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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 “O:T,*\;$,.&i!, ,I,“,~: !~~:i “iiZ{Cf:,)i~ii,::. _j:,L&! ,&iv 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