BEFORE THE

POSTAL RATE COMMISSION

WASHINGTON, DC 20268-0001

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

OFFICE OF THE CONSUMER ADVOCATE

INTERROGATORIES TO UNITED STATES POSTAL SERVICE

WITNESS JOHN F. LANDWEHR

(OCA/USPS-T3-1-3)

(July 10, 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-T3-1. In your testimony at 2, you indicate that Villa Rica
presently has no caller service customers. Your testimony at 3 indicates
that the Villa Rica facility is a fairly typical post office.

a\. For each of the Post Office box sizes at the Villa Rica post office,
please indicate the number of boxes held by resident businesses,
nonresident businesses, nonprofit resident organizations, nonprofit
nonresident organizations, resident nonbusinesses and nonresident
nonbusinesses.

b\. You state in your testimony that there are currently no caller
service customers at Villa Rica. For the most recent fiscal year for
which information is available, please indicate the number of post
offices that have caller service customers, the number of caller service
customers per post office, and the average annual volume of mail
delivered to a caller service customer.

c\. What action would be taken by the Villa Rica Post Office if a
nonbusiness resident requested a post office box and there were no
unused post office boxes available in the size requested by that
customer?

d\. What action would be taken by the Villa Rica Post Office if a
nonbusiness nonresident requested a post office box and there were no
unused post office boxes?

e\. What action would be taken by the Villa Rica Post Office if a
business resident requested a post office box and there were no unused
post office boxes?

f\. What action would be taken by the Villa Rica Post Office if a
business nonresident requested a post office box and there were no
unused post office boxes?

OCA/USPS-T3-2. In your testimony at 4, you indicate that the Middleburg,
VA, Post Office has a waiting list of 15 to 20 prospective customers.

a\. Please specifically identify, how many of the Middleburg, VA, post
office box holders are: resident nonbusinesses, nonresident
nonbusinesses, resident businesses, nonresident businesses, resident
nonprofit organizations, and nonresident nonprofit organizations.

b\. Of the 15 to 20 wait listed prospective post office box customers,
how many are: resident nonbusinesses, nonresident nonbusinesses,
resident businesses, nonresident businesses, resident nonprofit
organizations, and nonresident nonprofit organizations?

c\. Please describe the process used to determine who on the waiting
list will be offered the next available post office box?

d\. If a post office box becomes available to rent, is there any
preference given to offering the box to a resident versus a nonresident?

e\. If a post office box becomes available to rent, is there any
preference given to offering the box to a resident business versus a
resident nonbusiness?

f\. You indicated that the Middleburg, VA, Post Office has a waiting
list for post office boxes. Assume that a current
nonresident-post-office-box holder's fee is up for renewal. Which
methodology does the Postal Service follow: offer the box to the first
resident on the waiting list, or allow the current box holder to renew
their post office box service without reviewing resident status?

g\. Does the Postal Service currently offer post office box service on a
first-come first-serve basis?

OCA/USPS-T3-3. In your testimony at 7 and 10, you suggest that one of
the problems with non-resident customers is that all communications are
long-distance.

a\. Does the Postal Service call collect, or otherwise charge,
non-resident box holders?

b\. If the Postal Service does not have a policy of calling collect why
does it not have this policy?

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, DC 20268-0001

July 10, 1996