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‘RECEIVED
BEFORE THE
POSTAL RATE COMMISSION
WASHINGTON, D.C.
20268-000
Special
Services
Fees
uL 8
I[ j. AM '96
?
POSTAL RATE COHHISSI~N
OFFICE OFTHE SECRETARY
and Classifications)
Docket
No.
~-7
i
MC96-3
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES TO UNITED STATES POSTAL SERVICE
WITNESS TIMOTHY D. ELLARD
(OCA/USPS-T6-7-12)
(July
8, 1996)
Pursuant
the
Postal
hereby
Rate
submits
documents.
the
to
United
incorporated
sections
Commission,
25 and 26 of
the
interrogatories
Instructions
States
Postal
Office
the
of
Rules
the
and requests
included
with
Service
dated
of
Practice
Consumer
for
production
19,
1996,
by reference.
Respectfully
#522
dW
GAIL WILLETTE
Director
Office
of the
Advocate
OCA Interrogatories
June
submitted,
Consumer
DAVID RUDERMAN
Attorney
Advocate
of
of
l-4
are
hereby
to
Docket
NO. MC96-3
OCA/USPS-T6-7.
a.
Please
2
Please
confirm
POBOX.DAT of
tabulations
times
the
b.
the
are
in
If
If
Please
explain
POBOX.DAT of
weights
100 times
Tables
2-7
do not
on file
too
large
are
approximately
confirm,
do confirm,
SSR-111.
supplied
or
that
please
on POBOX.DAT should
you
of
times
32988
as shown
Please
POBOX.DAT is
as large
in
Please
confirm
sum of
as the
Table
refer
the
100
explain
be used
please
that
described
explain
USPS-T-4.
please
provide
a citation
explain
base
source
witness
the
of
Lion's
large
all
Table
in
for
how
to
tabulate
the
reasons
of
four
approximately
1 weighted
page
these
If
this
data.
to
the
where
testimony
discrepancy
53 of
base
of
(149,9301)
PO
confirm,
If
do confirm,
you
these
or
was the
do not
figures
library
between
base
Table
SSR-111.
figures
you
of
1 This is the sum of the weighted
weighted
base for group 2 as shown in
first
testimony.
2 at
respondents
the
99762,
Group
your
source
the
in
total
the
provide
presented
weights
about
2 of
to
please
weighted
file
the
you
why the
three
Please
the
disparity.
Box Study
/---
SSR-111
data.
OCA/USPS-T6-8.
b.
either
provided
observations
a.
that
small.
weights
for
to
provided
too
survey
refer
references.
the
in
are
total
your
for group 1 and
2 of USPS-T-6.
the
Docket
No.
MC96-3
testimony
and
installed
(14,290,298)
3 of
"(Do
same ZIP
Suppose
you
Code
reside
/
as the
town
at
the
that
ZIP
Please
would
post
office
bjoxes
by witness
"If
used
the
Lion
in
Table
of
obtain
ZIP
This
for
in
the
a~nd they
person
does
20016),
SW, Washington
only
la
service?"
20016
(Friendship,
the
business)
box
Code is
DC.
Questicmn
SSR-111.
place
residence
live
nclt
but
rent
instead
DC 20026.
personal
use.
ZIP
is
Code
not
If
box was obtained.
the
you
same
do not
explain.
that
both
was obtained
are
please
explain
what
this
fee
the
residence
Washington,
and the
DC.
If
town
you
where
do not
explain.
the
correct
response
to
question
la
respondent.
Please
the
you
Plaza,
Code where
confirm
be for
17 of
primary
location
that
OCA/USPS-T6-10.
3 asks,
your
where
is
please
box
page
NW, Washington
box
as the
Please
to
L'Enfant
confirm
confirm,
,,--..
at
Please
the
C.
Is
closest
this
confirm,
b.
of
as reported
residence
Ave,
a PO box
Suppose
number
refer
a respondent's
a PO box
a.
total
Please
on New Mexico
rents
the
USPS-T-4.
OCA/USPS-T6-9.
asks
3
were
refer
to
to
page
be changed
to
18 of
Question
SSR-:Lll.
$(MID-PRICE)
for
6
Docket
No.
would
months,
or
a.
MC96-3
would
post
try
to
office
it
as something
find
an alternative?"
that
the
box
fees
that
classification
in
MC96-3
changes
are
be avoided
cannot
not
proposed
restricted
to
for
a 6
period.
Were
not
accept
confirm
month
b.
you
you
Please
4
respondents
revert
informed
to
current
that
prices
any box
after
rent
increases
would
6 months
elapsed?
Please
explain.
C.
Would
to
you
this
anticipate
question
increases
the
to
question
Suppose
the
e.
Please
designed
tested
rates
revert
to
least
at
current
would
Did
any
the
6 month
period?
restrict
the
example,
suppose
a 6 week period.
rates
would
6 months.
not
be
How could
as these
to
questionnaire,
did
be temporary
Please
and not
subtle
effect
you
understand
6 months)
that
and then
your
understanding
increased
again
that
for
at
explain.
inquire
If
(for
Or was it
be raised
respondents
respondents
For
to
such
from
explain.
rates?
6 months?
that
not
time?
increases
changes
the
were
did
of
least
wording
responses?
rates
period
stated
for
reaction
question
the
question
a-
When you
the
a 6 month
questionnaire
box
if
limited
messed
d.
a different
so,
about
what
what
would
responses
happen
were
they
after
given.
Docket
f.
No.
MC96-3
5
You state
in
your
overreact
to
price
Was this
increases?
price
and the
indicate
study
of
Please
explain.
Please
refer
potential
the
at
post
box
to
office
renters
to
7,
lines
page
or
so,
how could
the
Statement
pages
24-30
box
tend
minimize
If
to
questionnaire
that
respondents
USPS-T-6,
to
OCA/USPS-T6-11.
pages
increases.
designed
accomplished?
2-3
that
questionnaire
overreaction
pages
testimony
rate
currently
reduce
of
of
8-9
this
Work
be
at
SSR-111.
research
These
included
on waiting
lists
a
for
boxes.
a.
Please
confirm
waiting
lists
explain
why there
b.
the
alternatives
,I--.
are
were
collected
from
respondents
study.
If
you
do not
confirm,
figures
in
the
column
marked
printout
of
sample
that
respondents
references
Are
this
the
confirm
testimony.
C.
data
disposition
on
please
"Waiting
pages
42-49
SSR-111.
Please
list
in
in
Completes"
of
that
were
If
to
data
you
and tabulations
not
included
in
do not
confirm,
please
the
tabulations.
respondents
on the
to
post
from
office
waiting
lists
boxes
when
SSR-111
the
or
waiting
in
provide
more
faced
your
page
likely
with
to
box
seek
rent
Docket
NO. MC96-3
increases?
your
6
Please
Questions
a.
any
tabulations
used
to
sup:port
response.
OCA/LJSPS-T6-12.
resident
provide
la
and
lb
Please
refer
appear
to
and nonresident
Please
provide
testimony
box
to
attempt
to
holders
tabulations
separately
page
for
17 of
SSR-111.
differentiate
between
under
the
tested
rates.
and graphs
for
Tables
3-8
resident
and nonresident
of
your
box
holders.
b.
Do your
the
C.
Does
resident
your
study
box
compared
to
support
show differences
in
and nonresident
same for
and
,--.
data
indicate
holders
those
with
box
that
renting
renting
survey
data
sensitivity
between
holders?
the
the
for
price
nonresident
box
business
results.
for
rate
personal
use?
Please
is
the
use
explain
Docket
No.
MC96-3
7
CERTIFICATE
I hereby
document
upon
accordance
certify
all
with
that
I have
participants
section
OF SERVICE
3.B(3)
this
date
of
record
of
the
in
served
this
special
the
foregoing
proceeding
rules
of
practice.
DAVID RLJDERMAN
Attorney
Washington,
D.C.
July 8, 1996
20268-0001
,_-.
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.__--
in
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