. ,,-..
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C.
20268-0001
Special
Services
Fees
and Classifications)
Docket
No.
MC963
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES TO UNITED STATES POSTAL SERVICE
WITNESS PAUL M. LION
(OCA/USPS-T4-l-7)
(June 27, 1996)
Pursuant
the
,/---
Postal
hereby
Rate
submits
documents.
the
to
United
incorporated
sections
Commission,
25 and 26 of
the
interrogatories
Instructions
States
Postal
Office
the
of
Rules
the
and requests
included
with
Service
dated
of
Practice
Consumer
for
production
19,
1996,
by reference
Respectfully
GAIL WILLETTE
Director
Office
of the
Advocate
OCA Interrogatories
June
submitted,
Consumer
DAVID RUDERMAN
Attorney
Advocate
of
of
l-4
are
hereby
to
Docket
No.
MC96-3
OCA/USPS-T4-I.
Please
concerning
a.
Are
2
attributable
there
any
providing
office
I--
Please
these
cost
.f---
the
box
in
the
costs,
and
‘All
the
Other,"
associated
with
residents,
non-resident
testimony
service
to
attributable
box
cost
costs
holders?
If
of
yes,
differences.
versus
If
yes,
non-resident
please
foreign
specify
these
three
main
"Space
Support,"
differences
providing
box
categories
in
Space
post
to
clffice
Provision,"
attributable
service
US citizens,
of
costs
residents,
non-
and non-resident
nationals.
extent
possible,
should
Also,
if
Postal
differences,
differences,
estimates.
the
holders?
attributable
cost
your
differences.
interrogatory
size
these
box
To the
between
US citizens
identify
foreign
34 and 35 of
non-resident
specify
national
cost
box
versus
non-resident
12)
pages
costs.
post
please
to
differences
resident
(1)
b.
refer
the
information
be provided
Service
please
and provide
requested
separately
data
are
provided
documentary
in
by fee
unavailable
the
or
best
other
this
Group
to
and box
support
estimates
support
of
for
the
Docket
No.
MC96-3
3
. .,--.
OCA/USPS-T4-2.
testimony
concerning
boxes.
To the
attributing
to
in
please
the
of
to
your
Support,
Nos.
explain
all
and the
35,
lines
of
knowledge,
Space
does
of
the
those
of
post
your
office
methodology
and All
of
and R94-1.
effect
to
Provision,
differences
7-14,
costs
methodology
R90-1
known
page
attribution
Commission's
Docket
methodology
refer
the
best
Space
conform
costs
Please
Other
attributing
costs
these
If
you
cannot
from
the
Commission's
differences
of
confirm,
on attributable
costs.
P
OCA/USPS-T4-3.
testimony
concerning
boxes.
To the
allocating
size
allocating
office
/-”
the
best
of
conform
and R94-1.
from
differences
boxes.
to
the
to
the
you
to
cannot
Commission's
on the
of
allocation
lines
post
office
post
the
post
your
office
methodology
boxes
boxes
please
methodology
of
to
of
buy fee
methodology
office
confirm,
7-14,
costs
does
Commission's
costs
If
35,
knowledge,
costs
to
page
attribution
your
attributable
differences
those
refer
attributable
and box
R90-1
Please
Clroup
of
in
Docket
explain
and the
attributable
of
all
known
effect
costs
Nos.
of
to
post
Docket
No.
MC96-3
OCA/USPS-T4-4.
4
Please
refer
to
page
19,
lines
l-6,
of
your
testimony.
a.
Please
confirm
Subgroup
Codes
you
at
b.
C.
I-C
from
Please
first
confirm
the
confirm,
If
the
sample
of
the
stratum
sampling
in
a stratified
approximately
describe
12,000
exactly
your
sample
ZIP
what
"representative
term
sample
of
the
please
ZIP
Please
of
ZIP
Codes.
If
was sampled
Codes
refer
containing
differential
rates
to
Codes
refers
CMRAs.
explain.
is
sampling
ZIP
sample"
the
six
for
by
each
steps
strata,
of
the
described
please
strata.
on pages
testimony.
provide
sampling
Please
for
C.
that
do not
Please
of
step.
you
your
stage
select
please
If
for
b.
of
a probability
of
first
was to
confirm,
OCA/USPS-T4-5.
a.
sample
to
provide
19-20
the
a universe
do not
this
that
the
at
provide
sampling
Please
provide
referred
to
the
the
at
the
number
conclusion
number
step
of
conclusion
a list
in
of
of
3.
the
ZIP
of
ZIP
of
Codes
step
Codes
step
remaining
eligible
1.
remaining
eligi.ble
2.
32 metropolitan
areas
that
are
Docket
d.
No.
MC96-3
Please
5
provide
represented
step
e.
the
number
by the
of
unique
ZIP
Codes
291 CMRAs identified
at
that
the
were
conclusion
of
4.
Please
confirm
of
291 CMRAs identified
the
the
sampling
that
ZIP
Codes
that
in
universe.
If
did
step
you
not
match
4 were
do not
ZIP
Codes
eliminated
confirm,
from
please
explain.
f.
Please
confirm
augmenting
in
/---
g.
the
that
the
the
sample
CMRA list
of
only
step
please
explain
to
new CMRAs would
the
Please
how you
confirm
consisted
list
that
of
all
Yellow
Pages
or
areas
identified
of
in
ZIP
If
4.
already
do not
which
be selected
step
If
identified
th~en
additional
to
be located
file
3.
327 by
ZIP
Codes
from.
could
PhoneDisc
to
confirm,
327 CMRAs referred
CMRAs that
in
Codes
you
determined
the
the
CMRAs was expanded
for
you
the
do not
in
in
step
6
either
the
32 metropolitan
confirm,
please
explain.
h.
Please
describe
i.
Please
confirm
the
1995
confirm,
and the
the
PhoneDisc
that
the
editions
of
please
provide
Yellow
the
corresponding
file
phone
the
phone
referred
Pages
phone
If
books.
name of
book
to
date.
books
you
each
in
step
were
all
do not
metropolitan
If
6.
area
a metropolitan
./-
area
has
several
Yellow
Pages
phone
books,
separately
list
Docket
No.
MC96-3
each
one.
(For
includes
j.
example,
Northern
Georges
Co.
Please
provide
PhoneDisc
k.
6
Please
Virginia,
(MD),
date
that
the
correspond
with
Pages
the
Please
state
50 of
size.
District
Co.
of
associated
area
Prince
(MD),
Columbia.)
with
only
You then
portions
of
the
the
same geography
phone
OCA/USPS-T4-6.
that
DC metro
Montgomery
and the
the
Washington
entries
on the
file.
confirm
Yellow
the
books
refer
the
relied
to
PhoneDisc
as that
page
display
covered
used
by the
upon.
22 of
your
299 CMRAs provided
go on to
file
the
testimony.
data
average
box
You
on mailbox
sizes
in
Table
12.
a.
Are
these
figures
meant
in
general?
If
sizes
to
be representative
then
not,
what
is
of
the
CMPA box
purpose
of
Table
12?
b.
Do you
total
C.
view
these
confirm
explain.
attempted
to
that
you
only
for
the
299 CMPAs of
characteristics
and
Please
299 CMRAs interviewed?
Please
If
50 CMRAs as a representative
you
I-B
do confirm,
were
please
explain
If
excluded.
you
sample
determine
Delivery
why Delivery
do not
confirm,
with
lines
l-4
of
page
22 of
your
box
!;ubgroup
Subgroups
please
.I--.
reconcile
of
testimony.
the
size
I-C.
I-A
Docket
* ,---
d.
No.
Are
of
these
each
size
and what
the
portion
at
box
each
these
of
computes
OCA/USPS-T4-7.
sample
average
not
that
7
MC96-3
Is
it
as a probability
CMRAs in
the
32 identified
weighted
responding
numbers
the
the
sizes
CMRA?
represent.
supporting
weighted
more
number
If
not,
If
so,
spreadsheet
file
of
boxes
explain
please
why
cite
(BOXSZE.XLS)
averages.
accurate
sample
by the
of
to
ZIP
metropolitan
describe
Codes
or
areas?
the
Subgroup
as a census
Please
I-C
of
explain.
Docket
NO. MC96-3
/‘-
CERTIFICATE
I hereby
document
accordance
upon
certify
all
with
that
I have
participants
section
OF SERVICE
3.B(3)
this
date
of
record
of
the
in
served
this
special
DAVID RUDERMAN
Attorney
Washington,
D.C.
June 27, 1996
20268-0001
the
foregoing
proceeding
rules
of
in
practice.