Download OCA-USPS-T42-1-6.pdf

RECEIVED
UNITED STATES OF AMERICA
Before The
POSTAL RATE COMMISSION
WASHINGTON, D.C. 20268-0001
Postal Rate and Fee Changes,
2001
Nov 28
I I 44 n/d ‘01
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Docket No. R2001-1
)
OFFICE OF THE CONSUMER ADVOCATE
INTERROGATORIES
TO UNITED STATES POSTAL SERVICE
WITNESS: ABDULKADIR M. ABDIRAHMAN (OCAIUSPS-T42-1-6)
November 28,200l
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
submitted,
SHELLEY S. DREIFUSS
Acting Director
Office of the Consumer Advocate
1333 H Street, N.W.
Washington, D.C. 20268-0001
(202) 789-6830; Fax (202) 789-6819
and
included with OCA interrogatories
28, 2001, are hereby incorporated
Respectfully
of the Postal Rate
by reference.
2
Docket No. R2001-1
OCANSPS-T42-1.
Your testimony
(a)
Please
The following
refers to USPS-LR-J-69,
confirm
aggregate
33.)
interrogatory
printed-stamped
envelope
is $0.04177.
If you are unable to confirm,
please provide
estimated
to be $0.0058.
confirm,
please
(See USPS-LR-J-69
provide
the
corrected
the corrected
at page
amount
and
is
at page 35.) If you are unable to
amount
Cite the sources for all calculated
and
provide
its complete
values.
Please confirm that the total unit cost of a printed household
number 10 envelope
is the sum of $0.04177
If you are unable to
all calculated
+ $0.0058,
which
Appendix
A, page 3, of your testimony
costs $2.38.
envelope
calculated
Please
Confirm
derivation
and include specific cites for
indicates
10 envelopes
that the average
consisting
that the unit cost of a printed
($2.38 / 50).
cost of a
of 50 envelopes
household
number
10
If you are unable to confirm, please provide
amount and provide its complete derivation.
Cite the sources for all
values.
explain
Distribution
envelope
box lot of number
is $0.0476
the corrected
is $0.04757.
values.
printed household
(e)
(See USPS-LR-J-69
10
Cite the sources for all calculated values.
confirm, please provide the step-by-step
(4
cost of a number
Please confirm that the total unit Test Year selling cost for a printed envelope
derivation.
(c)
at page 35.
pages 2 to 17, in section B.
that the Test Year unit manufacturing
provide its complete derivation.
(b)
refers to USPS-LR-J-69
how the costs
Costs are factored
cost of $0.04177
in USPS-LR-J-69
at page 36 for Test Year
into the costs for the aggregated
and/or the unit selling cost of $0.0058.
unit printed
If the Test
3
Docket No. R2001-1
Year Distribution
envelope
distribution
Costs are not factored into either the aggregated
cost or the unit selling
Please
number
as designated
10 envelopes,
explain
explain
the purpose
of the
into Postal Service costs.
the differences
among
in your Appendix
the printed
household
A, page 3, numbered
2127,
and 2148.
OCANSPS-T42-3.
number
please
costs and where they are incorporated
OCABJSPS-T42-2.
2135,2146,2147
cost,
printed stamp
Please explain the differences
6% envelopes,
as designated
between
in your Appendix
the printed household
A, page 3, numbered
2623,
2643 and 2644.
OCANSPS-T42-4.
Footnotes
The following
interrogatory
refers to USPS-LR-J-69
at page 34.
6, 12 and 13 refer to SFS data.
(a)
Please explain what the abbreviation
SFS data refers to.
(b)
Please provide a copy of the SFS data used in preparing
USPS-LR-J-69
if one
has not been previously provided in this docket.
OCANSPS-T42-5.
“PFSC Customer
The following
Service Cost.”
interrogatory
refers to USPS-LR-J-69
Please explain what the abbreviation
at page 34,
“PFSC” stands
for.
OCAAJSPS-T42-6.
printed
envelope
If one were to perform
($0.0476
delivery confirmation,
envelope
a rough estimate
- see OCAIUSPS-T4Z1
of the unit cost of a
(b)) that incorporates
manual
please confirm that one could add to the unit cost of a printed
the cost of manual delivery confirmation
for a Priority Mail piece ($0.4064
-
4
Docket No. R2001-1
from USPS-T26
from USPS-LR-69
at page 6) less the unit selling cost of a printed envelope
at page 35) yielding a unit cost of
$0.4482
($0.0476
($0.0058
-
+ $0.4064
-
$0.0058).
If you are unable to confirm, please explain what steps would be necessary
to prepare
a rough estimate
of the unit cost of a USPS delivery confirmation
printed
envelope.
CERTIFICATE
I hereby
participants
OF SERVICE
certify that I have this date served the foregoing
of record in this proceeding
in accordance
Washington, D.C. 20268-0001
November 28.2001
upon all
with Rule 12 of the rules of
practice.
Stephanie
document
Wallace