Interrogatories from American Postal Workers Union



[The original document is here.]

1-2. The APWU asks for details about all of the facilities being studied for closure and those that are not on the RAOI list: the hours of operation; the facility finance number and corresponding main office finance number, e.g., the finance number assigned to a station and the corresponding finance number for the main post office to which the station reports; the street address for each office; the type (post office, CPU, approved shipper, stamps on consignment, etc.) and hours of operation of each of the “five postal retail and/or alternate access sites” of each facility listed in this Library Reference; and the driving distance and driving time between each facility listed in this Library Reference and its corresponding five “postal retail and/or alternate access sites”; and the revenue and expenses.

(These two questions basically ask to see some information that is readily available on the USPS website (although it may be outdated) concerning addresses, finance numbers, etc.  But some of the other information is not available but was used in the Postal Service analysis of which post offices to study for closure — revenue, expenses, distance to other post offices.)

3. Were all of the “alternate access channels” listed in your testimony, including those that only sell postage stamps, considered as “alternate access sites” when determining if a facility qualified for discontinuance review? If not, identify which types of “alternate access sites” were considered when identifying the postal retail facilities for discontinuance review.

4. Describe the standard types of products and service available in each type of alternative access sites. Where the range of products and services vary with a type, please describe the range of variability.

5. Boldt had testified that: “given changes in many communities, it is likely that these customers already travel outside their local community to purchase other goods and services and conduct other activities of daily living.” Please provide a copy of all studies or other documentation and information you relied upon in coming to this conclusion.

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