BEFORE THE POSTAL RATE COMMISSION WASHINGTON, D.C. 20268-0001 II i I MAILING ONLINE SERVICE I : 7 ,‘I; r ,~.lr,,I ‘, ibl iJ q ;: Joi ,j ‘,’ *,i / i, YIr, Docket No. MC98-1 RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS STIREWALT TO INTERROGATORY OF THE OFFICE OF THE CONSUMER ADVOCATE (O’XUSPS-T3-77) The United States Postal Service hereby provides the response Stirewalt to the following USPS-T3-77, interrogatory of the Office of the Consumer filed on October 27, 1998. response to this interrogatory The interrogatory A motion for extension was filed on November Advocate: by the response. submitted, UNITED STATES POSTAL SERVICE By its attorneys: Daniel J. Foucheaux, Jr. Chief Counsel, Ratemaking David H. Rubin 475 L’Enfant Plaza West, S.W. Washington, D.C. 20260-I 137 (202) 268-2986; Fax -5402 November 10, 1998 OCAf of time to file a 6, 1998. is stated verbatim and is followed Respectfully of witness RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS STIREWALT TO INTERROGATORY OF THE OFFICE OF THE CONSUMER ADVOCATE OCXWSPS-T3-77. Please refer to USPS-LR-l/MC98-1, Attachments 1 and 2. Please provide, in hardcopy and in electronic format, a new version of USPS-LRa. l/MC98-1, Attachments 1 and 2, that is up-to-date in that it reflects the current procedures for operating Mailing Online and corrects all known errors. To the extent that the procedures for operating Mailing Online (e.g. b. Telecommunications Internet Connection, Processing Center - Application Server, Processing Center - Netpost Command Center Server, etc.) reflected in the hardcopy and electronic material provided in response to part (a) of this interrogatory are expected to change, please identify those procedures. RESPONSE: a. The current procedures for MOL are of relatively little use in updating Attachments and 2 to reflect the experiment, different procedures. Nonetheless, analysis with current procedures, and 2 with corrections because the experiment An electronic spreadsheet is expected to have while I have not completely compared my I am attaching revised versions of Attachments for known errors and modifications 1 1 based on new information. copy, in the format of my response to OCAIUSPS-T3-1, being provided in USPS-LR-20/MC98-1. I also am attaching a description of the revisions, which increase my costs by $100,000 for “fixed”, $70,000 for year 2000 and $80,000 for year 2001, with no changes in the other years. understand that an updated information procedures during the Mailing Online experiment Moreover, I systems cost analysis reflecting expected is being developed for presentation to the Commission. b. Since the procedures determined, for the Mailing Online experiment I cannot identify those procedures have not yet been which are expected to change. is RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS STIREWALT TO INTERROGATORY OF THE OFFICE OF THE CONSUMER ADVOCATE Summary of change to Attachments 1 and 2 in response to OCAIUSPS-T3-77 Interrogatory Reference XAIUSPS-T3-35(c) Bytes Per Business Day”, the “*“following the fkst “COMP FACT’ should be “c”, A calculation for total number of bytes associated with mailing lists sent with nonmail-merge jobs was not included. In addition, BYTES/PAGE should be multiplied by the average number of pages “number of Bytes Per Business Day in the ‘Telecommunications Servers” Section of FTP XAIUSPS-T3-35(d) developers and learned that mail merge documents are not stored in Postscript format in the current Mailing Online system ICAIUSPS-T3-41, XX/USPS-T3-42 XWUSPS-T3-44(d) XAJUSPS-T3-37 XX/USPS-T3-47(b) XAIUSPS-T3-SO(b) XPJUSPS-T3-47(g) XAIUSPS-T3-48 XWJSPS-T3-51(a) based on new “PROCESSING CENTER DATA STORAGE Postscript Files For NonMail Merge Jobs” and “PROCESSING CENTER APPLICATION SERVER RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS STIREWALT TO INTERROGATORY OF THE OFFICE OF THE CONSUMER ADVOCATE I I OCAIUSPS-T3-72(c) The San Mateo processing center forwards all print jobs to the print site in PDF format. OCAIUSPS-T3-52(c) Confirmed that the formula used to calculate the figure 320.78 should contain the multiplicative terms 3.2 pages per piece Backup Financial Trans.&ons (Night Only) Changed 30270 to 5020 in Attachment 1 Section titled “Telecommunications FTP Servers” Modified Attachment 1 Section Titled -PROCESSING CENTER APPLICATION SERVER Backup PDF Files (Night Only) I Modification based on new information Error COrrection RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS STIREWALT TO INTERROGATORY OF THE OFFICE OF THE CONSUMER ADVOCATE Attachment 1, modified in response YR 1999 Estimate CATEGORY I COMPONENT Description. ttem # TELECOMMUNICATIONS to OCAIUSPS-T3-77 YR 2000 Estimate YR 2002 Estimate YR 2001 Estimate tNTERNET 22.81s 12 s17.so 0.75 sss.13 0.5 T 4 58.68 58.58 0.03 3.2 so20 Source File to PDF Conversion n By%SPsrsesord D”tiW PeakHo”PROCESSING YR 2003 Estimate CENTER - NETPOST COMMAND - SOURCE RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS STIREWALT TO INTERROGATORY OF THE OFFICE OF THE CONSUMER ADVOCATE Attachment 1, modified in response to OCA/USPS-T3-77 YR 1999 Estimate TELECOMMUNICATIONS PROCESSING FTP SERVERS CENTER-DATA STORAGE YR 2000 Estimate (continued) YR 2001 Estimate YR 2002 Estimate YR 2003 Estimate SOURCE RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS STIREWALT TO INTERROGATORY OF THE OFFICE OF THE CONSUMER ADVOCATE Attachment 1, modified in response to OCAIUSPS-T3-77 (continued) 3 RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS STIREWALT TO INTERROGATORY OF THE OFFICE OF THE CONSUMER ADVOCATE Attachment 1, modified in response to OCAMSPS-T3-77 YR 1999 Estimate PROCESSING CENTER APPLlCATlON PROCESSING CENTER-APPLICATION Backup PDF Files (Night Only) m PROCESSING CENTER APPLlCATlON YR 2000 Estimate (continued) YR 2001 Eslimate YR 2002 Estimate YR 2003 Estimate SOURCE SERVE1 SERVE1 SERVEF Y RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS STIREWALT TO INTERROGATORY OF THE OFFICE OF THE CONSUMER ADVOCATE Attachment 2, modified . in response -. - ,_----. to OCAIUSPS-T3-77 - RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS STIREWALT TO INTERROGATORY OF THE OFFICE OF THE CONSUMER ADVOCATE Attachment 2, modified in response to OCA/USPS-T3-77 Management Administration - 6 RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS STIREWALT TO INTERROGATORY OF THE OFFICE OF THE CONSUMER ADVOCATE Attachment :ATEGORY 2, modified FIXED COSTS in response YR 1999 to OCAIUSPS-T3-77 ANNUAL COSTS (continued) YR 1999 YR 2000 - YR 2001 YR 2002 YR 2003 RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS STIREWALT TO INTERROGATORY OF THE OFFICE OF THE CONSUMER ADVOCATE Attachment CATEGORY 2, modified FIXED COSTS in response YR 1999 to OCALJSPS-T3-77 1 (continued) ANNUAL COSTS YR 1999 - - YR 2000 00 (I 0 00 00 I1 YR 2001 YR 2002 YR 2003 1 - 10 RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS STIREWALT TO INTERROGATORY OF THE OFFICE OF THE CONSUMER ADVOCATE Attachment ZATEGORY GRAND TOTALS 2, modified 1 FIXED COSTS in response YR 1999 to OCAIUSPS-T3-77 1 1.245.387 ANNUAL COSTS (continued) YR 1999 I .558.624 YR 2000 2,lO2.515 YR 2001 2.752.584 YR 2002 2,499.118 YR 2003 2.497.66! DECLARATION I, Daniel Stirewalt, declare under penalty of perjury that the foregoing are true and correct, to the best of my knowledge, Dated: I! / lo (78‘ information, and belief. answers CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing participants of record in this proceeding in accordance upon all with section 12 of the Rules of Practice. David H. Rubin 475 L’Enfant Plaza West, S.W. Washington, D.C. 20260-I 137 November 10. 1998 document BEFORE THE POSTAL RATE COMMISSION WASHINGTON, D.C. 20268-0001 ;‘~‘rFf;,‘; I. _‘T., ,,,.1, :/3r 13 J 2.; , ;j ‘33 _,, .;, 1 i’ ,, :~ ~. Docket No. MC98-1 MAILING ONLINE SERVICE .’ , NOTICE OF UNITED STATES POSTAL SERVICE OF FILING OF LIBRARY REFERENCE USPS-LR-20 The United States Postal Service hereby gives notice that it is filing today the following library reference: USPS-LR-20/MC98-1 Electronic Spreadsheet Provided by Witness Stirewalt in Response to OCAIUSPS-T3-77. Copies are also on file with the Postal Service library Respectfully submitted, UNITED STATES POSTAL SERVICE By its attorneys: Daniel J. Foucheaux, Jr. Chief Counsel, Ratemaking q&,&-l q, (2JJl;, David H. Rubin CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing document upon all participants of record in this proceeding in accordance with section 12 of the Rules of Practice. 475 L’Enfant Plaza West, SW. Washington, DC. 20260-1137 (202) 268-2986; Fax -5402 November 10, 1998
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