WATERFRON

[~~x---l

,Port

Commission

w&d

April 1,2009

Tay Yoshitani

Chief Executive Officer

Port of Seattle

271 1 Alaskan Way

Seattle, WA 98121

Dear Tay:

On behalf of the Waterfiont Coalition, I would like to express our support for

your concept to address

drayage truck emissions in the port of Seattle. 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

Waterfiont 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

inotor carriers deploy clean burning drayage equipment.

We support the outline that Port of Seattle 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

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

1707

St. NW

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(202) 861

0825

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levied on shippers to help fund the replacement of all harbor trucks. 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 may 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 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.

I 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 Seattle 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.

would welcome any questions or comments and

can be reached at (202) 861

0825.

Sincerely,

Robin

Lanier

Executive Director