BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C.
20268-00&v
RECEIVEU
5
12 24 Pi '96
PJSTCi RniB C~HUISSICN
OFFICE Oi ~THESECRETARY
Special
Services
Fees and Classifications
Docket
No. MC96-3
ANSWERSOF THE OFFICE OF THE CONSUMERADVOCATE
TO INTERROGATORIESOF UNITED STATES POSTAL SE:RVICE
WITNESS: JAMES F. CALLOW (USPS/KA-T300-18-21)
(NOVEMBER5, 1996)
The Office
of the Consumer Advocate
hereby
submi-ts
of James F. Callow
to interrogatories
USPS/OCA-T300-18-21,
October
Each interrogatory
is stated
followed
22, 1996.
verbatim
the answers
dated
and is
by the response.
Respectfully
submitted,.
J+QJyJ
8--oe,
SHELLEY S. DREIFUSS
Attorney
Office
of the Consumer Advocate
.
’
ANSWERSOF OCA WITNESS JAMES F. CALLOW
TO INTERROGATORIESUSPS/OCA-T300-18-21
Please provide
the complete derivation,
USPS/OCA-T300-18.
including
diskettes
for any spreadsheets,
of the cost per box
data in OCA-LR-3, pages 1 and 3, column 3, as revised
October 8,
In particular,
please explain
how the total
costs for post
1996.
office
boxes provided
in USPS-T-5, Exhibit
E, at 8 are separated
into the three components of costs used in LR-SSR-119.
A.
See revised
1996.
The library
spreadsheets
box figures
October
in the
reference,
reference
containing
Please
per box figures
note
OCA-LR-3,
filed
has been expanded
calculations
shown in column
8, 1996.
cost
library
that
the
the
cost
1 and 3 of OCA-LR-3,
revisions
shown in column
3.
5,
to include
used to develop
3 on pages
November
per
filed
make no changes
.
ANSWERSOF OCA WITNESS JAMES F. CALLOW
TO INTERROGATORIESUSPS/OCA-T300-18-21
USPS/OCA-T300-19.
line 17, to page
customers
receive
box
service
than
you think these
instead
of or in
A.
My post
revenue
office
in order
designed
Please
27, line
a lower
they get
customers
addition
post
box fee proposal
to maintain
office
from my proposed
of service
that,
however,
lower
value
than
test
Valued
offset
by limited
value.
more valuable
free
mail
boxes.
recommended
Having
value
said
is of
the privacy
delivery
office
and
to their
and security,
Moreover,
but
resulting
box service
delivered
of carrier-delivered
I
fees.
between
to post
a day.
delivery,
i.e.,
the Commission's
and free
For such boxholders,
than
any additional
coverage
current
such as privacy
By contrast,
Theft
trade-offs
of access
24 hours
cost
believe
at a price,
box features,
free.
office
necessarily
face
available
the
under
post
boxholders
at 27.
not be cost
for
raise
neutrality,
adopted
service.
hours
not
the same as that
year
carrier
of box service
home.
negative
in the
I do not
Potential
home is
is virtually
determinations
OCA-T-300
so that
I have effectively
Consequently,
did
contribution
box fees
fees
by the Commission
security
refer
to your testimony
at page 26,
1. Are you saying that post office
box
value of service
from their
post office
from carrier
delivery?
If so, why do
are choosing post office
box service,
to carrier
delivery?
are
box sections.
via
carrier
to the
"free"
delivery
mail
may create
box service
is marginally
it
follow
does not
that
may
box
-
ANSWERSOF OCA WITNESS JAMES F. CALLOW
TO INTERROGATORIESUSPS/OCA-T300-18-21
CONTINUATION OF ANSWER TO USPS/OCA-T300-19
service
has a high
value.
The magnitude
from the
decision
appropriate
---__
~----
of that
value
the
considerations
to carrier
for
that
to purchase
Nevertheless,
relative
value-merely
service,
an omnibus
there
cannot
some positive
be determined
solely
service.
of the value
and other
rate
is
case.
postal
of box service
services,
are more
ANSWERSOF OCA WITNESS JAMES F. CALLOW
TO INTERROGATORIESUSPS/OCA-T300-18-21
USPS/OCA-T300-20.
Please refer to your testimony
at page 27,
Please provide
specific
cites
to witness
Carlson's
lines
3-5.
testimony
where he discusses
the low value of post office
box
service.
I relied
A.
testimony
on the
concerning
the
Page 2, lines
7-14;
Page 3, lines
16-21.
sections,
space
difficult
to obtain,
office
for
place
of employment,
mail
at
post
parking
offices
with
additional
boxholders
time
or
expense
(or sufficiently
additional
box
is nonexistent
some boxholders
If
Carlson's
for
long)
access
obtain
box service
do not
live
and expense
near
to
near
their
is required
on Saturdays.
concern
of the post
of witness
of box service:
some
24-hour
of employment.
Page 9, lines
sections,
At
box sections,
place
mail
low value
or involves
their
obtain
portions
automobile
To secure
boxholders.
post
following
about
office
certain
13-20.
At some post
personal
might
preclude
safety
offices
with
related
to the
the boxholder
box
from obtaining
times.
Page 9, lines
Page 10, lines
24-27,
20-22.
and Page 10, lines
location
1-2;
and,
to
ANSWERSOF OCA WITNESS JAMES F. CALLOW
TO INTERROGATORIESUSPS/OCA-T300-18-21
Please refer
to your testimony
USPS/OCA-T300-21.
lines
15-18.
Please provide
a table comparable
to
by witness
Needham, at USPS-T-7, Table IV, at 12,
percentage
difference
between your proposed Group
and the CMRA fees presented
in USPS-T-4, Table 11
at page 28,
that provided
showing the
I,, size 1 fees
at 22.
A.
Group
Current
Box Size
1 Fee
OCA
Proposed
Box Size
1 Fee
CMRA
Average
Fee
Smallest
Box
Percent
Difference
From
Current
IA
$24.00
$24.00
$144.78
503%
503%
IB
$22.00
$22.00
$80.82
267%
267%
IC
$20.00
$16.00
$60.96
205%
281%
Percent
Diffmerence
From OCA
Proposed
DECLARATION
I,
answers
Postal
James F. Callow,
to interrogatories
Service
information
Executed
are true
declare
under penalty
USPS/OCA-T300-18-21
and correct,
of perjury
of the United
to the best
and belief.
i
that
the
States
of my knowledge,
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
SHELLEY S. DREIFUSS
Attorney
Washington,
DC 20268-0001
November 5, 1996
the foregoing
in
of practice.