BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C.
20268-0001
Special
Services
Fees and Classifications
RECEIVE[!
NW
Docket
II
IZ 30 PN '96
No. MC96-3
ANSWERSOF THE OFFICE OF THE CONSUMERADVOCATE
TO INTERROGATORIESOF UNITED STATES POSTAL SERVICE
WITNESS: SHERYDAC. COLLINS (USPS/OCA-T400-22-23)
(NOVEMBER4, 1996)
The Office
of the Consumer Advocate
of Sheryda C. Collins
to interrogatories
October
21, 1996.
Interrogatory
Witness
Thompson.
An objection
was filed
verbatim
on October
31, 1996.
and is followed
hereby
submits
the answers
USPS/OCA-T400-22-23,
USPS/OCA-T400-21
to interrogatory
Each interrogatory
was redirected
USPS/OCA-T400-24
is stated
by the response.
Respectfully
dated
submitted,
SHELLEY S. DREIFUSS
Attorney
Office
of the Consumer Advocate
to
.
’
ANSWERSOF OCA WITNESS SHERYDAC. COLLINS
TO INTERROGATORIESUSPS/OCA-T400-22-23
USPS/OCA-T400-22.
Please refer to page 3 lines
15-18 of your
concerning
return
receipt
testimony
where you state "The proposal
service
includes
a modest classification
fee structure
change and a large fee increase
for most users.
The small
increase
in cost that the classification
change entails
cannot
justify
the fee increase
and I urge the Commission to reject
it."
Should fee increases
only be based on cost increases?
a.
Please explain
your answer fully.
Should any criteria
other than costs be considered
when
b.
raising
fees?
Please identify
all such other criteria.
Would you agree that certified
mail and return
:receipt
have
C.
a high value of service?
If your answer is no please
explain.
A.
Cost
a.-b.
is one of the nine
Section
3622
(b) of the
U.S.C.
requires
that
with
these
C.
Postal
postal
pricing
Reorganization
rates
and fees
criteria
listed
Title
Act.
be set
at
39,
in accordance
factors.
Please
see witness
Sherman's
answer
to
USPS/OCA-TlOO-22(e).
--
-
.
ANSWERSOF OCA WITNESS SHERYDAC. COLLINS
TO INTERROGATORIESUSPS/OCA-T400-22-23
USPS/OCA-T400-23.
Please turn to page 25 of your testimony.
a.
Please confirm
that postal
cards generally
have a higher
value of service
than private
cards.
If you do not confirm,
please explain.
b.
Assume hypothetically
that postal
card manufacturing
costs
are not part of postal
and postcard
subclass
attributable
costs,
but rather
are included
in the institutional
costs of
the Postal Service.
1.
Under this scenario,
would you support
a proposal
to
include
postal
card manufacturing
costs in the
attributable
costs of the postal
and postcard
subclass
in this docket?
If not, why not?
If yes, why?
Under this scenario,
would you support
a proposal
for a
ii.
stamped card fee as proposed by witness
Needham in
USPS-T-E?
If not, why not?
If yes, why?
I have no information
A.
a.
this
statement.
not
separate
not
appear
coverage
cards
to be relevant.
Certainly,
postal
cards
of value
i.
Yes.
requirement
the direct
postal
so comparisons
consideration
or type
In any event,
would
subclasses,
for
b.
that
that
is not
allow
and private
of value
the high
the result
me to confirm
cards
of service
implicit
are
would
cost
of some explicit
of service.
Criterion
each class
and indirect
three
of mail
postal
of the Act
or type
costs
states
of mail
attributable
"the
service
to that
bear
class
. . . .'I
ii.
testimony.
manufacturing
No.
This
The implicit
costs
scenario
cost
removed
is covered
coverage
at pages
of postal
from the attributable
cards,
cost
24-25
with
pool
of my
ANSWERSOF OCA WITNESS SHERYDAC. COLLINS
TO INTERROGATORIESUSPS/OCA-T400-22-23
CONTINUATION OF ANSWER TO USPS/OCA-T400-23:
under
(e.g.,
is over
mail
300 percent.
which
institutional
the hypothetical,
currently
costs
included
Imposition
costs),
of a new fee on a category
makes such a large
is unwarranted.
in institutional
contribution
to
of
ANSWERSOF OCA WITNESS SHERYDAC. COLLINS
TO INTERROGATORIESUSPS/OCA-T400-22-23
The following
refers
to your testimony
as a
OCA/USPS-T400-24.
whole.
Please confirm
that you read a final
version
of Dr.
a.
Sherman's testimony
(OCA-T-100) in this docket prior
to
filing
your testimony.
Do you agree with all statements
made in Dr. Sherman's
b.
If your answer is
testimony
in this docket (OCA-T-100)?
other than an unqualified
yes, please identify
all
statements
in witness
Sherman's testimony
(by page and line
number) with which you disagree
and why you disagree
with
Dr. Sherman with regard to those statements.
A.
Objection
filed.
-
.,
”
DECLARATION
I,
Sheryda C. Collins,
the answers
States
Executed
to interrogatories
Postal
knowledge,
declare
Service
information
c
USPS/OCA-T400-22-23
are true
and correct,
and belief.
/
under penalty
/WL
of perjury
that
of the United
to the best
of my
CERTIFICATE OF SERVICE
I hereby
certify
document upon all
accordance
with
that
I have this
participants
section
3.B(3)
of record
in this
of the special
Attorney
Washington,
DC 20268-0001
November 4, 1996
date served
the foregoing
proceeding
rules
in
of practice.