February 9,2009

Commissioner Bill Bryant

President

Port Commission of Seattle

271 1 Alaskan Way

Seattle, WA 98 12 1

Dear Commissioner Bryant:

On behalf of the Waterfront Coalition,

would like to express our support for

your concept to address

drayage truck emissions in the ports of Seattle and Tacoma. As

you move forward jointly with your truck emission program, we would urge you to adopt

emission standards that are within the ports' jurisdiction. We would also urge you not to

consider fees levied on shippers or other industry stakeholders to fund a truck

replacement or retrofit program. Finally, we would also urge you not to consider

additional provisions regulating the

drayage industry in your region that do not directly

address truck emissions.

By way of background, the Waterfront Coalition represents manufacturers, retailers,

agricultural producers and transportation providers moving international commerce

through North American blue water ports including the ports of Seattle and Tacoma. Our

members understand the need to reduce drayage truck emissions in the Pacific Northwest

and throughout the nation. Many of our members participate in broad based industry

efforts, such as the Coalition for Responsible Transportation, to ensure that licensed

motor carriers deploy clean burning

drayage equipment.

We support the outline that Port of Seattle and Tacoma staff presented to us concerning

broad initiatives to reduce

drayage truck emissions in the region. The Waterfront

Coalition supports the adoption of a rolling ban on trucks based on the model year of the

equipment without fees imposed on industry stakeholders. This policy allows

drayage

providers to identify the most efficient investment decision to comply with the rule while

preserving the competitive advantage marine terminals maintain in the region. The

outline of your truck plan would also keep both ports out of managing

drayage

operations.

In our view, it is important that your truck plan remain devoid of fees to fund truck

replacement or retrofit technology. As you may be aware, the Clean Truck Program as

1707

St. NW

Suite 570

Washington,

20036

(

(202) 861

0825

(

www.portmod.org

endorsed by both the ports of L.A. and Long Beach includes a $70 container (FEU) fee

levied on shippers to help fund the replacement of all harbor trucks. That fee is

scheduled to be collected beginning on February

8th. This fee has been in part

responsible for a recent diversion of discretionary cargo to load centers outside of

.the San

Pedro Bay including the ports of Seattle and Tacoma. Similar fees adopted in

Seattle-

Tacoma area mat erode this competitive advantage currently enjoyed in the region.

Such fees also have the potential to void investments motor carriers and others have put

into clean burning equipment. Many of our shipper, carrier and

drayage members are

collaborating on business models to ensure that truckers have access to clean burning

equipment. These investments in green technology result in higher dray rates paid by

shippers and ocean carriers. Mandatory fees imposed on industry stakeholders to fund

truck replacement or retrofit equipment may undermine these voluntary investments and

weaken the business investment climate in the region.

As you and your staff develop your truck plan, we would also encourage you not to

include provisions that do not directly address truck emission reductions. Such ancillary

policies may result in added costs to doing business through Seattle and Tacoma marine

terminals that could contribute to a diversion of cargo and tie the ports into lengthy and

costly litigation. Already, the Intermodal Carrier Conference of the American Trucking

Associations has filed suit against both the ports of L.A. and Long Beach for including a

truck concession requirement in their Clean Truck Program designed to restructure the

size and nature of the harbor

drayage industry. These provisions do nothing to directly

reduce truck emissions, while forcing out of the industry many hardworking small

business owners and contributing to a poor business climate to guarantee future supply

chain investments.

would like to thank you for allowing our group to share our views concerning a way

forward to reduce truck emissions. Once again, we support your concept of

implementing a rolling ban based on the age of the truck applicable to both Seattle and

Tacoma marine terminals. We are confident that our industry partners will find the most

efficient means of complying with the rule so as to maintain the region's competitive

advantage.

Please consider the Waterfront Coalition a resource as you roll out your truck program. I

would welcome any questions or comments and I can be reached at (202) 861

0825.

Sincerely,

Robin Lanier

Executive Director