RE,zE{!jC,!)
SEP 9
v:,r;,bN
Mailing Online Service, 1998
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Docket~,No. MC98-1
)
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES
TO UNITED STATES POSTAL SERVICE
WITNESS: PAUL G. SECKAR
(OCA/USPS-T2-11-16)
September 9, 1998
Pursuant to sections 25 and 26 of the Rules of Practice of the Postal Rate
Commission,
the Office of the Consumer
requests for production
OCA/USPS-Tl-1-7
incorporated
of documents;
Advocate
Instructions
hereby submits interrogatories
included with OCA interrogatories
to witness Lee Garvey, dated July 21, 1998, are hereby
by reference.
Respectfully
and
submitted,
Gail Willette
Acting Director
Office of the Consumer Advocate
Shelley S. Dreifuss
Attorney
,2
Docket No; MC98-1
OCAAJSPS-TZI I.
Please refer to USPS-T-2,
Exhibit A, Table 14.
a.
Please explain the phrase “System Developer”
b.
Please provide a detailed breakdown
$1,138,310,
C.
l/MC98-1,
a.
found on line (29).
Please refer to USPS-T-2,
Attachment
costs incurred?
Exhibit A, Table 14, and USPS-LR-
2 at 18.
For 1999, please confirm that the total information
$1,145,387.
b.
of the system developer costs of
In what year(s) are the system developer
OCAIUSPS-T2-12.
on line (29).
systems fixed costs are
If you do not confirm, please explain.
Please confirm that the system developer cost is $1,138,310.
If you do not
confirm, please explain.
C.
Please confirm that the information
developer
d.
costs, are $2,283,697.
Please confirm that the information
developer
costs, to be recovered
systems fixed costs, including system
If you do not confirm, please explain.
systems fixed costs, including system
in 1999 are $831,867.
If you do not confirm,
please explain.
e.
Please confirm that the information
developer
costs, to be recovered
systems fixed costs, including system
in 2000 are $1,451,830.
If you do not confirm,
please explain.
OCA/USPS-TZ13.
LR-l/MC98-1,
Please refer to USPS-T-2,
Attachment
2 at 18.
Exhibit A, Tables 14 and 15, and USPS-
3
Docket No. fvlC98-1
a.
For 1999, please confirm that the total information
$1,558,624.
b.
For 2000, please confirm that the total information
costs, and information
is $2,390,491
d.
OCAWSPS-T2-14.
b.
system variable costs, to be recovered
+ $1,558,624).
costs, and information
is $3,484,345
a.
($831,867
system fixed costs, including system
($1,451,830
system fixed costs, including system
system variable costs, to be recovered
+ $2,032,515).
Please refer to USPS-T-2,
in 1999,
If you do not confirm, please explain.
Please confirm that the total of information
developer
systems variable costs are
If you do not confirm, please explain.
Please confirm that the total 9f information
developer
systems variable costs are
If you do not confirm, please explain.
$2,032,515.
C.
’
in 2000,
If you do not confirm, please explain.
Exhibit A, Tables 14 and 15.
For 1999, please confirm that the average information
costs), per transaction,
system fixed cost
(including
system developer
is $11.60 ($831,867
71,722).
If you do not confirm, please explain and provide the correct figure.
For 1999, please confirm that the average information
transaction,
is $21.73 ($1558,624
/71,722).
I
system variable cost, per
If you do not confirm, please
explain and provide the correct figure.
C.
For 1999, please confirm that the total average information
and variable), per transaction,
is $33.33 ($2,390,491
system cost (fixed
171,722).
If you do not
confirm, please explain and provide the correct figure.
d.
For 1999, please confirm that if the average number of pieces per transaction
less than the 4,120 assumed by witness Stirewalt,, then the total average
is
.
.
Docket No. MC98-1
4
information
system cost per piece would be higher than the $0.0012 cents per
impression
calculated
in USPS-T-2,
Exhibit A, Table 1. If you do not confirm,
please explain.
OCA/USPS-T2-15.
Please refer to USPS-LR-lIMC98-I,
Attachment
1, page 6. Please
confirm that the “YR 2000 Estimate” for the total annual number of Mailing Online
transactions
year).
is 125,268 (10,439 users x 12 average customer sessions per user per
If you do not confirm, please explain and provide the correct figure.
OCAIUSPS-T2-16.
a.
Please refer to USPS-T-2,
For 2000, please confirm that the average information
(including system developer
125,268).
b.
Exhibit A, Tables 14 and 15.
costs), per transaction,
system fixed cost
is $11.59 ($1,451,830
If you do not confirm, please explain and provide the correct figure.
For 2000, please confirm that the average information
transaction,
I
is $16.23 ($2,032,515
I 125,268).
system variable cost, per
If you do not confirm, please
explain and provide the correct figure.
C.
For 2000, please confirm that the total average information
and variable), per transaction,
is $27.82 ($3,484,345
system cost (fixed
I 125,268).
If you do not
confirm, please explain and provide the correct figure.
d.
For 2000, please confirm that if the average number of pieces per transaction
less than the 4,119 assumed by witness Stirewalt, then the total average
information
system cost per piece would be higher than the $0.001 cents per
is
.
.
Docket No. MC98-1
impression
calculated
5
in USPS-T-2,
I
Exhibit A, Table 1. If you do not confirm,
please explain.
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the foregoing
participants
of record in this proceeding
in accordance
upon all
with section 12 of the rules of
practice.
Shelley S. Dreifuss
Attorney
Washington, D.C. 20268-0001
September 9,1998
document