BEFORE THE

POSTAL RATE COMMISSION

WASHINGTON, D.C. 20268-0001

Special Services Fees and Classifications) Docket No. MC96-3

OFFICE OF THE CONSUMER ADVOCATE

INTERROGATORIES TO UNITED STATES POSTAL SERVICE

WITNESS PAUL M. LION

(OCA/USPS-T4-27-37)

(August 2, 1996)

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 1-4 to the United States Postal
Service dated June 19, 1996, are hereby incorporated by reference.

Respectfully submitted,

GAIL WILLETTE

Director

Office of the Consumer Advocate

DAVID RUDERMAN

Attorney

OCA/USPS-T4-27. Refer to your response to OCA/USPS-T4-15(d).

a\. Please explain why the calculation of Delivery Group E attributable
costs is impossible. Please identify any data necessary to make the
calculations.

b\. What evidence to the contrary do you have that the attributable cost
of Delivery Group E is not 1.6 percent of total post office box
attributable costs for the test year?

c\. Assume the attributable cost of Delivery Group E is 1.6 percent of
total post office box attributable costs. Please explain the rationale
for not treating these costs as institutional costs.

OCA/USPS-T4-28. Refer to LR-SSR-104 in this proceeding, and USPS
LR-F-180, which presents updated caller service costs for Docket No.
R90-1.

a\. Please list each item incorporated in the calculation of caller
service costs in LR-SSR-104 that is based on studies, material or
analyses conducted in FY 1979 or earlier.

b\. Please provide an estimate of the time and cost to update the
studies, materials or analyses referred to in "a" above.

OCA/USPS-T4-29. Refer to LR-SSR-104 in this proceeding, and USPS
LR-F-180, which presents updated caller service costs for Docket No.
R90-1.

a\. Please confirm that the average time per separation of 8.1851
minutes used to determine the cost of window service-accounting
functions for caller service in LR-SSR-104 was based on data and
computed using the same methodology as LR-F-180. If you do not confirm,
please explain.

b\. Please explain whether the average time per separation of 8.19
minutes used to determine the cost of window service-accounting
functions for caller service in LR-F-180 is based on studies, materials
or analyses conducted in FY 1979 or earlier? *See* Docket No. R90-1,
USPS LR-F-180, Update of Cost Analysis for Caller Service, February 1990
at 11.

c\. Please identify any data used to calculate the average time per
separation in LR-SSR-104 that have been updated since 1979.

d\. For any data used in the calculation of the average time per
separation in LR-SSR-104 that have not been updated since the 1979,
please identify the data and explain why they were not updated for this
proceeding.

OCA/USPS-T4-30. Refer to LR-SSR-104, Exhibit II, concerning the average
time per separation.

a\. What efforts were taken to verify that the average time per
separation determined in LR-SSR-104 is currently 8.1851 minutes? Please
explain any such efforts and provide any documentation.

b\. If no efforts were taken, please explain your basis for believing
that the average of 8.1851 minutes per separation remains accurate.

OCA/USPS-T4-31. Refer to LR-SSR-104 in this proceeding, and USPS
LR-F-180, which presents updated caller service costs for Docket No.
R90-1.

a\. Other than the hourly labor rate of \$23.939 and the number of large
and small firms, please confirm that the determination of window and
platform delivery costs for large and small firms in LR-SSR-104 was
based on data and computed using the same methodology as LR-F-180. If
you do not confirm, please explain.

b\. Please explain whether the calculations used to derive the total
annual window/platform delivery costs for large and small firms in
LR-F-180 are based on studies, materials or analyses conducted in FY
1979 or earlier? *See* Docket No. R90-1, USPS LR-F-180, Update of Cost
Analysis for Caller Service, February 1990 at 12-13.

c\. Please identify any data used to calculate the total annual
window/platform delivery costs for large and small firms in LR-SSR-104
that have been updated since 1979.

d\. For any data used in the calculation of total annual window/platform
delivery costs for large and small firms in LR-SSR-104 that have not
been updated since the 1979, please identify that data and explain why
they were not updated for this proceeding.

OCA/USPS-T4-32. Refer to LR-SSR-104, page 1, concerning the number of
separations per caller.

a\. What efforts were taken to verify that the number of separations per
caller is currently 2.32? Please explain any such efforts and provide
any documentation.

b\. If no efforts were taken, please explain why the number of
separations per caller was not reevaluated for this proceeding.

c\. If no efforts were taken, please explain your basis for believing
that the 2.32 separations per caller remains accurate.

OCA/USPS-T4-33. Refer to LR-SSR-104, page 6, concerning the
determination of storage costs for caller service.

a\. What efforts were taken to verify that the number of square feet
allocated per firm is currently 4.1 square feet? Please explain any such
efforts and provide any documentation.

b\. If no efforts were taken, please explain why the number of square
feet allocated per firm was not reevaluated for this proceeding.

c\. If no efforts were taken, please explain your basis for believing
that the 4.1 square feet allocated per firm remains accurate.

OCA/USPS-T4-34. Refer to LR-SSR-104, Exhibit I, concerning the
calculation of attributable costs for caller service.

a\. Please confirm that the figure of 100,770 represents the number of
entities that pay a caller service fee. If you do not confirm, please
explain what it does represent and why it is used in the calculation of
caller service costs.

b\. In determining caller service attributable costs, please explain why
the annual cost per caller of \$667.08 is divided by 2.32 to reach an
annual cost of \$287.54 per call number or separation. Please explain
why the \$287.54 amount rather than the \$667.08 amount used to
calculate the attributable cost of caller service.

OCA/USPS-T4-35. Refer to your response to Presiding Officer's
Information Request No. 1, question 8. Please provide the average number
of post office boxes installed in contract offices administered by
non-city delivery offices.

OCA/USPS-T4-36. Refer to LR-SSR-119, at page 5. Please provide the
average rental cost per square foot for Delivery Group III.

OCA/USPS-T4-37. Refer to your responses to OCA/USPS-T4-10-11 and
LR-SSR-119. Please confirm that the sheet entitled "CRA" in LR-SSR-119
was used in the calculation of post office box attributable costs. If
you do not confirm, please explain.

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 3.B(3) of the special rules of practice.

DAVID RUDERMAN

Attorney

Washington, D.C. 20268-0001

August 2, 1996