UNITED STATES OF AMERICA
Before The
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
Postal Rate and Fee Changes,
2001
Docket No. R2001-1
)
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES
TO UNITED STATES POSTAL SERVICE
WITNESS: SUSAN W. MAYO (OCA/USPS-T35-8-11)
October 19,200l
Pursuant
Commission,
requests
to Rules 25 through
28 of the Rules of Practice’ of the Postal Rate
the Office of the Consumer
for production
OCA/USPS-1-21
of documents.
dated September
Advocate
Instructions
28,2001,
Respectfully
hereby submits interrogatories
included with OCA interrogatories
are hereby incorporated
submitted,
SHELLEY S. DREIFUSS
Acting Director
Office of the Consumer Advocate
FREDERICK
Attorney
1333 H Street, N.W.
Washington, D.C. 20268-0001
(202) 789-6830; Fax (202) 789-6819
and
E. DOOLEY
by reference.
Docket
2
No. R2001-1
OCAAJSPS-T35-8.
Your response
The following
refers to your response
to OCAIUSPST355.
states,
[Clircumstances
within the control of the Postal Service, such as
scheduling of transportation to and from the airport, as well as scheduling
of delivery personnel to perform on-time delivery, would not be considered
to be beyond the control of the Postal Service.
However, one could easily infer that scheduling
and the scheduling
“breakdown
of delivery
in the transportation
the public that a “postmaster
generalized
transportation
interpretation
personnel
network.”
of transportation
could
be considered
an example
of a
Please explain how the USPS can assure
or his/her designee”
of your
to and from the airport
proposed
will not deny a claim based upon a
DMCS
language
“breakdown
in the
network”?
OCANSPS-T35-9.
Your response
to OCANSPS-T35-7
indicates
that the Postal
Service will update the terms and conditions
of the Express Mail refunds appearing
the reverse
Please
information
number
side of each postage
provide
on the back of the Express Mail postage label.
of Express
Mail postage
Provide the full calculation
labels.
label.
the cost of updating
on
the
Provide an estimate of the
labels printed in FY 2000, FY 2001 and FY 2002.
for both the cost data and the estimate
Please provide specific cites to all source documents
of the number of
and provide copies if one
has not been previously filed in this docket,
OCAIUSPS-T3510.
For Express Mail, please provide available
recent year for which data are available
data from the most
that show, by ounce, the volume of Express
Docket
3
No. R2001-1
Mail for each type of mailing envelope
preparing
your answer,
please
or container
provide
supplied by the Postal Service.
the information
in a format
similar
In
to that
provided by USPS witness Scherer in his response to DFCIUSPS-T30-1.
OCANSPS-T35-11.
In reducing
the level of insurance
automatically
included
Express Mail from $500 to $100, please: (a) identify and explain the indemnity
deducted
from Express Mail, and (b) explain the consideration
Mail rate proposals
with regard to the decreased
the level of insurance
source
documents
included
at no extra cost.
in
costs
you gave to the Express
value of service due to a reduction
Please provide
in
specific cites to all
and provide copies if one has not been previously filed in this docket.
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
October 19,200l
in accordance
document
upon all
with Rule 12 of the rules of