.
BEFORE THE
POSTAL RATE COWRI88ION
WASHINGTON, DC 20268-0001
RECEIVELI
Ocr 1'1
SPECIAL
SERVICES
Docket
REFORM, 1996
II 52 RM
No.
MC96-3
DOUGLAS F. CARLSON
RESPONSE TO INTERROGATORIEB
OF THE UNITED STATES POSTAL SERVICE (USPSfDF'C-1-9)
October
I,
the
Douglas
interrogatories
(USPS/DFC--1-9).
4,
F.
Carlson,
of
the
14,
hereby
United
The interrogatories
1996
provide
States
were
my responses
Postal
to
Service
filed
on October
1996.
Each
interrogatory
is
stated
verbatim
and
is
followed
by my response.
Dated:
October
14,
1996
Q&4&&&-hDOUGLAS F.
‘96
CARLSON
DOUGLAS F. CARLSON
RESPONSE TO INTERROGATORIES
OF THE UNITED STATES POSTAL SERVICE
UGPS/DFC-I.
Please
refer
3.
(a) Why did you obtain
than carrier
delivery,
in
than
(b) Why did you obtain
carrier
delivery,
in
to
your
at
pages
2 and
post office
box
Walnut
Creek?
service,
rather
post office
Davis?
service,
rather
(c) Was the only reason
you
Emeryville
to test
the delivery
please
explain
fully.
box
obtained
service
a post
there?
post office
Berkeley?
box
office
box
If not,
service,
rather
l(e) Have you obtained
post office
box service
other
post office?
If so, please
list
each post
explain
why you obtained
post office
box service.
:in any
office,
than
(d) Why did you obtain
carrier
delivery,
in
testimony
I(f) What size boxes have you used at each of the
locations
where you have used post office
box service?
you have used other
than size 1 boxes,
please
explain
circumstances
that
led to your use of larger
boxes.
in
and
If
the
RESPONSE:
(:a) I o'btained
box
(Ii) The Postal
going
to the post
(Iii)
mail
my
carrier
post-office
contrast,
apartments
Service
office
A post-office
than
window
service
box
at
some
large
are
mailboxes,
increasing
the
thieves
burglarize
postal
streets.
My
mail
delivered
to
a post-office
(iii)
my street
effectively
By using
address
protect
Creek
because:
provides
better
When large
security
articles
for
my
arrive
at
the articles
are held for pickup
at
offices,
placed
in a secure
locker).
articles
typically
Walnut
and I enjoy
is one of my hobbies,
every day to pick up my mail;
delivery.
box,
(or,
in
probably
that
arrive
left
out
risk
of
vehicles
is
in
cluster
the
open
theft.
that
safer
from
In
mailboxes
in
near the
occasionally
Also,
are parked
on city
,theft
when
it
is
box;
a post-office
box,
to my correspondents.
my
at
the
privacy;
I can avoid
revealing
Thus,
I can more
.
DOUGLAS F. CARLSON
RESPONSE TO INTERROGATORIES
OF THE UNITED STATES POSTAL SERVICE
(iv)
A post-office-box
communicate
address,
to
s,ince
address
people
over
the
I can avoid
usually
is
telephone
spelling
than
out
the
Jr.
' s Birthday,
office
delivered
holidays,
Presidents
mail
to
a street
street
I(v) Often
I can obtain
my mail earlier
in
post-officfe
box than through
carrier
delivery.
Walnut
Creek post
on non-widely-observed
easier
to
the
name;
day from
A:Lso, the
post-office
a
boxes
such as Martin
Luther
King
Columbus Day, and Veterans
Day,
Day.
(b)
Please
(c)
When I decided
Emeryville,
purpose
two
see my response
I obtained
of
testing
weeks
of
that
Emeryville
the
(d)
for
for
delivery
were
(;e) I have
too
for
service
never
move to
the
sole
I determined
rely
my mail.
just
was so
on the
In
from
box
in
addition,
I decided
short.
reside
in
to
box
delivery
I could
I do not
carrier
like
service.
that
hours
Since
I might
delivery
receiving
lobby
USPS/DFC-l(a).
a post-office
testing
inconsistent
that
that
to
in
Berkeley,
I am not
eligible
Berkeley.
had post-office
boxes
at
the
following
offices:
Berkeley,
box
during
CA (Sather
my four
years
Gate
at
I obtained
box service
for
response
to USPS/DFC-l(a).
university
residence
employees
to
handle
mailing
address
four
different
Seattle,
session
at
the
UC Berkeley,
the
In
halls,
not
my mail.
for the entire
street
addresses
University
reasons
addition,
I did
and sort
WA (University
Station)--1
from
described
since
a post-office
1986
I
to
1990.
in my
lived
in
want non-USPS
I also wanted
one
four years;
indeed,,
I had
by the time I graduated.
Station)--1
of
used
Washington.
attended
summer
I obtained
box
had
DOUGLAS F. CARLSON
RESPONSE TO INTERROGATORIES
OF THE UNITED STATES POSTAL SERVICE
service
for
the
reasons
USPS/DFC-l(a).
In
residence
I did
and
hall,
sort
addition,
attending
since
not
want
law
I lived
at
the
visit
to
Minneapolis,
the post
for the
KJSPS/DFC-l(a).
Minneapolis
according
delivery
or
access
Delivery
six
days
service.
campus
office
reasons
also
<:oncord,
to
to
the
the
did
not
(or
Sunday).
Concord
before
procedure
boxes
is
I needed
office
was not
the
Walnut
Creek
post
described
in
C!ruz,
CA (Main
or
opened
a box
to
Office)--1
the advantages
to USPS/DFC-l(a).
(f)
Size
1.
of
box
service,
I
closed
provide
Sunday).
to
other
access
the
DMM !j
box
me for
side
of
to
the
boxes
in
Concord
my residence
a box for the
USPS/DFC-l(a).
opened
lunchtime
a box in
office
at
By holding
to
had a 3-week waiting
Davis to Walnut
Creek
The
for the interim.
walk
my mail.
(or
much farther
from
I desired
office.
my response
in
criterion
delivery
because
I would
post
be able
I promptly
did not
on the
school--my
first
box--just
Postal
Service
and thought
the
to
During
I visited
on Saturday
Station
Office)--1
Minnesota.
described
a minimum
provide
sudden,
post
of
in Minneapolis,
that
the station
a week
CA (Main
was rather
obtain
handle
nearest
the campus,
since
described
in my response
because
the Walnut
Creek post office
list
for boxes.
Since my move from
to
to
was considering
I wanted
a box
The University
on Saturday
Santa
a university
employees
University
I opened
910.2.1.
After
arriving
the box when I discovered
reasons
to
in
Station)--1
school
test: delivery
at
value
box service
than
my response
non-USPS
MN (Riverside
my exploratory
box
in
my mail.
Minneapolis,
to
described
a box
during
I was interested
in
enjoy the opportunity
high
the
to
or after
school
to
Santa Cruz,
I learned
as I described
in
my response
DOUGLAS F. CARLSON
RESPONSE TO INTERROGATORIES
OF THE UNITED STATES POSTAL SERVICE
USPB/DFC-2.
In any instance
when you have used post office
box service,
was carrier
delivery
to your residence
available
as an alternative?
If so, to what extent
have you
received
mail both at your residence
and your box on the
same day?
If not,
please
explain
why carrier
delivery
was
not available,
to the best of your knowledge.
RESPONSE:
During
my first
two
campus residence
hall.
university's
their
unique
mail
During
5-digit
directly
residence
halls
ZIP
from
did
my summer
the
years
in Berkeley,
I lived
The residence
halls
used
and they
a USPS carrier.
not
receive
Seattle
in
Code,
mail
at
the
delivery
received
its mail from
mail
had been delivered
by the
(The
university
Code.)
Otherwise,
carrier
delivery.
my
With
only
a few
mail
sent
to
give
out
rebates
will
occasionally
narrow
exceptions,
at
approximately
five
address
ten
times
arrives
Advo
after
mailers,
or other
advertising
my name ends up on mailing
lived
Advo
in
mailings
to
my complaints
the bundled
to
pile
the
walk-sequenced
Walnut
apartment-complex
Creek,
the
5-digit
example,
I receive
the
or
individual
management
that
twice
would
is
a week,
as
that
companies
(Incidentally,
delivered
and within
discard
or
mail
such
cluster
mailboxes,
Instead,
he/she
the post office.
below the mailboxes,
the
I also
address.)
mail,
never
all
I will
The other
advertising
carrier
had
when
mail
a month.
mail
lists.
city
always
rebates
once
ZIP
for
I have
(For
Washington,
campus mail
the university
eligible
mail-in
that
I
is
for
approximately
to
the
to
a post-office
box.
letters
to my street
my street
by me only
been
box.
address
not accept
send test
Therefore,
initiated
always
my post-office
my street
of
had a unique
I have
the
on Saturday.
University
hall
the
a
received
However,.
residence
after
service,
USPS.
in
the
send
when
the
despite
dropped
48 hours
the
DOUGLAS F. CARLSON
RESPONSE TO INTERROGATORIES
OF THE UNITED STATES POSTAL SERVICE
When I
material.)
only
two
or
three
lived
in
the
pieces
of
mail
usually
was test
letters
correspondents
knew only
residence
per
halls,
month,
that
I sent to
my post-office-box
:C received
and this
myself.
1fY
address.
mail
DOUGLAS F. CARLSON
RESPONSE TO INTERROGATORIES
OF THE UNITED STATES POSTAL SERVICE
USPS/DFC-3.
28 to page
(a)
4,
Please
line
Please
refer
2.
describe
(b) Why do you
address?
to
what
not
your
testimony
you value
want
to
at
about
receive
pa'ge
box
your
3,
line
service.
mail
at
a street
RESPONSE:
(a)
Please
see my response
to
USPS/DFC-l(a).
(b)
Please
see my response
to
USPS/DFC-l(a).
In
to
be concerned
abo,ut
addition,
I now have
receiving
mail
at
a reason
my street
address.
When I
Creek,
my name was on enough mailing
lists
received
one or two pieces
of first-class
When I moved
to
of-address
order.
forwarding
order,
mai:L,
and both
sent
to
cards
During
to
from
sent
pleading
person,
offer
guess
to
is
and
the
any
event,
service
my old
the
in
use
I file'd
a changeof
the
pieces
of
forwarded
take
that
any
the
for
assistance.
post-office-box
Hansen,
of
time
a post-office
service
,as did .a11
The
week.
offimce
to
or
box
after
the
usually
remainis
forwarding
are
The fewer problems
of
I
Hansen
eve."
problem.
My
to my sold add~ress
a boxholder
instead
not
discarding
represent
not
no
Mr.
and did
mail
box
were
a letter
When I visited
indifferent
a post-office
that
I had
,and postal
I receive13
me.
Layton
was keeping
a period
at
each
post
steps
to investigate
the
mail was being delivered
new tenant
since
disappeared,
helping
Walnut
months
two
address
postmaster,
believe
that
problems
with
than with
street
addresses.
forwarding
four
exactly
he was completely
for
first
I normally
received
at the Walnut
Creek
interested
response
in
1995,
I received
were test
pieces
Many other
test
letters
address.
the other
mail that
carrier
supervisors
him
August
the
I received
I sent
particularly
in
in
that
I typically
mail per week.
pieces
my old
that
Emeryville
livesd
another
carrier
mail.
In
out
clsoses
of
it,
I
leiss common
with
mail
reason
delivery.
to
DOUGLAS F. CARLSON
RESPONSE TO INTERROGATORIES
OF THE UNITED STATES POSTAL SERVICE
USPSJDFC-4.
(a) Please
refer
to your testimony
at page 4, lines
3
through
8.
If the Postal
Service's
non-resident
fee
proposal
is approved
and implemented,
would you (1) keep
your box service
at Berkeley,
assuming
the fee would
include
the $36 non-resident
fee,
(2) move your box service
to
Emeryville,
assuming
the $36 fee would not apply,
or (3)
give up box service
entirely,
and receive
all
your mail
by
carrier
delivery?
(b)
a free
Please
box is
answer part
(a) assuming,
hypotheti'cally,
available
to you in Emeryville.
that
RESPONSE:
(a) As I discussed
in my testimony
on page
move my box service
to Emeryville
because
the
are
too
short
:I do not
and pay
entirely
intend
and delivery
know whether
the
is
I would
nonresident
fee,
or
(1)
(2)
unreliable.
keep
give
my box
up box
recommends
Governors
approves
On one hand,
one.
fee
because
city
whose
lobby
hours
Berkeley
would
in
office,
problems
who held
me for
the
and the
be penalized
through
no fault
shorter
cities.
taking
than
their
boxes
enough to
for
of
Board
'of
the
a rational
post
than
live
step
"resident"
mine
living
in
a
my ow,n, had
office
The nonresident
in Emeryville.
Meanwhile,
boxes in Berkeley
next to
per year for
were fortunate
fee
effect,
significantly
or many other
penalize
nonresident
Berk'eley
it,
as the decision
would be a difficult
I would bitterly
resent
the nonresident
I would,
post
the
in
s,ervice
I do not
and receive
my mail by carrier
delivery.
to give the matter
serious
thought
unless
Commission
less
they
service
2, I would not
lobby hours
would
f'ee
to
in
also
avoid
the
boxholder,s
be :paying
$36
I would,
simply
becau,se
near a post office
with
some of these
"resident"
boxholders
Moreover,
longer
hours.
probably
would be imposing
greater
costs
on the Pmostal
I abide by all
regulatio:ns,
pick up
Service
than I do, since
my mail
daily,
and pay
my fees
on time.
DOUGLAS F. CARLSON
RESPONSE TO INTERROGATORIES
OF THE UNITED STATES POSTAL SERVICE
On the
other
so :I might
to
decide
me despite
inc:Lude
place
box
on box
offered
DFC at
cause
3,
nonresident
if
and delivery
service
service
service
Moreover,
insufficient,
believe
change
merely
in
I doubt
box
lobby
that
higher
hours
general,
I
if
the
address
delivery
my answer
to
office
to
is mor,e
See my testimony,
fee
,plus
t,he value
not
the
to
value
to
over
th,e past
13
be willing
to
when I could
free.
a free
pay
to
still
would
Therefore,
box
receive
for
or re'ceive
in Emeryville.
important
Emeryville
of
(a).
on a
in Emeryville
is
to my Emer,yville
I would
box were
availability
with
service.
extremely
in
v,alue
be capturing
Emeryville
is
even
comparable
longer
hours
in Berkeley
free at my street
address
delivery
even
that
in
Berkeley
basic
and observations
to my street
reliable
than
and
for
of
the
I
th,e value
post
the
Thus,
would
on my tests
a free
Reliability
that
to
just
of
post office
post office.
service
box.
at
not
in
an even
post-office-box
months,
delivery
noticeably
more
post-office
my box
Emeryville
surcharge
Based
woulmd happen
however,
se,
the
15-23.
nonresident
wou'ld
place
lines
me of
better
better
I would
Emeryville
Berkeley
post-office-box
my mail
keep
the
the
me of
(b)
per
service,
be worthwhile
(which
a discussion
me to
hours
since
than
page
(For
on box
still
Note,
service
service.
Emeryville
lobby
Berkeley,
convenient
fee
surcharge).
fee,
in
would
total
on box
value
service,
please
refer
to my response
to
While I might place
a value
on b'ox service
a nonresident
box
a high
service
increased
value
USPS/DFC-l(a).)
high enough to
not
box
a nonresident
nonresident
local
I place
that
the
a high
place
hand,
in
me.
be
I d'o
Emeryvill'e
DOUGLAS F. CARLSON
RESPONSE TO INTERROGATORIES
OF THE UNITED STATES POSTAL SERVICE
USPS/DFC-5.
Please
refer
to your testimony
at pa'ge 4, lines
8 to 11.
Please
provide
all
studies
or other
documentation
that
you relied
upon to determine
that
box service
in
Emeryville
is less satisfactory
than the box service
for
residents
of other
cities.
RESPONSE:
ILobby
box
hours
service.
shorter
those
one factor
Emeryville's
in
lobby
assessing
the
hours
significantly
are
than the lobby hours
in many other
in which
I have had box service--e.g.,
Creek,
Santa
Service's
of
are
Cruz,
and Berkeley.
own survey
post
offices
USPS-T-4
at
offer
longer
Emeryville,
provide
hours
please
that
24-hour
12 (Table
8B).
cities,
Davis,
the
Indeed,
revealed
qu,ality
Surely
to
including
Walnut
Poe&al
approximately
access
of
42 percent
their
b'ox lobby.
many more post office,s
(For the lobby
hours
than Emeryville.
see my testimony,
DFC at
page
2,
in
line,s
7-
9.)
Reliability
assessing
of
the
office.
quality
letter
10 to
or
new box
postal
in
mail--that
have
recall
the
15 days
to
Emeryville.
in
at
at
my box
each
in
test,
compared
f,actor
a particular
Emeryville
I mailed
and always
in
least
in
post
Ma'y 1995,
on
one test
Walnut
Cr'eek and my
I depositeld
the test
similar
t:ypes
of
mail
written
that
test
I compared
letters
with
letters,
pssstal
cards
handwritten
mail with handwrit,ten
mail,
cards,
with
records
levels
typewritten
of
the
on approximately
letter
or
postal
arr.ived
on time
(overnight)
Emeryville
was delayed
at
the
service
both
For
important
is,
with
postal
and typewritten
not
box
another
my box
card
simultaneously
is
of
When I opened
approximately
mai.
delivery
of
service
results
25 to
card
mail.
of
50 percent
addressed
to
Alth'ough
this
t'est,
of
Walnut
the
I do
I
days,
Creek
while
the mail addres:sed
to
The difference
in
least
one day.
As much ,as I wanted
was m
obvious.
DOUGLAS F. CARLSON
RESPONSE TO INTERROGATORIES
OF THE UNITED STATES POSTAL SERVICE
to
receive
ser,ious
In
good
delivery
June
Walnut
problems
Emeryville,
existed
I opened a box
I conducted
a similar
Creek
letters
as to
in
1995,
Berkeley.
test
good
service
to
Berkeley.
and postal
Walnut
Creek.
cards
my move to Emeryville
to test
delivery
to
delivery
test
mail
sent
sent
to
always
Berkeley
Emeryville
reverse
will
I received
another
small
more
will
sti:Ll
is
pieces
pieces
office
in
comparing
deliver,y
of
was at
least
the
my
as
box in
in August.
ago, I have
box
reliable
to
in
ha,ve
if
improved
Ber:keley,
on time
rarely,
to
interrogatory,
The results
USPS/DFC-5.
unreliable.
whsn
ever,
<as
mail
does
are
three
items
while
none
service
is
delivered
in
This
arrived
in
unacceptable,
on Saturday
later.
(In
that
this
October
the
this
overnight
Berkeley
Emeryville.
especially
not
case,
mail
In July,
I also tested
Berkeley
(94712),
my box
can
:reveals
my last
delivery
I mailed
Berkeley
(Berkeley
area.)
October
This unreliable,
when mail that
until
Monday
is
Columbus
arrive
is
Tuesday.)
delivery
of
in Emeryville
Monday,
flats
to
(94662),
three
and three
and
delivery
on Saturday,
delivered
conduct
Attachment
test
11,
to
to
in
improved
since
1995.
However,
San Francisco
to Emeryville.
in
is
reported
one-week
San Francisco's
arrived
I decided
are
On Friday,
of test
mail from
from San Francisco
Emeryville
earliest
post
time
seems
arrive
not--but
this
test.
Response
days
Berkeley
service
that
delivery
to Emeryville
has
systematic
test
in May and June
All
of
that
occur.
After
1 to
to
main
this
over a year
the Emeryville
delivery
is
at the
test,
I then decided
to use
when I moved to Emeryville
!:ince
continued
somewhat,
Emeryville.
to
as my address
While
in
Reliability
Berkeley
periodically.
I concluded
Day,
12,
sporadic
should
be
two
so the
my box in
and my
DOUGLAS F. CARLSON
RESPONSE TO INTERROGATORIES
OF THE UNITED STATES POSTAL SERVICE
street
address
summarized
in
test
provides
of flats
in
Berlkeley
flats
that
Attachment
in
The results
(94608).
2 to
Response
support
is poor,
delayed
DFC at
my box
Emeryville
further
Berkeley
were
testimony,
to
in
to
four
occasions.
This
test
also
Emeryville
is
while
to Emeryville
was better
than to
I mailed
on July 10 did not arrive
I am not
cannot
an expert
provide
on statistical
confidence
delivery
to
See my
reveals
unreliable:
This
USPS/DFC-5.
for my testimony
that
as the flats
I mailed
on all
7-8.
are
that
delivery
delivery
of
Berkeley,
the flat
until
July
15.
sampling
intervals
methods,
so I
However,
my tests.
for
I die know that
Berkeley
outperforms
Emeryville
noticeably
Indeed,
every
time I test
delivery
of first-class
letters.
I bselieve
tha,t
I mailed
Octsober
ser,vice
neelds.
that
the
failure
on October
12 provides
in Emeryville
of
11 to
the
three
arrive
strong
support
is insufficiently
pieces
in
for
of
test
Emeryville
my contention
reliable
for
mail
on
that
my
DELIVERY TEST OF FIRST-CLASS MAIL
WEEK OF OCTOBER 8-12,1996
Item
/ Date Mailed /
I
I
From
Postal Card
Postal Card
1O/7/96
1O/7/96
Berkeley
Berkeley
Berkeley
Emeryville
1O/8/96
1018196
Postal Card
Postal Card
1018196
1018196
Emeryville
Emeryville
Berkeley
Emeryville
1Ol1Ol96
1Ol1Ol96
No
No
Envelope
Envelope
1018196
1018196
Emeryville
Emeryville
Berkeley
Emeryville
1019196
1019196
Yes
Yes
Postal Card
Postal Card
1019196
1019196
Berkeley
Berkeley
Berkeley
Emetyville
10110196
10110196
Yes
Yes
1Lener
Received
/ToBoxIII...I
I
,
I
/ On-Time?
I
Yes
Yes
/ Days Late
I
I
1
1
z
E
z
7w7
71~0
1 sari
wanosco
11vorreca
as or IV-74-yo
1
NO
I
I
2
m
DELIVERY TEST OF FIRST-CLASS
Collection
Date Mailed
714nroc
7110196
7110196
I
1
/
~~
Emeryville
Emervville
1
/
c;.nn PLA
5:00 PM
5:oo PV
I
~ANW7
94662
94712
No
7112196
1
1
Days Late
On-Time?
Received
To
Time
FLATS
7liWX
1
Nn
7112196
1
No
/
~-1
1
A
1
I
I
DOUGLAS F. CARLSON
RESPONSE TO INTERROGATORIES
OF THE UNITED STATES POSTAL SERVICE
USPS!/DFC-6.
Please
refer
to your testimony
20 to 21.
How are you "similarly
situated"
live
in Berkeley,
given
that
you do not live
at page 4, lines
to people
who
in Berkeley?
RESPONSE:
I do not
the definition
live
in
accept
of
Berkeley
Emeryville,
city
versus
situated
to
My residence
streets,
(ii)
Berkeley
(iii)
Most
Residents
other
I work
the
of
of
city
limit
both
are
share
shop
Berkeley.
offer
at
University
I am
in
Berkeley.
Alameda
County.
are
same
face
living
of
Berkeley
equally
in
the
by the
Postal
be free
Postal
Service
versa.
Berkeley.
faculty,
a majority
and face
to
services
vice
California,
and residents
city's
or
don't--and
of
right
Residents
Emeryville.
each
Typically,
and
of our
many similar
and personal
Residents
similar
in
transportation
mail when the
§ 403(c).
of
and the
Berkeley.
in the same location
users
of the
See 39 U.S.C.
I
common
and Emeryville
40,000
students,
All of us spend
discrimination
via
some products
establishments
unreasonable
that
and general
city's
to
miles,
and Emeryville
Berkeley
the
that
legislature.
Berkeley
in
question
reasons,
0.5
Berkeley
state
approximately
related
(vii)
both
the
shop
staff
live
in
daytime
lives
issues
of
establishments
the
of
only
related
to crime,
traffic,
in the East Bay.
commercial
Many
located
the
Berkeley:
same congressman
in
Emeryville
((vi)
of
southern
residents
(Iv) Residents
that
the
by the
problems
conditions
following
and Emeryville
representatives
(:iv)
the
residents
is
from
represented
of
for
in
depends
on whether
As a resident
of
Emeryville.
I believe,
similarly
(i)
the apparent
premise
U*similarly
situated"
safety.
of
from
Emeryville
undue
Service
establishes
or
among
fees.
-
DOUGLAS F. CARLSON
RESPONSE TO INTERROGATORIES
OF THE UNITED STAT?k POSTAL SERVICE
USPS/DFC-7.
Please
refer
to
(a) Please
provide
any
test.imony
on the hours of
refer
to on this
page.
your
testimony
documentation
operation
at
at
page
5.
underlying
the facilit.ies
your
(b) Do the hours you report
represent
the only
which
access
to post office
boxes at these
facilities
possible?
How do you know?
hours
you
in
is
RESPONSE:
(a) I placed
phone
telephone
numbers
for
Francisco.
I
I needed
to
informed
Oakland
the
determine
and on which
stations
calls
to the main
the Postal
Service
days
the
and branches
in
gave
me the
representative
how late
of
week
the
box
hours
did
of
not
could
various
city.
information
for
have
send
box
the
information
I am confident
as we spent
me.
me was accurate,
telephone
as she
read the hours
The information
of
hours
If
reliability
the
of
Postal
or
1When I received
Monday
in
Service
accuracy
open,
at
through
in
Friday,
me a chart
that
showed
1 to Response
to
San Francisco
me over
in
a hard-copy
the
information
of several
stations
also was consistent
stations
open,
were
to
her
that
were
read
the
but
form
she
that
closely
she
of
gave
and
to me over the phone.
with my own observations
San Francisco.
has
the
telephone
that
the information
over 10 minutes
on the
scrutinized
San
The representative
in
lobbies
lobbies
lobbies
their
The representative
who answered
box
Saturday,
and Sunday,
then mailed
same informati0n.l
See Attachment
USPS/DFC-7.
customer-service
in Oakland
and
any concerns
my information,
about
the
the
Postal
The
I did discover
one discrepancy.
the chart,
I do believe,
station
at Mills
College
also is open 24 hours a day.
however,
that
this
post office
is not necessarily
accessible
to the
as a guard station
exists
at the entrance
ts3 Mills
genwal
public,
college.
co11<sge, an all-female
DOUGLAS F. CARLSON
RESPONSE TO INTERROGATORIES
OF THE UNITED STATES POSTAL SERVICE
Service
should
Service's
response
(:b) As far
their
at
Francisco
or
lobbies.
except
DFC/USPS-T4-1
boxes
boxholders
except
as I
page 5, lines
11-28.
at any post offices
that
Oakland
during
and the
Postal
thereto.
as I know,
post-office
testimony
indications
boxes
consider
that
the
boxholders
hours
that
do not
have
indicated
I have not
I have
have
are
to
in my
seen
visited
access
posted
access
for
in
to
the
San
their
box
‘arrporf
Form*
,“dable
. .
.
.
.
. .
.
.
.
.
.
. .
.
.
. .
.
.
. .
.
.
. .
.
.
.
.
.
.
.
.
.
.
.
.
. .
.
.
.
. .
.
.
.
?
>i
.
.
.
.
. . PO Emes a”
~
c$?j
PHONENUMBERS
CUSTOMER
SERVICE
lNFORMATlOi-4
(510) 251~3360,
RATE INFORMATION:
(510) 251-3300
ie IOren,
DOUGLAS F. CARLSON
RESPONSE TO INTERROGATORIES
OF THE UNITED STATES POSTAL SERVICE
USPS/DFC-0.
4 to 7.
Please
refer
(a)
Please
estimate
worth
to you than your
to
your
testimony
how much less a box
box in Walnut
Creek.
at
page
in
Berkeley
If
your box in Berkeley
is worth
less than
box in Walnut
Creek,
why are you obtaining
in Berkeley
rather
than Walnut
Creek?
(b)
previous
service
7,
lines
is
your
box
RESPONSE :
(;a)
to
I do not
me of
box
ascertain
is
that
price
the quality
as I have
value
to
never
I do not
service.
the
presented
know,
of
box
quantified
believe
service
until
decide
I can,
me and I must
that
or cancel
my box.
of service
is higher
in
the
I can
value
reliably
a particular
whether
however,
price
to renew
recognize
one post
office
at
when
than
anot:her.
(b)
the
I have
a box
same reason
When I
lived
in
Walnut
was 30 to
Berkeley
are
Now that
I
Walnut
live
60 minutes
Creek
in
way via
would
Berkeley
box
Creek,
(Walnut
I
live
way.
streets.
to
in
and
Walnut
box
in
Berkeley
though
Creek
would
me than
because
service
and
-
lobby
Walnut
hours
Creek
a box
my previous
value
Emeryville
not
work
in
and
in
and would defeat
my
that
my nonresident
be more
box
to
me of
with
the
Walnut
Creek while
I lived
in Walnut
holding
constant
my residence
in
Therefore,
in
Emeryville.
from
using
in
box
for
of the commute.
is an easy 15
Thus,
the
Creek
to
each
be impractical
When I testified
less
Creek
I was tired
my commute
I was comparing
now that
Walnut
Walnut
to
apart.)
city
of
my commute
Emeryville,
purpose
in moving.
in ESerkeley
is worth
Walnut
instead
from
Creek,
12 miles
each
Berkeley
why I moved
Berkeley
minutes
in
box
in
my box
value
of
Creek,.
Emeryville,
valuable
to
Creek
is
15 miles
were
better
in
in
my
a
me than
away--even
Walnut
Creek.
a
DOUGLAS F. CARLSON
RESPONSE TO INTERROGATORIES
OF THE UNITED STATES POSTAL SERVICE
USPSfDFC-9.
Please
refer
to your testimony
at page
lines
20 to 24.
How much less than $40 would a box
Laurel
Station
be worth
to Valerie
Horwitz?
10,
at the
RESPONSE:
Valerie
Horwitz
at the Laurel
lower
because
reports
Station
in
the location
that
She also added
short.
a nonresident
fee and,
now for
her
arbitrary
box
the
and
risk
way,"
in
instead
to
of theft.
that
receive
the
obtain
Postal
raised
"especially
be likely
mail
if
thus,
San Francisco,
she would
not
a box
Oakland
even if the price
were
is not safe and the lobby hours
are too
imposed
box
she would
not
delivery
to
at
the
use
Service
fee she pays
in such an
a post-office
home,
despite
DECLARATION
I,
that
of
the
Douglas
foregoing
my knowledge,
Dated:
F.
October
Carlson,
answers
information,
14,
declare
are
under
true
penalty
and correct,
to
and belief.
--
1996
DOUGLAS F.
-
of
CARLSON
perjury
the
best
CERTIFICATE
I hereby
foregoing
document
in accordance
sections
certify
I have this
upon the required
with
3(B)(3)
that
OF SERVICE
section
and 3(C)
day served
participants
12 of the Rules
of the
Special
the
of record
of Pram-tice
L
Rules
and
of Practice.
(z!L&Q+bL
DOUGLAS F. CARLSON
October 14, 1996
Emeryville,
California