¨ The DoD program is still bundled both in terms of services and geographical requirements. This will eliminate a number of the small quality movers.

¨ The DoD program in no way reflects commercial business practices.

¨ The program continues the practice of paper companies by putting control of DoD's entire HHG program into the hands of the 3rd party broker. The 3rd party broker has no real resources such as trucks, lift vans, warehouses, agent family networks. The 3rd party broker takes a cut off the top and passes off the shipment to a subcontractor. DoD receives nothing for the increase cost for use of the third party broker.

¨ The program requires the transportation provider to pay a commission to the broker regardless if the military member uses these services. If DoD wants these services, they should contract for them separately and not force the moving industry to pay the third party broker

¨ The program sets forth that the third party broker settle the claims. This puts another level of bureaucracy between the group who actually moves the member and the service member. The transportation provider should be the one to settle claims not the third party broker who has no stake in the process financial or otherwise. This process increases the likelihood the third party broker would "BUY" customer satisfaction by paying off bogus claims and then charging them back to the transportation provider.

¨ The FSMP proposed claims settlement process is worse than the present-day DoD program for two reasons. In the present program, at least DoD, as the public servant, has the responsibility to be fiscally prudent to settle claims. Also in the present program, even though DoD is settling claims and surbrogates against the carrier, it is at reduced liability, not full replacement value as in the DoD proposal. It makes no sense to have someone other than the one physically transporting the goods to settle claims. This is like giving a third party broker a blank check to spend your money. What other industry allows DoD to do this?

¨ This proposal fails to utilize objective, measurable criteria that the 3rd party broker would use to select the carrier. Criteria should be developed using scoring and pricing grids to ensure that only qualified and competitive carriers can participate. Further, there must be a definite separation between the 3rd party broker and the carrier selection process to avoid a huge potential for abuse. Obviously, this proposal must address the possibility that the 3rd party broker could reward and/or punish various carriers without regard to the real best value to DoD.