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BEFORE THE
POSTAL RATE COMMISSION
20268-0001
WASHINGTON, D.C.
Auc6
AH'96
II 43
POSTAL RATE COilHlSSlDH
OFFICE OFTHE SECRETARY
Special
Services
Fees
Docket
and Classifications)
No.
MC963
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES TO UNITED STATES POSTAL SERVICE
WITNESS TIMOTHY D. ELLARD
(OCA/USPS-T6-25-28)
(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
the
of
Rules
the
and requests
included
with
Service
dated
of
Practice
Consumer
for
Advocate
production
OCA Interrogatories
June
19,
1996,
GAIL WILLETTE
Director
Office
of the
are
Attorney
submitted,
Consumer
of
1-4
by reference.
Respectfully
of
Advocate
hereby
to
Docket
No.
MC96-3
OCA/USPS-T6-25.
the
actual
2
Please
post
box
refer
office
to
Table
fees
1 of
proposed
your
testimony
by witness
and
Needham
to
in
USPS-T-7.
a.
Please
confirm
set
proposed
of
resident
b.
box
C.
higher
for
fees
would
confirm
group
and box
was tested-regardless
size
whether
the
same
the
non-
apply.
that
than
a given
the
the
proposed
resident
non-resident
fee
for
fee
each
group
is
$36 a
I and
II
size.
Please
fee
,-
fee
Please
year
that
confirm
that
proposals
price
are
and that
survey's
for
close
the
lowest
Groups
to
your
resident
tested
I and
fee
the
non-resident
survey's
highest
proposals
are
If
price.
II,
you
do not
tested
close
to
your
confirm,
please
explain.
d.
Please
confirm
informed
that
than
resident
the
concerning
the
Please
the
the
their
to
acceptance
confirm
acceptance
non-resident
fees
post
Refer
OCA/USPS-T6-26.
a.
that
would
office
Table
of
that
Table
rates
for
respondents
generally
box
7,
three
not
$36 a year
more
fees.
page
price
7 does
run
were
not
non-residents
15,
of
your
testimony
levels.
differentiate
and residents
between
at
the
Docket
NO. MC96-3
rates
that
3
each
would
OCA/USPS-T6-25(c)).
b.
If
you
rates
c.
If
confirm
the
relevant
residents
Please
be subject
you
do not
response
to
the
to
to
proposed
under
the
confirm,
proposal
please
"a",
provide
the
rate
separately
(see,
explain.
acceptance
for
non-
and residents.
explain
how the
be alleviated
in
problems
light
of
your
caused
by non-residents
response
to
"a"
and
will
"b"
above.
OCA/USPS-T6-27.
you
explain
Please
that
refer
objections
to
to
page
rate
7 of
your
increases
testimony
are
where
likely
to
be
overstated.
a.
Please
this
b.
provide
to
survey
literature
that
support
conjecture.
Please
explain
determined
C.
citations
from
citations
to
adjusting
the
Please
how the
refer
your
support
survey
to
page
the
midpoint
between
the
estimate
of
recommend
this
true
acceptance
survey
any
results.
A2 of
of
procedure?
price
USPS-T-l.
for
If
should
be
provide
recommendations
100 percent
acceptance
Please
specific
estimates
rate
acceptance.
Witness
and the
the
so,
for
proposed
please
Lyons
survey
rates.
explain
chooses
result
as
Did
why the
you
Docket
--
No.
MC96-3
midpoint
is
and the
superior
survey
OCA/USPS-T6-28.
11~
that
and
you
to
Is
your
Are
believe
other
refer
to
your
that
Please
elaborate
belief
solely
leading
customers
Please
b.
any
point
between
100 percent
estimate.
Please
do not
list
to
&A/USPS-T&18.
inference.
a.
4
responses
In both
of
these
these
data
are
on the
due to
to
reasons
the
sparse
relatively
to
OCA/USPS-Tb-
responses
you
stated
suitable
for
for
conclusion.
this
response
large
by waiting
sampling
errors?
explain.
you
aware
of
weaknesses
(other
than
small
sample
size)
,F”-.
that
render
describe
C.
Can any
Please
any
these
such
estimates
explain
data
unsuitable
for
inference?
Please
weaknesses.
or
fully.
comparisons
be made using
these
data?
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
served
this
special
SHELLEY DREIFUSS
Attorney
Washington,
August
6,
,,--,
D.C.
1996
20268-0001
the
foregoing
proceeding
rules
of
in
practice.