BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C.
20268-0001
POSTAL RATE COHHiSS10~
OFFlCEOFTtiE
SECRETARY
Special
Services
Fees
and Classifications)
Docket
No.
MC96-3
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES TO UNITED STATES POSTAL SERVICE
WITNESS PAUL M. LION
(OCA/USPS-T4-38-43)
(August
6, 1996)
Pursuant
the
Postal
hereby
Rate
submits
documents.
the
to
United
incorporated
sections
Commission,
25 and 26 of
the
interrogatories
Instructions
States
Postal
Office
of
Rules
the
and requests
included
with
Service
dated
of
Practice
Consumer
for
OCA Interrogatories
June
19,
1996,
GAIL WILLETTE
Director
Office
of the
Attorney
submitted,
Consumer
Advocate
of
Advocate
production
by reference.
Respectfully
/-
the
of
1-4
are
hereby
to
Docket
No.
MC96-3
2
OCA/USPS-T4-38.
"Form
Refer
1901's
represents
If
a.
b.
to
Volumes."
the
you
total
represents.
If
do confirm,
"Caller
please
that
the
explain
in
reconcile
or
II,
and
column
figure
8,577
separations.
please
Numbers
Exhibit
confirm
of
confirm,
figure
233,786
Please
number
do not
you
LR-SSR-104,
this
Separations,"
detail
what
this
figure
with
the
on page
1 of
LR-
SSR-104.
OCA/USPS-T4-39.
that
/-
the
derived
Refer
figure
to
"Separations
per
the
Caller"
a
If
you
do not
b.
If
you
do confirm,
(not
"Total
233,786,
by multiplying
firms)
LR-SSR-104,
of
number
Please
1.
confirm
Separations,"
of
firms
was
(100,700)
by the
(2.32).
please
please
in
Number
total
confirm,
or,
page
the
explain.
provide
a count
of
a list
alternative,
of
call
numbers
call
numbers
assigned.
OCA/USPS-T4-40.
all
data
"Number
Refer
and calculations
of
Square
Feet
to
LR-SSR-104,
used
Allocated
to
Exhibit
derive
per
Firm".
the
IV.
Please
figure
4.1,
provide
the
Docket
--.'
No.
MC96-3
3
OCA/USPS-T4-41.
Refer
to
Table
the
attributable
costs
of
post
office
boxes.
the
cost
is
included
in
costs
of
per
If
a.
parcel
lockers
18 of
your
testimony
concerning
Please
the
total
confirm
that
attributable
box.
you
do not
excluding
confirm,
the
cost
please
of
explain
parcel
lockers
the
rationale
from
for
attributable
costs.
b.
If
you
do confirm,
parcel
lockers
the
number
number
or
and
of
of
post
post
highway
contract
I-C,
and Delivery
facilities
a.
/--.
Please
provide
number
of
boxes
I-B
and
boxes
in
to
the
installed
in
your
that
service
and how the
attributable
also
of
concerning
provide
receive
by Delivery
cost
costs.
testimony
Please
use.
customers
the
city,
Group
rural
I-A,
I-B
II.
Table
space
boxes
I-C,
4 of
Group
Refer
in
Table
box
where
included
delivery
reporting
of
to
office
office
OCA/USPS-T4-43.
explain
has been
Refer
OCA/USPS-T4-42.
,/-.
please
to
number
7 of
testimony
concerning
expand.
of
use
for
for
each
and Delivery
your
post
offices
each
box
box
size
Group
II.
size
reporting
equaled
by Delivery
that
the
the
number
Group
I-A,
Docket
-.
b.
No.
Please
provide
above
that
number
of
I-C,
,/-
MC96-3
also
post
and Delivery
4
the
number
reported
office
Group
of
post
space
boxes
II.
offices
available
by Delivery
identified
to
Group
in
expand
the
I-A,
I-B
"a"
and
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
SHELLEY DREIFUSS
Attorney
Washington,
August
6,
D.C.
1996
20268-0001
the
foregoing
proceeding
rules
of
in
practice.