a
BEFORE THE
-.--
IIECEIVEU
POSTAL RATE COMMISSION
WASHINGTON, D.C.
20268-0001
JUL
24 1208P/I‘9s
rosnt
RATE COHHISSION
OFFICE INTHE SECRETARY
Special
Services
Fees and Classifications)
Docket
No. MC!36-3
OFFICE OF THE CONSUMERADVOCATE
INTERROGATORIES TO UNITED STATES POSTAL SERVICE
WITNESS PAUL M. LION
(OCA/USPS-T4-21-26)
(July 24, 1996)
Pursuant
the Postal
hereby
to sections
Rate Commission,
submits
documents.
25 and 26 of the Rules
the Office
interrogatories
Instructions
of the
and requests
included
with
Service
dated
of Practice
of
Consumer Advocate
for
production
OCA Interrogatories
of
l-4
r-'
the United
incorporated
States
Postal
June 19,
1996,
are hereby
by reference.
Respectfully
submitted,
GAIL WILLETTE
Director
Office
of the Consumer Advocate
SHELLEY DREIFUSS '
Attorney
to
Docket
No. MC96-3
OCA/USPS-T4-21.
2
Refer
to LR-SSR-104,
footnote
15, at 23,. concerning
that
the
"Facility
computed
on the
foot
(see LR-SSR-99,
a.
If
you do not
Mail
post
If
b.
per
you do not
basis
as the
I-B,
concerning
rents
for
For postal
facilities
If
Postal
floor
Foot"
confirm
Foot"
cost
why the
was not
rental
cost
was
per
:square
"Facility
estimated
Cost
on the
per
square
foot
for
caller
service
per Square
Foot"
rental
I-C,
for
cost
post
per
floor
for
lobby
lines
floor
pays or imputes
other
please
floor
explain.
on the
foot
the
same
(see LR-
boxes by Delivery
Group II.
space located
having
square
office
and Delivery
to page 34,
Service
confirm,
provide
Processing
space and all
you do not
rental
explain
please
average
Refer
lobby
average
confirm,
OCA/USPS-T4-22.
the
please
at 5) computed
Group I-A,
that
per Square
as the average
Square
Cost Mail
SSR-99,
Please
boxes.
"Facility
/"-'
Processing
confirm,
as the
office
service.
at 5).
Processing
same basis
caller
Cost Mail
same basis
page 1, and USPS-T-l<
18-19,
of your
in postal
space,
the
facilities.
please
same rent
space in the
testimony
confirm
for
the
sam'e facility.
Docket
No. MC96-3
3
OCA/USPS-T4-23.
Refer
to LR-SSR-104,
service.
define
and distinguish
Please
key parameters:
of Firms
"Caller
page 1, concerning
between
the
Numbers or Separations"
caller
following
and "Total
two
Number
or Callers".
OCA/USPS-T4-24.
Refer
to LR-SSR-104,
page 1, concerning
caller
service.
a.
Please
that
b.
Please
that
define
and explain
are caller
service
define
and explain
are caller
service
what constitutes
"Large
Firms"
"Small
Firms"
customers.
what constitutes
customers.
I”-OCA/USPS-T4-25.
concerning
caller
$67,221,780
service
a.
If
Refer
service.
represents
in the
attributable
b.
before
In addition,
caller
Please
the total
FY 96 test
you do not
year,
to LR-SSR-104,
service
year,
confirm,
costs
for
Exhibit
confirm
attributable
before
I on page 2,
that
the
costs
"Total"
for
of
caller
rates.
please
explain
and provide
caller
service
in the
the
total
FY 96 test
rates.
please
provide
in the
the total
FY 96 test
year,
attributable
after
rates.
costs
for
Docket
4
No. MC96-3
,_.-_.
OCA/USPS-T4-26.
USPS-Tl,
between
service
service
to LR-SSR-104,
WP D, at page 3.
difference
caller
Refer
the
Please
"Total"
in LR-SSR-104,
blefore
rates
Exhibit
explain
annual
of $29,041,000
and reconcile
cost
Exhibit
I,
I oh page 2, and
thla
of $67,221,780
and the cost
for
of c,aller
in WP D.
CERTIFICATE OF SERVICE
I hereby
document
accordance
certify
upon all
with
that
I have this
participants
section
3.B(3)
date
of record
of the
served
in this
special
,,'--.
SHELLEY
*p+
REIFUSS
Attorney
Washington,
D.C.
July 24, 1996
I./
20268-0001
the
for'egoing
proceeding
rules
in
of practice.