1
.
UNITED STATES OF AMERICA
Before The
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
Postal Rate and Fee Changes, 2000
Docket No. R2000-1
)
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES
TO UNITED STATES POSTAL SERVICE
WITNESS: DAVID R. FRONK (OCA/USPS-T33-13-16)
March 21. 2000
Pursuant
Commission,
requests
to sections
25 and 26 of the Rules of Practice
the Office of the Consumer
for production
OCAAJSPS-1-14
of documents.
Advocate
Instructions
of the Postal
Rate
hereby submits interrogatories
and
included with OCA interrogatories
dated January 24, 2000, are hereby incorporated
Respectfully
submitted,
w&b
TED P. GERARDEN
Director
Office of the Consumer Advocate
EMMETT RAND COSTICH
Attorney
1333 H Street, N.W.
Washington, D.C. 20268-0001
(202) 789-6830; Fax (202) 789-6819
by reference.
*
-2-
Docket No. R2000-1
OCANSPS-T33-13.
Please
refer
to interrogatory
and
response
to part (a) thereof.
proposal,
[you] did not use the weight study data [LR-I-911 on this disaggregated
(that is, disaggregated
(4
your
[your] additional ounce rate
a basis
by shape and by weight step).”
Do the disaggregated
significant
You state “that in developing
MMANSPS-T33-7
data (by shape and by weight step) suggest that there are
cost differences
sealed parcels?
by shape for the single piece category of letters and
Please site specific data from the weight study to support your
answer.
lb)
Has the Postal Service considered
First-Class
or studied shape-based
letters and sealed parcels?
rate differentials
for
Please provide copies of all documents
related to this question.
(c)
Did you consider
First-Class
the desirability
letters and sealed parcels?
provide copies of all documents
Cd)
or need for shape-based
Do the weighted
on your response
for
and
related to this question.
(by volume within shape and weight cell) costs from the weight
study match the total volume variable
parcels?
Please elaborate
rate differentials
costs of First-Class
letters and sealed
Please site specific data from the weight study and billing determinants
to support your answer.
(4
Please show the rate schedule that would result from applying a cost coverage of
171.2 percent
to unit attributable
sealed parcels disaggregated
such a rate schedule
schedule.
would
costs of single piece First Class letters and
by shape and by weight step.
generate
If you do not confirm,
the same revenue
Please confirm that
as your proposed
please provide an arithmetic
demonstration
.
.
Docket No. R2000-1
-3-
using the same approach
assuming
to calculating
that billing determinants
total revenue that you have used (i.e.,
all change in the same proportion
when going
from before rates to after rates volumes).
(9
Has the Postal Service observed
any change in the proportions
of First Class
single piece letters and sealed parcels by weight step as a result of the R97-1
change
in the additional
ounce rate?
Please provide the FYI998
and FYI 999
volumes by weight step for First Class single piece letters and sealed parcels.
OCAIUSPS-T33-14.
Please refer to interrogatory
response to part (c) thereof.
single-piece
discount,
that is received
automatibility
is received in bulk,
(b)
meets mail preparation
OCAAJSPS-T33-15.
(b)
standards
that ensure its
standards that ensure its automatibility.
Please refer to the response to interrogatory
forwarding
First-Class
documents
related to this question.
First-Class
MMAAJSPS-I.
or studied a separate charge for returning or
letters and sealed parcels?
Did you consider the desirability
response
(4
and that meets mail preparation
Has the Postal Service considered
forwarding
a special case because it is single piece mail
_” Please estimate the proportion of courtesy reply envelopes that
(4
(4
and your
You state, “While I recognize that the QBRM discount is a
it really represents
in bulk
Stamps.ComAJSPS-T33-4
Please provide copies of all
or need for a separate
letters and sealed parcels?
and provide copies of all documents
charge for returning
Please elaborate
on your
related to this question.
Please provide a complete copy of the UAA Mail Study performed
or
in 1999.
Docket No. R2000-1
OCA/USPS-T33-16.
and footnote
-4.
Please refer to your testimony
16. You stated, “In FY 1996, 12.51 percent of the single-piece
Mail in ODIS (excluding
Response
in Docket No R97-1 at page 42
BRM) was identified
to OCA/USPS-T3-10
1998 single-piece
as Stamped
in Docket No. MC97-1).
and Metered
First-Class
FIM (see
Applying this percentage
volume of 54.5 billion yields 6.8 billion pieces.”
to TY
Please provide an
estimate of courtesy reply mail for the test year of the current proceeding.
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the foregoing
participants
of record in this proceeding
practice.
Washington, D.C. 20268-0001
March 21.2000
in accordance
document
upon ‘all
with section 12 of the rules of