PRESIDING
RULING NO.
OFFICER'S
MC96-3/12
UNITED STATES OF AMERICA
POSTAL RATE COMMISSION
WASHINGTON,
D.C.
20268-0001
Special
Services
Fees
and
Classifications
Docket
No.
r .--..-.-.
MC96-3
.,* ,------_
PRESIDING
OFFICER'S
RULING ON
OFFICE OF THE CONSUMER ADVOCATE
MOTIONS TO COMPEL INTERROGATORY RESPONS
(September
This
Motion
to
filed
ruling
addresses
Compel
a Response
August
Motion
and
to
(b),
part
20,
1996;
Compel
37,
to
provided
by
limited
number
IOCS
and
and
craft
OCA/USPS-25(a),
of
28,
Advocate
the
Consumer
Advocate
OCA/1JSPS-36(a)
1996.
Each
is
granted
in
office
employees.
contends
showing
size.
The
showing
and
tables
Service
more
a table
office
will
the
table
number
is
In-Office
Cost
OCA states
size.
help
to
it
to
evaluate
of
correspond
System
that
a
the
IOCS.
because
of
Consumer
Interrogatories
previously
two
the
Postal
value
information
the
of
The
not
craft
tallies
reliability
_-
requests
by
of
Office
August
filed
the
below.
employees,
comparison
the
47,
and
of
Interrogatory
to
OCA/USPS-25(a)
(IOCS)
to
and
1996)
Office
Responses
as descri'bed
a table
the
12,
helpful
that
contends
the
IOCS
It
in
that
is
designed
points
out
evaluating
developing
this
the
information
to
that
the
measure
it
already
reliability
requested
ta:ble
will
work
have
time,
presents
of
would
the
be
Docket
It
burdensome.
employee
that
might
discovery,
is
The
relevant
to
contribution
focus
comply
rates,
is
a basic
evidence
is
of
The
data
for
a single
not
an
of
to
has
IOCS,
the
I
OCA to
actual
additional
benefit
of
more
justify
appear
likely
to
impose
on
Postal
at
least
the
Service.
four
of
find
of
identify
take
amount
representativeness
the
of
that
is
and
those
the
proposed
:Service
The
of
the
!S 3622(b).
Postal
areas
indicated
‘may
period
the
enable
39 U.S.C.
JOCS results.
for
to
e.Jidence
from
and
responses
rates,
resulting
of
pay
cost
data
furt!ler
The
Isought
inquiry
and
IOCS.
inconsiderable
importance
cost
proposed
system
exploring
Service
pay
classification
and
all
relevance
and
policies
on
the
Service
of
compel
rate
whether
collection
for
to
period,
tables
developing
costs
rate
provide
pay
of
Postal
of
provide
burden
involves
dependent
the
Postal
the
to
a single
on balancing
of
the
a means
evaluation
motions
institutional
heavily
OCA are
many
against
,with
of
to
is
docket
a week
a month
with
evaluation
to
take
conclusion
reliability
the
would
than
case
This
changes.
/-
the
information
information.
order
the
more
a primary
requested
it
at
take
As
periods.
by
estimates
complement
it
IOCS
-2
NO. MCPG3
pay
that
as much
but
time,
that
IOCS
than
a week."i
effort
an obvious
tallies.
one
Postal
is
pay
This
of
burden
such
Service
which
' Opposition
of the United
States
Postal
Consumer Advocate
Motion
to Compel a Response
OCA/USPS-25(a),
August
27, 1996, at 4, n.3.
might
central
of
in
the
the
(data
does
work
coun:sel
be
is
justif~ied
measure
period
data
the
However,
additional
periods
as
of
recognizing
this
examine
compilation
not
would
should
'compileId
Service
to Office
to Interrogatory
and
of
the
,-
Docket
NO. MC963
allow
OCA to
-3-
choose
the
period
it
considers
most
likely
to
be
representative.
Similar
request
considerations
that
the
interrogatory
files
by
the
that
to
the
responses
and
in
all
OCA's
files
will
the
reliability
has
agreed
and
of
OCA seeks
and
Fiscal
Year
measurement
a man week
to
produce.2
provided
this
in
this
and
1993
TRACS
2 Objecticmn
Consumer Advocate
43(f),
(b) , 42(f),
1996, at 3.
on
the
also
record
of the United
Interrogatories
and Partial
and
OCA to
data
evaluate
Service.
finance
Again,
in
OCA
numbers
The
present
rural
for
or
requested
this
light
be
in
similar
two
carrier
(OCA/USPS-471.
can
programs
justified
information
the
completely
effort
of
the
docket.
OCA/USPS-47
information
available
it
to
the
to
Postal
confidential.
systems:
(OCA/USPS-361,
the
may mask
find
notes
(OCA/USPS-31
allowing
be
data
of
data
provided
intended
to
I
and
Service
unlikely
of
by
Service
but
IOCS
Postal
requested
means
to
IOCS
interrogatories
submitted
inconsiderable,
the
A review
the
OCA
pr,ograms
for
are
the
respond
interrogatories
that
best
Postal
take
the
answers
considered
OCA/USPS-36
_-
the
the
seeks
The
other
concerns,
may
importance
data
those
estimates
information
cost
to
these
that
to
information.
that
information
not
this
of
compelled
filing.
other
of
constitute
be
measures
its
submitted
indicates
clarify
is
Service
or
my evaluation
interrogatory
reliability
provided
52)
other
This
OCA has
part
Service
produce
Postal
obtain
Postal
37.
used
dictate
case
Service
systems
OCA contends
compared
this
Postal
issues.
with
to
Fiscal
evaluate
that
if
Year
1995
the
States
Postal
Service
to Office
of the
OCA/USPS-36(a)
and (b), 37(a)
and
Objection
to OCA/USPS-47,
August
26,
Docket
reliability
of
explains
that
results
as
it
is
the
available
boxes
to
rural
this
balancing
compel
the
Service
information
expense
involved
documents
might
in
system
would
results.
FY95
costs
are
docket
and
do not
justify
or
it
to
creating
since
indica-tes
FY93
is
be
that
not
constructed
sto.rage.
above,
of
correcting
devl?loping
in
these
system
information
have
available,
produce
carrier
for
readily
this
:Service
Similarly,
to
transportation
in
to
described
responses
were
request
objects
currently
test
reliability
nor
rural
TRACS results
and
Postal
FY93
case.
files
the
the
It
this
copy
The
carrier
develop
information
carrier
Postal
in
hard
to
in
rural
electronic
reasonable
evaluate
errors
FY93
used
of
systems.
reported.
year
in
requested
to
found
base
Applying
it
costing
originally
information
from
these
corrected
revised,
FY95
- 4 -
NO. MC96-3
two
I do not
req)dests.
it
might
Howe.ver,
central
find
If
help
OCA
neither
aspect,5
therefore
the
the
time
profiles
the
of
of
benefits
ant2
pa,st
cost
measures.
RULING
The
and,
to
Postal
Service
OCA/USPS-25(a)
is
to
directed
the
to
limited
respond
extent
to
#OCA/USPS-37;
described
by
this
ruling.
j-l
b&z!//
H. Edward
Presiding
r
Quick,
Officer
Jr.
the