utilities must make reasonable assumptions in order to approximate accurate utility costs. Id. at 8. The Public Representative does not believe that perfection of “the theory” should be enemy of good attribution” and concludes that distribution keys “the are acceptable so long as the cost drivers accurately reflect causation for any given component. Id. at 9-10. The Postal Service disagrees with the Public Representative’s use of distribution keys and maintains that the rationale for distributing volume-variable costs is “very different” from the rationale used to distribute all inframarginal costs. Postal Service Reply Comments at 25. The Postal Service describes the distribution of variable costs as following causal path,” which a meaningful cost “a “produces measurement.” Id. In contrast, it describes the distribution of inframarginal costs as and which an undefined and misleading cost “arbitrary” “non-causal,” “produces measure.” Id. GCA criticizes the Public Representative’s justification of the use of distribution keys to allocate inframarginal costs and argues that variability does “mere not establish the required causal connection” between inframarginal costs and products. GCA Reply Comments at 1-2. GCA further contends that to assign common costs, “one is content to rely on accounting conventions which are not meant to, and cannot, establish causal relationships.” Id. On reply, UPS argues that Proposal One uses the existing identifiers of causation (cost drivers and distribution keys as developed by the Postal Service) to allocate inframarginal costs. UPS Reply Comments at 14-16. UPS claims that attributing average costs using distribution keys in a multi-product enterprise is analogous to attributing average variable cost in a single-product enterprise, and provides a reliable way to attribute cost drivers among multiple products. Id. at 17.
utilities must make reasonable assumptions in order to approximate accurate utility costs. Id. at 8. The Public Representative does not believe that “the perfection of theory” should be “the enemy of good attribution” and concludes that distribution keys are acceptable so long as the cost drivers accurately reflect causation for any given component. Id. at 9-10. The Postal Service disagrees with the Public Representative’s use of distribution keys and maintains that the rationale for distributing volume-variable costs is “very different” from the rationale used to distribute all inframarginal costs. Postal Service Reply Comments at 25. The Postal Service describes the distribution of costs as following “a causal path,” which “produces a meaningful cost measurement.” Id. In contrast, it describes the distribution of inframarginal costs as “arbitrary” and “non-causal,” which “produces an undefined and misleading cost measure.” Id. GCA criticizes the Public Representative’s justification of the use of distribution keys to allocate inframarginal costs and argues that “mere variability does not establish the required causal connection” between inframarginal costs and products. GCA Reply Comments at 1-2. GCA further contends that to assign common costs, “one is content to rely on accounting conventions which are not meant to, and cannot, establish causal relationships.” Id. On reply, UPS argues that Proposal One uses the existing identifiers of causation (cost drivers and distribution keys as developed by the Postal Service) to allocate inframarginal costs. UPS Reply Comments at 14-16. UPS claims that attributing average variable costs using distribution keys in a multi-product enterprise is analogous to attributing average variable cost in a single-product enterprise, and provides a reliable way to attribute cost drivers among multiple products. Id. at 17.
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