BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON,
DC. 20268-0001
II
I
SPECIAL SERVICES REFORM, 1996
RFSPONSE
OF llNlTFQ
Docket
STATFS
POSTAL
No,. MC96-:3
interrogatories
Postal Service
of the Office
of the Consumer
on August
9, 1996,
responses
are filed in accordance
Consumer
Advocate
MC96-3/12,
is still working
as possible.
Motions
Preparing
shortages
response.
Masking
Advocate:
Presiding
to Compel
the response
estimated.
access to the mainframe
prepare
both responses.
information
year workload
numbers
These
Ruling on Office
of the
Responses,
that
and will produce
in the office
in order to respond
Also, unanticipated
computer
Accordingly,
its responses
Each interrogatory
is
m’
=
filed
it as soon
to 25(a) has taken longer thaln estimated
and end of fiscal
gaining
to have its responses
14, 1996.
and 37(b) indicate
the requested
the finance
longer than originally
z
to the following
OCA/USPS-25(a),
Officer’s
Interrogatory
L
12, 1996.
on preparing
time to complete
with
to OCA/USPS25(a)
to staffing
responses
and 37(a) and (b), filed on August
September
The responses
hereby provides
22
mc1
;z
z
z;;
m
-+‘, =
$2
s
THE OFFSNSUMER
ADVOCATE,
(OCA/USPS-25(a)
AND 37(a) AND (b))
AND MOTION FOR EXTENSION OF TIME
(September
23, 1996)
States
B
SFRVLCE
JO INTFR-
The United
zz
2u,
:2
-z
z:b”
problems
have added to the timse needed
interrogatories.
requests
verbatim
and is followed
to
an extension
of
The Postal Servicse hopes
ready by the end of the week.
is stated
the
to 37(b) has taken
and unavoidable
the Postal Service
to these
preparing
due
by the response.
Respectfully
UNITED
submitted,
STATES POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
Lh&-ti
Susan M. Duchek
475 L’Enfant Plaza West, S.W.
Washington,
D.C. 20260-I
137
(202) 268-2990;
Fax -5402
September 23, 1996
,-
-
--
-__
ml5331
U.S. POSTAL SERVICE RESPONSE TO INTERROGATORIES
OFFICE OF THE CONSUMER ADVOCATE
OF
OCAJJSPS-3’7
Page 1 of 1
OCAWSPS-T-37.
Please refer to Tables 4-6 of USPS-LR-SSR-90.
a.
Please provide the programs used to produce the cost and C.V. estimates
presented in these tables. If they have already been provided, please provide a
citation to the appropriate MC96-3 library reference.
b.
Please confirm that the IOCS FY 1995 data file provided as USPS-LR-SSR-22
is the only input file required by the programs used to produce Tables 4-6 of
SSR-90.
If you do not confirm, please provide the additional filles.
OCAWSPS-37
Response:
a.
See USPS LR-SSR-150.
b.
The Postal Service
as soon as possible.
is working
on this request
and will provide tlhe information
-
U.S. POSTAL SERVICE RESPONSE TO INTERROGATORlElj
OFFICE OF THE CONSUMER ADVOCATE
OF
OCF\IUSPS-25
Page 1 of 1
OCAWSPS-25.
Please refer to Attachment
a.
Please provide
b.
Please confirm that these employee universe counts are used 1.0 develop
estimation
weighting factors.
If you do not confirm, please explain and
provide the appropriate employee universe counts used for weighting.
OCAIUSPS-25
a.
..-.-
table containing
employee
universe
counts
Response:
The Postal Service
information
b.
a similar
2 to OCAIUSPS-T5-13b.
is working
on this request
and will provide
the
as soon as possible.
Response
filed August
--
23, 1996
__-
005333
CERTIFICATE
I hereby
participants
certify
of record
that
OF SERVICE
I have this day served the foregoing
in this proceeding
in accordance
with
section
of Practice.
L.>;y.Ld
Susan M. Duchek
475 L’Enfant Plaza West, S.W.
Washington,
D.C. 20260-I
137
September 23, 1996
,-
document
uipon all
12 of the Rules