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FER 13 I1 20 All $02 POSTAL RATE COMMISSION Pc,5R;,, I~,,,.: ., N OFFICC of 71:: F>;!,;;;::Lxy Official Transcript of Proceedings Before the RECEIVED FER 13 I1 20 All $02 POSTAL RATE COMMISSION pc,5r;,, i~,,,.: ., n OFFICC OF 71:: f>;!,;;;::Lxy In the Matter of: Postal Rate and Fee Changes Docket No. R2001-1 VOLUME 1 l-C Designation of Responses of Postal Service Witnesses Smith through Xie filed In Response to P.O. Ruling R2001-1/23 DATE: Febpuapy 8, 2002 PLACE: Washington, DC PAGES: 4475 through 4833 HERITAGE REPORTING CORPORATION Official Reporters 1220 L Street, NW, Suite 600 Washington, DC 20005-4018 (202)628-4888 [email protected] I 4475 BEFORE THE POSTAL RATE COMMISSION WASHINGTON, DC 20268-0001 Postal Rate and Fee Changes Docket No. R2001-1 DESIGNATION OF WRITTEN CROSS-EXAMINATION Party lnterroaatories United States Postal Service Marc A. Smith (USPS-T-15) Postal Rate Commission POlR No. 6, Question 9 POlR No. 7, Question 6 POlR No. 7, Question 6 (Further Response) Don M. Spatola (USPS-T-20) Office of the Consumer Advocate POlR No. 5, Question 8 Postal Rate Commission POlR No. 4, Question 3 POlR No. 5, Question 8 United Parcel Service POlR No. 4, Question 3 William M. Takis (USPS-T-19) United Parcel Service UPSIUSPS-TIS-1.4 Altaf H. Taufique (USPS-T-34) National Newspaper Association NNAJUSPS-T34-1-3 Postal Rate Commission POlR No. 4, Question 12 POlR No. 5, Question 1, 2, 3 4476 Partv lnterroaatories William P. Tayman (USPS-T-6) Direct Marketing Association, Inc. DFC/USPS-T6-2 DMAIUSPS-T6-1-2, 4-5, 7-8, 11-12, 15-17, 19-23, 25-35, 44-47, 59, 62-63 MPAIU S PS-T6-4 NAA/USPS-T6-3-4, 6 OCNUSPS-T6-3-7, 10-11, 16, 18, 30, 32, 34, 36- 37, 38c-d, 40, 42, 51 VPIUSPS-T6-2-3, 9, 14 Newspaper Association of America DMAIUSPS-TG-I5a, 19, 23, 28-29, 33 NMUSPS-T6-1-6 OCNUSPS-T6-1, 7, 23-24, 38, 40, 46, 51-54, 56 VPIUSPS-T6-5, 8 Office of the Consumer Advocate DMAIUSPS-T6-1-12, 14-26, 34-43, 47-48 OCAIUSPS-T6-1-57 Postal Rate Commission POlR No. 6, Question 7 POlR No. 7, Questions 9, 10 George S. Tolley (USPS-T-7) Postal Rate Commission POlR No. 7, Questions 7, 8 Eliane Van-Ty-Smith (USPS-T-13) AOL Time Warner AOL-TW/USPS-T13-1c-e, 2, 4b, e, g, 5-8 Magazine Publishers of America MPAIUSPS-TI3-1 Postal Rate Commission POIR No. 6, Question 6(b-c) United Parcel Service AOL-TW/USPS-T13-4b, e, g, 5, 8 MPAIUSPS-T13-1 4417 pa@ lnterroaatories Jennifer Xie (USPS-T-2) Parcel Shippers Association PSAIUSPS-T2-1-3 Postal Rate Commission UPSIUSPS-T25-27 redirected to T2 POlR No. 2, Question 3 Respectfully submitted, P Le- h-1 diA&L+ Steven W. Williams Secretary 4478 INTERROGATORY RESPONSES DESIGNATED AS WRITTEN CROSS-EXAMINATION interrogatory Desianatina Parties United States Postal Service Marc A. Smith (USPS-T-15) POlR No. 6, Question 9 PRC POlR No. 7, Question 6 PRC POlR No. 7, Question 6 (Further Response) PRC Don h4. Spatola (USPS-T-20) POlR No. 4, Question 3 PRC, UPS POlR No. 5. Question 8 OCA, PRC William M. Takis (USPS-T-19) UPSIUSPS-TI9-1 UPS UPS/USPS-TI 9-4 UPS Altaf H. Taufique (USPS-T-34) NNNUSPS-T34-1 NNA NNNUSPS-T34-2 NNA NNNUSPS-T34-3 NNA POlR No. 4, Question 12 PRC POlR No. 5, Question 1, 2, 3 PRC William P. Tayman (USPS-T-6) DFCIUSPS-T6-2 DMA DMNUSPS-T6-I DMA, OCA DMNUSPS-T6-2 DMA, OCA DMNUSPS-T6-3 OCA DMAIUSPS-T6-4 DMA, OCA DMNUSPS-T6-5 DMA, OCA DMNUSPS-T6-6 OCA DMNUSPS-T6-7 DMA, OCA DMNUSPS-TG-8 DMA, OCA DMNUSPS-T6-9 OCA DMNUSPS-T6-I0 OCA 4479 lnterroaatory Designating Parties DMNUSPS-T6-11 DMA, OCA DMNUSPS-T6-12 DMA, OCA DMNUSPS-T6-14 OCA DMNUSPS-T6-15 DMA, OCA DMNUSPS-T6-I5a NAA DMNUSPS-76-16 DMA, OCA DMNUSPS-T6-I7 DMA, OCA DMNUSPS-T6-I 8 OCA DMNUSPS-T6-I9 DMA, NAA. OCA DMNUSPS-T6-20 DMA, OCA DMNUSPS-T6-21 DMA, OCA DMNUSPS-T6-22 DMA, OCA DMNUSPS-T6-23 DMA, NAA, OCA DMNUSPS-T6-24 OCA DMNUSPS-T6-25 DMA,OCA DMNUSPS-T6-26 DMA, OCA DMNUSPS-T6-27 DMA DMNUSPS-T6-28 DMA, NAA DMNUSPS-T6-29 DMA, NAA DMNUSPS-T6-30 DMA DMNUSPS-T6-3 1 DMA DMNUSPS-T6-32 DMA DMNUSPS-T6-33 DMA, NAA DMNUSPS-T6-34 DMA, OCA DMNUSPS-T6-35 DMA. OCA DMNUSPS-T6-36 OCA DMNUSPS-T6-37 OCA DMNUSPS-T6-38 OCA DMNUSPS-T6-39 OCA DMNUSPS-T6-40 OCA DMNUSPS-T6-4 1 OCA DMNUSPS-T6-42 OCA DMNUSPS-T6-43 OCA DMNUSPS-T6-44 DMA DMNUSPS-T6-45 DMA DMNUSPS-T6-46 DMA DMAlUSPST6-47 DMA. OCA 4480 lnterroaatory Desianatina Parties DMNUSPS-T6-48 OCA DMNUSPS-T6-59 DMA DMNUSPS-T6-62 DMA DMNUSPS-TG-63 DMA MPNU S PS-T6-4 DMA NMUSPS-T6-1 NAA NAAIUSPS-T6-2 NAA NAAIUSPS-T6-3 DMA, NAA NAAIUSPS-T6-4 DMA, NAA NAA/USPS-T6-5 NAA NAAIUSPS-T6-6 DMA, NAA OCNUSPS-T6-1 NAA, OCA OCNUSPS-TG-2 OCA OCNUSPS-T6-3 DMA, OCA OCNUSPS-T6-4 DMA, OCA OCNUSPS-T6-5 DMA, OCA OCNUSPS-T6-6 DMA, OCA OCNUSPS-T6-7 DMA. NAA, OCA OCNUSPS-T6-8 OCA OCNUSPS-T6-9 OCA OCNUSPS-T6-I0 DMA, OCA OCNUSPS-T6-11 DMA, OCA OCNUSPS-T6-12 OCA OCNUSPS-T6-13 OCA OCNUSPS-T6-14 OCA OCNUSPS-T6-15 OCA OCNUSPS-T6-16 DMA, OCA OCNUSPS-T6-17 OCA OCNUSPS-T6-18 DMA, OCA OCNUSPS-T6-I9 OCA OCNUSPS-T6-20 OCA OCNUSPS-T6-21 OCA OCNUSPS-T6-22 OCA OCNUSPS-T6-23 NAA, OCA OCNUSPS-T6-24 NAA, OCA OCNUSPS-T6-25 OCA OCNUSPS-T6-26 OCA 4481 Interroaatory Desianatina Parties OCNUSPS-T6-27 OCA OCNUSPS-T6-28 OCA OCNUSPS-T6-29 OCA OCNUSPS-T6-30 DMA, OCA OCNUSPS-T6-31 OCA OCNUSPS-T6-32 DMA, OCA OCNUSPS-T6-33 OCA OCNUSPS-T6-34 DMA, OCA OCNUSPS-T6-35 OCA OCNUSPS-T6-36 DMA, OCA OCNUSPS-T6-37 DMA, OCA OCNUSPS-T6-38 NAA, OCA OCNUSPS-T6-38c DMA OCNUSPS-T6-38d DMA OCNUSPS-T6-39 OCA OCNUSPS-T6-40 DMA, NAA, OCA OCNUSPS-T6-41 OCA OCNUSPS-T6-42 DMA, OCA OCAIUSPS-T6-43 OCA OCNUSPS-T6-44 OCA OCNUSPS-T6-45 OCA OCNUS PS-T6-46 NAA, OCA OCNUSPS-T6-47 OCA OCNUSPS-T6-48 OCA OCNUSPS-T6-49 OCA OCNUSPS-T6-50 OCA OCNUSPS-T6-51 DMA, NAA,OCA OCNUSPS-T6-52 NAA. OCA OCNUSPS-T6-53 NAA,OCA OCNUSPS-TG-54 NAA, OCA OCNUSPS-T6-55 OCA OCNUSPS-T6-56 NAA,OCA OCNUS PS-T6-57 OCA VPIUS PS-TG-2 DMA VPIUSPS-T6-3 DMA VPIUSPS-T6-5 NAA VPIUSPS-T6-8 NAA 4482 Interrogatory Desianatina Parties VPNSPS-T6-9 DMA VPIUSPS-T6-14 DMA POlR No. 6, Question 7 PRC POlR No. 7, Questions 9, 10 PRC George S. Tolley (USPS-T-7) POlR No. 7, Questions 7, 8 PRC Eliane Van-Ty-Smith (USPS-T-13) AOL-TWIUSPS-TI 3-1 c AOL-TW AOL-TWIUSPS-TI 3-1d AOL-TW AOL-TWIUSPS-TI 3-1 e AOL-TW AOL-TWIUSPS-TI 3-2 AOL-TW AOL-TWIUSPS-TI 3-4b AOL-TW, UPS AOL-TWIUSPS-TI 3-4e AOL-TW, UPS AOL-TWIUSPS-TI 3-49 AOL-TW, UPS AOL-TWIUSPS-TI 3-5 AOL-TW, UPS AOL-TWIUSPS-TI3-6 AOL-TW AOL-TWIUSPS-TI 3-7 AOL-TW AOL-TWIUSPS-TI 3-8 AOL-TW, UPS MPAIUSPS-TI3-1 MPA, UPS POlR No. 6, Question 6(b-c) PRC Jennifer Xie (USPS-T-2) PSNUSPS-TZ1 PSA PSAJUSPS-T2-2 PSA PSA/USPS-T2-3 PSA UPSIUSPS-T25-27 redirected to T2 PRC POlR No. 2, Question 3 PRC United States Postal Service Marc A. Smith (USPS-T-15) 4484 RESPONSE OF UNITED STATES POSTAL SERVICE WITNESS SMITH TO PRESIDING OFFICERS INFORMATION REQUEST NO. 6, QUESTION NO. 9 9. The piggyback and related factors for the Base Year and Test Year in LR-J46 and LR-J-52, respectively, are developed using SAS programs. While the final output generated by these SAS programs is provided in the aforementioned library references, it is not possible to track various CRAlRollfoward type cost components and the relevant distribution keys. The cost components, referred to as 'COMP' in the SAS program, are not the same as those used in the CRA/Rollfoward. Please provide a spreadsheet containing LR-J-46 and LR-J-52 components and distribution keys by cost function and mail subclass that are used to develop the piggyback and related factors for the Base Year and the Test Year. RESPONSE: Spreadsheets containing the LR-J-46 and LR-J-52 components and distribution keys by cost function and subclass are provided in USPS LR-J-202. There is one Excel workbook for the base year and one for the test year. Each cost function is provided on a separate sheet within these workbooks. For each of these components, the component number for the CFWRollforward is provided as well as the corresponding "COMP" component number from the SAS programs. In addition, to help link the CWRollfotward components to the programmer assigned "COMP" numbers we have provided two Tables in USPS LR-J-202 (in poir6pb.xls). Table 1 is the general piggyback matrix from page 298 in USPS-LR-J-52. This summarizes the calculation of the piggyback factors by cost function, indicating the CWRollfoward components used in the calculation of piggyback factors.
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