BEFORE THE
POSTAL PATE COMMISSION
20268-0001
WASHINGTON, D.C.
Special
Services
Fees
and Classifications
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5EP 30 3 33PH'96
pOSTPiR:~: ~,?~>ci:‘rlON
OFF,~~Q; T~,EsECFET.kRY
Docket
No.
MC96-3
OFFICE OF THE CONSUMER ADVOCATE
COMMENTS IN RESPONSE TO
PRESIDING OFFICER'S RULING NO. MC96-3/16
(September
30, 1996)
The Office
its
of
September
6,
interrogatory
comments
are
1996
26,
in
interrogatory
comparisons
reliability
of
MC96-3/12,
original
to
are
of
a response
and
supplements
to
These
cc).
Officer's
motion
permit
IOCS.
Service
relevance
(b)
12,
to
additional
Ruling
at
the
1996,
means
at
No.
MC96-
to
the
purpose
of
known
and estimated
facility
level.
judge
the
Officer's
accuracy
Ruling
and
No.
2.
attempted
by intimating
of
individual
See Presiding
has
compel,
a comparison
an obvious
September
The Postal
parts
by craft
the
COCA) hereby
compel
to
by Presiding
the
costs
Advocate
-
1996.
53 is
attributable
question
motion
authorized
As stated
Such
Consumer
OCA/USPS-53,
September
3/I6,
the
11 !
to
that
confuse
this
it
not
does
simple
know
how to
-
005533
Docket
No.
generate
MC96-3
2
an IOCS estimate
edification
of
generates
the
of
Postal
cost
for
Service,
an IOCS estimate
of
a sample
the
cost
0ffice.l
following
by craft
For
the
formula
by
individual
office:'
CS.k.1 Ink1 * njkl.
C,, k, 1 is
where
particular
the
total
CAG for
tallies
for
that
tallies
for
an individual
estimated
the
of
and
nature
the
IOCS.
between
were
cause
of
actual
negative,
of
The Postal
production
of
that
variation
For
example,
is
that
if
would
to
the
the
of
a
total
total
number
number
of
of
an odd distribution
has
reflect
90 percent
cost
not
of
were
of
office.
on the
the
positive,
a need
is
reliability
differences
and
to
It
10 percent
investigate
the
differences.
explained
information,
between
sample
will
demonstrate
requested
be variation
by individual
and estimated
the
offices
nkl is
and njkl
there
costs
Service
sample
office.
expects
actual
all
craft,
CAG and craft,
this
such
of
a particular
The OCA fully
/-
cost
in
concrete
masked
to
terms
how
conceal
' "[Wlhere
less than all
offices
in a CAG are sampled
by
IOCS, since
total
labor
costs
include
costs
for the entire
CAG,
estimated
costs
for a particular
sampled office
within
that
CAG
will
be greater
than the actual
costs
for that
office."
Opposition
of the USPS to OCA Motion
to Compel
, September
13, 1996, at 5.
2 Assuming
that
the documentation
contained
in LR-SSR-90
is
complete
and accurate.
-
Docket
-.
No.
facility
could
identities,
labor-management
thus
no way to
specific
data
relations
balance
against
WHEREFORE the
the
Postal
(bi
and
005534
3
MC96-3
Service
in
any way harm
or
its
Postal
Service's
There
position.
concerns
about
facility
respond
the
to
presiding
officer
interrogatory
to
OCA/USPS-53,
direct
parts
cc).
Respectfully
submitted,
EMMETT RAND COSTICH
Assistant
Director
CERTIFICATE
I hereby
document
accordance
upon
with
certify
all
that
OF SERVICE
I have
participants
section
3.B(3)
this
date
of
record
of
the
served
in
this
special
t:he foregoing
proceeding
rules
Attorney
D.C.
20268-0001
30, 1996
.-
in
,of practice.
-yj$/w&w
63-A
MMETT RAND COSTICH
Washington,
September
is
relevance.
OCA requests
to
competitive
hypothetical
obvious
the