black youth. The household goods moving industry in particular is an ideal mechanism for serious address to this problem. Jobs as packers, warehousemen, helpers and drivers do not require. formal education, and potential employees can be easily trained. Each agent of Allstates will create a local job cluster of clerks secretaries, drivers, helpers, warehousemen, sales people and managers. Compared to many business development efforts which require significant capital, a local household goods moving company is labor intensive, providing a large number and variety

of jobs for the investment involved.

For these reasons, the NAACP believes that Allstates Transworld Van Lines, Inc. effort can provide immediate and discernable benefit.

C. End to illegal or "grey" trucking

Without access to the financial stability of interstate markets of a large carrier, many local moving companies that do serve inner city areas are uninsured or under-insured; they may operate interstate without a certificate; they may lack recources to fulfill their honestly made promises of service. These are problems for the involved trucker, but they are also problems for the consumer forced to rely on these Allstates, as the carrier responsible for the acts of its agents will be able to assure that a dequate insurance is carried, that each opersation is run in a business-like manner, and that the public--no matter where it is located--is served.


VI. NAACP Support not Based Solely on Race

NAACP is aware of the Commission's decisions that the race of an applicant is not relevant factor in an operating rights case, except where it relates to a special ability to provide service. While we disagree with that policy, we do not think the limits imposed by the Commission are relevant here.

The concern of the NAACP is with the service provided to black people and the representative pa rticipation of local black truckers in the household goods industry. That the owner of Allstates Transworld Van Lines is black is not critical to our support.

During peak months in the industry, apparently all people experience service problems and lack of service. Black people in the inner cities receive even less service. The Interstate Commerce Commission has expressed its concern with problems industry-wide. The NAACP is concerned with the adequacy of service to black people and other minorities, So long as the major van lines, the reputalbe companies most able to provide service, do not serve inner city, black neighborhoods, and hire very few or no black agents to serve these areas, there is a need for carriers who will serve our people and who will associate themselves with others willing to serve..

Allstates Transworld Van Lines, Inc. has indicated that it will serve this need. The Company has gathered a group of potential agents who apparently are serving inner city neighborhoods now but are limited in the service they can provide by lack of interstate rights. The NAACP supports Allstates for that reason. The fact that the owner of Allstates is black and is

presently serving low incore, black neighborhoods, only lends credibility to his promise to us and to the public.

VII. Conclusion

The NAACP understands that this Commision's original decosion to deny the application of Allstates was that there was "no need for the firm's services". By implication this finding meant that the Commision concauded that some 23 million black Americans were being adequately served by exising carriers. This is not the fact. It is not the fact for the reasons which have been outlined in this presentation, and for the further reason that there still exists in our so ciety some of the vestiges and constraints of racism whether we like it or not.



As a duly constituted regulatory agency of the Federal, Government bearing primary responsibility for the enforcement of federal regula tions rela ting to the dynamic transportation industry, it is imperative that the peculiar difficulties faced by the public in urban, minority communities be faced realistically and forthrightly.

On March 27, 1978, the President of the United States delivered his message to Congress on a comprehensive National Urban Policy. The thrust of that policy as states was "to build a New Partnership involving all levels of government, the private sector, and neighborhood and voluntary organizations in a major effort to make America's cities better places in which to live and work."

Two of the principles by which this New Partnership will be guided, stated President Carter, were, first, that of "being flexible enough to give help where it is most needed and to

respond to the particular needs of each community", and second "increasing access to opportunity for those disadvantaged by economic circumstances or history of discrimination”.

As a governmental, regulatory a gency, the Interstate Commerce Commission, in the public interest, and in furthe rance of stated public policy, has a duty and responsibility to re cognize that there is a major portion of the public in the minority community which is inadequately served by present car riers, and favorable consideration should be given to applicant; Allstates Transworld Van Lines, Inc., and its plans and capability to address this need.

Respectfully su bmitted,



Margaret Bush Wilson,
Chairman of the Board





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