September 14, 1998


To: The Secretary,
 Washington Utilities and Transportation Commission
 

In the     }
Matter Of    } Docket No. TV-971477
Household Goods Carriers  }
Rulemaking    }



Comments of Edward Mitchell


Table of Contents
1. ABSTRACT 2
2. BACKGROUND 3
3. CORRUPTION IN THE HOUSEHOLD GOODS CARRIER INDUSTRY 6
3.1. The Industry Slogan: “We Don’t Care” 9
3.2. “It’s Basically Like a Lottery” 10
3.3. Theft and Pilferage 11
3.4. Using Anonymous Workers to Eliminate Accountability 13
3.5. Police Enforcement is almost Non-Existent 15
3.6. Pilferage is Just a Tip to the Hired Help 16
3.7. The “Inventory Game” 17
3.8. “Classic” Fraud 19
3.9. Making The Industry Accountable 20
3.10. The Problems 21
3.11. Solutions and Innovations Created By Market Forces 22
3.12. Government Regulation and Consumer Information 26
3.13. Summary 28
4. SPECIFIC COMMENTS ON DOCKET NO. TV 971477 29
4.1. WAC 480-15-210 (3) 30
4.2. WAC 480-15-480 Annual Reports and Regulatory Fees 31
4.3. WAC 480-15-490 Tariff and Rates, General 33
4.4. WAC 480-15-620 What Information must I provide to each shipper? 34
4.5. WUTC Should Include Its Internet URL 34
4.6. WAC 480-15-480 Annual Reports and Regulatory Fees 35
4.7. The Consumer Guide Booklet 35
5. CONCLUSION 38



 1. Abstract
 The household goods carrier industry in the State of Washington is a cartel 
that is immune to the competitive market forces that shape most industries.  
Under the present rules, carriers lack incentives to improve service, quality, 
reliability, productivity and efficiency, to reduce costs and to reduce losses 
due to theft, pilferage and damage. As reported in the literature, the 
household goods carrier industry is rife with poor customer service, 
corruption, fraud and a high incidence of theft, pilferage and damage to 
consumer’s property.  Innovation in the industry is non-existent. However, by 
making simple rules changes, including eliminating unnecessary restrictions, 
the WUTC could foster a competitive market environment that unleashes and 
rewards carriers that innovate and improv