Before The

POSTAL RATE COMMISSION

WASHINGTON, D.C. 20268-0001

Experimental Premium Forwarding Service ) Docket No. MC2005-1

OFFICE OF THE CONSUMER ADVOCATE

INTERROGATORIES TO UNITED STATES POSTAL SERVICE

WITNESS ARNETTA L. COBB (OCA/USPS-T1-1-13)

> November 29, 2004

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.

If data requested are not available in the exact format or level of
detail requested, any data available in (1) a substantially similar
format or level of detail or (2) susceptible to being converted to the
requested format and detail should be provided.

The production of documents requested herein should be made by
photocopies attached to responses of these interrogatories. If
production of copies is infeasible due to the volume of material or
otherwise, provision should be made for inspection of responsive
documents at the Office of the Consumer Advocate, 1333 H Street, N.W.,
Washington, D.C. 20268‑0001, during the hours of 8:00 a.m. to 4:30 p.m.

If a privilege is claimed with respect to any data or documents
requested herein, the party to whom this discovery request is directed
should provide a Privilege Log (*see, e.g.*, Presiding Officer Ruling
C99‑1/9, p. 4, in *Complaint on PostECS*, Docket No. C99‑1).
Specifically, "the party shall make the claim expressly and shall
describe the nature of the documents, communications, or things not
produced or disclosed in a manner that, without revealing information
itself privileged or protected, will enable other parties to assess the
applicability of the privilege or protection." Fed. R. Civ. P. 26(b)(5).

The term "documents" includes, but is not limited to: letters,
telegrams, memoranda, reports, studies, newspaper clippings, speeches,
testimonies, pamphlets, charts, tabulations, and workpapers. The term
"documents" also includes other means by which information is recorded
or transmitted, including printouts, microfilms, cards, discs, tapes and
recordings used in data processing together with any written material
necessary to understand or use such punch cards, discs, tapes or other
recordings.

"All documents" means each document, as defined above, that can be
located, discovered or obtained by reasonable diligent efforts,
including without limitation all documents possessed by: (a) you or your
counsel; or (b) any other person or entity from whom you can obtain such
documents by request or which you have a legal right to bring within
your possession by demand.

"Communications" includes, but is not limited to, any and all
conversations, meetings, discussions and any other occasion for verbal
exchange, whether in person or by telephone, as well as all documents,
including but not limited to letters, memoranda, telegrams, cables, or
electronic mail.

"Relating to" means discussing, describing, reflecting, containing,
analyzing, studying, reporting, commenting on, evidencing, constituting,
setting forth, considering, recommending, concerning, or pertaining to,
in whole or in part. Responses to requests for explanations or the
derivation of numbers should be accompanied by workpapers. The term
"workpapers" shall include all backup material whether prepared
manually, mechanically or electronically, and without consideration to
the type of paper used. Such workpapers should, if necessary, be
prepared as part of the witness\'s responses and should "show what the
numbers were, what numbers were added to other numbers to achieve a
final result." The witness should "prepare sufficient workpapers so that
it is possible for a third party to understand how he took data from a
primary source and developed that data to achieve his final results."
Docket No. R83-1, Tr. 10/2795‑96. Where the arithmetic manipulations
were performed by an electronic digital computer with internally stored
instructions and no English language intermediate printouts were
prepared, the arithmetic steps should be replicated by manual or other
means.

Please especially note that if you are unable to provide any of the
requested documents or information, as to any of the interrogatories,
provide an explanation for each instance in which documents or
information cannot be or have not been provided.

> Respectfully submitted,

SHELLEY S. DREIFUSS

Director

Office of the Consumer Advocate

Kenneth E. Richardson

Attorney

1333 H Street, N.W.

Washington, D.C. 20268-0001

\(202\) 789-6830; Fax (202) 789-6819

OCA/USPS-T1-1. Please refer to your testimony at page 1, line 21. Please
explain in more detail your statement that the Postal Service will
reship the mail for an entire delivery address \"for one or more
individual addressees.\" For instance,

(a) May one person in a household purchase Premium Forwarding Service
    (PFS) while the remaining persons in the household may continue to
    receive service at the permanent address?

(b) Can two or more persons from the same permanent address each
    purchase a separate PFS for different temporary addresses?

(c) Have you considered the error rate caused by permitting individual
    household members to register for individual PFS service and the
    cost of correcting such errors? If so, please explain.

(d) How will pieces erroneously forwarded in a PFS box be handled when
    returned to the Postal Service if (1) they were addressed to another
    person in the household at the permanent address of the PFS customer
    and (2) if the pieces were addressed to another household?

OCA/USPS-T1-2. Please refer to your testimony at page 2 where you
indicate some informal arrangements have guided the definition of PFS.

(a) Have any of the informal arrangements in some offices and districts
    included a fee for the arrangement? If so, please explain.

(b) Please describe the characteristics of the informal arrangements in
    some offices and districts which differed from the definition
    finally proposed here for PFS.

(c) Are these informal arrangements the same arrangements referred to by
    witness Rothschild in her testimony at page 4, line 19, and page 5,
    line 3, as the Snowbird program and Snowbird Temporary Forwarding?

(d) Are these informal arrangements the same arrangements referred to by
    witness Rothschild in her testimony at page 7 as \"Bundled
    Reshipping?\"

OCA/USPS-T1-3. Please explain the \"Snowbird program\" referenced by
witness Rothschild on page 4 of her testimony who says she utilized
lists of Snowbird program users from post offices in approximately 25
postal districts.

OCA/USPS-T1-4. Please refer to your testimony at page 2, lines 21-2,
where you state small Priority Mail pieces will be rerouted unless
delivery will not be delayed by placing them in the PFS shipment.

(a) What will be the standard for the number of days Priority Mail
    pieces may be held for shipment in the PFS box rather then rerouted
    immediately?

(b) Will carriers and clerks be made aware of that standard? If so, how?

OCA/USPS-T1-5. Please refer to your testimony at page 3, line 2, where
you indicate packages and parcels will be shipped PFS if they will fit
into the Priority Mail packaging size that is \"typically used for a
customer\'s PFS shipments....\" Otherwise, they will be forwarded
(reshipped) postage due at the Priority Mail rate.

(a) Will the typical size of Priority Mail packaging vary for each
    customer depending on each customer\'s average mail volume?

(b) If a customer typically has a small volume of mail forwarded by PFS
    and a typical Priority Mail box size is used, and the customer then
    receives a small package via parcel post that will not fit into the
    typically used size of Priority Mail box, is it your testimony that
    the customer will then be required to pay the Priority Mail rate as
    postage due for the parcel which was originally shipped at parcel
    post rates? If so, can customers opt to have such packages forwarded
    at the rate applicable to the original shipping rate rather than the
    Priority Mail rate in order to save the more expensive cost of
    Priority Mail?

(c) If a large catalog does not fit into the PFS box, will it also be
    reshipped as postage due Priority Mail?

(d) Can customers with PFS opt out of having to pay for forwarding
    packages that do not fit into the typical Priority Mail PFS shipment
    box that would otherwise be forwarded at the postage due Priority
    Mail rate? Has this issue been explored in the designing the PFS
    service? If so, please explain the analysis leading to the current
    proposal.

OCA/USPS-T1-6. Please refer to your testimony on page 3 regarding
Standard Operating Procedures. Please describe the amount and type of
planned training of Sales and Service Associates and carriers that will
be required to explain PFS to all customers who inquire about temporary
change of address service.

OCA/USPS-T1-7. Please refer to your testimony on page 3 regarding the
information required to sign-up for PFS. Many times persons moving
temporarily on business assignments or extended vacations do not know
how long they will be there.

(a) What provisions in PFS service do you have for such customers?

(b) What provisions in PFS service do you have for those customers who
    need to alter their plans and shorten or lengthen their stay and
    modify the PFS?

(c) What provisions do you have to refund prepaid PFS money if the
    service is purchased and the customers\' plans are changed slightly
    or, in some cases, changed significantly? For instance, a planned
    long winter vacation may be suddenly interrupted by family
    emergencies early in the vacation.

OCA/USPS-T1-8. Please explain why Wednesday was selected as the day of
the PFS shipment. Will local post offices be permitted to establish a
different shipment day? If so, will the variation depend on the workload
of the office or the number of PFS shipments from any particular office
or carrier route?

OCA/USPS-T1-9. Please explain your testimony at page 6 as to why PFS
would not be available to individuals whose primary address is a
commercial mail receiving agency (CMRA).

OCA/USPS-T1-10. Please provide a copy of the PFS label referred to in
your testimony on page 6, note 3, what will allow for employee
identification and a report on PFS shipments.

OCA/USPS-T1-11. If a PFS customer\'s mail volume exceeds the size of
available Priority Mail boxes, will the postal service send the PFS
shipment in two or more Priority Mail boxes?

OCA/USPS-T1-12. Why do all the pieces in the PFS system have to be
shipped Priority Mail?

OCA/USPS-T1-13. Why must all pieces not fitting into a PFS box be
forwarded at Priority Mail Rates regardless of the class they were
originally entered under?