f
RECE\VED
BEFORETHE
POSTAL RATE COMMISSION
WASHINGTON,
D.C. 2026%OoQct
25
4 2
s PE\
‘96
p05TA,,R,.lECL-‘UHIS~iCN
c CREIA~~
nFF,CEOFTHi ,E
SPECIAL SERVICES REFORM, 1996
I
Docket
No. MC96-3
UNITED STATES POSTAL SERVICE INTERROGATORIES
AND REQUESTS FOR
PRODUCTION
OF DOCUMENTS
TO OFFICE OF THE CONSUMEl,R ADVOCATE
WITNESS CALLOW (USPS/OCA-T300-22-29)
Pursuant
2 of the Special
following
Consumer
.to rules 25 and 26 of the Rules of Practice
Rules of Practice,
interrogatories
Advocate
the United
and requests
witness
Callow:
States
for production
and Procedure
and rule
Postal Service
directs
the
of documents
to Office
of the
(USPS/OCA-T300-22-29).
Respectfully
UNITED
submitted,
STATES POSTAL SERVICE!
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemakilng
l+F-7d?d~
Susan M. Duchek
CERTIFICATE
Ii hereby certify
participants
of record
of Practice.
OF SERVICE
that I have this day served the foregoing document
upon all
in this proceeding in accordance with sectioln 12 of the Rules
475 L’Enfant Plaza West, S.W.
Washington,
D.C. 20260-l
137
(202) 268-2990;
Fax -5402
October 25, 1996
2
USPS/OCA-T300-22.
post office
a.
b.
On page 1, column
boxers are reported
9 of OCA-LR-3,
TYAR Total Costs
to be $466,254,352.
Please explain
the derivation
spreadsheets,
workpapers
Please explain
in detail why TYAR Total Costs for post offfice
of $466,254,352
post office
for
differ
of this figure in detail,
providing
all
and other related documents.
from the TYAR total attributable
boxes of $516,598,000
shown
in Exhibit
b’oxes
costs
For
IJSPS-T-51, page
n
L.
c.
In deriving
the TYAR Total Costs for post office
$466,254,352,
would
decline
decrease
explain
d.
did You assume
the rationale
underlying
Please explain
in detail all evidence
would
that a decrease
be accompanied
and rental related
Is it Your testimony
convert
detail
costs
assumptions
in det:ail.
of post office
that postal
with
facilities,
post office
If not,
data which
lboxes in use
in the space
boxes.
in the test year, would
uses or activities?
or other supporting
than the
you did make.
in the test Year by a like decrease
associated
costs
If so, please
or other supporting
in the number
the space to other
all evidence
boxes in use?
this assumption
in detail what
box attributable
or by a larger perc:entage
of post office
please explain
indicate
I?.
that post office
in a larger proportion
in the number
boxes of
If so, please expllain in
data for this conclusion.
3
f,.
In LISPS-T-5, Appendix
“Additionally,
B, lines ,l O-l 4, witness
it was assumed
space and rental related
Office
costs
please explain
supporting
USPWOCA-T300-23.
T-4).”
office
with the decmase
these costs would
Do you disagree
why in detail
and discuss
data for your contrary
Please confirm
presented
in the
in Plost
not respond
respond
some
with this statement?
all evidence
If so,
Ior other
conclusion.
At page 23, lines 1-2 of your testimony,
relies on cost estimates
box proposal
associate
stated,
be no change
in the test year, but rather, they would
time after the test year.”
proposal
that there would
Boxes in use because
immediately
Patelunas
by Postal Service
that you used Postal Service
you state,
witness
Lion (USPS-
cost data to derive your post
costs presented
rather than the Commissicn’s
“My
in PRC-LFI-1
and
2.
a.
If you do not confirm,
b.
If you did not review
presented
in PRC-LR-1
please explain
and/or
consider
USPSOCA-T300-24.
problem
in pricing
the Commissions
costs
and 2 to derive your post office
wfry did you need an extension
September
in detail.
of time from September
box proposal,
25,
1996
to
30, 1996 to prepare and file your testimony?
OCA witness
post offices
Sherman
says that
“[tlhere
boxes that is not considered
--
is a broad general
explicitly
in the [Postal
____
-.
4
Service’s]
proposal.
to a post office
lines
l-4.
That problem
box rather than to a business
At pages 24-29
the Postal Reorganization
witness
Sherman’s
a.
is that there may be a cost savings
or residence.”
of your testimony,
Act.
“problem
In that discussion,
in pricing
Do you disagree
you discuss
with
OCA-T700,
various
page 27,
pricing
you do not address
post office
witness
in delivery
crliteria
of
OCA
boxes.”
Sherman’s
assessment?
Please explain
in detail.
b.
If you do not disagree
address
witness
his idea in the context
Please explain
USPSiOCA-T300-25.
with
Sherman,
then why did you not
of the pricing
criteria
elf the Act?
in detail.
Please refer to OCA-LR-3,
Post Office
Boxes USPS Proposal,
page 1.
a.
Please confirm
number
confirm,
b.
3.
C.
of boxes) represent
please explain
Please confirm
Costs)
that columns
that columns
If you do not confirm,
using witness
post office
of boxes)
boxes in use.
and 2 (TYAR
If you do not
in detail.
were both calculated
Please confirm
1 (TYBR number
8 (TYBR Total Costs)
using th.e same cost per box from column
please explain
in detail.
that the cost per box from column
Patelunas’s
and 9 (TYAR Total
TYBR post office
3 was calculated
box attributable
---.
cost
5
figure
of $529,374,000
confirm,
d.
please explain
Is it your testimony
use would
USPWOCA-T3001-26.
a.
h.
If you do not
that the unit cost per box for post office
boxes in
rates and the test
fully.
Please refer to OCA-LR-3,
Post Office
Box and Caller Service
page 3.
Please confirm
that columns
1 (USPS TYBR number
(OCA TYAR number
of boxes) represent
you do not confirm,
please explain
Please confirm
from column
that columns
3.
Please confirm
using witness
figure
please explain
please explain
TYBR post office
from Exhibit
and 9 (OCA
in detail.
3 was calculated
box attriblutable
USPS-T-5E, at 8.
cost
If you do not
in detail.
that the unit cost per box for post office
remain the same in the test year before
year after rates?
If
using the same cost per box
that the cost per box from column
Patelunas’s
and 2
boxes in use.
8 (USPS TYBR Total Costs)
If you do not confirm,
Is it your testimony
use would
post office
of boxes)
in detail.
were both calculated
of $529,374,000
confirm,
d.
USPS-T-5E, at 8.
in detail.
Please explain
TYAR Total Costs)
C.
Exhibit
remain the same in the test year before
year after rates?
OCA Proposal,
from
Please explain
fully.
boxes in
rates and the test
6
USPSiOCA-T300-27.
state that
boxholders
“The
Postal Service’s
through
a.
treatment
of non-resident
non-resident
surcharge
is unfair and inequitable”.
the criteria
a non-resident
Uncler what
circumstances
Do you consider
Wazshington,
With
respect
higller
during
assumption
you have based your statement
is unfair and inequitable.
or criteria
would
Please explain
the higher charges
D.C. area during
Please explain
d.
upon which
surcharge
be fair and equitable?
c.
you
discriminatory
the proposed
Please provide
that
b.
On page 15, line 21. page 16, line 2 of your testimony,
a non-resiNdent
surcharge
fully.
imposed
on Metro
rush hours to be unfair
riders in the
and inequitable?
why or why not.
to Metro,
please assume
that the cost ps!r rider is not
rush hour than at other times.
affect
your view
How would
about the fairness
that
and equity
of higher
rush hour fares?
USPSiOCA-T30Cl-28.
“[ilmplementing
costing
the proposed
information
a.
On page 17 lines 6-8 of your testimony,
non-resident
and demonstrated
Specifically,
what
non-resident
surcharge
demonstrated?
surcharge
need would
need would
you state that
in the absence
of critiical
be unfair and inequitable”.
have to be demonstratsd
fair and equitable
and how could
to make the
it be
-
I
7
b.
What
costing
surcharge
explain
data would
be needed to make the non-resident
fair and equitable
and how could it be obtailied?
Please
fully.
USPS/OCA-T300-29.
On page 26, line 18 - page 27, line 1 of your testimony,
you
state that:
Post offic’e box service offers relatively low value. Box features such
as privacy and security are offset by more limited boxholder access to
the mail at post office box sections, as compared to carrier delivery.
a.
Please explain
boxholders
b.
your conclusion
than those
receiving
that access to mail is rnore limited
carrier delivery,
other relevant
information
Please explain
how you determined
security
are offset
post office
to support
by more limited
box sections,
data and other relevant
all data and
this claim.
that the value of privacy
boxholder
as compared
information
including
for
access
to carrier
to support
and
t,o the mail at
delivery,
your claim.
providing
all