UNITED STATES OF AMERICA

Before the

POSTAL REGULATORY COMMISSION

WASHINGTON, DC 20268-0001

Rate and Service Changes To Implement)

Baseline Negotiated Service Agreement ) Docket No. MC2007-5

With Life Line Screening )

OFFICE OF THE CONSUMER ADVOCATE INTERROGATORIES

TO UNITED STATES POSTAL SERVICE

WITNESS MICHELLE K. YORGEY

(OCA/USPS-T1-1-4)

(September 7, 2007)

Pursuant to Rules 25 through 28 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 OCA/LLS-T1-1-11, dated August 27,
2007, are hereby incorporated by reference.

Respectfully submitted,

Kenneth E. Richardson, Acting Director

Office of the Consumer Advocate

Emmett Rand Costich, Attorney

901 New York Avenue, N.W.

Washington, D.C. 20268-0001

\(202\) 789-6833; Fax (202) 789-6891

e-mail: <costicher@prc.gov>

OCA/USPS-T1-1. Please refer to your testimony, Appendix A, page 3, which
presents Life Line Screening's Standard Mail Regular and ECR letter unit
revenue in column (1), entitled "Revenue per piece." Please provide
electronic workpapers showing the development of the "Revenue per piece"
figures for letters shown in column (1). Also, please provide citations
to all figures used.

OCA/USPS-T1-2. Please refer to your testimony, Appendix A, page 3, which
presents the volumes for Life Line Screening's Standard Mail Regular and
ECR letters in column (2), entitled "Volume." Please provide electronic
workpapers showing the development of the "Volume" figures for letters
shown in column (2). Also, please provide citations to all figures used.

OCA/USPS-T1-3. Please refer to your testimony, Appendix A, page 4, which
presents Life Line Screening's Standard Mail Regular and ECR letter unit
costs in the column (1), entitled "TYAR 2008 Total Unit Cost (Dollars)."
Please provide electronic workpapers showing the development of the
"TYAR 2008 Total Unit Cost" figures for Standard Mail Regular and ECR
letters shown in column (1). Also, please provide citations to all
figures used.

OCA/USPS-T1-4. Please refer to your testimony, Appendix A, page 4, which
presents Life Line Screening's Standard Mail Regular and ECR letter unit
costs in column (1), entitled "TYAR 2008 Total Unit Cost (Dollars)."
Also, please refer to Note (1), which references the sources used to
develop the unit costs for Regular letters in column (1).

a\. Please confirm that you relied on PRC-LR-22, Docket No. R2006-1, as
the basis for developing the "TYAR 2008 Total Unit Cost\[s\]" for Life
Line Screening's Standard Mail Regular and ECR letters. If you do not
confirm, please explain.

b\. In Docket No. R2006-1, please confirm that the Commission relied on
PRC-LR-15, which contains the calculation of the Commission\'s
recommended rates for Standard Mail Regular and ECR letters and flats,
as the basis for the Standard Mail Regular and ECR letters rate design,
and that PRC-LR-15 identified total unit costs for Standard Mail Regular
and ECR letters. If you do not confirm, please explain.

c\. Please provide a detailed explanation of why you used PRC-LR-22
rather than PRC-LR-15 as the basis for developing the "TYAR 2008 Total
Unit Cost\[s\]" for Life Line Screening's Standard Mail Regular and ECR
letters. In your explanation, please identify any differences between
PRC-LR-22 and PRC-LR-15, and explain how your use of PRC-LR-22 rather
than PRC-LR-15 affected the development of the "TYAR 2008 Total Unit
Cost\[s\]" for Life Line Screening's Standard Mail Regular and ECR
letters.

##