![](media/image1.png){width="1.1368055555555556in"
height="1.4722222222222223in"}**TWO MEN AND A TRUCK**®

**Each franchise independently owned and operated**

3160 Hillsborough Road (919) 309-9582

# Durham, NC 27705 Fax: (919) 382-0794

[www.twomen.com](http://www.twomen.com/)

April 11, 2008

Docket Management Facility

U.S. Department of Transportation, Room W12-140

1200 New Jersey Avenue, SE.

Washington, DC 20590-0001

**RE:** Federal Register Notice of Proposed Rulemaking Pertaining to the
Transportation of Household Goods Docket No FMCSA-2008-0019; RIN
2126-ABO1

To Whom It May Concern,

I am writing in regards to the proposed rulemaking pertaining to the
movement of household goods in interstate commerce. While I understand
and support Government regulation to insure consumer protection in this
industry; further reporting on a quarterly or annual basis will do
nothing to improve safety or assurance within the industry. Many of the
troubles of this nature originate with the illegal or rogue companies
servicing Customers.

Detailed reporting, such as proposed, will prove burdensome and costly
for small, locally owned and operated moving companies like Oliver &
Finley, LLC d/b/a TWO MEN AND A TRUCK of Durham, NC. With annual
revenues at approximately \$2 million dollars, and approximately 4,000
total moves completed in 2007, we must consider the rising expenses of
operating a small business in this industry. The added expense of
reporting of this nature will be difficult to offset without a visible
affect on our Customers. In addition to the hourly rate of clerical
employees, assuming small businesses employ individuals of this nature,
it is important to consider potential lost revenues associated with the
diversion of duties. A staff member will spend numerous hours compiling
the requested documents on a monthly, quarterly, and annual basis. An
estimated cost to small business of \$123 per quarter is a
misrepresentation of the actual affect the proposal will have on the
small business level.

Regulations on both the Federal and State level are in effect to
accomplish better monitoring of household goods transportation
companies. On June 11, 2003, FMCSA published an interim final rule (68
FR 35064) that required household goods motor carriers to have an
arbitration program for individual shippers and to provide prospective
shippers with a description of the household goods motor carrier\'s
customer complaint and inquiry handling procedure. This rule is in
addition to North Carolina state requirements for similar reporting to
those proposed and complaint processes, of which are available to the
general public upon request. It is also important to consider that
Consumer Protection agencies such as the Better Business Bureau and
Angie's List are readily available to Consumers. With the growing
interest and use of the internet, consumer blogs, review pages and
rating systems available, Consumers are able to fully research and
investigate companies prior to selecting a household goods mover.

Committed transportation companies, such as my own, understand the
importance of providing exceptional service and claims handling for
customers. Only this kind of service encourages repeat business and/or
referrals which are essential to the success of our organization. It is
my opinion that both the Federal Government and the State Government
should allocate time more effectively to better inform the general
consumer. The committed companies which have followed regulations in
providing information, documenting, and quality of service do not appear
to be the focus of this rule proposed. The lesser companies, which have
little to no consideration for authority and consumer protection, have
not previously, nor will they continue, to adhere to regulations in
regards to this proposal, general reporting, licensing, etc.

I respectably request that the Federal Motor Carrier Safety
Administration consider the following before making a determination on
the Proposed Rulemaking Pertaining to the Transportation of Household
Goods Docket No FMCSA-2008-0019; RIN 2126-ABO1:

> 1\) Costs involved in complying with the proposal will reduce the
> limited profit margin of independently owned and operated moving
> companies, and could cause companies to forgo potential revenues in
> the diversion of operations.
>
> 2\) State and Federal regulations currently exist aimed at achieving
> similar goals in safety and consumer protection. Numerous documents,
> such as the Order For Service, Bill of Lading, Rights and
> Responsibility Booklet, Addendum to the Bill of Lading (Itemizing the
> Consumers Valuation Options), and the Notice of Arbitration are
> required and distributed by companies to consumers. This regulation as
> proposed may be a duplication of State regulations currently in
> effect.
>
> 3\) With documentation as listed above, in addition to alternative
> avenues made available to consumers for investigation (i.e. the BBB,
> Angie's List, Yahoo Reviews, Blogs, etc) Consumers must hold some form
> of accountability in researching and selecting the relocation company
> that is right for them.
>
> 4\) All costs associated with implementing, monitoring, evaluating and
> publicizing such reporting as proposed should be calculated. It
> appears that the evaluation and regulation of submitted reports would
> be burdensome and costly on the Federal Motor Carrier Safety
> Administration and its affiliates. Regular audits would be a necessity
> to insure the accuracy of information reported. A support staff may be
> considered to field Consumer and Carrier requests for information.
>
> 5\) More focus should be directed at non-compliant transportation
> companies that fail to meet the standards, documenting, distributing
> requirements intended for safety and the protection of Consumers.
> Further formalities for compliant companies will not prove effective
> in accomplishing the goal of decreased consumer complaints in the
> industry.
>
> 6\) Because the FMCSA would require companies to "self-report," the
> accuracy of information provided would not suffice in assisting the
> Agency in identifying companies that may be out of compliance with
> consumer protection regulations. A more informative Consumer is the
> solution.

I hope that each point listed above is considered in making a final
determination on the Proposed Rulemaking Pertaining to the
Transportation of Household Goods Docket No FMCSA-2008-0019; RIN
2126-ABO1. As an independently owned and operated moving company
Franchisee I support and welcome government regulation for the
protection of consumers in the household goods transportation industry.
However, I believe that this proposed rule would be burdensome and
costly for businesses, such as my own, who struggle to remain profitable
and Customer conscious in a highly competitive and regulated industry. I
appreciate your consideration and time to further investigate the affect
this proposal will have on small business and the Customer's in which
they service.

Signed,

Brooke Wilson

Brooke Wilson

Oliver & Finley, LLC

d/b/a TWO MEN AND A TRUCK of Durham, NC