IIECEIVED
UNITED STATES OF AMERICA
Before the
POSTAL RATE COMMISSION
Postal Rate and Fee Changes,
2000
JUN15 2 17PM'00
Docket No. R2000-1
1
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES
TO MAGAZINE PUBLISHERS OF AMERICA,
WITNESS: RITA D. COHEN (OCA/MPA-Tl-1-5)
June 15,200O
Pursuant
Commission,
requests
to sections
25 and 26 of the Rules of Practice
the Office of the Consumer
for production
OCA/USPS-1-14
of documents.
Advocate
Instructions
dated January
submitted,
Director
Office of the Consumer Advocate
KENNETH
Attorney
1333 H Street, N.W.
Washington, D.C. 20268-0001
(202) 789-6830; Fax (202) 789-6819
and
included with OCA interrogatories
by reference.
Respectfully
of the Postal Rate
hereby submits interrogatories
to the United States Postal Service,
hereby incorporated
ET AL
E. RICHARDSON
24, 2000,
are
Docket No. R2000-1
OCA/MPA-T-1-1.
-2-
Please refer to page 21 of your testimony,
You state that the testimony
(4
presented
Please indicate whether
lines 21 through
22.
by USPS witness Bozzo is “state-of-the-art.”
you believe that Dr. Bozzo’s testimony
is long run or
short run in its economic modeling analysis.
(b)
Please state whether
you believe the economic
modeling
effort should be long
run or short run.
(4
Please state your understanding
of the Commission’s
findings
on the issue of
whether the economic modeling effort should be long run or short run.
OCA/MPA-T-1-2.
(4
Please refer to page 22 of your testimony,
Do you believe
theoretically
that witness
correct,
has included
has used the correct estimating
(b)
Bozzo has provided
all necessary
lines 2 through 5.
an economic
variables
model that is
in the analysis,
and
methodology?
Has Dr. Bozzo complied with the Commission’s
findings in Docket No. R97-1 on
the subject of methodology?
(4
If the Commission
should find that Dr. Bozzo’s
methodology
contains
errors,
should the study be adopted?
(4
If your answer to (c), above, is “yes”, please explain why you would advocate
adopting an incorrect study.
Cd
If your answer to (d), above, is that adoption
though erroneous,
represents
improvement
of Dr. Bozzo’s methodology,
even
over the current state of knowledge,
please indicate and quantify the level of improvement.
Docket No. R2000-1
-3-
OCA/MPA-T-1-3.
Please refer to page 24 of your testimony,
the associated
Table 4 on page 25, wherein
activities for which volume variabilites
mail processing
(a)
analogous
activities
gathered
comparable
data for comparing
use,
characteristics?
Please
location,
have been
have not been computed,
have you
the sites at which the two types of
network
position,
and
of the activities,
other
relevant
If so, please furnish the data.
Please provide information
information,
variabilities
such as the size of the sites, magnitude
geographical
to certain
have been estimated.
at sites for which
to activities for which variabilities
capital
(4
have not been estimated are analogous
computed
activities are performed,
(b)
you assert that certain mail processing
activities for which volume variabilities
In comparing
lines 19 through 20, and
on site visits during which you developed
the above
including the activity observed, date, location, and all data collected.
indicate
how the information
collected
in (b), above, was analyzed
to
arrive at your conclusion.
OCANSPS-T-1-4.
Please refer to page 25 of your testimony,
lines 9-l 1, in which you
comment on witness Degen’s testimony.
(4
In your view, does witness Degen’s testimony
run aspects of mail processing?
(b)
Please provide the basis for your understanding.
consider the long run or the short
-4-
Docket No. R2000-1
OCALJSPS-T-1-5.
Please refer to page 26 of your testimony,
you discuss allied volume variability factors.
variability factor of the sorting operations
lines 10-13, in which
You advocate that the composite volume
should be used as an upper bound for the
volume variability factors of the allied operations.
(4
Do you have a study to substantiate
this statement?
If so, please provide the
study.
W
Do you have studies,
other suggestions
analyses,
concerning
or position papers to substantiate
allied volume variability
furnish the studies, analyses, or position papers.
factors?
any of your
If so, please
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the foregoing
participants
of record in this proceeding
in accordance
upon all
with section 12 of the rules of
practice.
14h-t).
viNNIE D. WALLACE
Washington, D.C. 20268-0001
June 15,200O
document