,--.. 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 ---__-. --- .- ~__.--- 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
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