.
,/---
BEFORE THE
POSTAL RATE COMMISSION
20268-0001
WASHINGTON, D.C.
RECEIVED
h
8
12 08 /'M ‘96
POSTA. RATECOMMISSION
OF WE SECH&
OFWE
Special
Services
Fees
Docket
and Classifications)
No.
MC96-3
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES TO UNITED STATES POSTAL SERVICE
WITNESS JOHN F. LANDWEHR
(OCA/USPS-T3-13-24)
(August
8, 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
Advocate
Consumer
for
production
OCA Interrogatories
June
19,
1996,
of
of
1-4
are
hereby
by reference
Respectfully
GAIL WILLETTE
Director
Office
of the
submitted,
Consumer
Advocate
5Lb-matti~
SHELLEY DREIFUSS
Attorney
,/-.
&
..~~&==%&,
r~FTc0
A'
to
Docket
. /--.
No.
MC96-3
2
OCA/USPS-T3-13.
a.
Refer
Please
explain
within
the
post
b.
corporate
limits
two-thirds
office
revenue
non-resident
determined
that
the
of
your
providing
Middleburg,
the
1,856
testimony.
delivery
given
box
delivery."
would
be lost
were
to
the
that
holders
and businesses
mail
service
area
Refer
"temporary
of
to
are
rely
Middleburg
provided
office
box
other)
or
change
explain.
of
4,
lines
within
16-17,
Please
holders.
post
the
page
forwarding
that
(or
page
of
confirm
please
not
residents
box
Please
mail
_---
to
one third
OCA/USPS-T3-15.
a.
of
service
Refer
concerning
concerning
9-11,
on
Post
the
limits?
OCA/USPS-T3-14.
outside
for
lines
for
of
city
delivery
corporate
f-‘
"all
boxes
How much box
if
4,
rationale
and
Office
page
the
approximately
residents
to
the
office
your
explain
box
testimony
how you
customers
"reside
office."
4,
lines
21-24,
of
your
testimony
orders."
Postal
customers
address
of
orders.
Service
a fee
If
does
not
charge
for
the
forwarding
you
do not
confirm,
post
of
Docket
,---.
b.
No.
MC963
Please
the
estimate
generated
C.
3
number
by residents
period
during
which
Please
confirm
that
forwarding
order
a resident
box
of
temporary
forwarding
orders
and
the
and non-residents,
these
is
orders
were
the
cost
of
the
same
for
If
holder.
you
state
time
generated.
processing
a temporary
a non-resident
do not
as it
confirm,
is
for
please
explain.
OCA/USPS-T3-16.
a.
At
what
for
,,.-7.
b.
Refer
to
in
the
stage
San Luis,
what
is
the
"recipients
that
of
Please
to
,/--'
b.
explain
opening
page
7,
lines
1,
of
is
the
to
to
Act
from
your
this
16-18,
federal
confirm,
page
policy
Freedom
"[tlhe
of
of
and non-resident
do not
the
explain
Information
of
checks
you
responding
Please
process
date
resident
Refer
OCA/USPS-T3-18.
a.
to
benefit
If
authorities."
footnote
testimony.
new facility
AZ?
Refer
confirm
6,
planning
expected
OCA/USPS-T3-17.
Please
page
lines
of
the
process
requests.
and
please
7,
of
box
Information
for
your
testimony.
holders
are
state
explain.
18-19,
Postal
new facility?
of
your
Service
Act
responding
testimony.
with
respect
requests.
to"
Freedom
of
Docket
,
,<--.
No.
MC96-3
Please
C.
explain
on behalf
such
d.
of
Act
same as the
cost
residents.
If
the
are
and
confirm
the
a.
l-2,
the
person(s)
If
b.
If
you
difficult
do not
not
of
Freedom
than
of
non-residents
requests
confirm,
the
of
explain.
reimbursement
Freedom
is
on behalf
please
processing
for
of
whatever
Informaticsn
Act
explain.
to
your
testimony
of
Service
the
is
provides
listed
explain
please
pages
Service
box
explain
7-8,
lines
testimony.
Please
box
only
on the
please
named on the
control."
your
on the
Postal
do confirm,
at
name(s)
confirm,
the
requests
greater
processing
such
request
name(s)
matches
to
of
on behalf
Service
Postal
circumstances
person(s)
cost
do not
Act
proportionately
processing
in
Information
residents.
respectively,
whose
1093)
you
you
Refer
that
(PS Form
of
Please
lines
the
incurred
OCA/USPS-T3-19.
of
requests
Postal
requests?
26,
that
of
are
on behalf
Information
Does
Freedom
non-residents
confirm
costs
T--.
whether
requests
Please
e.
4
service
box
mail
25-
where
application
form
piece.
under
provides
application
how "[u]se
what
box
service
to
a
form.
of
the
box
is
Docket
. ,---.
No.
MC96-3
OCA/USPS-T3-20.
26 and
25-26
Refer
lines
and
l-8,
lines
if
the
basis
for
your
What
is
b.
in
page
all
non-resident
not
22-
9-10,
that
lines
the
box
be reduced,
Service's
confirm,
that
the
a current
cable
TV hook-up
street
address."
Refer
9,
box
Canadian
lines
even
proposal
please
explain
for
the
hookup
lease,
to
the
citizens
delivery
fee
your
testimony.
Blaine
Post
Office
who own vacation
area
could
by providing
(gas,
or
electric,
page
10,
at
lines
the
of
residency,
water,
sewage,
a deed
any other
USPS-T-7
avoid
proof
a mortgage,
bill,
(See,
in
of
citizens?
Blaine
or
5-6,
holders
"Canadian
as a "utility
OCA/USPS-T3-22.
to
Postal
do not
non-resident
trash),
testimony.
to
of
confirm
proposed
confirm
will
lines
pages
Please
pages
the
to
7-8,
conclusions.
made up of
such
you
Refer
property"
,/-'
If
proportion
Please
referenced
pages
refer
ascribed
recommends
boxes.
at
Also,
respectively.
above
OCA/USPS-T3-21.
a.
testimony
requirements"
Commission
office
your
respectively.
on the
post
to
l-11,
"administrative
customers
5
of
trust,
verifiable
proof
24.)
14-16,
of
your
a
of
a
Docket
I
No.
MC96-3
6
,<---._
a.
Please
provide
material
that
all
support
many similar
b.
Please
with
surveys,
the
offices
provide
to
studies,
conclusion
reports
that
or
"there
are
other
also
nationwide."
the
reference
data,
number
any
of
of
the
offices
similar
information
nationwide,
requested
in
(a)
above.
C.
If
(b)
you
are
above,
number
of
unable
to
provide
please
estimate,
offices
similar
OCA/USPS-T3-23.
Please
a.
to
the
information
based
upon
requested
your
in
experience,
the
nationwide.
refer
to
your
response
to
OCA/USPS-T3-4.
/---.
In
for
response
post
ofEice
methods
b.
used
If
so,
In
response
your
Are
their
to
aware
of
employees?
,--.
In
response
mention
Are
for
post
you
one possibility
aware
office
of
box
other
assignment?
them
you
OCA/USPS-T3-4a,
to
and differences
C.
assignment.
describe
employees
you
box
by postmasters
please
you
OCA/USPS-T3-4a,
assign
other
post
office
postmasters
state
that
boxes
you
sequentially.
who similarly
If
so,
please
describe
with
the
method
you
you
instruct
any
instruct
similarities
use
to
OCA/USPS-T3-4a,
state,
regulations
or
guidelines
for
this
process."
regulations
or
guidelines
regarding
efficient
"There
Are
are
no
there
management
any
or
Docket
No.
MC96-3
operation
Are
7
of
post
office
postmasters
utilization
box
evaluated
of
sections?
If
positively
resources
in
for
operating
so,
provide
them.
efficient
their
offices?
Please
explain.
d.
Your
response
assignment
to
mail
boxes
to
of
boxes
boxes.
in
method?
OCA/USPS-T3-4b
results
Would
it
no particular
Please
OCA/USPS-T3-24.
states
in
that
efficient
distribution
be inefficient
pattern
sequential
to
(randomly)
assign
of
the
20
as oplposed
to
your
explain.
Please
assume
the
following:
(1)
TWO Posital
/*-Service
Zip
customers
Code
area
office
box
least
once
(3)
where
in
in
the
area
near
his
Mail
inadequate
this
prefer?
volume
a post
He does
volume
non-resident
Code area
reside.
B rents
the
a Zip
they
he resides.
Given
in
which
a day.
Customer
Accumulated
a.
work
office
may frequently
Postal
mail
mailbox
interrogatory,
office
Service's
volumes
capacity
which
differs
Customer
(2)
and thus
rarely
not
that
exceeds
box
visit
in
from
A rents
checks
box
the
Zip
on a daily
exceed
box
capacity.
frequently
and the
customer
in
his
Code
box
concern
a post
box
area
basis.
MC96-3
that
present
problems
due
scenario
presented
in
would
at
capacity.
his
stated
the
a postmaster
to
Docket
.
..--
b.
No.
Please
to
box
MC96-3
a
explain
Customer
capacity
the
A,
rationale
whose
than
are
mail
for
charging
volumes
Customer
B's.
are
less
a non-resident
likely
to
fee
exceed
Docket
No.
MC96-3
r-..
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
gwfbY?d
t!#dJ
SHELLEY DREIFUSS
Attorney
Washington,
August
8,
D.C.
1996
20268-0001
the
foregoing
proceeding
rules
of
in
practice.