RECEIVE!)
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C.
20268-0001
Special
Services
Fees and ClassificationsDocket
h 21 I 30 PM'96
P-ISTAL
~'.,r(li'FICf
o'FhT"‘,,
,~~r-..Yl.,>,z!:
r .rit Sti.FiE;,$ny
No. MC96-3
ANSWEROF THE OFFICE OF THE CONSUMERADVOCATE
TO INTERROGA'TORYUSPS/OCA-TlOO-6, parts a.-c.,
OF THE UNITED STATES
POSTAL SERVICE, REDIRECTED TO WITNESS: SHERYDAC:. COLLINS
(October 21, 1996)
The Office
of Sheryda
(October
of the Consumer Advocate
C. Collins
7, 1996),
interrogatory
to interrogatory
redirected
is stated
submits
the answer
USPS/OCA-TlOO-15, parts
from witness
verbatim
hereby
Sherman.
and is followed
Respectfully
a.-c.
'The
by the response.
submitted,
SHELLEY S. DREIEUSS
Attorney
Office of the Consumer Advocate
i
ANSWEROF OCA WITNESS SHERYDAC. COLLIN:i
TO REDIRECTED INTERROGATORYUSPS/OCA-TlOCl-6
USPS/OCA-TlOO-6.
Please refer to page 18 line
[sic]
15-18 of your
testimony.
a.
Do you contend that witness Needham has not pres:ented accurate
proposed certified
mail costs and revenues at Tr. 4/1073 for
Docket Nos. R90, R94, and MC96-3?
If you:r answer to (a) is anything
but an unqualifi.ed
no,
b.
please identify
all inaccurate
information
at Tr. 4/1073, and
explain
how one would derive accurate
information
about costs
and revenues for certified
mail.
What is your understanding
of the after-rates
cost coverage
C.
for certified
mail in Docket Nos. R90 and R94? Please explain
in detail.
A.
a.-b.
I am unable
certified
4/1073)
mail
costs
Witness
Lyons'
came so late
oral
their
explanation
,It
is my understanding
witness
Larson
coverage
for
certified
proposed
was 127 percent.
testified
mail
final
the
filed
I was not
Also,
(Tr.
answ'er to
September
on September
that
was not
whether
Needham presented
answer
in OCA's questions
cross-examination
Service
Needham's
representations.
requested
certainty
witness
explanation
in the proceeding
independently
c.
with
OCA/USPS-TFJ-8 (revised
and witness
oral
and revenues
are accurate.
interrogatory
to state
9 (Tr.
able
the
2/153-54)
to verify
complete,
submitted
9)
written
in advance
of
supplied.
that
in Docket
No. R90-1 Postal
that
the
ratmas cost
resulting
USPS-T-22
from
after
fee incr,eases
at 40, Docket
she
NO. R90~-1.
ANSWEROF OCA WITNESS SHERYDAC. COLLINS
TO REDIRECTED INTERROGATORYUSPS/OCA-TlOO-6
CONTINUATION OF ANSWER TO USPS/OCA-TlOO-6C:
It
is my understanding
Service
witness
Foster
coverage
for
proposed
was 172.1
I would
in the
record
Service
rate
mail
that
exactly
Larson
minimum,
corrected
I believe
the errors
and Foster
be presented
explained.
workpapers
with
plainly
Larson's
the mistakes
In addition,
correcting/avoiding
witnesses.
them in the
that
laying
at 65, Docket
well-documenteld
witness
committed
witness
No. R!34-1.
explanation
Iby Postal
present
proceeding.
and Foster's
they
committed
Needham should
mistakes
omnibus
Needham has
out her methodology
the alleged
cost
in the two prev,ious
cases and the manner in which
purportedly
rat'as
from fee incrmaases he
USPS-T-11
to see a detailed,
No. R94-1 Postal
the after
resulting
percent.
showing
witnesses
in Docket
testified
certified
like
that
At a
workp,apers
should
highlighted
and
pre.sent
her own
for
committed
by earlier
DECLARATION
I,
the
Sheryda
answer
United
to redirected
States
my knowledge,
Executed
C. Collins,
Postal
interrogatory
Service
information
c&z&&
declare
a?/,
is true
and belief.
/996
under
penalty
of perjury
USPS/OCA-TlOO-6
and correct,
that
of the
to the
best
of
CERTIFICATE OF SERVICE
1: hereby
certify
document upon all
accordance
with
that
I have this
participants
section
3.B(3)
of record
date served
in this
of the special
proceeding
rules
SHELLEY S. DREIFUSS
Attorney
Washington,
DC 20268-0003
October 21, 1996
the foregoing
in
o:f practice.