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'RECEIVE11
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C.
20268-0001
Special
Services
Fees
and Classifications
)
B,iz28 i I ii tA ‘36
pZjT:I. iii,' c~~':Mic:l:il
OFFICE
Oi TtiL ZEL'.ETARY
Docket
No.
MC963
OFFICE OF THE CONSUMER ADVOCATE
MOTION TO COMPEL RESPONSES TO INTERROGATORIES
OCA/USPS-36(a)
AND lb),
37, AND 47
(August
28, 1996)
The Office
Presiding
of
the
Consumer
direct
the
Postal
OCA/USPS-36(a)
and
Officer
interrogatories
interrogatories,
information
various
R94-1
filed
necessary
(1)
statistical
or
cost
(21 to
included
in
produce
the
on grounds
verify
Post,al
that
relevance,
(b),
declined
included
burden,
objected
were
in
to
These
the
reliability
since
Docket
of
No.
formulas
actually
Postal
to
the
request
mathematical
documentation
has
1996,
that
respond
and 47.
whether
has
certain
to
37,
16,
determine
estimates
The Service
of
to
COCA) requests
Service
14 and
systems
Service
variance
documentation.
C-1
August
Advocate
these
used
to
Service
interrogatories
and privi1ege.l
i Objection
of the USPS to OCA Interrogatories
OCA/USPS36(a)
and (b),
37(a)
and (b),
42(f),
43(f),
and Partial
Ob~jection
The
OCA
is
not
currently
to OCA/USPS-47,
August
26, 1996.
seeking
compelled
responses
to interrogatories
42(f)
The Postal
Service
anticipates
that
its response
to
Docket
.
-
No.
All
are
MC96-3
but
one of
designed
to
statistical
1993
the
base
the
are
comparable
virtually
year
Docket
or
for
impossible
systems
to
determine
two
of
fiscal
reliability
has
utilizing
attributable
that
the
services
associated
,I--
recent
estimates,
with
them.
the
base
then
with
1995.
R94-1,
the
last
year
in
the
of
for
Postal
a variety
of
reasons,
No.
MC'96-3
Docket
R94-1.
This
makes
been
changes
have
cost
It
categories
systems'
it
of
reliability
be self-evident.
is
must
If
needed
when
be remember-ed
mail
degree
of
will
render
a response
to those interrogatories
The
OCA
will
thus
await
the response
at 4.
deciding
whether
to seek compelled
responses
makes
and FY 1995.
of
estimates,
also
were
reliability
caution
It
hit
estimates
MC96-3.
seem to
a certain
FY
in
FY 1993
estimates.
Reliability
for
statistical
greater
of
of
way reliability
the
would
costs
and
there
a comparison
cost
1993
in
year
between
years
years
provided
whether
declined,
attributable
are
in
declined
reliability
For
whether
the
the
systems.
tell
iOCA/USPS-37)
estimates
provided
otherwise)
has
No.
reliability
those
FY 1995,
to
of
estimates
to
interrogatories
fiscal
costing
The relevance
for
in
has
impossible
developed
cost
for
reliability
(intentional
to
a comparison
statistical
some of
objected
systems
Commission
Service's
not
the
allow
costs
was the
which
005024
and
speci.al
uncertainty
such
as
unnecessary.
Id.
to OCA/lJSPS-40
before
to 42(f)
and ,43(f).
Docket
,---
No.
MC96-3
coefficients
of
uncertainty.
variation
(c.v.'s),
As reliability
increases-differences
become
blurred.
objected
to
whether
this
recently.
use
of
of
reliability
of
the
(a)
and
5 full
cost
between
the
are
attributable
become
cost
has
to
has
increased
make
without
meaningless
if
having
co.5 t - coverage
Indeed,
rel.ative
changes
estimates
determine
cannot
estimates
reliability.
dockets
Service
participants
cost
that
c,ategories
designed
distinctions
and the
attributable
and
1995
(RCS)
Service
involved
of
of
in
some
way.
Parts
System
that
OCA/USPS-37)
relative
between
FY 1993
for
their
comparisons
unknown
cost
The interrogatories
blurring
a measure
as uncertainty
attributable
The Commission
some sense
provide
declines-i.e.,
in
(except
appropriate
005025
3
of
In
a burden
responding
person-days")
that
relevant
in
unusual,
much
to
less
undue.
to
argument.
parts
ia)
four
the
its
to
for
five
Rural
The estimated
and
(b)
the
days
seek
of
effort
OCA/USPS-36
FY 1993
work
make
argument,
as undue.
of
to
Carrier
relevance
be described
estimates
then
for
addition
can hardly
reliability
MC96-3,
OCA/USPS-36
estimates
comparable.
accepted
interrogatory
reliability
makes
in
(b)
(‘4
If
.it
RCS are
iis not
e.ven
to
be
Docket
No.
MC96-3
4
Interrogatory
for
FYs 1993
The Postal
and
is
might
In
designs
decreases
in
one year
to
Even
fact
the
relevant
the
in
1993
for
FY 1993.
determining
whether
differences
could
indicate
no changes
would
allow
TRACS estimates
which
in
turn
least
were
good
and
c!hanges
or
beneficial.
or
from
would
conclude
as reliable
enough
FY 1995
all
to
sample
sample
and FY 1995
Commission
at
in
ccsst
FY 1995
Not
FY 1993
the
are
changes
intentional
between
(TRACS).
The FY 1993
FY 1993
the
estimates.
necessarily
System
of
the
in
documentation
requested
reliability
between
of
of
it
in
the
an error
reliability
are
estimates,
not
changes
another
Cost
provide
fact,
the
that
FY 1995
to
sampling
to
but
for
basic
Transportation
agreed
relevant
led
seeks
the
FY 1995
have
estimates.
for
has
for
information
sample
1995
Service
documentation
design
WA/USPS-47
that
as the
for
be
FY
a general
rate
case.
In
burden
addition
argument.
WA/USPS-47
as undue.
1993
is
not
to
even
to
it
TRACS is
4 full
argument,
relevant
unusual,
effort
person-days")
be accepted
Interrogatory
interrogatory
relevance
The estimated
("3
If
its
in
that
MC96-3,
much less
solely
involved
Service
in
sample
then
three
to
be described
design
to
a
responding
can hardly
the
makes
for
four
the
days
FY
of
work
undue.
OCA/USPS-37
relates
the
is
to
a simpler
library
matter.
reference
This
SSIR-90,
which
Docket
No.
was filed
MC96-3
in
MC96-3
various
statistical
relates
solely
interrogatory
used
to
31(k)
(3) (i)
the
the
"presumptively
it
cannot
were
used
The primary
fact
that
numbers,
This
is
routinely
the
of
masks
few
days
to
involved
is
in
that
also
terms
section
of
material
sought
Tables
what
is
request
files
4-6
in
were
mathematical
seems
OCA/USPS-37
the
such
to
fi.nance
The Postal
data
sets
a masking
for
be the
sensitive.
objection.
in
to
contain
commercially
no basis
responding
Service
to
for
numbers
The fact
complete
Postal
considers
basis
finance
files
c.v.'s.
the
Service
that
FY 1995.
and data
upon
and data
be verified
responsive
a legitimate
Commission.3
always
the
it
for
requested
be furnished
be verified
generate
materials
the
is
to
the
program
can
concern
which
not
even
Nor
By the
practice,
the
(IOCS)
programs
SSR-90.'
and shall
without
computer-generated.
formulas
of
necessary
OCA/USPS-37,
of
of
for
OCA/USPS-37
System
production
rules
Indeed,
Cost
4-6
estimates
Interrogatory
In-Office
Tables
of
reliability
systems.
seeks
generate
I,
and contains
cost
to
This
.
5
it
discovery,
provides
exercise
objection.
Service
takes
to
a
Some work
and when
requested
2 The Postal
Service
itself
has recently
stressed
the
importance
of Tables
4-6 in evaluating
the reliability
of the
IOCS.
See Opposition
of the USPS to OCA Motion
to Compel a
Response
to Interrogatory
OCA/USPS-25(a),
August
27, 1996, ;at 3.
interrogatory
OCA/USPS-33,
August
3.4, 1996.
3 See, e.g.,
Docket
,r-,
No.
MC96-3
information
a few
is
days
of
6
"presumptively
work
WHEREFORE the
the
Postal
and
(b),
hardly
constitutes
OCA requests
Service
37,
necessary"
to
respond
an undue
the
to
and routinely
presiding
generated,
burden.
officer
interrogatories
to
direct
OCA/USPS-36(a)
and 47.
Respectfully
submitted,
EMMETT RAND COSTICH
Assistant
Director
CERTIFICATE
I hereby
document
certify
upon
accordance
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
---~~
20268-0001
-
foregoing
proceeding
rules
EMMETT RAND COSTICH
Attorney
Washington,
August
28,
the
of
in
practice.