BEFORE THE
POSTAL PATE COMMISSION
20268-0001
WASHINGTON, D.C.
RECElVELl
Ocr 30
12 20 FN ‘96
POSTAiIXTEC‘Hlj,E”!>‘I
OFIzICE Oi T!iE SEC()i,,+;{y
Special
Services
Docket No. MC96-3
Fees and Classifications
ANSWERSOF THE OFFICE OF THE CONSUMERADVOCATE
TO INTERROGATORIES OF UNITED STATES POSTAL SE,RVICE
WITNESS: PAMELA A. THOMPSON(USPS/OCA-T200-l-9)
(OCTOBER30, 1996)
The Office
of the Consumer Advocate
of Pamela A. Thompson to interrogatories
October
followed
16, 1996.
Each interrogatory
hereby
submits
the answers
USPS/OCA-T200-1-9,
is stated
verbatim
dated
and is
by the response.
Respectfully
submitted,
EMMETT‘RAND COsTICH
Assistant
Director
Office
of the Consumer Advocate
____
-__--
_--~
ANSWERSOF 00. WITNESS PAMELA A. THOMPSON
TO INTERROGATORIESUSPS/OCA-T200-1-9
USPS/OCA-T200-1.
that the Postal Service Board of: Governors
(a) Please confirm
Resolution
No. 95-9 does not limit
the amount of net income to be
earned by the Postal Service but rather
states
that net income
may equal or exceed the cumulative
prior
years'
loss recovery
target
prescribed
by the Resolution.
If you do not confirm,
please explain
what amount net income is limited
to by the
Resolution
and how you determined
the amount of the limit.
that the transcript
of the Board of Governors
(b) Please confirm
meeting that you quote on page 9 of your testimony
indicates
that
the Board was informed
of the fact that Postal Service
actual
and
planned net income exceeds the amount required
by Board of
Governors Resolu,tion
No. 95-9.
If you cannot confirm,
please
explain
why.
A.
(a) - (b)
be met in both
Confirmed.
Thus,
the terms
FY 96 and FY 97 without
of the
any rate
resolution
increases.
will
ANSWERSOF 00. WITNESS PAMELA A. THOMPSON
TO INTERROGATORIESUSPS/OCA-T200-1-9
USPS/OCA-T200-2.
On page 5 lines
lo-12 of your testimony
you
state that "Docket No. MC96-3 abandons the earlier
classification
reform initiative
goal of net revenue neutrality."
On page 6,
lines
8-12, you claim that "it is unfair
and inequitable
to
depart
from the earlier
classification
reform policy
of net
revenue neutrality
by burdening
special
services
alone with
additional
non-attributable
net revenue requirements."
In your opinion,
would the proposals
made by the Postal
(a)
Service
in this case have been more fair and equitable
if Docket
Nos. MC95-1 and MC96-2 had never been filed?
Please explain
your
answer fully.
In your opinion,
must all future
classification
cases
(b)
be based on the philosophy
of net revenue neutrality
espoused in
Docket No. MC95-I?
Please explain
your answer fully.
A.
(a)
Postal
You appear
Service
methodologies
to miss
the point
p:roposed
classification
in Docket
No. MC95-1.
of my testimony.
The
reform
and
principles
In this Request,
the Postal Service proposes to
establish
this framework as the basis for current
and
future
classification
reforms
by restructuringthe-%CS
into four classes:
Expedited
Mail,
First-Class
Mail,
Standard Mail,
and Periodicals.
(Emphasis added.)
Request
of the United
Decisions
Class
on Classification
Mail,
proposed
at 2.
rates
provide
the
was projected
MC95-1
States
for
Prior
the
same test
Postal
Reform
to Docket
reformed
year
it
---.
that
the
test
year.
Service
were designed
No. R94-1..
year.
and Third-
I?ostal
to institutional
in Docket
uses FY 96 as the test
Recommended
Second-,
No. MC96-3,
contribution
by the Commission
for
of First-,
subclasses
and MC96-2 used E'Y 95 as the
does not;
Service
Docket
costs
Docket
No.
to
as
Nos.
MC96-3
ANSWERSOF OCA WITNESS PAMELA A. THOMPSON
TO INTERROGATORIESUSPS/OCA-T200-1-9
CONTINUATION OF ANSWER TO USPS/OCA-T200-2:
The Docket
Service
for
of the United
a Recommended Decision
hereafter,
reform
Request
No. MC96-3
No. MC96-3 Request,
Docket
changes
to a select
reform
goal
Postal
Service
proposes
few special
at 3, the
No. MC96-3 Request
classification
on Special
States
Changes,
classification
In its
services.
Service
changes
reform
Service's
framework
classification
(b)
explicitly
NO, not
all
future
However,
in the
application
of the
If
the Postal
generate
revenues,
an unforeseen
it
need for
own classification
current
-and future
of classification
classification
the Postal
framework
reform
Service
its
effect
reform
is
and capricious.
neutral.
classification
for
in the midst
revenue
approach
from the
designed
arbitrary
discriminatory,
own
and states,
departure
reforms
Docket
its
This filing
is unusual in that it would have the
of increasing
net revenue for the Postal Service,
outside
of an omnibus rate proceeding.
The Postal
Postal
should
Service
must be consistent
used when it
initiatives
had wanted
cases must be net
elects
to
on a piecemeal
to use classification
basis.
reform
have done so from the beginning.
new revenue
in FY 97 arose
to
If
in the m~idst of
ANSWERSOF OCA WITNESS PAMELA A. THOMPSON
TO INTERROGATORIESUSPS/OCA-T200-1-9
CONTINUATION OF ANSWER TO USPS/OCA-T200-2:
classification
rate
case and explained
Sparing
under
reform,
its
the
previously
largest
cloaks
the Postal
why it
customers
of "revenue
deferred"
Service
should
needed new revenue
rate
increases
neutrality"
has the appearance
in
have filed
a
in FY 97.
MC951
and "adjustments
of favoritism.
and MC96-3
...
ANSWERSOF OCA WITNESS PAMELA A. THOMPSON
TO INTERROGATORIESUSPS/OCA-T200-1-9
Under the omnibus rate case scenarios
USPS/OCA-T200-3.
YOU
postulate
on pages 12-13 of your testimony
(where $339.4 million
of revenue requirement
is spread over all classes of mail or all
could the first
two goals for
classes except First
Class Mail),
this case articulated
by witness
Lyons on pages 2 and 3 of
USPS-T-l be accomplished
for the special
services
which are the
If your answer is other than no, please
subject
of this docket?
explain
how these goals could be accomplished.
A.
the
To insure
first
of his
clarity,
two goals
I will
identify
articulated
what I understand
by witness
to be
Lyons on pages
2 and 3
testimony.
the pricing
and classification
proposals
First,
are designed to place the services
and products
on a more
economically
rational,
businesslike
basis.
. . .
offerings
Second, we have reviewed the service
themselves
to see what improvements
could be made to
make them more useful
to the customer,
and both easier
to administer
and understand.
I do not believe
accomplished
testimony
goal
rate
is precluded
case.
on the classification
rate
case.
rate
increase
recover
the
additional
Service
witness
provided
to illustrate
would
there
requested
at pages
what the magnitude
if
Service
revenues
through
an omnibus
Lyons states
in his
testimony
of my
of an
chose.to
rate
case.
at 6, the
following:
In the interest
of mitigating
the
increases
on its customers,
the Postal
would like to moderate the pace toward
is
in an
12-13
the Postal
net
be,
from being
To my knowledge,
changes
The examples
are provided
average
Postal
either
in an omnibus
no restriction
omnibus
that
impact of general
Service
the eventual
-.-
ANSWERSOF OCA WITNESS PAMELA A. THOMPSON
TO INTERROGATORIESUSPS/OCA-T200-1-9
CONTINUATION OF ANSWER TO USPS/OCA-T200-3:
need to increase
overall
revenues as a result
of
rising
cost levels.
. . . The infusion
of revenues from
these sources would contribute
to the Postal Service's
general
financial
policy
goals,
including
the Eloard of
Governors'
concern for restoring
equity.
The same logic
could also apply to future
proposals
for new products
or
classification
that would create additions
to total
of an omnibus rate case, and that would
revenue,s, outside
expand contributions
to institutional
costs.
If
the
Postal
revenues,
Service
I cannot
could
not be filed
goals.
However,
one mail
while
rates.
class
other
needed
think
$339.4
of a reason
and still
achieve
in an omnibus
or subclass
classes
million
rate
would
or subclasses
additional
net
why an omnibus
rate
case
witness
first
two
case,
be targeted
of mail
it
Lyons'
is
for
escaped
less
likely
a rate
with
that
increase
stable
ANSWERSOF OCA WITNESS PAMELA A. THOMPSON
TO INTERRCGATORIESUSPS/OCA-T200-1-9
At the bottom of page 4 and the top of page 5
USPS/OCA-T200-4.
of your testimony,
you quote selected
portions
of statements
from
the Postal Service's
Request in Docket No. MC95-1 in order to
Please
characterize
the intent
of "classification
reform."
confirm
that the statements
of which you have quoted portions
were limited
in scope to clarifying
the intent
of the Request in
Docket No. MC95-1, and did not purport
to address generic
If you cannot confirm,
please explain
"classification
reform."
fully.
A.
Not confirmed.
OCA/USPS-T200-2(a).
_.--
Please
see the response
to
ANSWERSOF OCA WITNESS PAMELA A. THOMPSON
TO INTERROGATORIESUSPS/OCA-T200-1-9
USPS/OCA-T200-5.
Please confirm
that most (if not all)
classes
of mail
(a)
and types of services
face some type of competition,
in the sense
that users usually
have some alternatives
available
to perform
the same function
performed
by the class of mail or type of
service?
If you cannot confirm,
please explain
fully.
(b) Please confirm
that the relationships
between a service
and the potential
alternatives
provided
by competitors,
in terms
of price,
quality,
convenience,
effectiveness,
etc.,
are
generally
considered
relevant
in pricing
that service.
If you
cannot confirm,
please explain
fully.
that the relationship
between a postal
Cc) Please confirm
service
and the potential
alternatives
provided
by competitors
are specifically
relevant
in postal
ratemaking.
If you cannot
confirm,
please explain
fully,
including
why such factors
should
not be reflected
in consideration
of 39 U.S.C. §§ 3622(b) (2),
(4), and (5).
that the relationships
between postal
(d) Please confirm
services
and the potential
alternatives
provided
by competitors
and that the pace of change in the
are not necessarily
static,
markets for postal
products
may vary considerably
actross postal
products.
If you cannot confirm,
please explain
fully.
Please confirm
that developments
in the market for a
(e)
particular
postal
product,
independent
of any general
cost level
increases
or any specific
changes in attributable
costs for that
product,
may justify
adjustments
in the rates or fees for that
product,
under circumstances
in which no omnibus rate changes are
required.
(Adjustments
can be thought
of as "justified"
if, had
the market developments
in question
occurred
prior
to the last
general
rate case and been considered
during such a case, the
result
would or could have been different
rates than those
If you cannot confirm,
please explain
fully.
recommended.)
A.
market
analysis,
analyses
postal
I cannot
(a) and (d1t
that
products
alternatives.
confirm.
I have not
nor am I aware of any published
examine
the
or between
However,
interrelationships
postal
your
products
hypothetical
conducted
Postal
existing
any
Service
between
and potential
is possible.
--
ANSWERSOF OCA WITNESS PAMELA A. THOMPSON
TO INTERROGATORIESUSPS/OCA-TZOO-1-9
CONTINUATION OF ANSWER TO USPS/OCA-T200-5:
Confirmed.
(b)-(c)
The scenario
(e)
consider
for
purposes
pertinent.
:If the
been available
likely
additional
in a prior
consequences
Otherwise,
Priority
information
general
rate
were adjusted
$1
Postal
to seek other
single-piece
coverage,
third
I would
rate
case would
billion
case,
class
not
me to
I would
be in order.
adjustments
all
--
it
rates
expect
would
the net
For example,
of new information
I would
as well.
expect
to see any other
the
However,
up to 100 percent
adjustments.
is
had
to be minusicule.
revenue,
were brought
expect
then
on the basis
of net
for
you hypothesize
In any event,
so as to forgo
Service
necessary
and I do not believe
of such adjustments
a general
rates
was not
of my testimony,
have been different.
revenue
if
you present
cost
if
ANSWERSOF OCA WITNESS PAMELA A. THOMPSON
TO INTERROGATORIESUSPS/OCA-T200-1-9
USPS/OCA-TZOO-6.
Please consider
the following
hypothetical.
A new analysis
conducted by the Postal Service
shows that,
in
light
of a variety
of market considerations,
users of one
particular
postal
service
are getting
an extraordinarily
"good
deal,"
and that higher rates for that service
could be
implemented
that would be fully
in accord with the ratemaking
factors
of the Act.
Assume that is not open to question
that the
higher rate levels
suggested by the analysis
comport with all
factors
of the Act, including
fairness
and equity.
Because the
Postal Service does not plan to file
a general
rate case in the
immediate future,
however, it has two options.
Option One is to
act immediately
to bring the rates for this product
in line with
demand by filing
a case seeking rate increases
limited
to that
product.
Option Two is to leave the rates unchanged until
the
next general
rat:e case, at which time the rates will
be increased
in light
of the new analysis.
Please confirm
that,
under this hypothetical,
the users
(a)
of the service
have done nothing
to entitle
them to continuation
If you cannot confirm,
please explain
of this "good deal."
fully.
that continuation
of the "good deal"
(b) Please confirm
deprives
users of all other services
of a potential
increased
contribution
to net revenue that could be provided
bsy users of
the service
in question.
If you cannot confirm,
please explain
fully.
In your opinion,
under this hypothetical,
should the
(c)
Postal Service be allowed to pursue Option One -- selective,
but
justified,
price adjustments?
Please explain
your answer fully.
Further
assume that the new market analysis
probably
(d)
could have been conducted
at the time of the last general
rate
increase
if attention
had been focused in that direction,
but was
Would this additional
assumption
change your answer to any
not.
of the previous
subparts?
Please explain
any necessary
changes
fully.
A.
(a)-(b)
plausible.
comparison
This
Not confirmed.
A determination
of all
such a comparison
of fairness
relative
cost
will
reveal
not
hypothetical
and equity
coverages.
any other
is not
requires
a
You have assumed that
rates
that
need
ANSWERSOF OCA WITNESS PAMELA A. THOMPSON
TO INTERROGATORIESUSPS/OCA-T200-1-9
CONTINUATION OF ANSWER TO USPS/OCA-T200-6:
adjusting.
In addition,
-users
of one particular
extraordinarily
whether
'good
or not
them to the
users
provided.
price
the
nothing
to e,ntitle
In your
However,
service
service
that
"good
always
be "deprived"
revenue.
Specifically,
are being
deprived
following
scenario
is
halve stated,
when compared
countries.
mailstream
although
cost
in this
It
users
all
it
increased
certain
that
an
is
those
the best
postal
Otherwise,
contribution
to
have done
be getting
in my view
that
case,
cln the
does not
who are getting
prices.
of potential
deal"
deal."
may indeed
implies
of the
to entitle
stamp especially
or below
pay profit-maximizing
about
"good
users
should
says nothing
get an extremely
First-Class
interrogatory
an
advertisements
them to the "good
are near
that
deal."
the
in other
deal,"
It
states
have done anything
radio
First-Class
"good
your
. . ."
users
hypothetical,
extraordinarily
whose rates
are getting
Service
of similar
however,
service
of this
mailstream
follow,
postal
of illustration,
of a $0.32
cost
only
of the
As Postal
First-Class
hypothetical
deal,'.
continuation
For purposes
your
deal.
products
some users
contributions
special
might
would
to net
services
be available
if
ANSWERSOF 0'3 WITNESS PAMELA.A. THOMPSON
TO INTERROGATORIESUSPS/OCA-T200-1-9
CONTINUATION OF ANSWER TO USPS/OCA-TZOO-6:
First
Class's
"good
deal"
Cc)
No.
See the response
(d)
No.
Omnibus rate
testimony
to be presented
testimony
and evidence
an area during
Therefore,
testimony
an across-the-board
rate
fails
to focus
elected
consequences
all
of its
evidence
actions,
and
re-evaluated.
allow
one party
to Flick
when the evidence
on
to do so.
and rates
rate
increase
then
created
Service
are based upon the
examined,
history.
Service
"out
and
To
and
is
are manipulated.
were "out
were still
it
case so that
recent
in MC95-1.
evidence
Rates
then
the
is presented;
that
neutrality"
all
one party
case,
effectively
coverages
Postal
Postal
rate
and what rates
Consider
If
must accept
what evidence
presented;
cost
presented.
can be presented,
would
allow
and examined.
a new omnibus
do otherwise,
to USPS/OCA-T200-6(a-b).
cases
the omnibus
the party
or initiate
choose
were eliminated.
The Postal
in R94-1.
of line"
a principle
As a result,
of line"
did
not
abandoned
the
recently
did
Service
requested
As a result,
not
get
of "net
certain
get adjusted.
created
certain
adjusted.
The
revenue
cost
coverages
Finally,
principle
that
the
of "net
ANSWERSOF OCA WITNESS PAMELA A. THOMPSON
TO INTERROGATORIESUSPS/OCA-T200-1-9
CONTINUATION OF ANSWER TO USPS/OCA-T200-6:
revenue
case,
remain
neutrality"
MC96-3.
As a result,
unadjusted.
discriminatory
your
in a severely
question.
certain
The potential
ratemaking
restricted
is
"out
for
enormous
"classification"
of line"
arbitrary
under
cost
coverages
and
the
assumptions
of
ANSWERSOF OCA WITNESS PAMELA A. THOMPSON
TO INTERROGATORIESUSPS/OCA-T200-1-9
USPS/OCA-T-200-7.
Please refer
to page 14 of your testimony.
Would
it
be
fair
to
equate
your testimony
on this page
(a)
with a "sporting"
theory of postal
ratemaking,
in which parties
participate
in a designated
“game”
known as an omnib'us rate case,
and it is thus "unsporting“
of the Postal Service
to try to alter
the results
of that game to the detriment
of some of the
"winners,"
whether they deserved to win or not?
Please explain
your answer fully.
Is your objection
to what you refer
to as "divide-and(b)
conquer ratemaking"
based on a perceived
inability
c'f the
Commission to distinguish
between "justified"
selective
interim
rate adjustments
and "unjustified"
ones?
Please expllain your
answer fully.
would be served by a
Cc) In your view, whose interests
ratemaking
process in which beneficial
interim
rate adjustments
could be identified,
but could not be implemented
under the
theory that either
they should have been proposed in the last
the next omnibus
omnibus rate case, or they should wait until
Please explain
your answer fully.
In particular,
rate case?
please identify
any objectives
of regulation
(e.g.,
the objective
stated bv Prof. Baumol -- Docket No. R84-1, USPS-T-5, __
pqs. 8-11
-- and many others,
such as Alfred
Kahn in this 1970 treatise
The
Economics of Regulation
at page 17, that regulation
should act=
a surroaate
for the free market forces)
that YOU believe
would or
would not be enhanced by such a constraint.
A.
:It seems
(a)-(c)
postal
ratemaking
testimony
MC95-1 Request,
reform
guidelines
reform
initiatives.
Prior
process
at 14 points
classification
disrespectful
reform
out
to either
a "sport"
the Postal
Service
framework
in MC95-1.
In its
were for
Service
the
stated
current
See my response
of the classification
to liken
the
or a “‘game.”
that
the Postal
to completion
of Congress
that
established
Docket
the
-and future
a
No.
classification
classification
to USPS/OCA-T200-2(a)
reform
My
initiative,
II
the
ANSWERSOF OCA WITNESS PAMELA A. THOMPSON
TO INTERRCXXTORIES USPS/OCA-T200-1-9
CONTINUATION OF ANSWER TO USPS/OCA-T200-7:
Postal
Service
treatment
altered
of mail
and subclasses
the
classes
are being
neutrality.
framework,
fostered
and subclasses.
treated
The Postal
which
Not all
to the
Service's
mail
same goal
actions
inequitable
classes
of net
revenue
are discriminatory
and
unexplained.
Apparently,
and-conquer
you misinterpret
ratemaking."
presenting
limited
targeting
expectation
alone.
that
Service
Recent
believes
selective"
rate
the Commission
on what
Finally,
regulation
outcomes,
witness
that
actions
of rate
history
selecting
increases
that
will
increases
would
mail
of selectively
increase,
leave
allow
Service's
it
well
in the
enough
effectively
to pick
and who benefits
suggest
that
categories
the Postal
for
"justified
decision,"
second-guessing
from
the
and that
I?ostal
Service
or "unjustified."
my understanding
is
a rate
is a "management
has no business
"justified"
is
mailers
Service's
at risk
for
"divide-
to the Postal
the purpose
or subclass
non-targeted
and chose who is
rates.
cases with
class
The Postal
stable
I am referring
rate
a mail
my use of the phrase
it
is
of the efficiency
supposed
not profit-maximizing
to produce
outcomes.
Sherman to USPS/OCA-TlOO-7(c).
rationale
competitive
See response
for
market
of OCA
ANSWERSOF OCA WITNESS PAMELA A. THOMPSON
TO INTERROGATORIESUSPS/OCA-T200-1-9
USPS/OCA-T200-8.
Please refer
to page 15, lines
8-12, where
you state:
If a classification
initiative
is filed
and the revenues
generated
by the class or subclass
of mail undergoing
reform
fail
to cover costs,
then rate increase
may be ,appropriate.
The rate increases
should be designed to be contribution
neutral.
Please confirm
that if a subclass
has costs exceeding
(a)
revenues
(i.e.,
negative
contribution),
any rate increase
designed to correct
that situation
cannot be contribution
neutral.
If you cannot confirm,
please explain
fully.
Was
it
your
intent
to
suggest
that
the
rate increases
(b)
should be designed to yield
the contribution
target
for the
subclass
initially
set in the last general
rate case?
If not,
please explain
fully.
A.
(a)
Not confirmed.
zero
contribution
However,
mail
whose cost
reductions
costs
could
contribution
equaled
costs.
more ‘in
For example:
rates
in Docket
both
COD rates
Money order
line"
recover
with
rates
could
revenue
If
then
rates
could
"in
the Commission's
income.
receive
effect
COD rates
of
rate
of any
are below
was recommended
a classific:ation
line"
be lowered
Docket
by
case
and be
be raised
could
in net
to the Commission's
more than
No. R94-1,
to bring
neutral.
relative
the net
to
to be categories
Such categories
increases.
be designed
are likely
to neutralize
and money order
the Commission
there
contribution
an increase
is too high
recommendation.
rate
from negative
represents
year,
coverage
designed
necessary
rates
obviously
in any given
most recent
Going
so that
revenues
to bring
No. R94-3
its
ANSWERSOF OCA WITNESS PAMELA A. THOMPSON
TO INTERROGATORIESUSPS/OCA-T200-1-9
CONTINUATION OF ANSWER TO USPS/OCA-T200-8:
recommendation.
- no change
(b)
in that
The overall
in the net
No.
it
Docket
assume that
the
are appropriate
coverages
crying
year.
coverages
Docket
for
This
in MC96-3.
No. MC96-3.
adjustment
contradicts
making
it
the
any claim
needed adjustments
Docket
is
neutral
Even if
by the
in cost
case
and cost
No. MC96-3
is not
services
Postal
to
No. R94-1
R94-1 cost
are more egregious
special
rate
inappropriate
in Docket
in FY 96, that
than
increase
year.
established
There
omnibus
rate
Therefore,
need to be attained
out
is merely
--_-
for
is doing
MC96-3.
an across-the-board
test
cost
be contribution
contribution.
were based upon a FY 95 test
uses FY 96 as its
Service
could
No. R94-1 was an unusual
requested
coverages
effect
what the
situa~tions
targeted
Service
coverages.
in
that
it
ANSWERSOF OCA WITNESS PAMELA A. THOMPSON
TO INTERROGATORIESUSPS/OCA-T200-1-9
USPS/OCA-T200-9.
Please refer to page 12 of your testimony,
where you claim that the "choice
of a few special
services
as the
source of additional
revenue was entirely
coincidental
and thus
capricious."
Is it your testimony
that,
out of all the classes
of
(a)
mail and types of services,
the special
services
which are the
subject
of this case were chosen entirely
at random?
If not,
what do you mean by the phrase "entirely
coincidental."
Please
explain
your answers fully.
Is it your testimony
that the determination
to seek
(b)
additional
net revenue in this filing
was made before
any
analysis
of which special
service
could be improved and thus
should be included
within
the scope of the request
for a
what
is
the
basis
for
this
recommended decision?
If so,
testimony?
If not, would you agree that such analysis
makes the
statement
quoted above inapposite?
Please explain
your answers
fully.
(a)-(b)
A.
revenue
No.
is being
sought
had the bad luck
rational
basis
(Of course,
being
the
special
that
My point
is precisely
solely
to be ready
for
choosing
rather
than
why the
If
No. MC96-3 is
few special
services
other
remain
instead
is opportunistic
subclasses,
below
a case for
really
revenue
also
entirely
for
that
is not
a
burden.
coincidental,
the bad luck
of a rational
process
$340 million.)
a classification
rates
case for
only
for
those
enhancement
for
the benefit
coverages
cost
services
a new revenue
for
coverages
a
special
of
EY 96 are permitted
No. R94-1 recommendations.
fixing
Ex.tra
That
rates
needed
raising
whose cost
Docket
is
the result
Service
then
services,
special
reclassification.
of raising
explained
Docket
for
burden
result
services,
from those
how to allocate
the new revenue
accidental
the opposite.
that
If
this
have fallen
to
case is
out
of
ANSWERSOF OCA WITNESS PAMELA A. THOMPSON
TO INTERROGATORIESUSPS/OCA-T200-1-9
CONTINUATION OF ANSWER TO USPS/OCA-T200-9:
line,
Priority,
Fourth,
then
why hasn't
Single
Piece
Cash on Delivery
the
Postal
Third,
Service
proposed
Bound Printed
Matter,
(COD), and Money Orders?
fixing
Special
Rate
DECLARATION
I,
Pamela A. Thompson, declare
the answers
States
Postal
knowledge,
Executed
to interrogatories
Service
information
are true
under penalty
of perjury
USPS/OCA-TZOO-1-9 of th:e United
and correct,
and belief.
to the besit of my
that
CERTIFICATE OF SERVICE
I hereby
certify
that
I have this
date
document upon al:1 participants
of record
accordance
of the special
with
section
3.B(3)
served
in this
proceeding
rules
C&k
EMMETTRAND COSTICH
Attorney
Washington,
DC 20268-0001
October 30, 1996
the foregoing
in
of practice.