www.peninsulatruck.com ____________________________________________________________________________ May 5, 2015 Tim Vander Pol Peninsula Truck Lines, Inc. 1010 S 336th St, Suite 202 Federal Way, WA 98003 William F. Mascaro 1001 North Fairfax Street, Suite 600 Alexandria, VA 22314-1798 Re: Household Goods - Docket 2015-1, Subject 1—Deferred Subject Dear Bill, Peninsula Truck Lines, Inc. opposes the proposal on household good and personal effects for the following reasons:

a) There is no way to ascertain the condition of the goods when they are shipped in the appropriate packaging. These items are by definition used and in varying conditions. Carriers will be left to argue with customers about both the condition of the goods prior to shipping and the value of used goods, which has no definitive answer. This will lead to more disputes, more time spent by carrier personnel dealing with the ambiguity and worse customer experiences based on the changed expectations.

b) If people want to ship antique furnishing of their relatives, we let customers know that we don’t ship antiques but that they can ship them as personal effects with the $0.10 per pound release value. Customers know that they are solely responsible for the packaging of the articles and have no expectation of compensation if their packaging was insufficient.

The realignment of the class with the average density is not worth the loss of the release value and the confusion it would cause with customers. We request that you maintain the release value on this item. It might be appropriate to take the opposite approach of high liability goods and reduce the class to 125 from the proposed class 150 for the released value. Sincerely,

Tim Vander Pol V.P. Pricing and Administration Peninsula Truck Lines, Inc.

1010 S 336th, Suite 202 Federal Way, WA 98003

Office: 253-929-2048 Fax: 253-929-2009

Toll Free: 1-800-942-9909

From: William Mascaro Sent: Thursday, March 12, 2015 12:57 PM To: 'Rick Schweitzer' Cc: Joel Ringer Subject: CCSB Docket 2015-1, Subject 1 - Household Goods, Personal Effects or Military Baggage Mr. Schweitzer, As the CCSB member assigned to the household goods proposal, I wanted to follow-up with you regarding the email correspondence between yourself and CCSB Chairman Joel Ringer on January 30, 2015 on the above referenced docket proposal. While we were unable to meet and discuss the transportation characteristics of household goods prior to the American Moving and Storage Association’s meeting the week of February 8-11, 2015, the CCSB is still interested in any information regarding the transportation characteristics of these products that the AMSA might be able to submit. As a deferred proposal, this matter will be listed in Section II of CCSB Docket 2015-2, which is scheduled to be issued on April 30, 2015. A notification of the proposal will be mailed to you and other Parties of Record at that time. Matters listed in CCSB Docket 2015-2 will be considered at a public meeting scheduled for June 2, 2015 in Arlington, Virginia. Regards, William Mascaro Member, Commodity Classification Standards Board 1001 N. Fairfax St., Suite 600 Alexandria, VA 22314 703-838-1834

From: William Mascaro Sent: Thursday, February 26, 2015 11:37 AM To: 'Steve Stutts' Subject: RE: DOCKET 2015-1, SUBJECT 1 - HOUSEHOLD GOODS, INCLUDING PERSONAL EFFECTS OR MILITARY BAGGAGE Mr. Stutts, Thank you for your interest in CCSB Docket 2015-1, Subject 1 involving household goods. In view of your interest, we will add you as a Party of Record to the proposal. As a Party of Record, you will be notified by U.S. mail of the particulars regarding the CCSB meeting at which this matter will be acted on. That meeting is currently scheduled for June 2, 2015 in Arlington, Virginia. Your email will be added to the Public Docket File for Subject 1 of Docket 2015-1 and will be considered by the CCSB along with the other material contained therein. Following the meeting, a notice will be mailed to you detailing what action, if any, was taken. In order to ensure delivery of the materials, it would be appreciated if you could provide me with your mailing address. In the meantime, should you have any questions regarding this proposal, or the CCSB’s procedures in general, please feel free to contact me. Best regards, William Mascaro Member, Commodity Classification Standards Board 1001 N. Fairfax St., Suite 600 Alexandria, VA 22314 703-838-1834 From: Steve Stutts [mailto:nsloprez@gmail.com] Sent: Wednesday, February 25, 2015 1:46 PM To: William Mascaro Subject: DOCKET 2015-1, SUBJECT 1 - HOUSEHOLD GOODS, INCLUDING PERSONAL EFFECTS OR MILITARY BAGGAGE

Mr. Mascaro, As an interested party concerning the ultimate disposition on the above mentioned subject, I wanted to voice my thoughts as early in the process as possible. My company, North & South Logistics, Inc, has worked with the moving companies over the last ten years on their linehaul of crated household shipments. We act as a broker to facilitate the timely pickup and delivery of the crates that typically are about 3 pcs. Although I don't take issue with the data that was presented related to the density, I do believe the release value is probably where it should remain. The reason being that the movers have a solid handle

on how they manage their risk based on the current scenario. Changing that dynamic would present the linehaul carriers with a unnecessary level of claims that I don't think they want entertain. Currently, the $.10/lb release value, although most probably very understated, serves as a buffer for the carriers not to have claims filed against them. It appears to me to be a win-win. It is my opinion, and I believe shared by many, that forcing the liability higher would price the HHGs shipper out of that mode of transportation and for no compelling reason. If density is the issue, I believe it prudent to follow that course, as a lot of carriers have already done. But, I would hope that the release value change be taken off the table. Regards, Steve Stutts President North & South Logistics, Inc. 336-877-5870 919-882-1002 fax www.nsloltl.com <nsloprez@gmail.com>

From: Joel Ringer Sent: Friday, January 30, 2015 2:55 PM To: 'Richard Schweitzer' Cc: 'Michael, Scott'; William Mascaro Subject: RE: CCSB Docket 2015-1, Subject 1 - Household Goods, Personal Effects or Military Baggage Rick, The issues you raise are, for the most part, addressed in the proposal analysis and addendum, which are available for review in the public docket file on our website. If there is not to be an exchange of information or views relating to the transportation characteristics of household goods, personal effects or military baggage, or how you believe the proposal is at odds with applicable law, I’m not sure that a meeting at this time would accomplish much. Joel Joel L. Ringer Chairman Commodity Classification Standards Board 1001 North Fairfax Street, Suite 600 Alexandria, Virginia 22314 703.838.1826 ringer@nmfta.org From: Richard Schweitzer [mailto:rpschweitzer@rpslegal.com] Sent: Friday, January 30, 2015 12:58 PM To: Joel Ringer Cc: 'Michael, Scott'; William Mascaro Subject: RE: CCSB Docket 2015-1, Subject 1 - Household Goods, Personal Effects or Military Baggage Joel— Thank you agreeing to defer consideration of the proposal. Scott Michael and I will be pleased to meet with you on Thursday, February 5 at your offices at 10:00 a.m. But we are not yet prepared to provide additional information on density, handling, stowability and liability. We hope to develop more information on those issues as part of our review by the AMSA Legal Advisory Council. Instead, on February 5, we would like to discuss the origins and objectives of this proposal. Who proposed this change, what analysis went into the research project, and what the CCSB intends to accomplish with the proposed change. That discussion will give AMSA more context in which to comment on the specifics at a later date. Please let me know if you think that type of meeting would be fruitful from your end. Thanks, Rick Schweitzer

Richard P. Schweitzer, PLLC 1776 K Street, N.W. Suite 800 Washington, D.C. 20006 (202) 223-3040 phone (202) 223-3041 fax www.rpslegal.com From: Joel Ringer [mailto:Joel.Ringer@nmfta.org] Sent: Friday, January 30, 2015 11:53 AM To: Rick Schweitzer Cc: Michael, Scott; William Mascaro Subject: CCSB Docket 2015-1, Subject 1 - Household Goods, Personal Effects or Military Baggage

Rick, At our public meeting on Tuesday, January 27, 2015, the CCSB voted to defer disposition of Docket 2015-1, Subject 1, Household Goods, Personal Effects or Military Baggage, to our next public meeting on June 1, 2015. As a party of record to the proposal, you will be receiving a Notice of Disposition (Disposition Bulletin 1333) in the mail. The Notice is already posted on our website in the public docket file. Here is the link: http://www.nmfta.org/Dockets/Docket%202015-1/2015_1_Disposition.pdf In requesting deferral, you stated that you and Scott Michael of the American Moving and Storage Association would like to meet with me, CCSB staff and counsel to discuss the proposal, preferably before AMSA’s upcoming meeting on February 8-11. In checking our respective calendars, we find that we are available to meet with you and Mr. Michael next Thursday, February 5. If convenient, we could meet at the CCSB’s/NMFTA’s offices at 10:00 am. Central to our discussion should be the transportation characteristics — density, handling, stowability and liability — of household goods, personal effects or military baggage. You indicated that the proposal “would conflict with existing law and industry practice on liability,” and we would certainly want to discuss that issue. Please let me know if you and Mr. Michael will be able to meet with us next Thursday. Regards, Joel Joel L. Ringer Chairman Commodity Classification Standards Board 1001 North Fairfax Street, Suite 600 Alexandria, Virginia 22314 703.838.1826 ringer@nmfta.org