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: VIRGINIA J. MAYES (OCAAJSPS-T32-11-12)
February 28,200O
Pursuant
Commission,
requests
to sections
25 and 26 of the Rules of Practice
the Office of the Consumer
for production
OCAKISPS-1-14
of documents.
Advocate
Instructions
hereby submits interrogatories
submitted,
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
and
included with OCA interrogatories
dated January 24, 2000, are hereby incorporated
Respectfully
of the Postal Rate
by reference.
-2-
Docket No. R2000-1
Please confirm the following statements.
OCANSPS-TM-II.
statement,
please explain why.
If you cannot confirm a
If you disagree with any definitions,
please provide your
definition.
(a)
The markup for subclass
I is defined as the difference
subclass I and total attributable
cost of subclass 1. A4Uf =
(b)
The difference
The systemwide
total revenue of
costs of subclass I all divided by total attributable
TRi - TAG
TAG
between total revenue and total attributable
defined as the contribution
Cc)
between
to institutional
cost for subclass
I is
costs of subclass i. CL = TRi -TAG
markup is defined as the sum of all contributions
divided by the
CCIi
sum of all attributable
(d)
MU =
The relative portion of institutional
the contribution
contributions.
(e)
costs.
to institutional
costs contributed
costs of subclass
by subclass
I divided
I is defined as
by the sum of all
CIi
POIG = CCr,
The relative portion of attributable
total attributable
POAC; =
STAG
I
TAG
TAC/
costs of subclass
costs attributed to subclass
I is defined as the
I divided by the sum of all attributable
costs.
-3-
Docket No. R2000-1
(9
A markup index for subclass I is defined as the markup for subclass
the systemwide
MU
X = Mu =
markup.
Cli
TAG
7””
C-Ii
Ccl,
CIixCTACj
I
=TAC;x~CJ=
i
;Aci
TAG
I
c
c TACj
(9)
I divided by
POIC!
=-’POACi
Thus, a markup index for subclass I is equal to the relative portion of institutional
costs contributed
by subclass i divided by the relative portion of attributable
costs
attributed to subclass i. X = E.
(h)
By the definition of proportionality,
proportional
a markup index for subclass I is directly
to the relative portion of institutional
X cc POIG , and inversely proportional
costs contributed
by subclass I,
to the relative portion of attributable
costs
1
attributed to subclass /, X 0~~
POACi
0)
Simultaneously
increasing the institutional
share and decreasing
share of costs borne by subclass I will unambiguously
the attributable
cause the markup index
for subclass I to increase.
OCANSPS-T32-12.
OCANSPS-T32-6.
Please refer to the attachment
Please
confirm
that column
column (5). If you do not confirm, please explain.
to your response to interrogatory
(6) divided
by column
(8) equals
-A-
Docket No. R2000-1
CERTIFICATE
I hereby
participants
OF SERVICE
certify that I have this date served the foregoing
of record in this proceeding
practice.
Washington, D.C. 20268-0001
February 28,200O
in accordance
with section
document
upon all
12 of the rules of