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POST::. i:ATE c?!!‘!:~s!;H
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OF711~~~~~~~~~~~~~
BEFORE THE
POSTAL RATE COMMISSION
20268-0001
WASHINGTON. D.C.
Special
Services
Fees and Classifications
Docket No. MC96-3
ANSWERSOF THE OFFICE OF THE CONSUMERADVOCATE
TO INTERROGATORIESOF UNITED STATES POSTAL SERVICE
WITNESS: SHERYDA C. COLLINS (USPSJCKA-T400-25-28)
(NOVEMBER6, 1996)
The Office
of Sheryda
of the Consumer Advocate
C. Collins
October
23, 1996.
Witness
Sherman.
followed
to interrogatories
Interrogatory
hereby
submits
the answers
USPS/OCA-T400-25-28,
USPS/OCA-T400-29 was redirected
Each interrogatory
is stated
verbatim
and is
by the response.
Respectfully
*
submitted,
GL%&$&J
SHELLEY S. DREIFUSS
Attorney
Office
of the Consumer Advocate
dated
to
-
.
ANSWERSOF OCA WITNESS SHERYDA C. COLLINS
TO INTERROGATORIESUSPS/OCA-T400-25-28
USPS/OCA-T400-25.
At page 6, lines
9-11 of your testimony,.you
state that "no fee increase
for certified
mail should be approved
until
all of the evidence
regarding
the costing
of this service
is fully
explained
on the record."
What is your understanding
of what is included
in the
a.
certified
mail costs total
attributable
cost contained
in USPS-T-5C, page 16.
Please explain
in detail.
If only certified
mail costs are contained
in the
b.
certified
mail total
attributable
cost contained
in
USPS-T-5C, page 16, then what further
information
is
necessary
to fully
explain
on the record the costing
of
certified
mail?
Please explain
in detail.
A.
a.-b.
certified
mail
witness
costs
which
interrogatory
testimony
Lyons
the
coverage
that
mail
include
ancillary
cost
in USPS-T-22,
I thought
However,
record
included
period
that
and pricing
upon reading
for
still
in the
after
some of the
of certified
transcripts
writing
was muddy.
and
testimony,
I
See my
5-11.
stated
this
that
was not
coverage
service
there
had been ‘a major
of certified
methodology.
certified
is
For a brief
in preparation
in the costing"
Needham stated
what
the costing
up.
that
at pages
Witness
table
surrounded
responses
became convinced
cost
exactly
in USPS-T-5C.
had been cleared
chang[e]
sure
Needham was cross-examined,
confusion
mail
I am not
so;
mail.
there
Tr.
structural
2/154.
Witness
was a change
in the
What she presented
as a pure
in her testimony
she claimed
revenues.
page 40, in Docket
However,
the
cost
No. R90-1 did
did
not
coverage
not
include
ANSWERSOF OCA WITNESS SHERYDAC. COLLINS
TO INTERROGATORIESUSPS/OCA-T400-25-28
CONTINUATION OF ANSWER TO USPS/OCA-T400-25:
ancillary
service
stated
that
errors
in the
revenues.
in that
docket
attributable
To further
to interrogatory
that
components
the
CRA (USPS-T-SC,
attributable
Revenue,
Pieces
Beginning
and Weight
(266,431
288,827
certified
which
costs
RPW change.
Tr.
4/1200.
Patelunas'
2/271-72)
mail
from FY 1994.
indicated
in the
for
in with
for
return
Certified
22,395
certified
mail
this
interrogatory
the unit
was due to a
revenues,
and hence
merchan'dise.
receipts
for
Tr.
receipt
is a decline
2/271-12.
volume
-~
--
His
seems to indicate
(266,431)
' This would explain
only a portion
of the large decline
See my response
attributable
costs for certified
mail.
USPS/OCA-T400-27.
--
=
in the unit
from FY 1994.l
The FY 1995 transactions
FY 1995
He states,
Mail."
return
of this
This
change.
transaction
the volumes
The result
were
are used to calculate
receipts
in answering
witness
(Tr.
there
mail.
certified
return
for
dockets)
(RPW) reporting
volume plus
CRA volume.)
phraseology
permanent
with
were included
attributable
for
Needham then
certified
matter,
change was for
in FY 1995,
merchandise
this
were changed
associated
volumes,
for
OCA/USPS-13
page 16),
"The RPW reporting
Witness
(and in previous
of volume
costs,
n.1.
costs
complicate
response
Id.,
--
a
shown
in unit
to
.
ANSWERSOF OCA WITNESS SHFRYDA C. COLLINS
TO INTERROGATORIESUSPS/OCA-T400-25-28
CONTINUATION OF ANSWER TO USPS/OCA-T400-25:
in USPS-T-l,
return
receipts
before
(289,613)
and after
no adjustment.
merchandise
on the
should
rates
revenues,
the
receipts
(277,803)
If
they
revenues
Are
at 23.
be included
there
are
from the CRA with
And how would
receipts
are included,
:for both
in WP D, which
are straight
included?
return
have merchandise
transactions
See USPS-T-5G and 5J, both
merchandise
I remain
changed
the
return
certified?
However,
removed.
used to caluculate
Why should
(Lyons workpapers)
WP D, page 1,
one know?
with
is a significant
effect
calculated.
confused.
due to the
be revisited
Certified
confused
during
state
the next
mail
of the
fees
should
record;
omnibus
rate
'not be
and this
matter
case.
--
--
ANSWERSOF OCA WITNESS SHERYDAC. COLLINS
TO INTERROGATORIESUSPS/OCA-T400-25-28
USPS/OCA-T400-26.
At page 10, lines
17-19 of your testimony,
you state that there has been "no clear and complete explanation
of the methodology
for developing
certified
mail costs."
Please explain
in detail
to what "methodology"
you are
a.
referring?
Is it your testimony
that the certified
mail total
b.
attributable
cost presented
in USPS-T-5C, page 16,
include
[sic]
costs other than for certified
mail?
If
what
other
costs
do
you
believe
are
included?
If
so,
in detail
why you believe
not, then please explain
"no
clear
and
complete
explanation"
of
there has been
certified
mail costs in this docket.
A.
--..
a.-b.
See my answer
to USPS/OCA-T400-25.
----
ANSWERSOF OCA WITNESS SHERYDAC. COLLINS
TO INTERROGATORIESUSPS/OCA-T400-25-28
USPS/OCA-400-27.
At page 10, line 26-page 11, line 2 of your
"Witness
Patelunas
also confirmed
that the
testimony,
you state,
unit costs for certified
mail have declined
17.6 percent
from FY
1994 to EY 1995."
a.
In making this statement
did you review and/or
consider
witness
Patelunas's
response to OCA/USPS-13
(Tr. 2/271-77).
If not, why not?
b.
Please confirm
that witness Patelunas
stated that
approximately
39.4 percent of the decline
in certified
mail unit costs between FY 1994 and FY 1995 is due to
an RPW reporting
change concerning
return
receipt
for
If
you
do
not
confirm,
please
merchandise
volumes.
explain
in detail.
Assuming as a fact that approximately
39.4 percent
of
C.
the decline
in certified
mail unit costs between FY
1994 and FY 1995 is due to the RPW reporting
change
concerning
return
receipt
for merchandise
volumes cited
by witness
Patelunas,
does this portion
of the decline
in unit attributable
costs represent
the "declining
you refer to on page 11, lines
4-5
attributable
costs"
of your testimony?
Is it your testimony
that total
attributable
costs for
d.
certified
mail decreased between FY 1994 and FY 1995?
If so, please explain
in detail.
A.
unit
a.
Yes.
b.
Confirmed.
C.
Even assuming
cost
of certified
response
the
the RPW reporting
mail
to the above-cited
change
as a fact,
has declined.
Witness
interrogatory,
OCA/USPS-13(d),
the
Patelunas'
shows
following:
(3.1)
Mail
(3.2)
Window Service
-12.3%
of total
(7.3)
Elemental
-21.0%
of total
-11.6%
of total
(10.1)
-.
---
Processing
Evaluated
Direct
Labor
-:10.6% of total
Load
Routes
--
ANSWERSOF OCA WITNESS SHERYDAC. COLLINS
TO INTERROGATORIESUsPs/OCA-T400-25-28
CONTINUATION OF ANSWER TO USPS/OCA-T400-27:
These are not
instituted
d.
for
No.
the
the
result
of account
FY 1995 CRA.
and component
changes
ANSWERSOF OCA WITNESS SHERYDA C. COLLINS
TO INTERROGATORIESUSPS/OCAT400-25-28
USPS/OCA-T400-28.
At page 22, lines
15-17 of your testimony,
you state that "the manufacturing
costs are already
attributed
to
postal
cards and are covered by the 20-cents
postage paid by
users of postal
cards."
Please confirm
that the manufacturing
costs of postal
cards are covered by the 20-cent postage paid by
users of the postal
and post cards subclass
as a whole.
If you
do not confirm,
please explain
in detail.
A.
Not confirmed.
total
revenues
costs
of postal
thus
no basis
of categories)
that
postal
every
of postal
cards
for
also
category
cards.
See my response
cards
more than
(including
saying
that
covers
of mail
to USPS/OCA-T400-13.
cover
manufacturing
any other
those
costs.
is covering
The
the attributable
costs).
category
One might
the costs
There
is
(or collection
as well
say'
attributed
to
DECLARATION
I,
Sheryda C. Collins,
the answers
States
Executed
to interrogatories
Postal
knowledge,
declare
Service
information
are true
under penalty
USPS/OCA-T400-25-28
and correct,
and belief.
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)
date
of record
in this
of the special
&$&!y
served
the foregoing
proceeding
rules
in
of practice.
2L%qLdJ
SHELLEY S. DREIFUSS
Attorney
Washington,
D.C.
November 6, 1996
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20268-0001
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