------------ ----------- ----------------------------------------------
  Appendix D,              
  Rate Filing              
  Version 2,               
  2/15/08                  

  Page 6       2.7         **DPS did not notify TSPs of accepted rates
  Appendix D               along with the Round 1 rejections. This is one
                           of the things that made rate filing very
                           difficult since we got a printout of all
                           rejected rates and had to figure out what
                           rates were accepted by a process of
                           elimination. For the best clarity and
                           user-friendliness, DPS provide notice of both
                           accepted and rejected rates.**

  Page 6       2.7         Not having a valid CIP/COR should be a
  Appendix D               correctable error at any time rather than
                           resulting in rates rejections. TSP should
                           receive notice that CIP/COR need to be filed
                           by a certain date to have rates accepted.

  Page 8       2.8.d       What does this paragraph mean? Does it use the
  Appendix D               term \"most favorable\" like the GSA schedule
                           does in that it has to be the commensurate
                           with the most favorable rates a TSP would
                           provide in the commercial marketplace? If so,
                           who determines that and based on what
                           criteria?

  Page 9       2.11        How will SDDC ensure timely approval of all
  Appendix D               new entrant applicants in an open season if
                           the open season is announced annually just
                           prior to rate filing? Does not seem that there
                           will be enough time to do this.

  Page 9       2.12        Duality\--DPS should give a technical notice
  Appendix D               that 2 rates are being submitted for the same
                           channel by the TSP's in CFAC with one another
                           prior to actual submission of rates, by
                           rejecting both rates and notifying that only
                           one of the TSP's may refile in the second
                           round, since the filing could very well be an
                           inadvertent mistake. A second round error
                           should result in both rates being rejected
                           again.

  Page 11      2.18        Why won\'t SDDC share historical shipment data
  Appendix D               by channel after the 1st year of the program?
                           This data is very valuable for the TSP to
                           develop its rates for the next rate cycle and
                           would benefit SDDC/DOD greatly.

  Page 11      2.18        On a similar vein, we request that SDDC
  Appendix D               reconsider its rule that accepted rates per
                           channel will not be published. This
                           information should be available under FOIA.

  Page 11      2.18        Why is the TSP\'s \"average\" rate used to
  Appendix D               check rate reasonableness for Special
                           Solicitation? Each rate should be evaluated on
                           its own based on the costs involved in each
                           traffic channel.

  Page 12      2.19        Why won\'t SDDC share historical shipment data
  Appendix D               by channel after the 1st year of the program?
                           This data is very valuable for the TSP to
                           develop its rates for the next rate cycle and
                           would benefit SDDC/DOD greatly.

  Page 12      3.1         Why would alternate TSP\'s on a volume move be
  Appendix D               allowed to withdraw their rates? Is it to
                           force the primary to service all the tonnage
                           at the low rate? What if the primary does not
                           have capacity to service all the business and
                           all the alternates withdraw their rates?

  Page 12      3.1         What is the purpose of the information for
  Appendix D               volume moves noted as \"trailer interchange?\"
                           Is TSP required to show if they will be
                           allowing other TSP\'s to service the tonnage?
                           Why should SDDC care as long as the business
                           is properly handled? Any use of alternate
                           carriers or alternate agents should be the
                           business of the winning TSP with full
                           accountability for their actions.

  Page 12      3.1         If a volume move overlaps a performance score
  Appendix D               rerack, will its BVS score change during the
                           course of the volume move?
  ------------ ----------- ----------------------------------------------

  ----------------- ----------- ----------------------------------------------
  Page 13 Appendix  3.1         Please define exactly how the BVS will be
  D                             calculated for volume moves (what performance
                                score applies and how it is determined)?

  Page 14 Appendix  4.1         This section says that \"{OTO requests} will
  D                             be sent to eligible TSP\'s that have rates on
                                file for that channel or code of service.\"
                                How exactly will this work, e.g., when and how
                                will the request be sent, and how will
                                eligible TSP\'s be determined since, by
                                nature, the OTO channel does not have regular
                                rates on file.

  Page 14 Appendix  4.1         Please define exactly how the BVS will be
  D                             calculated for OTO\'s (what performance score
                                applies and how it is determined)?

  DPS Rate Filing               
  Instructions for              
  TSP\'s 9/9/05,                
  Version 1                     

                                What happens if a TSP is disqualified,
                                suspended or inactivated when they file rates?

  Appendix C, TSP               
  Qualifications,               
  12/4/07                       

  Page 5 Appendix C Intro       3rd to the last paragraph says that the TOS is
                                located in Appendix B of the DTR, but it is
                                actually Part IV, Attachment U-R; same
                                paragraph, the link for the TOS is actually in
                                Section 4.0 of Appendix C; same paragraph
                                traffic distribution will not be in Chapter
                                402 of the DTR, but in the Attachment U
                                section;

  Page 6 Appendix C 2.1.4.b     Trusted Agent\--currently the system allows
                                anyone to designate themselves as a Trusted
                                Agent, which totally defies logic of
                                controlling access to critical TSP
                                qualification information. The Trusted Agent
                                (and/or any alternates) should only be able to
                                be designated by the President or CEO to
                                prevent unauthorized changes to a TSP\'s
                                information in DPS. There shouldn\'t be any
                                yes/no radio button for a user to toggle when
                                setting up their ETA login for DPS access.
                                Only the President or CEO should be able to
                                designate a Trusted Agent by affirmatively
                                entering their name in the President/CEO ETA
                                Registration. See Appendix O ETA instructions
                                page 73, Section 9.1

  Page 8 Appendix C 2.1.8       This section requires a TSP to make updates in
                                DPS due to certain key events; however it has
                                been demonstrated that making changes to a
                                TSP\'s info during or just before a rate
                                filing window can result in the TSP being
                                ineligible to file rates. The deadlines for
                                notification of these changes should be
                                flexible in case they bump into a rate filing
                                window.

  Page 8 Appendix C 2.1.8       SDDC needs to provide the instructions
                                referred to in the \*\*NOTE regarding change
                                of name or SCAC. We reserve the right to make
                                comment on these instructions/rules once they
                                are published.

  Page 10 Appendix  2.1.12      A TSP who is adversely affected by any
  C                             decision by SDDC should have access to either
                                administrative relief or relief through the
                                courts.

  Page 11 Appendix  2.1.13      TSP appeals\--there should not be any hard
  C                             copy requirement. Electronic (email)
                                submission should meet the filing requirements
                                and, in fact, ought to be preferred over hard
                                copy.
  ----------------- ----------- ----------------------------------------------

  ------------ ----------- ----------------------------------------------
  Page 15      2.2.4.b     DPS currently puts people in the key personnel
  Appendix C               status without input from any person at the
                           TSP. This is not right and causes problems
                           regarding who a TSP wishes to declare as their
                           key personnel. This problem needs to be
                           corrected because it is currently a huge
                           housekeeping item in DPS and is totally
                           unnecessary. DPS should never pre-populate key
                           personnel other than the President/CEO

  Page 20      2.0         TSP Application Submission Instructions\--from
  Appendix C               this point forward the numbering is off since
                           there is already a section 2. This section
                           should be 3.0, and each succeeding section
                           re-numbered.

  Page 23      2.0         Page 23 of 34\--Detailed Form
  Appendix C               Instructions\--the rules here should contain a
                           block specified copy of each form and show
                           exactly how each field should be filled out
                           since it turns out that DPS was very
                           meticulous about exactly what was acceptable
                           in each field and what was rejected. For
                           example, in some cases, you had to put \"N/A\"
                           but in other cases it rejected that entry.

  Families                 
  First                    
  Domestic                 
  400NG                    
  Tariff,                  
  Version 2.0,             
  12/7/07                  

  Page 5 400NG Item 1      The introduction and Item 1 in this document
                           says that it consists of 2 parts (1) a printed
                           tariff document that contains governing rules
                           and regulations and (2) an electronic rating
                           engine used to compute the cost of individual
                           shipments. SDDC needs to make the 2nd part
                           available to industry now so that we can be
                           assured that our systems will rate shipments
                           properly. We have no assurance at this point
                           in time that the rates in the SDDC rating
                           engine are identical 100% of the time with the
                           rates provided to us by AMSA on a CD. In fact,
                           since we know that SDDC \"reprogrammed\" the
                           AMSA 400NG tariff into their own system, we
                           are quite concerned that there will be
                           differences. Since an invoice that is rated
                           incorrectly will be placed into audit
                           exception by DPS/PowerTrack, it could
                           needlessly delay our payment from the
                           government. SDDC needs to correct this
                           deficiency now before we start moving
                           shipments in DPS.

  400NG        Various     We note that the cover page of this document
               pages       says it is Version 2.0 issued 12/7/07, but
                           various pages in it say it was issued 4/21/05
                           or 10/28/05. The issue date and Version number
                           should appear as a header or footer on each
                           page of the document to avoid any confusion
                           about when changes are made and when they are
                           effective.

  Page 17      Item 4      Several places in this item misspell the word
  400NG                    \"weighing\" as \"weighting\" (2b, 2c, 2j, 3).

  Page 17      Item 4      #2 in this section is lettered a-h and then it
  400NG                    skips \"I\" and goes directly to \"j\"

  Page 18      Item 4.5    Reweighing of shipments\--Please clarify
  400NG                    whether or not a reweigh charge applies and
                           what would be the determining factor as to
                           whether DOD will approve payment of same.
  ------------ ----------- ----------------------------------------------

  --------------- ----------- ----------------------------------------------
  Page 19 400NG   Item 6      We have never seen any functionality in DPS
                              that allows for consolidation of shipments.
                              How does DPS deal with consolidated shipments
                              for rating, stops, enroute, etc.? Has
                              consolidation functionality been tested in
                              DPS?

  Page 21 400NG   Item 17     The rules here state that the TSP must use the
                              \"DOD-approved facility located nearest the
                              destination city or installation shown in Bock
                              18 of the PPGBL unless otherwise authorized
                              and directed by the PPSO. SIT and related
                              charges are based on the nearest available
                              DOD-approved facility.\" We object to this
                              rule for 2 reasons\--first, TSP control of the
                              shipment and, second, inability of either DPS
                              or the PPSO to keep track of what facilities
                              are \"available\" at any given point in time,
                              especially in the summer in areas where
                              warehouses often are saturated for SIT. As to
                              the first point, the TSP should be able to use
                              its own agent\'s facility, whether it is
                              exactly nearest the destination or not. If it
                              is within 30 miles (50 miles for
                              international) of the destination city or
                              installation, the TSP should be able to use
                              its own agent\'s facility no matter what. If
                              it is further away than 30/50 miles, the TSP
                              should obtain PPSO approval to place the
                              shipment in the more distant location.

  Page 21 400NG   Item 17.3   The TSP rate for what channel applies to
                              origin SIT? The rates filed by TSP's were for
                              business from a state to a region and the SIT
                              charges are associated with that destination
                              region based on the cost to provide storage in
                              that region. The shipment award is made based
                              on your BVS and quartile ranking outbound from
                              that state, but the origin SIT takes place in
                              the origin state, but the rate for SIT for
                              that channel has nothing to do with a TSP's
                              costs in that origin state. Where in the
                              business rules does it state what rate will
                              apply and how that rate application is
                              determined?

  Appendix P,                 
  PowerTrack                  
  Offset                      
  Requirements,               
  9/14/05                     

  PowerTrack                  What steps must a TSP take if it disputes an
  Offset                      offset? Where are the rules governing appeal
                              or objections to an offset in PowerTrack?

  PowerTrack                  What constitutes a "delinquent" claim that
  Offset                      qualifies to be offset in PowerTrack?

                              

  Appendix O, ETA             
  Instructions                
  1/15/08,                    
  Version 3.3.                

  Page 72         9.1.7       We repeat our concern that all TSP users
  Appendix O                  requesting ETA access are allowed to designate
                              for themselves whether or not they are a
                              trusted agent. This is a very dangerous way to
                              handle the trusted agent designation and is
                              already leading to very serious security
                              issues for TSP\'s. An individual should not be
                              able to show themselves as trusted agent; it
                              should be a function that only a President/CEO
                              can designate some as trusted agent or
                              alternate trusted agent.

  Page 69         9.1         The user roles matrix needs to be part of this
  Appendix O                  document and be defined as to what each role
                              has access to in DPS. Additional user roles
                              are also needed, such as general agent as has
                              been used overseas.

  Page 83         10.1.12     There should be another role for claims
  Appendix O                  representative who can access claims for
                              multiple TSP\'s with a single login since
                              there are a number of claims settlement firms
                              under contract with many different TSP\'s for
                              claims management.

  Page 83         10.1.14     Not all local agents have their own DUNS
  Appendix O                  number if they are a subsidiary of a parent
                              company. How should those agents register in
                              ETA?
  --------------- ----------- ----------------------------------------------

  ------------ ----------- ----------------------------------------------
  Appendix U,              
  12/21/07                 

  IV-U-10      C.3.f.      Shipment offering, booking and routing should
                           take into account pickup and delivery spreads.
                           The current rules in this section refer only
                           to pickup spreads.

  IV-U-10      C.3.g.      This section states that the TSP must update
                           DPS with their origin and shipping agents at
                           the time of acknowledgement of shipment. This
                           is not how DPS works and should not be a
                           requirement. The TSP should be able to enter
                           shipping agents, but should not be required to
                           do so, particularly if the TSP does not want
                           its agents to be able to update data in DPS.
                           Also, the agents are often not known yet at
                           the time of shipment acknowledgement.

  IV-U-12      C.3.j.      TSP\'s may also need to submit invoices if
                           there has not been a SIT delivery or residence
                           delivery, such as in the case of an attempted
                           pickup and the shipment never actually moves,
                           or if the shipment is converted to member
                           expense storage or NTS prior to residence
                           delivery.

  IV-U-12      C.3.j.      We continue to be dismayed by the heavy
                           paperwork requirements that still exist for
                           TSP\'s since one of the goals of DPS was to
                           reduce paperwork. We are also considered about
                           the differences each branch of the Service may
                           have for the TSP to turn in origin paperwork.
                           Finally, the current requirement is that
                           origin paperwork must be returned to the PPSO
                           within 7 WORKING days of pickup, not 7
                           CALENDAR days. The rules should reflect
                           current practice on this issue. We think a TSP
                           ought to be able to comply with this
                           regulation by scanned and emailed copies of
                           documents, with originals retained for random
                           sample audit purposes. We are hopeful that the
                           current near 100% audit will no longer happen
                           under DPS or the TSP\'s paperwork requirement
                           has not been reduced one bit, nor has the
                           government\'s.

  IV-U-16      C.3.q.      Members do not have to file \"Quick Claims\"
                           in DPS and this should be reflected in the
                           business rules wherever applicable.

  IV-U-18      D.7         The TSP industry would still very much like to
                           be able to review the business rules related
                           to counseling\--first, so that we understand
                           what the member\'s expectations may be based
                           on what they hear in counseling and, second,
                           so that we can identify any disconnects with
                           how we understand the program is supposed to
                           operate.

  IV-U-19      D.10        SDDC still needs to provide a complete and
                           current User Role Matrix and needs to look at
                           establishing other user roles for better
                           functionality of DPS, such as general agent as
                           has been used overseas, or a claims
                           representative who can access multiple SCAC\'s
                           under one login (like a billing representative
                           can do).

  IV-U-21      E           System requirements should include a 2-way
                           interface between TSP\'s and DPS to eliminate
                           duplicate entry of data and speed exchange of
                           real-time information. This is what it says in
                           this document but that is certainly not what
                           we have with DPS and it is a cost-driver!

  Attachment               
  U.A,                     
  Electronic               
  Bill                     
  Payment,                 
  12/21/07                 

  IV-U.A-3     B.2.e       The TSP should have 7 WORKING days to provide
                           weight tickets, not 7 CALENDAR days as this
                           section reads.
  ------------ ----------- ----------------------------------------------

  -------------- ------------ ----------------------------------------------
  IV-U.A-3       B.2.e        The TSP should not have to enter packing
                              materials into DPS, since the packing charge
                              is now a flat fee based on weight and there is
                              no more carton count or MAXPACK calculation in
                              DPS.

  IV-U.A-3       B.2.e        It is extremely difficult for a TSP to deal
                              with differing paperwork requirements
                              depending on the branch of the Service and
                              this increases the cost to the government if
                              we have to provide all the documents
                              identified in the \"NOTE\" on Air Force
                              Shipments. Also, the DD619, if it remains a
                              requirement to provide hard copy, needs to be
                              modified since there is no more carton count
                              required, nor should the TSP have to write
                              \"NONE\" in each column for packing.

  IV-U.A-5       B.3.i        Some shipments require the ability to submit
                              an invoice before delivery to SIT or
                              residence, such as and attempted pickup where
                              the shipment is subsequently cancelled, or a
                              conversion to member expense storage or NTS.

  IV-U.A-5       B.3.i        Again, the reference to submission of weight
                              tickets should say within 7 WORKING days, not
                              7 calendar days.

  IV-U.A-6       B.3.k        The PPSO should have a clear requirement to
                              provide a response to the approval request so
                              that the driver or work crews are not delayed.
                              Response time should be a maximum of 2 hours,
                              during normal work hours, which should be 8am
                              to 5pm local time, Mon-Fri.

  IV-U.A-7       B.3.p        If DPS provides an incorrect billing rate,
                              then Prompt Pay Interest should apply if it
                              takes longer than 30 days for the supplemental
                              invoice to be paid and it is proven that the
                              TSP\'s original invoiced rate was correct, and
                              DPS was wrong.

  IV-U.A-9       B.4.b.2.c    Note: This section correctly states that the
                              weight tickets must be provided to the PPSO
                              within 7 WORKING days of pickup.

  IV-U.A-10      B.4.b.3.a    The PPSO does not have to print the GBL and
                              provide it to the agent or TSP. The TSP prints
                              its own GBL. If the PPSO prints the PPGBL
                              immediately after booking, it will have the
                              original instead of the TSP.

  IV-U.A-11      B.4.b.4      It seems rather archaic that in the design of
                              DPS there is no functionality to email
                              documents such as the PPGBL, particularly
                              since one of the fundamental purposes of DPS
                              was to reduce paperwork.

  IV-U.A-11      B.4.b.8      Invoice submission should be able to take
                              place upon completion of services on the
                              shipment, not just upon delivery of a
                              shipment. As noted above, some shipments only
                              have an attempted pickup or convert to member
                              expense storage or NTS prior to residence
                              delivery.

  IV-U.A-12 and  Figure U.A.3 The DD619 and 619-1 should be modified NOW to
  13             & U.A.4      match the requirements of Families First/DPS
                              and avoid confusion. For example, no carton
                              counts are necessary to they should be removed
                              from the form. SIT is approved in DPS, so
                              those sections of the form are redundant
                              (Block 13 DD619-1). Block 16 should never be
                              used to record loss or damage and should be
                              stricken from the since there is another form
                              specifically required to list loss/damage. We
                              should not perpetuate an outdated and
                              overly-complicated form when we have DPS in
                              operation.

  IV-U.A-14      B.4.b.8.d    There should not be a requirement to provide
                              the number of boxes on the invoice in
                              DPS/PowerTrack, unless this requirement refers
                              strictly to the number of lift vans on an
                              international shipment. There is no more
                              requirement to count packed boxes in DPS since
                              packing is a flat fee based on weight.

  IV-U.A-15      B.4.b.10.b   Some destination services should be
                              automatically approved in DPS if there was a
                              corresponding origin service approved\--for
                              example, crating at origin should generate an
                              automatic approval of uncrating at
                              destination; 3rd party disassembly of an item
                              should generate an automatic approval of 3rd
                              party reassembly.

  IV-U.A-15      B.4.b.10.c   The PPSO should have a clear requirement to
                              provide a response to the approval request so
                              that the driver or work crews are not delayed.
                              Response time should be a maximum of 2 hours,
                              during normal work hours, which should be 8am
                              to 5pm local time, Mon-Fri

  IV-U.A-15      B.4.b.10.d   The requirement stated here for the PPSO to
                              act on an open item within 3 business days is
                              entirely too long. What is the penalty to the
                              PPSO if they don't act on an open item timely?
                              How does DPS monitor this and what is the
                              relief to the TSP?

  IV-U.A-18      B.4.b.11.l   We don't believe that submission of a negative
                              supplemental invoice has been tested in DPS.

  IV-U.A-19      B.4.b.11.n   Something in this first line does not make
                              sense \"the DPS entered weight must be entered
                              in DPS.\"

  IV-U.A-33      D.3          References to \"fuel service charge\" should
                              say \"fuel surcharge\" since that is the
                              common term for this item and will be
                              confusing if they don\'t match.

  IV-U.A-32-39   D            SDDC should carefully review this whole
                              section as it does not comply with the recent
                              court ruling regarding PPI. If DPS is
                              programmed in accordance with the language in
                              this section, it will result in PPI additional
                              unnecessary costs to the Military Services,
                              who are already complaining about the cost of
                              Families First.

  IV-U.A-35      D.6 Note     Just because the PPSO asks for hard copy
                              documentation, it should not stop the PPI
                              clock. There is no basis in either the PPI law
                              or elsewhere for this position.

  IV-U.A-39      E            Diversion Business Rules\--we question why the
                              rules are in attachment U.A., since they seem
                              more suited as a \"Shipment Management\" issue
                              and should be belong in that section.

  IV-U.A-40      E.2.2.c.1 &  If a shipment is diverted and the TSP does not
                 E.3.2.d.1    have a rate on file from either the origin
                              point to the point of diversion or from the
                              diversion point to the new destination, it is
                              totally unreasonable for the TSP to have to
                              use the \"lowest\" rate available for that
                              channel. DOD should have to negotiate a rate
                              with the TSP for the portion of transportation
                              already completed and DOD can terminate the
                              GBL and give it to another TSP for onward
                              movement. The TSP alone knows its costs and
                              should be required to move a shipment below
                              cost. It should be the TSP\'s discretion only
                              to agree to move a shipment at the lowest
                              available rate or it should be able to file an
                              OTO to cover the movement.

  Attachment U.E              
  Minimum                     
  Performance                 
  Score,                      
  12/21/07                    

  IV-U.E-2       A.6          SDDC\'s current methodology of advising of
                              disqualified or revoked TSP\'s needs to be
                              improved so that one does not have to search
                              thru the list of TSP\'s to see if anyone is
                              added. Newly disqualified or revoked TSP\'s
                              should be posted on the SDDC website, as well
                              as reinstated TSP\'s as the events occur and
                              then should be added (or removed) from the
                              list of disqualified or revoked TSP\'s.

  Attachment U.F              
  Best Value                  
  Score,                      
  12/21/07                    
  -------------- ------------ ----------------------------------------------

+-----------+----------+----------------------------------------------+
| IV-U.F-1  | A. Intro | We find it hard to understand how a TSP      |
|           |          | could file bankruptcy and still be deemed to |
|           |          | meet the qualifications to participate in    |
|           |          | the program (as evidenced by the recent      |
|           |          | bankruptcy of all the TSP\'s in the SIRVA    |
|           |          | group of companies). This seems to fly in    |
|           |          | the face of the information here that SDDC   |
|           |          | wishes to do business with companies who are |
|           |          | \"financially healthy.\"                     |
+-----------+----------+----------------------------------------------+
| IV-U.F-1  | B        | When the claims metrics were developed, the  |
|           |          | Business Process Working Groups (BPWG\'s)    |
|           |          | responsible for them agreed that the claims  |
|           |          | data would not be used for the first year,   |
|           |          | not just so that sufficient data could be    |
|           |          | captured. The most significant reason that   |
|           |          | we agreed not to use the data till sometime  |
|           |          | after the first year was to model what       |
|           |          | happened to TSP\'s BVS when claims metrics   |
|           |          | were added. It was agreed that we could not  |
|           |          | be sure of unintended consequences without   |
|           |          | testing how the BVS\'s stacked up after      |
|           |          | inclusion of claims metrics. Many TSP\'s     |
|           |          | were concerned that there are a number of    |
|           |          | items outside of our control in the claims   |
|           |          | process, for example, the length of time to  |
|           |          | settle a claim if one is to do a proper      |
|           |          | investigation including getting repairs done |
|           |          | or estimates of repairs. The claims metrics, |
|           |          | in effect, \"punish\" a TSP from the 1st day |
|           |          | after filing of a claim. The business rules  |
|           |          | should reflect that the reason for waiting   |
|           |          | till after the first year to incorporate     |
|           |          | claims metrics was to determine the impact   |
|           |          | on the BVS in a model environment before     |
|           |          | including it in a TSP\'s score, which may    |
|           |          | mean that inclusion is sometime after the    |
|           |          | 2nd year.                                    |
+-----------+----------+----------------------------------------------+
| IV-U.F-2  | C.1      | We do not believe in the scientific          |
|           |          | soundness of SDDC\'s method of calculating   |
|           |          | whether or not a TSP is statistically valid  |
|           |          | based on the number of surveys returned      |
|           |          | versus the number of shipments moved.        |
|           |          | Industry has offered various reports by      |
|           |          | statisticians that have demonstrated that    |
|           |          | SDDC\'s approach is not a random survey and  |
|           |          | is not statistically valid. We refer back to |
|           |          | the studies that have been provided to SDDC  |
|           |          | by HHGFAA and Tim Helenthal from National    |
|           |          | Van Lines and incorporate them into our      |
|           |          | comments here by reference.                  |
+-----------+----------+----------------------------------------------+
| IV-U.F-2  | C.1      | During the first ranking period, SDDC had to |
|           |          | add in median scores to a high percentage of |
|           |          | TSP\'s to achieve statistical validity. We   |
|           |          | believe this only dilutes the actual         |
|           |          | performance scores and \"dumbs down\" the    |
|           |          | whole rating system. However, if SDDC        |
|           |          | intends to continue to use this methodology  |
|           |          | to achieve statistical validity, then it     |
|           |          | should incorporate the methodology in this   |
|           |          | section of the Business Rules.               |
+-----------+----------+----------------------------------------------+
| IV-U.F-2  | C.1.b    | The claims process is still very cumbersome  |
|           |          | to use, whether the service member is a 20   |
|           |          | year old Gen Y techie or a 55 year old       |
|           |          | non-techie. Using the claims metrics as      |
|           |          | envisioned here will result in service       |
|           |          | members rating their satisfaction as poor    |
|           |          | just because of the claims module of DPS,    |
|           |          | not necessarily because of anything a TSP    |
|           |          | did or did not do in the claims settlement   |
|           |          | process. It may cause service members to     |
|           |          | transfer their claims to the MCO out of      |
|           |          | sheer frustration with ETA logins and        |
|           |          | passwords and a poorly designed claims       |
|           |          | system.                                      |
+-----------+----------+----------------------------------------------+
| IV-U.F-2  | C.1.a.1  | Achieving statistical validity has been a    |
|           |          | huge hurdle for SDDC. TSP\'s have been       |
|           |          | rightly concerned since the beginning of     |
|           |          | ICSS, that the people who tend to complete   |
|           |          | the survey are at either end of the          |
|           |          | satisfaction spectrum and the vast majority  |
|           |          | in the middle who are essentially satisfied  |
|           |          | don\'t bother to complete the survey. We     |
|           |          | also want to go on record now (again) that   |
|           |          | we totally disagree with the recommended fix |
|           |          | that would require a service member to fill  |
|           |          | out the survey in order to receive           |
|           |          | settlement of their claim further            |
|           |          | exacerbates the problem. This would only     |
|           |          | ensure that all those members who had a      |
|           |          | claim fill out a survey (probably 1 in 5),   |
|           |          | leaving 80% of the members who are           |
|           |          | essentially satisfied out of the measurement |
|           |          | of customer satisfaction. One recommendation |
|           |          | is to give the TSP credit for a satisfied    |
|           |          | customer if a survey has not been completed  |
|           |          | after a certain amount of time post-delivery |
|           |          | (90 days for example). Failure to achieve    |
|           |          | statistical validity waters down a critical  |
|           |          | element and critical reason for the whole    |
|           |          | development of Families First/DPS in the     |
|           |          | first place.                                 |
+-----------+----------+----------------------------------------------+
| IV-U.F-2  | C.1.b    | Giving the claims score 20% of the value of  |
|           |          | the entire BVS is disproportionate. In the   |
|           |          | commercial marketplace, it can be proven     |
|           |          | that customers with claims can be just as    |
|           |          | pleased with the overall service they        |
|           |          | received as a customer who did not have a    |
|           |          | claim. The mere fact that there was a claim  |
|           |          | is not, in and of itself, evidence of poor   |
|           |          | customer service. A second very important    |
|           |          | issue is the concern that some TSP\'s will   |
|           |          | not require members to use DPS to settle     |
|           |          | their claims. Unless SDDC can assure that    |
|           |          | all claims will be settled using DPS, only   |
|           |          | those TSP\'s who are diligent about using    |
|           |          | DPS stand to lose points on the claims       |
|           |          | score, since DPS gives full points to any    |
|           |          | TSP who does not have claims in DPS.         |
+-----------+----------+----------------------------------------------+
| IV-U.F-3  | C.1.b    | A member\'s decision to transfer the claim   |
|           | .1.b.2.a | to the Military Claims Office (MCO) may just |
|           |          | be the result of a confusing claim due to    |
|           |          | many parts of a shipment (NTS, DPM, POV,     |
|           |          | dHHG) and the member being unable to sort    |
|           |          | thru who is responsible for what. The TSP    |
|           |          | should not necessarily be penalized every    |
|           |          | time a claim is transferred to the MCO.      |
+-----------+----------+----------------------------------------------+
| IV-U.F-3  | C.1.b.1  | Measuring the Time to Disposal of a claim    |
|           |          | against whichever TSP has the lowest number  |
|           |          | of days to disposal only shows who is able   |
|           |          | to most swiftly throw money at a claimant    |
|           |          | and does nothing to measure satisfaction     |
|           |          | with the claims process and restoring the    |
|           |          | member\'s goods to the condition they were   |
|           |          | in prior to the move (which often involves   |
|           |          | repair estimates and repair time). At the    |
|           |          | time these metrics were developed, SDDC saw  |
|           |          | nothing wrong with rewarding the TSP who is  |
|           |          | fastest to get a claim check out, rather     |
|           |          | than rewarding the TSP who satisfies the     |
|           |          | customer in the claims process. This needs   |
|           |          | to be corrected. If a TSP has 60 days to     |
|           |          | make settlement of a claim per the 400NG,    |
|           |          | then the measurement should be the frequency |
|           |          | that it takes longer than 60 days and what   |
|           |          | the average days to dispose over 60 days may |
|           |          | be. Even if this measurement were reduced to |
|           |          | only those claims that it takes more than 30 |
|           |          | days to settle would make more sense than    |
|           |          | measuring starting on day one after receipt  |
|           |          | of a claim. Quicker is not necessarily       |
|           |          | better. A second issue with this is that     |
|           |          | there could easily be situations where a     |
|           |          | member is deployed or otherwise unable to    |
|           |          | work with the carrier to process the claim   |
|           |          | quickly, through no fault of the TSP. The    |
|           |          | TSP would always be penalized in this        |
|           |          | scenario if the claims metrics stay the way  |
|           |          | they are. The TSP needs to be able to have   |
|           |          | the full points if the delay is on the part  |
|           |          | of the service member. At one point, someone |
|           |          | at SDDC said not to worry about this effect  |
|           |          | because all TSP's will have the same risk on |
|           |          | this, but that is not true. One TSP may have |
|           |          | few claims but one shipper who is TDY for 3  |
|           |          | months and that TSP's claims score is shot,  |
|           |          | while another TSP may have more claims with  |
|           |          | higher dollar amounts but because he just    |
|           |          | sends a check, his claims score is better    |
|           |          | than the first TSP. That makes no sense.     |
+-----------+----------+----------------------------------------------+
| IV-U.F-3  | C.1.b.1  | The rules stated here treat the carrier who  |
|           |          | meets the minimum acceptable performance     |
|           |          | (settlement of claims within 60 days) the    |
|           |          | same as the TSP who takes any amount of time |
|           |          | longer than 60 days (This section states \"A |
|           |          | TSP meeting the minimum standard . . . earns |
|           |          | zero points\" and also says \"A TSP not      |
|           |          | meeting the minimum standard . . . earns a   |
|           |          | zero point score.\"). That is patently       |
|           |          | unfair. The system should punish performance |
|           |          | that is below the minimum acceptable         |
|           |          | standard. Either a TSP has 60 days to settle |
|           |          | a claim or it does not\--the business rules  |
|           |          | clearly state that a TSP has 60 days and     |
|           |          | punishing it for settling in some time less  |
|           |          | than 60 days does not make sense. The        |
|           |          | measurement should be related to the         |
|           |          | percentage of over-aged claims only,         |
|           |          | addressed in C.1.b.3                         |
+-----------+----------+----------------------------------------------+
| IV-U.F-5  | C.1.b.2  | Considering how difficult it has been for    |
|           |          | SDDC to get customers to fill out a survey   |
|           |          | after delivery, we don't believe that        |
|           |          | you\'ll have much better luck at having them |
|           |          | complete a survey after the claim settlement |
|           |          | is done. Also if a TSP can prove that it     |
|           |          | sent its settlement check within 30 days,    |
|           |          | any negative rating received from the        |
|           |          | customer should be able to be removed from   |
|           |          | DPS.                                         |
+-----------+----------+----------------------------------------------+
| IV-U.F-5  | C.1.b.2  | The points assignment for Late Payment is    |
|           |          | not clear. This section refers to Table      |
|           |          | U.F.4 but that table does not show how       |
|           |          | differing rates of Late Payment affect the   |
|           |          | 15 points possible. The text here in         |
|           |          | Attachment U.F. only states that \"A TSP     |
|           |          | with zero percent reported late payments     |
|           |          | earns the full award points\" and \"A TSP    |
|           |          | with greater than 3% reported late payments  |
|           |          | earns no points.\" What happens to a TSP in  |
|           |          | between those two extremes? Does Table U.F.6 |
|           |          | apply in those cases?                        |
+-----------+----------+----------------------------------------------+
| IV-U.F-7  | C.1.b.3  | We don\'t understand how you can say that    |
|           |          | the measurement of percentage of over-aged   |
|           |          | claims \"does not include actual completed   |
|           |          | repairs or actual payment.\" The member is   |
|           |          | not likely to accept a final offer till      |
|           |          | repairs are completed, so this measurement   |
|           |          | does not make sense and will be              |
|           |          | misinterpreted.                              |
+-----------+----------+----------------------------------------------+
| IV-U.F-10 | C.1.b.4  | We don\'t think anyone can anticipate the    |
|           |          | multitude of reasons that a member may       |
|           |          | choose to transfer a claim to the MCO which  |
|           |          | may have nothing to do with a TSP\'s         |
|           |          | mishandling of the claim. This measure needs |
|           |          | to be carefully examined before making it    |
|           |          | part of the BVS. It is even possible that    |
|           |          | the MCO may offer settlement to members in   |
|           |          | certain situations, particularly in light of |
|           |          | the Services\' attempt to get legislation    |
|           |          | passed that allows them to pay Full          |
|           |          | Replacement Value to members in certain      |
|           |          | situations.                                  |
+-----------+----------+----------------------------------------------+
| IV-U.F-11 | C.1.b.5  | See comments above about the customer survey |
|           |          | process on claims\--It is our opinion that   |
|           |          | service members will not differentiate       |
|           |          | between their frustration with the DPS       |
|           |          | claims module and their satisfaction with    |
|           |          | the TSP\'s performance during the claims     |
|           |          | process. TSP\'s will get dinged for the poor |
|           |          | performance and poor design of the DPS       |
|           |          | claims module. SDDC should be very cautious  |
|           |          | before proceeding to use this measurement to |
|           |          | determine the TSP\'s BVS.                    |
+-----------+----------+----------------------------------------------+
| IV-U.F-2  | C.1.b    | The explanation for the calculation of the   |
| thru 19   |          | claims score takes 14 pages (including the   |
|           |          | tables) out of a total of 19 pages to        |
|           |          | explain the whole BVS process. We think the  |
|           |          | claims metrics calculations are entirely too |
|           |          | cumbersome and industry the Claims Services  |
|           |          | should form a working group to come up with  |
|           |          | some alternatives that are simpler and       |
|           |          | provide meaningful data to SDDC.             |
+-----------+----------+----------------------------------------------+
| IV-U.F-   | Overall  | A TSP should be notified each time that BVS  |
|           |          | scores are being calculated and be given a   |
|           |          | report in DPS of what shipments and          |
|           |          | individual scores are contained in that BVS  |
|           |          | comprehensive score. The TSP should have a   |
|           |          | fixed number of days to advise SDDC if the   |
|           |          | TSP determines that the data in DPS is       |
|           |          | erroneous or contains shipments that should  |
|           |          | not be part of its BVS comprehensive score.  |
+-----------+----------+----------------------------------------------+
| A         |          |                                              |
| ttachment |          |                                              |
| U.G TSP   |          |                                              |
| Ranking,  |          |                                              |
| 12/21/07  |          |                                              |
+-----------+----------+----------------------------------------------+
| IV-U.G-1  | B.       | New entrants should not be allowed to come   |
|           |          | on at the median score, particularly since   |
|           |          | the median score is used to achieve          |
|           |          | statistical validity for TSP\'s who have     |
|           |          | actually moved shipments in the program. New |
|           |          | entrants should be assigned a minimum        |
|           |          | administrative score that is less than the   |
|           |          | program median average or it again totally   |
|           |          | dilutes the value of achieving that score by |
|           |          | offering service on real shipments. We       |
|           |          | suggest that the new entrant score should be |
|           |          | 20 points less than the median score. A new  |
|           |          | entrant could achieve an actual score by     |
|           |          | being responsive to short fuse shipment      |
|           |          | offerings and providing outstanding service. |
|           |          | They should not be rewarded just for         |
|           |          | entering the program.                        |
+-----------+----------+----------------------------------------------+
| A         |          |                                              |
| ttachment |          |                                              |
| U.H       |          |                                              |
| Customer  |          |                                              |
| Sat       |          |                                              |
| isfaction |          |                                              |
| Survey,   |          |                                              |
| 12/21/07  |          |                                              |
+-----------+----------+----------------------------------------------+
| IV-U.H-2  | A.2.d    | Waiting till 30 days prior to the end of any |
|           |          | performance period to try to contact members |
|           |          | to increase the survey response rate is too  |
|           |          | late. When the CSS/ICSS process was created  |
|           |          | by the joint Business Process Working Group, |
|           |          | the design included that telephonic surveys  |
|           |          | would be conducted all the time to enhance   |
|           |          | the response rate. With 6 performance review |
|           |          | periods annually, realistically this should  |
|           |          | be an ongoing process. Many TSP\'s are       |
|           |          | assisting in this process but it is          |
|           |          | fundamentally SDDC\'s issue as stated in     |
|           |          | Attachment U.F C.1.a.2.a \"Lack of valid     |
|           |          | survey results is considered a system        |
|           |          | problem.\"                                   |
+-----------+----------+----------------------------------------------+
| IV-U.H-3  | A.4.d.   | This paragraph needs to be clarified in that |
|           |          | surveys on dHHG, iHHG or iUB shipments that  |
|           |          | originate out of NTS will NEVER be used in   |
|           |          | determining a TSP\'s PS, even after Phase    |
|           |          | III of Families First is implemented. This   |
|           |          | issue was covered at a recent Business Rules |
|           |          | session with JPMO HHGS and it was agreed     |
|           |          | that this was the intent since the member    |
|           |          | would not be able to differentiate between   |
|           |          | his satisfaction (or dissatisfaction) with   |
|           |          | issues caused by the NTS contractor versus   |
|           |          | by the TSP who handled his dHHG, iHHG or iUB |
|           |          | shipment, resulting in an unfair rating to   |
|           |          | the TSP. This section should read that when  |
|           |          | Phase III of Families First is implemented   |
|           |          | the NTS TSP will be rated on the origin      |
|           |          | services provided when the NTS shipment was  |
|           |          | picked up.                                   |
+-----------+----------+----------------------------------------------+
| IV-U.H-4  | A.5      | We do not believe in the scientific          |
|           |          | soundness of SDDC\'s method of calculating   |
|           |          | whether or not a TSP is statistically valid  |
|           |          | based on the number of surveys returned      |
|           |          | versus the number of shipments moved.        |
|           |          | Industry has offered various reports by      |
|           |          | statisticians that have demonstrated that    |
|           |          | SDDC\'s approach is not a random survey and  |
|           |          | is not statistically valid. We refer back to |
|           |          | the studies that have been provided to SDDC  |
|           |          | by HHGFAA and Tim Helenthal from National    |
|           |          | Van Lines and incorporate them into our      |
|           |          | comments here by reference. We believe that  |
|           |          | SDDC\'s methodology is tainted by            |
|           |          | \"naysayer\'s bias\" meaning that there is a |
|           |          | greater propensity for persons to            |
|           |          | voluntarily complete a survey where their    |
|           |          | experiences were at one extreme or other     |
|           |          | other, i.e. either highly satisfied or       |
|           |          | highly dissatisfied. This is borne out by    |
|           |          | the general comments being received during   |
|           |          | the ICSS process.                            |
+-----------+----------+----------------------------------------------+
| IV-U.H-4  | A.7      | Since SDDC has asked for TSP assistance in   |
|           |          | achieving a higher rate of return on         |
|           |          | customer surveys, it would be most helpful   |
|           |          | to change this rule so that a TSP could view |
|           |          | information in DPS to identify customers who |
|           |          | have not completed the survey. This would    |
|           |          | assist TSP\'s in making followup contacts    |
|           |          | with those shippers to encourage them to     |
|           |          | complete the survey.                         |
+-----------+----------+----------------------------------------------+
| A         |          |                                              |
| ttachment |          |                                              |
| U.J       |          |                                              |
| Shipment  |          |                                              |
| Ma        |          |                                              |
| nagement, |          |                                              |
| 12/21/07  |          |                                              |
+-----------+----------+----------------------------------------------+
| IV-U.J-2  | B.2.a    | Spread dates are used for both pickup and    |
|           |          | delivery (not just for pickup as it states   |
|           |          | in this section) and need to be allowed for  |
|           |          | in the business rules.                       |
+-----------+----------+----------------------------------------------+
| IV-U.J-2  | B.2.a.1  | TSP\'s should be given information about how |
|           |          | many other TSP\'s are in a given quality     |
|           |          | band and how many total TSP\'s are in a      |
|           |          | given channel so that they have some idea    |
|           |          | about how much business they may get in that |
|           |          | channel.                                     |
+-----------+----------+----------------------------------------------+
| IV-U.J-2  | B.2.a.1  | The business rules should provide some way   |
|           |          | that a TSP can tell if it is receiving the   |
|           |          | proper shipment allocation. As it currently  |
|           |          | stands, the TSP has no idea what to expect   |
|           |          | and can\'t tell if it is being bypassed or   |
|           |          | not receiving its appropriate amount of      |
|           |          | shipments per channel in the 5,3,2,1         |
|           |          | rotation.                                    |
+-----------+----------+----------------------------------------------+
| IV-U.J-5  | B.3.c    | A PPSO should not be able to override a DPS  |
|           |          | shipment award if a punitive action is       |
|           |          | \"pending\" against a TSP. Either the TSP    |
|           |          | has a punitive action or they don\'t. The    |
|           |          | PPSO could use this override to shut a TSP   |
|           |          | out of business but never actually take the  |
|           |          | punitive action. The TSP should be eligible  |
|           |          | to receive shipments unless they are         |
|           |          | suspended, disqualified or revoked from      |
|           |          | participation in the program. At a minimum,  |
|           |          | if a PPSO overrides a shipment award because |
|           |          | QA action is pending against the TSP, we     |
|           |          | believe this should result in a notification |
|           |          | (email or other DPS) alert to the TSP that   |
|           |          | the shipment is not being awarded to them    |
|           |          | and why. This may be the TSP\'s first        |
|           |          | indication that there is a problem or it     |
|           |          | could be an indication of a DPS system       |
|           |          | problem erroneously showing a TSP with       |
|           |          | pending QC action.                           |
+-----------+----------+----------------------------------------------+
| IV-U.J-5  | B.3      | DPS should not default the transit time per  |
|           |          | the transit time table. Transit times are    |
|           |          | supposed to be minimums and the actual       |
|           |          | transit time on the shipment should be       |
|           |          | determined in part by customer need. If the  |
|           |          | system defaults the minimum transit time,    |
|           |          | then DPS perpetuates one of the problems of  |
|           |          | TOPS.                                        |
+-----------+----------+----------------------------------------------+
| IV-U.J-6  | B        | If a PPSO overrides a shipment award because |
|           | .3.a.3.e | punitive action is pending against the TSP,  |
|           |          | we believe this should result in a           |
|           |          | notification (email or other DPS) alert to   |
|           |          | the TSP that the shipment is not being       |
|           |          | awarded to them and why. This may be the     |
|           |          | TSP\'s first indication that there is a      |
|           |          | problem or it could be an indication of a    |
|           |          | DPS system problem erroneously showing a TSP |
|           |          | with pending punitive action.                |
+-----------+----------+----------------------------------------------+
| IV-U.J-7  | B.3.b.   | The language in the \"NOTE\" in this section |
|           | Note     | continues SDDC\'s misunderstanding of        |
|           |          | shipment spread dates. Many times thru the   |
|           |          | development of Families First we have        |
|           |          | provided information about how spread dates  |
|           |          | work in the commercial environment. Here is  |
|           |          | a brief synopsis.                            |
|           |          |                                              |
|           |          | Spread dates allow the member to have a      |
|           |          | general idea of a window                     |
|           |          |                                              |
|           |          | (spread) of dates that their shipment will   |
|           |          | arrive for delivery. The spread dates are    |
|           |          | calculated based on the weight of the        |
|           |          | shipment and the distance it is traveling,   |
|           |          | as well as the time of year in some cases    |
|           |          | (i.e. peak season).                          |
|           |          |                                              |
|           |          | A larger shipment will have a smaller number |
|           |          | of days within which the carrier may arrive  |
|           |          | and still be \"on time,\" while a smaller    |
|           |          | shipment will have a larger number of days.  |
|           |          | At the time the shipment is booked and       |
|           |          | surveyed, the TSP will discuss with the      |
|           |          | member their schedule and the general        |
|           |          | transit time needed for a shipment of that   |
|           |          | weight/mileage. For example, the TSP may     |
|           |          | advise that there will be a delivery spread  |
|           |          | of from 3-5 days after loading (the smaller  |
|           |          | the shipment, the longer the spread may be), |
|           |          | beginning on a certain date and ending on a  |
|           |          | certain date. The TSP would then explain     |
|           |          | that, after the shipment has loaded, but     |
|           |          | typically before the first date of the       |
|           |          | delivery spread, the TSP will gain a better  |
|           |          | idea of the actual arrival time of the van   |
|           |          | (based on other shipments that may be on     |
|           |          | board, etc.). The TSP will explain that      |
|           |          | within 24-48 hours prior to scheduled        |
|           |          | delivery arrival, it will commit to a date   |
|           |          | certain for arrival and notify the member of |
|           |          | that date. This allows the TSP to have the   |
|           |          | best utilization of their van and driver,    |
|           |          | while affording the member a time commitment |
|           |          | for delivery. All of this is based on the    |
|           |          | delivery address being known prior to        |
|           |          | loading the shipment. In all cases, however, |
|           |          | the member would be able to rely upon a      |
|           |          | commitment for delivery of the shipment      |
|           |          | sometime within the spread of dates given    |
|           |          | after the premove survey-they just won\'t    |
|           |          | have the firm date established till a few    |
|           |          | days prior to actual delivery.               |
|           |          |                                              |
|           |          | This is how they should work in the DOD      |
|           |          | environment as well, which leads to more     |
|           |          | efficient use of a TSP\'s van capacity while |
|           |          | providing timely information to the customer |
|           |          | about when to expect delivery of their       |
|           |          | shipment.                                    |
|           |          |                                              |
|           |          | As DPS currently is programmed, it presumes  |
|           |          | that the first day of the delivery spread    |
|           |          | can't be before the RDD. As a result, any    |
|           |          | spread days after the first day of the       |
|           |          | spread and any delivery made during the      |
|           |          | delivery spread will be after the RDD, i.e., |
|           |          | late. Yet, the delivery will have been       |
|           |          | accomplished as mutually coordinated with    |
|           |          | the customer.                                |
|           |          |                                              |
|           |          | The more appropriate structure in DPS would  |
|           |          | be that the RDD would be the same date as    |
|           |          | the last day of the delivery spread. The TSP |
|           |          | would have to commit to getting the shipment |
|           |          | to destination no later than the last day of |
|           |          | the delivery spread (the RDD). The first day |
|           |          | of the delivery spread reflects the          |
|           |          | commitment of a date that the shipment won't |
|           |          | arrive any earlier than. As a result, a TSP  |
|           |          | commits to getting the shipment to           |
|           |          | destination between a specific date range,   |
|           |          | although the exact date of arrival may not   |
|           |          | be determined possibly as late as 24-48      |
|           |          | hours prior to the actual date. The customer |
|           |          | knows ahead of time the specific date by     |
|           |          | which they have committed to be available at |
|           |          | destination to accept the shipment. Any SIT  |
|           |          | request approval parameters would then be    |
|           |          | based on the first day of the delivery       |
|           |          | spread.                                      |
+-----------+----------+----------------------------------------------+
| IV-U.J-7  | B.3.c    | DPS should monitor a PPSO\'s use of short    |
|           |          | fuse shipments to make sure that this method |
|           |          | of booking is not used too often, depriving  |
|           |          | the TSP\'s with the highest BVS from         |
|           |          | receiving their fair allocation of           |
|           |          | shipments. It should be used as a tool to    |
|           |          | ensure that PPSO\'s are booking shipments in |
|           |          | DPS in a timely fashion and not letting a    |
|           |          | backlog of shipments build up until they     |
|           |          | become short fuse.                           |
+-----------+----------+----------------------------------------------+
| IV-U.J-7  | B.3.d    | This description of spread dates is quite    |
|           |          | accurate except that the use of spread dates |
|           |          | is not just during the counseling, but       |
|           |          | during the actual service of the shipment.   |
|           |          | The only way that spread dates provide       |
|           |          | flexibility to the customer and to the TSP   |
|           |          | is by using them as the required service     |
|           |          | dates on a shipment, not just as a piece of  |
|           |          | information during counseling. Proper use of |
|           |          | spread dates, as this section shows, will    |
|           |          | give flexibility to the customer and TSP,    |
|           |          | maximize direct delivery (and reduce SIT     |
|           |          | costs) and allow the TSP to better manage    |
|           |          | its resources for servicing shipments.       |
+-----------+----------+----------------------------------------------+
| IV-U.J-7  | B.3.e    | It is assumed that a TSP would not be        |
|           |          | offered a shipment for service dates that    |
|           |          | the TSP has blacked out. But, what if a      |
|           |          | member changes dates on a shipment that now  |
|           |          | puts the pickup on a day or days that has    |
|           |          | been blacked out by the TSP, can the TSP now |
|           |          | \"refuse\" the shipment without penalty?     |
+-----------+----------+----------------------------------------------+
| IV-U.J-8  | B.3.g    | DPS should not default the transit time per  |
|           |          | the transit time table. Transit times are    |
|           |          | supposed to be minimums and the actual       |
|           |          | transit time on the shipment should be       |
|           |          | determined in part by customer need. If the  |
|           |          | system defaults the minimum transit time,    |
|           |          | then DPS perpetuates one of the problems of  |
|           |          | TOPS. This also creates an expectation in    |
|           |          | the member\'s mind that the transit time     |
|           |          | should never take longer than this           |
|           |          | \"minimum\" time.                            |
+-----------+----------+----------------------------------------------+
| IV-U.J-8  | B.3.g.1  | DPS should notify the TSP at the time of     |
|           |          | shipment offering that the transit time      |
|           |          | reflected in the offering is less than the   |
|           |          | minimum transit time required for the        |
|           |          | shipment. The TSP should have the ability to |
|           |          | accept or reject the offering if it has a    |
|           |          | shortened transit time, without penalty to   |
|           |          | the TSP. At the JPMO HHGS Town Hall meeting  |
|           |          | the week of 3/10/08, Danny Martinez was      |
|           |          | asked about this issue and he explained that |
|           |          | the TSP should attempt to negotiate          |
|           |          | different dates with the member, but if not  |
|           |          | agreement could be reached and the TSP could |
|           |          | not meet the dates requested, the TSP could  |
|           |          | advise the PPSO and the PPSO could pull the  |
|           |          | shipment back without penalty to the TSP.    |
|           |          | However the Business Rules here do not       |
|           |          | reflect that and they should be modified.    |
|           |          | Otherwise, the TSP would be forced to accept |
|           |          | a shipment offering that on which it knows   |
|           |          | it will have a service failure. That does    |
|           |          | not provide good customer service to the     |
|           |          | member and unfairly penalizes the TSP, who   |
|           |          | would likely get a low CSS rating on the     |
|           |          | shipment. The likelihood of this problem     |
|           |          | arising is very high, particularly if the    |
|           |          | member does self-counseling and they do not  |
|           |          | understand the implications of requesting a  |
|           |          | shorter than minimum transit time.           |
+-----------+----------+----------------------------------------------+
| IV-U.J-9  | B.3.g.2  | The description here of how dates are        |
|           |          | established on shipments moving under DPS    |
|           |          | leads to the establishment of what is        |
|           |          | effectively a guaranteed 1 day delivery,     |
|           |          | which is far more restrictive than the       |
|           |          | current program and far costlier to provide  |
|           |          | to the government. As you know, in the       |
|           |          | current program, the TSP can offer the       |
|           |          | shipment for delivery any time from the day  |
|           |          | after pickup up to the RDD and be in         |
|           |          | compliance with the contract. While we       |
|           |          | understand SDDC\'s desire to reduce the      |
|           |          | incidence of SIT, to do so by establishing   |
|           |          | guaranteed 1-day delivery is the most        |
|           |          | drastic way to do so and shifts the cost     |
|           |          | completely to the TSP, who has no recourse   |
|           |          | but to roll that cost in his rate. But with  |
|           |          | the rate reasonableness ranges that were     |
|           |          | established, it was virtually impossible to  |
|           |          | roll the cost in. Not even our very best     |
|           |          | corporate customers (commercial practice)    |
|           |          | receive a guaranteed 1-day delivery on all   |
|           |          | shipment sizes and distances. Please refer   |
|           |          | to the information we are provided above     |
|           |          | regarding IV-U.J-7, B.3.b.                   |
+-----------+----------+----------------------------------------------+
| IV-U.J-9  | B.4      | The language in this section does not match  |
|           |          | the Quality Assurance rules in Attachment    |
|           |          | U.Q, E.2.c.1 and E.3.a.2. Attachment U.Q     |
|           |          | states that the penalty for a shipment       |
|           |          | refusal is a 30-day immediate suspension     |
|           |          | from \"t*hat PPSO\'s market*.\" Attachment   |
|           |          | U.J should be changed to remove the language |
|           |          | that says the suspension is for \"that       |
|           |          | market\" since that indicates worldwide      |
|           |          | suspension for the market (dHHG, iHHG or     |
|           |          | iUB) rather than just from the PPSO\'s       |
|           |          | market. In plain English then, as we         |
|           |          | understand the Business Rules from the March |
|           |          | Town hall Meeting, if a TSP refuses a dHHG   |
|           |          | shipment from Ft. Bragg, NC, for a first     |
|           |          | offense, the TSP would be suspended from all |
|           |          | dHHG shipments from Ft. Bragg only for 30    |
|           |          | days. Please clarify this language so that   |
|           |          | there is no difference between U.Q and U.J   |
|           |          | because this is a critically important       |
|           |          | distinction.                                 |
+-----------+----------+----------------------------------------------+
| IV-U.J-9  | B.4      | DPS should consider the time zone where the  |
|           |          | TSP is located to determine whether or not   |
|           |          | the response to a shipment offer is timely.  |
|           |          | Otherwise, TSP\'s located in CONUS will be   |
|           |          | required to staff on weekends for shipment   |
|           |          | offerings to cover Pacific Rim time zones.   |
|           |          | This is a cost-driver that does not need to  |
|           |          | occur.                                       |
+-----------+----------+----------------------------------------------+
| IV-U.J-9  | B.4.a    | If a TSP does not respond to a shipment      |
|           |          | offering within 23 hours, we suggest that    |
|           |          | the Business Rules be modified to send a     |
|           |          | notification via email to the TSP at 23      |
|           |          | hours, giving the TSP 1 additional hour to   |
|           |          | respond to the shipment offering. If there   |
|           |          | is no response to the 1-hour final warning,  |
|           |          | then the punitive action should be put in    |
|           |          | motion, unless the TSP can show that the     |
|           |          | non-response was due to a technical system   |
|           |          | error. We also suggest that SDDC has to      |
|           |          | acknowledge the real world possibility that  |
|           |          | a TSP\'s email or web access may be cut off  |
|           |          | through no fault of the TSP. In those cases, |
|           |          | the TSP should be able to show that the      |
|           |          | problem was not their fault (for example     |
|           |          | non-payment of an internet service provider  |
|           |          | bill would be the TSP\'s fault), and that    |
|           |          | the immediate suspension action is           |
|           |          | unwarranted. SDDC knows this situation can   |
|           |          | happen because DPS and SDDC both have had    |
|           |          | server issues. From time to time, worldwide  |
|           |          | ISP\'s even have the network go out. The     |
|           |          | rules should give this flexibility or at     |
|           |          | least some due process for the TSP to        |
|           |          | demonstrate that the failure to respond was  |
|           |          | not their fault.                             |
+-----------+----------+----------------------------------------------+
| IV-U.J-10 | B.5.e    | The TSP should not be required to enter      |
|           |          | premove survey data within 7 days of         |
|           |          | pack/pickup date since that means that they  |
|           |          | would have to actually perform the premove   |
|           |          | survey earlier than within 7 days of the     |
|           |          | pack/pickup date. On short fuse shipments,   |
|           |          | this may be physically impossible. The rules |
|           |          | should state that the premove survey should  |
|           |          | be conducted in enough time to allow the TSP |
|           |          | and member to properly prepare for the       |
|           |          | shipment. In the case of a short fuse        |
|           |          | shipment, there should be no time limit      |
|           |          | imposed for the premove survey.              |
+-----------+----------+----------------------------------------------+
| IV-U.J-10 | B.5.e    | This language should be carefully clarified. |
|           |          | We believe it should state \"The TSP must    |
|           |          | contact the member/employee *within 7 days   |
|           |          | of shipment booking* to arrange a time to    |
|           |          | perform the survey.\" As it is currently     |
|           |          | worded, it appears to state that the premove |
|           |          | survey itself has to be performed within 7   |
|           |          | days of shipment booking and that is simply  |
|           |          | not practical nor effective, particularly    |
|           |          | when a shipment has been booked              |
|           |          | significantly in advance of the actual move  |
|           |          | dates.                                       |
+-----------+----------+----------------------------------------------+
| IV-U.J-10 | B.5.e    | The paragraph in between the two \"NOTES\"   |
|           |          | continues the confusion about how spread     |
|           |          | dates really work. We also don\'t understand |
|           |          | what the 2nd NOTE means. Does this mean that |
|           |          | DPS will set the RDD if the TSP has not      |
|           |          | contacted the member within 72 hours of      |
|           |          | entering premove survey in DPS?              |
+-----------+----------+----------------------------------------------+
| IV-U.J-10 | B.6      | The Business Rules need to spell out how the |
|           |          | TSP requests approvals for services when the |
|           |          | request needs to be handled immediately,     |
|           |          | e.g., if the crew is at residence and needs  |
|           |          | immediate feedback to continue servicing the |
|           |          | shipment. We know this has been discussed at |
|           |          | various meetings/town halls that the TSP or  |
|           |          | TSP representative will need to call the     |
|           |          | PPSO for immediate approval, but we believe  |
|           |          | the process should be spelled out in the     |
|           |          | rules. Otherwise, we can envision a PPSO     |
|           |          | saying that they have 3 business days to     |
|           |          | respond to our request.                      |
+-----------+----------+----------------------------------------------+
| IV-U.J-11 | B.6.e    | This section says that the PPSO will be      |
|           |          | notified of approvals that are overdue (more |
|           |          | than 5 business days since submission by the |
|           |          | TSP). This language conflicts with           |
|           |          | Attachment U.A.B.4.b.10.d which states that  |
|           |          | the response must be in 3 business days. In  |
|           |          | either event, the response time is too long  |
|           |          | since the TSP may be waiting for approval    |
|           |          | for a work crew present at residence. The    |
|           |          | language should be consistent in both        |
|           |          | sections and should be no more than 3        |
|           |          | business days.                               |
+-----------+----------+----------------------------------------------+
| IV-U.J-13 | B.9.b &  | This states that a comment will print in     |
|           | c        | block 25 of the PPGBL if an excess cost      |
|           |          | situation exists. However, some of the       |
|           |          | potential excess costs will not be known     |
|           |          | until the actual shipment weight is entered. |
|           |          | The actual shipment weight is almost always  |
|           |          | entered after the PPGBL has been generated,  |
|           |          | so this notation does not appear to be       |
|           |          | effective.                                   |
+-----------+----------+----------------------------------------------+
| IV-U.J-13 | B.10     | DPS should have a shipment notes             |
|           |          | functionality to allow various parties to    |
|           |          | communicate on issues about the shipment,    |
|           |          | including allowing the service member to put |
|           |          | information in that cannot otherwise be      |
|           |          | entered as updated data in the shipment      |
|           |          | record itself.                               |
+-----------+----------+----------------------------------------------+
| IV-U.J-15 | B.11.c   | Will every shipment have a DD1780 prepared   |
|           |          | and will they still be sent to the TSP in    |
|           |          | all cases? The Business Rules are not clear  |
|           |          | as to whether they are only prepared when    |
|           |          | there are problems or other issues that      |
|           |          | should be documented on a DD1780. How will   |
|           |          | the TSP know if a DD1780 has been done on a  |
|           |          | shipment?                                    |
+-----------+----------+----------------------------------------------+
| IV-U.J-15 | B.11.c   | Since DPS offers shipments to the TSP, not   |
|           |          | to the local agent, this section should be   |
|           |          | reworded to remove that reference. There are |
|           |          | cases even now where the TSP has named       |
|           |          | itself as the booking agent on a Letter of   |
|           |          | Intent, but the base contacts the local      |
|           |          | agent for a commitment to service. If this   |
|           |          | practice continues under DPS, it should be   |
|           |          | clear in the business rules that a           |
|           |          | commitment by a local agent DOES NOT commit  |
|           |          | the TSP. Only the TSP itself should be able  |
|           |          | to commit itself to services since there     |
|           |          | will be no more Letter of Intent nor implied |
|           |          | action on the part of any local agent to be  |
|           |          | the action of the principal (TSP).           |
+-----------+----------+----------------------------------------------+
| IV-U.J-15 | B.11.d   | Figures U.J 3 and U.J 4 should be updated to |
|           |          | reflect the newly-approved DD619 and DD619-1 |
|           |          | forms announced in May of 2008. As a matter  |
|           |          | of record, whether referring to the forms as |
|           |          | they currently exist in Attachment U.J or    |
|           |          | the new DD619/619-1 forms, these forms need  |
|           |          | to be further revised as they do not reflect |
|           |          | the processes in use for DPS/Families First. |
|           |          | For example, there will be no need for a     |
|           |          | carton count since all packing charges are   |
|           |          | paid on a flat fee based on the weight of    |
|           |          | the shipment. There should not be any        |
|           |          | loss/damage recorded on the DD619-1 since    |
|           |          | there are separate forms specifically for    |
|           |          | that function, as well as the claims module  |
|           |          | itself in DPS. Failure to update the forms   |
|           |          | to follow the functionality of DPS/Families  |
|           |          | First will lead to unnecessary confusion.    |
+-----------+----------+----------------------------------------------+
| IV-U.J-16 | B.11.i   | Under DPS/Families First, the DD1857 will no |
|           |          | longer be allowed to be completed \"after    |
|           |          | the fact.\" If the government terminates     |
|           |          | SIT, it must do so in DPS and cannot         |
|           |          | \"undo\" the conversion per the terms of the |
|           |          | 400NG and the International Tariff.          |
+-----------+----------+----------------------------------------------+
| IV-U.J-   | C.1.b.   | The TSP should have some way to annotate an  |
|           | Note     | updated email address in DPS, even if it is  |
|           |          | only in a \"notes function\" as recommended  |
|           |          | above under section B.10.                    |
+-----------+----------+----------------------------------------------+
| IV-U.J-17 | C.2      | The business rules need to be clarified as   |
|           |          | to when the 2 hours (3 hours for             |
|           |          | international) free waiting time commences   |
|           |          | for delivery. We believe the TSP should      |
|           |          | record the arrival of the shipment in DPS    |
|           |          | and that starts the 2 hours free waiting     |
|           |          | time clock. Then the TSP should make         |
|           |          | attempts to contact the member to arrange    |
|           |          | for delivery. If, after 2 hours, the TSP is  |
|           |          | unable to contact the member, the PPSO may   |
|           |          | help, but the TSP would be on waiting time.  |
+-----------+----------+----------------------------------------------+
| IV-U.J-18 | C.3      | Earlier versions of the Business Rules had   |
|           |          | indicated that if there was no residence     |
|           |          | delivery address in DPS, the TSP would       |
|           |          | record the arrival of the shipment in DPS    |
|           |          | and SIT would be automatically authorized by |
|           |          | DPS. We think that is the far simpler method |
|           |          | of handling inbound SIT at destination and   |
|           |          | that the final Business Rules should state   |
|           |          | so.                                          |
+-----------+----------+----------------------------------------------+
| IV-U.J-18 | C.3      | This paragraph reflects a more accurate      |
|           |          | understanding of how delivery spread dates   |
|           |          | are used on shipments. However, it conflicts |
|           |          | with all the earlier Business Rules which    |
|           |          | speak only of a firm RDD that must be        |
|           |          | established during the pre-move survey       |
|           |          | process. We believe the earlier stated       |
|           |          | Business Rules should be modified to be      |
|           |          | brought in line with how delivery spread     |
|           |          | dates really work.                           |
+-----------+----------+----------------------------------------------+
| IV-U.J-18 | C.3      | On deliveries out of SIT, it is not clear    |
|           |          | from the Business Rules if you have created  |
|           |          | the expectation the TSP has to request       |
|           |          | approval for delivery out from the PPSO if   |
|           |          | the member accesses DPS and requests a       |
|           |          | delivery out of SIT. Please clarify this.    |
|           |          | Our understanding from DPS testing and       |
|           |          | various training sessions was that the       |
|           |          | member could simply go into DPS, request     |
|           |          | delivery out and the TSP would then make     |
|           |          | arrangements to delivery. Does the TSP have  |
|           |          | to get approval from the PPSO for delivery   |
|           |          | out of SIT? What if the member asks for us   |
|           |          | to deliver a shipment out to an address      |
|           |          | further than 50 miles from the destination   |
|           |          | of the shipment as shown on the original     |
|           |          | GBL? There needs to be some more detail here |
|           |          | because the member could ask for delivery    |
|           |          | out terms that could lead to additional      |
|           |          | cost.                                        |
+-----------+----------+----------------------------------------------+
| IV-U.J-19 | C.4.b    | DPS requires the TSP to enter the inventory  |
|           |          | numbers of all items delivered in a partial  |
|           |          | delivery. This is a very cumbersome process  |
|           |          | to record each inventory number,             |
|           |          | particularly if only a few items were held   |
|           |          | for delivery at a later date. The DPS entry  |
|           |          | in this field should allow for text to show  |
|           |          | a range of inventory items delivered or held |
|           |          | back for later delivery.                     |
+-----------+----------+----------------------------------------------+
| IV-U.J-19 | C.5.a    | The rules here state that the TSP must use   |
|           |          | the \"DOD-approved facility located nearest  |
|           |          | the destination city or installation shown   |
|           |          | in Bock 18 of the PPGBL unless otherwise     |
|           |          | authorized and directed by the PPSO. SIT and |
|           |          | related charges are based on the nearest     |
|           |          | available DOD-approved facility.\" We object |
|           |          | to this rule for 2 reasons\--first, TSP      |
|           |          | control of the shipment and, second,         |
|           |          | inability of either DPS or the PPSO to keep  |
|           |          | track of what facilities are \"available\"   |
|           |          | at any given point in time, especially in    |
|           |          | the summer in areas where warehouses often   |
|           |          | are saturated for SIT. As to the first       |
|           |          | point, the TSP should be able to use its own |
|           |          | agent\'s facility, whether it is exactly     |
|           |          | nearest the destination or not. If it is     |
|           |          | within 30 miles (50 miles for international) |
|           |          | of the destination city or installation, the |
|           |          | TSP should be able to use its own agent\'s   |
|           |          | facility no matter what. If it is further    |
|           |          | away than 30/50 miles, the TSP should obtain |
|           |          | PPSO approval to place the shipment in the   |
|           |          | more distant location.                       |
+-----------+----------+----------------------------------------------+
| IV-U.J-20 | C        | Earlier versions of the Business Rules had   |
|           | .5.a.2.a | indicated that if there was no residence     |
|           |          | delivery address in DPS, the TSP would       |
|           |          | record the arrival of the shipment in DPS    |
|           |          | and SIT would be automatically authorized by |
|           |          | DPS. We think that is the far simpler method |
|           |          | of handling inbound SIT at destination and   |
|           |          | that the final Business Rules should state   |
|           |          | so.                                          |
+-----------+----------+----------------------------------------------+
| IV-U.J-20 | C        | If the member has recorded a requested       |
|           | .5.a.2.b | delivery date in DPS that is much longer     |
|           |          | than the normal transit time, but they have  |
|           |          | a delivery address, this presents an issue   |
|           |          | for the TSP. If the TSP arrives at           |
|           |          | destination before the RDD and before the    |
|           |          | end of the normal transit time and there is  |
|           |          | a delivery address, the TSP should not       |
|           |          | request SIT at government expense. However,  |
|           |          | if the TSP arrives at destination before the |
|           |          | RDD, but after the normal (minimum) transit  |
|           |          | time per DPS, the TSP should be allowed to   |
|           |          | request and receive approval for SIT at      |
|           |          | government expense. Otherwise, it is         |
|           |          | possible that a service member with a        |
|           |          | delivery address could decide to go on       |
|           |          | vacation or some other extended time away    |
|           |          | from home prior to arrival at the new        |
|           |          | destination address and this would cause the |
|           |          | TSP to have to hold the shipment free of     |
|           |          | charge to the government. This is unfair and |
|           |          | is an overall cost driver to the program     |
|           |          | since the only way the TSP can recoup that   |
|           |          | cost is to build it into its overall rate.   |
+-----------+----------+----------------------------------------------+
| IV-U.J-22 | C.5.d.   | While we know that lots of things need to be |
|           | Note     | tweaked in DPS, it would seem that the       |
|           |          | ability to track the 2 hour contact window   |
|           |          | for free waiting time prior to delivery      |
|           |          | would be a high priority development issue.  |
+-----------+----------+----------------------------------------------+
| IV-U.J-22 | C.5.d.2  | Again, if there is no residence delivery     |
|           |          | address and it is known that the member is   |
|           |          | not available for delivery, the TSP should   |
|           |          | not have to wait 2 hours for approval of     |
|           |          | SIT. Previous iterations of the business     |
|           |          | rules indicated that DPS would automatically |
|           |          | approve SIT on those cases.                  |
+-----------+----------+----------------------------------------------+
| IV-U.J-23 | C        | This section appears to allow the use of     |
|           | .5.d.6.a | delivery spread dates unlike many other      |
|           |          | previous sections of the rules. If nothing   |
|           |          | else, the rules need to be made consistent.  |
|           |          | If you are going to allow the use of         |
|           |          | delivery spread dates, then all the various  |
|           |          | sections should refer to that fact, not just |
|           |          | refer to an RDD and the GBL should be able   |
|           |          | to print a spread of dates for the delivery  |
|           |          | of the shipment. If you are not going to     |
|           |          | allow the use of delivery spread dates       |
|           |          | (which we think is a mistake and counter to  |
|           |          | industry\'s understanding during the         |
|           |          | development of DPS/Families First, then you  |
|           |          | should eliminate references to delivery      |
|           |          | spreads in sections such as this one.        |
+-----------+----------+----------------------------------------------+
| IV-U.J-23 | C        | If there is a delivery address, and if       |
|           | .5.d.6.a | delivery spread dates were used and the TSP  |
|           |          | arrives at destination early, then SIT       |
|           |          | should not be authorized. However, if the    |
|           |          | TSP arrives during the spread window or      |
|           |          | after the spread window and there is a       |
|           |          | delivery address and the member cannot take  |
|           |          | delivery of the goods, then SIT should be    |
|           |          | requested and approved.                      |
+-----------+----------+----------------------------------------------+
| IV-U.J-23 | C        | If there is no delivery address, and the TSP |
|           | .5.d.6.b | arrives at any time to deliver the shipment, |
|           |          | SIT should be requested and approved. We     |
|           |          | also don\'t believe the Families First rules |
|           |          | for SIT should refer back to Chapter 406 of  |
|           |          | DTR Part IV because Chapter 406 refers to    |
|           |          | old program rules, and contains much that    |
|           |          | conflicts with the regulations in this       |
|           |          | Attachment U.J.                              |
+-----------+----------+----------------------------------------------+
| IV-U.J-24 | C.6      | Reweigh\--DPS currently does not know what   |
|           |          | to do if the reweigh is accomplished at      |
|           |          | delivery out of SIT, because if the weight   |
|           |          | is not identical to the original weight, DPS |
|           |          | presumes that either some of the shipment is |
|           |          | still in SIT or it gives an error message    |
|           |          | for the weight. This was revealed at the DPS |
|           |          | town hall in March 08.                       |
+-----------+----------+----------------------------------------------+
| IV-U.J-25 | C.6.a.3  | Why is a reweigh certificate required since  |
|           |          | the reweigh is ordered in DPS and the        |
|           |          | reweigh weights are recorded there as well   |
|           |          | as hard copies being provided. The           |
|           |          | certificate DD1671 seems to be a form that   |
|           |          | could be eliminated to avoid paperwork.      |
+-----------+----------+----------------------------------------------+
| IV-U.J-25 | C.7      | Special cases\--section says \"see section   |
|           |          | above for the business rules on diversion,   |
|           |          | terminations and reshipments\" but these 3   |
|           |          | types of situations are not covered at all   |
|           |          | in Attachment U.J.                           |
+-----------+----------+----------------------------------------------+
| IV-U.J-25 | C.9      | See comments above about DD619/619, and 1671 |
|           |          | being inaccurate and/or unnecessary in       |
|           |          | DPS/Families First environment.              |
+-----------+----------+----------------------------------------------+
| IV-U.J-26 | D        | There seems to be quite a bit of redundancy  |
|           |          | with sections B and C above. This just leads |
|           |          | to confusion especially when changes need to |
|           |          | be made to the business rules because you    |
|           |          | have to catch each place a subject is        |
|           |          | covered. Why isn\'t there just one section   |
|           |          | for \"shipment award\" for example and       |
|           |          | covering all the participants in the         |
|           |          | process?                                     |
+-----------+----------+----------------------------------------------+
| IV-U.J-27 | D.1.e    | See comments above that Attachment U.Q       |
|           | and      | indicates that the punitive action for a     |
|           | D.1.f    | shipment refusal is suspension from \"that   |
|           |          | PPSO\'s market\" not from the entire market. |
|           |          | This is a critical difference with hugely    |
|           |          | different consequences for the TSP. All      |
|           |          | sections of the business rules should match  |
|           |          | using the very same language so that         |
|           |          | conflicting language doesn\'t lead to        |
|           |          | interpretation issues.                       |
+-----------+----------+----------------------------------------------+
| IV-U.J-27 | D.1 Note | This section again seems to indicate that    |
|           |          | spread dates can be used and entered into    |
|           |          | DPS after the premove survey, which we agree |
|           |          | with, but which conflicts with information   |
|           |          | elsewhere in this document.                  |
+-----------+----------+----------------------------------------------+
| IV-U.J-27 | D.2      | Short fuse shipments are defined differently |
|           |          | here than in B.3.c. B.3.c says they are      |
|           |          | shipments booked with pickup within 5        |
|           |          | business days or less, but this section just |
|           |          | says 5 days. Our understanding all along and |
|           |          | the basis for our rate filing was that short |
|           |          | notice would be 5 BUSINESS days or less.     |
+-----------+----------+----------------------------------------------+
| IV-U.J-27 | D.2      | This section says \"if a TSP refuses a       |
|           |          | shipment, the TSP is not eligible to receive |
|           |          | shipments in that category for 30 calendar   |
|           |          | days.\" That is another difference in        |
|           |          | language between Attachment U.Q and between  |
|           |          | section D.1.e and D.1.f in this Attachment.  |
|           |          | It is absolutely critical that the document  |
|           |          | use the same language exactly in all these   |
|           |          | sections.                                    |
+-----------+----------+----------------------------------------------+
| IV-U.J-27 | D.2      | This section agrees with our understanding   |
|           |          | that the TSP does not have to list its       |
|           |          | origin and destination agents, but it        |
|           |          | conflicts with information in other portions |
|           |          | of the business rules as noted in our        |
|           |          | comments above.                              |
+-----------+----------+----------------------------------------------+
| IV-U.J-27 | D.3.d    | The TSP should not be required to enter      |
|           |          | premove survey data within 7 days of         |
|           |          | pack/pickup date since that means that they  |
|           |          | would have to actually perform the premove   |
|           |          | survey earlier than within 7 days of the     |
|           |          | pack/pickup date. On short fuse shipments,   |
|           |          | this may be physically impossible. The rules |
|           |          | should state that the premove survey should  |
|           |          | be conducted in enough time to allow the TSP |
|           |          | and member to properly prepare for the       |
|           |          | shipment. In the case of a short fuse        |
|           |          | shipment, there should be no time limit      |
|           |          | imposed for the premove survey.              |
+-----------+----------+----------------------------------------------+
| IV-U.J-27 | D.3.d    | This language should be carefully clarified. |
|           |          | We believe it should state \"The TSP must    |
|           |          | contact the member/employee within 7 days of |
|           |          | shipment booking to arrange a time to        |
|           |          | perform the survey.\" As it is currently     |
|           |          | worded, it appears to state that the premove |
|           |          | survey itself has to be performed within 7   |
|           |          | days of shipment booking and that is simply  |
|           |          | not practical nor effective, particularly    |
|           |          | when a shipment has been booked              |
|           |          | significantly in advance of the actual move  |
|           |          | dates.                                       |
+-----------+----------+----------------------------------------------+
| IV-U.J-28 | D.5      | See all comments for C.5 (any portions)      |
|           |          | above\--all the language here is redundant   |
|           |          | and all of our comments apply to D as well.  |
+-----------+----------+----------------------------------------------+
| IV-U.J-30 | D.8.b    | Weights\--If the TSP fails to enter shipment |
|           |          | weights, it cannot continue to process the   |
|           |          | shipment in DPS, including not being able to |
|           |          | offer it for delivery. Occasionally a        |
|           |          | shipment is not weighed at origin and must   |
|           |          | be \"backweighed\" at destination. DPS       |
|           |          | should allow a TSP to designate that this    |
|           |          | situation exists and process a shipment for  |
|           |          | SIT or delivery, entering the weights after  |
|           |          | the shipment has been delivered. Some causes |
|           |          | might be snow on the scales, scale not       |
|           |          | operational, driver error, etc.              |
+-----------+----------+----------------------------------------------+
| IV-U.J-31 | D.8.c    | Our understanding is that in transit updated |
|           |          | information is not required to be put into   |
|           |          | DPS (e.g. every time the truck a shipment is |
|           |          | on enters another portion of its trip or     |
|           |          | updates the ETA on the shipment in           |
|           |          | question). Ultimately when DPS has a 2-way   |
|           |          | interface with the TSP\'s computer system    |
|           |          | more defined real-time information should be |
|           |          | available but at this time, it is totally    |
|           |          | impractical to duplicate this information    |
|           |          | into DPS. The TSP still has to be responsive |
|           |          | to requests for an ITV update, but it can do |
|           |          | so with its own tracking system.             |
+-----------+----------+----------------------------------------------+
| IV-U.J-44 | E.8      | Block 1 of the GBL does not need to show the |
|           |          | TSP\'s agent any longer since it may often   |
|           |          | not be entered by the TSP as it is not a     |
|           |          | mandatory field.                             |
+-----------+----------+----------------------------------------------+
| IV-U.J-45 | E.8.a.8  | Block 8 RDD should allow for delivery spread |
|           |          | dates to be entered.                         |
+-----------+----------+----------------------------------------------+
| IV-U.J-45 | E.8.a.10 | The member\'s SSAN is not supposed to be     |
|           |          | displayed on the GBL for security reasons.   |
|           |          | The TSP has no need for it and certainly no  |
|           |          | more than the last 4 digits should be        |
|           |          | displayed if anything at all.                |
+-----------+----------+----------------------------------------------+
| IV-U.J-49 | E.8.     | On shipments where SIT is not authorized,    |
|           | a.25.a.3 | the business rules should clarify that when  |
|           |          | the TSP arrives at destination to deliver    |
|           |          | the shipment, SIT will still be approved     |
|           |          | under the rest of the guidance of these      |
|           |          | business rules. The notation that SIT is not |
|           |          | authorized should simply be a matter of what |
|           |          | the member is entitled to and may mean that  |
|           |          | he or she incurs excess cost, but it should  |
|           |          | not imply any requirement on the part of the |
|           |          | TSP to place the shipment into storage other |
|           |          | than at government expense. The TSP should   |
|           |          | be entitled to SIT authorization or waiting  |
|           |          | time if the member is not able to take       |
|           |          | delivery at destination. Anything else is an |
|           |          | internal matter between DOD and the military |
|           |          | service member.                              |
+-----------+----------+----------------------------------------------+
| IV-U.J-50 | E.8.     | On direct deliveries, GBL should not state   |
|           | a.25.d.1 | \"Before completing the delivery, the TSP    |
|           |          | must notify the TO or duty officer specified |
|           |          | in Block 20.\" The TSP is allowed to make    |
|           |          | direct deliveries without pre-clearing the   |
|           |          | delivery under DPS/Families First.\"         |
+-----------+----------+----------------------------------------------+
| A         |          |                                              |
| ttachment |          |                                              |
| U.Q       |          |                                              |
| Quality   |          |                                              |
| A         |          |                                              |
| ssurance, |          |                                              |
| 2/27/08   |          |                                              |
+-----------+----------+----------------------------------------------+
| IV-U.Q-2  | B.5.a    | This section states that TMA\'s and DTR Part |
|           |          | IV may apply as well as information in       |
|           |          | Attachment U.Q, however many parts of DTR    |
|           |          | Part IV and various TMA\'s clearly no longer |
|           |          | have any application. The Business Rules     |
|           |          | should clarify which prevails\--the Business |
|           |          | Rules or DTR Part IV                         |
+-----------+----------+----------------------------------------------+
| IV-U.Q-   | Entire   | Throughout this document language has been   |
|           | document | changed from earlier versions so that        |
|           |          | wherever the words \"can\" or \"may\" were   |
|           |          | used in regards to action by the PPSO, the   |
|           |          | language now states \"must\" or \"will.\"    |
|           |          | This appears to remove all discretion and    |
|           |          | traffic management from the PPSO.            |
+-----------+----------+----------------------------------------------+
| IV-U.Q-5  | C        | See previous comments that referred to       |
|           | .1.a.2.a | differing language about whether a           |
|           |          | suspension for shipment refusal is for the   |
|           |          | entire market (dHHG, iHHG or iUB) or only    |
|           |          | the market from that GBLOC. This section     |
|           |          | appears to have correct language.            |
+-----------+----------+----------------------------------------------+
| IV-U.Q-5  | C        | This is an example of unintended             |
|           | .1.a.2.c | consequences of changing \"may\" to \"must\" |
|           |          | since this language probably should read     |
|           |          | \"Suspension may be for all traffic out of a |
|           |          | GBLOC/BLOC.\" Otherwise, this makes no sense |
|           |          | as one of three options for levels of        |
|           |          | suspensions.                                 |
+-----------+----------+----------------------------------------------+
| IV-U.Q-5  | C.1.b    | How will a TSP be notified of SDDC punitive  |
|           |          | actions? Will SDDC use the DD1814 form?      |
+-----------+----------+----------------------------------------------+
| IV-U.Q-6  | C.2      | Many companies use clean neat T-shirts with  |
|           |          | the company name and logo on it but not with |
|           |          | the individual person\'s name on the shirt.  |
|           |          | Providing uniform shirts with the individual |
|           |          | person\'s name is not a standard practice    |
|           |          | and would be a huge cost consideration in    |
|           |          | providing service on DOD shipments.          |
+-----------+----------+----------------------------------------------+
| IV-U.Q-6  | C.3.a    | As stated previously in comments herein, if  |
|           |          | SDDC disqualifies, disapproves or revokes    |
|           |          | authority for a TSP, it must issue an        |
|           |          | announcement of that action so that other    |
|           |          | TSP\'s don\'t have to constantly search thru |
|           |          | the list of approved TSP\'s to see if        |
|           |          | someone is still in SDDC\'s good graces.     |
+-----------+----------+----------------------------------------------+
| IV-U.Q-7  | C.3.d    | We are unclear as to why SDDC is concerned   |
|           |          | at all with trip leasing or other such legal |
|           |          | instruments in this section. The             |
|           |          | method/legal instrument that a TSP uses to   |
|           |          | interact with another TSP should not be any  |
|           |          | issue with SDDC so long as the TSP to whom a |
|           |          | shipment is tendered maintains full          |
|           |          | responsibility for its shipments from        |
|           |          | beginning to end.                            |
+-----------+----------+----------------------------------------------+
| IV-U.Q-7  | C.4.     | What mechanism does SDDC/DPS have for        |
|           |          | reinstating a warehouse to DPS after a       |
|           |          | disqualification? What mechanism does        |
|           |          | SDDC/DPS have to ensure that newly-approved  |
|           |          | warehouses are added to the list of eligible |
|           |          | warehouses in DPS as soon as possible after  |
|           |          | qualification? We have suggested that it be  |
|           |          | RSMO\'s responsibility to enter this data    |
|           |          | into DPS as soon as they qualify a           |
|           |          | warehouse. What about if a local PPSO        |
|           |          | disqualifies and then reinstates a           |
|           |          | warehouse? How do TSP\'s know when a         |
|           |          | warehouse is eligible or ineligible?         |
+-----------+----------+----------------------------------------------+
| IV-U.Q-8  | D.3.a.5  | See comments above with our concerns about   |
|           |          | statistical validity. Frankly, the note at   |
|           |          | the end of subsection D.3.a.5.d gives us no  |
|           |          | confidence. In fact, it seems to admit that  |
|           |          | the statistical validity of the ICSS/CSS     |
|           |          | process is not reliable. *\"Surveys in       |
|           |          | industry and government often have no formal |
|           |          | statistical rigor applied and yet are        |
|           |          | frequently used for management information   |
|           |          | and decision making.\"*                      |
+-----------+----------+----------------------------------------------+
| IV-U.Q-11 | D.3.b.3  | As stated earlier in comments herein, we     |
|           | Note     | believe that certain elements of the claims  |
|           |          | score should be appealable, in particular    |
|           |          | the question of whether or not the claim     |
|           |          | settlement was sent within 30 days. If the   |
|           |          | TSP can prove that it was sent within 30     |
|           |          | days, then the TSP ought to be able to rebut |
|           |          | the member\'s comments.                      |
+-----------+----------+----------------------------------------------+
| IV-U.Q-10 | D.3.b    | Please see all our comments above regarding  |
|           |          | Attachment U.F as they pertain to the Claims |
|           |          | Score.                                       |
+-----------+----------+----------------------------------------------+
| IV-U.Q-11 | D.4      | How does DPS show a TSP\'s overall BVS       |
|           |          | ranking among other TSP\'s? This section     |
|           |          | says that \"A TSP may request its overall    |
|           |          | BVS ranking among TSP\'s based on its best   |
|           |          | value score (i.e., 14th out of 121           |
|           |          | TSP\'s).\" We have not seen this             |
|           |          | functionality and it is very important as a  |
|           |          | TSP tries to determine its rate filing       |
|           |          | strategy.                                    |
+-----------+----------+----------------------------------------------+
| IV-U.Q-11 | D.5      | We find this section about the annual MPS    |
|           |          | and whether a TSP can file rates or not to   |
|           |          | be confusing. We request that SDDC provide   |
|           |          | some hypothetical examples that will allow   |
|           |          | us to see how you envision this operating.   |
+-----------+----------+----------------------------------------------+
| IV-U.Q-11 | D.6      | See previous comments about the CS. When the |
|           |          | claims metrics were developed, the Business  |
|           |          | Process Working Groups (BPWG\'s) responsible |
|           |          | for them agreed that the claims data would   |
|           |          | not be used for the first year, not just so  |
|           |          | that sufficient data could be captured. The  |
|           |          | most significant reason that we agreed not   |
|           |          | to use the data till sometime after the      |
|           |          | first year was to model what happened to     |
|           |          | TSP\'s BVS when claims metrics were added.   |
|           |          | It was agreed that we could not be sure of   |
|           |          | unintended consequences without testing how  |
|           |          | the BVS\'s stacked up after inclusion of     |
|           |          | claims metrics. Many TSP\'s were concerned   |
|           |          | that there are a number of items outside of  |
|           |          | our control in the claims process, for       |
|           |          | example, the length of time to settle a      |
|           |          | claim if one is to do a proper investigation |
|           |          | including getting repairs done or estimates  |
|           |          | of repairs. The claims metrics, in effect,   |
|           |          | \"punish\" a TSP from the 1st day after      |
|           |          | filing of a claim. The business rules should |
|           |          | reflect that the reason for waiting till     |
|           |          | after the first year to incorporate claims   |
|           |          | metrics was to determine the impact on the   |
|           |          | BVS in a model environment before including  |
|           |          | it in a TSP\'s score, which may mean that    |
|           |          | inclusion is sometime after the 2nd year.    |
+-----------+----------+----------------------------------------------+
| IV-U.Q-12 | E        | See comments regarding Attachment U.J.       |
|           |          | B.11.c\--Evaluation of TSP performance       |
|           |          | should only begin when a shipment is offered |
|           |          | to the TSP. DPS/Families First does not      |
|           |          | envision offering shipments to anyone other  |
|           |          | than the TSP. From time to time, PPSO\'s     |
|           |          | contact a local agent to check to see if     |
|           |          | they can handle a shipment, but the TSP      |
|           |          | should not be committed to that shipment     |
|           |          | unless the TSP accepts it. No agents or      |
|           |          | designated representatives can accept        |
|           |          | shipments from DPS on behalf of a TSP.       |
+-----------+----------+----------------------------------------------+
| IV-U.Q-13 | E.1 and  | DPS did not function properly regarding      |
|           | 2        | Letters of Warning and Letters of Suspension |
|           |          | during industry testing. The TSP was         |
|           |          | supposed to receive an email notice that an  |
|           |          | LOW was issued, but the notice did not       |
|           |          | always generate. The email had a link to     |
|           |          | click on to see the details of the LOW, but  |
|           |          | the links were non-functional. SDDC needs to |
|           |          | make sure that the method for notifying a    |
|           |          | TSP of both LOW\'s and Letters of Suspension |
|           |          | works and that a TSP is advised in timely    |
|           |          | and in a manner that it can see the details  |
|           |          | of the punitive action.                      |
+-----------+----------+----------------------------------------------+
| IV-U.Q-14 | E.2.a.2  | This section says that TSP\'s must reply to  |
|           |          | suspensions with 15 days. We believe that    |
|           |          | the TSP should be able to request a 15-day   |
|           |          | extension for reply if the investigation of  |
|           |          | the violation takes longer than 15 days, but |
|           |          | in any event, they must respond within 30    |
|           |          | days of effective date of the suspension.    |
+-----------+----------+----------------------------------------------+
| IV-U.Q-16 | E.2.c.1  | We would like clarification on how DPS takes |
|           |          | into consideration domestic and              |
|           |          | international time zones to avoid            |
|           |          | automatically removing a TSP inadvertently   |
|           |          | for shipment refusal. Over weekends and      |
|           |          | holidays, it is possible to have an overseas |
|           |          | PPSO offer a shipment that will not be       |
|           |          | worked by the TSP till the next working day, |
|           |          | which may be more than 24 hours from the     |
|           |          | time of shipment offer. DPS should take into |
|           |          | consideration the location of the TSP (time  |
|           |          | zone) so that the TSP has 24 work hours to   |
|           |          | respond, not just 24 clock hours. We are not |
|           |          | clear how DPS will work in this regard since |
|           |          | it was not able to be tested. In the test    |
|           |          | environment, we worked with imaginary date   |
|           |          | scenarios that did not allow enough time to  |
|           |          | pass to see if the system recognized the     |
|           |          | time zone differences involved. Since the    |
|           |          | punishment for shipment refusal is so        |
|           |          | severe, TSP\'s need assurance that this      |
|           |          | function works properly.                     |
+-----------+----------+----------------------------------------------+
| IV-U.Q-17 | E.2.c.2  | Previously, a PPSO had discretion whether to |
|           |          | issue an immediate suspension for any of the |
|           |          | reasons listed in a-k in this subsection. We |
|           |          | believe that the last sentence of the first  |
|           |          | paragraph in this section should read \"An   |
|           |          | immediate suspension *may* be issued for the |
|           |          | following violations . . . \"                |
+-----------+----------+----------------------------------------------+
| IV-U.Q-17 | E        | This section conflicts with the definition   |
|           | .2.c.2.f | of RDD in Attachment U.J, B.3.g. The TSP\'s  |
|           |          | requirement is to deliver the shipment by    |
|           |          | the RDD, which is usually the member\'s      |
|           |          | desired delivery date, but may not be if no  |
|           |          | agreement was reached because the member\'s  |
|           |          | desired date is earlier than the required    |
|           |          | transit time. Per Attachment U.J., the RDD   |
|           |          | is then based on the minimum transit time    |
|           |          | allowed. If the TSP agrees to the member\'s  |
|           |          | desired delivery date, then the desired      |
|           |          | delivery date becomes the RDD. We believe    |
|           |          | that a suspension should only result if the  |
|           |          | shipment remains at origin on or after the   |
|           |          | RDD, not the member\'s desired delivery      |
|           |          | date. It has to be one or the other. If the  |
|           |          | TSP did not agree to deliver the shipment by |
|           |          | the member\'s desired delivery date, then it |
|           |          | should not be held accountable for that.     |
+-----------+----------+----------------------------------------------+
| IV-U.Q-18 | E        | The second sentence of this section cannot   |
|           | .2.c.2.k | be correct. In item (j) just above, it       |
|           |          | spells out that a TSP can be suspended for   |
|           |          | using a disapproved, disqualified or revoked |
|           |          | TSP for movement of a shipment. However,     |
|           |          | there is nothing anywhere else in the        |
|           |          | regulations or business rules that says we   |
|           |          | can\'t use a non-DOD approved TSP as a       |
|           |          | subcontractor. In fact, section C.3.c in     |
|           |          | this Attachment U.Q specifically states      |
|           |          | \"TSP\'s that have never applied for DOD     |
|           |          | approval may be used as sub-contractors by   |
|           |          | TSP\'s on the Active list.\"                 |
+-----------+----------+----------------------------------------------+
| IV-U.Q-19 | E.3.a.3  | This is the only reference that says that a  |
|           |          | punitive action may be taken against a TSP   |
|           |          | *if one of its associated CFAC\'s* commits   |
|           |          | another violation during the next 180 days.  |
|           |          | The TSP committing the violation is the one  |
|           |          | who should be punished, not any TSP in CFAC. |
|           |          | Just as SDDC wants each TSP to stand alone   |
|           |          | for qualification purposes and financial     |
|           |          | health, the TSP should stand alone for       |
|           |          | punitive action.                             |
+-----------+----------+----------------------------------------------+
| IV-U.Q-20 | E.3.c.4  | Short fuse shipments are defined differently |
|           |          | here than elsewhere in the Business Rules.   |
|           |          | We believe that the intent was that short    |
|           |          | fuse (short notice) shipments were to be     |
|           |          | defined as anything offered within 5         |
|           |          | business days or less. The Business Rules    |
|           |          | should be consistent.                        |
+-----------+----------+----------------------------------------------+
| IV-U.Q-23 | E.5.c.3  | Here, short fused shipments are correctly    |
|           |          | identified as being 5 business days or less  |
|           |          | from pickup.                                 |
+-----------+----------+----------------------------------------------+
| IV-U.Q-24 | E.7.q    | We will comment on this again in relation to |
|           |          | Attachment U.R., however, it is virtually    |
|           |          | impossible for a TSP to know about any       |
|           |          | outstanding arrest warrant on an employee,   |
|           |          | contractor or sub-contractor. We can and do  |
|           |          | perform background checks and run motor      |
|           |          | vehicle records. However, the MVR is limited |
|           |          | to the state in which the CDL is issued and  |
|           |          | there is no 50-state access point to check   |
|           |          | for convictions or outstanding arrest        |
|           |          | warrants on motor vehicle violations. As to  |
|           |          | criminal arrest warrants, we can only check  |
|           |          | for the state of residence of the            |
|           |          | individual. Private enterprise does not have |
|           |          | access to the Law Enforcement Information    |
|           |          | Network (LEIN) that police departments or    |
|           |          | Military Police or FBI may have access to.   |
|           |          | We think this is an important area and wish  |
|           |          | to comply but there is no way to assure that |
|           |          | we will know about any violation, conviction |
|           |          | or outstanding arrest warrant that may be    |
|           |          | issued by any law enforcement authority      |
|           |          | anywhere in the country. Furthermore,        |
|           |          | knowing about outstanding warrants is only a |
|           |          | spot-check that is accurate as of the time   |
|           |          | the search is done. A TSP should show that   |
|           |          | it has an acceptable method for checking     |
|           |          | backgrounds as thoroughly as possible and    |
|           |          | that it does so on a regular basis with all  |
|           |          | employees.                                   |
+-----------+----------+----------------------------------------------+
| IV-U.Q-27 | E.8.a.4  | A TSP would not know that a CSS was counted  |
|           |          | in calculation of its BVS until the          |
|           |          | calculation is done at each performance      |
|           |          | period. Therefore, this is one case where    |
|           |          | the comprehensive BVS score calculated at    |
|           |          | the end of each performance period should be |
|           |          | appealable. If it can be shown that a        |
|           |          | shipment originating out of NTS or an        |
|           |          | inbound reship was used in the calculation   |
|           |          | of the linehaul TSP\'s BVS, it should be     |
|           |          | removed from the BVS calculation at the      |
|           |          | request of the TSP.                          |
+-----------+----------+----------------------------------------------+
| IV-U.Q-27 | E.8.a.4  | A TSP should be notified each time that BVS  |
|           |          | scores are being calculated and be given a   |
|           |          | report in DPS of what shipments and          |
|           |          | individual scores are contained in that BVS  |
|           |          | comprehensive score. The TSP should have a   |
|           |          | fixed number of days to advise SDDC if the   |
|           |          | TSP determines that the data in DPS is       |
|           |          | erroneous or contains shipments that should  |
|           |          | not be part of its BVS comprehensive score.  |
+-----------+----------+----------------------------------------------+
| IV-U.Q-28 | F        | We question why there is any detail in this  |
|           |          | section at all. All of the FRV rules are     |
|           |          | spelled out in complete detail in the 400NG  |
|           |          | and the International Tariff. This is just   |
|           |          | another location where text has to be        |
|           |          | updated if any changes are made and it is a  |
|           |          | very high level overview. We think Section F |
|           |          | here should simply state that the rules for  |
|           |          | FRV are contained in the 400NG tariff and    |
|           |          | the International Tariff and leave it at     |
|           |          | that.                                        |
+-----------+----------+----------------------------------------------+
| IV-U.Q-30 | G        | In addition to the physical address, SDDC    |
|           |          | should provide an email address for appeals  |
|           |          | to be filed since one of the goals of        |
|           |          | DPS/Families First is to reduce paperwork,   |
|           |          | and it will speed communications.            |
+-----------+----------+----------------------------------------------+
| IV-U.Q-31 | I        | SDDC should provide an email address for     |
|           |          | providing the required RDD status report in  |
|           |          | the OTO program, since this system says they |
|           |          | must be sent via DPS and email. Sending them |
|           |          | by regular mail is slow, cumbersome and      |
|           |          | inefficient. Frankly, we don\'t understand   |
|           |          | why an email report is required if the data  |
|           |          | is entered in DPS too.                       |
+-----------+----------+----------------------------------------------+
| IV-U.Q-38 | Table    | Should refer to Market level suspension from |
|           | U.Q.1,   | the PPSO level                               |
|           | Note 2   |                                              |
+-----------+----------+----------------------------------------------+
| A         |          |                                              |
| ttachment |          |                                              |
| U.R,      |          |                                              |
| Tender of |          |                                              |
| Service,  |          |                                              |
| 3/18/08   |          |                                              |
+-----------+----------+----------------------------------------------+
| IV-U.R-1  | At       | There is no attachment 1 in this document;   |
|           | tachment | it starts out with Attachment 2. What is     |
|           | 1        | missing?                                     |
+-----------+----------+----------------------------------------------+
| IV-U.R-2  | At       | Since a TSP is no longer required to Letters |
|           | tachment | of Intent on file, then it stands to reason  |
|           | 2, 1.d.2 | that they would also not have a              |
|           |          | comprehensive list of agents, other than the |
|           |          | list that is populated in DPS. It appears    |
|           |          | that this requirement to provide lists of    |
|           |          | surface and aerial port agents and overseas  |
|           |          | general agents is no longer necessary.       |
+-----------+----------+----------------------------------------------+
| IV-U.R-2  | At       | This section contains a new requirement for  |
|           | tachment | no additional TSP seeking entry into the     |
|           | 2, 1.d.3 | program to share resources with any other    |
|           |          | TSP. This language is so ambiguous as to be  |
|           |          | unenforceable. For example, this would       |
|           |          | appear to preclude any new freight           |
|           |          | forwarders from entering the program since,  |
|           |          | by definition, a freight forwarder has no    |
|           |          | trucks and would have to utilize other       |
|           |          | approved TSP\'s to provide linehaul          |
|           |          | transportation services\--which would be     |
|           |          | shared resources; any TSP who uses the agent |
|           |          | of another TSP to provide origin or          |
|           |          | destination services would be sharing        |
|           |          | resources; any TSP who interchanges traffic  |
|           |          | with another TSP for hauling services (which |
|           |          | is totally approved in this program) would   |
|           |          | be sharing resources; any TSP who uses a     |
|           |          | factoring company that is used by another    |
|           |          | TSP would be sharing resources; any TSP who  |
|           |          | uses a claims settlement service provider    |
|           |          | used by another TSP would be sharing         |
|           |          | resources; any TSP who uses a 3rd party      |
|           |          | billing service company used by another TSP  |
|           |          | would be sharing resources; any relocations  |
|           |          | services broker would have to use van lines  |
|           |          | and van line agents to provide all of its    |
|           |          | services and it would then be sharing        |
|           |          | resources. We\'re sure there are many other  |
|           |          | examples (insurance carriers, bonding        |
|           |          | companies, rate filing firms, CPA, box       |
|           |          | suppliers, forms, etc., etc.) But, as        |
|           |          | worded, this section is unenforceable and is |
|           |          | discriminatory to any new freight forwarder  |
|           |          | or carrier seeking to enter the program. It  |
|           |          | would also have a disproportionately harmful |
|           |          | impact on potential small and small          |
|           |          | disadvantaged businesses which seek to enter |
|           |          | the program.                                 |
+-----------+----------+----------------------------------------------+
| IV-U.R-2  | At       | We are unable to find any place in the TOS   |
|           | tachment | where it defines what the list of CONUS      |
|           | 2, 1.d.4 | Origin SIT facilities is supposed to look    |
|           |          | like or what it is for. In any event, we     |
|           |          | think it is no longer meaningful, since (as  |
|           |          | stated above) there are no more letters of   |
|           |          | intent so there should be no need to provide |
|           |          | a list of agents or warehouses or any such   |
|           |          | thing. Likewise, there should be no          |
|           |          | requirement to produce a Certificate of      |
|           |          | Agency Agreement. The TSP should be free to  |
|           |          | use any service providers it chooses to      |
|           |          | perform work for DOD, as long as storage is  |
|           |          | placed into DOD-approved warehouses and as   |
|           |          | long as we meet the requirements in          |
|           |          | Attachment U.Q about not using disapproved,  |
|           |          | disqualified or revoked TSP\'s.              |
+-----------+----------+----------------------------------------------+
| IV-U.R-3  | At       | This section conflicts with the Rules in the |
|           | tachment | TSP Qualifications Document (Pamphlet 55-4)  |
|           | 2, 1.e.1 | Attachment C. That document says that if     |
|           |          | SDDC requires a hard copy of a TSP\'s        |
|           |          | audited or reviewed financial statement, it  |
|           |          | must be provided within 5 working days,      |
|           |          | while Attachment U.R. here says it must be   |
|           |          | provided within 10 business days. The        |
|           |          | documents should be consistent with one      |
|           |          | another.                                     |
+-----------+----------+----------------------------------------------+
| IV-U.R-3  | At       | This section says that the TSP\'s financial  |
|           | tachment | statements must meet SDDC\'s minimal         |
|           | 2,1.e.3  | requirements as stated in Attachment U.Q     |
|           |          | Qualification Business Rules. However, the   |
|           |          | Qualification Business Rules are actually    |
|           |          | Attachment C.                                |
+-----------+----------+----------------------------------------------+
| IV-U.R-4  | At       | We don\'t understand why this section is     |
|           | tachment | limited to international SIT warehouse       |
|           | 2, 2.a.1 | facilities? All SIT warehouse facilities     |
|           |          | need to be inspected and approved and we     |
|           |          | think this rule ought to reflect that        |
|           |          | requirement.                                 |
+-----------+----------+----------------------------------------------+
| IV-U.R-4  | At       | The requirement to assure that no TSP        |
|           | tachment | representative has an outstanding arrest     |
|           | 3, 2     | warrant is simply impossible to comply with  |
|           |          | by any TSP. First of all, if a private       |
|           |          | individual or company could even find out    |
|           |          | about outstanding arrest warrants (which it  |
|           |          | can\'t), the information would only be       |
|           |          | accurate on the day the report is run. There |
|           |          | is no way that any TSP can guarantee on any  |
|           |          | given day anywhere in the world that someone |
|           |          | doesn\'t have an outstanding arrest warrant. |
|           |          | On international shipments, it is totally    |
|           |          | impossible to make that guarantee on foreign |
|           |          | laborers since there is no method available  |
|           |          | to make such a check. For shipments being    |
|           |          | serviced on U.S. soil, even a criminal       |
|           |          | background check is not totally certain to   |
|           |          | catch every single conviction someone may    |
|           |          | have and there is no way that a criminal     |
|           |          | background check can catch outstanding       |
|           |          | arrest warrants anywhere in the United       |
|           |          | States. Without access to the national       |
|           |          | (NCIC) database, a carrier can not know      |
|           |          | every possible jurisdiction that may have an |
|           |          | outstanding warrant. Carriers do not have    |
|           |          | and can not get that access. In a recent     |
|           |          | situation that we handled, the driver lived  |
|           |          | and worked in FL and NJ over the last 10     |
|           |          | years. The criminal background check         |
|           |          | contacted the courts in the counties where   |
|           |          | he lived and worked during that time with no |
|           |          | outstanding warrants found. There was an     |
|           |          | outstanding civil infraction that had not    |
|           |          | been paid from NY State in 1999. That did    |
|           |          | not show up until he arrived to load a       |
|           |          | shipment at Ft. Drum, NY, where the gate     |
|           |          | officers ran an NCIC check and found the     |
|           |          | warrant, at which time he was taken into     |
|           |          | custody and had to settle up with the NY     |
|           |          | Court before he could continue. This man had |
|           |          | been driving for us for years and this       |
|           |          | outstanding arrest warrant had not shown up  |
|           |          | on any criminal background check nor was he  |
|           |          | ever stopped at any other military           |
|           |          | installation, even though they all had       |
|           |          |                                              |
|           |          | access to the NCIC.                          |
|           |          |                                              |
|           |          | The firm we use to perform our background    |
|           |          | checks (Kerby Baily & Associates) is run by  |
|           |          | former FBI agents. They have advised us that |
|           |          | they are unable to always find outstanding   |
|           |          | arrest warrants, particularly on             |
|           |          | misdemeanors. A recent communication from    |
|           |          | them stated *"Pre-employment background      |
|           |          | investigations are conducted within the      |
|           |          | maximum allowable scope as outlined by the   |
|           |          | Fair Credit Reporting Act (FCRA).            |
|           |          | Accordingly, we conduct criminal record      |
|           |          | research in the counties associated with the |
|           |          | subject reported during the past seven years |
|           |          | of activity. If a criminal record or warrant |
|           |          | existed outside of these counties, it would  |
|           |          | not be located. National arrest and warrant  |
|           |          | information is available to law enforcement  |
|           |          | agencies only vial the Law Enforcement       |
|           |          | Information Network (LEIN). The FCRA         |
|           |          | prohibits any use of LEIN information."*     |
|           |          |                                              |
|           |          | We think that this requirement should be     |
|           |          | that a TSP should perform criminal           |
|           |          | background checks on its employees and       |
|           |          | contractors before they are hired or put     |
|           |          | under contract. If SDDC wants to make it an  |
|           |          | ongoing requirement that we should check     |
|           |          | their background semi-annually or annually,  |
|           |          | that would be manageable but it would have a |
|           |          | cost associated with it. This requirement    |
|           |          | was placed into the TOS after TSP\'s had     |
|           |          | already filed their rates for Families First |
|           |          | so we had no opportunity to roll the cost    |
|           |          | into our rates. Therefore, this requirement  |
|           |          | should not be effective until the next time  |
|           |          | that TSP\'s must file rates for Families     |
|           |          | First. No matter what, however, it is        |
|           |          | impossible to comply with the regulation as  |
|           |          | it is currently worded.                      |
+-----------+----------+----------------------------------------------+
| IV-U.R-5  | At       | There should be some definition as to what   |
|           | tachment | types of reports that SDDC may request that  |
|           | 3, 4     | are not available in DPS.                    |
+-----------+----------+----------------------------------------------+
| IV-U.R-5  | At       | The requirement to notify the origin PPSO of |
|           | tachment | a TSP\'s decision to use an alternate        |
|           | 3, 7     | carrier to service the shipment is totally   |
|           |          | unnecessary. First of all, the TSP to whom   |
|           |          | the shipment is tendered is totally          |
|           |          | responsible for the movement of the shipment |
|           |          | from beginning to end. We have no            |
|           |          | requirement to notify the PPSO of which      |
|           |          | agents we are using (except for placement of |
|           |          | SIT in a government approved warehouse so it |
|           |          | makes no sense that we would have to notify  |
|           |          | of an alternate carrier. Freight forwarders  |
|           |          | have no trucks so they would have to notify  |
|           |          | the origin PPSO on every shipment. Crated    |
|           |          | shipments almost always are transported on   |
|           |          | \"alternate\"carriers, that being a freight  |
|           |          | transportation company versus a household    |
|           |          | goods carrier. One of the purposes of        |
|           |          | DPS/Families First was to adopt commercial   |
|           |          | practice and commercial practice uses        |
|           |          | alternate carriage to maximize efficiency in |
|           |          | loading trucks. A TSP should be required to  |
|           |          | advise a PPSO or SDDC of the name of an      |
|           |          | alternate carrier being used upon request,   |
|           |          | but should not have the burden of notifying  |
|           |          | the PPSO, particularly since the PPSO can\'t |
|           |          | tell the TSP they cannot use alternate       |
|           |          | carriage. This is a practice from the old    |
|           |          | program that should not carry over into      |
|           |          | these business rules.                        |
+-----------+----------+----------------------------------------------+
| IV-U.R-6  | At       | As stated previously in comments herein, it  |
|           | tachment | was our understanding that if there is no    |
|           | 3, 9     | destination delivery address in DPS, the TSP |
|           |          | should be able to enter the arrival of the   |
|           |          | shipment in DPS and that DPS should          |
|           |          | automatically approve destination SIT        |
|           |          | without further intervention or approval by  |
|           |          | the PPSO.                                    |
+-----------+----------+----------------------------------------------+
| IV-U.R-7  | At       | This section should read \"I hereby reaffirm |
|           | tachment | it is my responsibility to pickup on the     |
|           | 3,       | agreed date and deliver personal property    |
|           | 13.b.1   | shipments by the agreed date.\" We also      |
|           |          | believe that an inconvenience claim should   |
|           |          | only be payable if there is a delivery       |
|           |          | address in DPS.                              |
+-----------+----------+----------------------------------------------+
| IV-U.R-9  | At       | We don\'t believe it is in the best interest |
|           | tachment | of the member or the DOD to require us to    |
|           | 3,       | provide or use the member\'s Social Security |
|           | 19.a.3   | Number for any purposes. The member\'s name  |
|           |          | and the GBL number should be sufficient to   |
|           |          | identify the shipment.                       |
+-----------+----------+----------------------------------------------+
| IV-U.R-10 | At       | This section contains language that appears  |
|           | tachment | to show a more accurate understanding of     |
|           | 4, 1.b   | spread dates for delivery and other business |
|           |          | rules should be rewritten to accommodate     |
|           |          | this tool for maximizing efficient use of    |
|           |          | equipment and allowing the member to plan    |
|           |          | when they need to be available for delivery. |
+-----------+----------+----------------------------------------------+
| IV-U.R-11 | At       | The TSP should not be required to enter      |
|           | tachment | premove survey data within 7 days of         |
|           | 4, 1.c   | pack/pickup date since that means that they  |
|           |          | would have to actually perform the premove   |
|           |          | survey earlier than within 7 days of the     |
|           |          | pack/pickup date. On short fuse shipments,   |
|           |          | this may be physically impossible. The rules |
|           |          | should state that the premove survey should  |
|           |          | be conducted in enough time to allow the TSP |
|           |          | and member to properly prepare for the       |
|           |          | shipment. In the case of a short fuse        |
|           |          | shipment, there should be no time limit      |
|           |          | imposed for the premove survey.              |
+-----------+----------+----------------------------------------------+
| IV-U.R-11 | At       | This language should be carefully clarified. |
|           | tachment | We believe it should state \"The TSP must    |
|           | 4, 1.c   | contact the member/employee within 7 days of |
|           |          | shipment booking to arrange a time to        |
|           |          | perform the survey.\" As it is currently     |
|           |          | worded, it appears to state that the premove |
|           |          | survey itself has to be performed within 7   |
|           |          | days of shipment booking and that is simply  |
|           |          | not practical nor effective, particularly    |
|           |          | when a shipment has been booked              |
|           |          | significantly in advance of the actual move  |
|           |          | dates.                                       |
+-----------+----------+----------------------------------------------+
| IV-U.R-11 | At       | This paragraph appears to conflict with the  |
|           | tachment | one just before it regarding delivery dates  |
|           | 4, 1.c   | versus delivery spread dates. The TSP should |
|           |          | have 72 hours to establish agreed upon dates |
|           |          | or spread of dates.                          |
+-----------+----------+----------------------------------------------+
| IV-U.R-11 | At       | We aren\'t sure that this requirement is     |
|           | tachment | needed any longer regarding delivery of      |
|           | 4, 1.e   | containerized shipments since the agreed     |
|           |          | upon delivery date/spread dates should       |
|           |          | determine when the shipment will be          |
|           |          | delivered to residence.                      |
+-----------+----------+----------------------------------------------+
| IV-U.R-12 | At       | The requirement to notify the PPSO of the    |
|           | tachment | residence delivery of a shipment on a        |
|           | 4, 1.g   | weekend or holiday seems unnecessary since   |
|           |          | the TSP has to notify of shipment arrival    |
|           |          | and delivery in DPS. There should be no      |
|           |          | additional notification necessary.           |
+-----------+----------+----------------------------------------------+
| IV-U.R-13 | At       | There shouldn\'t be a requirement any longer |
|           | tachment | for packing being accomplished in a manner   |
|           | 4, 5.a   | requiring the least cubic measurement since  |
|           |          | the TSP is paid for packing based on a flat  |
|           |          | fee for the weight of the shipment. The TSP  |
|           |          | should be free to use any carton sizes or    |
|           |          | dimensions that it feels will best protect   |
|           |          | the goods.                                   |
+-----------+----------+----------------------------------------------+
| IV-U.R-14 | At       | This section ends with the line \"subject to |
|           | tachment | the following:\" but there is nothing        |
|           | 4, 5.b   | following\--it goes right into the next      |
|           |          | section.                                     |
+-----------+----------+----------------------------------------------+
| IV-U.R-14 | At       | Wardrobes should be required to be used as   |
|           | tachment | needed. Some shipments may not require the   |
|           | 4, 5.c   | use of wardrobes if there are no hanging     |
|           |          | clothes.                                     |
+-----------+----------+----------------------------------------------+
| IV-U.R-15 | At       | There is no paragraph C.15 herein. The       |
|           | tachment | sections are designated as attachments 1, 2, |
|           | 4, 7     | 3 etc., so C-15 appears to be Attachment 4,  |
|           |          | paragraph 15.                                |
+-----------+----------+----------------------------------------------+
| IV-U.R-15 | At       | Split shipments should read\--the            |
|           | tachment | established RDD or agreed upon delivery date |
|           | 4, 8     | or spread of dates applies to all parts of   |
|           |          | the shipment.                                |
+-----------+----------+----------------------------------------------+
| IV-U.R-15 | At       | There shouldn\'t be a requirement to provide |
|           | tachment | a copy of the overflow inventory to the      |
|           | 4, 8     | origin PPSO. The member will be given a copy |
|           |          | of the overflow inventory but since there is |
|           |          | no requirement to provide copies of the      |
|           |          | inventory to the PPSO on most shipments,     |
|           |          | requiring a copy of the O/F inventory does   |
|           |          | not make sense.                              |
+-----------+----------+----------------------------------------------+
| IV-U.R-16 | At       | All references to the number of days for     |
|           | tachment | turning in weight tickets should say seven   |
|           | 4, 13    | business days so that there is no confusion  |
|           |          | about what the requirement is.               |
+-----------+----------+----------------------------------------------+
| IV-U.R-17 | At       | The TSP is only required to give one copy of |
|           | tachment | the Notification of Loss or Damage at        |
|           | 4,       | Delivery form to the member. This is per the |
|           | 14.b.2   | instructions on the form itself including in |
|           |          | the Business Rules as Figure U.Q.3 and per   |
|           |          | the FRV rules in the 400NG and International |
|           |          | Tariff. The wording in this section needs to |
|           |          | be changed because it says we have to leave  |
|           |          | 3 copies of this form.                       |
+-----------+----------+----------------------------------------------+
| IV-U.R-17 | At       | The TSP does not have to use the high        |
|           | tachment | risk/high value inventory form; it is their  |
|           | 4, 15.a  | option to use it or not and that may         |
|           |          | determine how claims are handled for items   |
|           |          | that are high risk or high value. On the     |
|           |          | other hand, it is not optional for the       |
|           |          | member to use the form or not. If the TSP    |
|           |          | chooses to use the form, the member is       |
|           |          | required to complete it, either listing      |
|           |          | items on it or noting \"None\" in the detail |
|           |          | section.                                     |
+-----------+----------+----------------------------------------------+
| IV-U.R-18 | At       | This section should say that the TSP is      |
|           | tachment | required to input the weight of progear in   |
|           | 4, 15.g. | DPS.                                         |
+-----------+----------+----------------------------------------------+
| IV-U.R-18 | At       | If a TSP elects to do a new inventory when   |
|           | tachment | loading out of NTS, they should not be       |
|           | 4, 15.m. | required to do an exception sheet unless     |
|           |          | there are missing or over items. The         |
|           |          | re-inventory should be cross-referenced to   |
|           |          | the original NTS inventory. The condition    |
|           |          | descriptions listed on the re-inventory will |
|           |          | show the difference in condition from the    |
|           |          | original NTS inventory. If there is no NTS   |
|           |          | inventory available, the TSP should ask for  |
|           |          | assistance from the origin PPSO to have an   |
|           |          | inspector present when loading to create a   |
|           |          | new inventory.                               |
+-----------+----------+----------------------------------------------+
| IV-U.R-19 | At       | This section should state that security      |
|           | tachment | seals are required for all containerized     |
|           | 4, 15.s. | shipments, not just international shipments. |
+-----------+----------+----------------------------------------------+
| IV-U.R-20 | At       | There should not be a requirement to make    |
|           | tachment | duplicate entries of loss/damage identified  |
|           | 4, 18    | at the time of delivery on both the          |
|           |          | inventory and the Notice of Loss or Damage   |
|           |          | at Delivery Form. All loss or damage should  |
|           |          | be required to be noted on the Notice of     |
|           |          | Loss or Damage at Delivery Form and should   |
|           |          | suffice. Anything else is unnecessary work   |
|           |          | for the member and the TSP. Also, this       |
|           |          | section should state that 1 copy of this     |
|           |          | form will be provided to the member.         |
+-----------+----------+----------------------------------------------+
| C         |          | TSP\'s should be allowed to see the          |
| ounseling |          | Counseling Business Rules since there may be |
| Business  |          | items in them that we feel need              |
| Rules     |          | clarification or correction and because it   |
|           |          | would be helpful to know how members are     |
|           |          | counseled so we know what their expectations |
|           |          | are.                                         |
+-----------+----------+----------------------------------------------+