.
y-.
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C.
20268-0001
RECElvEn
4Jc 20
2 22 /q ‘96’
POSTAl RATEco,,,,,~~,~,,
OFF's OF THE ~~~~~~~~~~
Special
Services
Fees
and Classifications
Docket
)
MC96-3
Iio.
OFFICE OF THE CONSUMER ADVOCATE
MOTION TO COMPEL A RESPONSE
TO INTERROGATORY OCA/USPS-25(a)
(August
20, 1996)
The Office
Presiding
Officer
interrogatory
9,
1996,
in
each
Service
requests
direct
the
the
objected
Postal
showing
to
this
,-
to
Cost
that
respond
interrogatory,
the
In-Office
(OCA) requests
Service
That
the
to
filed
August
actual
number
of
System
(IOCS)
samp1e.i
interrogatory
so often
an estimate
of
by section
unable
to
the
case,
time
25(c)
on grounds
Postal
needed
of
address
the
the
the
to
rules
Service's
i See OCA Interrogatories
9,
Advocate
employees
The
of
and burden.2
As is
OCA is
Consumer
a table
of
stratum
relevance
required
the
OCA/USPS-25(a).
has
provide
of
to
Service
prepare
of
burden
of
the
USPS to
argument,
USPS (OCA/USPS-21.-30),
OCA Interrogatory
failed
a response
practice.
1996.
2 Objection
August
19, 1996.
has
to
as
Thus,
the
and the
August
Docket
,-‘.
No.
presiding
that
the
MC96-3
2
officer
should
ignore
requested
table
would
same type
used
to
generate
it.
The OCA would
seem to
the
require
National
note,
input
Payroll
however,
data
Hours
of
the
Summary
Report.
Interrogatory
same purpose
OCA/USPS-25(a)
as interrogatory
MC96-2.
That
to
a comparison
allow
estimates
and the
sampling
Postal
of
officer
overruled
provide
a response.'
judging
it
burden
burden,
requires
relevant
to
employee
universe
that
requested
judge
3 Presiding
the
Officer's
the
of
the
its
objection
no estimate
OCA/USPS25(a),
off the
both
<the estimates
estimates.
respect
Service
to
overall
reliability
are
the
not
used
Ruling
No.
on
Service
Service
has
burden
to
that
to
no
and
Ruling
OCA/USPS-25(a).
the
generate
MC96-2/l.
raised
approaches
OCA/USPS-25(a)
of
to
OCA/USPS-25(a),
OCA/USPS-T7-18,
respond
interrogatory
The
'The pre,siding
to
of
the
No.
OCA/USPS-T7-18
Postal
in
counts
Docket
values
and directed
that
the
accomplish
and confidentiality.
in
with
known
generated
objection
provided
estimated
to
in
as is
interrogatory
Given
has
to
reliability
that
to
the
The table
r--
estimates
concerns
that
MC96-Z/7
of
relevance,
confidentiality
the
of
objected
grounds
given
was designed,
procedure
Service
designed
OCA/USPS-T7-18
interrogatory
as a means
is
IOCS.
is
Although
ICCS cost
Docket
,/..‘
No.
estimates
MC96-3
(a fact
interrogatory
that
of
of
universe
employee
to
of-see
useful
for
implicit
other
itself
that
evaluating
IOCS estimates
then
Commission
errors
one of
by the
is
unquestioned.
interrogatory
the
inaccurate,
survey
IOCS is
undertaken
to
aware
effort
may
estimates
of
employee
estimates
recently
may be
noted,5
to
there
identify
be associated
the
and
with
is
attempt
postal
.u
The
be
are
If
evaluation
surveys
well
The IOCS generates
a substantial
quantify
to
they
counts.4
are
004957
OCA is
IOCS.
As the
for
data
the
counts
inaccurate.
"need
the
OCA/USPS-22),
reliability
universe
r-
3
‘a
Postal
the
Service.
The burden
OCA/USPS-25(a)
substantial
IOCS,
then
most
evaluation
a significant
important
sampling
The need
associated
may be high.
effort"
burden
for
efforts
accurate
with
responding
However,
undertaken
is
cost
if
with
there
to
is
respect
unavoidable.
' Both the overall
sampling
rate
(which is the product
of
office
sampling
rate
and employee
sampling
rate)
by <craft and CAG
and the actual
number of employees
sampled by craft
.and CAG are
The IOCS estimate
of employee
known for each pay period.
universe
counts
in a given
pay period
by craft
and CAG is t:hus
simply
the actual
number of employees
sampled
in that
pay period
See LRdivided
by the overall
sampling
rate
(by craft
and CAG).
SSR-90 at 15.
5 PRC Op. MC96-2 at 30.
Docket
,/-.
No.
MC96-3
4
WHEREFORE the
the
Postal
Service
004~5r;
OCA requests
to
respond
the
to
presiding
officer
interrogatory
Respectfully
to
direct
OCA/USPS-25(a).
submitted,
EMMETT RAND COSTICH
Assistant
Director
CERTIFICATE
I hereby
document
upon
accordance
certify
all
with
that
I have
participants
section
OF SERVICE
3.B(3)
this
date
of
record
of
the
in
special
served
this
____---
D.C.
1996
foregoing
proceeding
rules
EMMETT RAND COSTICH
Attorney
Washington,
August
20,
the
20268-0001
--
of
in
practice.