BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C.
20268-0001
Special
Services
Fees and Classifications
RECEIVEC
Nov11 2 16PM'96
Docket
No. MC96-3
ANSWEROF THE OFFICE OF THE CONSUMERADVOCATE
TO INTERROGATORYUSPS/OCA-T400-21
OF THE UNITED STATES POSTAL SERVICE
REDIRECTED TO WITNESS THOMPSON
(NOVEMBER4, 1996)
The Office
of the Consumer Advocate
of Pamela A. Thompson to interrogatory
21, 1996),
stated
redirected
verbatim
from witness
and is followed
hereby
submits
USPS/OCA-T400-21
Collins.
the answer
(October
The interrogatory
by the response.
Respectfully
submitted,
5dbti&
EMMETTRAND COSTICH
Assistant
Director
Office of the Consumer Advocate
is
ANSWEROF OCA WITNESS PAMELA A. THOMPSON
TO REDIRECTED INTERROGATORYUSPS/OCA-T400-21
USPS/OCA-T400-21.
8 and 9 of your testimony
On page 3, lines
you state ‘I oppose this attempt
to raise revenues outside
an
omnibus rate case".
a.
Is it your testimony
that rates and revenue can never be
increased
except in an omnibus rate case?
If your answer to
(a) is affirmative,
please identify
all legal authority
of
which you are aware that supports
your conclusion.
b.
If your answer to (a) is negative,
please explain
the
circumstances
under which you feel rates and revenues can be
increased
and how you reached this conclusion.
A.
a.
No.
b.
I am not
situations
in a position
in which
However,
selective
the decision
to raise
new net
from a rate
is unfair,
inequitable,
particular
category
increase,
revenue
burden,
designed
purpose
of a rate
rate
increase
is
to generate
categories
new net
in which
revenue
a selective
can be demonstrated
has caused
a new revenue
attributable
costs),
solely
case
case is
of certain
a situation
below
rate
and discriminatory.
When it
of mail
fall
a general
designed
be rational.
when rates
(e.g.,
rate
would
are justifiable.
an omnibus
arbitrary,
possible
outside
exclusion
increase
I can hypothesize
increase
then
revenue,
all
increases
rates
The predecisional
appropriate.
of mail
rate
When the primary
must be rational.
to generate
to catalog
to recover
may be appropriate.
that
it
a
burden
then
a targeted
the new demonstrated
However,
rate
should
be
ANSWEROF CKlA WITNESS PAMELA A. THCMPSON
TO REDIRECTED INTERRCGATORYUSPS/m-T400-21
CONTINUATION OF ANSWER TO USPS/OCA-T400-21:
possible
to make even this
any given
cost
year
coverage
recent
there
is too high
designed
necessary
rate
relative
neutral.
of mail
to the Commission's
to neutralize
discussion
could
the net
was 156.8
BY 95) total
mail
Comparing
individual
indicates
that
refers
revenue
In
whose
most
receive
rate
effect
percent.
coverage
projected
cost
coverages
consider
all
points.
The following
of any
coverage
variances
cost
Certified
by 26.5,
19.1,
Stamped Envelopes
for
while
coverages
exceed
Priority
Bound Printed
by 12.2,
Matter
and Registry
mail
MC96-3,
was 157 percent.
with
actuals
others
than
are below,
For example,
10 percentage
Docket
No. R94-1
10 percentage
by 28.3,
The
total
FY 95 (i.e.,
greater
by more than
by 31.2,
27.9,
are above,
page 4.
No. R94-1 recommendations.
recommendations
Rate Fourth
The actual
cost
Docket
cost
coverage
and services
some coverages
the Commission's
to OCA-LR-6,
R94-1 TYAR) cost
and services
Special
to be categories
Such categories
FY 95 (i.e.,
Commission
revenue
increases.
The following
projected
of case net
are likely
recommendation.
reductions
type
points:
Money Orders
by 25.6,
by 11.8.
by
Cards by
ANSWEROF OCA WITNESS PAMELA A. THOMPSON
TO REDIRECTED INTERROGATORYUSPS/OCA-T400-21
CONTINUATION OF ANSWER TO USPS/OCA-T400-21:
Bringing
these
Docket
No. R94-1
rate
cost
decrease.
Commission's
The following
Docket
points:
Classroom
by 24.6,
Rate by 17.0,
Insurance
"out
of line"
with
cost
coverages,
the
Postal
Certified.
are below
the
by more than
by 44.5,
by 17.5,
cost
proposes
10
Second-Class
Fourth-Class
Library
and P.O. Box/Caller
coverages
"in
line"
could
classification
Conceivably,
neutral.
Several
the Commission's
and rates
Service
each to have a
COD by 13.9,
these
offerings.
could
For example:
Insurance,
require
with
require
increase.
revenue
Delivery,
the Commission's
No. R94-1 recommendations
Service
line."
with
coverages
Third
by 14.7,
Docket
have been net
more "in
cost
Delivery
Bringing
each to have a rate
service
could
Piece
Special
by 10.3.
The Postal
line"
No. R94-1 recommendations
Single
the Commission's
special
"in
recommendations
percentage
Service
coverages
Docket
Docket
service
Money Orders
select
rates
are
No. 94-1 recommended
have been adjusted
Money Orders,
for
No. MC96-3 could
special
COD and P.O. Box/Caller
ignored
reform
to bring
them
Registry,
Special
service.
However,
and COD and targeted
ANSWEROF OCA WITNESS PAMELA A. THOMPSON
TO REDIRECTED INTERROGATORYUSPS/OCA-T400-21
CONTINUATION OF ANSWER TO USPS/OCA-T400-21:
The PRC Op. R94-1,
attributable
costs
million.
Docket
for
Appendix
special
No. MC96-3,
FY 95 costs
for
Apparently,
a new category
"Other"
is
Absent
the
special
responsible
additional
have had net
been in excess
revenues
services
PRC-LR-2
services
for
G, Schedule
for
were $1,360.5
additional
of $419.6
FY 95 were $1,145.0
(revised)
of attributable
attributable
1, total
costs,
included
of $216.3
special
$21.9
of the R94-1 PRC Op. projections
total
million.
costs
costs
million,
shows that
in
million.
services
million
for
would
would
FY 95.
have
DECLARATION
I,
Pamela A. Thompson, declare
the answers
United
to redirected
States
knowledge,
Postal
information
interrogatory
Service
is true
and belief.
under penalty
of perjury
USPS/OCA-T400-21
and correct,
that
of the
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
date
served
in this
of the special
proceeding
rules
EMMETTRAND COSTICH
Attorney
Washington,
DC 20268-0001
November 4, 1996
the foregoing
in
of practice.