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BEFORE THE
‘RECEIVE0
POSTAL RATE COMMISSION
WASHINGTON,
D.C. 20268-0001
Yrlw i!5
4 %b PIi ‘%
POSTAi RATE COHHISSION
OFFICE OF TtiE SECRETARY
Docket
SPECIAL SERVICES REFORM, 1996
COMMENTS
The United
its costing
Service
OF THE UNITED STATES POSTAL SERVICE
RECALLING ITS COSTING WITNESS
(November 25, 1996)
IN OPPOSITlON
States
opposing
witness
witness
Postal Service
witnesses,
subject
files these
arbitrary
to re-examination
and unfair.
costing
the testimony
consider
recalling
a Postal
affording
the
of intervenor
and 2, any opportunity
pursuant
the recall of
having
without
TO
for alny kind of
due process
to the Presiding
rights.
Officer’s
The
solicitation
Tr. 6/2032-33.
on November
witness
Moreover,
on his testimony,
to reexamine
comments
on this issue.
At the hearing
_-.
hereby files comments
at all, is a denial of the Postal Service’s
of comments
Officer
as unnecessary,
like opportunity
Postal Service
Service’s
Postal Service
or, in the case of PRC-LR-1
examination
No. MC96-3
arose.
19, 1996,
the issue of recalling
Chairman
Gleiman
the Postal Service’s
costing
requested
witness,
the Postal
that the Presiding
stating:
I think that we may have to -or I would like the Chair to consiider the
possibility
of recalling the Postal Service’s costing witness, because I tflink
that the Postal Service presented a method-a
proposal that is based on
methodologies
which have not been fully examined.
It is my ilnpression
that the Postal Service may have made changes separate and apart frorn
the ones that are in dispute involving the methodologies
that t,he
Commission
employed in R94. The Postal Service may have made
changes, small methodological
changes, and I think that these changes
have not been fully examined, and I think that we may have to recall the
Postal Service costing witness.
I would like the Chair to conslider that ,and
perhaps the Postal Service will have some comments
they would Ijke;tp;
file in that respect, because I have questiorls abou: Postal Serv/ce;J.‘Yi”““’
methodologies.
I don’t understand them.
f
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.- ~__.---
005913
7..
-27i. 6/20 19-20.
The Postal Service
the testimony,
costing
exhibits,
witness.
presented
filed this case on June 7, 1996.
and workpapers
Related
Postal Service
library
costs,
of witness
references
The initial
Patalunas,
also were filed.
the P’ostal Service’s
Those
as usual, for all of the categories
materials
of mail for the
base year, the test year before rates, and the test year after rates.
exhibits,
workpapers
and related
of material.
Costing
Patelunas’s
testimony,
in postal
costing
changes
library
Bankers
USPS-T-5, pages 8 through
from
and the Office
to questions
questions
systems,
from Presiding
as well as the operation
Patelunas
responded
concerning
certain
Request
rollforward
to Presiding
IOCS activity
No. 4, question
model.
thousands
For instance,
of pages
in witness
11 summarized
has responded
Major Mailers
Postal Workers
Advocate.
Officer’s
to demonstrate
Patelunas
including
the American
of the Consumer
seemed
‘The testirnony,
czhanges made
FY 1994 to FY 1995.
from participants,
Association,
constituted
were fully documented.
Since the case was filed, witness
interrogatories
references
contained
filing
Information
Officer’s
codes,
17, concerning
United
Patelunas
Requests.
an understanding
of its rollforward
Association,
Union,
Witness
to numerous
American
Palrcel Service
also has responded
A number
of these
of the Postal Service’s
model.
Information
and to Presiding
the additional
For example,
Request
Officer’s
workday
c:osting
witness
No. 2, question
Information
efflect in the
3,
005914
-3On September
examination,
where
Commissioners.
he responded
costing.
associated
of forecasted
volumes,
costing.
where
no witness
to legitimate
materials
witnesses,
to recall for no apparent
and 2 are totally
exempt
from any discovery
denial of due process.
involving
To recall witness
the use
Tr.2/320-26.
PRC-LR-1
of Postal
and :2,
been established
Patelunas,
discovery
burdens
for
but not
on the
is unfair to the Postal Service.
reason a Postal Service
the Commission
codes,
all aspects
nor has any mechanism
which
of certain
since the day this
concerning
much more extensive
of
The
services.
has been available,
on the record.
places
while
treatment
Tr.2/317-20.
cleaning
discovery
than on other participants,
more than cooperative,
a basic understanding
concerning
for contract
witness
has been produced
of these
and a blatant
to indicate
This is a far cry from the situation
other intervanor
Moreover,
seemed
about such items as IOCS activity
costing
case was filed, to respond
for oral cross-
from the OCA and from the
boxes in the CRA.
and expenses
The Postal Service’s
Service
appeared
to questions
post office
asked questions
Postal Service
Patelunas
The OCA asked questions
with
Commissioners
full scrutiny
witness
Again, the questions
Postal Service
costs
9, 1996,
analysts
witness
who prepared
at all, is completely
who has been
PRC-LR-1
arbitrary,
unfair,
005975
-4For all of the foregoing
reasons,
the Postal Service
opposes
recall of its c:osting
witness.
Respectfully
UNITED
submitted,
STATES POSTAL :SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
2?L&LdEA
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
&
242=-A&A
Susan M. Duchek
475 L’Enfant Plaza West, S.W.
Washington,
D.C. 20260-l
137
(202) 268-2990;
Fax -5402
November 25, 1996