Postal Rate and Fee Changes, 2000 ) Docket No. R2000-1 OFFICE OF THE CONSUMER ADVOCATE INTERROGATORIES TO UNITED STATES POSTAL SERVICE (OCAIUSPS-57-66) February IO,2000 Pursuant Commission, requests to sections 26 and 27 of the Rules of Practice the Office of the Consumer for production OCAIUSPS-1-14 of documents. Advocate Instructions hereby submits interrogatories L4ti submitted, ls!a 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, Docket No. RZOOO-1 OCA/USPS-57. Please refer to the response of the Postal Service to OCALJSPS-3. The interrogatory requests supporting the documentation “supporting -2- documentation filed for BY 1998. documentation for an FY 1999 CRA equivalent The response to states that the Service will file required by” Rule 102. Interrogatory 3 requests information different from that required by Rule 102. (4 Please confirm that the Postal Service will provide a response to interrogatory that includes information different from that required by Rule 102. If you do not confirm, please explain why the Postal Service neither objected responsive lb) answer to interrogatory nor provided a 3. Please confirm that the Postal Service regularly creates workpapers each year’s CRA that contain 3 information underlying different from that required by Rule 102. If you do not confirm please explain. (4 Please provide a// workpapers OCA/USPS-58. Refer to OCA/USPS-8 thereto filed February 7, 2000. mailings The questions and OCAIUSPS-9 and the below relate to widespread responses or saturation by the Postal Service to the general public, not to mailings to employees single-piece (4 underlying the FY 1999 CRA. mailings, targeted business mailings, or other limited-scope mailings. For the volume of GFY 1998 and GFY 1999 Postal Service mailings reported the Government Fiscal Year 1999 Revenue, Pieces, and Weight portion of the mailings are entered under Permit No. G-IO? Service mailings sent under Permit No. G-IO? or in Report, what Are any non-Postal Does the Postal Service use permits other than G-l O? If so, please list the permit numbers and the VOlUmeS mailed under those permits for GFYs 1998 and 1999. Docket No. R2000-1 (b) -3- Provide copies of mail entry documents, comparable to those required by the Postal Service of mailers, for Postal Service mailings entered under Permit No. G-10 in GFY 1998 and GFY 1999. (4 Provide any documents, similar documents, or saturation (4 including audits, reports, budgets, concerning mailpieces Are such mailpieces the cost of preparing studies, reviews, or and/or mailing widespread mailed under Permit No. G-10 (or other permits). mailed under Permit No. G-10 (or other permits) prepared by the Postal Service or by outside contractors? W Are RPW reported attempts volumes for Postal Service Mail estimates? made to reconcile such estimates with accounting If so, are any records? Please explain. 0-l Please provide copies of all documents relating to the proper use of permits such as Permit No. G-10 by Postal Service employees (9) State whether Service any records exist that would identify mailings made by the Postal to the general nationwide or agents. basis. public either on an area or regional basis or on a From any such records, provide a list of such mailings in GFY 1998 and GFY 1999. OCAIUSPS-59. 2000. Refer to OCAIUSPS-10 Please confirm that a reasonable and the response “estimated Standard A Mail Saturation ECR” is $0.05415. described below. is not a reasonable If $0.05415 and explain the derivation of the estimate. thereto filed February TY volume variable The derivation 7, unit cost for of this estimate is estimate, please provide an estimate Docket No. R2000-1 Derivation 4 of $0.05475: cost for all Standard 1, provides Exhibit USPS-32B Mail (A) regular ECR of $2,471,864,000. a TYAR volume for all Standard This results in an average ECR of $0.075297. provides “wpl~comm.xls,” at page 3 TYAR volume USPS-LR-I-166, regular ECR (auto, basic, HD, saturation delivery for all categories the two saturation saturation First-Class forecasts The average categories (letters and non-letters) could not be sent as Standard is $0.05150. of $0.075297 and Accordingly, Turning = $0.05415. Provide the unit cost of producing This mailpiece this was sent as Is there any reason that a similar mailpiece Mail (A) saturation ECR? If so, please explain. Provide an estimate of the cost of producing size stamps, denominated 130 million sheets of as “make-up rate” stamps (i.e., similar in size and format to the “Fruit Berries” stamp sheet, #I564516622, stamps rather than 20). At and delivery of overall regular unit ECR cost. Refer to the attachment. standard non-letters). of of regular ECR is $0.07162; the average unit test year cost for Mail under Permit No. G-10. 12 self-adhesive for each category unit test year cost for mail processing (do not include cost of mailing the mailpiece). OCAIUSPS-61. 12, 2000, spreadsheet provides total test year mail processing to volume variable cost, 71.9151% mailpiece filed January letters; basic, HD, saturation unit cost appears to be 71.9151% OCA/USPS-60. Mail (A) regular was provided by the Postal Service for the volume ECR. page 10 the same spreadsheet Table Mail (A) regular ECR of 32,828,211,000. variable costs of saturation costs for each category. Exhibit USPS-T-6, unit volume variable cost for all Standard No calculation provides a TYAR volume variable but for 12 Docket No. R2000-1 OCAIUSPS-62. distribute -5Provide an estimate new denominations of the time of First-Class required stamps, including to plan, “make-up print, and rate” stamps, for an assumed effective date of new rates of January 2001. OCANSPS-63. addresses Please provide an estimate of the number of domestic delivery the Postal Service expects to have in January 2001. OCANSPS-64. Refer to USPS-LR-I-179, filed February Table I. Total volume appears to differ by approximately that occurring in Standard the volume projections in forecasting (specifically in USUPS-T-6, methodologies OCANSPS-65. 8.5 billion pieces, with most of Mail (A). Please provide an explanation in USPS-LR-I-179 TYAR volume projections 7, 2000, and USPS-T-6, in at page 8 for PFY 2001) from the Table I for GFY 2001. and assumptions of the differences Identify all differences between the two forecasts. Please provide the equivalent of Library References l-130 through l-149 for a Base Year 1999. OCANSPS-66. LR-I-182 Please refer to the two page document entitled “Electronic from the Household that document Bill Payment The last sentence on the second page of questions “are included in the report.” (4 Please provide a copy of the report referred to in this sentence. (b) Please provide Household (c) of USPS- and the Impacts on Mail Volume--Evidence Diary Study 1995-1997.” indicates that recommended at the beginning a list of the questions recommended for inclusion in the been included in the 1998 or 1999 Diary Study. Have any of the recommended versions of the Household questions Diary Study? If not, why not? -__ -- Docket No. R2000-1 CERTIFICATE OF SERVICE I hereby certify that I have this date served the foregoing participants of record in this proceeding in accordance document with section 12 of the rules of practice. ~~(4cdLeup Stephanie Washington, D.C. 20268-0001 February IO,2000 upon all S. Wallace
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