GO5018
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON,
D.C. 20268-0001
RECEIVED
BIK 27
‘5
il jii PM jgp
POS’TAiRATECOHHISS;OH
OFFKEOFTHE SI'CRETARY
I
I
SPECIAL SERVICES REFORM, 1996
Docket
I
No. MC96--3
OPPOSITION OF THE UNITED STATES POSTAL SERVICE TO OFFICE OF -ff=jE-‘-‘.CONSUMER ADVOCATE MOTION TO COMPEL A RESPONSE TO
INTERROGATORY OCA/USPS-25(a)
(August 27, 1996)
The United
Consumer
States
Advocate
25(a)(“OCA
Motion”),
convincing
arguments
it would
Postal Service
Motion
hereby responds
to Compel
a Response
filed on August
demonstrating
not be burdensome
20, 1996.
to Interrogatory
0
*
The OCA has not made
either the relevance
to produce.
--_
to the Officie of
Accordingly,
of the information1
the OCA’s motion
or why
mcrst be
denied.
The OCA filed interrogatory
interrogatory
basically
the employee
Service
States
that the information
of relevance
and burden.
20, 1996,
should
to Presiding
germane
to the present
a table showing
19, 1996,
Objection
Advocate
That
the Postal
of the United
Interrogatory
the OCA filed its motion
OC4/
to compel,
arguing
be produced.
The OCA urges that the dispute
reference
9, 19196.
produce
On August
to Office of the Consumer
On August
on August
that the Postal Service
by craft and stratum.
on grounds
Postal Service
USPS-25(a).
requested
universe
objected
OCA/USPS-25(a)
Officer’s
Ruling No. MC96-2/7.
controversy.
?
over interrogatory
25(a) be resolved
by
That rulingl, however,
That ruling concerned
a discrete
market
is not
^.
-2research
survey.
categorize
That is hardly comparable
by craft
and stratum
The OCA’s argument
without
merit.
make any showing
limited
special
Moreover,
the requested
probability
sample
spend on various
cost incurrence
Furthermore,
of postal
information
“is relevant
Nowhere
is
to judge
does the OCA
to evaluate
the specific,
made in this case.
really would
of the IOCS.
. .”
Rather,
employees
not provide
information
of
The IOCS does not measure
“[tlhe
In-Office
proportions
USPS LR-SSR-90
work time, not employees
as reflected
Cost System
of employee
at 74.
by craft and stratum
work time
The relevant
or numbers
uses a
variable
of employees.
tells one nothing
is
The
about
bv the IOCS.
the Postal Service
from which
at 2.
is necessary
of work time to estimate
of employee
numbers
OCA Motion
of employees.
activities.
of the requested
states that the information
information
the reliability
or numbers
information
proposals
that the Postal Service
plus employees.’
the relevance
that the information
employees
actual
concerning
of the IOCS.”
service
value for assessing
proportion
all of its 700,000
The OCA merely
the overall reliability
to a request
the parties
already
has produced,
and Commission
as it always
does, other
can make determinations
’ The OCA states that the Postal Service has raised no confidentiality
concerns similar
to those raised concerning the market research survey in Docket hlo. MC96-2.
OCA
Motion at 2. The Postal Service does not interpret OCA/USPS25(,a)
as requiring any
information,
such as facility-specific
data, finance numbers,
or employee
names,
salaries, and social security numbers, which would be considered confidential.
If the
OCA is, in fact, requesting such information
or other information
which might tend to
reveal items such as these, then the Postal Service does object on the grounds of
confidentiality
and commercial
sensitivity.
ixz821)
-3concerning
the reliability
estimates
and confidence
has provided
responses,
detailed
descriptions
limits
number
IOCS sample
of offices
offices
to OCANSPS-T5-
Further
information
has been provided
type requested
should
in OCANSPS-25
not be required
FY 1995.
estimate
of the time involved
that this is “required
In fact,
by section
1-24
Rule 25/c).
degree of certainty
As the Postal Service
be compiled
sources
in the format
need to be written
of the
usefulness-
in responding
did not give a
to OCA/USPS25(a),
25(c) of the rules of practice.”
stating
OCA Moth
need only be provided
at 7.
“to the extent
still is unable to estimate
with
any
of time needed to respond.
in its initial
objection,
other than the IOCS.
may have to be extracted
information
would
from sources
stated
Information
by the Postal Service.
The Postal Service
the amount
and 26-30.
in light of its limited
rule 25(c) states that such estimates
possible.”
of
See r1.S. Posra/
The OCA makes much of the fact that the Postal Service
specific
and a listing
in IOCS documentation.
-particularly
by
and craft,
since FY 1993,
13- 15, OCA/lJSPS-2
to be produced
and the universe
size by stratum
by CAG for FY 1993 through
Responses
c.v,
Also, the Postal Service
in the IOCS sample
formulas
Service
contains
the lOCS in other interrogatory
sample
in estimation
Tables 4-S
IOCS reliability.
concerning
rate and effective
of changes
USPS LR-SSR-90,
reflecting
information
including
CAG, the sampling
of the IOCS.
requested
and/or
to accomplish
In fact,
recompiled
by the OCA.
this.
the information
information
will have to
from several
in order to pr:oduce the
A new program
or programs
This will take some amount
of time.
Also, a substantial
large databases
amount
of time is involved
of information.
being run at any point in time.
project.
Any compilation
number,
or employee
such programs
there are any number
Other processing
priorities
data are deleted.
for all of FY 1995.
may del,ay this particular
The interrogatory
from pay period to pay period.
for a “snapshot”
responding.
respond
information
has not been shown
information
utility
more useful
motion
to compel
2 Obviously,
any database
employees is large.
seems to
producing
would
of employees
the information
reduce the burden
of
that it could take at least a month
to
for all pay periods3
of such a burden clearly
case and is of limited
004’s
believes
if data are to be produced
Imposition
Of course,
in time at the end of FY 1995 would
The Postal Service
finance
This means that any compilation
have to be done on a pay period by pay period basis as the number
can fluctuate
against
of other jobs
will have to ensure that any facility-specific,
identifying
require the information
In addition,
’
in running
is not called for when the requested
to have a direct
in assessing
for that purpose
bearing
IOCS reliability,
already
on the proposals
and when
has been provided.
in the
other
Therefore,
the
must be denied.
containing
information
relative
to the universe
of all postal
3 Even if the “snapshot”
approach is followed,
a response still may take as much as
a week. The Postal Service still considers this unduly burdensome given the tenuous
relevance and usefulness of the information.
-5Respectfully
UNITED
submitted,
STATES POSTAL. SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
2w /&LA-?Susan M. Duchek
CERTIFICATE
I hereby certify
participants
of record
of Practice.
OF SERVICE
that I have this day served the foregoing document
upon all
in this proceeding in accordance with section 12 of the Rules
yt.cL/%&A.
Susan M. Duchek
475 L’Enfant Plaza West, S.W.
Washington,
D.C. 20260-I
137
(202) 268-2990;
Fax -5402
August 27, 1996