I
., ---
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON,
D.C. 20269-0001
RECEtVEc
posrni Rho,:Cc*HiLI;ICH
r i THESiCRETP~~Y
SPECIAL SERVICES REFORM, 1996
Docket
No. MC96-3
REPLY OF THE UNITED STATES POSTAL SERVICE TO OFFICE OF THE
CONSUMER ADVOCATE
COMMENTS
IN RESPONSE TO PRESIDING OFFICER’S
RULING NO. MC96-3/16
(October 2, 1996)
The United
supplemental
to Presiding
Officer’s
Postal Service
comments
Officer’s
Ruling Granting
by Presiding
Presiding
Presiding
was expected
of the Consumer
26, 1996.
Ruling Granting
in its supplemental
clearly
30
Advocate’
to Compel,
pursuant
Presiding
The Postal Service’s
Postal Service
Ruling No. MC96-3/17,
Ruling No. MC96-3/16
to explain
replies to the September
in Part OCA Motion
September
Officer’s
Officer’s
Officer’s
hereby
filed by the Office
Ruling No. MC96-3/16,
is authorized
Respond,
States
October
Leave to
1, 1996,
enunciated
comments.
reply
what
The Presiding
the OCA
Offic’er said:
I will allow the OCA to supplement
its Motion with a more defailed
explanation
of how it plans to assess the reliability of the IOCS using the
requested data. If the OCA provides an explanation
that is suiYiciently
specific, and plausible, I will address the question of the sensitivity
of
facility-specific
total costs, before making a final ruling.
Presiding
Officer’s
supplemental
Presiding
Ruling No. MC963/16,
comments
Officer’s
clearly
fall far short of the showing
added).
required
The OCA’s
by the
Ruling.
’ Office of the Consumer Advocate
Ruling No. MC963/16,
September
-
at 4 (emphasis
Comments
in Response to.~.Presiding
r-2
30, 1996 (“OCA Cc,mmentgn,.
-
Officer’s
-.-
’
.)
d
005560
.-
-2The OCA’s supplemental
In fact,
the OCKs
it is seeking
reliability
to demonstrate,
of the IOCS.
and estimated
obvious
are neither
are merely
conclusory
For example,
attributable
Elsewhere,
costs
demonstrate
differences?
reliability
OCA Comments
needs the requested
facility
at 2. Why would
would
would
of the IOCS.”
OCA Comments
between
were negative,
that necessarily
comments
statements
indicate
this would
of
,anything
and how?
are no more poirrted
concerning
it?
actual
this be an odd distlribution
need to be investigated
overly general
of known
lev1al” is “an
the cause of such an odd distribution
Its supplemental
than its original
“a comparison
of the differences
and 10 percent
Even if it were “odd”,
What
to judge the
why is the OCA unable to explain
“if 90 percent
a need to investigate
of the IOCS?
and reliability
nor plausible.
of this very premise
is necessary
by craft at the individual
cost were positive,
no explanation.
persuasive
that
specific,
recitations
the OCA states that
If it is so obvious,
the OCA states
and estimated
differences.”
added).
detailed,
i.e. that the information
means to judge the accuracy
at 7 (emphasis
offers
comments
comments
of
about
The OCA
or
why it allegedly
information.’
* The OCA also spends time reciting a formula that it claims would generate an “IOCS
estimate of cost by craft by individual office.”
OCA Comments
at 2. The OCA
implies that its recitation of this formula was necessitated
because t’he Postal Service
suggested
that it did not know how to “generate
an IOCS estimate of cost for a
sample office.”
Id. at 2. The Postal Service never said that it did not know how to
generate such an estimate, but rather argued that in certain circumstances,
estimated
costs for a sampled office will be greater than actual costs for .the office.
OCA
acknowledges
this with its hypothetical
of 90 percent of the differences
between
actual and estimated
being positive and 10 percent being negative.
See id.
_-
-3In fact, the requested
reliability.
various
The IOCS estimates
activities,
several special
certain
information
including
demonstrated
sample
proportions
the costs
offices
information
the OCA certainly
to develop
and it appears
its testimony
continuing
collecting
The OCA has not
and actual)
of various
the estimates
of
discovery
on September
relied upon any of the information
on the IOCS.
for unclear
crafts
are correct.
The OCA filed its testimony
on either the reliability
discovery
is to distribute
now argue that it needs the requested
that none of its testimony
been so assiduously
The purpose
services.
on
of rnail and
the reason behind the extended
Rule 2.E.
IOCS
work time spent
about whether
activities
cannot
testimony,
under Special
at 74.
(both estimated
reveals anything
in evaluating
each category
of mail and special
of time spent on various
Further,
permitted
categories
anyone
of employee
USPS LR-SSR-90
that knowing
at individual
“proportions
time spent processing
services.”
costs to those
will not assist
The OCA certainly
or unreliability
objectives
now believes
that its initial
it has
took no position
of the IOCS.
and undisclosed
30,
in
Thus, this
should
not be allowed
to continue.3
Moreover,
could
respond
the Postal Service
to this request
may have been incorrect.
needed
/-
to respond
could
in a reasonably
Currently,
expeditious
the Postal Service
assumption
manner,
estimates
be as much as two to three weeks.
that it
if so compelled,
that the time
Also, there is some
3 The OCA also cannot argue that it needs the evidence for some sort of rebuttal
presentation.
The Postal Service presently does not plan to file rebuttal evidence on
data systems nor does it appear that any other participants
have any like plans.
-4concern
what
that the information
the OCA is seeking.
Postal Service
destined
when
the Postal Service
In any event,
the requested
might
develop
may not be exactly
it is not fair to impose
information
is neither
this burden
relevant
on the
nor, apparently,
to see the light of day in these proceedings.
The OCA’s fishing
no uncertain
terms,
expedition
must come to an end.
The OCA rnust be told,
that it is time to haul in its nets, fo!d them
Respectfully
UNITED
in
up, and go home.
submitted,
STATES POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
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
-J-@,,
Susan M. Duchek
475 L’Enfant Plaza West, S.W.
Washington,
D.C. 20260-I
137
(202) 268-2990;
Fax -5402
October 2. 1996