BEFORE THE

POSTAL RATE COMMISSION

WASHINGTON, D.C. 20268-0001

Postal Rate and Fee Changes, 1997 ) Docket No. R97-1

OFFICE OF THE CONSUMER ADVOCATE

INTERROGATORIES TO UNITED STATES POSTAL SERVICE

WITNESS CARL G. DEGEN

(OCA/USPS-T12-1-11)

July 22, 1997

Pursuant to sections 25 and 26 of the Rules of Practice of the Postal
Rate Commission, the Office of the Consumer Advocate hereby submits
interrogatories and requests for production of documents. Instructions
included with OCA interrogatories 1‑7 to the United States Postal
Service dated July 16, 1997, are hereby incorporated by reference.

> Respectfully submitted,

GAIL WILLETTE

Director

Office of the Consumer Advocate

EMMETT RAND COSTICH

Assistant Director

Office of the Consumer Advocate

OCA/USPS-T12-1. Please provide IOCS sampling information disaggregated
by BMC\'s, MODS, and non-MODS offices. In particular, please provide:

a\. The number of BMC\'s, MODS, and non-MODS offices by CAG existing at
the beginning of FY 1996.

b\. The number of employees by craft (or craft cost pool) and CAG at
BMC\'s, MODS, and non-MODS offices for FY 1996. These numbers can be
presented by pay period or as an average of the pay period employee
complements over the year. If provided as an average and there is
significant fluctuation by pay period in the employee complements, then
please provide the high and low complement values also.

c\. The total employee compensation (from the Payroll Data System) by
craft and CAG at BMC\'s, MODS, and non-MODS offices for FY 1996.

d\. A list of CAG A, CAG B, and BMC\'s that were not included in the FY
1996 IOCS office sample. Please designate the CAG and MODS status for
each of these offices.

e\. For each office in part d of this interrogatory, please provide the
number of employees by craft at BMC\'s, MODS, and non-MODS offices for
FY 1996. Please provide numbers comparable to those provided in part b
of this interrogatory.

f\. For each office in part d of this interrogatory, please provide the
total employee compensation (from the Payroll Data System) by craft and
CAG at BMC\'s, MODS, and non-MODS offices for FY 1996.

g\. The number of BMC\'s, MODS, and non-MODS offices by CAG that are in
the FY 1996 IOCS sample.

h\. The effective employee sample size by craft at BMC\'s, MODS, and
non-MODS offices for FY 1996. Please provide numbers comparable to those
provided in part b of this interrogatory.

i\. The total employee compensation (from the Payroll Data System) by
craft and CAG at BMC\'s, MODS, and non-MODS offices for FY 1996 IOCS
sample offices.

OCA-USPS-T12-2. Please refer to footnote 13 of your testimony. This note
states that IOCS does not sample Remote Encoding Centers, but that a
distribution methodology based on sampled RBCS images is under
development.

a\. Please describe the plans and current status for this Remote
Encoding Center distribution methodology.

b\. Please describe any changes in the treatment of Remote Encoding
Center costs between FY 1995 and FY 1996 and between FY 1996 and BY
1996.

OCA/USPS-T12-3. Please refer to Tables 4 and 5 of your testimony.

a\. Please confirm that Table 4 contains the variability for each of the
mail processing cost pools. If you do not confirm, please provide the
cost pool variabilities.

b\. Please confirm that the costs shown in Table 5 incorporate the
variability figures of Table 4. If you do not confirm, please explain
how the Table 4 variabilities are used.

c\. Suppose that there were an error in the second row of Table 4, and
that the variability for the OCR cost pool should be 85 percent instead
of the 78.6 percent listed in your table. Then please confirm that Table
5 should be modified by multiplying all entries in the column labeled
\"MODS ocr\" by the ratio (85/78.6). If you do not confirm, please
explain how Table 5 would need to be updated.

OCA/USPS-T12-4. Please refer to LR-H-146.

a\. Please provide a copy of the SAS logs for programs listed in this
library reference.

b\. Please provide the H-146 SAS programs in electronic form.

OCA/USPS-T12-5. Please refer to LR-H-146, lines 77-280 of program
MODSPOOL.

a\. Please provide a list of valid MOD values and a description of each.

b\. Please confirm that LDCs defined at lines 77-280 correspond to those
listed on pages I-32 to I-38 of H-146. If you do not confirm, please
explain.

c\. Please describe the difference between LDC1 (program MODSPOOL, line
65) and the coded LDC\'s at lines 77-280.

d\. Line 364 of MODSPOOL refers to LDC of data set LDC96M. Is this LDC
equivalent to the LDC codes assigned at lines 77-280 based on the MODS
values? Please explain.

OCA/USPS-T12-6. Please refer to program MODSPOOL of LR-H-146.

a\. Line 331 refers to a data set named \"PAY.LDC96.\" Please describe
the contents, variable names and definitions, and possible values of all
variables in data set PAY.LDC96.

b\. Has PAY.LDC96 been included in a library reference in this docket?
If not, please provide this file in electronic form.

c\. Lines 62-67 of MODSPOOL read a file named OPLDC96.DATA, referenced
by infile MOD96. Please describe the contents, variable names and
definitions, and possible values of all variables for OPLDC96.DATA.

d\. Has OPLDC96.DATA been provided as a library reference in this
docket? If not, please provide this file in electronic form.

OCA/USPS-T12-7. Please confirm that the cost data reporting system for
cost segment 3.1 has been changed for BY 1996 by incorporating
MODS-based data and by redefining variability assumptions for clerk and
mailhandler costs. If you do not confirm, please explain the purpose of
your testimony.

OCA/USPS-T12-8. Please refer to page II-5 of H-146. This refers to the
tally encrypted finance number, F2 on the FY 1996 IOCS data set. If
additional IOCS variables are encrypted or suppressed, then:

a\. Please list all other IOCS variables that are encrypted.

b\. Please list all other IOCS variables that are suppressed.

c\. If any IOCS variables are suppressed, then how are they coded on the
H-23 data file? If suppressed values are simply blanked out, how can
they be distinguished from missing values?

OCA/USPS-T12-9. Please refer to programs MOD1POOL (lines 13-209) and
MODSPOOL (lines 77-280) of H-146. Please confirm that the LDC assignment
in MOD1POOL is identical to the assignment of LDC values in MODSPOOL. If
you do not confirm, please identify the differences and explain why a
different algorithm was used.

OCA/USPS-T-12-10. Please refer to program MOD1POOL, lines 297-413, of
H-146. This section of code begins with the comment \"REMAP TALLIES WITH
NO MODS CODES OR INVALID MODS CODES.\"

a\. Please confirm that this program only processes IOCS data from MODS
offices. If you do not confirm, please explain.

b\. How many MODS IOCS tallies had no MODS codes?

c\. How many MODS IOCS tallies had invalid MODS codes?

d\. How many unique MODS finance numbers were associated with the IOCS
tallies having invalid or missing MODS codes?

e\. Do all the relationships implied at lines 297-413 also hold for
tallies with valid IOCS MODS codes? Please explain.

f\. Please explain how MODS codes could be missing or incorrect for an
IOCS observation at a MODS office, collected using IOCS CODES data entry
devices. Please explain why IOCS CODES software would be programmed to
allow entry of invalid or missing MODS codes at MODS offices.

OCA/USPS-T12-11. Please refer to page II-6 and line 415 of program
MOD1POOL of library reference H-146. Line 415 begins a section of the
program with the comment \"MODS-BASED ENCIRCLEMENT.\"

a\. Please explain what is meant by the term \"MODS-based
encirclement.\"

b\. Please provide all documents or materials prepared by or for any
subdivision of the Postal Service related to \"MODS-based
encirclement.\"

c\. Please describe what is accomplished by the \"MODS-based
encirclement\" portion of MOD1POOL, at lines 415-505.

CERTIFICATE OF SERVICE

I hereby certify that I have this date served the foregoing document
upon all participants of record in this proceeding in accordance with
section 12 of the rules of practice.

EMMETT RAND COSTICH

Attorney

Washington, D.C. 20268-0001

July 22, 1997

CERTIFICATE OF SERVICE

I hereby certify that I have this date served the foregoing document
upon all participants of record in this proceeding in accordance with
section 12 of the rules of practice.

EMMETT RAND COSTICH

Attorney

Washington, D.C. 20268-0001

July 22, 1997