,
.,-’
-
RECEIVF+
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, DC 20268-0001
POSTALRATECOHHISS,~~
OFFICE OFTHE SECRETA~~~
Special
Services
Fees
Docket
and Classifications)
No.
MC96-3
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES TO UNITED STATES POSTAL SERVICE
WITNESS SUSAN W. NEEDHAM
(OCA/USPS-T&35-37)
(July
26, 19961
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
Advocate
Consumer
for
production
OCA Interrogatories
June
19,
of
1996,
of
l-4
are
hereby
by reference.
Respectfully
GAIL WILLETTE
Director
Office
of the
SHwEf+
Attorney
submitted,
re
Consumer
Ad&&e,.
..
to
Docket
No.
MC96-3
OCA/USPS-TB-35.
The following
provided
testimony
cards
in
in
your
USPS Cost
dispensers,
/-
2
cost
segment
Govt.
Mfg.
1989
1990
1991
1992
1993
1994
1995
$4,913,678
$4,361,220
$4,927,19.3
$3,774,641
$4,156,707
$3,077,873
$4,352,568
Postal
Costs
Does
a relationship
your
Table
XXIX
Manufacturing
1989-95
106 and data
and Components
Cards
between
entitled
the
Government
Source
in
provided
for
reports,
stamps
data
Postal
segment
Segments
please
exists,
cost
postal
and
16,
Rpt.
provided
in
Cards
USPS LR-SSR-106
cost
USPS Cost
a relationship
information
USPS Cost Seg. & Components
Stamps and Dispensers
cost sm
$4,914,000
$4,361,000
$4,927,000
$3,775,000
$4,157,000
$3,078,000
$4,353,000
exist
provided
the
includes
16.
Costs,
data
dispensers,
If
at
Segments
FY
a.
table
at
6,
stamps
and the
and
and Components
identify
the
this
interrogatory.
FY
type
report?
of
relationship
b.
The following
relationship
your
testimony
refers
to
between
the
refers
to
part
data
a of
exists,
a specially
please
created
explain
library
If
why
a
Docket
No.
MC96-3
3
*---.
reference
Postal
c.
as opposed
Service
card
refers
that
costs
a report
and on file
The following
confirm
to
cost
are
to
readily
with
the
exhibit
segment
Postal
stamp
If
to
Rate
USPS-T-5H
16,
$3,760,000.
available
at
Commission
49.
Please
and dispenser
you
do not
the
postal
confirm,
please
explain
d.
The following
proposed
volume
refers
rates
is
to
(with
exhibit
mix),
421,302,OOO.
USPS-T-5J
please
If
you
at
confirm
are
15.
that
unable
to
c and d of
this
For
FY96
postal
card
confirm,
please
explain.
/ S.-Y
e.
The following
Please
refers
to
that
the
confirm
$0.008925,.
parts
unit
when USPS witness
manufacturing
costs
The following
Assume
that
$0.008925.
yields
a stamped
($0.02/$0.008925).
./--
to
unit
Please
are
is
stamped
card
used
= $0.008925).
refers
the
cost
Patelunas'
and volumes
($3,760,000/421,302,000
f.
manufacturing
interrogatory.
part
e of
manufacturing
confirm
card
cost
If
not,
that
this
interrogatory.
cost
of
a proposed
coverage
explain.
of
a stamped
fee
of
224 percent
card
$0.02
is
Docket
No.
MC96-3
4
.;
g.
The following
confirm
refers
that
FY 1996
If
$4,950,000.
h.
i.
Please
to
you
explain
your
stamped
do not
why the
stamp
in
part
c of
identified
in
your
testimony.
this
take
into
account
interrogatory
confirm
costs
that
to
your
double
confirm,
please
Your
at
107.
Please
manufacturing
please
ceosts
are
explain.
and dispenser
postal
card
costs
interrogatory
differ
from
those
your
responses
testimony
addition
in
OCA/USPS-T8-36.,
this
and your
results
unable
card
confirm,
identified
Please
testimony
of
at
postal
counting
to
card
those
parts
a - h of
106-07.
Please
manufacturing
costs.
If
you
are
explain.
testimony
at
103-04
indicates
that,
given
the associated
‘bargain'
with postal
cards,
the
Postal
Service
recently
decided
to review
current
manufacturing
costs
of postal
cards and analyze
the
value
of service
associated
with the general
design
of
a postal
card and the convenient
feature
of preaffixation
of postage.
In your
and
/.-.
testimony
"The
state,
at
first
beneficial
features
identifies
prestamped
a.
Please
is
confirm
smal1e.r
than
you
104,
article
of
postal
postal
that
the
refer
in
to
Postal
cards."
card
a postal
maximum
USPS LR-SSR-106
World
Postal
at
describes
World
7-13,
the
also
limitations.
card
is
4 inches
3 inches
x 6 inches
x 5 inches
allowed
and
at
Docket
No.
the
MC96-3
post
5
card
rate.
If
you
are
unable
to
confirm,
please
explain.
b.
Does
the
space
C.
or
available
to
on the
return
space
available
for
the
Business
For
Reply
half
you
are
of
limit
unable
a double
preprinting
response?
If
,the
to
you
psostal
a court'esy
are
unable
to
card
reply
confirm,
explain.
the
double
"the
card,
please
perf/fold
is
confirm
located
prefers."
postal
cards
bear
large
volume
users
may need
prevent
postal
please
explain.
card
"live"
theft.
Since
postal
cards
bear
large
volume
users
may need
refunds
confirm,
due
to
please
postal
explain.
at
that
the
on the
top,
USPS LR-SSR-106
Since
to
If
card
explain.
as USPS itself
for
on a postal
user?
postage
the
half,
,--.
card
Does
please
f.
the
imprint
please
or
e.
permit
confirm,
limit
d.
stamp
postage,
If
you
"live"
postage,
an accounting
card
spoilage.
the
bottom
7.
please
add security
are
not
at
to
response
confirm
that
measures
unable
please
to
confirm,
confirm
mechanism
If
to
you
that
to
are
allow
unable
Docket
No.
MC963
6
,..-;
OCA/USPS-T8-37.
testimony
a.
The following
at
Please
b.
confirm
cost
If
C.
explain
costs,
which
a 136.7
were
additional
,.‘--.
to
your
to
Please
costs
coverage
recommended
in
to
unable
the
to
for
the
confirm,
card
in
explain.
recommended
post
postal
R94-1
coverage,
coverage
card
such
a
subclass.
explain
that
post
now being
of
170 percent.
why the
should
manufacturing
are
OCA/USPS-T&35(f)
R94-1.
cards
explain.
up in
of
costs
postal
Commission
attributed
cost
refers
cost
are
R94-1,
cost
manufacturing
attributed
confirm,
an additional
manuEacturing
were
you
marked
percent
interrogatory.
percent
to
card
percent
why the
The following
card
in
136.7
unable
Please
assume
d.
are
If
that
of
postal
XXIX
indicated.
confirm
you
the
Table
coverage
had
,,.-w
that
in
years
Please
refers
106-07.
identified
the
interrogatory
224 percent
required
and part
attributed
be required
to
versus
cards
c of
postal
assume
the
an
136.7
to
this
Docket
No.
MC96-3
CERTIFICATE
I hereby
document
accordance
upon
with
certify
all
that
I have
participants
section
3.Bi3)
OF SERVICE
this
date
of
record
of
the
in
served
this
special
SHELLEY
ep+
DREIFUS
Attorney
Washington,
DC
July
26, 1996
,_.--.
20268-0001
the
foregoing
proceeding
rules
of
in
practice.