BEFORE THE
POSTAL RATE COMMISSION
20268-0001
WASHINGTON, D.C.
Special
Services
RECEIVEL)
Nov8 IOzz AH'96
Docket No. MC96-3
Fees and Classifications
ANSWEROF THE OFFICE OF THE CONSUMERADVOCATE
TO INTERROGATORYUSPS/OCA-T300-27, PARTS C.-D., OF THE UNITED
STATES POSTAL SERVICE, REDIRECTED TO WITNESS: ROGER SHERMAN
(NOVEMBER8, 1996)
The Office
of Roger
(October
Sherman
of the Consumer Advocate
to
25, 1996),
interrogatory
interrogatory
redirected
is stated
verbatim
hereby
submits
USPS/OCA-T300-27,
from witness
parts
Callow.
and is followed
the answer
C.-d.,
The
by the response.
,.*-.
Witness
filed
Sherman is out of town and his
declaration
will
later.
Respectfully
submitted,
EMMETTRAND COSTICH
Assistant
Director
Office of the Consumer Advocate
be
ANSWEROF OCA WITNESS ROGER SHERMAN
TO REDIRECTED INTERROGATORYUSPS/OCA-T300-27
On page 15, line 21- page 16, line 2 of your
USPS/OCA-T300-27.
discriminatory
testimony,
you state that "The Postal Service's
treatment
of non-resident
boxholders
through the proposed
non-resident
surcharge is unfair
and inequitable".
C.
Do you consider
the higher charges imposed on Metro
riders
in the Washington,
D.C. area during rush hours to
be unfair
and inequitable?
Please explain why or why
not.
d.
With respect to Metro, please assume that the cost per
rider is not higher during rush hour than at other
times.
How would that assumption affect
your view about
the fairness
and equity of higher rush hour fares?
A.
,r-,
c.
There is not enough information
No.
or equity
of Metro
rush-hour
and non-rush-hour
differences
to capacity
rush-hour
expanding
lead
case,
rush hour with
rush-hour
Even with
d.
rule
could
To say more would
-_-
that
travelers
be caused by
travel
requiring
is also
possible
may share
to pay for
the higher
fare
(capacity,
more capacity,
capacity
rush-hour
because capacity
so
and
would affect
demand would
woul~d be filled
fare.
equal
second case of sharing
It
costs.
fairness
between
likely
of rush-hour
group would require
though,
a higher
the difference
would very
and thus higher
combined willingness
to a higher
groups
expansion
and non-rush-hour
In that
sharing
charges
usage by either
then their
fares.
In any case,
with
in costs,
additions
that
fares.
to discuss
costs,
capacity
still
which could
in question
lead to higher
require
is not available
information
be claimed
c. above,
prices
about
to us in this
the optimal
at the rush hour.
the different
case.
in the
customer
at
DECLARATION
I,
Roger Sherman,
answer to redirected
the United
States
of my knowledge,
declare
under penalty
interrogatory
Postal
Service
information
of perjury
USPS/OCA-T300-27,
is true
and belief.
and correct,
that
parts
the
C.-d.
to the best
of
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,
D.C.
November 8, 1996
20268-0001
the foregoing
in
of practice.