Best Buy

California

Multimodal, LLC

Container

Connection

Converse

Dunavant

Enterprises

Gap

Inc.

Green Fleet

Systems

GSC Logistics

Hanjin Shipping

The Home Depot

Intermodal Bridge

Transport

JC Penney

"K"

Line America

Lowe's

Nike

NYK Group

Companies

PDS Trucking

Performance Team

Southern Counties

Express

Target

Total

Transportation

Services, lnc.

March 30,2009

President Bill Bryant

Port Commission of Seattle

Alaskan Way

Seattle, WA 98 12 1

Dear Commissioner Bryant:

Meeting

h~,

i-"-/

We are writing you today to express the Coalition for Responsible Transportation's

(CRT's) support for the proposed Port of Seattle Clean Truck Program that will be

considered by the Commission on March 3 1,2009.

First and foremost, the Port of Seattle is to be commended for the superb job that Port

staff have done in facilitating a meaningful dialog with Port stakeholders, and for

distilling the myriad suggestions from those stakeholders into what we believe is a

prudent and viable framework for dramatically reducing port

related air emissions from

the

drayage truck fleet that serves your Port. We appreciate the outreach that has been

conducted by your staff and for the opportunity to provide input and insight on behalf

of our membership, which includes importers, exporters,

drayage providers, ocean

carriers and terminal operators.

CRT was formed in 2007 to facilitate the implementation of practical and sustainable

solutions to reduce port truck pollution at our nation's blue water ports in a manner that

balances the environmental needs of Port communities with the efficient flow of

commerce. CRT member companies are committed to responsible stewardship of the

environment and to taking leadership roles within their respective industries in the

development of transportation related environmental initiatives. In 2008, CRT member

companies were responsible for roughly

million TEUs of cargo volume transiting

through West Coast ports and have deployed over 1,000 clean trucks to support that

cargo.

CRT was founded on the principle

.that private enterprise should partner with port

leadership to bring clean truck technology to local ports, and we believe that the

proposed Clean Truck Program is consistent with that principle.

CRT supports the Port of Seattle CTP framework as it has been presented to us because

it strikes the delicate balance of improving the air quality in

the Georgia Basin

Puget

Sound region without adversely impacting the flow of commerce through the Port.

Specifically, CRT applauds the port for:

Setting hard targets for emission reduction goals through implementation of an

aggressive

timeline for the phase

out of high polluting diesel trucks servicing

Wal

Mart Stores

1415 L Street, Sacramento, CA 95814

(916) 492

2766

www.responsibletrans.org

the Port. This timeline will ensure that quantifiable air quality benefits are met

while allowing private industry a reasonable amount of time to procure

compliant equipment.

Taking a technology

neutral approach to air quality goals, which will allow

CRT members to deploy a variety of clean

air equipment, whether clean diesel,

LNG,

or even electric technology, in a manner that is most cost effective for

their individual business models.

Choosing not to disenfranchise independent owner operator (100) drivers.

CRT member companies utilize both employee drivers and

100s according to

their individual needs and the needs of their customers. By preserving the

flexibility to use both employees and

100s to meet the clean air goals of the

Port, you will have adopted a model that will provide for the fastest and most

cost

effective way to deploy clean equipment at the Port.

Avoiding the creation of a port

administered drayage management system and

the imposition of container fees to support such a regulatory regime. The

decision not to implement container fees in conjunction with Seattle's CTP will

have a profound impact on Seattle's competitive position with regard to other

ports on the West Coast of the United States. We have already begun to see the

movement of discretionary cargo away

from Southern California due in part to

the onerous regulations and

$70

per container

(FEU)

fees that have been

implemented there. Seattle's decision to avoid similar fees will give it a

competitive advantage on the West Coast and position the Port well to attract

new cargo, which will result in additional investment in the Port that will

accelerate the deployment of clean equipment.

Calling for continued collaboration with Port stakeholders during the

implementation of the CTP. CRT looks

forward to working with the Port of

Seattle through the adoption and implementation of the CTP so that we may

provide feedback on best practices, help the Port

identi@ financing solutions to

support the retirement of older equipment, and maintain a productive dialog

geared towards maximizing the success of the CTP.

In summary, CRT supports the adoption of the Port of Seattle Clean Truck Program as

it has been presented to us, and looks forward to working in partnership with the Port of

Seattle to implement the program.

'PS

ecutive

lacy

irector