Criticisms of Neels’s Approach Commenters assert that many of regressions produce anomalous or implausible results. Thompson Comments at 9; Amazon Comments at 20-21; PR Comments at 41. For example, Thompson notes that 31 of the 37 regressions (that Neels interprets as revealing hidden variable costs) predict negative fixed costs, which Neels interprets as conceptually plausible.” Thompson Comments at 8 (citing “not Neels Report at 44). Several commenters express their concerns that Neels selectively uses his regression results. Specifically, Thompson asserts that Neels arbitrarily replaces the regressions that produce implausible results with alternative regressions lacking a constant term, the result that these cost components have no fixed costs.” “forcing ‘truly’ Id. Similarly, the Public Representative states that he analyzed cost components that were estimated to have negative intercepts statistically different from zero. PR Comments at 41. The Public Representative examined the attributable costs of these cost components and found that none of these components actually had attributable costs. Id. The Public Representative asserts that is safe to conclude that the “[i]t component[-]level regressions do not produce meaningful component-level results.” Id. After excluding 37 regressions that Neels interpreted as revealing hidden variable costs, Amazon and Thompson state that 17 of the remaining 47 component-level regressions have a negative slope coefficient. Amazon Comments at 109; Thompson Comments at 8-9. Amazon and Thompson note that UPS reported that 8 of these 17 regressions are statistically significant and that 11 of the 17 regressions are “strongly negative.” Amazon Comments at 109; Thompson Comments at 9 (citing Neels Report at 38-39). While Neels discounts these anomalous results as noise,” Amazon “statistical and Thompson assert that the cause of these counterintuitive results appear to be more
Criticisms of Neels’s Approach Commenters assert that many of regressions produce anomalous or implausible results. Thompson Comments at 9; Amazon Comments at 20-21; PR Comments at 41. For example, Thompson notes that 31 of the 37 regressions (that Neels interprets as revealing hidden variable costs) predict negative fixed costs, which Neels interprets as “not conceptually plausible.” Thompson Comments at 8 (citing Neels Report at 44). Several commenters express their concerns that Neels selectively uses his regression results. Specifically, Thompson asserts that Neels arbitrarily replaces the regressions that produce implausible results with alternative regressions lacking a constant term, “forcing the result that these cost components have no ‘truly’ fixed costs.” Id. Similarly, the Public Representative states that he analyzed cost components that were estimated to have negative intercepts statistically different from zero. PR Comments at 41. The Public Representative examined the attributable costs of these cost components and found that none of these components actually had attributable costs. Id. The Public Representative asserts that “[i]t is safe to conclude that the component[-]level regressions do not produce meaningful component-level results.” Id. After excluding 37 regressions that Neels interpreted as revealing hidden variable costs, Amazon and Thompson state that 17 of the remaining 47 component-level regressions have a negative slope coefficient. Amazon Comments at 109; Thompson Comments at 8-9. Amazon and Thompson note that UPS reported that 8 of these 17 regressions are statistically significant and that 11 of the 17 regressions are “strongly negative.” Amazon Comments at 109; Thompson Comments at 9 (citing Neels Report at 38-39). While Neels discounts these anomalous results as “statistical noise,” Amazon and Thompson assert that the cause of these counterintuitive results appear to be more
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