IAM Visit to SDDC – February 18
By Chuck White, IAM's Senior Vice President
Last Thursday, February 18, Terry Head, IAM President, Peg Wilken, IAM Chairperson, Tim Helenthal, IAM Vice-Chair and I met with SDDC staff at their offices at Scott AFB. Present from SDDC was the full Personal Property Directorate leadership team, Lt Col Todd Jensen, SDDC Director of Personal Property, Danny Martinez, Personal Property Business Processes Division Chief, Jill Smith, Chief, Personal Property Systems Integration Division, David Jones and Rose Lindsey.
We provided a very aggressive list of agenda items that included over 20 topics. We understood it would be next to impossible to cover all of those items, as well as agenda items that Lt Col Jensen had asked to cover, during the face to face time we had with them but we wanted them to at least see ALL of the issues IAM is currently focused on.
We started with the U.S. Transportation Command’s (USTC) “HHG Channeling Concept Pilot”. That initiative had been put on hold a few months ago but coincidentally USTC issued a follow up to their original Federal Register Notice (FRN) the day of our meeting with SDDC. Essentially the FRN that indicated USTC/SDDC would NOT be moving forward on the initiative. See the exact wording below. This is a huge win for the industry. IAM championed the fight against this initiative through its direct communication with USTC and SDDC leadership, congressional interaction and consultation with legal representation. Though it was a drawn out process our efforts proved successful. SDDC will now focus on moving DP3 and DPS to its planned FOC (Full Operating Capability).
SUMMARY: The DoD is not proceeding with the proposed Defense Personal Property Program (DP3) Household Goods Channeling Pilot Test, as set forth in the September 8, 2015 notice.
We received an update on the 2016 rate filing…..After a number of glitches and stops and starts to Round 2, it appears the rate filing will close today, Monday February 22. On Thursday there were still 14 TSPs with small issues that needed to be fixed but SDDC had reached out to them each individually and felt they could get them updated in time to finally close the rate filing on the 22nd. TSPs should soon see SDDC messaging regarding when the new Traffic Distribution Lists (TDL) for the May 15 Performance Period will be available and when Peak Season shipment bookings will begin.
We also learned that SDDC has announced that MG Susan Davidson, Commander SDDC will be leaving. She will be headed to Hawaii to take over as the Commanding General, 8th Theater Sustainment Command, Fort Shafter, Hawaii. No timeframe for the move has been announced and no replacement has yet been named.
Much of the early discussion focused on a number of 2016 Solicitation items that have raised a great deal of concern within industry:
- New re-weigh item (Item 505 in the IT-16) – huge issues stem from this item; particularly as they relate to crated HHG shipments but also having significant consequences for Domestic van shipments as well. I think most fully understand the issue so I will not go over the specifics but we spent a significant amount of time going over the issues with the SDDC staff. We had already articulated the issue a number of times via email but once again laid out all of over concerns as they relate to the operational issues and the payment/cash flow ramifications.
SDDC agreed to go back and review the wording again and I am very hopefully that we will see some revised language sometime before the May 15 implementation date. I also followed up with SDDC staff reiterating our position….again….the day following the meeting.
- Crating item (IT Item 508) – Once again we reviewed our concerns with these aspects of Item 508:
- The new restrictive guidelines for crate size, 3 inches on all sides for internal crates and 5 inches for external crates. We feel these are too restrictive, particularly with regards to external crates.
- All crating/uncrating must be done at residence – we raised a number of operational issues that may prohibit the ability of these services being done at residence, e.g. crating a motorcycle at residence and then being able to load a huge, heavy crate onto a truck.
- Disallowing the crating “for items that can stand alone”. We asked how we should operationally handle items like 3-wheelers, ATVs, etc that are not crated but must move in a Code 4 shipment? No concrete answers to this.
- The following new language in the new IT is obviously incorrect and must be changed. It makes no sense – “Regardless of the actual crate size, TSP’s must bill either the actual cubic feet of the item, or the cubic feet limitation listed in Billing Note 5 above, whichever is less.”
- Members must keep crates for future use or crating may not be allowed for the same item in the future….where do they keep it? What if they refuse? Should the TSP be held responsible/liable if a member no longer has the crate?
- Why are crated domestic shipments treated differently than international HHG shipments? Why is crating for the exact same items not allowed in the Code 2 program that are crated in the Code 4 arena? SDDC did indicate they would take a second look at this.
- This is a huge item that SDDC staff indicated they would also take under advisement.
- Item 401 – IAM asked that this item, which had been found in the 400NG for several years be added to the IT. The problem is that it was added but the wording was amended without consultation with industry. The wording now indicates that:
TSP will not accept the following:
1) HHGs, which are jointly (Government and TSP) determined to be in a condition that makes it liable to impregnate, contaminate, or otherwise cause damage to other HHGs or equipment.
“Jointly” is the key word that has been added. We are concerned that TSPs will be forced to move items/shipments that have been contaminated, i.e. moldy, if the PPSO personnel do not agree and TSPs will be forced to move these items and accept liability. We have already addressed the issue with the Military Claims Offices (MCOs) and will be setting up future communications between ALL three parties (industry, MCOs & SDDC).
Refusals – A very long and drawn out conversation took place regarding the possibility of reinstituting the ability for industry to refuse shipments during the Peak Season. SDDC believes that, at least for the 2016 Peak Season, NO refusals will be allowed. Tim Helenthal in particular made a very strong case for the need to rethink this policy. He pointed to the loss of capacity for DOD, the addition of the SCR 6975 to DPS, the lack of the needed Blackout granularity (destination CONUS Blackout and greater OCONUS Blackout granularity) and other issues as reason for reinstituting refusals. Lt Col Jensen indicated that SDDC would continue to review the policy and its secondary and tertiary effects but at least for 2016 the lack of the ability to refuse shipments would remain in place.
Click counts/DPS Lockout- Suspensions – This has become a huge issue as more and more TSPs are having log-in/digital certificates locked out of DPS. This has happened for perceived over clicking in the short fuse queue but also in other modules as well. A recent event in January saw 5-6 TSPs have accounts locked out of DPS completely for over clicking in the invoicing module. SDDC indicated that the accounts were clicking as many as 350,000 – 500,000 times per hour. These are numbers that seem outrageous. The instances occurred on a Sunday when no personnel were in place at those TSPs. What possible reason could there be for over clicking to that degree in the invoicing module? At first SDDC & Transcom looked at this as a “denial of service” attack, i.e. HACKERS, going after the system to bring it down. They seem to be backing away from that theory.
But SDDC/Transcom continue to see this as an industry issue, either via a TSP webbot or some type of hacking of a TSP’s system from the outside. After consultation with a number of sources we believe this is an internal DPS/ETA issue and not an industry problem. We are hoping to engage the key stakeholders (SDDC, Transcom, DPS PMO, CACI and DISA) at another face to face meeting at Scott AFB in the near future. This seems to oversight run amuck! The fingers always seem to point at industry and their webbots as the root of the problem. However, IAM feels that SDDC/Transcom need to look at its own systems for the answers to why these issues continue to occur.
We had hoped to get to other issues. We spent nearly three hours with the SDDC staffers but that was just not enough to get through our entire agenda. We will continue to dialog with SDDC on all of the other issues not covered during this meeting….and there are many as most of you realize.
Now only time will tell how SDDC deals with our most pressing issues particularly as they relate to the 2016 Solicitation items.