,.I--
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C.
20268-0001
~RECEIVED
Jn IO II 2~ ItH‘96
POST*1
RATE
COHHlSZlOH
OFF,CE OF THE SECRETAM’
Special
Services
Fees
and Classifications)
Docket
No.
MC96-3
(.:'
J
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES TO UNITED STATES POSTAL SERVICE
WITNESS PAUL M. LION
(OCA/USPS-T4-10-16)
(July
10, 1996)
Pursuant
the
/H--X
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
Practicfe
Consumer
for
Advocate
production
OCA Interrogatories
June
19,
of
of
l-4
19>96, are
to
hereby
by reference.
Respectfully
GAIL WILLETTE
Director
Office
of the
submitted,
i
Consumer
DAVID RUDERMAN
Attorney
Advocate
~. :
_ ~~.
_-
Docket
No.
MC96-3
2
OCA/USPS-T4-10.
subtotal
a.
b.
Refer
for
"Space
Please
that
$193,853,000.
If
Please
the
explain
in
category
Please
LR-SSR-119,
Sheet
8,
which
contains
the
Support".
confirm
Support
C.
to
the
you
do not
for
above,
on page
35,
the
11 of
correct
for
your
amount
Support
please
between
and amount
line
Space
confirm,
difference
"a."
provide
subtotal
is
explain.
the
amount
the
Space
for
S;pace
Support
testimony.
for
the
Space
Support
8,
which
contains
category.
Refer
OCA/USPS-T4-11.
subtotal
a.
b.
for
"All
Please
confirm
Please
the
explain
on page
c.
that
If
in
Please
category.
"a."
35,
provide
LR-SSR-119,
Sheet
Other."
$108,799,000.
Other
to
the
you
do not
your
correct
All
confirm,
Other
please
between
and amount
13 of
the
for
difference
above,
line
amount
for
the
the
is
explain.
amount
All
for
Other
testimony.
amount
for
the
All
Other
All
category
the
Docket
No.
MC96-3
3
WA/USPS-T4-12.
Refer
$217,853
in
INTEREST
EXPENSE-BLDG
a.
the
Please
to
column
provide
LR-SSR-119,
Sheet
and
8,
"TOTAL ACCRUED ($1,000)"
& LEASEHOLD
the
the
for
amount
"C/S
18.2.5
(COMPONENT 215)".
calculations
used
to
derive
the
amcmunt
$217,853.
b.
To the
extent
amount
referred
document
please
cost
to
"Cost
provide
figures
used
in
above
"a."
Segments
in
the
are
calculations
not
and Components,
documents
containing
of
contained
Fiscal
those
in
Year
the
the
1994",
figures.
,/-A
Refer
OCA/USPS-T4-13.
where
it
Segments
states
and
attributable
page
34,
"[alttributable
Components
costs
for
lines
costs
Report
post
for
office
5-6,
are
are
Report
for
FY 1994
Cost
Segments
and Components
Report
for
FY 1995
Please
there.
confirm
If
you
that
do not
the
page
35,
number
‘4."
confirm,
line
please
6,
of
was inadvertently
explain.
the
from
rather
your
testimony
Cost
explain
derived
and Components
to
from
Please
Segments
Refer
your
derived
FY 1994".
boxes
of
Cost
WA/USPS-T4-14.
,/--.
to
why
the
than
testimony.
placed
the
Docket
No.
MC96-3
4
OCA/USPS-T4-15.
a.
b.
Please
confirm
Group
confirm,
please
Please
confirm
post
d.
Please
provide
III
the
Table
boxes.
attributable
boxes
are
allocated
Group
please
II
testimony.
are
allocated
you
do not
to
attributable
costs
as Table
18,
Please
explain
why the
attributable
Group
E) post
as institutional
Refer
to
Delivery
Delivery
office
Group
Group
boxes.
I-A,
If
you
explain.
costs
define
your
for
to
post
attributable
Please
If
costs
total
OCA/USPS-T4-16.
of
explain.
same form
(proposed
18,
costs
provide
treated
,r-.
44,
office
and Delivery
confirm,
III
a.
post
that
do not
in
page
no attributable
III
office
I-C,
I-B,
to
that
Delivery
III
C.
Refer
per
box
or
in
for
the
Delivery
boxes
Group
for
Delivery
should
not
costs.
LR-SSR-93,
and describe
(1)
business
and residential
(2)
contract
boxes,
(3)
detached
boxes.
and
the
Item
following
facility
1,
Group
alternative,
Delivery
costs
office
for
page
box
boxes,
3.
types:
III.
Group
be
Docket
b.
No.
Please
"a."
B,
5
identify
above
I-C,
offices
,--.
MC963
is
Delivery
where
located
Group
each
in
II,
box
relation
type
defined
to
and Delivery
Delivery
Group
and described
Group
III
I-A,
post
in
I-
Docket
No.
MC96-3
CERTIFICATE
I hereby
document
accordance
upon
certify
all
with
that
I have
participants
section
3.B(3)
OF SERVICE
this
date
of
record
of
the
in
special
served
this
the
proceeding
rules
tfJYz‘z~
Attorney
Washington,
DC
July
10, 1996
,--
20268-0001
foregoing
of
in
practice.