flECElVED
UNITED STATES OF AMERICA
Before the
POSTAL RATE COMMISSION
WASHINGTON. D.C. 20268-0001
Postal Rate and Fee Changes, 2000
Docket No. R2000-1
1
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES
TO UNITED STATES POSTAL SERVICE
WITNESS: LLOYD RAYMOND (USPS-T13-1-9)
February 17,200O
Pursuant
Commission,
requests
to sections
26 and 27 of the Rules of Practice
the Office of the Consumer
for production
OCA/USPS-1-14
of documents.
Advocate
Instructions
hereby submits interrogatories
dated January
by reference
Respectfully
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
to the United States Postal Service,
hereby incorporated
of the Postal Rate
24, 2000, are
Docket No. RZOOO-1
-2-
OCANSPS-T13-1.
Please
refer to page 7, line 7 through
page 8, line 21 of your
testimony.
(4
Did you
perform
observations
analysis
that would constitute
collection efforts?
(b)
a statistical
Did you perform
routes should
to determine
a statistically
the
accurate
number
sample
of data
in your data
If your answer is yes, please delineate the methodology.
a statistical
be selected
analysis
and/or stratification
for data collection?
to determine
If your answer
which
is yes, please
provide the analysis.
Cc)
Please indicate whether the resulting database
representative
of the population,
could be considered
random and
including all pertinent documentation
on which
you base your conclusions.
(4
Did you perform
eliminate
potential
an analysis
of the statistical
implementation
sites
that
implications
did
not
of the decision
have
Delivery
to
Unit
Computers?
OCANSPS-T13-2.
Why did you perform a two-phase
Did you have a methodology
approach?
that presented
study for the data collection?
the statistical
implications
of such an
If so, please explain.
OCANSPS-T13-3.
It is the OCA’s understanding
that letter carriers do not, in general,
have their activities monitored by data collectors.
(4
Did you perform any analysis of potential differences
between the work actions of
the observed carriers on the days on which they were observed in comparison
their work actions on days during which they were not observed?
to
-3.
Docket No. R2000-1
(b)
Did you have access
researchers?
to any such studies
If so, please
provide
copies
or analyses
performed
of all documents
by other
related to such
studies or analyses.
OCANSPS-T13-4.
Please refer to Section IV of your testimony,
headed “Procedure,”
on page 10 and following.
(4
Did you develop or have a handbook
data collection
procedure
or other documentation
in a standardized
used to convey the
way to all data collection
If so, please discuss and provide the documentation
furnished
personnel?
consistently
to all
personnel.
(b)
Did you have training sessions
data
collection
personnel?
conducted
on a formal, consistent
If so, please
discuss
and provide
basis with all
all relevant
information.
OCANSPS-T13-5.
page
13.
Please refer to Section V, “Quality Assurance”
In this section
you discuss
of your testimony
the review and correction
of potential
on
data
collection errors.
(4
Please provide information
on the total number of data observations
correct, the number of observations
(or other) rules and methodologies
determined
accepted
as
to be incorrect, and the statistical
used to eliminate the observations
considered
as being incorrect,
lb)
Did you perform an analysis of the outliers?
and statistical tests used.
If so, please provide the analysis
-4-
Docket No. R2000-1
OCAAJSPS-T13-6.
Please refer to page 14 of your testimony,
your state, “Of the 844 route-days
lines 7 through
8 where
observed 100 route-days were studied from sites and
routes chosen at random.”
(4
Were the randomly
observed
routes representative
of the population
of routes?
Please explain.
(b)
(4
Do you have a stu’dy to verify whether the aforesaid routes were random?
Were the remaining
744 route-days
a sample that was not random?
Do you
have a study or analysis of the statistical accuracy of the 744 nonrandom
(4
days?
If so, please provide all related documents.
Would
the data you provided
different
proportions
proportions?
(e)
If only the nonrandom
sample
have produced
were
used to generate
and/or
management
the
samples.
line 19, through
page 8,
the selection process for zip codes, cities, and carrier routes.
Please provide copies of the paperwork,
studies,
significantly
sample were used?
Please refer to page 7 of your testimony,
line 4, which discusses
(b)
if only the random
Baron
Please provide separate data sets for the random and nonrandom
OCAIUSPS-T13-7.
(a)
to witness
route-
other
documents,
including memos, letters, emails, faxes,
sent
internally
by
the
Postal
Service
to the various proposed data collection site locations.
Please indicate what criteria, studies, and analyses were used in determining
the
selection of the sites in (a).
(c)
If information
as to the selection process by the various criteria is unavailable
you, please refer this interrogatory
to the Postal Service.
to
Docket No. R2000-1
-5-
OCANSPS-T13-8.
wherein
refer to your testimony
5, lines 3 through
5,
a
managing system.
Were the data collected specifically
for this rate case, or were the data collected
for other, possibly additional, objectives?
(b)
on page
you indicate that the objective of the study was to gather data to establish
workload
(-3
Please
If the data collection
was undertaken
Please explain your answer in detail.
for purposes
other than this rate case,
please identify when the Postal Service decided to use the data for the rate case.
Please provide all related documents,
(4
Were
any
modifications,
(4
changes
made
to
the
data
(scrubs,
adjustments,
estimates,
etc.) in order for the data to be used in this rate case?
Please provide a copy of any other data simultaneously
collected
as part of the
data collection effort if the data have not already been provided.
OCANSPS-T13-9.
data collection
Postal
Service
Please provide the actual or, if unavailable,
efforts, including
personnel
total contractor
involved
in the data
estimated
costs of the
costs as well as person
hours of all
collection
efforts
outlined
in your
testimony.
CERTIFICATE
OF SERVICE
I hereby certify that I have this date served the foregoing document upon all
participants of record in this proceeding in accordance with section 12 of the rules of
practice.
Stephanie Wallace
Washington, D.C. 20268-0001
February 17,200O