UNITED STATES OF AMERICA
Before The
POSTAL RATE COMMlSSlON
WASHINGTON, D.C. 202680001
Postal Rate and Fee Changes,
2001
POSTAL
i?,h,~t,
;o#MISS!ON
OFF,CEOFTHE SECRETARY
Docket No. R2001-1
)
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES
TO UNITED STATES POSTAL SERVICE
WITNESS LINDA A. KINGSLEY
(OCAAJSPS-T39-13-14)
November 28.2001
Pursuant
Commission,
requests
to Rules 25 through
28 of the Rules of Practice
the Office of the Consumer
for production
OCA/USPS-1-21
of documents.
dated September
Advocate
Instructions
hereby submits interrogatories
and
included with OCA interrogatories
28, 2001, are hereby incorporated
/cLAr&
SHELLEY S. DREIFUSS
Acting 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
of the Postal Rate
by reference.
-2-
Docket No. RZOOI-1
OCNUSPS-T39-13.
a.
Please refer to the response to OCANSPS-145.
Refer to the response to part a., where it states that “First-Class
involve the use of more stackers.”
stackers” for automation
Please explain how the “use of more
compatible,
barcoded
First-Class
pieces weighing one ounce as compared to automation
Standard
productivity
b.
Mail letter-shaped
Mail letter-shaped
compatible,
Mail letter-shaped
processed
on different sort plans” (emphasis
assume First-Class and Standard
Mail are processed
and Standard
added).
Please
on the same sort plans.
Holding all other factors constant, please confirm that automation
compatible,
barcoded First-Class
Mail and Standard Mail letter-shaped
pieces weighing one ounce would have the same throughput
productivity
and
when processed on the Delivery Bar Code Sorter (DBCS),
Mail Processing
Bar Code Sorter (MPBCS),
Code Sorter (CSBCS).
ii.
and
pieces.
Refer to the response to part a., where it states that “First-Class
i.
barcoded
pieces weighing one ounce affects throughput
for First-Class and Standard
Mail are sometimes
sort plans likely
and Carrier Sequence
Bar
If you do not confirm, please explain.
Holding all other factors constant, please confirm that automation
compatible,
barcoded
First-Class
Mail and Standard
Mail letter-shaped
pieces that weigh two and three ounces would have the same throughput
and productivity
when processed
on the DBCS, MPBCS, and CSBCS.
If
you do not confirm, please explain.
C.
Refer to the response to part a., where it states that “First-Class
Mail are sometimes processed
on different sort plans” (emphasis
and Standard
added).
Please
-3
Docket No. R2001-1
assume First-Class
and Standard Mail are processed on the same sort plans.
Holding all other factors constant, please confirm that automation
barcoded
First-Class
Mail and Standard Mail letter-shaped
thickness
would have the same throughput
the DBCS, MPBCS, and CSBCS.
d.
pieces of the same
and productivity when processed
assume First-Class
and Standard
on different sort plans” (emphasis
and Standard
Mail are processed
First-Class
Mail and Standard
length would have the same throughput
DBCS, MPBCS, and CSBCS.
e.
added).
Please
on the same sort plans.
Holding all other factors constant, please confirm that automation
barcoded
on
If you do not confirm, please explain.
Refer to the response to part a., where it states that “First-Class
Mail are sometimes processed
compatible,
Mail letter-shaped
and productivity
compatible,
pieces of the same
when processed
on the
If you do not confirm, please explain.
Refer to the response to part b., where it states “These differences
would likely
impact productivity.”
i.
Please define the term “productivity’
ii.
Please provide a numeric example showing the calculation
If there are alternative
alternative
III.
for productivity,
of productivity.
please show these
calculations.
Please identify the calculation
predominately,
iv.
calculations
as used in the response.
of productivity
from subpart ii. used, or used
by the Postal Service.
Does the calculation
of productivity
differ based upon the type of
automated
mail processing
equipment?
productivity
for each type of automated
If yes, show the calculation
mail processing
equipment
of
-4-
Docket No. R2001-1
f.
Refer to the response to part h., where reference is made to “mail pieces that are
rejected on the first pass.” To what extent are automation
First-Class
Mail and Standard
Mail letter-shaped
compatible,
pieces weighing one ounce
“rejected on the first pass” on the DBCS, MPBCS, and CSBCS?
the frequency,
or an estimate of the frequency,
barcoded
Please provide
with which ihis occurs for DBCS,
MPBCS, and CSBCS processing.
9.
Refer to the response to part h., where reference is made to “mail pieces that are
rejected on the first pass.” To what extent are First-Class
compatible,
barcoded letter-shaped
automation
pieces weighing one ounce “rejected on the
first pass” as compared to automation
compatible,
shaped pieces weighing one ounce?
Please provide the frequency,
estimate of the frequency,
barcoded Standard
Mail letteror an
with which this occurs for DBCS, MPBCS, and
CSBCS p.rocessing.
h.
Refer to the response to part h., where reference is made to “mail pieces that are
rejected on the first pass.” To the extent there are different reject rates on the
first pass for automation
compatible,
weighing one ounce vs. automation
barcoded
First-Class
compatible,
letter-shaped
barcoded Standard
pieces
Mail letter-
shaped pieces weighing one ounce, would the different reject rates produce a
small or large impact on the throughput
and productivity
pieces on the DBCS, MPBCS, and CSBCS?
of any studies, reports, other documents,
explanation.
of such letter-shaped
Please explain and provide copies
or communications
that support the
-5-
Docket No. R2001-1
OCANSPS-T39-14.
a.
Please refer to the response to OCAAJSPS-168.
Refer to the response to part a., which references
states that “First-Class
OCANSPS-145(a)
where it
sort plans likely involve the use of more stackers,”
explain how the “use of more stackers” for automation
First-Class
Mail flat-shaped
automation
compatible,
barcoded
pieces weighing two ounces as compared to
barcoded Standard
ounces affects throughput
compatible,
Please
and productivity
Mail flat-shaped
pieces weighing two
for First-Class and Standard Mail flat-
shaped pieces.
b.
Refer to the response to part a., which references
states that “First-Class
sort plans” (emphasis
processed
i.
and Standard
added).
OCANSPS-145(a)
Mail are sometimes processed
where it
on different
Please assume First-Class and Standard
Mail are
on the same sort plans.
Holding all other factors constant, please confirm that automation
compatible,
barcoded
First-Class
Mail and Standard
Mail flat-shaped
pieces weighing two ounces would have the same throughput
productivity
when processed
on the Advanced
and
Flat Sorting Machine
(AFSM) 100, the Flat Sorting Machine (FSM) 881, and the Flat Sorting
Machine (FSM) 1000. If you do not confirm, please explain.
ii.
Holding all other factors constant, please confirm that automation
compatible,
barcoded
First-Class
Mail and Standard
Mail flat-shaped
pieces that weigh three and four ounces would have the same throughput
and productivity
when processed
on the AFSM 100, FSM 881, and FSM
1000. If you do not confirm, please explain.
-6-
Docket No. R2001-1
C.
Refer to the response to part a., which references
states that “First-Class
sort plans” (emphasis
processed
and Standard
added).
Mail are sometimes processed
where it
on different
Please assume First-Class and Standard
on the same sort plans.
confirm that automation
OCANSPS-145(a)
compatible,
Mail are
Holding all other factors constant, please
barcoded First-Class
Mail and Standard
flat-shaped
pieces of the same thickness would have the same throughput
productivity
when processed
Mail
and
on the AFSM 100, FSM 881, and FSM 1000. If you
do not confirm, please explain.
d.
Refer to the response to part a., which references
states that “First-Class
sort plans” (emphasis
processed
and Standard
added).
Mail are sometimes processed
where it
on different
Please assume First-Class and Standard Mail are
on the same sort plans.
confirm that automation
OCALJSPS-145(a)
compatible,
Holding all other factors constant, please
barcoded
First-Class
Mail and Standard
flat-shaped
pieces of the same length would have the same throughput
productivity
when processed
Mail
and
on the AFSM 100, FSM 881, and FSM 1000. If you
do not confirm, please explain.
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
November 28,200l
in accordance
document
upon all
with Rule 12 of the rules of