Port of Seattle Commission Special Meeting

February

loth,

2009

Comments for Submission to the Record

Joe Rinzel, Vice President, State Government Relations

Retail Industry Leaders Association

1700 North Moore Street, Suite 2250

Arlington, Virginia 22209

703.600.2053

j oe.rinzel@rila.org

On behalf of the Retail Industry Leaders Association, I would like to express our support for

your outline for a clean truck program that ensures a reduction in truck emissions while

maintaining a healthy business climate for supply chain investments in the ports of Seattle and

Tacoma.

By way of background, the Retail Industry Leaders Association (RILA) is a national trade

association of the largest and fastest growing companies in the retail industry. Its member

companies include more than 200 retailers, product manufacturers, and service suppliers, which

together account for more than $1.4 trillion in annual sales. RILA members operate more than

100,000 stores, manufacturing facilities and distribution centers, have facilities in all 50 states,

and provide millions of jobs domestically and worldwide.

Many of our member companies are also affiliated with the Coalition for Responsible

Transportation (CRT), which is committed to being a responsible steward of the environment by

facilitating the implementation of practical and sustainable solutions that reduce port truck

pollution at our nation's blue water ports without disrupting the flow of commerce.

The Coalition for Responsible Transportation was formed in 2007 as a cooperative effort to work

with industry stakeholders to begin to provide an intelligent, industry led response toward

improving air quality in and around our nation's ports. Working together we can and will build

an environmentally sound marine transportation system for the 2

1'' Century

Shippers, like

RILA's retail members, support the adoption of a rolling ban on trucks based on

the model year of the equipment without fees imposed on industry stakeholders. The

timeline

included in your outline allows transportation providers to make sound investments that maintain

both the Seattle and the Tacoma port's competitive advantage over other west coast ports.

RILA's members, who are among the largest shippers through the Port of Seattle, urge you to

continue to not include fees on industry stakeholders to fund truck replacement programs. The

ports of Los

Angeles and Long Beach will soon implement a $70/FEU fee to help fund clean

trucks. In our view, this has in part led to the movement of some discretionary cargo out of

LAILB and into other

fee fiee" ports such as Tacoma and Seattle.

Mandatory fees may void investments shippers, carriers and

drayage providers have already

made to purchase fleets of expensive clean burning harbor trucks. We hope you will chose to

rely on industry to identify the most cost effective investments available to comply with the

standards you set.

We urge you not to include unnecessary provisions unrelated to the commission's goals and that

would result in added costs to doing business through Seattle and Tacoma marine terminals.

Already, the Intermodal Carrier Conference of the American Trucking Association 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 force hard working small business owners out of the market while

doing nothing to directly reduce truck emissions

Taking an industry friendly approach is good for business in SeattleITacoma. The more

SeaTac's is able to differentiate itself from the ports of Southern California by working together

with willing industry partners, the more it will position itself as a preferential gateway

which

benefits everyone tied to the port economy including the truckers and drivers we have heard

from today.

Many independent owner operators, such as those here today, make a good living and run

successful small businesses, the backbone of the American economy. Independent operators

can, will, and have deployed clean equipment without needing the port to get into the truck

financing business or to impose any fees or employee mandates. Many of

RILA's members

have negotiated rates at the ports of LA and Long Beach with their individual trucking providers

that allow for the purchase of new, clean equipment that is totally privately funded.

In these tough economic times it is extremely important to approach worthy environmental

mitigation issues such as this one with careful consideration for unintended consequences. We

must work together to avoid the problems encountered by some of your southern neighbors.

Working in collaboration, we can ensure that we address the shared goal of reducing carbon

emissions around the ports while protecting the businesses and good jobs affiliated with the

port's operations.

I would like to

thank you for allowing me to share the Retail Industry Leaders Association's

views concerning a way forward to reduce truck emissions. Once again, RILA supports 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 industry stakeholders will find the most

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